Comment #1Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: N/AComment Intent: Not an ObjectionComment Type: GeneralComment: Greetings All, I have been a HERS rater since 2004. I have made a career out of providing ESLH, HERS and IEEC code compliance. It has been great being a part of the revolution of building science. To say nothing of being a part of a solution to bring comfort and efficiency to my neighbors. I have read Addendum 30 and I belive you are heading in the right dircetion with standarizing the proceedures such as forms and expanding trianing for all of the areas of compliance. New York State recently adopted the 2015 IECC which overlaps many areas of HERS and every other above code construction program. It has been mandatory, since 10-3-2016. When this came out I spent many hours meeting with Building departments including NYC DOB where I now sit on the advisery board for their energy code. I always promote the HERS program to every community I speak at. This is easy because I belive in the proticals and procedures of RESNET are far superior to other third party inspections and testing. My work visiting these building departments has lead to expanding the HERS program throughout lower NY. state. Heres my concern, R104.4 in this section it reffers to approved third party inspection agenies." They must have NO affiliation with the building's design or construction". There are many good resaons for this, the first is obivious, "you can't rate your own work". The second is if I am allowed to inspect and pass my own work my pricing gets very agressive and this parctice leaves a true thrid party inspectors without a recourse to be competitive. Third reason, is even more outragous and the driving reason for my spending this time writing this. I have had many ocasions where the rater also owns an insulation company. He is hired to inspect his competitors work and decides to make an example of his workmanship and fails the work with the sole reason to promote his company over his competitors. Dispicable? Yes . This is not in theory, This is happening now, I need RESNET to look at this. An address this with a tighten of disclosure forms that asks the right question from your raters. The rules have been defined clearly we just need enforcment. Without them, the true party inspectors will be a thing of the past. Thanks for your time, Glenn LaMay Rater # 8644961
Greetings All,
I have been a HERS rater since 2004. I have made a career out of providing ESLH, HERS and IEEC code compliance. It has been great being a part of the revolution of building science. To say nothing of being a part of a solution to bring comfort and efficiency to my neighbors.
I have read Addendum 30 and I belive you are heading in the right dircetion with standarizing the proceedures such as forms and expanding trianing for all of the areas of compliance.
New York State recently adopted the 2015 IECC which overlaps many areas of HERS and every other above code construction program. It has been mandatory, since 10-3-2016.
When this came out I spent many hours meeting with Building departments including NYC DOB where I now sit on the advisery board for their energy code. I always promote the HERS program to every community I speak at. This is easy because I belive in the proticals and procedures of RESNET are far superior to other third party inspections and testing. My work visiting these building departments has lead to expanding the HERS program throughout lower NY. state.
Heres my concern,
R104.4 in this section it reffers to approved third party inspection agenies." They must have NO affiliation with the building's design or construction". There are many good resaons for this, the first is obivious, "you can't rate your own work". The second is if I am allowed to inspect and pass my own work my pricing gets very agressive and this parctice leaves a true thrid party inspectors without a recourse to be competitive. Third reason, is even more outragous and the driving reason for my spending this time writing this. I have had many ocasions where the rater also owns an insulation company. He is hired to inspect his competitors work and decides to make an example of his workmanship and fails the work with the sole reason to promote his company over his competitors. Dispicable? Yes .
This is not in theory, This is happening now, I need RESNET to look at this. An address this with a tighten of disclosure forms that asks the right question from your raters.
The rules have been defined clearly we just need enforcment. Without them, the true party inspectors will be a thing of the past.
Thanks for your time,
Glenn LaMay
Rater # 8644961
Comment #2Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: 9-5Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: TechnicalComment: Remote QA has shown to be a useful tool through other programs so I’m glad to see RESNET has decided to go in the same direction. My Comment is more of a clarification than an objection, however I would suggest a change made. It appears that “on site, in person” was removed to allow any portion of the 1% QA field requirement to be met through remote audits, but the second sentence in the paragraph still has the language that would suggest that remote audits cannot meet the 1% requirement, “All other.” I suggest the removal of excess verbiage to clarify. It has been previous established that all HERS raters shall have field QA in accordance with these standards via 904.3.3.1.1 and 904.3.3.1.2. Seems confusing to restate again in 904.3.3.1.5. Proposed Change: 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed.. All other Any portion of QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Remote QA has shown to be a useful tool through other programs so I’m glad to see RESNET has decided to go in the same direction. My Comment is more of a clarification than an objection, however I would suggest a change made. It appears that “on site, in person” was removed to allow any portion of the 1% QA field requirement to be met through remote audits, but the second sentence in the paragraph still has the language that would suggest that remote audits cannot meet the 1% requirement, “All other.” I suggest the removal of excess verbiage to clarify. It has been previous established that all HERS raters shall have field QA in accordance with these standards via 904.3.3.1.1 and 904.3.3.1.2. Seems confusing to restate again in 904.3.3.1.5.
904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed.. All other Any portion of QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Comment #3Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: 9-5Paragraph / Figure / Table / Note: 904.3.3.1.5 “Remote” QA Field ReviewsComment Intent: Not an ObjectionComment Type: EditorialComment: This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine. Draft PDS-02 Addendum 30 for Section 904.3.3.1.5 States the following. 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed.. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET. The term “inspections completed” is unclear whether as to what type of inspection. We propose language to clarify the inspections. Proposed Change: 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings for HERS Raters, or 1% of the annual total confirmed final field inspections completed for RFI’s. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine.
Draft PDS-02 Addendum 30 for Section 904.3.3.1.5 States the following. 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed.. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
The term “inspections completed” is unclear whether as to what type of inspection. We propose language to clarify the inspections.
904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings for HERS Raters, or 1% of the annual total confirmed final field inspections completed for RFI’s. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Comment #4Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: 9-5Paragraph / Figure / Table / Note: 904.3.3.1.5 “Remote” QA Field ReviewsComment Intent: Not an ObjectionComment Type: EditorialComment: This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 340 Raters and 11 Providers from New Jersey to Maine. Draft PDS-02 Addendum 30 for Section 904.3.3.1.5 States the following. 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed.. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET. The term “inspections completed” is unclear whether as to what type of inspection. We propose language to clarify the inspections. Proposed Change: 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive on-site, in-person QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings for HERS Raters, or 1% of the annual total confirmed final field inspections completed for RFI’s. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Comment #5Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: p18Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: GeneralComment: First, I would like to have it acknowledged that I had made comment on this section in the previous public comment period. My comment was rejected incorrectly by SDC 900 on the basis that my comment voided some mandate from the RESNET Board of Directors regarding the use of Remote QA. There is no such mandate, and as a result the rejection of my comment was incorrect. I am requesting that my full comment be taken into consideration here regardless of whether SDC 900 believes i'm commenting exclusively on the sections added/sticken. Second, the way this section is written is not clear as to the intent of the SDC 900. It could be read in two separate ways: "QA Field Reviews" only intend to mean in-person, boots on the ground, QAD physically at the house reviews, and therefore 1% QA only allows such in-person reviews; "Remote QA" can be used as a supplement. "QA Field Reviews" intend to mean any form of review - be it in-person or performed remotely - where a home is reviewed either physically on-site or virtually by a QAD. Therefore, 1% QA could be 100% completed via "Remote QA". Part of the issue is that "QA Field Review" is not defined. It is recommended to add a definition to make this clear. If the intent is that all 1% QA can be completed remotely, this is a bad policy. Remote QA is unproven, with no written standards for how to perform it and when it could not be performed. Cellular data transmission is simply not good /consistent enough to result in clean, clear imagining of a home such that a QAD can fully assess a home's attributes. This is especially the case for low-light spaces like attics, crawlspaces, etc. fine details like lighting characteristics and tight spaces like rim joists are also very difficult to assess accurately. It is simply not reasonable to allow a high percentage, let alone all 1% QA to be performed remotely. BER has tried it and it simply is not dependable. We have also observed other providers doing this, and they tend to do it in a very ramshackle, disorganized manner. It is simpy not ready for gametime. As such, i encourage SDC 900 to define QA Field Reviews as being in-person, on-site QA reviews of homes by QADs, and Remote QA can remain for other forms of additional or inteventional QA. Proposed Change: Add 904.3.3.1 QA Field Reviews 904.3.3.1.1 QA Field Reviews shall be in-person, on-site reviews of rated homes by RESNET QADs. As part of the QA Field Review process, QADs shall assess all verifiable minimum rated features and features of qualifying RESNET-approved EEPs while on-site. Any minimum rated features not verifiable by QADs during QA Field Reviews shall be documented by the rater. The QAD shall use verified and rater provided documentation to complete the provisions of 904.3.5. Edit as follows 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed. All other QA Field reviews of as-built features of rated homes for the purpose of verifying their accuracy, such as enhanced disciplinary status QA reviews or for completed and QA performed on pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
First, I would like to have it acknowledged that I had made comment on this section in the previous public comment period. My comment was rejected incorrectly by SDC 900 on the basis that my comment voided some mandate from the RESNET Board of Directors regarding the use of Remote QA. There is no such mandate, and as a result the rejection of my comment was incorrect. I am requesting that my full comment be taken into consideration here regardless of whether SDC 900 believes i'm commenting exclusively on the sections added/sticken.
Second, the way this section is written is not clear as to the intent of the SDC 900. It could be read in two separate ways:
Part of the issue is that "QA Field Review" is not defined. It is recommended to add a definition to make this clear.
If the intent is that all 1% QA can be completed remotely, this is a bad policy. Remote QA is unproven, with no written standards for how to perform it and when it could not be performed. Cellular data transmission is simply not good /consistent enough to result in clean, clear imagining of a home such that a QAD can fully assess a home's attributes. This is especially the case for low-light spaces like attics, crawlspaces, etc. fine details like lighting characteristics and tight spaces like rim joists are also very difficult to assess accurately. It is simply not reasonable to allow a high percentage, let alone all 1% QA to be performed remotely. BER has tried it and it simply is not dependable. We have also observed other providers doing this, and they tend to do it in a very ramshackle, disorganized manner. It is simpy not ready for gametime.
As such, i encourage SDC 900 to define QA Field Reviews as being in-person, on-site QA reviews of homes by QADs, and Remote QA can remain for other forms of additional or inteventional QA.
Add
904.3.3.1 QA Field Reviews
904.3.3.1.1 QA Field Reviews shall be in-person, on-site reviews of rated homes by RESNET QADs. As part of the QA Field Review process, QADs shall assess all verifiable minimum rated features and features of qualifying RESNET-approved EEPs while on-site. Any minimum rated features not verifiable by QADs during QA Field Reviews shall be documented by the rater. The QAD shall use verified and rater provided documentation to complete the provisions of 904.3.5.
Edit as follows
904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed. All other QA Field reviews of as-built features of rated homes for the purpose of verifying their accuracy, such as enhanced disciplinary status QA reviews or for completed and QA performed on pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Comment #6Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: 19Paragraph / Figure / Table / Note: 904.3.3.2.5Comment Intent: ObjectionComment Type: TechnicalComment: As per my previous comment, I would like to have it acknowledged that I had made comment on this section in the previous public comment period. My comment was rejected incorrectly by SDC 900 on the basis that my comment voided some mandate from the RESNET Board of Directors regarding the use of Remote QA. There is no such mandate, and as a result the rejection of my comment was incorrect. I am requesting that my full comment be taken into consideration here regardless of whether SDC 900 believes i'm commenting exclusively on the sections added/sticken. The way this section is written reads is that RESNET intends to allow ALL field QA to be performed Remotely. If the intent is that all 1% QA can be completed remotely, this is a bad policy. Remote QA is unproven, with no written standards for how to perform it and when it could not be performed. Cellular data transmission is simply not good /consistent enough to result in clean, clear imagining of a home such that a QAD can fully assess a home's attributes. This is especially the case for low-light spaces like attics, crawlspaces, etc. fine details like lighting characteristics and tight spaces like rim joists are also very difficult to assess accurately. It is simply not reasonable to allow a high percentage, let alone all 1% QA to be performed remotely. BER has tried it and it simply is not dependable. We have also observed other providers doing this, and they tend to do it in a very ramshackle, disorganized manner. It is simpy not ready for gametime. As such, i encourage SDC 900 to delete this section entirely. Stop trying to water down QA based on unfounded and erroneous claims that this is what the Board wants. If RESNET Staff or members of the SDC 900 have a personal bias towards allowing Remote QA (Such as SDC 900 Chair, John Hensley, who has it published on his own Providership's website that he is"... working with RESNET to promote and focus on Remote Q/A join up and we can explain" http://www.bpconsultingsolutions.com/resnet-quality-assurance-provider.php) ... then these members of SDC 900 should recuse themselves in evaluating this section, as it is entirely inappropriate that members - let alone the Chair - of SDC 900 should be proposing vast, sweeping, unsubstantiated and undocumented QA processes based on their own personal and business interests to do so. It is very clear that a smaller staffed QA Provider like Mr. Hensley's would benefit from the reduced process/time/travel burden of having to physically go on site to perform field QA. This is not an acceptable reason for such a signfiicant change, and the evidence that there is a conflict of interest in this matter regarding Mr. Hensley and his interests as a Provider, and the unsubstantiated manner in which my previous comments on this topic were falsely rejected and undermined, will force me to have to take this matter to the RESNET Standards Management Board and/or the Board of Directors if this comment is once again falsely rejected or not addressed with clear evidence that RESNET has an adequate plan to address my concerns. Proposed Change: Delete 904.3.3.2.5 Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Assurance Designee, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
As per my previous comment, I would like to have it acknowledged that I had made comment on this section in the previous public comment period. My comment was rejected incorrectly by SDC 900 on the basis that my comment voided some mandate from the RESNET Board of Directors regarding the use of Remote QA. There is no such mandate, and as a result the rejection of my comment was incorrect. I am requesting that my full comment be taken into consideration here regardless of whether SDC 900 believes i'm commenting exclusively on the sections added/sticken.
The way this section is written reads is that RESNET intends to allow ALL field QA to be performed Remotely.
As such, i encourage SDC 900 to delete this section entirely. Stop trying to water down QA based on unfounded and erroneous claims that this is what the Board wants. If RESNET Staff or members of the SDC 900 have a personal bias towards allowing Remote QA (Such as SDC 900 Chair, John Hensley, who has it published on his own Providership's website that he is"... working with RESNET to promote and focus on Remote Q/A join up and we can explain" http://www.bpconsultingsolutions.com/resnet-quality-assurance-provider.php) ... then these members of SDC 900 should recuse themselves in evaluating this section, as it is entirely inappropriate that members - let alone the Chair - of SDC 900 should be proposing vast, sweeping, unsubstantiated and undocumented QA processes based on their own personal and business interests to do so. It is very clear that a smaller staffed QA Provider like Mr. Hensley's would benefit from the reduced process/time/travel burden of having to physically go on site to perform field QA. This is not an acceptable reason for such a signfiicant change, and the evidence that there is a conflict of interest in this matter regarding Mr. Hensley and his interests as a Provider, and the unsubstantiated manner in which my previous comments on this topic were falsely rejected and undermined, will force me to have to take this matter to the RESNET Standards Management Board and/or the Board of Directors if this comment is once again falsely rejected or not addressed with clear evidence that RESNET has an adequate plan to address my concerns.
Delete
904.3.3.2.5 Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Assurance Designee, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
Comment #7Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02Page Number: 9-5Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: GeneralComment: Our organization has experimented with remote QA many times (outside of the 1%QA process) and we have concluded that it doesn't work well enough to supplant onsite, in person QA, and we are a long way off from when it will, if ever. No one has proven it works and there is no evidence that it is superior to in person QA whatsoever. Over the past several years the RESNET BOD has been embarking on a mission and adopted a policy to improve QA and consistency. Last time I checked, they have not revised this poilcy to diminish or eliminate it, which this proposed amendment language will effectively accomplish. Therefore, this amendment is in direct violation of board policy. Before this or any amendment to allow remote QA can be taken seriously by anyone, it needs to be well established and documented that it can be an effective and useful tool. Second, it needs to be established exactly how it should be performed and under what circumstances it could or should be performed and why. Simply changing a few words in the standards and opening Pandora's box to allow the lowest common denominators in this industry perform a completely untested, unproven and undefined field QA without any guidelines whatsoever will have the exact opposite effect of promoting improved QA oversight and HERS Index consistency. The path towards robust, effective field QA as we know it will be over if this makes it through the amendment process. The few players left who still believe in what we are trying to accomplish as an industry and want to do things the right way for the right reasons will simply be undercut by those who have no interest in quality assurance or playing by the rules. This will simply be a huge victory for proponents of no field QA and no industry oversight. Additionally, the language regarding field QA for RFIs needs to be cleaned up so that it is clear to anyone who read it. Based on my comments above, it only makes sense to leave the language regarding on-site field QA in place, with some minor clarification. I encourage the committee or working group that drafted this language to please take some more time to actually develop a strong case for remote QA and prove to the industry that it will actually result in an improved and enhanced process and outcome. Otherwise, this is simply an irresponsible and ill advised attempt to try to sneak this into the standards and undermine the BOD's policy to enhance consistency and quality. Proposed Change: 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters must annually receive a minimum of one (1) on-site, in-person QA Field reviews on a minimum of one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed. All RFI’s must annually receive on-site, in-person QA Field reviews on a minimum of one percent (1%) of the annual total of inspections completed for confirmed or sampled ratings. All other non-1% QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Our organization has experimented with remote QA many times (outside of the 1%QA process) and we have concluded that it doesn't work well enough to supplant onsite, in person QA, and we are a long way off from when it will, if ever. No one has proven it works and there is no evidence that it is superior to in person QA whatsoever. Over the past several years the RESNET BOD has been embarking on a mission and adopted a policy to improve QA and consistency. Last time I checked, they have not revised this poilcy to diminish or eliminate it, which this proposed amendment language will effectively accomplish. Therefore, this amendment is in direct violation of board policy.
Before this or any amendment to allow remote QA can be taken seriously by anyone, it needs to be well established and documented that it can be an effective and useful tool. Second, it needs to be established exactly how it should be performed and under what circumstances it could or should be performed and why. Simply changing a few words in the standards and opening Pandora's box to allow the lowest common denominators in this industry perform a completely untested, unproven and undefined field QA without any guidelines whatsoever will have the exact opposite effect of promoting improved QA oversight and HERS Index consistency. The path towards robust, effective field QA as we know it will be over if this makes it through the amendment process. The few players left who still believe in what we are trying to accomplish as an industry and want to do things the right way for the right reasons will simply be undercut by those who have no interest in quality assurance or playing by the rules. This will simply be a huge victory for proponents of no field QA and no industry oversight.
Additionally, the language regarding field QA for RFIs needs to be cleaned up so that it is clear to anyone who read it.
Based on my comments above, it only makes sense to leave the language regarding on-site field QA in place, with some minor clarification. I encourage the committee or working group that drafted this language to please take some more time to actually develop a strong case for remote QA and prove to the industry that it will actually result in an improved and enhanced process and outcome. Otherwise, this is simply an irresponsible and ill advised attempt to try to sneak this into the standards and undermine the BOD's policy to enhance consistency and quality.
904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters must annually receive a minimum of one (1) on-site, in-person QA Field reviews on a minimum of one percent (1%) of the annual total of confirmed or sampled ratings or inspections completed. All RFI’s must annually receive on-site, in-person QA Field reviews on a minimum of one percent (1%) of the annual total of inspections completed for confirmed or sampled ratings. All other non-1% QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Return to Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-02