Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01

Comment #1

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Requiring on-site photos is a step in he right direction, but the supporting note seems to completely negate that requirement. For that reason, it should be removed. It’s extremely difficult to imagine a scenario where photos would be “impossible” if the rater was actually on site during the appropriate phase of construction. 

Separately, photos of the right, left, and back elevations may not be taken from a far enough distance away to show the entirety of the assembly. These are the only photos that might be "impossible or lack sufficent detail" so it should be removed. 

Proposed Change:

Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet)

The building’s Front, Back, Right, Left elevations


Comment #2

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 1
Comment Intent: Objection
Comment Type: General

Comment:

The process of keeping and maintaining the recommended amount of photo record per rating seems extreme. For some of us smaller Raters this additional record keeping will likely add cost to running our business. In an already hyper competitive world of energy ratings, this is one more step to eliminating the “small guy”. Perhaps a written record of the insulation levels, test results and appliance nameplates is a better option instead of the dense photo documentation.


Comment #3

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: supporting documentation for each file QA:
Comment Intent: Not an Objection
Comment Type: General

Comment:Proposed Change:

I suggest the following additions to the list of required documentation: photo or other documentation of window values; a date/time stamp on photos; and ahri certificate, manufacturer's data, or appliance database reference for HVAC and appliances


Comment #4

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Technical

Comment:


903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • EEP Verification Checklists (Energy Star) • RESNET Standard Disclosure • Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials o Heating, Cooling, and Service Hot Water Equipment including nameplate/model number o Whole House Ventilation Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Leakage of air ducts test result(s) for each system o Dwelling Unit Mechanical Ventilation test result(s) for each system o The building’s Front, Back, Right, Left elevations  o Appliances (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number 903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • EEP Verification Checklists (Energy Star) • RESNET Standard Disclosure • Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials o Heating, Cooling, and Service Hot Water Equipment including nameplate/model number o Whole House Ventilation Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Leakage of air ducts test result(s) for each system o Dwelling Unit Mechanical Ventilation test result(s) for each system o The building’s Front, Back, Right, Left elevations  o Appliances (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number 903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • EEP Verification Checklists (Energy Star) • RESNET Standard Disclosure • Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials o Heating, Cooling, and Service Hot Water Equipment including nameplate/model number o Whole House Ventilation Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Leakage of air ducts test result(s) for each system o Dwelling Unit Mechanical Ventilation test result(s) for each system o The building’s Front, Back, Right, Left elevations  o Appliances (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number 

 

MINHERS does not specify this level of photo documentation or the ability to utilize QA approved builder literature. QA Addendum 34 must work hand in hand with MINHERS Appendix B. MINHERS Appendix B specifies to document not photo document or be approved by QA (do they get approval before or after QA?. If you change this you must also change Appendix B. This level of photo documentation is too ornerous. The minimum number of photos I count is 50 for a two story with two units. Addendum not specific enough about photos impossible to take.  I forgot my camera therefore it is impossible to take photos could be a reason. I only do 9 houses a year so this year I have no photos for my  one QA house-Do I fail?...no -current addendum leaves it up to QA (who I paid $600 to fly in and do my QA). Think he will fail him?

 Addendum not specific enough on any measure. Addendum does not specify how long pictures must be kept. RESNET requires 3 year min records. Should be specified in Addendum. So if I need 50 pics with enough detail and my firm does 1000 houses that is 50,000 pictures year times 3 years is 150,000 pictures. RESNET has done 2,000,000 ratings with 0 pictures. Pictures can be forged with lat. and long. and camera can be adjusted with date. I am against this level of ohoto documentation especially since it can be so easily manipulated with incorrect lat/long/date. If I want to cheat it is easy. This ornerous addendum penalizes those who do ratings correctly by increasing time to perform rating and therefore cost of rating. 

Currently there are numerous large rating firms/providers who are electronically collecting only partial data. RESNET QA should approve electronic data collection programs to confirm the data program is collecting the minimum rated features. Just review any large provider and see if they are collecting window sizes and orientations in their electronic data collection? Builders change windows all the time. This is being missed on a large scale. RESNET Conference 2019 had 3 data collection firms (not rating software) and NONE of them collected all the minimum rated features. THEY SHOULD ALL BE DISALLOWED TILL THEY COLLECT ALL THE MINIMUM RATED FEATURES per Appendix B and they should all be certified by RESNET jsut like calculation software is certified. Why are we allowing calc software to be certified and not data collection software? 

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each type of rating and each rating file QA:RATER shall maintain all documentation for a period of 3 years • Date of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • EEP Verification Checklists (Energy Star) • RESNET Standard Disclosure • Photos or wrtitten/ electronic  RESNET approved electronic documentation of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow Alternative supporting documentation such as purchase orders or builder spec sheets specific and documented to the address of the house can  serve as written documentation) o Each unique building assembly depicting assembly thickness and R value/insulation materials o Heating, Cooling, and Service Hot Water Equipment including nameplate/model number o Whole House Ventilation Equipment including nameplate/model number and controls o Infiltration test result or automated test report/documentation o Leakage of air ducts test result(s) for each system o Dwelling Unit Mechanical Ventilation test result(s) for each system o The building’s Front, Back, Right, Left elevations  o Appliances ,if present at rating, (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number

ALL ELECTRONIC DATA COLLECTION SOFTWARE MUST BE APPROVED BY RESNET  AND CARRY THE LOGO 1" TALL MINIMIM FONT OF 10 ON ANY SALES LITERATURE WITH A RESNET APPROVAL DATE. wording to state:EXPIRES IN 5 YEARS. 

If QA determines minimum rated features are not properly documented per above standards RATER and RFI under rater who performed any part of the documentattion-one time probation for 6 months and two times suspension for 90 days three times suspended from ratings until PROVIDER can document rater/RFI is qualified to perform ratings/data collection and this infraction information shall reside under RESNET REGISTRY. If QA fails to adhere to above requirements QA shall be suspended for 90 days first time and second time suspended 6 months until reapplication with RESNET approved 10 hours training and new application and new fees, third time suspended from QA for 1 year. 


Comment #5

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3
Comment Intent: Not an Objection
Comment Type: General

Comment:

I like the intent of this addition and support its inclusion in the MINHERS Standard.  I do think this list should be reconciled with the similar list being included ANSI/RESNET 301 Appendix B though.


Comment #6

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3
Comment Intent: Objection
Comment Type: Technical

Comment:

While I whole-heartedly agree with the addition of this section into Chapter 9, I would suggest the following edits and a means of improvement and in order to bring this section in alignment with ANSI/RESNET 301 Appendix B.

- Add "and time" to sate of inspection/test to align with Appendix B.

- Delete "are impossible or would".  The inclusion of this language is vague and unenforceable.  Given the prelevence of technology such as smart phones and digital cameras I don't understand what would be an example of "impossibility" when taking a photo.

- Add "or automated test report" to duct leakage testing to be in alignment with infiltration testing.

- Delete ",Back, Right, Left elevations".  While photos of all sides of a building would be recommended I do not beleive it is necessary at a minimum requriement.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the
following supporting documentation for each file QA:
• Date and time of the inspection/test
• The name of the Certified Rater or RFI conducting the inspection/test
• Plans (or alternative documentation showing building dimensions)
• EEP Verification Checklists (Energy Star)
• RESNET Standard Disclosure
• Photos of the following building features where applicable to the rated Dwelling
Unit (Note: Where photos are impossible or would lack sufficient detail, the
Quality Assurance Designee may, at their discretion, allow alternative supporting
documentation such as purchase orders or builder spec sheet)
o Each unique building assembly depicting assembly thickness and R
value/insulation materials
o Heating, Cooling, and Service Hot Water Equipment including
nameplate/model number
o Whole House Ventilation Equipment including nameplate/model number
and controls
o Infiltration test result or automated test report
o Leakage of air ducts test result(s) or automated test report for each system
o Dwelling Unit Mechanical Ventilation test result(s) for each system
o The building’s Front, Back, Right, Left elevations
o Appliances (Refrigerator, Dishwasher, Washer, Dryer) including
nameplate/model number


Comment #7

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

In order to align with ANSI/RESNET 301 I would suggest adding the time, date and geotagging requirements to this section and deleting the de facto exception for providing photos.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the
following supporting documentation for each file QA:
• Date of the inspection/test
• The name of the Certified Rater or RFI conducting the inspection/test
• Plans (or alternative documentation showing building dimensions)
• EEP Verification Checklists (Energy Star)
• RESNET Standard Disclosure
• Photos of the following building features where applicable to the rated Dwelling
Unit (Note: Each photo and/or report shall be time/date stamped and geotagged  Where photos are impossible or would lack sufficient detail, the
Quality Assurance Designee may, at their discretion, allow alternative supporting
documentation such as purchase orders or builder spec sheet
)
o Each unique building assembly depicting assembly thickness and R
value/insulation materials
o Heating, Cooling, and Service Hot Water Equipment including
nameplate/model number
o Whole House Ventilation Equipment including nameplate/model number
and controls
o Infiltration test result or automated test report
o Leakage of air ducts test result(s) for each system
o Dwelling Unit Mechanical Ventilation test result(s) for each system
o The building’s Front, Back, Right, Left elevations
o Appliances (Refrigerator, Dishwasher, Washer, Dryer) including
nameplate/model number


Comment #8

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Not an Objection
Comment Type: General

Comment:

I fully support the proposal to require photos but do suggest a few tweeks to the language as written. "impossible" is vauge and i was always taught nothing is impossible :)." impractical " seems to fit better. Allowing  The alternative to photos to be at the QAD's descretion.....this is vauge also..... does it mean the QA can issue a blanket statment to their raters saying they accept alternatives and is really at the raters discretion if they can take the photos or not? what happens if a QA says they wont accept alternatives but the rater couldnt get all the requiered photos? I propose language that says always attempt to take photos but if impratical an alternative is allowed, all the data can then be on hand for the QA review 

Builders specs are a promise of what is intended to be installed not proof that the measure was installed, A purchase order,  or even better,  a reciept,  at least gives you some confidence in that if  the the builder has had to pay for the thing, they will install it ( maybe) 

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the
following supporting documentation for each file QA:
• Date and time of the inspection/test
• The name of the Certified Rater or RFI conducting the inspection/test
• Plans (or alternative documentation showing building dimensions)
• EEP Verification Checklists (Energy Star)
• RESNET Standard Disclosure
Every effort shall be made to capture Photos of the following building features where applicable to the rated Dwelling
Unit (Note: Where photos are impossible impratical  or would lack sufficient detail, the
Quality Assurance Designee may, at their discretion, allow alternative supporting
documentation such as purchase orders or reciepts are allowed  builder spec sheet)
o Each unique building assembly depicting assembly thickness and R
value/insulation materials
o Heating, Cooling, and Service Hot Water Equipment including
nameplate/model number
o Whole House Ventilation Equipment including nameplate/model number
and controls
o Infiltration test result or automated test report
o Leakage of air ducts test result(s) for each system
o Dwelling Unit Mechanical Ventilation test result(s) for each system
o The building’s Front, Back, Right, Left elevations
o Appliances (Refrigerator, Dishwasher, Washer, Dryer) including
nameplate/model number


Comment #9

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Not an Objection
Comment Type: General

Comment:

I wanted to voice my agreement with this preliminary draft standard's decision not to include a requirement for the list of required photos to include the photo's date/time stamp and geotag EXIF data.  I saw other Public Comments suggest that this requirement be added, and I wanted to voice my opposition against that decision.

My main concern in making EXIF data like a date/time stamp and a geotag a requirement for all photos taken for QA purposes is the ease at which EXIF data can be edited, in mass, with the correct app or software.  Below are just a few websites I found doing a quick Google Search of how to change EXIF data for a given photo.

https://www.howtogeek.com/203592/what-is-exif-data-and-how-to-remove-it/

https://gadgets.ndtv.com/apps/features/remove-location-data-from-photos-view-edit-exif-android-windows-mac-iphone-1821872

Regarding this ability on a phone, I was able to quickly find over 30 free or paid apps in the Google Play Store that can change this information just by typing in "Geotag App".

I am sure that this is not an exhaustive list of every program/process capable of editing date/time stamp and geotag EXIF data that is available, but this ease of access should caution the Rating Community in thinking that requiring this level of data will somehow prevent people from falsifying information.  If someone is going to cheat, they are going to find a way to do it regardless, and we should not add additional requirements throughout the entire industry for both Raters to provide and then QADs to verify this information on top of everything else.


Comment #10

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Technical

Comment:

The requirement for photos of any Whole House Ventilation Equipment including nameplate/model number and controls should be removed for the following reasons:

  1. The description used in the preliminary draft standard, "Whole House Ventilation Equipment", is not consistent with the name and definition of this type of equipment found in ANSI 301-2019 Section 3.2 or ANSI 380-2019 Section 3, where it is listed as "Whole-House Fan".
  2. This type of equipment is not a defined minimum rated feature according to ANSI 301-2019 Table 4.5.2(1) and should not be considered for Quality Assurance purposes unless it is added to that list.
  3. ANSI 301-2019 Appendix B does not contain any On-Site Inspection Protocols for this type of equipment, so Raters do not have a defined way to approach assessing them and likewise QADs for reviewing the Rater's work.
  4. The only instructions related to how to deal with a Whole House Fan in ANSI 380-2019 is in section 4.2.12., dealing with the positioning of any fan louvers/shutters.
  5. The only instructions related to Whole House Fans in ANSI 301-2019 is section 4.4.9., which basically states that if present it will be considered with the normalized Energy Consumption for the Rated Home’s cooling end-use (nEC_x).  However, the ability to model this only exists in REM/Rate, and only then as a Boolean variable (True/False), thus at a minimum negating the requirement for model number as there is not a way to denote a difference in CFM or wattage performance and no need to look up performance values from a model number.
Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA:

• Photos of the following building features where applicable to the rated Dwelling Unit

o Whole House Ventilation Equipment including nameplate/model number and controls


Comment #11

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Technical

Comment:

This preliminary draft standard deals with File QA, which inherently relies on information/photos gathered by Raters/RFIs during their Rough/Pre-Drywall and Final/Confirmed Ratings of the Rated Home that are then shared with the QAD / QA Provider reviewing their files.  The on-site inspection procedures for these tasks are laid out for Raters/RFIs in ANSI 301-2019 Appendix B.

The requirement from this preliminary draft standard for photos of each unique building assembly depicting assembly thickness and R value/insulation materials is not in alignment with the amount of photos of building assemblies required from ANSI 301-2019 Appendix B, and even that Appendix contradicts itself in terms of the number of photos required for different minimum rated features.

ANSI 301-2019 Appendix B outlines the photo requirements in the general on-site inspection protocol section as a minimum of one representative photo of the Wall Assembly and one representative photo of the Roof/Ceiling Assembly.  It goes on to further require in the Floor/Foundation Assembly, Wall Assembly, and Roof/Ceiling Assembly sections the requirement to "Collect photos to confirm installation at several site locations and in sufficient detail to confirm thickness, type, and grade of the insulation installation", which is conflict with the general section in the number of actual photos required.  The requirement of "several" site locations is obviously not 100% defined and open to interpretation by a QAD, but it does not require "each unique" building assembly.  Notably ANSI 301-2019 Appendix B excludes the requirement for photos of insulation for Rim/Band Joists.

In order to align with ANSI 301-2019 Appendix B, I suggest that the requirement for photos of building assemblies be re-written to align with the broader language in Appendix B requiring "several" site locations of the Floor/Foundation Assembly, Wall Assembly, and Roof/Ceiling Assembly only.  This will ensure that QADs / QA Providers are only asking for those photos that Raters are already required to take.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA:

• Photos of the following building features where applicable to the rated Dwelling Unit

o Each unique building assembly depicting assembly thickness and R value/insulation materials Collect photos to confirm installation at several site locations and in sufficient detail to confirm thickness, type, and grade of the insulation installation for the Floor/Foundation Assembly, Wall Assembly, and Roof/Ceiling Assembly.


Comment #12

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Editorial

Comment:

I agree with the preliminary draft standard's intent requiring photos showing what Heating, Cooling, and Service Hot Water equipment is installed in the Rated Home, but the current language is not specific enough to account for the challenge of finding the Cooling Equipment information in AHRI with only the indoor unit (evaporator and/or air handler) or only the outdoor unit (condenser) model number, where there can sometimes be in excess of 500 different records to search through and even then you can possibly not find the correct piece of equipment.  The way this is written, a Rater/RFI might only think that they need to take a photo of one of them and cause this situation for a QAD to occur.

I would recommend breaking these three items up into separate lines and add the requirement for both the indoor unit (evaporator and/or air handler) and the outdoor unit (condenser) model number for the Cooling Equipment to alleviate any confusion.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA:

• Photos of the following building features where applicable to the rated Dwelling Unit

o Heating, Cooling, and Service Hot Water Equipment including nameplate/model number

o Heating Equipment including nameplate/model numer

Cooling Equipment including nameplate/model number of both of the indoor unit (evaporator and/or air handler) and the outdoor unit (condenser)

o Service Hot Water Equipment including nameplate/model number


Comment #13

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: General

Comment:

The requirement for photos of the Dwelling Unit Mechanical Ventilation test result(s) for each system should be removed for the following reasons:

  1. The chief reason that this requirement should not be considered is for safety reasons, this requirement does not take into account the physical constraints that could potentially face a Rater/RFI performing a Confirmed Rating by themselves where they would have to use a ladder to reach a Dwelling Unit Mechanical Ventilation test site.  Unlike testing the Dwelling Unit’s Air Leakage with a blower door or a Heating and Cooling System’s Distribution system with a duct blaster, which can be done standing on the ground next to the diagnostic equipment, the testing sites for Dwelling Unit Mechanical Ventilation systems are often in ceilings and would require ladders to reach them with portable measurement devices.
    1. Per OSHA standards regarding Ladders, Section 1926.1053(b)(22), an employee shall not carry any object or load that could cause the employee to lose balance and fall.
      1. https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1053
    2. Imagine a situation where a Rater/RFI has to use a ladder to reach a 10' bathroom ceiling, and then use both hands to secure a Flow Hood to the ceiling around a bathroom exhaust fan to get a reading.  In this situation, the Rater/RFI has to remove three points of contact from the ladder just to hold the measurement device into place, and then per this requirement we are asking the Rater/RFI to try and hold the Flow Hood with one hand, while operating a camera in the other, allowing for enough space between the camera and the measurement device’s read out display to get a clear picture of the reading.  This situation is not a recipe for a safe working environment and would put a Rater/RFI in a situation where they would be prone to lose their balance, and as such we should avoid mandating it as apart of our standards for any reason.
  2. The second reason we should not require this photo to be taken is that it does not align with the existing procedures laid out in ANSI 301-2019 Appendix B / ANSI 380-2019 for this minimum rated feature.
    1. For the task of “Measure exhaust and supply airflow” ANSI 301-2019 Appendix B simply states “Ventilation airflows in the Dwelling Unit shall be measured following the procedures in ANSI/RESNET/ICC 380”.
    2. ANSI 380-2019 Section 6 Procedure for Measuring Airflow of Mechanical Ventilation Systems goes into great detail on how to perform these measurements, but nowhere in that document is the requirement for photos or pictures listed.  Regardless of method used, the only requirement is for the Rater/RFI to record the measured results from over at least a 10-second period.
Proposed Change:

Proposed Change:
903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA:

• Photos of the following building features where applicable to the rated Dwelling Unit

o Dwelling Unit Mechanical Ventilation test result(s) for each system


Comment #14

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Editorial

Comment:

All of the photos being required by this preliminary draft standard (except for photos of the building assemblies) should be able to be taken during a confirmed rating, unless those building features/minimum rated features are physically not installed yet.  The language used to describe situations where photos cannot be taken is not clear enough and should be rewritten to take this fact into account, as well as specify other means of alternative supporting documentation that would be acceptable in place of the photos being required in this preliminary draft standard.  If a Rater/RFI chooses not to provide a photo or one of these other means of alternative supporting documentation, then they should follow the RESNET standard on how to model the default values for that minimum rated feature.

This will enable clearer understanding of the intent of this statement as well as identify to Raters/RFIs the other acceptable forms of documentation that can be used as alternative supporting documentation, and not force them to return to a home to secure a photo for QA purposes after their Confirmed Rating is complete.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA:

• Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the The Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheets, AHRI certificates, manufacturer's data sheet, or appliance database reference for HVAC and appliances when the building feature is not installed in the Rated Home during the date of the Confirmed Rating.)


Comment #15

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Editorial

Comment:

Revise terminology and formatting to better align with that in 301-2019, which will be referenced by MINHERS soon.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the
following supporting documentation for each file QA:

  • Date of the inspection/test
  • The name of the Certified Rater or RFI conducting the inspection/test
  • Plans (or alternative documentation showing building dimensions)
  • EEP Verification Checklists (Energy Star)
  • RESNET Home Energy Rating Standard Disclosure
  • Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet.)
    • Each unique building assembly depicting assembly thickness and R- vValue/insulation materials
    • Heating, cCooling, and sService hHot wWater eEquipment, including nameplate/model number
    • Whole House Dwelling Unit Mechanical Ventilation System, Equipment including nameplate/model number and controls
    • Infiltration test result or automated test report
    • Duct lLeakage of air ducts test result(s) for each system
    • Dwelling Unit Mechanical Ventilation System test result(s) for each system
    • The building’s fFront, bBack, rRight, lLeft elevations
    • Appliances (rRefrigerator, dDishwasher, clothes wWasher, clothes dDryer), including nameplate/model number

Comment #16

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Technical

Comment:

Remove the word "impossible," since everyone's interpretation of that word can be different and is based on how hard they want to try.  It also introduces a significant amount of ambiguity into these requirements.

Remove the phrase "would lack sufficient detail," since, again, whether or not the photos would have sufficient detail is subject to interpretation (what's sufficient?) and dependent on effort.  It might also depend on whether or not the camera lens is damaged or even just dirty.

Instead, retain the phrase that the QAD may allow alternative documentation in order to encourage communication between Rater and QAD so that individual and local conditions and practices may be considered in enforcing these requirements.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the
following supporting documentation for each file QA:

  • Date of the inspection/test
  • The name of the Certified Rater or RFI conducting the inspection/test
  • Plans (or alternative documentation showing building dimensions)
  • EEP Verification Checklists (Energy Star)
  • RESNET Standard Disclosure
  • Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, tThe Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet)
    • Each unique building assembly depicting assembly thickness and R value/insulation materials
    • Heating, Cooling, and Service Hot Water Equipment including nameplate/model number
    • Whole House Ventilation Equipment including nameplate/model number and controls
    • Infiltration test result or automated test report
    • Leakage of air ducts test result(s) for each system
    • Dwelling Unit Mechanical Ventilation test result(s) for each system
    • The building’s Front, Back, Right, Left elevations
    • Appliances (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number

Comment #17

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Technical

Comment:

How many of each photos of each type are required?  What kind of photos of each type are required?  At what resolution?  Basically, how are these photos to be taken?  Below is what responses to these questions might look like.

Proposed Change:

  903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the

following supporting documentation for each file QA:

  • Date of the inspection/test
  • The name of the Certified Rater or RFI conducting the inspection/test
  • Plans (or alternative documentation showing building dimensions)
  • EEP Verification Checklists (Energy Star)
  • RESNET Standard Disclosure
  • Photos of the following building features where applicable to the rated Dwelling Unit at a resolution of at least 5 megapixels (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet)
    • One wide-angle and one close-up of eEach unique building assembly depicting assembly thickness and R value/insulation materials
    • One wide-angle and one close-up of each piece of Heating, Cooling, and Service Hot Water Equipment including nameplate/model number
    • One wide-angle and one close-up of each piece of Whole House Ventilation Equipment including nameplate/model number and controls
    • One set-up and the iInfiltration test result or automated test report
    • One set-up and the lLeakage of air ducts test result(s) for each system
    • One set-up and the dDwelling Unit Mechanical Ventilation test result(s) for each system
    • The building’s Front, Back, Right, Left elevations
    • One wide-angle and one close-up of each aAppliances (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number

Comment #18

Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01
Page Number: 2
Paragraph / Figure / Table / Note: 903.4.1.3.3.1
Comment Intent: Objection
Comment Type: Technical

Comment:

Reduce the amount of information that must be photographed.  Allow automated test reports for all test results that must be recorded because, even if they don't exist now, software providers will step up if we include the option in the standard.

Proposed Change:

903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the
following supporting documentation for each file QA:

  • Date of the inspection/test
  • The name of the Certified Rater or RFI conducting the inspection/test
  • Plans (or alternative documentation showing building dimensions)
  • EEP Verification Checklists (Energy Star)
  • RESNET Standard Disclosure
  • Photos of the following building features where applicable to the rated Dwelling Unit (Note: Where photos are impossible or would lack sufficient detail, the Quality Assurance Designee may, at their discretion, allow alternative supporting documentation such as purchase orders or builder spec sheet)
    • Each unique building assembly depicting assembly thickness and R value/insulation materials
    • Heating, Cooling, and Service Hot Water Equipment including nameplate/model number
    • Whole House Ventilation Equipment including nameplate/model number and controls setting
    • Infiltration test result or automated test report
    • Leakage of air ducts test result(s) for each system or automated test report
    • Dwelling Unit Mechanical Ventilation test result(s) for each system or automated test report
    • The building’s Front, Back, Right, Left elevations
    • Appliances (Refrigerator, Dishwasher, Washer, Dryer) including nameplate/model number

Return to Proposed MINHERS Addendum 34, QA Data File, Draft PDS-01