Comment #1Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 4Paragraph / Figure / Table / Note: 606Comment Intent: Not an ObjectionComment Type: EditorialComment: I found section 606 very confusing to read because it is backwards from how the testing goes. It starts with Sampling Set, then Qualification Set, and then an unexplained "qualification phase." It would read better if it starts with the Qualification Phase, then the Qualification Set, and then the Sampling Set. This to me is a logical order and much easier to follow. Proposed Change: 606.1 Qualification Phase 606.1.1 [Explanation of this here. I didn’t see any explanation in this doc.] 606.2 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. [Redundant] To qualify for sampling a builder must complete a Qualification Set. 606.2.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature prior to conducting a Qualification Set for each Sampled Feature. 606.2.2 Any feature being sampled must qualify for sampling by successfully being verified to meet the threshold specification for five (5) consecutive Sampled Features. A Qualification Set shall be made up of more than five (5) Sampled Features if a failure occurs during the qualification phase. 606.2.3 Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.2.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dwelling units without any incidence of failure. 606.2.5 Each Sampled Feature shall qualify for Sampling independently of the other Sampled Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required. 606.1 3 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. [Move this to a Definitions section, and also define there Qualification Phase, Qualification Set, and potentially other terminology,] For each stage of construction, each Sample Set will be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled;
I found section 606 very confusing to read because it is backwards from how the testing goes. It starts with Sampling Set, then Qualification Set, and then an unexplained "qualification phase." It would read better if it starts with the Qualification Phase, then the Qualification Set, and then the Sampling Set. This to me is a logical order and much easier to follow.
606.1 Qualification Phase 606.1.1 [Explanation of this here. I didn’t see any explanation in this doc.]
606.2 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. [Redundant] To qualify for sampling a builder must complete a Qualification Set. 606.2.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature prior to conducting a Qualification Set for each Sampled Feature. 606.2.2 Any feature being sampled must qualify for sampling by successfully being verified to meet the threshold specification for five (5) consecutive Sampled Features. A Qualification Set shall be made up of more than five (5) Sampled Features if a failure occurs during the qualification phase. 606.2.3 Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.2.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dwelling units without any incidence of failure. 606.2.5 Each Sampled Feature shall qualify for Sampling independently of the other Sampled Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required. 606.1 3 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. [Move this to a Definitions section, and also define there Qualification Phase, Qualification Set, and potentially other terminology,] For each stage of construction, each Sample Set will be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled;
Comment #2Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: 606.2, 607Comment Intent: Not an ObjectionComment Type: EditorialComment: Imprecise/unclear language Proposed Change: 606.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification of that Sampled Feature in for three (3) consecutive Sampled Features. instances. ----------------- 607 Quality Assurance by Sampling Providers The Sampling Provider’s QA Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. 607.1 Sampling Provider Accreditation Criteria Sampling Providers shall first be accredited by RESNET as a Rating Quality Assurance Provider in accordance with the Accreditation Process specified in Chapter 9 of these Standards and shall remain in good standing. Additionally, an applicant to become a Sampling Provider must provide the following: • Written policies and procedures explaining the Provider’s Sampling requirements for Raters and oversight process including Quality Assurance and data management processes ------------------ Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest. [NOTE - I don't have an edit here because I don't know what is being said. Stakeholders is a very broad term and could be construed as anyone working on a project. I'm also not clear what "certify" means or what type of financial interest we are talking about. Is that an ownership interest? Does that include all the subcontractors that are getting paid on a project? The Rater and Provider certainly have a financial interest. I know that's not what is meant here, but it's not clear either.]
Imprecise/unclear language
606.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification of that Sampled Feature in for three (3) consecutive Sampled Features. instances.
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607 Quality Assurance by Sampling Providers
The Sampling Provider’s QA Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. 607.1 Sampling Provider Accreditation Criteria Sampling Providers shall first be accredited by RESNET as a Rating Quality Assurance Provider in accordance with the Accreditation Process specified in Chapter 9 of these Standards and shall remain in good standing. Additionally, an applicant to become a Sampling Provider must provide the following: • Written policies and procedures explaining the Provider’s Sampling requirements for Raters and oversight process including Quality Assurance and data management processes
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Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest. [NOTE - I don't have an edit here because I don't know what is being said. Stakeholders is a very broad term and could be construed as anyone working on a project. I'm also not clear what "certify" means or what type of financial interest we are talking about. Is that an ownership interest? Does that include all the subcontractors that are getting paid on a project? The Rater and Provider certainly have a financial interest. I know that's not what is meant here, but it's not clear either.]
Comment #3Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 1-10Paragraph / Figure / Table / Note: AllComment Intent: ObjectionComment Type: GeneralComment: This comment is being issued on behalf of the Standards and Energy Code Committees of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers from New Jersey to Maine. Due to the nature of the new construction, gut rehab and adaptive reuse market in the northeastern US, the members of NEHERS have considerable experience in multi-family buildings and energy ratings for attached dwelling units.This proposed standard for Sampling has a significant impact on single family and multifamily projects of all sizes. Those Rating Companies that rely on sampling to provide a lower cost for Rating Services may be severely impacted by this proposed change. Given the nature of this wholesale change to Chapter 6 of MINHERS and the impact on work schedules caused by the COVID-19 Virus outbreak, RESNET should consider extending the deadline for the first public comment period from March 26 to April 24, 2020. In addtion, NEHERS Stanads Committee members have reviewed Proposed MINHERS Addendum 46, Sampling, Draft PDS-01, to some extent and offer a number of gramtical corrections. The numbering of sections is also out of sequence- after Section 606.2.5 "Each Sampled Feature......" ; the next section is numbered 605.3. The numbering sequence should either continue as 606.2.6 OR a new Section 607.1 should begin. The entire Proposed lanaguage is provided below with "stike" & "underlining" format. A copy of the word document with the changes is attached as well. Thank you Proposed Change: 600 General Provisions 600.1 Purpose Sampling is intended to provide verification that a group of Dwelling Units (single-family homes or dwelling units within a multifamily project dwelling units) meet a particular threshold such as ENERGY STAR®, energy code compliance, or qualification for an energy efficiency lending program. It is based on predetermined Threshold Specifications and subsequent testing and inspections of a subset of Dwelling Units. Verifying a group of Dwelling Units by Sampling entitles the customer to documentation that the Dwelling Units meet the desired threshold. Sampling does not constitute a Confirmed HERS Rating on any Dwelling Unit. 600.2 Scope This chapter sets out establishes the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling. The procedures described in this chapter are applicable to the following Dwelling Units: (a) single family homes (attached and detached), (b) units within a multifamily building or within multiple buildings. This chapter does not provide any warranty, either explicit or implied, that sampled Dwelling Units will meet or exceed the threshold specifications for the Sample Set. There may be instances in which state laws or regulations differ from these Standards. In such instances, state law or regulation shall take precedence over this standard. Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications may only be applied to any projects within the same Community. Records Maintenance The HERS Rater must document that the project met the minimum requirements for sampling and that each step in the sampling process has been met adhered to. This Ddocumentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s).Each inspection and/or test for each instances of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) Conformance with, or failure to meet Threshold Specification. Sampling Plan The HERS Rater shall develop a sampling Sampling plan Plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual minimum rated feature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) from the Sampling Plan. 603.1 Sampling Plan The following information shall be included in the Sampling Plan: Sampled Project name; Sampled Project location Sampled Project projected dates of construction; Total number of Dwelling Units, and for multifamily buildings, the number of dwelling units in each building; List of all Sampled Features and Threshold Specifications Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20% + X%. AND Only units that have 100% of the minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units removed shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled. 603.2 Sampling Plan Changes The Sampling Plan shall be adjusted when the following changes are made to the Sampled Project. The List list of all Sampled Features and Threshold Specifications in the Sampling Plan shall be amended as needed to reflect adjustments and additions. : 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the Sampling Verification Process. Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, aAt a minimum, all units within a group shall have the same number of bedrooms and same conditioned floor area within 10 percent of one another (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall then be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a certified Rater shall oversee this process. Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 605.2 Multifamily Unit Label Every Dwelling Unit subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This Dwelling Unit has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. Building Label If all Dwelling Units within the building are verified using the same application of the sampling protocol such that individual labels would be identical, each building (but not each dwelling unit) may be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “The residential Dwelling Units in this building have been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on an electrical panel for the building and the font shall be a minimum of 10 points. Procedures for Inspections and Testing The tTesting and inspection of Dwelling Units for minimum rated features shall be conducted in compliance with the procedures for conducting home energy Ratings contained in the RESNET MINHERS Standards. 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set will be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off limited toat the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in factat the Rater’s discretion, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled; 606.2 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. To qualify for sampling a builder must complete a Qualification Set. 606.2.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature. These are then verified prior to conducting a Qualification Set for each Sampled Feature. 606.2.2 Any feature being sampled must qualify for sampling by successfully being successfully verified to meet the threshold specification for five (5) consecutive Sampled FeaturesDwelling Units. A Qualification Set shall be made up of more than five (5) Sampled Features if a failure occurs during the qualification phase. 606.2.3 Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.2.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dwelling units without any incidence of failure. 606.2.5 Each Sampled Feature shall qualify for Sampling independently of any other Sampled Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required. 605.3607.1 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Certified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) 1 For example, consider a 100-unit Sampled Project. The minimum quantity of Verifications for a given Sampled Feature is 100 – 10 (Qualification Set) = 90, then 90 * 0.2 = 18. Note: Qualification Set number may vary depending on failures but always requires a minimum 5 completed + 5 consecutive without failure. 6 Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Sampling Providers may complete the Sampling Verifications collectively on a single dwelling unit or distribute the tests and inspections across several dwelling units within a given Sample Set, provided the total number of individual tests and inspections meets or exceeds 20%. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be representative6 of the total group of Sampled Features. Verifications shall be spread across the beginning, middle, and end of the installation timeline for each Sampled Feature. A Sampled Feature that does not meet its Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to the Procedures for Resolving Failures. Procedure for Resolving Failures 606607.1 2 Failures When a Sampled Feature fails a Threshold Specification, Sampling of that feature must stop. All Failures shall be corrected and re-inspected and/or retested until they meet their Threshold Specifications. At any time, a given Sampled Feature is permitted to be removed from Sampling and every remaining instance shall be verified. 606607.2 3 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification for three (3) consecutive Sampled Features. Once a feature requalifies for Sampling, that Feature may continue being Sampled until a Failure occurs. Additional Verifications performed as a result of failures shall not count toward the required 20%. 606607.3 4 Documenting Failures The following items shall be documented and reported if required by program, code, or project representative. Failure reports must be maintained in the Raters records for 3 years. i. Failed feature, date, location, and result ii. Date, location, and results of requalification for Sampling Quality Assurance by Sampling Providers The Sampling Provider’s Quality Assurance Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. Sampling Provider Accreditation Criteria Sampling Providers shall first be accredited by RESNET as a Rating Quality Assurance Provider in accordance with the Accreditation Process specified in Chapter 9 of these Standards and shall remain in good standing. Additionally, an applicant to become a Sampling Provider must provide the following: • Written policies and procedures explaining the Provider’s Sampling process including Quality Assurance and data management processes • Minimum insurance coverage of $1,000,000 in for general liability coverage and $1,000,000 in for professional liability coverage After submitting an application to become a Sampling Provider, the applicant must successfully complete: • RESNET Enhanced Review of Rating QA Provider, if not completed within 12 months prior to application submittal. • RESNET QA Staff Orientation to Sampling When all requirements have been satisfied, RESNET staff shall submit the completed application to the Accreditation Committee for approval. The Sampling Provider’s first annual QA review following accreditation shall be an additional Enhanced Review, which shall demonstrate compliance with the Sampling Provider’s written policies and procedures and the requirements of this chapter. Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest.
This comment is being issued on behalf of the Standards and Energy Code Committees of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers from New Jersey to Maine.
Due to the nature of the new construction, gut rehab and adaptive reuse market in the northeastern US, the members of NEHERS have considerable experience in multi-family buildings and energy ratings for attached dwelling units.This proposed standard for Sampling has a significant impact on single family and multifamily projects of all sizes. Those Rating Companies that rely on sampling to provide a lower cost for Rating Services may be severely impacted by this proposed change.
Given the nature of this wholesale change to Chapter 6 of MINHERS and the impact on work schedules caused by the COVID-19 Virus outbreak, RESNET should consider extending the deadline for the first public comment period from March 26 to April 24, 2020.
In addtion, NEHERS Stanads Committee members have reviewed Proposed MINHERS Addendum 46, Sampling, Draft PDS-01, to some extent and offer a number of gramtical corrections.
The numbering of sections is also out of sequence- after Section 606.2.5 "Each Sampled Feature......" ; the next section is numbered 605.3. The numbering sequence should either continue as 606.2.6 OR a new Section 607.1 should begin. The entire Proposed lanaguage is provided below with "stike" & "underlining" format. A copy of the word document with the changes is attached as well.
Thank you
600 General Provisions 600.1 Purpose Sampling is intended to provide verification that a group of Dwelling Units (single-family homes or dwelling units within a multifamily project dwelling units) meet a particular threshold such as ENERGY STAR®, energy code compliance, or qualification for an energy efficiency lending program. It is based on predetermined Threshold Specifications and subsequent testing and inspections of a subset of Dwelling Units. Verifying a group of Dwelling Units by Sampling entitles the customer to documentation that the Dwelling Units meet the desired threshold. Sampling does not constitute a Confirmed HERS Rating on any Dwelling Unit.
600.2 Scope
This chapter sets out establishes the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling. The procedures described in this chapter are applicable to the following Dwelling Units: (a) single family homes (attached and detached), (b) units within a multifamily building or within multiple buildings. This chapter does not provide any warranty, either explicit or implied, that sampled Dwelling Units will meet or exceed the threshold specifications for the Sample Set. There may be instances in which state laws or regulations differ from these Standards. In such instances, state law or regulation shall take precedence over this standard. Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications may only be applied to any projects within the same Community. Records Maintenance The HERS Rater must document that the project met the minimum requirements for sampling and that each step in the sampling process has been met adhered to. This Ddocumentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s).Each inspection and/or test for each instances of each Sampled Feature shall have the following information recorded:
(a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) Conformance with, or failure to meet Threshold Specification. Sampling Plan The HERS Rater shall develop a sampling Sampling plan Plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual minimum rated feature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) from the Sampling Plan.
603.1 Sampling Plan The following information shall be included in the Sampling Plan: Sampled Project name; Sampled Project location Sampled Project projected dates of construction; Total number of Dwelling Units, and for multifamily buildings, the number of dwelling units in each building; List of all Sampled Features and Threshold Specifications Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20% + X%. AND Only units that have 100% of the minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units removed shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled. 603.2 Sampling Plan Changes The Sampling Plan shall be adjusted when the following changes are made to the Sampled Project. The List list of all Sampled Features and Threshold Specifications in the Sampling Plan shall be amended as needed to reflect adjustments and additions. : 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the Sampling Verification Process. Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, aAt a minimum, all units within a group shall have the same number of bedrooms and same conditioned floor area within 10 percent of one another (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall then be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a certified Rater shall oversee this process. Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 605.2 Multifamily Unit Label Every Dwelling Unit subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This Dwelling Unit has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. Building Label If all Dwelling Units within the building are verified using the same application of the sampling protocol such that individual labels would be identical, each building (but not each dwelling unit) may be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “The residential Dwelling Units in this building have been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on an electrical panel for the building and the font shall be a minimum of 10 points. Procedures for Inspections and Testing The tTesting and inspection of Dwelling Units for minimum rated features shall be conducted in compliance with the procedures for conducting home energy Ratings contained in the RESNET MINHERS Standards. 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set will be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off limited toat the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in factat the Rater’s discretion, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled; 606.2 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. To qualify for sampling a builder must complete a Qualification Set. 606.2.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature. These are then verified prior to conducting a Qualification Set for each Sampled Feature. 606.2.2 Any feature being sampled must qualify for sampling by successfully being successfully verified to meet the threshold specification for five (5) consecutive Sampled FeaturesDwelling Units. A Qualification Set shall be made up of more than five (5) Sampled Features if a failure occurs during the qualification phase. 606.2.3 Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.2.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dwelling units without any incidence of failure. 606.2.5 Each Sampled Feature shall qualify for Sampling independently of any other Sampled Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required. 605.3607.1 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Certified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) 1 For example, consider a 100-unit Sampled Project. The minimum quantity of Verifications for a given Sampled Feature is 100 – 10 (Qualification Set) = 90, then 90 * 0.2 = 18. Note: Qualification Set number may vary depending on failures but always requires a minimum 5 completed + 5 consecutive without failure. 6 Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Sampling Providers may complete the Sampling Verifications collectively on a single dwelling unit or distribute the tests and inspections across several dwelling units within a given Sample Set, provided the total number of individual tests and inspections meets or exceeds 20%. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be representative6 of the total group of Sampled Features. Verifications shall be spread across the beginning, middle, and end of the installation timeline for each Sampled Feature. A Sampled Feature that does not meet its Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to the Procedures for Resolving Failures. Procedure for Resolving Failures 606607.1 2 Failures When a Sampled Feature fails a Threshold Specification, Sampling of that feature must stop. All Failures shall be corrected and re-inspected and/or retested until they meet their Threshold Specifications. At any time, a given Sampled Feature is permitted to be removed from Sampling and every remaining instance shall be verified. 606607.2 3 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification for three (3) consecutive Sampled Features. Once a feature requalifies for Sampling, that Feature may continue being Sampled until a Failure occurs. Additional Verifications performed as a result of failures shall not count toward the required 20%. 606607.3 4 Documenting Failures The following items shall be documented and reported if required by program, code, or project representative. Failure reports must be maintained in the Raters records for 3 years. i. Failed feature, date, location, and result ii. Date, location, and results of requalification for Sampling Quality Assurance by Sampling Providers The Sampling Provider’s Quality Assurance Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. Sampling Provider Accreditation Criteria Sampling Providers shall first be accredited by RESNET as a Rating Quality Assurance Provider in accordance with the Accreditation Process specified in Chapter 9 of these Standards and shall remain in good standing. Additionally, an applicant to become a Sampling Provider must provide the following: • Written policies and procedures explaining the Provider’s Sampling process including Quality Assurance and data management processes • Minimum insurance coverage of $1,000,000 in for general liability coverage and $1,000,000 in for professional liability coverage After submitting an application to become a Sampling Provider, the applicant must successfully complete: • RESNET Enhanced Review of Rating QA Provider, if not completed within 12 months prior to application submittal. • RESNET QA Staff Orientation to Sampling When all requirements have been satisfied, RESNET staff shall submit the completed application to the Accreditation Committee for approval. The Sampling Provider’s first annual QA review following accreditation shall be an additional Enhanced Review, which shall demonstrate compliance with the Sampling Provider’s written policies and procedures and the requirements of this chapter. Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest.
Comment #4Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: 600 General ProvisionsComment Intent: Not an ObjectionComment Type: GeneralComment: To clarify capitalized terms, it would be helpful to include a Definitions section at the beginning of the chapter to define at least the following (not limited to): Community, Dwelling Units, Minimum Rated Features, Sampled Feature, Sampled Project, Sample Set, Qualification Set, Sampling Verification Process, and Threshold Specifications.
To clarify capitalized terms, it would be helpful to include a Definitions section at the beginning of the chapter to define at least the following (not limited to): Community, Dwelling Units, Minimum Rated Features, Sampled Feature, Sampled Project, Sample Set, Qualification Set, Sampling Verification Process, and Threshold Specifications.
Comment #5Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: 600 General Provisions, EligibilityComment Intent: Not an ObjectionComment Type: EditorialComment: “The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction.” The above provision could be interpreted two ways: 1.) By placing the responsibility on the builder or developer of features to be sampled, the builder/developer can choose features that have an increased likelihood of passing Threshold Specifications to showcase compliance and disproportionately affect the HERS Index. 2.) As more than one builder may be developing a community using the same trade partner (e.g., insulation, HVAC), this provision makes sure that sampling stays with the builder and not the trade partner even through the trades may installing the same exact product (e.g., fiberglass batts) across homes built by different builders. At the end of the day regardless of sampling, full responsibility over the feature stays with the builder. If interpreted the first way, NAHB recommends adjusting this responsibility to the HERS Rater. If the intention of the provision is as listed in item two above, it would be useful to provide additional clarification within the text to make the purpose of the quoted statement less ambiguous.
“The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction.”
The above provision could be interpreted two ways:
1.) By placing the responsibility on the builder or developer of features to be sampled, the builder/developer can choose features that have an increased likelihood of passing Threshold Specifications to showcase compliance and disproportionately affect the HERS Index. 2.) As more than one builder may be developing a community using the same trade partner (e.g., insulation, HVAC), this provision makes sure that sampling stays with the builder and not the trade partner even through the trades may installing the same exact product (e.g., fiberglass batts) across homes built by different builders. At the end of the day regardless of sampling, full responsibility over the feature stays with the builder.
If interpreted the first way, NAHB recommends adjusting this responsibility to the HERS Rater. If the intention of the provision is as listed in item two above, it would be useful to provide additional clarification within the text to make the purpose of the quoted statement less ambiguous.
Comment #6Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 6Paragraph / Figure / Table / Note: 600 General Provisions, 603.1 Sampling PlanComment Intent: Not an ObjectionComment Type: EditorialComment: “RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) from the Sampling Plan.” It is unclear if (a), (b), (c), and (d) refer to Date, Dwelling Unit Address, Sampled Feature, and Conformance with or failure to meet Threshold Specification listed under the Records Maintenance section, or if (a), (b), (c), and (d) refer to information listed in the 603.1 Sampling Plan section. If the latter, recommend labeling each item accordingly with letters.
“RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) from the Sampling Plan.”
It is unclear if (a), (b), (c), and (d) refer to Date, Dwelling Unit Address, Sampled Feature, and Conformance with or failure to meet Threshold Specification listed under the Records Maintenance section, or if (a), (b), (c), and (d) refer to information listed in the 603.1 Sampling Plan section. If the latter, recommend labeling each item accordingly with letters.
Comment #7Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 8Paragraph / Figure / Table / Note: 606.2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: “Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification.” We recommend that a root-cause analysis be conducted for any features that fail to meet Threshold Specifications, so that the builder can understand why the failure occurred, fix or adjust as necessary, and prevent further failures from happening in other units within the Community.
“Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification.”
We recommend that a root-cause analysis be conducted for any features that fail to meet Threshold Specifications, so that the builder can understand why the failure occurred, fix or adjust as necessary, and prevent further failures from happening in other units within the Community.
Comment #8Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: 605.3 Sampling Verification ProcessComment Intent: Not an ObjectionComment Type: GeneralComment: “A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Rater shall oversee this process.” While an increase in the sampling rate from 1-in-7 to 20% will help increase quality assurance, NAHB has concerns about an increased cost to builders. To help mitigate the cost impact, NAHB encourages RESNET to explore strategies of increasing the sampling rate without adding costs, such as flexibility with virtual inspections or other measures to reduce the cost burden.
“A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Rater shall oversee this process.”
While an increase in the sampling rate from 1-in-7 to 20% will help increase quality assurance, NAHB has concerns about an increased cost to builders. To help mitigate the cost impact, NAHB encourages RESNET to explore strategies of increasing the sampling rate without adding costs, such as flexibility with virtual inspections or other measures to reduce the cost burden.
Comment #9Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 10Paragraph / Figure / Table / Note: Quality Assurance by Sampling ProvidersComment Intent: Not an ObjectionComment Type: GeneralComment: “Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest.” The intent of the above statement is confusing, as builders or other stakeholders have a financial interest in the units that are being rated. NAHB recommends clarifying intent, or better defining stakeholders in this context.
“Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest.”
The intent of the above statement is confusing, as builders or other stakeholders have a financial interest in the units that are being rated. NAHB recommends clarifying intent, or better defining stakeholders in this context.
Comment #10Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: EligibilityComment Intent: ObjectionComment Type: EditorialComment: Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications may only be applied to any projects within the same Community. This section could be read to say that the Builder or Developer are responsible for sampling the features they also build Proposed Change: Eligibility The construction of the Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall be the responsability of a rater under the guidance of a Sampling Provider and may only be applied to any projects within the same Community.
Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications may only be applied to any projects within the same Community.
This section could be read to say that the Builder or Developer are responsible for sampling the features they also build
Eligibility The construction of the Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall be the responsability of a rater under the guidance of a Sampling Provider and may only be applied to any projects within the same Community.
Comment #11Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: Energy ModelingComment Intent: ObjectionComment Type: EditorialComment: Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area modeling of different plan types does not make sense even if they are within the +/- 10% conditioned floor area. Proposed Change: Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area Only one unique energy model needs to be created per plan or model type representing worst case configuration.
Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area
modeling of different plan types does not make sense even if they are within the +/- 10% conditioned floor area.
Only one unique energy model needs to be created per plan or model type representing worst case configuration.
Comment #12Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: Energy ModelingComment Intent: ObjectionComment Type: EditorialComment: Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. I think that the two bolded sections don't align. One says that untis with similar sizes can be modeld together and on says that each unit must have a unigue model? One model must be produced for each plan or dwelling unit type and each address must be assigned a modesl. I also think that the unit that is sampled shall not be given a confirmed HERS Index. I don't believe that this is mentioned in the standard. Proposed Change: Energy Modeling Dwelling Units with the same model # or configuration shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall within the sample shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. The unit that is inspected or tested during implementaiton of sampling shall not be given a confirmed HERS Index.
Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications.
I think that the two bolded sections don't align. One says that untis with similar sizes can be modeld together and on says that each unit must have a unigue model? One model must be produced for each plan or dwelling unit type and each address must be assigned a modesl. I also think that the unit that is sampled shall not be given a confirmed HERS Index. I don't believe that this is mentioned in the standard.
Energy Modeling Dwelling Units with the same model # or configuration shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area.
A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group.
If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group.
Each Dwelling Unit shall within the sample shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. The unit that is inspected or tested during implementaiton of sampling shall not be given a confirmed HERS Index.
Comment #13Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: LabelingComment Intent: ObjectionComment Type: EditorialComment: Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. We have learned from code that labels should ts.not be installed in electrical panels but rather should be posted in a permenant and prominent location. It also appears that RESNET is creating a new lable? This should HERS Report is anything? I don't understand the linkage to a minimum number of points? THis makes no sense. Proposed Change: Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a report label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).If the dwelling is also complying with code or an above code program that mandates the includeing of a label, the ” This label shall be posted located on the electrical panel or other prominent and perminent location. and the font shall be a minimum of 10 points.
Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points.
We have learned from code that labels should ts.not be installed in electrical panels but rather should be posted in a permenant and prominent location. It also appears that RESNET is creating a new lable? This should HERS Report is anything?
I don't understand the linkage to a minimum number of points? THis makes no sense.
Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a report label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).If the dwelling is also complying with code or an above code program that mandates the includeing of a label, the ” This label shall be posted located on the electrical panel or other prominent and perminent location. and the font shall be a minimum of 10 points.
Comment #14Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: 605.3 Sampling Verification ProcessComment Intent: ObjectionComment Type: EditorialComment: The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) This is confusing? and does not match the example footnote 1 Proposed Change: The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of dwelling units of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (i.e. Projects containing less than 12 units would not benefit from the sampling process.) it should be the number of dwelling units after qualification divided by 5. or at least the language above should match the footnote.
The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.)
This is confusing? and does not match the example footnote 1
The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of dwelling units of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (i.e. Projects containing less than 12 units would not benefit from the sampling process.)
it should be the number of dwelling units after qualification divided by 5. or at least the language above should match the footnote.
Comment #15Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: 600.2 ScopeComment Intent: Not an ObjectionComment Type: TechnicalComment: The definition of eligibility should be expanded to include key contractors to maintain consistency throughout the project. Proposed Change: Eligibilty The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall may only be applied to any projects that are within the same Community and use the same key contractors (insulation, electrical, framing, HVAC) across the Community.
The definition of eligibility should be expanded to include key contractors to maintain consistency throughout the project.
Eligibilty
The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall may only be applied to any projects that are within the same Community and use the same key contractors (insulation, electrical, framing, HVAC) across the Community.
Comment #16Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: Records MaintenanceComment Intent: Not an ObjectionComment Type: TechnicalComment: Records Maintenance should include the worst case model grouping to ensure that groupings are being created and recorded consistently and accurately. Proposed Change: Records Maintenance The HERS Rater must document that the project met the requirements for sampling and that each step in the sampling process has been met. This documentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s). Each inspection and/or test for each instance of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) Conformance with or failure to meet Threshold Specification, (e) Worst case model grouping.
Records Maintenance should include the worst case model grouping to ensure that groupings are being created and recorded consistently and accurately.
Records Maintenance
The HERS Rater must document that the project met the requirements for sampling and that each step in the sampling process has been met. This documentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s). Each inspection and/or test for each instance of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) Conformance with or failure to meet Threshold Specification, (e) Worst case model grouping.
Comment #17Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: EligibilityComment Intent: Not an ObjectionComment Type: TechnicalComment: The definition of eligibility should be expanded to include key contractors to maintain consistency throughout the project. Proposed Change: Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall may only be applied to any projects that are within the same Community and use the same key contractors (insulation, electrical, framing, HVAC) across the Community.
Eligibility
Comment #18Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 6Paragraph / Figure / Table / Note: Sampling PlanComment Intent: Not an ObjectionComment Type: TechnicalComment: Notification to RESNET should be done through the Registry, and should include the worst case grouping (e) noted in our previous comment. Proposed Change: Sampling Plan The HERS Rater shall develop a sampling plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual minimum rated feature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set via submission to the RESNET registry. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) (d), and (e) from the Sampling Plan.
Notification to RESNET should be done through the Registry, and should include the worst case grouping (e) noted in our previous comment.
Sampling Plan
The HERS Rater shall develop a sampling plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual minimum rated feature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set via submission to the RESNET registry. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) (d), and (e) from the Sampling Plan.
Comment #19Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: Energy ModelingComment Intent: Not an ObjectionComment Type: TechnicalComment: The description of which models may be grouped together should match the language found in ANSI 301-2019. In addition, if a project has better features (that are not Sampled) that affect the Index, and they are consistently verified as confirmed features of every dwelling unit, it would be appropriate to update those features in the worst case model. Proposed Change: Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. the same construction type, same envelope systems, same number of Bedrooms, same number of stories within the unit, same window area (±10%), same Conditioned Floor Area (±10%, not to exceed ±100 ft2), and same ceiling height (±0.5 ft) are permitted to be the same unit type. Dwelling Units that satisfy these criteria, but differ in other criteria, are not required to be modeled as the same unit type. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a certified Rater shall oversee this process.
The description of which models may be grouped together should match the language found in ANSI 301-2019. In addition, if a project has better features (that are not Sampled) that affect the Index, and they are consistently verified as confirmed features of every dwelling unit, it would be appropriate to update those features in the worst case model.
Energy Modeling
Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. the same construction type, same envelope systems, same number of Bedrooms, same number of stories within the unit, same window area (±10%), same Conditioned Floor Area (±10%, not to exceed ±100 ft2), and same ceiling height (±0.5 ft) are permitted to be the same unit type. Dwelling Units that satisfy these criteria, but differ in other criteria, are not required to be modeled as the same unit type. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a certified Rater shall oversee this process.
Comment #20Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 8Paragraph / Figure / Table / Note: 606.1 Sample SetComment Intent: Not an ObjectionComment Type: TechnicalComment: The example language is confusing and does not need to be included. Proposed Change: 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set wishall be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled;.
The example language is confusing and does not need to be included.
606.1 Sample Set
A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set wishall be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled;.
Comment #21Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: 605.3 Sampling Verification ProcessComment Intent: Not an ObjectionComment Type: TechnicalComment: The party completing the Sampling Verifications should be the Rater(s). In addition, the timeline for verifications should be clarified. In addition, the verification process should ensure that worst case units and all buildings within a multifamily project are being verified. Proposed Change: 605.3 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) 1 For example, consider a 100-unit Sampled Project. The minimum quantity of Verifications for a given Sampled Feature is 100 – 10 (Qualification Set) = 90, then 90 * 0.2 = 18. Note: Qualification Set number may vary depending on failures but always requires a minimum 5 completed + 5 consecutive without failure. 6 Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Sampling Providers Raters may complete the Sampling Verifications collectively on a single dwelling unit or distribute the tests and inspections across several dwelling units within a given Sample Set, provided the total number of individual tests and inspections meets or exceeds 20%. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be representative6 of the total group of Sampled Features. Verifications shall be spread across the beginning, middle, and end of the installation timeline for each Sampled Feature. Only units that have all selected Sampled Features available for verification at the time of inspection shall be included in the Sample Set. At a minimum, for each Projected Rating, a dwelling unit that matches that Projected Rating’s unit type and worst-case configuration, must be verified for each Sampled Feature. Sample Sets that include multifamily buildings with 5 units or more per building shall have a minimum of one unit verified per building. A Sampled Feature that does not meet its Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to the Procedures for Resolving Failures.
The party completing the Sampling Verifications should be the Rater(s). In addition, the timeline for verifications should be clarified. In addition, the verification process should ensure that worst case units and all buildings within a multifamily project are being verified.
605.3 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) 1 For example, consider a 100-unit Sampled Project. The minimum quantity of Verifications for a given Sampled Feature is 100 – 10 (Qualification Set) = 90, then 90 * 0.2 = 18. Note: Qualification Set number may vary depending on failures but always requires a minimum 5 completed + 5 consecutive without failure. 6 Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Sampling Providers Raters may complete the Sampling Verifications collectively on a single dwelling unit or distribute the tests and inspections across several dwelling units within a given Sample Set, provided the total number of individual tests and inspections meets or exceeds 20%. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be representative6 of the total group of Sampled Features. Verifications shall be spread across the beginning, middle, and end of the installation timeline for each Sampled Feature. Only units that have all selected Sampled Features available for verification at the time of inspection shall be included in the Sample Set.
At a minimum, for each Projected Rating, a dwelling unit that matches that Projected Rating’s unit type and worst-case configuration, must be verified for each Sampled Feature.
Sample Sets that include multifamily buildings with 5 units or more per building shall have a minimum of one unit verified per building.
A Sampled Feature that does not meet its Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to the Procedures for Resolving Failures.
Comment #22Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 4Paragraph / Figure / Table / Note: 600 General ProvisionsComment Intent: Not an ObjectionComment Type: EditorialComment: There are sections throughout the draft with no section numbering, or where the numbering is out of order. The Qualification Set should be defined before the Sample Set. Proposed Change: 600 General Provisions 600.1 Purpose Sampling is intended to provide verification that a group of Dwelling Units (single-family homes or multifamily dwelling units) meet a particular threshold such as ENERGY STAR®, energy code compliance, or qualification for an energy efficiency lending program. It is based on predetermined Threshold Specifications and subsequent testing and inspections of a subset of Dwelling Units. Verifying a group of Dwelling Units by Sampling entitles the customer to documentation that the Dwelling Units meet the desired threshold. Sampling does not constitute a Confirmed HERS Rating on any Dwelling Unit. 600.2 Scope This chapter sets out the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling. The procedures described in this chapter are applicable to the following Dwelling Units: (a) single family homes (attached and detached), (b) units within a multifamily building or within multiple buildings. This chapter does not provide any warranty, either explicit or implied, that sampled Dwelling Units will meet or exceed the threshold specifications for the Sample Set. There may be instances in which state laws or regulations differ from these Standards. In such instances, state law or regulation shall take precedence over this standard. 601 Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall may only be applied to any projects that are within the same Community and use the same key contractors (insulation, electrical, framing, HVAC) across the Community. 602 Records Maintenance The HERS Rater must document that the project met the requirements for sampling and that each step in the sampling process has been met. This documentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s). Each inspection and/or test for each instance of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) Conformance with or failure to meet Threshold Specification, (e) Worst case model grouping. 603 Sampling Plan The HERS Rater shall develop a sampling plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual minimum rated feature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set via submission to the RESNET registry. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) (d), and (e) from the Sampling Plan. 603.1 Sampling Plan The following information shall be included in the Sampling Plan: Sampled Project name; Sampled Project location Sampled Project projected dates of construction; Total number of Dwelling Units, and for multifamily buildings, the number of dwelling units in each building; List of all Sampled Features and Threshold Specifications Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled. 603.2 Sampling Plan Changes The Sampling Plan shall be adjusted when the following changes are made to the Sampled Project. The List of all Sampled Features and Threshold Specifications in the Sampling Plan shall be amended as needed to reflect adjustments and additions. 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the Sampling Verification Process. 604 Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. the same construction type, same envelope systems, same number of Bedrooms, same number of stories within the unit, same window area (±10%), same Conditioned Floor Area (±10%, not to exceed ±100 ft2), and same ceiling height (±0.5 ft) are permitted to be the same unit type. Dwelling Units that satisfy these criteria, but differ in other criteria, are not required to be modeled as the same unit type. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a certified Rater shall oversee this process. 605 Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 605.2 Multifamily Unit Label Every Dwelling Unit subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This Dwelling Unit has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. Building Label If all Dwelling Units within the building are verified using the same application of the sampling protocol such that individual labels would be identical, each building (but not each dwelling unit) may be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “The residential Dwelling Units in this building have been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on an electrical panel for the building and the font shall be a minimum of 10 points. 606 Procedures for Inspections and Testing The testing and inspection of Dwelling Units for minimum rated features shall be conducted in compliance with the procedures for conducting home energy Ratings contained in the RESNET MINHERS Standards. 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set wishall be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled; 606.12 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. To qualify for sampling a builder must complete a Qualification Set. 606.12.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature prior to conducting a Qualification Set for each Sampled Feature. 606.12.2 Any feature being sampled must qualify for sampling by successfully being verified to meet the threshold specification for five (5) consecutive Sampled Features. A Qualification Set shall be made up of more than five (5) Sampled Features if a failure occurs during the qualification phase. 606.12.3 Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.12.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dwelling units without any incidence of failure. 606.12.5 Each Sampled Feature shall qualify for Sampling independently of the other Sampled Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required. 606.21 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set wishall be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled; 607 605.3 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) 1 For example, consider a 100-unit Sampled Project. The minimum quantity of Verifications for a given Sampled Feature is 100 – 10 (Qualification Set) = 90, then 90 * 0.2 = 18. Note: Qualification Set number may vary depending on failures but always requires a minimum 5 completed + 5 consecutive without failure. 6 Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Sampling Providers Raters may complete the Sampling Verifications collectively on a single dwelling unit or distribute the tests and inspections across several dwelling units within a given Sample Set, provided the total number of individual tests and inspections meets or exceeds 20%. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be representative6 of the total group of Sampled Features. Verifications shall be spread across the beginning, middle, and end of the installation timeline for each Sampled Feature. Only units that have all selected Sampled Features available for Verification at the time of inspection shall be included in the Sample Set. A Sampled Feature that does not meet its Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to the Procedures for Resolving Failures. 608 Procedure for Resolving Failures 6086.1 Failures When a Sampled Feature fails a Threshold Specification, Sampling of that feature must stop. All Failures shall be corrected and re-inspected and/or retested until they meet their Threshold Specifications. At any time, a given Sampled Feature is permitted to be removed from Sampling and every remaining instance shall be verified. 6086.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification for three (3) consecutive Sampled Features. Once a feature requalifies for Sampling, that Feature may continue being Sampled until a Failure occurs. Additional Verifications performed as a result of failures shall not count toward the required 20%. 6086.3 Documenting Failures The following items shall be documented and reported if required by program, code, or project representative. Failure reports must be maintained in the Raters records for 3 years. i. Failed feature, date, location, and result ii. Date, location, and results of requalification for Sampling 609 Quality Assurance by Sampling Providers The Sampling Provider’s QA Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. 609.1 Sampling Provider Accreditation Criteria Sampling Providers shall first be accredited by RESNET as a Rating Quality Assurance Provider in accordance with the Accreditation Process specified in Chapter 9 of these Standards and shall remain in good standing. Additionally, an applicant to become a Sampling Provider must provide the following: • Written policies and procedures explaining the Provider’s Sampling process including Quality Assurance and data management processes • Minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage After submitting an application to become a Sampling Provider, the applicant must successfully complete: • RESNET Enhanced Review of Rating QA Provider, if not completed within 12 months prior to application submittal. • RESNET QA Staff Orientation to Sampling When all requirements have been satisfied, RESNET staff shall submit the completed application to the Accreditation Committee for approval. The Sampling Provider’s first annual QA review following accreditation shall be an additional Enhanced Review, which shall demonstrate compliance with the Sampling Provider’s written policies and procedures and the requirements of this chapter. Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest.
There are sections throughout the draft with no section numbering, or where the numbering is out of order. The Qualification Set should be defined before the Sample Set.
600 General Provisions 600.1 Purpose Sampling is intended to provide verification that a group of Dwelling Units (single-family homes or multifamily dwelling units) meet a particular threshold such as ENERGY STAR®, energy code compliance, or qualification for an energy efficiency lending program. It is based on predetermined Threshold Specifications and subsequent testing and inspections of a subset of Dwelling Units. Verifying a group of Dwelling Units by Sampling entitles the customer to documentation that the Dwelling Units meet the desired threshold. Sampling does not constitute a Confirmed HERS Rating on any Dwelling Unit. 600.2 Scope This chapter sets out the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling. The procedures described in this chapter are applicable to the following Dwelling Units: (a) single family homes (attached and detached), (b) units within a multifamily building or within multiple buildings. This chapter does not provide any warranty, either explicit or implied, that sampled Dwelling Units will meet or exceed the threshold specifications for the Sample Set. There may be instances in which state laws or regulations differ from these Standards. In such instances, state law or regulation shall take precedence over this standard. 601 Eligibility The Features being Sampled shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications shall may only be applied to any projects that are within the same Community and use the same key contractors (insulation, electrical, framing, HVAC) across the Community. 602 Records Maintenance The HERS Rater must document that the project met the requirements for sampling and that each step in the sampling process has been met. This documentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s). Each inspection and/or test for each instance of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) Conformance with or failure to meet Threshold Specification, (e) Worst case model grouping. 603 Sampling Plan The HERS Rater shall develop a sampling plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual minimum rated feature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set via submission to the RESNET registry. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) (d), and (e) from the Sampling Plan. 603.1 Sampling Plan The following information shall be included in the Sampling Plan: Sampled Project name; Sampled Project location Sampled Project projected dates of construction; Total number of Dwelling Units, and for multifamily buildings, the number of dwelling units in each building; List of all Sampled Features and Threshold Specifications Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled. 603.2 Sampling Plan Changes The Sampling Plan shall be adjusted when the following changes are made to the Sampled Project. The List of all Sampled Features and Threshold Specifications in the Sampling Plan shall be amended as needed to reflect adjustments and additions. 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the Sampling Verification Process. 604 Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area. the same construction type, same envelope systems, same number of Bedrooms, same number of stories within the unit, same window area (±10%), same Conditioned Floor Area (±10%, not to exceed ±100 ft2), and same ceiling height (±0.5 ft) are permitted to be the same unit type. Dwelling Units that satisfy these criteria, but differ in other criteria, are not required to be modeled as the same unit type. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model corresponding to the individual address for that unit. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a certified Rater shall oversee this process. 605 Labeling 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 605.2 Multifamily Unit Label Every Dwelling Unit subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This Dwelling Unit has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. Building Label If all Dwelling Units within the building are verified using the same application of the sampling protocol such that individual labels would be identical, each building (but not each dwelling unit) may be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “The residential Dwelling Units in this building have been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on an electrical panel for the building and the font shall be a minimum of 10 points. 606 Procedures for Inspections and Testing The testing and inspection of Dwelling Units for minimum rated features shall be conducted in compliance with the procedures for conducting home energy Ratings contained in the RESNET MINHERS Standards. 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set wishall be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled; 606.12 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. To qualify for sampling a builder must complete a Qualification Set. 606.12.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature prior to conducting a Qualification Set for each Sampled Feature. 606.12.2 Any feature being sampled must qualify for sampling by successfully being verified to meet the threshold specification for five (5) consecutive Sampled Features. A Qualification Set shall be made up of more than five (5) Sampled Features if a failure occurs during the qualification phase. 606.12.3 Any feature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.12.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dwelling units without any incidence of failure. 606.12.5 Each Sampled Feature shall qualify for Sampling independently of the other Sampled Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required.
606.21 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to.
For each stage of construction, each Sample Set wishall be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dwelling units that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dwelling units available for that phase within a new, 90-day period applied to that phase of tests and inspections.
Each dwelling unit subject to sampling is required to be part of an identified set of Sampling Verifications for each test or inspection that is sampled;
607 605.3 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a certified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled Feature by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) 1 For example, consider a 100-unit Sampled Project. The minimum quantity of Verifications for a given Sampled Feature is 100 – 10 (Qualification Set) = 90, then 90 * 0.2 = 18. Note: Qualification Set number may vary depending on failures but always requires a minimum 5 completed + 5 consecutive without failure. 6 Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Sampling Providers Raters may complete the Sampling Verifications collectively on a single dwelling unit or distribute the tests and inspections across several dwelling units within a given Sample Set, provided the total number of individual tests and inspections meets or exceeds 20%. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be representative6 of the total group of Sampled Features. Verifications shall be spread across the beginning, middle, and end of the installation timeline for each Sampled Feature. Only units that have all selected Sampled Features available for Verification at the time of inspection shall be included in the Sample Set. A Sampled Feature that does not meet its Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to the Procedures for Resolving Failures. 608 Procedure for Resolving Failures 6086.1 Failures When a Sampled Feature fails a Threshold Specification, Sampling of that feature must stop. All Failures shall be corrected and re-inspected and/or retested until they meet their Threshold Specifications. At any time, a given Sampled Feature is permitted to be removed from Sampling and every remaining instance shall be verified. 6086.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification for three (3) consecutive Sampled Features. Once a feature requalifies for Sampling, that Feature may continue being Sampled until a Failure occurs. Additional Verifications performed as a result of failures shall not count toward the required 20%. 6086.3 Documenting Failures The following items shall be documented and reported if required by program, code, or project representative. Failure reports must be maintained in the Raters records for 3 years. i. Failed feature, date, location, and result ii. Date, location, and results of requalification for Sampling 609 Quality Assurance by Sampling Providers The Sampling Provider’s QA Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. 609.1 Sampling Provider Accreditation Criteria Sampling Providers shall first be accredited by RESNET as a Rating Quality Assurance Provider in accordance with the Accreditation Process specified in Chapter 9 of these Standards and shall remain in good standing. Additionally, an applicant to become a Sampling Provider must provide the following: • Written policies and procedures explaining the Provider’s Sampling process including Quality Assurance and data management processes • Minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage After submitting an application to become a Sampling Provider, the applicant must successfully complete: • RESNET Enhanced Review of Rating QA Provider, if not completed within 12 months prior to application submittal. • RESNET QA Staff Orientation to Sampling When all requirements have been satisfied, RESNET staff shall submit the completed application to the Accreditation Committee for approval. The Sampling Provider’s first annual QA review following accreditation shall be an additional Enhanced Review, which shall demonstrate compliance with the Sampling Provider’s written policies and procedures and the requirements of this chapter. Builders or other stakeholders cannot use Sampling to certify or qualify Dwelling Units in which they have a financial interest.
Comment #23Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Comment Intent: ObjectionComment Type: EditorialComment: I have long been philosophically opposed to sampling on single family homes. I appreciate the many hours of effort and refinement that has gone into this proposed revision but I feel I must play the role of unpopular voice in the wilderness. As I have observed the output of multiple RESNET technical committees and documents, I view the current and proposed future sampling protocol as unnecessarily complicated. In my opinion, sampling should not be permitted on single family homes. This includes visual inspections as well as verification testing. For multi-family, I would propose a maximum sample set of up to 4 units per floor. 1 in 4 sample sets simplify the math as well as how sampling is communicated throughout the industry. If it is deemed that there should be an initial "proving period", let it be set at four units and then proceed. Concepts such as root cause analysis make sense in an academic setting but needlessly complicate this already complex option for multi-family. If the tested unit in the sample set passes, the remaing (up to) 3 units are considered "deemed to comply" with that item/result. Any failure in the 1 unit being sampled shall trigger an immediate requirement for full inspection / testing of the remaining (up to) 3 units in the sample set. All deficiencies must be corrected and then the unit(s) must be subsequently inspected/tested to verify compliance. In a few sentences, i have just described the entire sampling protocol. I realize that this is an unlikely longshot but I urge the review committee to consider a completely different approach to the concept of 1 in 7 with pages and pages of annotated notes. Thank you for the opportunity to respond. Sincerely Mike Barcik
I have long been philosophically opposed to sampling on single family homes. I appreciate the many hours of effort and refinement that has gone into this proposed revision but I feel I must play the role of unpopular voice in the wilderness. As I have observed the output of multiple RESNET technical committees and documents, I view the current and proposed future sampling protocol as unnecessarily complicated.
In my opinion, sampling should not be permitted on single family homes. This includes visual inspections as well as verification testing.
For multi-family, I would propose a maximum sample set of up to 4 units per floor. 1 in 4 sample sets simplify the math as well as how sampling is communicated throughout the industry. If it is deemed that there should be an initial "proving period", let it be set at four units and then proceed. Concepts such as root cause analysis make sense in an academic setting but needlessly complicate this already complex option for multi-family.
If the tested unit in the sample set passes, the remaing (up to) 3 units are considered "deemed to comply" with that item/result. Any failure in the 1 unit being sampled shall trigger an immediate requirement for full inspection / testing of the remaining (up to) 3 units in the sample set. All deficiencies must be corrected and then the unit(s) must be subsequently inspected/tested to verify compliance.
In a few sentences, i have just described the entire sampling protocol.
I realize that this is an unlikely longshot but I urge the review committee to consider a completely different approach to the concept of 1 in 7 with pages and pages of annotated notes. Thank you for the opportunity to respond. Sincerely Mike Barcik
Comment #24Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 2Comment Intent: Not an ObjectionComment Type: TechnicalComment: The proposed standard includes a requirement that RESNET be notified by the Provider of all Sampled Projects prior to conducting the intial Qualification set. However, there is no information included about how to notify RESNET or who at RESNET to notify. If this requirement is included, it should also specify the method for the notification. An example is in the proposed change below, but RESNET will need to determine the correct method. Proposed Change: RESNET must be notified by the Provider by email sent to: sampling@resnet.us of all Sampled Projects prior to conducting the initial Qualification Set.
The proposed standard includes a requirement that RESNET be notified by the Provider of all Sampled Projects prior to conducting the intial Qualification set. However, there is no information included about how to notify RESNET or who at RESNET to notify. If this requirement is included, it should also specify the method for the notification. An example is in the proposed change below, but RESNET will need to determine the correct method.
RESNET must be notified by the Provider by email sent to: sampling@resnet.us of all Sampled Projects prior to conducting the initial Qualification Set.
Comment #25Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Sampling PlanComment Intent: Not an ObjectionComment Type: TechnicalComment: Notification to RESNET is required to "include (a), (b), (c), and (d) from the Sampling Plan." However, the section titled "Sampling Plan" does not include anything marked (a), (b), (c), or (d). This needs to be clarified so we know what must be included. Since I don't know what is meant, I will have to propose a fill-in-the-blanks for the SDC to fill in. Proposed Change: At minimum this shall include (a) _______________, (b)_______________, (c)_______________, and (d)_______________, from the Sampling Plan.
Notification to RESNET is required to "include (a), (b), (c), and (d) from the Sampling Plan." However, the section titled "Sampling Plan" does not include anything marked (a), (b), (c), or (d). This needs to be clarified so we know what must be included. Since I don't know what is meant, I will have to propose a fill-in-the-blanks for the SDC to fill in.
At minimum this shall include (a) _______________, (b)_______________, (c)_______________, and (d)_______________, from the Sampling Plan.
Comment #26Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: 603.1 Sampling PlanComment Intent: Not an ObjectionComment Type: EditorialComment: This is more of a clarification request. One of the items required in the Sampling Plan is "Adjusted sampled rate if applicable for assigning Confirmed Ratings at final". However, under 600.1 Purpose, the statement is included that, "Sampling does not constitute a Confirmed HERS Rating on any Dwelling Unit." There are options to remove units from the sampling process and perform full confirmed HERS Ratings on them, but I am thoroughly confused about how or why this would be included in a sampling plan. If the plan is to perform full ratings on a number of units, those units would not be included as part of the sampling plan since they are not being sampled. I can understand putting the 100% Pre-drywall inspection in the plan to leave open the option of confirmed ratings as the project commences, but I think the rest of this belongs under 603.2 Sampling Plan Changes. Proposed Change: 603.1 Sampling Plan The following information shall be included in the Sampling Plan: Sampled Project name; Sampled Project location Sampled Project projected dates of construction; Total number of Dwelling Units, and for multifamily buildings, the number of dwelling units in each building; List of all Sampled Features and Threshold Specifications Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identifyinclude 100% Pre-drywall inspections in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled. 603.2 Sampling Plan Changes The Sampling Plan shall be adjusted when the following changes are made to the Sampled Project. The List of all Sampled Features and Threshold Specifications in the Sampling Plan shall be amended as needed to reflect adjustments and additions. 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the Sampling Verification Process. 603.2.3 Removal of dwelling units from the sampling process to be labeled as Confirmed Ratings The Sampling Plan shall be adjusted to document the dwelling units that were removed from the sampling plan. If it is determined that dwelling units are to be removed from the sampling process and 100% Pre-Drywall inspections were not completed, the 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled.
This is more of a clarification request. One of the items required in the Sampling Plan is "Adjusted sampled rate if applicable for assigning Confirmed Ratings at final". However, under 600.1 Purpose, the statement is included that, "Sampling does not constitute a Confirmed HERS Rating on any Dwelling Unit." There are options to remove units from the sampling process and perform full confirmed HERS Ratings on them, but I am thoroughly confused about how or why this would be included in a sampling plan. If the plan is to perform full ratings on a number of units, those units would not be included as part of the sampling plan since they are not being sampled. I can understand putting the 100% Pre-drywall inspection in the plan to leave open the option of confirmed ratings as the project commences, but I think the rest of this belongs under 603.2 Sampling Plan Changes.
603.1 Sampling Plan The following information shall be included in the Sampling Plan: Sampled Project name; Sampled Project location Sampled Project projected dates of construction; Total number of Dwelling Units, and for multifamily buildings, the number of dwelling units in each building; List of all Sampled Features and Threshold Specifications Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identifyinclude 100% Pre-drywall inspections in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled. 603.2 Sampling Plan Changes The Sampling Plan shall be adjusted when the following changes are made to the Sampled Project. The List of all Sampled Features and Threshold Specifications in the Sampling Plan shall be amended as needed to reflect adjustments and additions. 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the Sampling Verification Process.
603.2.3 Removal of dwelling units from the sampling process to be labeled as Confirmed Ratings
The Sampling Plan shall be adjusted to document the dwelling units that were removed from the sampling plan.
If it is determined that dwelling units are to be removed from the sampling process and 100% Pre-Drywall inspections were not completed, the 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND
Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled.
Comment #27Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 3Paragraph / Figure / Table / Note: 603.2.1Comment Intent: ObjectionComment Type: TechnicalComment: If the Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, what happens to the sample sets that were qualified prior to the adjustment? As a simplified example, if lighting percentages were a sampled feature and the threshold was that 80% of lights would be Tier II lights, but someone messed up the order and now only 20% of lights are Tier II, so rather than fixing the issue, the decision is made to lower the threshold to 20%, do all prior sets need to be adjusted to the new index number determined by the new threshold? On the other hand, if the original threshold was 20% but Lowe's has a sale on LED's so the threshold gets adjusted to 80% for a better index number, do all prior sets need to be corrected to meet the new threshold? Do we just have another model for those that meet the new threshold vs. those that met the old threshold? This is going to be impossible to track and train and contract for - it is a moving target. I propose striking this option all together. Proposed Change: 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project.
If the Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, what happens to the sample sets that were qualified prior to the adjustment? As a simplified example, if lighting percentages were a sampled feature and the threshold was that 80% of lights would be Tier II lights, but someone messed up the order and now only 20% of lights are Tier II, so rather than fixing the issue, the decision is made to lower the threshold to 20%, do all prior sets need to be adjusted to the new index number determined by the new threshold? On the other hand, if the original threshold was 20% but Lowe's has a sale on LED's so the threshold gets adjusted to 80% for a better index number, do all prior sets need to be corrected to meet the new threshold? Do we just have another model for those that meet the new threshold vs. those that met the old threshold? This is going to be impossible to track and train and contract for - it is a moving target. I propose striking this option all together.
603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project.
Comment #28Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 3Paragraph / Figure / Table / Note: Energy ModelingComment Intent: ObjectionComment Type: GeneralComment: The section about grouping dwelling units does not take into account the window area, volume, exposed wall area, etc. I agree with Comment #19 that this should match the language used in Standard 301. Proposed Change: Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area.the same construction type, same envelope systems, same number of Bedrooms, same number of stories within the unit, same window area (±10%), same Conditioned Floor Area (±10%, not to exceed ±100 ft2), and same ceiling height (±0.5 ft).
The section about grouping dwelling units does not take into account the window area, volume, exposed wall area, etc. I agree with Comment #19 that this should match the language used in Standard 301.
Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area.the same construction type, same envelope systems, same number of Bedrooms, same number of stories within the unit, same window area (±10%), same Conditioned Floor Area (±10%, not to exceed ±100 ft2), and same ceiling height (±0.5 ft).
Comment #29Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: 605.3Comment Intent: Not an ObjectionComment Type: EditorialComment: This section contains a paragraph fragment that makes no sense. It needs to be corrected and part of it removed. The paragraph starts by stating, "The Rater shall select the instances of Sampled Features that are subject to Verification." Does this mean that the Rater does not need to verify all the Sampled Features? I believe what was meant was that the Rater selects the units in which the instances of Sampled Features will be subject to verification. The third sentence in this paragraph is a fragment and should be removed. Proposed Change: The Rater shall select the dwelling units in which the instances of Sampled Features that to be verified are subject to Verification. The selected dwelling units instances shall not be announced in advance. The instances that are selected for Verification shall be
This section contains a paragraph fragment that makes no sense. It needs to be corrected and part of it removed. The paragraph starts by stating, "The Rater shall select the instances of Sampled Features that are subject to Verification." Does this mean that the Rater does not need to verify all the Sampled Features? I believe what was meant was that the Rater selects the units in which the instances of Sampled Features will be subject to verification. The third sentence in this paragraph is a fragment and should be removed.
The Rater shall select the dwelling units in which the instances of Sampled Features that to be verified are subject to Verification. The selected dwelling units instances shall not be announced in advance. The instances that are selected for Verification shall be
Comment #30Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 6Paragraph / Figure / Table / Note: 603.1Comment Intent: Not an ObjectionComment Type: TechnicalComment: The language for "removing" units from sampling to label as Confirmed Ratings doesn't clarify how 1% field QA'ed units should be handled. Typically, a provider will select at random units that were sample-tested to perform a 1% field QA rating. Those units typically get pulled out from sampling and labeled as Confirmed Ratings. Does this mean that those units would have to be identified as early as the predrywall phase in order to choose units that had 100% of features rated? And/or would the Option 2 pathway require that sampling be increased for the number of required 1% QA/confirmed units? Proposed Change: To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled.
The language for "removing" units from sampling to label as Confirmed Ratings doesn't clarify how 1% field QA'ed units should be handled. Typically, a provider will select at random units that were sample-tested to perform a 1% field QA rating. Those units typically get pulled out from sampling and labeled as Confirmed Ratings. Does this mean that those units would have to be identified as early as the predrywall phase in order to choose units that had 100% of features rated? And/or would the Option 2 pathway require that sampling be increased for the number of required 1% QA/confirmed units?
To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of minimum rated features verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled.
Comment #31Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 8Paragraph / Figure / Table / Note: 606.1Comment Intent: Not an ObjectionComment Type: TechnicalComment: Does this 90-day construction period supercede any other suggestions (like from multifamily guidelines) that sample sets result in testing of each unique unit type, or at a minimum each worst case projected model unit type? Proposed Change: 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set will be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period.
Does this 90-day construction period supercede any other suggestions (like from multifamily guidelines) that sample sets result in testing of each unique unit type, or at a minimum each worst case projected model unit type?
606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, each Sample Set will be composed of dwelling units eligible for the applicable Sampling Verifications within a 90-calendar day period.
Comment #32Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: Footnote 6Comment Intent: Not an ObjectionComment Type: EditorialComment: 6) Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc. Is this footnote still applicable? The text section that references this footnote #6 is crossed out, and it's not mentioned anywhere else. Sample Sets section 606.1, does not say anything about this.
6) Representative selection includes but is not limited to location within a building or community, unit type, exposure, orientation, unique options, changes in construction crews, etc.
Is this footnote still applicable? The text section that references this footnote #6 is crossed out, and it's not mentioned anywhere else. Sample Sets section 606.1, does not say anything about this.
Comment #33Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 10Paragraph / Figure / Table / Note: 606.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: Clarification needed: 606.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification for three (3) consecutive Sampled Features. Please clarify if this means 3 additional sampling features need to be verified AFTER the initial failure (4 verified), or if the initial failure getting fixed and passing counts as one of those three consecutive.
Clarification needed:
606.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the threshold specification for three (3) consecutive Sampled Features.
Please clarify if this means 3 additional sampling features need to be verified AFTER the initial failure (4 verified), or if the initial failure getting fixed and passing counts as one of those three consecutive.
Comment #34Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: n/aParagraph / Figure / Table / Note: MINHERS Appendix B - Glossary of TermsComment Intent: Not an ObjectionComment Type: GeneralComment: I suggest that an edit of MINHERS Appendix B - Glossary of Terms be undertaken at the same time as this edit and includes the addition of several other definitions such as: Qualification Set, Sampled Feature, Sampling Verification Other terms should be deleted, such as: Sampling Controls; Failed Item This list is not meant to be comprehensive.
I suggest that an edit of MINHERS Appendix B - Glossary of Terms be undertaken at the same time as this edit and includes the addition of several other definitions such as:
Qualification Set, Sampled Feature, Sampling Verification
Other terms should be deleted, such as: Sampling Controls; Failed Item
This list is not meant to be comprehensive.
Comment #35Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: n/aParagraph / Figure / Table / Note: MINHERS Appendix B - Glossary of TermsComment Intent: Not an ObjectionComment Type: GeneralComment: I suggest that an edit of MINHERS Appendix B - Glossary of Terms be undertaken at the same time as this edit and includes the addition of several other definitions such as: Qualification Set, Sampled Feature, Sampling Verification Other terms should be deleted, such as: Sampling Controls; Failed Item This list is not meant to be comprehensive.
Comment #36Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5Comment Intent: Not an ObjectionComment Type: EditorialComment: There may be municipalities that have diffirent requirements. Proposed Change: 600.2 Scope This chapter sets out the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling. The procedures described in this chapter are applicable to the following Dwelling Units: (a) single family homes (attached and detached), (b) units within a multifamily building or within multiple buildings. This chapter does not provide any warranty, either explicit or implied, that sampled Dwelling Units will meet or exceed the threshold specifications for the Sample Set. There may be instances in which statelocal laws or regulations differ from these Standards. In such instances, statelocal law or regulation shall take precedence over this standard.
There may be municipalities that have diffirent requirements.
600.2 Scope This chapter sets out the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling. The procedures described in this chapter are applicable to the following Dwelling Units:
(a) single family homes (attached and detached), (b) units within a multifamily building or within multiple buildings.
This chapter does not provide any warranty, either explicit or implied, that sampled Dwelling Units will meet or exceed the threshold specifications for the Sample Set. There may be instances in which statelocal laws or regulations differ from these Standards. In such instances, statelocal law or regulation shall take precedence over this standard.
Comment #37Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 5-6Paragraph / Figure / Table / Note: 601?Comment Intent: Not an ObjectionComment Type: EditorialComment: In general, it is advisable to check all capitalized terms to make sure they are, or are intended to be, definitions. Check for “Features”, “Sampling Plan Change”, "Sampled", “Sampled Projects”, etc. If referring to another section, simply refer to that section, don’t capitalize it. Also incuding several other editorial comments. Proposed Change: Eligibility The Minimum Rated Features being Sampled for which Sampling will be applied, shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications may only be applied to any projects within the same Community. Records Maintenance The HERS Rater must document that the project met the requirements for sampling and that each step in the sampling process has beenwas met. This documentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s). Each inspection and/or test Sampling Verification for each instance of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) The Threshold Specification value and Cconformance with or failure to meet Threshold Specificationit. 603? Sampling Plan The HERS Rater shall develop a sampling plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual mMinimum rRated fFeature within Dwelling Units. RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) from the Sampling Plan. 603.1 Required information for Sampling Plan The following information shall be included in the Sampling Plan: (a) Sampled Project name; (b) Sampled Project location (c) Sampled Project projected dates of construction; (d) Total number of Dwelling Units, and for multifamily buildings, the number of buildings, the number of dwelling units in each building; (e) List of all Sampled Features and Threshold Specifications (f) Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. (g) Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of mMinimum rRated fFeatures verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled.
In general, it is advisable to check all capitalized terms to make sure they are, or are intended to be, definitions. Check for “Features”, “Sampling Plan Change”, "Sampled", “Sampled Projects”, etc. If referring to another section, simply refer to that section, don’t capitalize it.
Also incuding several other editorial comments.
Eligibility The Minimum Rated Features being Sampled for which Sampling will be applied, shall be the responsibility of one builder or developer during the entire time of construction. Sampling Verifications may only be applied to any projects within the same Community.
Records Maintenance The HERS Rater must document that the project met the requirements for sampling and that each step in the sampling process has beenwas met. This documentation shall be kept for a minimum of three years. Examples of required documentation include but are not limited to; a copy of the sampling plan, inspection checklist(s), and failure report(s).
Each inspection and/or test Sampling Verification for each instance of each Sampled Feature shall have the following information recorded: (a) Date, (b) Dwelling Unit Address, (c) Sampled Feature, and (d) The Threshold Specification value and Cconformance with or failure to meet Threshold Specificationit.
603? Sampling Plan The HERS Rater shall develop a sampling plan prior to commencing Sampling. Any changes to the Sampling Plan shall be recorded as such and must comply with Sampling Plan Change requirements. Sampling shall be applied, but not limited, to any individual mMinimum rRated fFeature within Dwelling Units.
RESNET must be notified by the Provider of all Sampled Projects prior to conducting the initial Qualification Set. RESNET need not be notified of subsequent Qualification Sets on the same project. At minimum this shall include (a), (b), (c), and (d) from the Sampling Plan.
603.1 Required information for Sampling Plan The following information shall be included in the Sampling Plan: (a) Sampled Project name; (b) Sampled Project location (c) Sampled Project projected dates of construction; (d) Total number of Dwelling Units, and for multifamily buildings, the number of buildings, the number of dwelling units in each building; (e) List of all Sampled Features and Threshold Specifications (f) Home builder or general contractor’s primary contact for Sampling; and HERS Rater contact information. (g) Adjusted sampled rate if applicable for assigning Confirmed Ratings at final To have the option to remove dwelling units from the sampling process and label as Confirmed Ratings, the Rater shall identify in the Sampling Plan one of the following two options; Option 1: 100% Pre-drywall inspection, OR Option 2: The 20% sampling rate must be increased by a percentage equal to or greater than the projected percentage of units that may be removed as confirmed. Example: If X% are projected to be removed as Confirmed Ratings, then the sampling rate shall be increased to 20%+X%. AND Only units that have 100% of mMinimum rRated fFeatures verified can be labeled as Confirmed Ratings. The removed Dwelling Units shall be labeled as Confirmed. All remaining Dwelling Units in the Project shall be labeled as Sampled.
Comment #38Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 603.2 Sampling Plan ChangesComment Intent: ObjectionComment Type: EditorialComment: Section 603.2.1 says Threshold Specifications can be changed "at any point"during sampling. This could be used to circumvent failures. As long as changes to the specified threshold still results in meeting a HERS index goal for the project, changes could be made instead of counting them as failures. In other words, failures should not become adjustments to the Threshold Specificaitons. For example, a final duct leakage threshold is set but when doing the sampled test, a unit doesn't "pass" the threshold. A quick check is done and changing the duct leakage threshold results in a one point index change, but it still qualifies for code compliance. Rather than counting as a failure, that unit type energy model and specification is changed. This doesn't hold to the Purpose spelled out in 600.1 ..."It is based on predetermined Threshold Specifications..." In this case, it is more like random testing and basing Index on the result that is found. Proposed Change: 603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. Adjustments shall not be made after a sample set has failures of the Sampled Feature. The Sampling Plan changes shall be made before being applied to the next sample set having tests or inspections for the Sample Feature. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the previous Sampling Verification Process. If an added Sampled Feature does not meet those requirements, a new Qualification Set shall be verified for the new Sampled Feature.
Section 603.2.1 says Threshold Specifications can be changed "at any point"during sampling. This could be used to circumvent failures. As long as changes to the specified threshold still results in meeting a HERS index goal for the project, changes could be made instead of counting them as failures. In other words, failures should not become adjustments to the Threshold Specificaitons.
For example, a final duct leakage threshold is set but when doing the sampled test, a unit doesn't "pass" the threshold. A quick check is done and changing the duct leakage threshold results in a one point index change, but it still qualifies for code compliance. Rather than counting as a failure, that unit type energy model and specification is changed.
This doesn't hold to the Purpose spelled out in 600.1 ..."It is based on predetermined Threshold Specifications..." In this case, it is more like random testing and basing Index on the result that is found.
603.2.1 Adjustments to Threshold Specifications The Threshold Specification for a Sampled Feature is permitted to be adjusted at any point during the application of Sampling, including during the Qualification Set for the Sampled Project. Adjustments shall not be made after a sample set has failures of the Sampled Feature. The Sampling Plan changes shall be made before being applied to the next sample set having tests or inspections for the Sample Feature. 603.2.2 Addition of a Sampled Feature A Sampled Feature is permitted to be added to the Sampled Project at any point during the application of Sampling. Any feature added must comply with the Qualification Set requirements and the previous Sampling Verification Process. If an added Sampled Feature does not meet those requirements, a new Qualification Set shall be verified for the new Sampled Feature.
Comment #39Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 604? Energy ModelingComment Intent: Not an ObjectionComment Type: EditorialComment: The ANSI/RESNET/ICC 301-2019 already defines how to do the energy modeling for sampling. Simply refer to these standards. Proposed Change: Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area.Projected Ratings, using Worst-case Configuration, shall be prepared for each Dwelling Unit type in accordance with ANSI/RESNET/ICC 301-2019 Section 5.1.4.2 through 5.1.4.4.4.3. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model Projected Ratings using Worst-case Configuration must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model , corresponding to the individual address for that unit, shall be entered in the Approved Rating Software Tool. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a cCertified Rater shall oversee this process.
The ANSI/RESNET/ICC 301-2019 already defines how to do the energy modeling for sampling. Simply refer to these standards.
Energy Modeling Dwelling Units shall be grouped for modeling purposes. All units in a group, at a minimum, shall have the same number of bedrooms and same conditioned floor area (+/- 10%). For example, a group may contain only units with a given floor plan, or it may be a group of different floor plans assuming they all have the same number of bedrooms and are within +/-10% conditioned floor area.Projected Ratings, using Worst-case Configuration, shall be prepared for each Dwelling Unit type in accordance with ANSI/RESNET/ICC 301-2019 Section 5.1.4.2 through 5.1.4.4.4.3. A Worst-Case Analysis shall be performed to determine the model with the worst-case HERS Index for the group. The Worst-Case Analysis on a given group shall consider all variations in Minimum Rated Features and Threshold Specifications and shall also consider requirements of any relevant EEP. Every Dwelling Unit shall be assigned the HERS Index Score as determined by the worst-case analysis for the corresponding group. If changes or adjustments are made to a Threshold Specification, the worst-case model Projected Ratings using Worst-case Configuration must be updated accordingly and must still represent the worst-case analysis of all units within that group. Each Dwelling Unit shall have a unique energy model , corresponding to the individual address for that unit, shall be entered in the Approved Rating Software Tool. Actual onsite Sampled Verification results for Sampled Features shall not be entered in the final Sampled Rating energy model uploaded to the RESNET Buildings Registry. Minimum Rated Features that are not Sampled, shall not be updated in the model to reflect actual onsite verifications. At a minimum, a cCertified Rater shall oversee this process.
Comment #40Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 605. LabelingComment Intent: Not an ObjectionComment Type: EditorialComment: ANSI/RESNET/ICC 301-2019 already addresses labeling. Refer to those sections instead of rewriting. Proposed Change: 605 Labeling All rated Dwelling Units shall be labeled in accordance with Section 5.1.4.4.6 and Section 5.3 of the ANSI/RESNET/ICC 301-2019 Standard or in the case of multi-family buildings per Sections 605.1 of this Chapter. Labels shall be a minimum font size of 10 points. 605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 605.21 Multifamily Unit Label Every Dwelling Unit subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This Dwelling Unit has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. Building Label If all Dwelling Units within the building are verified using the same application of the sampling protocol such that individual labels would be identical, each building (but not each dDwelling uUnit) may be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “The residential Dwelling Units in this building have been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” in addition to the labeling requirements of Section 5.3 of the ANSI/RESNET/ICC 301-2019 Standard. This label shall be located on an electrical panel for the building and the font shall be a minimum of 10 points.
ANSI/RESNET/ICC 301-2019 already addresses labeling. Refer to those sections instead of rewriting.
605 Labeling All rated Dwelling Units shall be labeled in accordance with Section 5.1.4.4.6 and Section 5.3 of the ANSI/RESNET/ICC 301-2019 Standard or in the case of multi-family buildings per Sections 605.1 of this Chapter. Labels shall be a minimum font size of 10 points.
605.1 Single Family Every home subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This home has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 605.21 Multifamily Unit Label Every Dwelling Unit subject to this Sampling Standard shall be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “This Dwelling Unit has been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” This label shall be located on the electrical panel and the font shall be a minimum of 10 points. Building Label If all Dwelling Units within the building are verified using the same application of the sampling protocol such that individual labels would be identical, each building (but not each dDwelling uUnit) may be provided with a label in accordance with Section 604 of these standards, which contains the following statement: “The residential Dwelling Units in this building have been verified using the sampling protocol specified in Chapter 6 of the RESNET Standards (see www.resnet.us).” in addition to the labeling requirements of Section 5.3 of the ANSI/RESNET/ICC 301-2019 Standard. This label shall be located on an electrical panel for the building and the font shall be a minimum of 10 points.
Comment #41Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 8Paragraph / Figure / Table / Note: 606? Procedures for Inspections and TestingComment Intent: Not an ObjectionComment Type: EditorialComment: Definitions should be done in Appendix B, not in the body of the Standard. See comment #34. The term Sampled Feature is being used to describe features that are not yet sampled. Edits shown do not reflect the opinion that the order of these topics should be reversed: Sampling Plan, Energy Modeling, Inspections and Testing, Resolving Failures, Labeling, Quality Assurance would be a preferred order. Proposed Change: 606 Procedures for Inspections and Testing The testing and inspection of Dwelling Units for mMinimum rRated fFeatures shall be conducted in compliance with the procedures for conducting home eEnergy Ratings contained in the RESNET MINHERS Standards. 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, eEach Sample Set will be composed of dDwelling uUnits eligible for the applicable same Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dDwelling uUnits that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dDwelling uUnits available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dDwelling uUnit subject to sampling is required to be part of an identified Sample sSet of Sampling Verifications for each test or inspection that is sampledSampled Feature or phase of construction; 606.2 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. (This should be in the Sampling Plan section) To qualify for sampling a builder must complete a Qualification Set. 606.2.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each SampledMinimum Rated Feature prior to conducting a Qualification Set for each Sampled Feature. 606.2.2 Any feature being sampled must qualify for sampling by successfully being To qualify for Sampling, a Minimum Rated Feature must be verified to meet the predetermined threshold specification for five (5) consecutive Sampled FeaturesDwelling Units. A Qualification Set shall be made up of more than five (5) Sampled FeaturesDwelling Units if a failure occurs during the qualification phase. 606.2.3 Any Minimum Rated fFeature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.2.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dDwelling uUnits without any incidence of failure. 606.2.5 Each SampledMinimum Rated Feature shall qualify for Sampling independently of the other SampledMinimum Rated Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required.
Definitions should be done in Appendix B, not in the body of the Standard. See comment #34.
The term Sampled Feature is being used to describe features that are not yet sampled.
Edits shown do not reflect the opinion that the order of these topics should be reversed: Sampling Plan, Energy Modeling, Inspections and Testing, Resolving Failures, Labeling, Quality Assurance would be a preferred order.
606 Procedures for Inspections and Testing The testing and inspection of Dwelling Units for mMinimum rRated fFeatures shall be conducted in compliance with the procedures for conducting home eEnergy Ratings contained in the RESNET MINHERS Standards. 606.1 Sample Set A group of Dwelling Units at the same stage of construction (e.g. pre-drywall, final) within a 90-day period that the sampling rate is applied to. For each stage of construction, eEach Sample Set will be composed of dDwelling uUnits eligible for the applicable same Sampling Verifications within a 90-calendar day period. For example: a Sample Set that is defined for a predrywall inspection must include dDwelling uUnits that are eligible for that pre-drywall inspection within a given 90-day period. If fewer than five (5) dwelling units are available for that phase of inspection, the Sample Set must be cut off at the number of dwelling units that are available within that 90-day period. This Sample Set need not be carried through to final inspection; in fact, a whole new Sample Set may be defined for the final inspection phase based on the dDwelling uUnits available for that phase within a new, 90-day period applied to that phase of tests and inspections. Each dDwelling uUnit subject to sampling is required to be part of an identified Sample sSet of Sampling Verifications for each test or inspection that is sampledSampled Feature or phase of construction; 606.2 Qualification Set Sampling shall be conducted in accordance with the Sampling Plan. (This should be in the Sampling Plan section) To qualify for sampling a builder must complete a Qualification Set. 606.2.1 A builder or developer shall complete and have verified the installation of a minimum of five (5) of each SampledMinimum Rated Feature prior to conducting a Qualification Set for each Sampled Feature. 606.2.2 Any feature being sampled must qualify for sampling by successfully being To qualify for Sampling, a Minimum Rated Feature must be verified to meet the predetermined threshold specification for five (5) consecutive Sampled FeaturesDwelling Units. A Qualification Set shall be made up of more than five (5) Sampled FeaturesDwelling Units if a failure occurs during the qualification phase. 606.2.3 Any Minimum Rated fFeature that fails to meet the Threshold Specification shall be corrected and re-inspected and/or retested until it meets the Threshold Specification. 606.2.4 Sampling shall begin only after the Threshold Specifications have been verified in five (5) consecutive dDwelling uUnits without any incidence of failure. 606.2.5 Each SampledMinimum Rated Feature shall qualify for Sampling independently of the other SampledMinimum Rated Features. The Qualification Set, and any Dwelling Units tested prior to the Qualification Set, are not part of a Sampling Set and shall not count toward the minimum quantity of Sampling Verifications required.
Comment #42Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 9Paragraph / Figure / Table / Note: Sampling Verification ProcessComment Intent: Not an ObjectionComment Type: EditorialComment:Proposed Change: 605.3 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a cCertified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled FeatureDwelling Units in the Sample Set by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.) Sampling Providers may complete the Sampling Verifications may be completed collectively on a single dDwelling uUnit or distributed the tests and inspections across several dDwelling uUnits within a given Sample Set, provided the total number of individual tests and inspectionsSampling Verifications meets or exceeds 20% and the 90-calendar day rule is maintained. All Sampled Features shall be verified, at least once, for each unit type. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be A Sampled Feature that does not meet its predetermined Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to Section...the Procedures for Resolving Failures.
605.3 Sampling Verification Process A complete set of Sampling Verifications shall be performed at a minimum rate of twenty percent (20%) within a given Sample Set. At a minimum, a cCertified Rater shall oversee this process. The minimum quantity of Sampling Verifications for each Sampled Feature within a Sampled Set shall be calculated by multiplying the number of instances of each Sampled FeatureDwelling Units in the Sample Set by 20% and rounding the result up to the nearest whole number.1 (Projects containing less than 12 units would not benefit from the sampling process.)
Sampling Providers may complete the Sampling Verifications may be completed collectively on a single dDwelling uUnit or distributed the tests and inspections across several dDwelling uUnits within a given Sample Set, provided the total number of individual tests and inspectionsSampling Verifications meets or exceeds 20% and the 90-calendar day rule is maintained. All Sampled Features shall be verified, at least once, for each unit type. The Rater shall select the instances of Sampled Features that are subject to Verification. The selected instances shall not be announced in advance. The instances that are selected for Verification shall be
A Sampled Feature that does not meet its predetermined Threshold Specification is a Failure. Sampling is permitted to continue for each Sampled Feature until a Failure occurs. All Failures shall be addressed according to Section...the Procedures for Resolving Failures.
Comment #43Amendment: Proposed MINHERS Addendum 46, Sampling, Draft PDS-01Page Number: 10Paragraph / Figure / Table / Note: 606.2? Requalifying for SamplingComment Intent: Not an ObjectionComment Type: EditorialComment:Proposed Change: 606.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the tThreshold sSpecification for three (3) consecutive Sampled FeaturesDwelling Units. Once a feature requalifies for Sampling, that Feature may continue being Sampled until a Failure occurs. Additional Verifications performed as a result of failures shall not count toward the required 20%.
606.2 Requalifying for Sampling Once a Sampled Feature fails, it must requalify for sampling by successfully being verified to meet the tThreshold sSpecification for three (3) consecutive Sampled FeaturesDwelling Units. Once a feature requalifies for Sampling, that Feature may continue being Sampled until a Failure occurs. Additional Verifications performed as a result of failures shall not count toward the required 20%.
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