Draft Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 1
Comment Type: General

Comment:

Enough regulation...STOP...You change them faster than anyone can learn them...STOP

Even the info you ask preliminary to the survey is not necessary as yiou will do NOTHING with it.

STOP REGULATING!!!

Proposed Change:

QUIT it!!!

Response:
Rejected. The comment made by this commentator is not specific to BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #2

Page Number: 61
Paragraph / Figure / Table / Note: 6.3.4
Comment Type: Technical

Comment:

Section 6 and the Normative annexes of the proposed standard include software varification criteria for all software tests exceptfor the ASHRAE Standard 140 tests. Rather than reference an outdated source (HERS BESTEST) for these software verification test criteria, the standard should include the criteria directly in the standard. A number of editorial changes are also proposed to specify the date of the ASHRAE Standard and to clean up the existing language to include the verification criteria for these tests.

Proposed Change:

6.3.4. ANSI/ASHRAE Standard 140, Class II, Tier 1 Tests. ~~ASHRAE Standard 140, Class II Tests were developed from the HERS BESTEST1 for testing the accuracy of simulation software for predicting building loads.~~ The ANSI/ASHRAE Standard 140-2011, Class II, Tier 1 test procedure ~~has been adopted by RESNET and~~ is a requirement for all software programs to be accredited. The acceptance criteria for this test suite are as specified in Tables 4-1 and 4-2 of the original HERS BESTEST document “Home Energy Rating System Building Energy Simulation Test (HERS BESTEST) – Volume 2, Tier 1 Test Reference Results” by R. Judkoff and J. Neymark, as published by the National Renewable Energy Laboratory, Golden, Colorado, Report No. NREL/TP-472-7332b, November 1995. This document may be found online at: http://www.nrel.gov/docs/legosti/fy96/7332b.pdf developed in accordance with Annex 22 of ANSI/ASHRAE Standard 140-2011and are as follows:

Annual Heating Loads:
Colorado Springs, CO
Heating    range max    range min
L100AC             79.48            48.75
L110AC           103.99            71.88
L120AC             64.30            37.82
L130AC             53.98            41.82
L140AC             56.48            43.24
L150AC             71.33            40.95
L155AC             74.18            43.53
L160AC             81.00            48.78
L170AC 92.40            61.03
L200AC           185.87          106.41
L202AC           190.05          111.32
L302XC             90.52            52.66
L304XC             75.32            43.91
L322XC           118.20            68.35
L324XC             80.04            44.01

Annual Heating Load deltas:
Colorado Springs, CO
Heating                  range max          range min
L110AC-L100AC           28.12                  19.37
L120AC-L100AC            -7.67    -18.57
L130AC-L100AC    -5.97                -27.50
L140AC-L100AC    -4.56    -24.42
L150AC-L100AC    -3.02    -12.53
L155AC-L150AC             6.88 -1.54
L160AC-L100AC             5.10 -3.72
L170AC-L100AC           17.64                    7.12
L200AC-L100AC         107.66 56.39
L202AC-L200AC             9.94 -0.51
L302XC-L100AC           14.50 -3.30
L302XC-L304XC           17.75    5.66
L322XC-L100AC           39.29    15.71
L322XC-L324XC           38.27    20.21

Annual Cooling Loads:
Las Vegas, NV
Cooling    range max    range min
L100AL             64.88            50.66
L110AL             68.50    53.70
L120AL             60.14            47.34
L130AL             45.26            32.95
L140AL             30.54            19.52
L150AL 82.33            62.41
L155AL             63.06    50.08
L160AL             72.99            58.61
L170AL             53.31    41.83
L200AL             83.43            60.25
L202AL             75.96            52.32

Annual Cooling Load deltas:
Las Vegas, NV
Cooling                range max    range min
L110AL-L100AL             7.84 -0.98
L120AL-L100AL             0.68 -8.67
L130AL-L100AL -13.71           -24.40
L140AL-L100AL -27.14 -38.68
L150AL-L100AL    20.55       8.72
L155AL-L150AL -9.64 -22.29
L160AL-L100AL          12.28 3.88
L170AL-L100AL           -4.83 -15.74
L200AL-L100AL          21.39       6.63
L200AL-L202AL          14.86             2.03

Response:
Rejected. Software accreditation and software verification testing will be removed from this standard because it is not included in the Title, Purpose and Scope of the BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #3

Page Number: 15
Paragraph / Figure / Table / Note: Table 4.2.2.1
Comment Type: Technical

Comment:

The proposed change is to incorporate the Board of Director's Interpretation on service hot water heaters into Standard 301 adn remove it from the standard interpretation list.

Proposed Change:

[Add additional footnote (p)and strike extraneous “Same as Rated Home” item under Rated Home column]

Building Component

HERS Reference Home

Rated Home

Service water heating systems ^{(h) (m) (p)}

Fuel type: same as Rated Home

Efficiency

Electric: EF = 0.97 - (0.00132 * store gal)

Fossil fuel: EF = 0.67 - (0.0019 * store gal)

Use (gal/day): 30*N_du + 10*N_br
where N_du = number of dwelling units

Tank temperature: 120 F

Same as Rated Home ^(m)

Same as Rated Home

Same as Rated Home

~~Same as Rated Home~~

Same as HERS Reference Home

(p) Raters are expected to obtain Energy Factors (EF) for domestic hot water equipment directly from manufacturer’s literature or from AHRI directory for equipment being used. For instances where a manufacturer provided or AHRI published EF does not exist (e.g. commercial water heaters), the rater shall use the guidance provided here to determine the effective EF of ht water heater.

i. For conventional residential (oil, gas and electric) water heaters or heat pump, use default EF values provided in Table 4.4.2(3) for age-based efficiency or Table 4.4.2(4) for non-age-based efficiency.

ii. For commercial water heaters used in residential applications, one of the following approaches shall be followed to determine the EF for a particular piece of equipment.

a. Use the commercial hot water system calculator posted on the RESNET web site.

b. Use Table C404.2 Minimum Performance of Water Heating Equipment in the 2012 International Energy Conservation Code to find the minimum requirement for the type of water heater.

Response:
Accepted as modified. Proposed changes will be made to the draft.

Comment #4

Page Number: 2
Paragraph / Figure / Table / Note: Definitions
Comment Type: Technical

Comment:

The definition of Conditined Floor Area should be modified to reflect the Board of Director's Interpretation on Conditioned Floor Area

Proposed Change:

Conditioned fFloor aArea (CFA) – The ~~finished~~ floor area in square feet of a home that is conditioned by heating or cooling systems, measured in accordance with ANSI Standard Z765-2003 with exceptions as specified in Appendix A of the RESNET Mortgage Industry National Home Energy Rating Systems Standards.

CFA includes:

i. All finished space within the conditioned space boundary (i.e. within the insulated envelope), regardless of HVAC configuration. CFA includes

ii. Unfinished spaces that are directly conditioned (i.e. having fully ducted HVAC supply or other intentional heating or cooling source).

CFA does not include:

i. Spaces such as insulated basements or attics that are unfinished and not directly conditioned

ii. Heated garages.

Response:

Accepted as modified (see also comment #72). The definition of Conditioned Floor Area (CFA) will be modified as follows:

Conditioned Floor Area (CFA) – The projected floor area of the Conditioned Space within a building measured in accordance with ANSI Standard Z765-2012 with exceptions as specified in Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards.

Comment #5

Page Number: 13 and following
Paragraph / Figure / Table / Note: Table 4.2.2(1)
Comment Type: Technical

Comment:

RESNET Board of Directors Interpretations 2006-003, 2006-004 and 2007-002 all address air exchange rate and mechanical ventilation in the Reference and Rated Homes. Additionally, ASHRAE has recently adopted addenda 'n' and 'r' to ANSI/ASHRAE Standard 62.2-2010, which alter the methods by which mechanical ventilation requirements are calculated, considering natural infiltration in combination with mechanical ventilation. This proposed change brings the RESNET Draft Standard 301 into alignment with these recent changes, updates all references to the ASHRAE Handbook of Fundamentals to the most recent edition and incorporates the above Board of Directors Interpretations on this matter.

Proposed Change:

[Modify Air exchange rate and Mechanical ventilation in Table 4.2.2(1) and Table notes (d), (e) and (f) as follows:]

Air exchange rate

Specific Leakage Area (SLA) ^(d) = 0.00036 (assuming no energy recovery)

For residences that are not tested, the same as the HERS Reference Home

For residences ~~without mechanical ventilation~~ systems that are tested in accordance with ~~ASHRAE Standard 119, Section 5.1~~Chapter 802 of the RESNET Standards, without mechanical ventilation systems, the measured air exchange rate ^(e)but not less than 0.30 ach

For residences ~~with mechanical ventilation systems that are~~ tested in accordance with ~~ASHRAE Standard 119, Section 5.1~~ Chapter 802 of the RESNET Standards, with mechanical ventilation systems, the measured air exchange rate ^(e)combined with the mechanical ventilation rate,^(f) which shall not be less than ~~0.01~~0.03 x CFA + 7.5 x (Nbr+1) cfm

Mechanical ventilation:

None, except where a mechanical ventilation system is specified by the Rated Home, in which case:

Annual vent fan energy use:

kWh/yr = ~~0.03942*CFA + 29.565*(N_br+1) (per dwelling unit)~~0.5*(supVfan + exhVfan)*8.76

where:

~~CFA = conditioned floor area~~

~~N_{br =}number of bedrooms~~

supVfan = cfm of supply ventilation fan

exhVfan = cfm of exhaust ventilation fan

where supVfan and exhVfan are calculated in accordance with ANSI/ASHRAE Standard 62.2-2010, addendum ‘r’

Same as Rated Home

(d) Where Effective Leakage Area (ELA) is defined in accordance with Section ~~5.1~~4.12 of ASHRAE Standard ~~119~~62.2-2010, addendum ‘r’ and where SLA = ELA / CFA (where ELA and CFA are in the same units). Either hourly calculations using the procedures given in the ~~2001~~2009 ASHRAE Handbook of Fundamentals, Chapter 2616, page ~~26.21~~16.23, equation 40(48) (Sherman-Grimsrud model) using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the energy loads resulting from air exchange.

(e) Tested envelope leakage shall be determined and documented by a Certified Rater using the on-site inspection protocol as specified in ~~Appendix A~~Section 802, Mortgage Industry National Home Energy Rating Systems Standards. ~~under “Blower Door Test.”~~ Either hourly calculations using the procedures given in the ~~2001~~2009 ASHRAE Handbook of Fundamentals, Chapter 2616, page ~~26.21~~16.23, equation 40(48) (Sherman-Grimsrud model) using Shelter Class 4 or calculations yielding equivalent results shall be used to determine the energy loads resulting from air exchange.

(f) The combined air exchange rate for infiltration and mechanical ventilation shall be determined in accordance with equation 43(51) of ~~2001~~2009 ASHRAE Handbook of Fundamentals page ~~26.24~~16.25 in combination with the ~~”Whole-house Ventilation”~~ Section 4 provisions of ~~2001~~ ANSI/ASHRAE Standard 62.2-2010, addendum ‘r’ ~~Handbook of Fundamentals, page 26.19 for intermittent mechanical ventilation~~.

Response:
Accepted as modified. Proposed changes per comment #42 will be made to the draft.

Comment #6

Page Number: 15 and 19
Paragraph / Figure / Table / Note: Table 4.2.2(1)
Comment Type: Technical

Comment:

Board of Directors Interpretation 2006-002 addresses Thermal distribution systems in Table 4.2.2(1) and Table note (n) in an attempt to clarify and simplify the ASHRAE Standard 152 distribution system testing procedures. Since the adoption of this Interpretation by the Board, Section 803 of the RESNET Standards has effectively superseded the Standard 152 distribution system testing procedures. This proposed change to the RESNET Draft Standard 301 replaces the reference to ASHRAE Standard 152 with reference to Section 803 of the RESNET Standards. Additionally, there have been numerous complaints regarding the interpretation, use and misuse of Table 4.2.2(4), so this proposed change also deletes this table in its entirety, specifying the DSE for ductless and hydronic distribution systems directly in Table 4.2.2(1) instead.

Proposed Change:

[Modify Table 4.2.2(1) as follows:]

Thermal distribution systems:

A thermal distribution system efficiency (DSE) of 0.80 shall be applied to both the heating and cooling system efficiencies.

~~As specified by Table 4.2.2(4)~~For forced air distribution systems: same as Reference Home, except when tested in accordance with ~~ASHRAE Standard 152-2004~~Section 803 of the RESNET Standards ⁽ⁿ⁾, and then either calculated through hourly simulation or calculated in accordance with ASHRAE Standard 152-2004 with the ducts located and insulated as in Rated Home

For ductless distribution systems: DSE=1.00

For Hydronic distribution systems: DSE=1.00

[Modify Table not (n) as follows:]

(n) Tested duct leakage shall be determined and documented by a Certified Rater using the on-site inspection protocol as specified in ~~Appendix A under “Air leakage (ducts)”~~Section 803of the Mortgage Industry National Home Energy Rating System Standards (the RESNET Standards).

[Delete Table 4.2.2(4) and its notes in their entirety]

Table 4.2.2(4). Default Distribution System Efficiencies for Inspected Systems ^(a)
~~Distribution System Configuration and Condition~~:	~~Forced Air Systems~~	~~Hydronic Systems ^(b)~~
~~Distribution system components located in unconditioned space~~	~~0.80~~	~~0.95~~
~~Distribution systems entirely located in conditioned space ^(c)~~	~~0.88~~	~~1.00~~
~~Proposed “reduced leakage” with entire air distribution system located in the conditioned space ^(d)~~	~~0.96~~
~~Proposed “reduced leakage” air distribution system with components located in the unconditioned space^(d)~~	~~0.88~~
~~“Ductless” systems ^(e)~~	~~1.00~~

~~Table 4.2.2(4) Notes:~~

~~(a) Default values given by this table are for distribution systems as rated, which meet minimum IECC 2000 requirements for duct system insulation.~~

(b) Hydronic Systems shall mean those systems that distribute heating and cooling energy directly to individual spaces using liquids pumped through closed loop piping and that do not depend on ducted, forced air flows to maintain space temperatures.

~~(c) Entire system in conditioned space shall mean that no component of the distribution system, including the air handler unit or boiler, is located outside of the conditioned space boundary.~~

(d) Proposed “reduced leakage” shall mean substantially leak free to be leakage of not greater than 3 cfm to outdoors per 100 square feet of conditioned floor area and not greater than 9 cfm total air leakage per 100 square feet of conditioned floor area at a pressure differential of 25 Pascal across the entire system, including the manufacturer’s air handler enclosure. Total air leakage of not greater than 3 cfm per 100 square feet of conditioned floor area at a pressure difference of 25 Pascal across the entire system, including the manufacturer’s air handler enclosure, shall be deemed to meet this requirement without measurement of air leakage to outdoors. This rated condition shall be specified as the required performance in the construction documents and requires confirmation through field-testing of installed systems as documented by a Certified Rater.

~~(e) Ductless systems may have forced airflow across a coil but shall not have any ducted airflows external to the manufacturer’s air handler enclosure.~~

Response:
Accepted. The proposed language will be incorporated into BSR/RESNET Standard 301-201x.

Comment #7

Page Number: na
Comment Type: General

Comment:

My comments are limited to just energy performance related to the plumbing system itself and, more specifically to what’s between the water heater and the hot water fixtures – namely the pipe itself.

ENERGY STAR has delivered ever-increasing performance with water heating products. WaterSense has done a good job, thus far, with hot water fixtures. There appears to be no initiative to address energy efficiency with respect to the pipe in between hence defining the plumbing system. In short, I believe an opportunity is being ignored.

Below is from a parametric analysis I did during 2009-2011 on 8700 homes with standard plumbing; 3600 homes with dedicated hot water recirculation loops incorporating timer pumps in terms of wasted energy and wasted water. Waste was defined as “water down the drain which had previously been heated while waiting for hot water for current use.” The values are community specific but useful for comparative purposes. The values are annualized and represent the waste in the plumbing system for one housing unit.

Wasted energy, $ Wasted water, gal CO2 emissions, lb

Standard plumbing
EWH $171 8800 1700
GWH 109 8800 780

Dedicated loop/timer (weighted avg)
EWH 384 5000 3780
GWH 253 5000 1810

Demand controlled pump
EWH 72 1200 700
GWH 46 1200 330

The table above reeks of opportunity for demand controlled pump solutions especially as retrofits for standard plumbed existing homes of which 90M owner occupied currently exists today.

As to the dedicated loop/timer pump systems for this community, it has now been recognized that good intentions resulted in unintended consequences and revised plumbing codes are under review.

As to new residential construction a number of analyses have been conducted which clearly demonstrate a demand controlled pump including installation and included in a new mortgage will result in a net decrease in monthly home ownership expenses due to the reduced water and energy expenses provided by a demand controlled pump installation. Take this one step further: why wouldn't a government insured new home mortgage, via Freddie Mac or Fannie Mae, not require a demand controlled pump in such a new insured mortgage? Why would this be important? DOE and EPA, both, are working on energy (and water) reduction policy; so why shouldn't a quasi-federal agency also be involved?

In summary: there is low hanging fruit with respect to addressing the plumbing system. Energy is energy whether saved by a more efficient dishwasher, refrigerator, HVAC and properly designed plumbing system.

My apologies for the length of the comment.

Response:
Rejected. The comment does not make a proposed change to BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #8

Page Number: 11
Comment Type: General

Comment:

Calculating the HERS score must include duct testing and infiltration testing via blower door. The 2012 codes require such testing and an accurate HERS score needs to require field testing to be a valid indicator of energy efficiency use for comparison purposes.

Response:
Accepted. BSR/RESNET Standard 301-201X will be modified to require testing of envelope leakage and air distribution system leakage for Confirmed Ratings. The definition of a confirmed rating will be revised as follows.

“Confirmed Rating – A Rating Type accomplished using the actual data gathered from an on-site audit inspection and~~, if required,~~ performance testing of the physical building and its installed systems ~~and equipment~~ including, at a minimum, air distributions system testing and envelope leakage testing.”

Comment #9

Page Number: 1
Comment Type: General

Comment:

My comment is on the label for certifing the energy performance of a home. In discussions with builders, remodelers, and other profesionals in the residential construction industry, they are all asking for the same thing when it comes to a label - predicted annual energy costs, and annual energy consumption information compared to a baseline. People in the environmental industry would like to see a carbon dioxide equivalent figure as well, which I feel is worth including.

In addition, above-code programs like LEED, which compare not just the energy performance of a house to the same house built to local code, but one home to another, see an annual energy metric (or absolute energy metric) as better suiting our needs. Even EPA went away from the static HERS Index target for ENERGY STAR for Homes. I fervently believe it is in RESNET's best interest to create a calculation methodology based on annual energy consumption to complement the HERS Index, which can be done using the same inputs as the HERS Index, just a different output.

Proposed Change:

Create an annual energy metric (or absolute energy metric) for labeling new and existing homes.

Create protocols for including the consumption of pools, spas, heated driveways, heated garages and other large permanently installed energy users that currently aren't included in the HERS Index and annual energy metric.

Response:
Noted. BSR/RESNET Standard 301-201x already requires the reporting of annual energy use and annual energy cost so it is not clear what change the commentator is seeking in this regard. The creation of protocols for evaluating the energy consumption of additional components of a home is beyond the scope of this public review but rather is an on-going effort within the energy rating community, which when completed will likely become a proposed revision to this Standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #10

Page Number: Entire document
Comment Type: General

Comment:

This standard is proposing the use of Source Energy efficiency at a predetermined efficiency level. We feel using source energy is very biased and inaccurate and will unfairly rate standard electric heating options as being inefficient causing an unacceptable HERS score.

Electric generation comes from many forms including nuclear, fuel, coal, natural gas, wind, hydro, solar, biomass, etc. The generation mix varies from region to regions, state to state and even county to county in some areas. In some areas, nearly 100% of power is generated with non-fossil sources and the efficiency is very high. Using an average national efficiency for rating HVAC equipment would at best be highly inaccurate. Additionally, there is a rapidly growing amount of renewable energy in our country and electric heating systems provide a very efficient means of utlizing this power while also providing other critical needs of the electric grid.

We propose that appliance energy efficiency rating be used at the point of energy delivery (site energy efficiency). The consumer can control and maximize efficiency at this level; however, can not control how energy production occurs outside his home. This also would create a level and fair basis for all HVAC and general purpose appliances in the home.

Proposed Change:

Use site energy efficiency references for HVAC appliances rather than source energy efficiency.

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #11

Page Number: 14
Paragraph / Figure / Table / Note: 4.2.2(1) and 4.2.2(1a)
Comment Type: Technical

Comment:

Currently air source heat pumps are used as the base reference for electric heating systems. Using this approach discriminates against many very beneficial and effiecient electric heating systems which benefit consumers, utilities and society. We propose that standard electric resistance heating systems be used as the baseline (including electric thermal storage devices) with appliance efficiency requirements of 100%.

Proposed Change:

Table 4.2.2(1)

Electric: ~~air source heat pump~~ electric resistance heat in accordance with Table 4.2.2(1a)

Table 4.2.2(1)

~~7.7 HSPF air source heat pump~~ electric resistance heating 100% eff.

Comment #12

Page Number: New normative annex
Comment Type: Technical

Comment:

We propose for the RESNET Standard 301 (RESNET PDS 301-01) to include a new normative annex for the 2009 IECC Standard Design Auto-Generation Tests in addition to the existing Annex C – 2006 IECC Standard Design Auto-Generation Tests. The justification for the need of the proposed annex is that many states now have adopted the 2009 IECC as their energy code for new residential construction; and consequently, there are IECC performance path calculation tools available that provide an option for 2009 IECC code compliance.

Proposed Change:

2009 IECC Standard Design Auto-Generation Tests

(Normative)

This normative Annex contains the Reference Home auto-generation test suite for 2009 IECC performance compliance tools. The test cases in this proposed test suite are designed to verify that software tools automatically generate accurate Standard Reference Designs given only the building information from the Proposed Homes.

Minimum Reporting Requirements

Software tools applying for verification shall provide evidence that their software meets the requirements of this test suite. The software tool provider or software vendor is responsible for producing the documentation needed to show that the software has been verified through this test suite. In some cases, the data needed to verify accuracy is of no interest or value to the end-user of the software, but in any case, the software tool must generate it. At a minimum, software tools applying for accreditation must report the following values for the Reference Home:

Areas and overall U-factors (or R-values in the case of slab-on-grade construction) for all building components, including ceilings, walls, floors, windows (by orientation) and doors.
Overall solar-heat gain coefficient (SHGC_o)[1] of the windows during heating.
Overall solar-heat gain coefficient (SHGC_o) of the windows during cooling.
Wall solar absorptance and infrared emittance
Roof solar absorptance and infrared emittance
Total internal gains to the home (Btu/day)
Specific leakage area (SLA) for the building, by zone or as SLA_o[2], as appropriate
Attic net free ventilation area (ft²)
Crawlspace net free ventilation area (ft²), if appropriate
Exposed masonry floor area and carpet and pad R-value, if appropriate
Heating system labeled ratings, including AFUE, COP, or HSPF, as appropriate.
Cooling system labeled ratings, including SEER or EER, as appropriate.
Thermostat schedule for heating and cooling
Air distribution system characteristics, including locations of all supply and return ducts and the air handler units, supply and return duct R-values, and supply and return duct air leakage values (in cfm₂₅).[3]
Mechanical ventilation kWh/yr, if appropriate

Software tools must have the ability to recreate or store the test case Standard Reference Designs as if they were Proposed Homes such that they also can be simulated and evaluated as the Proposed Homes.

Auto-generation Test Case Descriptions

Test Case1. HERS BESTEST case L100 building configured as specified in the HERS BESTEST procedures, located in Baltimore, MD, including a total of 3 bedrooms and the following mechanical equipment: gas furnace with AFUE = 82% and central air conditioning with SEER = 16.0.

Test Case 2. HERS BESTEST case L100 configured on an un-vented crawlspace with R-7 crawlspace wall insulation, located in Dallas, TX, including a total of 3 bedrooms and the following mechanical equipment: electric heat pump with HSPF = 8.2 and SEER = 15.0.

Test Case 3. HERS BESTEST case L304 in Miami, configured as specified in the HERS BESTEST procedures, located in Miami, FL, including a total of 2 bedrooms and the following mechanical equipment: electric strip heating with COP = 1.0 and central air conditioner with SEER = 17.0.

Test Case 4. HERS BESTEST case L324 configured as specified as in the HERS BESTEST procedures, located in Colorado Springs, CO, including a total of 4 bedrooms and the following mechanical equipment: gas furnace with AFUE = 95% and no air conditioning.

Test Case 5. Recreate or store the Reference Homes created in Tests 1 through 4 as Rated Homes and simulate and evaluate them.

Acceptance Criteria

Test Cases 1 – 4.

For test cases 1 through 4 the values contained in Table C-1 shall be used as the acceptance criteria for software tool accreditation. For Standard Reference Design building components marked by an asterisk (*), the acceptance criteria may include a range equal to ± 0.05% of the listed value. For all other Reference Home components the listed values are exact.

Table C-1 Acceptance Criteria for Test Cases 1 – 4

Reference Home Building Component	Test 1	Test 2	Test 3	Test 4
Above-grade walls (U_o)	0.082	0.082	0.082	0.057
Above-grade wall solar absorptance (α)	0.75	0.75	0.75	0.75
Above-grade wall infrared emittance (ε)	0.90	0.90	0.90	0.90
Basement walls (U_o)	n/a	n/a	n/a	0.059
Above-grade floors (U_o)	0.047	0.047	n/a	n/a
Slab insulation R-Value	n/a	n/a	0	0
Ceilings (U_o)	0.030	0.035	0.035	0.030
Roof solar absorptance (α)	0.75	0.75	0.75	0.75
Roof infrared emittance (ε)	0.90	0.90	0.90	0.90
Attic vent area* (ft²)	5.13	5.13	5.13	5.13
Crawlspace vent area* (ft²)	n/a	10.26	n/a	n/a
Exposed masonry floor area * (ft²)	n/a	n/a	307.8	307.8
Carpet & pad R-Value	n/a	n/a	2.0	2.0
Door Area (ft²)	40	40	40	40
Door U-Factor	0.35	0.50	1.20	0.35
North window area* (ft²)	57.71	57.71	57.71	49.95
South window area* (ft²)	57.71	57.71	57.71	49.95
East window area* (ft²)	57.71	57.71	57.71	49.95
West window area* (ft²)	57.71	57.71	57.71	49.95
Window U-Factor	0.35	0.50	1.20	0.35
Window SHGC_o (heating)	0.34	0.34	0.34	0.34
Window SHGC_o (cooling)	0.28	0.28	0.28	0.28
SLA_o (ft²/ft²)	0.00036	0.00036	0.00036	0.00036
Internal gains* (Btu/day)	66,840	66,840	62,736	107,572
Labeled heating system efficiency rating	AFUE = 82%	HSPF = 8.2	HSPF = 7.7	AFUE = 95%
Labeled cooling system efficiency rating	SEER = 16.0	SEER = 15.0	SEER = 17.0	SEER = 13.0
Air Distribution System Efficiency	0.88	0.88	0.88	0.88
Thermostat Type	Manual	Manual	Manual	Manual
Heating thermostat settings	72 F (all hours)	72 F (all hours)	72 F (all hours)	72 F (all hours)
Cooling thermostat settings	75 F (all hours)	75 F (all hours)	75 F (all hours)	75 F (all hours)

Test Case 5.

Test case 5 requires that each of the Standard Reference Design for test cases 1-4 be stored or recreated in the software tool as Proposed Homes and simulated as any other rated home would be simulated. If the resulting Proposed Home is correctly configured to be identical to its appropriate Standard Reference Design, code compliance calculations arising from normal operation of the software tool should produce virtually identical scoring criteria for both the Standard Reference Design and the Proposed Home for this round of tests. For test case 5, the energy use e-Ratio shall be calculated separately from the simulation results for heating and cooling, as follows:

e-Ratio = (Proposed Home energy use) / (Standard Reference Design energy use)

Acceptance criteria for these calculations shall be ± 0.5% of 1.00. Thus, for each of the preceding test cases (1-4), the e-Ratio resulting from these software tool simulations and the subsequent e-Ratio calculations shall be greater than or equal to 0.995 and less than or equal to 1.005.

[1] The overall solar heat gain coefficient (SHGC_o) of a fenestration is defined as the solar heat gain coefficient (SHGC) of the fenestration product taken in combination with the interior shade fraction for the fenestration.

[2] SLA_o is the floor-area weighted specific leakage area of a home where the different building zones (e.g. basement and living zones) have different specific leakage areas.

[3] cfm₂₅ = cubic feet per minute of air leakage to outdoors at a pressure difference between the duct interior and outdoors of 25 Pa.

Comment #13

Page Number: 33
Paragraph / Figure / Table / Note: 4.3.3.2.8
Comment Type: Technical

Comment:

Heat pumps are becoming much more popular in northern climates where the heating load is greater than the cooling load. Sizing to the heating load in many situations will cause the heat pump to be grossly oversized for the cooling load. This will create comfort and dehumidification issues in the home and will erode efficiency during the cooling cycle.

Proposed Change:

4.3.3.2.8. Heat pump equipment shall be sized to equal the ~~larger of the heating and~~ cooling season calculations in accordance with these procedures.

Response:
Rejected. When heat pumps are sized to equal the cooling load, the heating load in many climates must be met by back-up strip resistance heating, which seriously degrades the performance of the heat pump. In fact, there is also strong evidence to indicate that heat pumps in cold climates should be sized somewhat larger than the recommendations of the AACA Manual J and Manual S recommendations to reduce back up strip resistance heating.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #14

Page Number: 4.3.3.2.4
Paragraph / Figure / Table / Note: 4.3.3.2.4
Comment Type: Technical

Comment:

This section refers to ASHRAE 62.2 2004. I request the standard be updated to reflect the requirements of ASHRAE 62.2.2010.

The 2004 standard was an interim standard. It has been replaced with the 2007 changes and again updated with the 2010 additions.

Response:
Accepted. The commentator specified the incorrect paragraph, however, proposed ASHRAE Standard 62.2 update will be incorporated into section 4.3.3.2.5 of BSR/RESNET Standard 301-201x.

Comment #15

Page Number: 34
Paragraph / Figure / Table / Note: 4
Comment Type: General

Comment:

The minimum field verified standard does not include an actual Blower Door or Tracer Gas Test. This omission of testing on a National Level, leaves this in the hands of the individual Provider.

I believe that every home rated should have a Blower Door Test completed. The actual CFM at 50 and the calulated volume of the house should be available to the rating process. These numbes should also be available along with the calculated ACH at 50 number on the Rating Label.

Allowing a home to go from a projected rating from plans to a confirmed rating without Diagnostic Testing simply means we are guessing.

I would like my profession to rise above, and actually test each and every rated house.

Response:
Accepted. BSR/RESNET Standard 301-201X will be modified to require testing of envelope leakage and air distribution system leakage for Confirmed Ratings. The definition of a confirmed rating will be revised as follows.

“Confirmed Rating – A Rating Type accomplished using the actual data gathered from an on-site audit inspection and~~, if required,~~ performance testing of the physical building and its installed systems ~~and equipment~~ including, at a minimum, air distributions system testing and envelope leakage testing.”

Comment #16

Page Number: various
Paragraph / Figure / Table / Note: various
Comment Type: Editorial

Comment:

The RESNET Technical Committee recently proposed, and the RESNET Board approved, an amendment to the RESNET Standards which allows ratings to be labeled “confirmed” without inputting actual field testing and inspecting findings back into the rating software. So long as verification testing and inspection findings from the field are equal to or better than threshold specifications/minimum rated features for a worst-case rating analysis, the home can be labeled as “confirmed”.

The blending of all non-projected ratings under a single umbrella of “confirmed” will leave RESNET with no categorical distinction for a rating which is based on actual built conditions. All ratings which actually represent the home being rated will simply be aggregated together with all the ratings that are worst-case and meet threshold testing and inspection requirements. Looking down the road to a point in time when RESNET will want to mine the data in the RESNET Rating Registry (and no doubt third parties will be willing to pay RESNET for that same privilege), RESNET will have no easy way to cull the data which represents actual house performance and specification characteristics, data that will most certainly be of interest to RESNET and others. Everything else, project and confirmed ratings, will be “close” to representing the actual house but only actual data is actual data.

Proposed Change:

Contents

(page i)

5.2. National Home Energy Performance Label Certifications ................... 52

5.2.1. Confirmed and Actual Ratings .................................................................52

3. Definitions

(page 2)

Actual Rating – A Rating Type accomplished using data gathered from an on-site audit inspection and, if required, performance testing of the physical building and its installed systems and equipment which is input into RESNET-accredited software to create a Rating which reflects the actual condition of the Rated Home.

(page 48)

5.1.2.1.2.3. For Confirmed, Actual, Sampled and Projected Ratings, estimated energy cost savings shall be calculated as follows –

(page 49)

5.1.2.2.2.3. For Confirmed, Actual, Sampled and Projected Ratings, estimated energy cost savings shall be calculated as follows –

(page 50)

5.1.4.2. Actual Rating. All Actual Ratings shall be for individual real properties where all Minimum Rated Features of the Rated Home are verified in the field through inspection and testing in accordance with the minimum requirements of Section 4.4 of this Standard and where field collected data is input into RESNET-accredited software.

5.1.4.1.2. All Actual Ratings shall be subject to the Quality Assurance requirements of Section 900 of the RESNET Mortgage Industry National Home Energy Rating Systems Standard.

5.1.4.2.2. All Actual Ratings shall use the field-verified Minimum Rated Feature data collected from field inspection and testing of the Rated Home and input the data into an accredited software rating tool to generate the actual Home Energy Rating for the Rated Home.

5.1.4.2.3. All Actual Ratings shall be submitted to the National RESNET Registry (see Section 5.3) for certification.

5.1.4.2.4. Following registration of Actual Ratings, the results of the Rating shall be certified in accordance with Section 5.2 of the Standard.

(page 52)

5.1.4.3.7. Upon completion of construction and field verification of the proposed specifications for all Minimum Rated Features of the Rated Home in accordance with Section 4.3.1 of this Standard (e.g. on-site visual inspections, on-site diagnostic test results or default values for envelope air leakage and distributions system efficiencies), and entry of either the field verified rated features or the threshold specification for a Worst-Case Analysis into an accredited rating tool, a pProjected Rating for the home shall become a Confirmed Rating for the home. If actual data for the Rated Home, reflecting the actual condition of the home, are entered into the rating tool, the Projected Rating for the home may become an Actual Rating for the home.

(page 52)

5.2.1. Confirmed and Actual Ratings.

5.2.1.1. All Confirmed and Actual Ratings shall be labeled using Rating Certification Form 5.2-1 provided by RESNET.

(page 54)

5.3.1.1. The Rated Home characteristics, including but not limited to the following:

a) Physical location of the home, including street address, city, state and zip code

b) IECC climate zone of the home

c) Certified Rater ID

d) Accredited Rating Provider ID

e) Date of the Rating

f) Status of the Rated Home (new or existing)

g) Rating Type for the home (confirmed, actual or sampled)

Response:
Accepted. BSR/RESNET Standard 301-201X will be modified to require testing of envelope leakage and air distribution system leakage for Confirmed Ratings. However, a Rating category of “Actual” will not be added to BSR/RESNET Standard 301-201x as it will not be required under these circumstances. The definition of a confirmed rating will be revised as follows.

“Confirmed Rating – A Rating Type accomplished using the actual data gathered from an on-site audit inspection and~~, if required,~~ performance testing of the physical building and its installed systems ~~and equipment~~ including, at a minimum, air distributions system testing and envelope leakage testing.”

Comment #17

Page Number: 22
Paragraph / Figure / Table / Note: 4.2.2.3
Comment Type: Editorial

Comment:

Insulated siding has become more popular as a form of continuous insulation. It would be appropriate to be included in this standard. Additional information on insulated siding including the new ASTM standard is available at http://www.insulatedsiding.info.

Proposed Change:

4.2.2.2.3. Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation (i.e. rigid foam, fibrous batts, loose fill, or sprayed insulation, or insulated siding) covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-value.

Response:
Accepted. The proposed change will be included in the final Committee draft of BSR/RESNET Standard 301-201x.

Comment #18

Page Number: 2
Paragraph / Figure / Table / Note: 3. Definitions
Comment Type: Technical

Comment:

Definition of CFA needs to align with Interpretation 2010-02

Response:

Accepted. Proposed changes will be made to the draft as per Public Comment #4 as reconciled with the SDC response to comment #72.

Comment #19

Page Number: 17
Paragraph / Figure / Table / Note: Table 4.2.2(1a) Notes (m)
Comment Type: Technical

Comment:

The de-rating of instantaneous DHW per Amendment 2011-03 should be referenced in this section

Response:
Accepted. Table 4.4.2(1a), Note (m) will be modified to reflect this comment.

Comment #20

Page Number: 21
Paragraph / Figure / Table / Note: 4.2.2.2.2. Insulation Assessment
Comment Type: Technical

Comment:

This section will need to be re-written to reflect the changes to Appendix A's insulation grading once that Amendment is adopted.

Response:
Rejected. Appendix A’s draft insulation grading language was erroneous and has been revised to reference the procedures provided in this proposed standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #21

Page Number: all - general
Comment Type: General

Comment:

Using the 2006 IECC as the baseline is problematic. We suggest adjusting the baseline to the 2009 or 2012 IECC. There are several items that are difficult to reconcile to the 2006 IECC baseline because of changes that have been made to the code. For instance, as of the 2009 IECC there is no longer an allowance to trade off against outdated federal minimums for equipment efficiency [T4.2.2(1a)] . The federal minimums are slated to be updated over the next several years. Without a change this standard could quickly become obsolete. Also the 2006 IECC did not have air leakage requirements as are now found in the more recent versions of the code.

We would also like to see the use of general accepted engineering practices for framing factors [T4.2.2(6)]. The framing factors should be consistent with other code compliant software such as found in the Methodology for Developing the REScheckTM Software through Version 4.4.2.

[4.3.3.1.5, 4.3.3.2.6] The assumption made in this section is that all windows have blinds. This is a highly unlikely scenario and we suggest modeling as though blinds are not present.

Many of the existing home assumptions are artificially low. We suggest updating the limits.

We highly encourage the collection and monitoring of data collected for HERS ratings. We suggest a program similar to B3 which is produced by The Weidt Group for the entry and collection of such data.

Response:
Rejected. BSR/RESNET Standard 301-201x does not propose to provide a direct means of IECC code compliance. Rather, it intends to provide a Reference Home that is stable over time so as to reflect improvements in homes over time relative to the Standard Reference Design provisions of the 2006 IECC.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #22

Page Number: 33, 36, 70,
Paragraph / Figure / Table / Note: Default Air Leakage Rate for HERS Rating
Comment Type: Technical

Comment:

Should blower door testing be required for confirmed ratings?

It's complicated...

See EnergyLogic’s position on the matter http://nrglogicblog.com/?p=650&preview=true

Proposed Change:

It's a complicated matter that should be discussed. The fact is RESNET doesn’t require blower door testing. The reality is most providers require it, most raters do it. These two discrepancies should be a concern to an industry pushing for consistency.

In short EnergyLogic's argument is that it's in the best interest of the industry that every home with a confirmed rating get an air leakage test assuming the house being tested is under safe conditions.

The full argument with a position paper on details on how this could be implemented with changes in the standard can be found here:

http://nrglogicblog.com/?p=650&preview=true

Response:
Accepted. BSR/RESNET Standard 301-201X will be modified to require testing of envelope leakage and air distribution system leakage for Confirmed Ratings. The definition of a confirmed rating will be revised as follows.

“Confirmed Rating – A Rating Type accomplished using the actual data gathered from an on-site audit inspection and~~, if required,~~ performance testing of the physical building and its installed systems ~~and equipment~~ including, at a minimum, air distributions system testing and envelope leakage testing.”

Comment #23

Page Number: 4
Paragraph / Figure / Table / Note: 3. Definitions
Comment Type: Technical

Comment:

A home that generates electricity on-site but does not use it efficiently should not be able to be rated at a lower, better Index value than a home that more efficiently uses purchased energy, but this is possible given the proposed definition of HERS Index.

For example, a 2,000 square foot home that uses 500 million Btu of site energy and has on-site energy production of 500 million Btu will get a “perfect” score of 0, while a 2000 square foot home that is very efficient and only uses 20 million Btu of site energy will get a worse score, even though it is 25 times more energy efficient. Such a result is contrary to the goal of the proposed standard. Accordingly, “net purchased” should be stricken from before the word “energy” in the last line.

Proposed Change:

HERS Index

…that uses zero ~~net~~ purchased energy...

Response:
Rejected. Removal of the word “net” from the definition would result in a definition that is counter to the intent. The word “net” is used because renewable energy produced from intermittent energy resources such as solar or wind power will not produce power at all of the times when energy is needed by the home. Thus, the term “net” is used to allow periods of excess power production to be weighed against a home’s energy use at times when the resource in unavailable. However, the comment also points out the fact that the period over which the energy use is to be accumulated is not specified. Therefore, the definition will be modified state “. . . that uses zero annual net purchased energy. . .” to specify that the period over which the energy use is to be considered is the annually.

If the commentator intended that both the word “net” and the word “purchased” were to be stricken as stated in the comment, then that would also not be acceptable because that would not allow a distinction between energy use that is produced on site by the home’s equipment and power that is purchased from an off-site production facility.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #24

Page Number: 3
Paragraph / Figure / Table / Note: 3. Definitions
Comment Type: Technical

Comment:

The amount of electricity produced by site fossil fuel uses will be totally dependent on the type of generation technology used. This definition is technically incorrect, as it assumes that an electric generation system in a home will have the exact same efficiency as central station generation. For many types of generation systems, the will not be correct by orders of magnitude (e.g., the home generation is 20% efficient, and the central station generation is 60% efficient).

If RESNET does not choose to delete this definition and more appropriately focus the proposed standard and whether a home efficiency uses energy, regardless of that energy’s source, the approach to “Equivalent Electric Energy” must be modified to address technical concerns. The amount of electricity produced by site fossil fuel uses will be totally dependent on the type of generation technology used. The proposed approach incorrectly assumes that all possible home electric generation systems will have the same efficiency. RESNET should develop separate methodologies for determining the “Equivalent Electric Energy” from all possible forms of home electricity generation. These methodologies must address the fact that many home generators do not separately meter their fuel use, which will significantly complicate the calculation of equivalent electric energy.

Moreover, using the proposed “Reference Electricity Production Efficiency” to generate an “Equivalent Electric Energy” value raises a series of other technical concerns. First, it is not appropriate to assume that all home electricity generation systems produce electricity as efficiently as central station generation. In general, because of economies of scale, central station generation will be more efficient by orders of magnitude. Second, RESNET’s proposed “Reference Electricity Production Efficiency” value of 40 percent has not been sufficiently substantiated. For example, it significantly underestimates the efficiency of modern natural gas-based generation, which has an efficiency of over 60 percent. As noted, RESNET should develop separate methodologies specific to the various home generating systems for determining “Equivalent Electric Energy.” If RESENT continues to use the proposed approach, it must better explain the basis for the proposed 40 percent value before finalizing this standard. The use of incorrect estimates for electricity production efficiency will distort the HERS Index score.

Proposed Change:

Delete the definition for "Equivalent Electric Energy".

Equivalent Electric Energy - The amount of electricity that would be produced from site fossil fuel uses when converted to electric power using the Reference Electricity Production Efficiency.

Response:
Rejected. Site fossil fuel use must be converted to an electric equivalent before the two energy uses are comparable. Furthermore, for consistency, the conversion from one form of energy to the other should be uniform across all home energy ratings. The standards development committee has determined that the conversion efficiency of 40% proposed by BSR/RESNET Standard 301-201x is both equitable and balanced. In accordance with other another public comment (#49) the term “Reference Electricity Production Efficiency” will be deleted from BSR/RESNET Standard 301-201x and the conversion efficiency of 40% will be specified in Section 4.1.2 and 4.5.4 where the term is used in the draft.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #25

Page Number: 6
Paragraph / Figure / Table / Note: 3. Definitions
Comment Type: Technical

Comment:

There are many technical issues with this definition. The first issue is that on-site power production does not make a home more energy efficient. A 2,000 square foot home that uses 500 million Btu’s of site energy and has on-site energy production of 500 million Btu’s will get a “perfect” score of 0, while a 2000 square foot home that is very efficient and only uses 20 million Btu’s of site energy will get a worse score, even though it is 25 times more energy efficient.

The second issue is that the proposed definition ignores on site thermal energy production, from such technologies as solar thermal energy systems and wood-fired stoves. This proposed definition ignores on-site energy production from those sources, focusing only on electric production. This does not make sense, especially for northern areas where heating energy is the dominant annual energy use of the home.

The third issue is the implicit assumption that on-site electric production efficiency will be exactly equal to the efficiency of central station power plants. The amount of electricity produced by site fossil fuel uses will be totally dependent on the type of generation technology used. For many types of generation systems, the will not be correct by orders of magnitude (e.g., the home generation is 20% efficient, and the central station generation is 60% efficient if it is combined cycle natural gas and 100% efficient if it is renewable).

The proposed approach incorrectly assumes that all possible home electric generation systems will have the same efficiency. RESNET should develop separate methodologies for determining the “Equivalent Electric Energy” from all possible home electricity generation. These methodologies must address the fact that many home generators do not separately meter their fuel use, which will significantly complicate the calculation of equivalent electric energy.

Moreover, using the proposed “Reference Electricity Production Efficiency” to generate an “Equivalent Electric Energy” value raises a series of other technical concerns. First, it is not appropriate to assume that all home electricity generation systems produce electricity as efficiently as central station generation. In general, because of economies of scale, central station generation will be more efficient by orders of magnitude. Second, RESNET’s proposed “Reference Electricity Production Efficiency” value of 40 percent has not been sufficiently substantiated. This value significantly underestimates the efficiency of modern natural gas-based generation, which can have efficiencies of over 60 percent. Further, it is not clear how and to what extent RESNET considered the efficiencies of purchased renewable generation or nuclear generation when coming up with this figure. As noted, RESNET should develop separate methodologies specific to the various home generating systems for determining “Equivalent Electric Energy.” If RESENT continues to use the proposed approach, it must better explain the basis for the proposed 40 percent value before finalizing this standard. The use of incorrect estimates for electricity production efficiency will distort the HERS Index score.

Proposed Change:

Delete the definition of "On-Site Power Production (OPP)".

On-Site Power Production (OPP) - Electric Power produced at the site of a Rated Home. OPP shall be the net electrical power production, such that it equals the gross electrical power production minus any purchased fossil fuel energy, converted to its Equivalent Electric Power, used to produce the on-site power.

Response:
Rejected. BSR/RESNET Standard 301-201x will continue to credit electric energy produced on site as non-purchased energy. The commentator is incorrect about the standard not accounting for site thermal energy production from solar energy and wood-fired stoves and is also incorrect about the standard not accounting for the type of on-site generation technology used in the production of on-site energy. This factor is fully accounted in the specified calculation of PEfrac which references the determination of On-site power production as specified in Section 5.1.1.4 of BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #26

Page Number: 7
Paragraph / Figure / Table / Note: 3. Definitions
Comment Type: Technical

Comment:

Using the proposed “Reference Electricity Production Efficiency” to generate an “Equivalent Electric Energy” value raises a series of technical concerns. First, it is not appropriate to assume that all home electricity generation systems produce electricity as efficiently as central station generation. In general, because of economies of scale, central station generation will be more efficient by orders of magnitude. Second, RESNET’s proposed “Reference Electricity Production Efficiency” value of 40 percent has not been sufficiently substantiated. This value significantly underestimates the efficiency of modern natural gas-based generation, which can have efficiencies of over 60 percent. Further, it is not clear how and to what extent RESNET considered the efficiencies of purchased renewable generation or nuclear generation when coming up with this figure. As noted, RESNET should develop separate methodologies specific to the various home generating systems for determining “Equivalent Electric Energy.” If RESENT continues to use the proposed approach, it must better explain the basis for the proposed 40 percent value before finalizing this standard. The use of incorrect estimates for electricity production efficiency will distort the HERS Index score.

EEI recommends that RESENT consider the following before moving forward with finalizing any “Reference Electricity Production Efficiency” factor:

First, the value for a “modern, high-efficiency, central power plant” of 40% is incorrect and understated. The most common types of power plants built over the past 10-15 years have been combined cycle gas turbines or renewable plants (wind, solar, hydro, etc). Renewable power plants, since no resources are lost, have an efficiency level of 100%, and even after transmission/ distribution losses, the overall efficiency is around 92.5%, not 40%. The newest combined cycle gas turbines have efficiencies in the 59-61% range. Even after considering national average transmission and distribution losses, the overall efficiency is at least 52-53% for these units. See:

http://www.siemens.com/innovation/apps/pof_microsite/_pof-fall-2011/_html_en/combined-cycle-gas-turbines.html

The second issue is that on-site power production is usually much less efficient than central station power generation. A gasoline generator operating at full load is about 19.3% efficient, and is about 15.3% efficient at 50% load. See:

http://powerequipment.honda.com/generators/models/em4000

Other types of small scale electric generation (such as microturbines) have efficiency levels well below 40% (usually in the 26-31% range). See: http://www.capstoneturbine.com/_docs/Product%20Catalog_ENGLISH_LR.pdf

Therefore, the use of such an incorrect estimate will be to provide an overstated credit and distort the HERS score.

Proposed Change:

Delete the definition of "Reference Electricity Production Efficiency"

Reference Electricity Production Efficiency - Electric power production efficiency, including all production and distribution losses, of 40%, approximating the efficiency of a modern, high-efficiency central power plant. The Reference Electricity Production Efficiency is to be used only to convert site fossil fuel energy uses to an Equivalent Electric Power for the sole purposes of providing home energy rating system credit for On-site Power Production.

Response:
Rejected. The standards development committee has determined that the conversion efficiency of 40% proposed by BSR/RESNET Standard 301-201x is both equitable and balanced. In accordance with other another public comment (#49) the term “Reference Electricity Production Efficiency” will be deleted from BSR/RESNET Standard 301-201x and the conversion efficiency of 40% will be specified in Section 4.1.2 and 4.5.4 where the term is used in the draft.

BSR/RESNET Standard 301-201x will continue to credit electric energy produced on site as non-purchased energy. The commentator is incorrect about the standard not accounting for the type of on-site generation technology used in the production of on-site energy. This factor is fully accounted in the specified calculation of PEfrac which references the determination of On-site power production as specified in Section 5.1.1.4 of BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #27

Page Number: 9
Paragraph / Figure / Table / Note: 4.1
Comment Type: Technical

Comment:

Proposed Change:

In Section 4.1, third line, change to:

value of 100 and a home that uses no ~~net purchased~~ energy has an Index value of 0 (zero).

Response:
Rejected. BSR/RESNET Standard 301-201x will continue to credit electric energy produced on site as non-purchased energy. Whether the home achieves low ratings due to the use of on-site power production or the incorporation of greater efficiency technologies or some combination of both will be left to the marketplace to decide.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #28

Page Number: 10
Paragraph / Figure / Table / Note: Section 4.1.1
Comment Type: Technical

Comment:

Adding “fossil fuel” before “consumption” will make the standard more technically inclusive of all technologies and ensure that all energy usage is accounted for.

Proposed Change:

In Section 4.1.1, for nEC_x and EC_r, replace “including auxiliary electric consumption” with “including auxiliary electric and fossil fuel consumption”.

Response:
Rejected. The phrase “including auxiliary electric consumption” is purposefully intended to modify fossil fuel heating systems that require electric components for pilot or for heated air distribution. Modifying this language will only confuse the meaning.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #29

Page Number: 10
Paragraph / Figure / Table / Note: Section 4.1.1 Equations
Comment Type: Technical

Comment:

Based on the way that the equations are written, REUL and EC_r are cancelled out, since they will appear in the numerator and denominator when the nEC_x is substituted into the equation for nMEUL.

Proposed Change:

The equations in Section 4.1.1 need to be revised to make algebraic sense.

Response:
Rejected. The equations are purposefully step-wise in this procedure. The intent of the step-wise nature of this procedure is that the specified terms not be algebraically canceled out.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #30

Page Number: 11
Paragraph / Figure / Table / Note: 4.1.2
Comment Type: Technical

Comment:

As a general matter, the proposed standards’ focus on whether energy is produced on-site or purchased is misplaced and could distort home ratings. The goal of the standard should be to encourage more efficient homes, and the source of the energy is not relevant to how efficiently it is used. A home that generates electricity on-site but does not use it efficiently should not be able to be rated at a lower, better Index value than a home that more efficiently uses purchased energy, but this is possible given the proposed definition of HERS Index.

Consistent with this general objection, I would recommend that this equation be altered to remove the PEfrac, which will remove the on-site electricity production from the formula. This will create a formula that is based solely on actual energy consumption and efficiency of the home. The use of PEfrac will lead to less energy efficiency. PEfrac is not technically correct since it only looks at on-site electricity production and ignores on-site thermal energy or other on-site energy production.

Proposed Change:

Change equation 4.1-2 to read as follows:

HERS Index = PEfrac * (TnML / TRL) * 100

Comment #31

Page Number: 11
Paragraph / Figure / Table / Note: Section 4.1.2
Comment Type: Technical

Comment:

In another comment, it is recommended that PEfrac be removed from Equation 4.1-2 to create a formula that is based solely on the actual energy consumption and actual energy efficiency of the home being rated. There are technical flaws with the use of a “reference electricity production efficiency” of 40%. The most common types of power plants built over the past 10-15 years have been combined cycle gas turbines or renewable plants (wind, solar, hydro, etc). Renewable power plants, since no resources are lost, have an efficiency level of 100%, and even after transmission/distribution losses, the overall efficiency is around 92.5%, not 40%. The newest combined cycle gas turbines have efficiencies in the 59-61% range. Even after considering national average transmission and distribution losses, the overall efficiency is at least 52-53% for these units.

In addition, there are technical flaws with the OPP that are addressed in another comment. The largest flaw is that this equation does not consider the production of non-electric energy at the home. By only looking at power and ignoring thermal energy or on-site fossil fuel energy (e.g., anaerobic digestors), the equation does not provide any “credit” to other forms of on-site energy production. In addition, the equation ignores any upstream fossil fuel energy production losses. Please see the following EIA article about natural gas production: http://www.eia.gov/todayinenergy/detail.cfm?id=4030

Proposed Change:

Delete the definitions for PEfrac, TEU, and OPP from section 4.1.2.

Response:
Rejected. BSR/RESNET Standard 301-201x will continue to credit electric energy produced on site as non-purchased energy. Whether the home achieves low ratings due to the use of on-site power production or the incorporation of greater efficiency technologies or some combination of both will be left to the marketplace to decide. See also committee responses to Comments 23-30 from the same commentator.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #32

Page Number: 14
Paragraph / Figure / Table / Note: Table 4.2.2(1)
Comment Type: Technical

Comment:

Electric resistance systems (furnaces, boilers, zoned heaters) are used in many homes in the United States. According to the Energy Information Administration 2009 Residential Energy Consumption Survey, of the 38.2 million US homes with electric space heating, about 50% (19.1 million) use central warm-air electric furnaces, and 9.8 million (25.7%) use heat pumps. For the years 2000 through 2009, of the 6.9 million homes built with electric heat, 4.3 million used central warm-air furnaces and 2.2 million used heat pumps. Therefore, the heating system row for electricity in this table should include electric furnaces, along with associated changes in Table 4.2.2(1a) that are shown in another comment.

Proposed Change:

In Table 4.2.2(1), under the Heating systems, for electric, change the text to “air source heat pump or furnace in accordance with Table 4.2.2(1a)”.

Response:
Rejected. BSR/RESNET Standard 301-201x will not reduce the efficiency of the HERS Reference Home below those Section 404 of the 2006 IECC for the Standard Reference Design.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #33

Page Number: 17
Paragraph / Figure / Table / Note: Table 4.2.2(1a)
Comment Type: Technical

Comment:

Electric resistance systems (furnaces, boilers, zoned heaters) are used in many homes in the United States and should be included in the “default” HERS reference home table. According to the Energy Information Administration 2009 Residential Energy Consumption Survey, of the 38.2 million US homes with electric space heating, about 50% (19.1 million) use central warm-air electric furnaces, and 9.8 million (25.7%) use heat pumps. For the years 2000 through 2009, of the 6.9 million homes built with electric heat, 4.3 million used central warm-air furnaces and 2.2 million used heat pumps. Therefore, the reference home device for electricity in this table should include electric furnaces, along with associated changes in Table 4.2.2(1) that are shown in another comment.

Proposed Change:

In Table 4.2.2(1a), under the electric heating row, change the language in the “Reference Home Device” column to “7.7 HSPF air source heat pump or 99% AFUE / 0.99 COP electric furnace or boiler”.

Comment #34

Page Number: 17
Paragraph / Figure / Table / Note: Table 4.2.2(1a)
Comment Type: Technical

Comment:

This will make the note consistent with proposed changes to Tables 4.2.2(1) and 4.2.2(1a).

Proposed Change:

For Table 4.2.2(1a) note (i), change the last sentence to:

“For electric heating systems, the prevailing minimum efficiency ~~air source heat pump~~ furnace or boiler shall be selected”.

Comment #35

Page Number: 24
Paragraph / Figure / Table / Note: SEction 4.2.2.5.1.2
Comment Type: Technical

Comment:

There are miscellaneous gas appliances that are installed in homes that should be included into any analysis of the energy efficiency of a home under the proposed standard. If all miscellaneous electric loads are included in calculations, then all miscellaneous gas or other fossil fuel loads should be included as well.

Based on published data and utility rate schedules, typical gas light systems use 18 therms per month, or 216 therms per year.

Based on data from the American Gas Association Residential Natural Gas Market Survey of January 2010, the national average energy usage of a gas fireplace is 115 therms, with a range that varies by region from 48 to 283 therms per year.

Proposed Change:

In Section 4.2.2.5.1.2, revise the wording to read “Where the Rated Home is equipped with natural gas cooking appliances or clothes drying appliances, or gas fireplaces or gas lighting systems,…..

In Table 4.2.2.5(2), add the following rows:

Gas Lights (therms)	216
Gas Fireplace (therms)	115

Response:
Rejected. The values provided by Table 4.2.2.5(2) are specified to replace the values given in Table 4.2.2.5(1) for all electric homes. There is no electrical reference equivalent to a gas fireplace and there is virtually no use of gas-fired lighting systems in homes.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #36

Page Number: 43
Paragraph / Figure / Table / Note: Section 4.5.4.1
Comment Type: Technical

Comment:

The proposed changes will make the equation technically correct. The use of a “reference electric production efficiency” creates a total distortion of the energy usage and energy efficiency of homes, by discounting the fossil fuel energy usage by 60%.

As a simplified example, if a fossil fuel appliance uses 341,200 Btu’s per year, the actual equivalence is 341,200 / 3412 = 100 kWh. However, under the current equation, the value used for the HERS score would be a vastly understated and incorrect 40 kWh “equivalent”. The more energy an appliance or system uses, the larger the distortion of the score will be.

There are technical flaws with the use of a “reference electricity production efficiency” of 40%. The most common types of power plants built over the past 10-15 years have been combined cycle gas turbines or renewable plants (wind, solar, hydro, etc). Renewable power plants, since no resources are lost, have an efficiency level of 100%, and even after transmission/distribution losses, the overall efficiency is around 92.5%, not 40%. The newest combined cycle gas turbines have efficiencies in the 59-61% range. Even after considering national average transmission and distribution losses, the overall efficiency is at least 52-53% for these units.

In addition, the equation also is technically incorrect and inconsistent in that it does not account for the energy losses associated with fossil fuel energy production. Please see the following EIA article about natural gas production: http://www.eia.gov/todayinenergy/detail.cfm?id=4030

Proposed Change:

Revise Section 4.5.4.1 to read as follows:

4.5.4.1. Energy units used in the calculation of energy savings shall be units of Equivalent Electric Energy ~~using the Reference Electricity Production Efficiency for fossil fuels~~. Equivalent electric energy use shall be calculated using Equation 4.5-1.

kWh_eq = kWh_elec + Btu_fossil * 0.40 / 3412

Response:
Rejected. BSR/RESNET Standard 301-201x will continue to represent fossil fuel use as an equivalent electric energy where it is necessary that all fuel uses be compared. See also committee responses to comments #23 - #31 from the same commentator.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #37

Page Number: 47
Paragraph / Figure / Table / Note: Section 5.1.1.4
Comment Type: Technical

Comment:

For home energy efficiency ratings, on-site power production or, to be more technically accurate, on-site energy production, should not be used in any formula. On-site energy production does not make a home more energy efficient.

The example shown in Section 5.1.1.4 highlights the problem. The most common types of gas-fired power plants built over the past 15 years have been combined cycle gas turbines. The newest combined cycle gas turbines have efficiencies in the 59-61 percent range. Even after considering national average transmission and distribution losses, the overall efficiency is at least 52-53 percent for these units – well above the value of 0.40 shown throughout the proposed standard.

A more accurate value of electric production would result in the example creating the following estimate:

OPP = 3.413 MBtu – (6 MBtu * 0.60) = -0.187 MBtu

Also, this equation will be inadequate in areas where central station generation is dominated by renewable energy (e.g., hydroelectric and wind in the Pacific Northwest).

Proposed Change:

Delete Section 5.1.1.4.

~~5.1.1.4 If the Rated Home....~~

~~For example, assume....~~

Response:
Rejected. BSR/RESNET Standard 301-201x will continue to use 40% delivered efficiency for the conversion of fossil fuels to their electric equivalent. See also committee responses to comments 23-31 from the same commentator.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #38

Page Number: as listed
Comment Type: General

Comment:

A certfied HERS score must include duct testing and infiltration testing via blower door & duct tester. The 2012 codes require such testing and an accurate HERS score should require it.

For projected ratings the code or program maximum allowable number should be used. (i.e. 2009 IECC or unlisted code should be at 7 ACH)

Response:
Accepted. BSR/RESNET Standard 301-201X will be modified to require testing of envelope leakage and air distribution system leakage for Confirmed Ratings. The definition of a confirmed rating will be revised as follows.

“Confirmed Rating – A Rating Type accomplished using the actual data gathered from an on-site audit inspection and~~, if required,~~ performance testing of the physical building and its installed systems ~~and equipment~~ including, at a minimum, air distributions system testing and envelope leakage testing.”

Comment #39

Page Number: 49
Paragraph / Figure / Table / Note: Section 5.1.2.2.1.1 & Table 5.1.2(1)
Comment Type: Technical

Comment:

The current text is not technically consistent. For fossil fuel emissions, information is provided about emissions at the house, but there is no information about associated upstream emissions. For electricity, no information is provided about the fact that using electrical appliances in the home generates zero emissions at the home, but there is a reference to associated upstream emissions.

Any upstream emissions associated with electricity production are not relevant to any assessment as to how energy efficiency a home is, particularly when home owners have little option to control or reduce these emissions. Accordingly, it does not make sense to “link” household electric usage with power plant emissions. Moreover, the proposed standard takes an inconsistent approach as to how to deal with upstream emissions related to different fuels.

Since this standard is about rating homes, not energy supply, any information about emissions should be focused on the emissions produced by equipment in the home, at the home, or at the home site. The proposed edits create a consistent comparison methodology.

Also, federal laws have capped or reduced electric generation NOx and SO2 emissions significantly over the past 22 years (see http://www.eia.gov/electricity/annual/html/table3.9.cfm), so it does not make sense to “link” household electric usage with capped power plant emissions.

Proposed Change:

For Section 5.1.2.2.1.1, revise the text to read “For electricity use, pollution emissions ~~using the statewide average emission rates provided by the Environmental Protection Agency’s most recent eGrid database¹⁶ for electricity generation.~~ shall be calculated using the emission factors given in Table 5.1.2(1) below.

Also, modify Table 5.1.2(1) as follows:

Fuel Type

Units

MBtu

per Unit

CO2

lb/MBtu

NOx

lb/MBtu

SO2

lb/MBtu

Electricity

(rest of the table is unchanged)

kWh

0.003413

0.0000

Response:
Rejected. The assertion that electric energy consumption results in zero environmental pollution emissions is rejected.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #40

Page Number: 73
Paragraph / Figure / Table / Note: Annex B Table 3.2(1)(a)
Comment Type: Technical

Comment:

Proposed Change:

On Page 73, in Table 3.2(1)(a), under the electric heating row, change the language in the “Reference Home Device” column toread as follows: “7.7 HSPF air source heat pump or 99% AFUE / 0.99 COP electric furnace or boiler”.

Response:
Rejected. The Annexes associated with software verification testing and accreditation will be removed from BSR/RESNET Standard 301-201x.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #41

Page Number: 73
Paragraph / Figure / Table / Note: Annex B Table 3.2(1)(a) note i
Comment Type: Technical

Comment:

This will make the note consistent with proposed changes to Tables 4.2.2(1) and 4.2.2(1a).

Proposed Change:

For Table 3.2(1)(a) note (i), change the last sentence to “For electric heating systems, the prevailing minimum efficiency ~~air source heat pump~~ furnace or boiler shall be selected”.

Response:
Rejected. The Annexes associated with software verification testing and accreditation will be removed from BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #42

Page Number: 13
Paragraph / Figure / Table / Note: Table 4.2.2(1)
Comment Type: General

Comment:

The standard refers to "mechanical ventilation" multiple times, when a more appropriate reference would be "whole-house mechanical ventilation" (WHMV). By replacing references to "mechanical ventilation" with "whole-house mechanical ventilation" and inserting a new definition for "whole-house mechanical ventilation", PDS-301 will be consistent with the lexicon of ASHRAE 62.2 and the 2012 IRC and IECC. The definition proposed below is copied from the 2012 IRC and IECC.

Further, to ensure consistency with ASHRAE 62.2, please formally rescind RESNET Formal Interpretation 2007-001, which provides an incorrect interpretation of ASHRAE 62.2 (i.e., the interpretation states that occupant override controls are not permitted, while ASHRAE 62.2 specifically requires that they be provided). This incorrect interpretation is currently causing problems for raters and manufacturers who are trying to comply with RESNET standards and ASHRAE 62.2.

Thanks for your consideration.

Proposed Change:

1. Section 3 - Insert a new definition as follows:

Whole-house mechanical ventilation system – An exhaust system, supply system, or combination thereof that is designed to mechanically exchange indoor air with outdoor air when operating continuously or through a programmed intermittent schedule to satisfy a whole house ventilation rate.

2. Replace "mechanical ventilation" with "whole-house mechanical ventilation” at the following locations:

a. Table 4.2.2(1), page 13, 3rd column:

For residences without whole-house mechanical ventilation systems that are tested in accordance with ASHRAE Standard 119, Section 5.1, the measured air exchange rate (e) but not less than 0.30 ach

For residences with whole-house mechanical ventilation systems that are tested in accordance...

b. Table 4.2.2(1), page 13, 1st column: Whole-house mechanical ventilation:

c. Table 4.2.2(1), page 13/14, 2nd column: None, except where a whole-house mechanical ventilation system is specified by the Rated Home...

d. Page 16: (f) The combined air exchange rate for infiltration and whole-house mechanical ventilation shall be determined in accordance with equation 43 of 2001 ASHRAE Handbook of Fundamentals page 26.24 in combination with the" Whole-house Ventilation" provisions of 2001 ASHRAE Handbook of Fundamentals, page 26.19 for intermittent whole-house mechanical ventilation.

e. Page 24: 4.2.2.5.1.4. Whole-House Mechanical Ventilation. Where whole-house mechanical ventilation is provided in the Rated home...

f. Page 31: 4.2.2.5.2.12. Whole-House Mechanical Ventilation System Fans. If whole-house mechanical ventilation fans are present in the Rated Home...

g. Page 32: 4.3.3.1.4. Whole-house Mmechanical ventilation rate shall be zero.

h. Page 37, Table 4.4.2(1): 20. Whole-House Mechanical Ventilation System(s)

i. Page 61: 16. Whole-house Mmechanical ventilation kWh/yr, if appropriate

j. Page 70, Table Table 3.2(1), column 3: …For residences without whole-house mechanical ventilation systems that are tested in accordance with ASHRAE Standard 119, Section 5.1, the measured air exchange rate (e) but not less than 0.35 ach

For residences with whole-house mechanical ventilation systems that are tested in accordance with ASHRAE Standard 119, Section 5.1, the measured air exchange rate^(e) combined with the whole-house mechanical ventilation rate…

k. Page 70, Table 3.2(1), column 1: Whole-House Mechanical Ventilation:

l. Page 70, Table 3.2(1), column 2: None, except where a whole-house mechanical ventilation system is specified by the Qualifying Home, in which case…

m. Page 73: (f) The combined air exchange rate for infiltration and whole-house mechanical ventilation shall be determined in accordance with equation 43 of 2001 ASHRAE Handbook of Fundamentals page 26.24 in combination with the” Whole-house Ventilation” provisions of 2001 ASHRAE Handbook of Fundamentals, page 26.19 for intermittent whole-house mechanical ventilation.

n. Page 77: 15. Whole-house Mmechanical ventilation kWh/yr, if appropriate

o. Page 80: 15. Whole-house Mmechanical ventilation kWh/yr, if appropriate

3. Update the reference for equations from ASHRAE Fundamentals to cite the relevant equations in the 2009 edition (instead of the 2001 edition, which is outdated): d. Page 16: (f)

4. Provide further clarification for how to account for WHMV flow rates in equipment sizing:

Page 33: 4.3.3.2.4. Where a whole-house mechanical ventilation system is provided, the whole-house Mmechanical ventilation flow rate shall ~~only~~ be included ~~for systems that are controlled to run every hour or every time the HVAC system operates~~. ~~Standard~~ Flow rates for bathroom, ~~and~~ kitchen, and other local exhaust ~~ventilation~~ that does not serve as a component of a whole-house mechanical ventilation system ~~may~~ shall not be considered ~~as ventilation~~ for sizing purposes.

Response:
Accepted. Proposed changes will be made to the draft.

Comment #43

Page Number: 22
Paragraph / Figure / Table / Note: Section 4.2.2.2.6
Comment Type: Technical

Comment:

The Zone Method is not an accurate calculation procedure for cold-formed steel framing (C-sections). It significantly overestimates the U-factor of steel assemblies. Further, The ASHRAE Handbook of Fundamentals (Chapter 27) describes multiple methods for calculating thermal properties of assemblies containing steel framing. There is no one method that is appropriate across the board for all steel assemblies. Each has deficiencies or limitations.

The Handbook of Fundamentals clearly cites research by Oak Ridge National Laboratory that shows the modified zone method to be the most accurate method for steel framing. However, that method is limited as well, since it assumes a clear-wall assembly without framing for openings. It may not be applicable to assemblies with higher framing factors.

The methods most appropriate for conventional assemblies using cold-formed steel (that are not clear wall assemblies) are either based on hot box tests or the series path method described in ASHRAE 90.2.

The 90.2 method includes typical series path equations with a correction factor based on member depth and spacing. The method is the same one used to develop steel framing U-factors in Appendix A of ASHRAE 90.1 for other than low-rise residential buildings. Thus, two ANSI consensus committees have accepted this method. Further, the same method and correction factors were included in the 2003 International Energy Conservation Code (IECC). However, over time the format of the IECC changed such that the focus was towards the simple prescriptive table approach, and thus most of the conversion equations, including cold-formed steel framing, were summarily removed in favor of pre-calculated tables.

Hot box test results are the most accurate of the methods but very expensive to conduct. Thus, we recognize the need and support the use of rational and appropriate calculation methods. Further, it is appropriate to modify hot box test results when an assembly is different than the tested assembly if the base assembly (i.e., studs and cavity insulation) are identical. Corrections based on different levels of continuous insulation, siding or other components outside of the cavity are appropriate and recognized by our modification.

Given the very conservative nature of the zone method and its limitations in regard to cold-formed (or light gauge) steel, we recommend that it be removed as the lone method for steel assemblies and replaced with the three more appropriate options shown in our modification to proposed Section 4.2.2.2.6.

Proposed Change:

Modify Section 4.2.2.2.6 as follows:

4.2.2.2.6. Steel framing in insulated assemblies: ~~calculations for~~ the overall thermal properties of steel-framed walls, ceilings and floors shall be based on ~~the “Zone Method” from 2009 ASHRAE Handbook of Fundamentals (p 27.5); or equivalent.~~ one of the following methods:

A series path calculation described in Section 5.5 of ANSI/ASHRAE Standard 90.2-2007 (Energy Efficient Design of Low Rise Buildings).
Testing in accordance with ASTM C1363 (Standard Test Method for Thermal Performance of Building Materials and Envelope Assemblies by Means of a Hot Box Apparatus). Test results may be modified to add or subtract R-values to the tested assembly to reflect differences between the tested assembly and proposed assemblies when such differences occur outside of the cavity.
For clear wall assemblies (without door or window headers and jack or king studs), the modified zone method from 2009 ASHRAE Handbook of Fundamentals, Chapter 27.

Response:
Accepted. The proposal change will be incorporated in the final Committee draft of BSR/RESNET Standard 301-201x.

Comment #44

Page Number: 1
Paragraph / Figure / Table / Note: FORWARD
Comment Type: Editorial

Comment:

Clarification and increased probability that the standard will be adopted and can be applied and used if adopted

Proposed Change:

There are numerous places in the standard that use different terms, statements, formats for presentation of the same thing; these should be made consistent throughout the document. This is a general comment and placed here under the Forward on page 1 as it applies to multiple sections in the standard.

Response:
Rejected. The comment is non-specific and does not propose specific changes to the language in BSR/RESNET Standard 301-2010x. The comment will be considered in future maintenance of the Standard.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #45

Page Number: 1
Paragraph / Figure / Table / Note: FORWARD
Comment Type: Editorial

Comment:

IP is certainly the most useful way to present the requirements, but for ANSI and adoptability purposes SI are also now recognized in standards criteria,

Proposed Change:

The standard is presented entirely in IP units. SI units should be added in parentheses.

Response:
Rejected. An effort will be made to provide SI units in future revisions of BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #46

Page Number: 1
Paragraph / Figure / Table / Note: section 1
Comment Type: Editorial

Comment:

To improve the text to more accurately reflect a purpose statement. There is no reason to refer to intent as that occurs by virtue of the rating and labeling standards being developed and published. It is also not necessary to include a permissive statement about providers of HERs following the document. The suggested changes result in a more concise and accurate statement of purpose that leaves it open as to who uses the document and more accurately presents the purpose of the standard as promoting more uniform and consistent rating and labeling of residential buildings.

Proposed Change:

1. Purpose. The provisions of this document ~~are intended to~~ establish ~~national~~ residential energy rating and labeling Standards, consistent with the provisions of the Energy Policy Act of 1992, which ~~any provider of home energy ratings may follow to~~ provide for ~~produce~~ ~~uniform energy ratings and energy performance labels for residential buildings~~ uniformity and consistency in the rating and labeling of such buildings.

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #47

Page Number: 1
Paragraph / Figure / Table / Note: section 2
Comment Type: Editorial

Comment:

The last sentence is not appropriate for a standard with the stated purpose and intended use given in Section 1 (Purpose). It is informational in nature at the very least and should be included in any informative appendices deemed appropriate to illuminate the content of the standard but not intended to be part of the standard. Where there are one or more specific criteria in this standard that relate to or would specifically refer to the referenced document then it is appropriate to include such a reference where relevant within this standard. It is not an appropriate statement for the scope of a standard; scope simply stating what the standard covers (and by absence in the scope what it does not cover). The scope should clearly outline to what the standard applies and when done appropriately it should not need clarification via exceptions. More appropriate language consistent with other standards and model codes is proposed to more clearly define the scope, most notably clarification of residential buildings. It is noted the term residential building is not defined in the standard yet the term is used in the standard. Consideration might be given to simply saying in the scope “low-rise residential buildings” and then define that term as suggested in this comment in the definitions section of the standard . The term “dwelling unit” is generally understood and is specifically defined in model codes and standards to distinguish multi-family buildings from hotels and motels and other residential use group buildings.

Proposed Change:

2. Scope. This standard is applicable to all one and two family dwellings and residential buildings not over three stories in height above grade containing multiple dwelling units. single family residences and to all multifamily residences three stories or less in height above ground excepting hotels and motels. This Standard is a companion to the RESNET Mortgage Industry National Home Energy Rating Systems Standards.

Response:
Accepted as modified. The proposed revisions as modified below will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

“2. Scope. This standard is applicable to all one- and two-family dwellings and dwelling units in residential buildings not over three stories in height above grade containing multiple dwelling units.”

Comment #48

Page Number: 1
Paragraph / Figure / Table / Note: section 3
Comment Type: General

Comment:

The current introductory text in Section 3 can be enhanced as suggested and would then be consistent with that in other standards and model codes. It is suggested that Section 3 be separated into three subsections (general, definitions and acronyms). The first as proposed above more clearly states the general guidance associated with definitions. The second becomes the current terms that are defined and the third becomes acronyms. The current definitions and acronyms are better separated to enhance use of the standard, noting that the delineation of an acronym is not technically a definition. Many standards development organizations format their standards to separate definitions from acronyms. This makes it easier to use the standard and most importantly ensures that terms that have an actual definition are all grouped together and not separated by acronyms.

Proposed Change:

.1 General. Unless stated otherwise, the terms and words in Section 3.2 shall have the meanings indicated therein. Words used in the present tense include the future, words in the masculine gender include the feminine and neuter, and singular and pleural are interchangeable. Terms not defined in Section 3.2 shall have ordinary accepted meanings such as the context implies.

3.2 Specific Words and Terms.

(Simply list out in alphabetical order all terms and words defined in the current draft).

3.3 Acronyms

(Simply list out in alphabetical order all acronyms that are not associated with a definition).

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #49

Page Number: 7
Paragraph / Figure / Table / Note: section 3
Comment Type: General

Comment:

The definition of “Reference Electricity Production Efficiency” contains requirements. The purpose of a definition is to define a term. The appropriate place to include requirements that relate to the term defined is at the point in the standard where the term is used.

Response:
Accepted. The definition and all references to the term “Reference Electricity Production Efficiency” will be struck and the requirements specified by the definition will be moved to Sections 4.1.2 and 4.5.4 of BSR/RESNET Standard 301-201x.

Comment #50

Page Number: 9
Paragraph / Figure / Table / Note: section 3
Comment Type: Technical

Comment:

Revise the definition of U-factor to be consistent with that used in ASHRAE standards and ICC model codes so as to eliminate confusion amongst the building community that would use the RESNET standard.

Response:
Accepted. These definition of R-Value and U-Factor will be harmonized across these standards and included in the final Committee draft of BSR/RESNET Standard 301-201x, as follows.

“R-value – The inverse of the time rate of heat flow through a body from one of its bounding surfaces to the other surface for a unit temperature difference between the two surfaces, under steady state conditions, per unit area (h·ft2·oF/Btu) [m2·K/W].

U-Factor – The coefficient of heat transmission (air to air) through a building component or assembly, equal to the time rate of heat flow per unit area and unit temperature difference between the warm side and cold side air films (Btu/h·ft2·oF) [W/m2·K].”

Comment #51

Page Number: 9
Paragraph / Figure / Table / Note: section 4.1
Comment Type: Editorial

Comment:

The language in Section 4.1 appears unnecessary and its elimination should help to simplify the standard (e.g. fewer and more precise wording in a standard will enhance its acceptability and can lead to fewer interpretive issues and increase uniformity of use. The term “HERS Index” is defined in Section 3 and there is no reason to repeat that definition in Section 4.1. This can lead to confusion and needlessly complicates the standard. More importantly, should this standard be adopted and then amended the location of these criteria here and in the definitions section increases the chance in amending the document that one set of these criteria might not be appropriately amended. The sentence associated with states or territories having an alternative method should not be addressed in a standard that is intended for national use. If the standard is written correctly it should have a high rate of adoption and use and need not address what might happen if there are alternative methods. Let those who want to divert from the standard do so with good reason on their own. Recognizing such situations in this standard would seem to weaken the intent of RESNET in developing and publishing this standard and as such encourage such alternatives. A section on determining a HERS index should do just that – tell how to make the determination and as amended pursuant to this comment we believe this is just what the standard will do; relying as needed on the definitions in Section 3.

Proposed Change:

4.1. Determining the HERS Index. The HERS Index for a residential building shall be a numerical integer value that is based on a linear scale constructed such that the HERS Reference Home has an Index value of 100 and a home that uses no net purchased energy has an Index value of 0 (zero). Each integer value on the scale shall represent a 1% change in the total energy use of the Rated Home relative to the total energy use of the Reference home. Except in states or territories whose laws or regulations require a specific alternative method, which shall control, equations 4.1-1 and 4.1-2 shall be used in a 2 step process to calculate the HERS Index for the Rated Home, as follows: determined in accordance with Sections 4.1.1 and 4.1.2.

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #52

Page Number: 9
Paragraph / Figure / Table / Note: section 4.1.1
Comment Type: Editorial

Comment:

The proposed text can be improved with respect to its presentation in standards language. The use of the term individual is moot due to the use of the word each as proposed. Also clarification is needed that the loads are space heating, space cooling and domestic hot water. This change is intended to and we believe will clarify intent and simplify the presentation and use of the standard. It is noted that an acronym appears in this section yet is not proposed for Section 3. If this acronym is retained it may be a candidate for listing in a section proposed for only acronyms (see comments to Section 3 suggesting separate subsections for definitions and acronyms). In addition it does not appear clear if the term “normalized modified energy use loads” can be fully understood and applied by all users of the standard and as such this term should be defined. On a general note the format and manner in which equations are presented in the standard should be checked for consistency throughout.

Proposed Change:

4.1.1. Calculating End Use Loads. ~~Calculate the~~ The ~~individual~~ normalized Modified End Use Loads (nMEUL) for space heating and , cooling, and domestic hot water use shall each be determined in accordance with ~~using~~ equation 4.1-1:

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #53

Page Number: 10
Paragraph / Figure / Table / Note: equation 4.1-1
Comment Type: General

Comment:

The use of the term “accredited simulation tools” is used with respect to simulation tools. The terms accredited or “accredited simulation tools” are not defined but the following terms are:

Accreditation Categories (software tools) – Specific computer software tool functionalities that may be accredited by RESNET under the provisions of this Standard.

Accredited Software Rating Tool – A computerized procedure that is accredited by RESNET for the purpose of conducting home energy ratings and calculating the annual energy consumption, annual energy costs and a HERS Index for a home.

The manner in which the above definitions are presented and the use of the term “accredited simulation tools” in Equation 4.1-1 suggests that it is the intent of this standard is to provide for the title, purpose and scope as established for the standard as well as institute a situation where those adopting the standard must then defer to and rely on RESNET accreditation on an ongoing basis; a process that is likely to change over time and over which they have no oversight. The manner in which RESNET is engaged or required to be involved as an accrediting entity with respect to use of the standard (e.g. conformity assessment) should be decoupled from the provisions in the standard related to how a rating is determined and presented.

The manner in which the issue of conformity assessment is addressed in the standard can pose a problem if RESNET intends to have this standard adopted in any way by Federal, state or local authorities as part of their building-related legislation or regulation directly or as an alternative path to compliance with building energy codes. The issue of conformity assessment is addressed through the use of terms such as “approved” and “nationally recognized” in model codes and standards. Then as warranted federal, state or local agencies that formulate, adopt and implement associated laws and regulations will determine, based on those terms as defined in the model codes and standards, the degree to which they would verify the continued acceptance of any third parties. Based on that ongoing assessment they would continue (or not) to allow them to conduct testing, certification, etc. work associated with conformity assessment on behalf of the federal, state or local officials who have that ultimate responsibility as the adopting entity. Inclusion of RESNET in this standard as an accrediting body with respect to conformity assessment with the standard should be seriously considered and removed in place of the suggested use of “approved” and its definition. As currently presented in the standard RESNET accreditation is listed as the only acceptable conformity assessment method as a first-party entity (e.g. self-certification and accreditation) with respect to its ability to perform the stated services on a continuing (e.g. in perpetuity) basis. This is something that accrediting entities such as ANSI, NAVLAP, IAS and others are actively engaged in on an ongoing basis as third party accrediting entities. As such they could assess any RESNET certification programs separately and through certification RESNET could be recognized as an “approved” entity. Inclusion of a first party conformity assessment entity or accrediting agency as RESNET is in the standard opens up the question for users – who then provides oversight of those agencies ongoing activities to ensure they meet standards for conformity assessment entities and should continue to be “approved”.

The issue of who or want is “approved” needs to be addressed in a generic way through the use of the term “approved” and a definition of that term meaning the authority who has adopted and is requiring use of this standard. Certainly RESNET programs associated with accrediting can be considered in looking at who is “approved” and there is no reason why they would not be subsequently approved. Requiring accreditation by RESNET specifically and singularly by name in the standard could adversely affect the adoption and use of the standard. For this reason it is recommended that RESNET eliminate a reference to RESNET accreditation and replace that term with “approved” and a definition of approved consistent with that in model codes and standards. Then separately such RESENT accreditation programs assessed by a recognized third party accrediting agency who can document on continuing basis the acceptability of RESNET accreditation in meeting any criterion that requires third party approval. We believe by doing this the RESNET standard can secure the acceptability that RESNET desires. If not certainly some will adopt the standard and resultant programs but later on challenges to the acceptability of a singular self-certified entity could adversely affect the continued reliance on the standard.

Proposed Change:

Replace the term “accredited” with “approved” and add a definition of approved as “Approved by the entity adopting this standard as a result of investigation and tests conducted by him or her, or by reason of accepted principles or tests by nationally recognized organizations.”on 4.1-1:

Response:
Accepted. The provisions on Software Verification and Testing will be removed from the proposed BSR/RESNET Standard 301-201x to another document promulgated by RESNET. The terms “Accreditation Categories” and “Accredited Software Rating Tool” will be stricken from the definitions. References to “accreditation” of products by RESNET will be removed from BSR/RESNET Standard 301-201x and replaced with “approved” where Approved is defined as follows:

“Approved – shall mean approved by an entity adopting and requiring the use of this Standard as a result of investigation and tests conducted by the entity or by reason of accepted principles or tests by nationally recognized organizations.”

Comment #54

Page Number: 10
Paragraph / Figure / Table / Note: section 4.1.2
Comment Type: Editorial

Comment:

The proposed text can be improved with respect to how it is presented in standards language. It is preferable to state the subject first and then the requirement.

Proposed Change:

4.1.2. Calculating the HERS Index. ~~Determine the~~ The HERS Index ~~using~~ shall be determined in accordance with equation 4.1-2:

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #55

Page Number: 11
Paragraph / Figure / Table / Note: section 4.2
Comment Type: Editorial

Comment:

The two separate subsections (4.2.1 and 4.2.2) appear confusing and could be stated more clearly. We believe the proposed change does this by simply indicating to use identical analytical approaches and configure the homes in accordance with the stated table.

Proposed Change:

4.2.1. General ~~Requirements~~. ~~Except as specified by this Section, the HERS Reference Home and the Rated Home shall be configured and analyzed using identical methods and techniques.~~

~~4.2.2. Residence Specifications.~~ The HERS Reference Home and Rated Home shall be ~~configured and~~ analyzed using identical analytical approaches and configured as specified by Table 4.2.2(1).

Response:
Rejected. The proposed revisions do not improve the meaning or clarity of Section 4.2 of BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #56

Page Number: 15
Paragraph / Figure / Table / Note: section 4.2.1(1)
Comment Type: Editorial

Comment:

Clarification and accuracy.

Proposed Change:

The table in the thermostat row references nonexistent Section 4.2.1.1. Reference should be made to the correct section.

Response:
Accepted. The correct reference for programmable thermostats is Section 4.3.1 and this revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #57

Page Number: 15
Paragraph / Figure / Table / Note: table 4.2.1(1) note (a)
Comment Type: General

Comment:

If the term glazing area or door area are used more than one place in the standard it may be advisable to include a definition of glazing and doors in Section 3, thereby eliminating the need to define the term where used throughout the standard. Moreover the existence of a definition ensures uniform and consistent application and use of the standard with respect to the defined terms that can be compromised if the terms are defined/redefined each time they appear in the standard. In addition if those terms are used somewhere in the standard and not defined it is unclear without a definition how they would be defined.

Proposed Change:

Note (a) seems more appropriate as a definition.

Response:
Accepted. Definition for glazing area and door area as used in Table 4.2.1(1), note (a) will be incorporated in Section 3 of the final committee draft of BSR/RESNET Standard 301-201x.

Comment #58

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (b)
Comment Type: Editorial

Comment:

See prior comment to Section 2 concerning the scope of the standard and the necessity to accurately define residential buildings within the scope of the standard consistent with terminology used in building construction regulations. The proposed change above captures the intent of the draft standard

Proposed Change:

(b) For ~~homes with~~ one- and two-family dwellings with conditioned basements and ~~for multi-family attached homes~~ residential buildings not over three stories in height above grade containing multiple dwelling units the following formula shall be used to determine total window area:

Response:
Accepted as modified. The proposed changes as modified below will be included in the final Committee draft of BSR/RESNET Standard 301-201x.

“(b) For ~~homes with~~ one- and two-family dwellings with conditioned basements and ~~for multi-family attached homes~~ dwelling units in residential buildings not over three stories in height above grade containing multiple dwelling units the following formula shall be used to determine total window area:”

Comment #59

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (b)
Comment Type: Editorial

Comment:

Clarification and increased uniformity in application and use.

Proposed Change:

The terms/phrases “above-grade boundary wall” and above-grade thermal boundary gross wall” are used and not defined. “Above-grade thermal boundary wall” is defined. These phrases may be intended to mean the same thing, but it is not clear. They should all be defined or the text in some way clarified. As covered in other comments, it is more appropriate to define terms in Section 3 on definitions and not throughout the standard.

Response:
Accepted. Definitions for wall types used in Table 4.2.1(1), note (b) will be modified to make the definitions consistent with the equation equalities in the final committee draft of BSR/RESNET Standard 301-201x. Since these wall type definitions pertain only to the calculation provided by note (b), and the terms are not used elsewhere in the Standard, there is no need to provide definitions for these wall types within Section 3 of the Standard. The revised text in question will read as follows:
“where:
AF = Total fenestration area
CFA = Total floor area of directly conditioned space
FA = (Gross above-grade thermal boundary wall area) / (gross above-grade thermal boundary wall area + 0.5 x gross below-grade thermal boundary wall area)
F = 1- 0.44* (gross common wall area) / (gross above-grade thermal boundary wall area + gross common wall area)

and where:
Thermal boundary wall is any wall that separates conditioned space from unconditioned space or ambient conditions
Above-grade thermal boundary wall is any portion of a thermal boundary wall not in contact with soil.
Below-grade thermal boundary wall is any portion of a thermal boundary wall in soil contact
Common wall is the total wall area of walls adjacent to another conditioned living unit, not including foundation walls.”

Comment #60

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (c)
Comment Type: Editorial

Comment:

Clarification and increased ease of application and use.

Proposed Change:

Replace “due south” with either plain “south” or, if needed to clarify magnetic declination issues, “true south.”

Response:
Accepted. Global search and replace will be used to replace “due south” with “true south” in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #61

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (d)
Comment Type: Technical

Comment:

ASHRAE Standard 119 was withdrawn in 2012 and as such no longer exists.

Proposed Change:

Delete the footnote as presented and find an alternative note that will address the intent of the standard.

Response:
Accepted. BSR/RESNET Standard 301-201x, Table 4.2.1(1), Note (d) will be modified to reflect the correct reference for the calculation, which is now found in Section 4.1.2 of ASHRAE Standard 62.2.

Comment #62

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (e)
Comment Type: General

Comment:

See comments to Equation 4.1-1. It is inappropriate to list a specific conformity assessment agency or organization by name in standard. This issue is addressed through the use of terms such as “approved” and “nationally recognized” and then as warranted federal, state or local agencies that formulate and implement associated laws and regulations will determine the degree to which they would verify the continued acceptance of any third parties and continue to allow them to conduct testing, certification, etc. work associated with conformity assessment on behalf of those adopting entities. Inclusion of RESNET in this standard within the context that the only entity that can conduct such testing is a rater certified by RESNET (see defined term in Section 3) should be seriously considered and removed in place of the suggested use of “approved” and its definition. As currently presented in the standard RESNET certification is listed as the only acceptable conformity assessment method as a first-party entity (e.g. self-certification and accreditation) with respect to its ability to perform the stated services on a continuing (e.g. in perpetuity) basis. This is something that accrediting entities such as ANSI, NAVLAP, IAS and others are actively engaged in on an ongoing basis as third party accrediting entities. As such they could assess any RESNET certification programs separately and through certification RESNET could be recognized as an “approved” entity. Inclusion of a first party conformity assessment entity or accrediting agency as RESNET is in the standard opens up the question for users – who then provides oversight of those agencies ongoing activities to ensure they meet standards for conformity assessment entities and should continue to be “approved”.

Also for consideration, where any conformity assessment program is mentioned by name in a standard, whether adopted on a voluntary or mandatory basis, the adoption of the standard results in a defacto acceptance of the named conformity assessment program in perpetuity; that is something that can change in the future to be accepted now. This could adversely affect the adoption and use of the standard and for that reason, as in the comment on Equation 4.1-1, it is suggested that the issue of certification and accreditation be decoupled from the standard through the use of “approved” and “nationally recognized”.

Proposed Change:

(e) Tested envelope leakage shall be determined and documented ~~by a Certified Rater~~ using the on-site inspection protocol as specified in Appendix A, Mortgage Industry National Home Energy Rating Systems Standards under “Blower Door Test.” by an approved testing agency. Either hourly calculations using the procedures given in the 2001 ASHRAE Handbook of Fundamentals, Chapter 26, page 26.21, equation 40 (Sherman-Grimsrud model) or calculations yielding equivalent results shall be used to determine the energy loads resulting from air exchange.

Response:
Accepted as modified. The comment is modified to retain the specified air exchange rate calculation method and update the calculation specifications to the most current reference, as follows:

“(e) Tested envelope leakage shall be determined and documented by a Certified Rater using the on-site inspection protocol as specified in ~~Appendix A~~Section 802, Mortgage Industry National Home Energy Rating Systems Standards ~~under “Blower Door Test.”~~ by an Approved Tester. Either hourly calculations using the procedures given in the ~~2001~~2009 ASHRAE Handbook of Fundamentals, Chapter 2616, page ~~26.21~~16.23, equation 4048 (Sherman-Grimsrud model) or calculations yielding equivalent results shall be used to determine the ~~energy loads resulting from~~ air exchange rate.”

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #63

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (g)
Comment Type: General

Comment:

If the term thermal storage element is used more than one place in the standard it may be advisable to include a definition of thermal storage element in Section 3, thereby eliminating the need to define the term where used throughout the standard. What is proposed is more in alignment with a definition, although the criteria in the note associated with the limitations of the storage in terms of installation would be appropriate for the note. Also note the existence of a definition ensures uniform and consistent application and use of the standard with respect to the defined terms that can be compromised if the terms are defined/redefined each time they appear in the standard. In addition if those terms are used somewhere in the standard and not defined it is unclear without a definition how they would be defined.

Proposed Change:

Note (g) seems more appropriate as a definition.

Response:
Rejected. The term “thermal Storage element” is used only in Table 4.2.1(1) so there is no need to include its definition in Section 3 of BSR/RESNET Standard 301-201x.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #64

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (h) (1)
Comment Type: Editorial

Comment:

Clarification and increased ease of use.

Proposed Change:

Phrases such as “…is found in the Rated Home” may be confusing because the Rated Home will always initially be a design only. “Found” implies something identified in an existing home. Consideration should be given to revising the text so it can be applied in the design phase.

Response:
Accepted. The words “is found” will be stricken and the text will be adjusted accordingly in the final committee draft of BSR/RESNET Standard 301-201x, as follows:

“. . . . For the HERS Reference Home, the minimum efficiencies given in Table 4.2.2(1a) below will be assumed for:

1) A type of device not covered by NAECA in the Rated Home;

2) A Rated Home heated by electricity using a device other than an air source heat pump; or

3) A Rated Home that does not contain one or more of the required HVAC equipment systems.”

Comment #65

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (h), (i), (k) and (m)
Comment Type: Technical

Comment:

The term “prevailing federal minimum efficiency” is vague, undefined and will be subject to interpretation leading to increased mis-application of the standard. Beyond that it forces all users to research and determine what that efficiency might be. All federal rules are delineated in the Code of Federal Regulations (CFR) and should be specifically referenced to the CFR Title and Part by number and name.

Proposed Change:

Replace the term “prevailing federal minimum efficiency” with a specific citation to the Code of Federal Regulations.

Response:
Accepted. Table 4.2.1(1) notes (h), (i), (k), and (m) will be adjusted accordingly in the final committee draft of BSR/RESNET Standard 301-201x, as follows:

(h) For a Rated Home with multiple heating, cooling, or water heating systems using different fuel types, the applicable system capacities and fuel types shall be weighted in accordance with the loads distribution (as calculated by accepted engineering practice for that equipment and fuel type) of the subject multiple systems. For the HERS Reference Home, the minimum efficiencies given in Table 4.2.2(1a) below will be assumed for:

1) A type of device not covered by NAECA in the Rated Home;

2) A Rated Home heated by electricity using a device other than an air source heat pump; or

3) A Rated Home that does not contain one or more of the required HVAC equipment systems.

(i) For a Rated Home without a proposed heating system, a heating system with the efficiency provided in Table 4.2.2(1a) shall be assumed for both the HERS Reference Home and Rated Home. For electric heating systems, the efficiency air-source heat pump shall be selected.

(k) For a Rated Home without a proposed cooling system, an electric air conditioner with the efficiency provided in Table 4.2.2(1a) shall be assumed for both the HERS Reference Home and the Rated Home.

(m) For a Rated Home with a non-storage type water heater, a 40-gallon storage-type water heater of the same fuel as the proposed water heater shall be assumed for the HERS Reference Home. For tankless water heaters, the Energy Factor (EF) for shall be multiplied by 0.92 for Rated Home calculations. For a Rated Home without a proposed water heater, a 40-gallon storage-type water heater of the same fuel as the heating fuel type used for the heating system shall be assumed for both the Rated and HERS Reference Homes. In both cases the Energy Factor of the water heater shall be as prescribed for water heaters by CFR 430.32(d), published in the Federal Register/Volume 66, No. 11, Wednesday, January 17, 2001 for water heaters manufactured after January 20, 2004.

Comment #66

Page Number: 16
Paragraph / Figure / Table / Note: table 4.2.1(1) note (h) (1)
Comment Type: Editorial

Comment:

NAECA is not defined nor described in the standard. While many users will understand what this means others may not. More importantly if the intent is to have this standard adopted and used, whether on a mandatory or voluntary basis, what is presented in the standard needs to be crystal clear and not in need of any further interpretation or speculation as to intent or requirements.

Proposed Change:

Define the term NAECA. It is not listed in Section 3 and is not defined as to what NAECA means. The correct reference should be to a Public Law designation and included in the definitions, a list of acronyms and/or a listing of reference standards.

Response:
Accepted. The term NAECA will be defined with respect to the correct reference to Public law in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #67

Page Number: 17
Paragraph / Figure / Table / Note: Table 4.2.2(1a), Note (m)
Comment Type: Editorial

Comment:

The term “predominant” is subjective and not capable of being defined in a manner that would ensure consistency in the application and use of the standard. For instance, is predominant based on the township, city, county, state or region of the country? What is the statistical basis for that determination? Without these specifically defined continued use of “predominant” will cause confusion. The proposed change addresses this issue in a clear manner that is less likely to cause confusion and non-uniform application of the standard.

Proposed Change:

(m) For a Rated Home with a non-storage type water heater, a 40-gallon storage-type water heater with the prevailing federal minimum efficiency and with the same fuel as the proposed water heater shall be assumed for the HERS Reference Home. For a Rated Home without a proposed water heater, a 40-gallon storage-type water heater with the prevailing federal minimum efficiency with the same fuel as the ~~predominant~~ heating fuel type used for the heating system shall be assumed for both the Rated and HERS Reference Homes.

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x. This change is also reflected in the Committee Response to Comment 65.

Comment #68

Page Number: 18
Paragraph / Figure / Table / Note: Table 4.2.2(1a), Note (n)
Comment Type: General

Comment:

See comments to Equation 4.1-1 and Table 4.2.2(1), Note (e). It is inappropriate to list a specific conformity assessment agency or organization by name in standard. This issue is addressed through the use of terms such as “approved” and “nationally recognized” and then as warranted federal, state or local agencies that formulate and implement associated laws and regulations will determine the degree to which they would verify the continued acceptance of any third parties and continue to allow them to conduct testing, certification, etc. work associated with conformity assessment on behalf of those adopting entities. Inclusion of RESNET in this standard within the context that the only entity that can conduct such testing is a rater certified by RESNET (see defined term in Section 3) should be seriously considered and removed in place of the suggested use of “approved” and its definition. As currently presented in the standard RESNET certification is listed as the only acceptable conformity assessment method as a first-party entity (e.g. self-certification and accreditation) with respect to its ability to perform the stated services on a continuing (e.g. in perpetuity) basis. This is something that accrediting entities such as ANSI, NAVLAP, IAS and others are actively engaged in on an ongoing basis as third party accrediting entities. As such they could assess any RESNET certification programs separately and through certification RESNET could be recognized as an “approved” entity. Inclusion of a first party conformity assessment entity or accrediting agency as RESNET is in the standard opens up the question for users – who then provides oversight of those agencies ongoing activities to ensure they meet standards for conformity assessment entities and should continue to be “approved”.

Also for consideration, where any conformity assessment program is mentioned by name in a standard, whether adopted on a voluntary or mandatory basis, the adoption of the standard results in a defacto acceptance of the named conformity assessment program in perpetuity; that is something that can change in the future to be accepted now. This could adversely affect the adoption and use of the standard and for that reason, as in the comment on Equation 4.1-1 and Table 4.2.2(1), Note (e), it is suggested that the issue of certification and accreditation be decoupled from the standard through the use of “approved” and “nationally recognized”.

Proposed Change:

n) Tested duct leakage shall be determined and documented by ~~a Certified Rater~~ an approved testing agency using the on-site inspection protocol as specified in Appendix A under “Air leakage (ducts)”.

There is also a reference to nonexistent ‘Appendix A under “Air leakage (ducts)”’ that should be clarified and corrected so it is clear what is being referred to and where it is in the document or in a reference document.

Response:
Accepted as modified. The comment is modified to provide the correct reference for duct leakage testing, as follows:

“n) Tested duct leakage shall be determined and documented by ~~a Certified Rater~~ an Approved Tester using the ~~on-site inspection~~ protocols as specified in ~~Appendix A under “Air leakage (ducts)”~~Section 803, Mortgage Industry National Home Energy Rating Systems Standards.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #69

Page Number: 18
Paragraph / Figure / Table / Note: Table 4.2.2(1), Note (o)
Comment Type: Technical

Comment:

Clarification of intent. Also of note the term “biomass fuel” does not appear to be defined, which will lead to probable interpretation and confusion. In addition the use of “should” in a standard ensures that the intent to standardize ratings will not occur. A standard such as this must provide specific and clear criteria if the continuity and uniformity envisioned in HERS ratings is to be realized. The use of the term “house” is confusing (see prior comments on scope and definition of residential) and could lead many users to presume that dwelling units in multi-family buildings are not addressed. This raises another key issue that may need consideration here and in other parts of the standard – how does this standard address multi-family buildings where there are multiple dwelling units that are served by a singular central heating, cooling and/or service hot water system?

Proposed Change:

(o) Biomass fuel systems ~~should~~ shall ~~not~~ be included in ratings ~~when they are considered “supplemental systems”, i.e. where an automatic~~ only when a permanent heating system, sized to meet the load of the ~~house~~ dwelling unit does not exists. Biomass systems should only be included in the rating in those situations where the automatic heating system is not large enough to meet the load of the house, and a biomass fuel system is in place to meet the balance of the load, or where there is only a biomass fuel system in place. In the situation where there are two systems that together meet the load, Where installed to supplement a permanent heating system that cannot meet the load of the dwelling unit the biomass system shall be assigned only that part of the load that cannot be met by the ~~automatic~~ permanent heating system.

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x and “Biomass Fuel” will also be added as a defined term in the definitions, as follows:

“Biomass Fuel – Plant materials that have been processed to be capable of providing useful heat through combustion.”

Comment #70

Page Number: 18
Paragraph / Figure / Table / Note: Table 4.2.2(2), Note (b)
Comment Type: Editorial

Comment:

Standards should refer to the specific reference document by name and in a reference standards section refer to the edition of use. In referring to the IECC the latest edition (2012) is the most appropriate reference because among others it will be available when prior editions are less likely to be available or accessible. It should be noted that Note (a) to Table 4.2.2(4) refers to the 2000 IECC. The referencing of multiple (and in this case older) editions of the same document should be eliminated. If anything this will adversely affect the use of this document by requiring users to secure multiple different older editions of the IECC. In addition should RESNET desire this standard and the resultant ratings to be acceptable in lieu of state or local energy codes, the standard should refer to the lasted published edition of any reference standards. The appropriate format for this is to name the document in the text without any edition date and then in a reference standards section include the full title, edition date, publisher and other related information appropriate for knowing what the standard is and where it can be obtained.

Proposed Change:

(b) Climates zones shall be as specified by the ~~2004 Supplement to the~~ International Energy Conservation Code.

Response:
Accepted. Table 4.2.2(4) will be removed from the standard through acceptance of Comment #6.

Comment #71

Page Number: 19
Paragraph / Figure / Table / Note: Table 4.2.2(4), Note (a)
Comment Type: Editorial

Comment:

Note (a) is informative and is not needed. The default numbers are what they are and there is no reason to explain where they came from in the standard. This raises the issue of lack of similar background for other provisions in the standard; all of which could be included in an informative appendix to the standard or a separate background document.

Proposed Change:

Table 4.2.2(4), Note (a)

Response:
Rejected. Table 4.2.2(4) will not be incorporated in the final committee draft of BSR/RESNET Standard 301-201x due to Committee acceptance of public comment #6 recommending its deletion.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #72

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(4), Note (c)
Comment Type: Technical

Comment:

There is no definition of conditioned space. This along with the definition of building thermal envelope is critical to the application and use of the IECC. The intent seems clear and in lieu of defining those terms the proposed change makes the intent as to when duct systems are inside the building envelope or not (e.g. in conditioned space). Alternatively consideration should be given to defining the terms conditioned space and building thermal envelope, both of which are defined in energy codes and standards and whose definitions are critical to the uniform application and use of those documents.

Proposed Change:

(c) Entire system in conditioned space shall mean that no component of the distribution system, including the air handler unit or boiler, is located outside of the ~~conditioned space boundary~~ spaces of the dwelling unit that are heated and/or cooled.

Response:

Accepted in part. Table 4.2.2(4) will not be incorporated in the final committee draft of BSR/RESNET Standard 301-201x due to SDC acceptance of public comment #6 recommending its deletion. However, the SDC has determined that the comment warrants revision or addition of the following four inter-related definitions in Section 3 of BSR/RESNET Standard 301-201x.

Conditioned Floor Area (CFA) – The projected floor area of the Conditioned Space within a building measured in accordance with ANSI Standard Z765-2012 with exceptions as specified in Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards.

Conditioned Space – An area or room within a building serviced by a space heating or cooling system designed to maintain human comfort in accordance with ASHRAE Standard 55-2010.

Conditioned Space Boundary – The principal air containment planes of a building that separate the Conditioned Space within the building from Unconditioned Space.

Unconditioned Space – The outdoor environment or an area or room within a building that is not Conditioned Space but which may contain heat sources or sinks that influence the temperature of the area or room.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #73

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(4), Note (d)
Comment Type: Technical

Comment:

The provisions “substantially leak free” and “leakage less than 3 cfm per 100 sf” is contradictory and inconsistent. The former is subjective and indeterminate in any uniform manner while the latter is specific and determinant. The proposed change addresses this issue and enhances the standard by retaining the more specific of the two criteria. There is no need for the second sentence as it repeats the criteria of the first sentence.

The last sentence is revised for clarity and to address the issue of inappropriately embedding professional qualifications and credentialing inside this type of standard. For instance see comments to Equation 4.1-1 and Table 4.2.2(1), Note (e). It is inappropriate to list a specific conformity assessment agency or organization by name in standard. This issue is addressed through the use of terms such as “approved” and “nationally recognized” and then as warranted federal, state or local agencies that formulate and implement associated laws and regulations will determine the degree to which they would verify the continued acceptance of any third parties and continue to allow them to conduct testing, certification, etc. work associated with conformity assessment on behalf of those adopting entities. Inclusion of RESNET in this standard within the context that the only entity that can conduct such testing and documentation is a rater certified by RESNET (see defined term in Section 3) should be seriously considered and removed in place of the suggested use of “approved” and its definition. As currently presented in the standard RESNET certification is listed as the only acceptable conformity assessment method as a first-party entity (e.g. self-certification and accreditation) with respect to its ability to perform the stated services on a continuing (e.g. in perpetuity) basis. This is something that accrediting entities such as ANSI, NAVLAP, IAS and others are actively engaged in on an ongoing basis as third party accrediting entities. As such they could assess any RESNET certification programs separately and through certification RESNET could be recognized as an “approved” entity. Inclusion of a first party conformity assessment entity or accrediting agency as RESNET is in the standard opens up the question for users – who then provides oversight of those agencies ongoing activities to ensure they meet standards for conformity assessment entities and should continue to be “approved”.

Also for consideration, where any conformity assessment program is mentioned by name in a standard, whether adopted on a voluntary or mandatory basis, the adoption of the standard results in a defacto acceptance of the named conformity assessment program in perpetuity; that is something that can change in the future to be accepted now. This could adversely affect the adoption and use of the standard and for that reason, as in the comment on Equation 4.1-1 and Table 4.2.2(1), Note (e), it is suggested that the issue of certification and accreditation be decoupled from the standard through the use of “approved” and “nationally recognized”.

Proposed Change:

(d) Proposed “reduced leakage” shall mean ~~substantially leak free to be~~ leakage of not greater than 3 cfm to outdoors per 100 square feet of conditioned floor area and not greater than 9 cfm total air leakage per 100 square feet of conditioned floor area at a pressure differential of 25 Pascal across the entire system, including the manufacturer’s air handler enclosure. Total air leakage of not greater than 3 cfm per 100 square feet of conditioned floor area at a pressure difference of 25 Pascal across the entire system, including the manufacturer’s air handler enclosure, shall be deemed to meet this requirement without measurement of air leakage to outdoors. This rated condition shall be specified as “reduced leakage” ~~the required performance~~ in the construction documents and ~~requires confirmation~~ compliance confirmed through field-testing of installed systems as documented by ~~a Certified Rater~~ an approved testing agency.

Response:
Accepted as modified. Table 4.2.2(4) and its notes will be removed from BSR/RESNET Standard 301-201x based on acceptance of public comment #6.

Comment #74

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(4), Note (e)
Comment Type: Editorial

Comment:

The language as drafted is permissive and not appropriate for a standard where uniformity, consistency and clarity in the application of the standard are desired.

Proposed Change:

(e) Ductless systems ~~may have~~ having forced airflow across a coil ~~but~~ shall not have any ducted airflows external to the manufacturer’s air handler enclosure.

Comment #75

Page Number: 20
Paragraph / Figure / Table / Note: Section 4.2.2.1
Comment Type: Editorial

Comment:

The intent is clearly to have the user of the standard apply the framing fractions in the table. The proposed revisions communicate that intent and direction and eliminate text that is not needed and could detract from the desirability of the standard.

Proposed Change:

4.2.2.1. All enclosure elements ~~shall~~ ~~use framing fractions that are consistent with and representative of reality. Default enclosure~~ framing fractions ~~are provided by~~ shall be in accordance with Table 4.2.2(6).

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #76

Page Number: 21
Paragraph / Figure / Table / Note: Section 4.2.2.2.1
Comment Type: Editorial

Comment:

It is unclear how this section is to be applied as inspection is most likely to occur after modeling. The standard should be clarified to indicate the sequence in which inspection and modeling are conducted in order to arrive at a rating is intended to occur. One way to do that would be to write a new section 4 on compliance and outline therein an overview of the standard and how the rating is to be determined and compliance as to the validity of the rating in the actual construction is ensured.

The revision to exception (a) is intended to eliminate permissive language and strengthen the intent of the document. It is noted that the inclusion of where DAPIA packages may be submitted is likely moot as to application of this standard, unless the intent is to apply this standard over and above the HUD Code (24 CFR Part 3280). Of particular note, this exception applies to both manufactured and modular construction. Since modular construction is not regulated by HUD but instead state laws and regulations, why have the standard require DAPIA approved packages for modular homes to be sent to HUD?

Exception (b) is not worded as an exception because it actually contains criteria that are attached to the exception. The proposed change more clearly states the intent in a more appropriate format for an exception to the requirements in the standard. The word “similar” is subjective and should not be used in a standard if standardization with respect to HERS and clarity and uniformity of use are desired.

Exception (c) is deleted. As commented in previous sections (i.e. Equation 4-1.1) the inclusion of a conformity assessment entity by name is not appropriate. The exception is stated in permissive terms because the entity that can invoke “may” is not stated. In addition the “conditions specified in the RESNET approval process” is an open ended provision that could adversely affect the adoption and use of the standard. What is the process and more specifically what is the date certain of that process. A standard with a date certain approval and publication date cannot adopt by reference something that is not specifically defined as to a publication with a specific publication date.

Proposed Change:

4.2.2.2.1. The HERS Reference Home enclosure elements shall be modeled assuming Grade I insulation. Default values for Rated Home insulation that is not inspected according to the procedures of Appendix A, Mortgage Industry National Home Energy Rating Systems Standards shall be in accordance with the requirements of Grade III as given in Section 4.2.2.2.2 and shall be recorded as “not inspected” in the rating information.

Exceptions:

(a) Modular and manufactured housing using IPIA (In-Plant Inspection Agent) inspections ~~may~~ ~~be substituted~~ shall be considered as an acceptable alternative for the HERS inspection~~. However, housing~~ where the manufacturer ~~shall include~~ of the home includes RESNET insulation inspection details and requirements in their “DAPIA” (Design Approval Primary Inspection Agency) packages ~~submitted to HUD~~ which are used by IPIA’s for their factory inspections.

(b) The R-values for Structural Insulated Panels (SIP’s), Insulated Concrete Forms (ICF’s), and other ~~similar insulated~~ pre-manufactured assemblies when accompanied by supporting test data. Note that manufacturer’s claims of “equivalent” R-values based on reduced air leakage or other secondary effects may not be used; only the thermal resistance values for the actual materials as found in ASHRAE Handbook of Fundamentals may be used.

~~(c) A RESNET-approved, third-party audited installer certification program may be substituted under the conditions specified in the RESNET approval process.~~

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #77

Page Number: 22
Paragraph / Figure / Table / Note: Section 4.2.2.2.2
Comment Type: Editorial

Comment:

The intent appears to be a listing of four caveats to the provisions in Section 4.2.2.2.2 and as such the subsequent sections should not have a parallel numerical designation but actually listed as subsections to the parent section (4.2.2.2.2). Section 4.2.2.2.4 is revised editorially to improve the usability of the standard. For the convenience of the user the correction factors should be provided in the standard. If the reference to another document is retained it should be to the document by name, publication date and the specific criteria therein (e.g. section number). The date of publication should not be listed within the provisions of the standard but in a section on reference standards, which also applies to Section 4.2.2.2.6 and a number of other sections in the standard where other documents are referenced; some of which have different edition dates associated with the same reference. Section 4.2.2.2.5 is revised to more clearly state the intent. The use of the term “large” is subjective and indeterminate. In addition it is not appropriate to put informative notes in a standard. The standard must first be as clear and precise as to the requirements so no such notes are needed. If application and use of the standard is desired and there is a desire for notes or related support information then a separate commentary could be produced or the issue needing notes addressed in a Foreword to the standard. It is also important and critical to note the reference to the 2009 ASHRAE Handbook of Fundamentals. Other portions of this standard refer to the 2001 edition and still others refer to that document without any edition date. As covered above and in other comments, this issue should be addressed throughout the standard and is one of a number of areas that if left as proposed could detract from the adoptability, acceptability and use of the standard.

Proposed Change:

4.2.2.2.2. Insulation Assessment: Insulated surfaces categorized as “Grade I” shall be modeled such that the insulation R-value within the cavity is considered at its measured (for loose fill) or labeled value, including other adjustments such as compression, and cavity fill versus continuous, for the insulated surface area (not including framing or other structural materials which shall be accounted for separately). Insulated surfaces categorized as "Grade II" shall be modeled such that there is no insulation R-value for 2% of the insulated surface area and its measured or labeled value, including other adjustments such as compression and cavity fill versus continuous, for the remainder of the insulated surface area (not including framing or other structural materials). Insulated surfaces categorized as "Grade III" shall be modeled such that there is no insulation R-value for 5% of the insulated surface area and its measured or labeled value, including other adjustments such as compression and cavity fill versus continuous, for the remainder of the insulated surface area (not including framing or other structural materials). Other building materials, including framing, sheathing, and air films shall be assigned aged or settled -values according to ASHRAE Fundamentals. In addition, the following ~~accepted~~ conventions shall be used in modeling Rated Home insulation enclosures:

~~4.2.2.2.3.~~ a. Insulation that does not cover framing members shall not be modeled as if it covers the framing. Insulated surfaces that have continuous insulation (i.e. rigid foam, fibrous batts, loose fill, or sprayed insulation) covering the framing members shall be assessed and modeled according to Section 4.2.2.2 and combined with the cavity insulation, framing and other materials to determine the overall assembly R-value.

~~4.2.2.2.4.~~ b. ~~Compression: for modeling purposes, the~~ The base R-value of fibrous insulation that is compressed to less than its full rated thickness in a completely enclosed cavity shall be assessed according to the manufacturer's documentation~~; in the absence of such documentation, use R-value correction factor (CF) for Compressed Batt or Blanket from Manual J, 8th edition Table A5-1, Section 7-d~~.

~~4.2.2.2.5.~~ c. ~~Where large areas of insulation that is missing, or has a different R-value from the rest of an assembly exist, these~~ ~~areas~~ Areas of an assembly having different insulation types or R-values shall be modeled separately with the ~~appropriate~~ applicable R-value and assembly description separately from the rest of the assembly. Insulation R-values may not be averaged according to coverage area. For example, if 50 square feet of a wall area has no cavity fill insulation at all, that 50 square feet shall be recorded as a separate building component with no cavity insulation, but with the existing structural components area associated with each different insulation situation.

~~4.2.2.2.6.~~ d. ~~Steel framing in insulated assemblies: calculations for the~~ The overall thermal properties of steel-framed walls, ceilings and floors shall be based on the “Zone Method” from ~~2009~~ the ASHRAE Handbook of Fundamentals (p 27.5); or equivalent.

Response:
Accepted as modified. The proposed change except as modified below will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

~~“4.2.2.2.4~~. b. ~~Compression: for modeling purposes, the~~ The base R-value of fibrous insulation that is compressed to less than its full rated thickness in a completely enclosed cavity shall be assessed according to the manufacturer's documentation; ~~in the absence of such documentation, use R-value correction factor (CF) for Compressed Batt or Blanket from Manual J, 8th edition Table A5-1, Section 7-d.~~ In the absence of such documentation, use R-value correction factor (CF) for Compressed Batt or Blanket from Manual J, 8th edition Table A5-1, Section 7-d.”

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #78

Page Number: 22
Paragraph / Figure / Table / Note: Section 4.2.2.3
Comment Type: Technical

Comment:

Improved clarity in presentation of criteria leading to increased uniformity in application and reporting of the outcomes associated with use of the standard.

Proposed Change:

The term “renewable energy” is not defined in the standard and if not defined will result in considerable confusion and lack of uniformity, especially given the use of the term “other”. Is other biomass, geothermal, ground or water source applied to heat pumps, tides, etc.? Model codes and standards that address energy efficiency define this term to ensure clarity of application.

Response:
Accepted. The term “Renewable Energy System” will be defined in the final committee draft of BSR/RESNET Standard 301-201x as follows:

“Renewable Energy System – means of transforming solar thermal energy or producing electric power that rely on naturally-occurring, on-site resources that are not depleted as a result of their use. Renewable Energy Systems shall include, but are not limited to, solar energy systems, wind energy systems and geothermal energy systems.”

Comment #79

Page Number: 24
Paragraph / Figure / Table / Note: Section 4.2.2.5.1.5
Comment Type: Editorial

Comment:

When referring to a section number that is within the standard (e.g. itself) it is not necessary to clarify for the user that the section number applies to the standard. That is not done elsewhere and for consistency throughout the standard this issue should be corrected.

Proposed Change:

4.2.2.5.1.5. Ceiling Fans. Where ceiling fans are included in the Rated Home they shall also be included in the Reference Home in accordance with the provisions of Section 4.2.2.5.2.11 ~~of this Standard~~.

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #80

Page Number: 24
Paragraph / Figure / Table / Note: Section 4.2.2.5.2
Comment Type: Editorial

Comment:

Clarification as to intent and for consistency with the presentation of the parallel provisions in Section 4.2.2.5.1 for the reference home.

Proposed Change:

4.2.2.5.2. HERS Rated Homes. ~~For Rated homes, the following procedures shall be used to determine lighting, appliance and residual miscellaneous~~ ~~electric load energy consumption~~ The lighting, appliance and miscellaneous electric loads in the HERS rated home shall be determined in accordance with Sections 4.2.2.5.2.1 through 4.2.2.5.2.12.

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #81

Page Number: 24
Paragraph / Figure / Table / Note: Section 4.2.2.5.2.1
Comment Type: Editorial

Comment:

Consistency in presentation throughout the standard that fosters adoption and ease of use.

Proposed Change:

It is noted that in this section CFA is used to indicate conditioned floor area and in other portions of the standard the term is spelled out and an acronym not used. It is suggested that the standard refer to this term consistently throughout by spelling out the term and not using an acronym or because the term is defined in Section 3 and the acronym indicated therein then not using the term and simply using CFA throughout the text.

Response:
Accepted. The acronym “CFA” will be used in place of the term “conditioned floor area” consistently throughout the body of the Standard in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #82

Page Number: 24
Paragraph / Figure / Table / Note: Section 4.2.2.5.2.2
Comment Type: Editorial

Comment:

Consistency in presentation of similar provisions in the standard. This is also consistent with terminology found in standards and codes that are intended to be applied and used in a similar manner to this standard. See also the comment to Section 4.2.2.5.2.3. The standard is not currently consistent from section to section on this same issue of referencing an equation and requiring its use and that issue should also be addressed throughout the document.

Proposed Change:

4.2.2.5.2.2. Interior Lighting. Interior lighting in the Rated home is shall be ~~calculated~~ determined ~~using~~ in accordance with equation 4.2-2:

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #83

Page Number: 25
Paragraph / Figure / Table / Note: Section 4.2.2.5.2.3
Comment Type: Editorial

Comment:

Consistency in presentation of similar provisions in the standard. This is also consistent with terminology found in standards and codes that are intended to be applied and used in a similar manner to this standard. See also the comment to Section 4.2.2.5.2.2. Note for simplicity and to save time in presenting comments this same language should be repeated consistently throughout the standard (e.g. 4.2.2.5.2.4, etc.).

Proposed Change:

4.2.2.5.2.3. Exterior Lighting. Exterior lighting in the Rated home shall be determined ~~using~~ in accordance with equation 4.2-3:

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #84

Page Number: 29
Paragraph / Figure / Table / Note: Section 4.2.2.5.2.10
Comment Type: Editorial

Comment:

Consistency in terminology and presentation that fosters adoption and ease of use.

Proposed Change:

It is noted that this section refers to annual energy use and prior sections do not. It is suggested that consistent terminology and presentation be used throughout the 12 subsections to Section 4.2.2.5.2 as to presentation of the topic, what is being covered (annual energy use), referring to the equations by number, etc.

Response:
Accepted. The 12 subsections of Section 4.2.2.5.2 will be revised for consistent use of terminology and presentation in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #85

Page Number: 32
Paragraph / Figure / Table / Note: Section 4.3
Comment Type: Editorial

Comment:

Based on the section/subsection hierarchy it is not clear what “the following” refers to. Specific subsections that are intended to guide the assumptions must be numerically designated to eliminate confusion. The standard is such that there is no need to indicate who is to do the estimation – it is clear that HERS providers would to this and as presented opens up an unnecessary criticism of the standard – if not a HERS provider then those assumptions do not need to be used.

Proposed Change:

4.3. Operating Condition Assumptions. ~~All HERS providers shall estimate t~~ The annual purchased energy consumption for heating, cooling and hot water for both the Rated Home and the Reference Home shall be estimated in accordance with Sections 4.3.1 through 4.3.3. ~~using the following assumptions–~~

Response:
Accepted. The proposed change will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #86

Page Number: 32
Paragraph / Figure / Table / Note: Section 4.3.2
Comment Type: Editorial

Comment:

Increased ease of application and use of the standard in a consistent manner that fosters adoption and ease of use.

Proposed Change:

The current text is permissive in nature and needs to be corrected. It is unclear who the accrediting body is but it appears the intent is to have this issue addressed at the state level when the standard is adopted for use. If that is the intent then it is suggested that this section have a blank table which is to be filled in by the adopting entity as to the climatic conditions and that table reference in footnote suggested sources to consult when completing the table. This allows the adopting entity to decide this issue in a clearer manner than is presently provided. This approach is consistent with other model codes and standards.

Response:
Accepted. Section 4.3.2 will be modified and incorporated in the final committee draft of BSR/RESNET Standard 301-201x, as follows:

“4.3.2 Local Climate. The climatologically most representative TMY3 or equivalent climate data.”

Comment #87

Page Number: 32
Paragraph / Figure / Table / Note: Section 4.3.3
Comment Type: Editorial

Comment:

Clarification and increased uniformity of application and use that fosters adoption and ease of use.

Proposed Change:

See prior comments concerning referenced documents and inconsistency in edition. Also ACCA Manual S covers the issue of sizing and should be appropriately referenced.

Response:
Accepted. Manual S will be added as a reference for systems sizing in section 4.3.3.

Comment #88

Page Number: 32
Paragraph / Figure / Table / Note: Section 4.3.3
Comment Type: Editorial

Comment:

Increased simplicity and ease of application and use of the standard that fosters adoption and ease of use.

Proposed Change:

The topic covered relates to the loads associated with the reference home and the rated home for the purpose of HVAC system sizing. Section 4.3.3.1 provides relevant specifications for the former and Section 4.3.3.2 for the latter. The presentation of these provisions could be significantly improved through the use of a three column table that lists in row 1 the issue (e.g. indoor temperature), row 2 the value for the reference home and in row 3 the rated home.

Response:
Noted. This comment will be held on file for improvements in future revisions to BSR/RESNET Standard 301-201x

Comment #89

Page Number: 34
Paragraph / Figure / Table / Note: Section 4.4
Comment Type: Editorial

Comment:

The standard is such that there is no need to indicate who is to do the estimation – it is clear that HERS providers would to this and as presented opens up an unnecessary criticism of the standard – if not a HERS provider then those assumptions do not need to be used

Proposed Change:

4.4. Minimum Rated Features. ~~All HERS providers shall calculate the~~ The estimated annual purchased energy consumption for heating, cooling, water heating and lighting and appliances set forth in Section 4.2 of this Standard shall be determined using the energy loss and gain associated with the minimum rated features as set forth in Table 4.4.2(1).

Response:
Accepted. The proposed revision will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #90

Page Number: 35
Paragraph / Figure / Table / Note: Section 4.4.1
Comment Type: Editorial

Comment:

Clarification of intent to use what can be observed and then if not observable then it falls to local practice or codes. Those are combined in the suggested revision because they should be considered together. If not then there is not likely to be a need for the current reference to codes because in all cases building practice would be known and therefore be preferred. Manufactured housing and modular housing are also addressed in a more appropriate manner through the suggested revisions. It should be noted that there is no Section 4.4.1.1 in the standard so the reference to that section in section 4.4.1 should be changed to the appropriate section.

Proposed Change:

4.4.1. Data Sources. If data for the minimum rated features set forth in Section 4.4.1.1 of this Standard cannot be obtained by observation or without destructive disassembly of the home, default values shall be used~~. The default values are determined from the following sources listed in the preferential order of use:~~ based on current and historical local building practice and building codes and for modular or manufactured housing available data from the manufacturer.

~~(a) For manufactured homes, available manufacturer’s data:~~

~~(b) Current and historical local building practices; or~~

~~(c) Current and historical local building codes.~~

Response:
Accepted. The proposed revision will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #91

Page Number: 35
Paragraph / Figure / Table / Note: Section 4.4.2
Comment Type: Editorial

Comment:

Clarification and increased ease of application and use of the standard that fosters adoption and ease of use.

Proposed Change:

Modify all subsections to this section so that they are presented in mandatory standards language. For instance use “shall be determined” in lieu of “are determined” or “is determined”. Also note there is no governing text for the subsections under Section 4.4.2. The standard should be revised to include an introductory provision in Section 4.4.2 along the lines of “The features associated with the home shall be determined in accordance with Sections 4.4.2.1 through 4.4.2.4.”

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #92

Page Number: 35
Paragraph / Figure / Table / Note: Section 4.4.2.2.2
Comment Type: General

Comment:

Increased clarity that fosters adoption and ease of use. As stated in comments to other sections, it is inappropriate to list a specific conformity assessment agency or organization by name in standard. The text is revised for clarity and to address the issue of inappropriately embedding professional qualifications and credentialing inside this type of standard. For instance see comments to Equation 4.1-1 and Table 4.2.2(1), Note (e). It is inappropriate to list a specific conformity assessment agency or organization by name in standard. This issue is addressed through the use of terms such as “approved” and “nationally recognized” and then as warranted federal, state or local agencies that formulate and implement associated laws and regulations will determine the degree to which they would verify the continued acceptance of any third parties and continue to allow them to conduct testing, certification, etc. work associated with conformity assessment on behalf of those adopting entities. Inclusion of RESNET in this standard within the context that the only entity that can conduct such testing and documentation is a rater certified by RESNET (see defined term in Section 3) should be seriously considered and removed in place of the suggested use of “approved” and its definition. As currently presented in the standard RESNET certification is listed as the only acceptable conformity assessment method as a first-party entity (e.g. self-certification and accreditation) with respect to its ability to perform the stated services on a continuing (e.g. in perpetuity) basis. This is something that accrediting entities such as ANSI, NAVLAP, IAS and others are actively engaged in on an ongoing basis as third party accrediting entities. As such they could assess any RESNET certification programs separately and through certification RESNET could be recognized as an “approved” entity. Inclusion of a first party conformity assessment entity or accrediting agency as RESNET is in the standard opens up the question for users – who then provides oversight of those agencies ongoing activities to ensure they meet standards for conformity assessment entities and should continue to be “approved”.

Also for consideration, where any conformity assessment program is mentioned by name in a standard, whether adopted on a voluntary or mandatory basis, the adoption of the standard results in a defacto acceptance of the named conformity assessment program in perpetuity; that is something that can change in the future to be accepted now. This could adversely affect the adoption and use of the standard and for that reason, as in the comment on Equation 4.1-1 and Table 4.2.2(1), Note (e), it is suggested that the issue of certification and accreditation be decoupled from the standard through the use of “approved” and “nationally recognized”.

Proposed Change:

4.4.2.2.2. Observations of the condition of the building and duct system shall be made by ~~a Certified Rater~~ an approved agency and ~~. Based on these observations,~~ values from Tables 4.1.2(3) shall be used based on those observations.

Response:
Accepted as modified. The proposed revisions, as modified below, will be incorporated into BSR/RESNET Standard 301-201x.

4.4.2.2.2. Observations of the condition of the building and duct system shall be made by ~~a Certified Rater~~ an Approved Tester and ~~. Based on these observations,~~ values from Tables 4.1.2(3) shall be used based on those observations.

Comment #93

Page Number: 39
Paragraph / Figure / Table / Note: Section 4.4.3
Comment Type: Technical

Comment:

It is unclear how this provision is to be applied. First it is permissive, meaning for the same home with two different providers there can be two different results all else being identical depending on whether the rater chooses or not to implement the criterion. Secondly there is no determination associated with the measure of “capability” of energy analysis tools. This provision does not appear to have any relevance as well as it only applies to the rated home unless the intent is to allow the provider to count something in the rated home that is not covered for the baseline home. If that is the intent then as stated this provision is not specific enough to ensure that there will be any consistency or uniformity in if and how such additional features are addressed.

Proposed Change:

4.4.3. Additional Features. Any HERS provider may base annual purchased energy consumption estimates for the Rated Home on additional features if the Rating Provider’s energy analysis tool is capable of doing so.

Response:
Accepted. The proposal change will be incorporated in the final Committee draft of BSR/RESNET Standard 301-201x.

Comment #94

Page Number: 40
Paragraph / Figure / Table / Note: Section 4.5.2.1
Comment Type: General

Comment:

It is not appropriate within the body of a standard to include notes. Examples and explanations are more appropriate in a commentary or users guide.

Proposed Change:

Delete the note

Response:
Rejected. However, the intent of the footnote will be included by revising Section 4.5.2.1 as follows:

“4.5.2.1 Where an existing appliance (e.g., refrigerator) is replaced with a new appliance as part of the improvement, but the existing appliance is not removed from the home property, both the new and existing appliance shall be included in the Improved Home model.”

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #95

Page Number: 41
Paragraph / Figure / Table / Note: Section 4.5.3.1
Comment Type: Editorial

Comment:

Clarification and improved presentation to convey intent and improve use of the standard that fosters adoption and ease of use.

Proposed Change:

4.5.3.1. Both the Baseline Existing Home and Improved Home shall be configured and modeled in accordance with the Rated Home specifications of Table 4.2.2(1). ~~except that t~~ The configuration of the Baseline Home shall not ~~violate~~ exceed the ~~input constraints specified~~ values in Table 4.5.3(1) ~~below~~.

Response:
Accepted as modified. The proposed revisions, as modified below, will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

“4.5.3.1. Both the Baseline Existing Home and Improved Home shall be configured and modeled in accordance with the Rated Home specifications of Table 4.2.2(1). except ~~that t~~ The configuration of the Baseline Home shall not violate the specified input constraints in Table 4.5.3(1) ~~below~~.”

Comment #96

Page Number: 42
Paragraph / Figure / Table / Note: Section 4.5.3.2
Comment Type: Editorial

Comment:

Simplification and increased “usability” of the standard that fosters adoption and compliance.

Proposed Change:

Suggest replacing the current text with a table. Each of the sections and the exception is a singular sentence and conveys considerable information that is more likely to confuse users of the standard. Section 4.5.3.2 could be provided with the following text and then a table to convey the requirements with the necessary columns and rows developed from the current provisions of the standard.

“The Baseline Existing Home and Improved Home shall be configured and modeled in accordance with Table 4.5.3.2.”

Response:
Noted. This comment will be held on file for improvements in future revisions to BSR/RESNET Standard 301-201x.

Comment #97

Page Number: 45
Paragraph / Figure / Table / Note: Section 4.6.2
Comment Type: General

Comment:

The inclusion and implementation of a concept that allows for the review, revision, approval, publication and adoption of this standard at a fixed point in time with a proviso that values for application and use in the standard will be developed outside this process in perpetuity is inappropriate and could significantly impact the adoptability and use of this document. Given that the subsections to this section provide the detail for determining the values then it seems unnecessary for any mention of RESNET making these determinations other than as a note.

Proposed Change:

Revise by providing a blank table in which the selected values can be inserted by users, reference sources for the data and how the values should be determined. Then should RESNET want to provide information relevant to these numbers it can do so on an advisory basis outside the standards development process as is suggested in the standard.

Response:
Accepted as modified. The proposed revisions, as modified below, will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

4.6.2. Determination of Standard Economic Inputs. The following standard economic input values shall be determined by RESNET in accordance with this Section each January using the latest available specified data and published on the RESNET website.
a) General Inflation Rate (GR)
b) Discount Rate (DR)
c) Mortgage Interest Rate (MR)
d) Down Payment Rate (DnPmt)
e) Energy Inflation Rate (ER) The economic parameter values1 used in the cost effectiveness calculations specified in Section 4.6.1 shall be determined ~~as follows~~: in accordance with Sections 4.6.2.1 through 4.6.2.10.

1 (Informative Note) RESNET shall annually publish Standard Economic Input values for the General Inflation Rate (GI), Discount Rate (DR), Mortgage Interest Rate (MR), Down Payment Rate (DnPmt) and Energy Inflation Rate (ER) determined in accordance with this section that can be used by approved economic calculation tools.

Comment #98

Page Number: 46
Paragraph / Figure / Table / Note: Section 4.6.2.9.1
Comment Type: Editorial

Comment:

To clarify what minimum code or standard is applicable. There does not appear to be a definition of standard or code option in this document and it is believed the intent is to refer the user to some minimum that represents the least energy efficient design allowed (e.g. minimum standard or code applicable to the project). The suggested change is intended to clarify this intent, but it is noted that the document could be further revised to reference throughout a specific edition of the IECC as a minimum “stop” should there be no applicable standard or code where the building is to be constructed.

Proposed Change:

4.6.2.9.1. For New Homes the improvement costs shall be the full installed cost of the improvement(s) less the full installed cost ~~of the minimum standard or code option~~ associated with just meeting the minimum provisions of the energy code or standard in effect where the building is located less any financial incentives that accrue to the home purchaser.

Response:
Accepted as modified. The proposed revisions as modified below will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

4.6.2.9.1. For New Homes the improvement costs shall be the full installed cost of the improvement(s) less the full installed cost ~~of the minimum standard or code~~ ~~option~~ associated with ~~just meeting~~ the minimum provisions of the energy code or standard in effect where the building is located less any financial incentives that accrue to the home purchaser.

Comment #99

Page Number: 47
Paragraph / Figure / Table / Note: Section 5.1
Comment Type: General

Comment:

Increased understanding of the standard and to foster application and use.

Proposed Change:

Suggest one or two sentences that introduce the subject of certification and labeling and outline the format, flow and intended use of the entire section on certification and labeling.

Response:
Accepted. The proposed revisions, as shown below, will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

“5. Certification and Labeling. This section establishes minimum uniform standards for certifying and labeling home energy performance using the HERS Index. These include minimum requirements of the Home Energy Rating process, standard methods for estimating energy use, energy cost and pollution emission savings, minimum reporting requirements, and specification of the types of ratings that may be performed in accordance with this Standard.”

Comment #100

Page Number: 47
Paragraph / Figure / Table / Note: Section 5.1.1
Comment Type: Editorial

Comment:

Clarification and improved application and use of the standard that fosters adoption and ease of use.

Proposed Change:

Rewrite the entire section and subsections to more appropriately convey the requirements. It is currently written in informative dialogue as opposed to standards language that can be uniformly interpreted and applied. There is reference to “these standards” and “this standard”. When referring to a section number the only time the text should refer to a standard is when that section is to a standard other than the subject standard.

For instance 5.1.1 is better presented as “The rating for a home shall be determined in accordance with sections x through y”. Examples such as in 5.1.1.4 are not appropriate for a standard, but could be moved to an informative appendix that might provide an example of how one is to conduct a rating.

Response:
Accepted. Section 5.1.1 has been revised as follows. These revisions will be included in the final committee draft of BSR/RESNET Standard 301-201x.

5.1.1. General. ~~To determine the Rating for a home, all Rating Providers shall –~~The rating for a home shall be determined in accordance with sections 5.1.1.1 through 5.1.1.5.

5.1.1.1. ~~If rating~~For an existing home, required ~~visit the home to collect the data needed to calculate the rating;~~data shall be collected on site.

5.1.1.2. ~~If rating a new~~For a new, to-be-built home, ~~follow~~ the procedures ~~set forth in~~ of Section 4.7 and 4.8 ~~of these Standards~~ shall be used to collect ~~the~~ required data. ~~needed to calculate the rating;~~

5.1.1.3. ~~Use t~~The collected data shall be used to estimate the annual purchased energy consumption for heating, cooling and water heating, lighting and appliances for both the Rated Home and the Reference Home as ~~defined~~ specified in by Section 4.4. ~~of these Standards~~.

5.1.1.4. If the Rated Home includes On-site Power Production (OPP), then OPP shall be calculated as the gross electric power produced minus the Equivalent Electric Power Energy of any purchased fuels used to produce the electric power.1 The HERS Reference Home shall not include On-site Power Production.

For example, assume 1000 kWh (3413 kBtu or 3.413 MBtu) of gross electrical power is produced using 60 therms (6 MBtu) of natural gas to operate a high-efficiency fuel cell system. Using these assumptions, OPP = 3.413 MBtu - (6 MBtu * 0.4) = 1.0 MBtu.

5.1.1.5. Estimates completed ~~by all HERS providers under~~ using Sections 5.1.1.3 and 5.1.1.4 ~~of this Standard must be–~~shall comply with Sections 5.1.1.5.1 through 5.1.1.5.3

5.1.1.5.1. ~~Conducted~~ All estimates shall ~~using~~ assume the standard operating ~~assumptions~~ conditions ~~established~~ of in Section 4.2 of ~~these Standards~~.

5.1.1.5.2. All estimates shall be Bbased on the minimum rated features ~~set forth~~ of in Section 4.3 ~~of these Standards~~.

5.1.1.5.3. All estimates shall be ~~Conducted~~ calculated using Approved Software Rating Tools ~~that have been certified for accuracy in accordance with Section 6 of this Standard approved~~.

5.1.1.6. All Rating providers shall compare the estimates provided under Section 5.1.1 of this Standard to determine the energy rating of the home and, if applicable, the energy rating of the home with proposed conservation measures and On-site Power Production installed.

1 (Informative Note) For example, assume 1000 kWh (3413 kBtu or 3.413 MBtu) of gross electrical power is produced using 60 therms (6 MBtu) of natural gas to operate a high-efficiency fuel cell system. Using these assumptions, OPP = 3.413 MBtu - (6 MBtu * 0.4) = 1.0 MBtu.

Comment #101

Page Number: 49
Paragraph / Figure / Table / Note: Section 5.1.2.1
Comment Type: Editorial

Comment:

Clarification and use of language appropriate to a standard that fosters adoption and ease of use.

Proposed Change:

5.1.2.1. Energy Cost Savings. ~~If energy cost savings for the Rated Home are calculated, they shall be calculated using the following procedures.~~ When determined, the energy cost savings for the Rated Home shall be calculated in accordance with this section.

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #102

Page Number: 49
Paragraph / Figure / Table / Note: Section 5.1.2
Comment Type: Editorial

Comment:

Clarification and ease of use as well as increase the adoptability and desire to use the standard.

Proposed Change:

Rewrite the entire section and subsections to more appropriately convey the requirements. It is currently written in informative dialogue as opposed to standards language that can be uniformly interpreted and applied. Section 5.1.2.1.1 refers to a required use of something to occur in the future which is inappropriate for this standard. “Calculated as follows:” should be replaced with “Calculated in accordance with Sections x through y.” It is also noted that the subsections go to eight decimals. This suggests serious consideration of how this material is presented. It may be worth considering addressing the intent of this section trough a form that the user would complete and as used would implement the intent as exhibited in the draft standard.

Response:
Accepted. Section 5.1.2 has been revised as follows. These revisions will be included in the final committee draft of BSR/RESNET Standard 301-201x.

5.1.2.      Savings Estimates.

5.1.2.1.       Energy Cost Savings. If Where determined, the energy cost savings for the Rated Home are calculated, they shall be calculated ~~using the following procedures~~ in accordance with Sections 5.1.2.1.1 and 5.1.2.1.2.

5.1.2.1.1.      Energy Prices. Energy costs for all homes shall be calculated using state wide revenue-based energy price rate data published ~~annually~~ by ~~RESNET as derived from~~ the U.S. Department of Energy (DOE) Energy Information Administration (EIA).[1]

5.1.2.1.2.      Energy Cost Savings. Energy cost saving estimates for Rated Homes shall be ~~calculated as follows –~~in accordance with Sections 5.1.2.1.2.1 through 5.1.2.1.2.3.

5.1.2.1.2.1.     HERS Reference Home energy costs shall be determined by fuel type, by applying the energy prices rates ~~determined in accordance with Section 5.1.2.1.1~~ to the individual fuel types of the HERS Reference Home.

5.1.2.1.2.2.     Rated Home energy costs shall be determined by fuel type, by applying the same energy prices rates ~~data~~ used for the HERS Reference Home ~~in Section 5.1.2.1.2.1 above~~.

5.1.2.1.2.3.     For Confirmed, Sampled and Projected Ratings, estimated energy cost savings shall be calculated ~~as follows~~ in accordance with Sections 5.1.2.1.2.3.1 and 5.1.2.1.2.3.2.

5.1.2.1.2.3.1.      Estimated energy cost savings with respect to the HERS Reference Home shall be ~~determined as~~ the difference between the estimated energy costs of for the HERS Reference Home and the ~~estimated~~ energy costs of for the Rated Home.

5.1.2.1.2.3.2.      Estimated energy cost savings with respect to the Typical Existing Home shall be determined ~~as follows~~ in accordance with Sections 5.1.2.1.2.3.2.1 and 5.1.2.1.2.3.2.2.

5.1.2.1.2.3.2.1.            For each fuel type, ~~multiply~~ the HERS Reference Home costs shall be multiplied by 1.3 to determine the Typical Existing Home estimated energy costs by fuel type.

5.1.2.1.2.3.2.2.            Estimated energy cost savings with respect to the Typical Existing Home shall be the difference between the estimated energy costs of the Typical Existing Home and the estimated energy costs of the Rated Home.

5.1.2.2.       Pollution Emissions and Savings. If Where determined, the pollution emission savings for the Rated Home are calculated, they shall be calculated ~~using the following Procedures~~ in accordance with Sections 5.1.2.2.1 and 5.1.2.2.2.

5.1.2.2.1.      Pollution Emissions. Pollution emissions for all homes shall be calculated ~~using the following procedures~~ in accordance with Sections 5.1.2.2.1.1 and 5.1.2.2.1.2.

5.1.2.2.1.1.     For electricity use, ~~pollution emission shall be~~ data for ~~calculated using the statewide average emission rates provided by~~ the sub-region annual total output emission rates published by the Environmental Protection Agency’s ~~most recent~~ eGrid database[2] for electricity generation shall be used to calculate emissions. [3]

5.1.2.2.1.2.     For fossil fuel use, pollution emissions shall be calculated using the emission factors given in Table 5.1.2(1) below.

Table 5.1.2(1) National Average Emission Factors for Household Fuels[4]

Fuel Type

Units

MBtu
per Unit

CO2
lb/MBtu

NOx
lb/MBtu

SO2
lb/MBtu

Natural Gas

Therm

0.1000

117.6

93.0

0.0000

Fuel Oil #2

Gallon

0.1385

159.4

127.8

0.5066

LPG*

Gallon

0.0915

136.4

153.4

0.0163

* Liquid petroleum gas

5.1.2.1.1.      Pollution Emission Savings. Estimated pollution emission savings for Rated Homes shall be calculated ~~as follows~~ in accordance with Sections 5.1.2.2.2.1 through 5.1.2.2.2.3.

5.1.2.1.1.1.     HERS Reference Home pollution emissions shall be determined by fuel type by applying the pollution emissions determined in accordance with Section 5.1.2.2.1 to the individual fuel types of the HERS Reference Home.

5.1.2.1.1.2.     Rated Home pollution emissions shall be determined by fuel type by applying the same pollution emission data used for the HERS Reference Home in Section 5.1.2.2.2.1 above.

5.1.2.1.1.3.     For Confirmed, Sampled and Projected Ratings, estimated pollution emission savings shall be calculated ~~as follows~~ in accordance with Sections 5.1.2.2.2.3.1 and 5.1.2.2.2.3.2.

5.1.2.1.1.3.1.      Estimated pollution emission savings with respect to the HERS Reference Home shall be the difference between the pollution emissions of the HERS Reference Home and the pollution emissions of the Rated Home.

5.1.2.1.1.3.2.      Estimated pollution emission savings with respect to the Typical Existing Home shall be determined ~~as follows~~ in accordance with Sections 5.1.2.2.2.3.2.1 and 5.1.2.2.2.3.2.2.

5.1.2.1.1.3.2.1.            For each fuel type, multiply the HERS Reference Home pollution emissions by 1.3 to determine the Typical Existing Home pollution emissions by fuel type.

Estimated pollution emission savings with respect to the Typical Existing Home shall be the difference between the pollution emissions of the Typical Existing Home and the pollution emissions of the Rated Home.

[1] (Informative Note) RESNET will compile and publish state wide revenue based electricity price data that can be used in accordance with this section by Approved Software Rating Tools for the calculation of electricity costs.

[2]  ~~Available online:~~ (Informative Reference) http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html

[3] (Informative Note) RESNET will compile and publish annual total output pollution rate data for NOx, SO2 and CO2 in accordance with the provisions of this Section that can be used by Approved Software Rating Tools for the calculation of emissions.

[4] (Informative Reference) ~~Developed from the~~ U.S. DOE National Impact Analysis AHAM2 report (appendix 15A) http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/aham2_dfr_app-15a_environmentalemissionfactors_2011-04-13.pdf

Comment #103

Page Number: 49
Paragraph / Figure / Table / Note: Section 5.1.2.2
Comment Type: Editorial

Comment:

Clarification and use of language appropriate to a standard that fosters adoption and ease of use.

Proposed Change:

5.1.2.2. Pollution Emission Savings. ~~If pollution emission savings for the Rated Home are calculated, they shall be calculated using the following Procedures.~~ When determined, the pollution emission savings for the Rated Home shall be calculated in accordance with this section.

Response:
Accepted. The proposed revisions will be incorporated in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #104

Page Number: 51
Paragraph / Figure / Table / Note: Section 5.1.2.2.1.1, 5.1.2.2.1.2
Comment Type: Technical

Comment:

Clarification and use of language appropriate to a standard that fosters adoption and ease ofIt is inappropriate in a standard to reference web sites that can change daily and are not subject to any ongoing validation of acceptability, other than the point in time when the decision is made to reference them. For this reason, as an example, in referring to other documents in this standard they should be referenced by name and a specific publication date. If the intent of using this standard is uniformity and comparability of results as well as accuracy a specific standard should be referenced. ASHRAE Standard 105 covering the measurement and expression of building energy use and greenhouse gas emissions provides a standardized, defensible and useable set of criteria that all users could rely on, readily use and be more likely to derive comparable results for the same building than if those same users went to a web site or were faced with trying to figure out what the “most recent” eGrid numbers were.use.

Proposed Change:

5.1.2.2.1.1. For electricity use, pollution emission shall be calculated in accordance with ASHRAE Standard 105. ~~calculated using the statewide average emission rates provided by the Environmental Protection Agency’s most recent eGrid database16 for electricity generation.~~

~~16 Available online: http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html~~

~~17 Developed from the U.S. DOE National Impact Analysis AHAM2 report (appendix 15A)~~ ~~http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/aham2_dfr_app-15a_environmentalemissionfactors_2011-04-13.pdf~~

The same approach should be employed in revising section 5.1.2.2.1.2.

Response:
Accepted in part. ASHRAE Standard 105 does not contain information on appropriate emission factors for electricity production. A better and more specific reference for e-Grid will be incorporated in the final Committee draft, however, it must contain the specific emissions data needed for calculations (see also response to Comment #112 and Comment #102).

Comment #105

Page Number: 53
Paragraph / Figure / Table / Note: Section 5.1.4
Comment Type: Editorial

Comment:

Clarification and increased probability that the standard will be adopted and can be applied and used if adopted

Proposed Change:

The section needs to be rewritten in standards language and re-formatted to improve the potential for uniform application and use.

Response:

Accepted. Section 5.1.4 has been revised as follows. These revisions will be included in the final committee draft of BSR/RESNET Standard 301-201x.

5.1.4.         Rating Types. ~~This Standard addresses three Rating Types as follows~~ There shall be three Rating Types in accordance with Sections 5.1.4.1 through 5.1.4.3.

5.1.4.1.       Confirmed Rating. A Rating Type that encompasses one individual dwelling or dwelling unit and is conducted ~~All confirmed ratings shall be for individual real properties where all Minimum Rated Features of the Rated Home are verified in the field through inspection and testing~~ in accordance with ~~the minimum requirements of Section 4.4 of this Standard~~ Sections 5.1.4.1.1 through 5.1.4.1.3.

5.1.4.1.1.      All Minimum Rated Features of the Rated Home shall be field-verified through inspection and testing in accordance with Section 4.4.

5.1.4.1.2.      All field-verified Minimum Rated Features of the Rated Home shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating. The Home Energy Rating shall report the HERS Index that comports with these inputs.

5.1.4.1.3.      ~~All~~ Confirmed Ratings shall be subjected to the Quality Assurance requirements of Section 900 of the ~~RESNET~~ Mortgage Industry National Home Energy Rating Systems Standard.

~~5.1.4.1.2.~~      ~~All Confirmed Ratings shall use the field-verified Minimum Rated Feature characteristics of the Rated Home as input to the accredited software rating tool that generates the Home Energy Rating.~~

5.1.4.2.       Sampled Rating. A Rating Type that encompasses a set of dwellings or dwelling units and is conducted Sampled Ratings are a sub-type of Confirmed Ratings whereby field verification of the Minimum Rated Features is accomplished through sampling procedures in accordance with Section 600 of the RESNET Mortgage Industry National Home Energy Rating Systems Standard.in accordance with Sections 5.1.4.2.1 through 5.1.4.2.3.

5.1.4.2.1.      For the set of Rated Homes, all Minimum Rated Features shall be field-verified through inspection and testing of a single home in the set, or distributed across multiple homes in the set, in accordance with Section 600 of the Mortgage Industry National Home Energy Rating Systems Standard.

5.1.4.2.2.      The threshold specifications from the Worst-Case Analysis for the Minimum Rated Features of the set of Rated Homes shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating. The Home Energy Rating shall report the HERS Index that comports with these inputs.

5.1.4.2.3.      ~~All~~ Sampled Ratings shall be subjected to the Quality Assurance requirements of Section 900 of the Mortgage Industry National Home Energy Rating Systems Standard.

~~5.1.4.2.2.~~      All Sampled Ratings shall use the projected Minimum Rated Feature characteristics of the Sampled Home Plan as input to the accredited software rating tool that generates a Worst-Case Home Energy Rating for the Sampled Home Plan.

~~5.1.4.2.3.~~      ~~All Sampled Ratings shall report the HERS Index that comports with the Worst-Case Home Energy Rating for the Sampled Home Plan.~~

~~5.1.4.2.4.~~      ~~All Sampled Ratings shall be submitted to the National RESNET Registry (see Section 5.3) for certification.~~

~~5.1.4.2.5.~~      ~~Following registration of Sampled Ratings, the results of the Rating shall be certified in accordance with Section 5.2 of this Standard.~~

5.1.4.3.       Projected Ratings. A Rating Type that encompasses one individual dwelling or dwelling unit and is conducted Projected Ratings are determined based on architectural drawings with material, mechanical and electrical specifications for new home plans, or based on a site audit for existing homes that are to be improved, subject to the following provisions.~~[1]~~in accordance with Sections 5.1.4.3.1 through 5.1.4.3.5

5.1.4.3.1.      All Minimum Rated Features of the Rated Home shall be determined from architectural drawings, threshold specifications, and the planned location and orientation for a new home or from a site audit and threshold specifications for an existing home that is to be improved. For a new home, if the proposed orientation is unknown, the home shall be analyzed facing each of the four cardinal directions (i.e., North, South, East and West) and the orientation resulting in the largest HERS Index shall be used.

5.1.4.3.2.      Projected Ratings shall use either the envelope leakage rate specified as the required performance by the construction documents, the site-measured envelope leakage rate, or a the ~~default value as~~air exchange rate specified for the HERS Reference home in Table 4.2.2(1).

5.1.4.3.3.      Projected Ratings shall use either the distribution system efficiency specified as the required performance by the construction documents, the site-measured distribution system efficiency, or a the ~~default~~ thermal distribution system efficiency value as specified for the HERS Reference home in ~~from~~ Table 4.2.2(1)~~; and~~.

5.1.4.3.4.      The Minimum Rated Features of Rated Homes that were determined in Section 5.1.4.3.1 through 5.1.4.3.3 shall be entered into the Approved Software Rating Tool that generates the Home Energy Rating. The Home Energy Rating shall report the HERS Index that comports with these inputs.

5.1.4.3.5.      Projected Rating Reports shall contain the following text in no less than 14 point font at the top of the first page of the report: “Projected Rating Based on Plans – Field Confirmation Required.”

~~5.1.4.3.3.~~      Projected Ratings shall use the planned location and orientation of the proposed home, or if the proposed orientation is unknown, calculate ratings for the home facing each of the four cardinal directions, north, south, east and west, using the largest HERS Index score for the Rating.

~~5.1.4.3.4.~~      Projected Rating Reports shall contain the following text in no less than 14 point font at the top of the first page of the report: “Projected Rating Based on Plans – Field Confirmation Required.”

~~5.1.4.3.5.~~      ~~Projected Ratings shall not be accepted by the RESNET Registry for Rating Certification.~~

~~5.1.4.3.6.~~      ~~Projected Ratings shall not use the same or similar Rating Report formats provided by Section 5.2 of this Standard for Certified Ratings.~~

~~5.1.4.3.7.~~      Upon completion of construction and field verification of the proposed specifications for all Minimum Rated Features of the Rated Home in accordance with Section 4.3.1 of this Standard (e.g. on-site visual inspections, on-site diagnostic test results or default values for envelope air leakage and distributions system efficiencies), and entry of either the field verified rated features or the threshold specification for a Worst-Case Analysis into an accredited rating tool, a projected Rating for the home shall become a Confirmed Rating for the home.

~~[1]~~ Projected Ratings are intended primarily for use in the home design process, for plan review where building codes use Ratings as a compliance mechanism and in programs requiring threshold design compliance.

Comment #106

Page Number: 53 and 54
Paragraph / Figure / Table / Note: Section 5.1.4.1.3 and 5.1.4.2.4
Comment Type: Technical

Comment:

A requirement that a rating be submitted for certification is outside the scope of this standard as presently formulated. The issue of compliance verification, certification, and other reviews of the results derived when using this standard is something completely different that needs to be addressed in a separate standard, or more appropriately an administrative process. Much of the standard, if the language is improved as suggested in our other comments, will “establish national residential energy rating and labeling Standards that any provider of home energy ratings may follow to produce uniform energy ratings and energy performance labels for residential buildings”. This speaks only to, and the scope of this standard is limited as written to, the methodology by which someone would gather data and using those data develop an energy rating. It does not speak to professional competency, registration, certification or even labeling; all of which are part and parcel to a separate set of provisions that would be established for the administration of this standard. Those are not within the purpose and scope of this standard as presently written and all such provisions in the standard, such as that in this section, should be removed and relocated to a separate RESNET document that provides criteria to address the adoption, administration, and regulation of the use of this standard.

Proposed Change:

Delete the section

Response:
Accepted. The proposed change will be incorporated into BSR/RESNET Standard 301-201x.

Comment #107

Page Number: 55
Paragraph / Figure / Table / Note: Section 5.2
Comment Type: Technical

Comment:

A requirement that a rating be certified through submission to RESNET is outside the scope of this standard as presently formulated. The stated purpose of the standard is to “establish national residential energy rating and labeling Standards that any provider of home energy ratings may follow to produce uniform energy ratings and energy performance labels for residential buildings”. The competency of individuals to use this standard and develop ratings and any program to oversee their work is an administrative function associated with the subject of conformity assessment as covered in other comments. The place to develop standards associated with this issue is in another standard, set of administrative procedures or certification program subject to third party accreditation that RESNET would develop, release, administer and update.

Proposed Change:

Delete this section of the standard.

Response:
Accepted. The proposed change will be incorporated into BSR/RESNET Standard 301-201x.

Comment #108

Page Number: 59
Paragraph / Figure / Table / Note: Section 5.3
Comment Type: Technical

Comment:

A requirement that RESNET maintain a national registry of ratings is outside the scope of this standard as presently formulated. The stated purpose of the standard is to “establish national residential energy rating and labeling Standards that any provider of home energy ratings may follow to produce uniform energy ratings and energy performance labels for residential buildings”. RESNET can certainly choose to do that and does not need this standard to foster development or maintenance of such a registry. Coupled with comments to other portions of Section 5, this is related to administration of the results from the use of this standard as opposed to outlining how the ratings are to be derived. Any activity associated with overseeing the application and use of this standard as to qualifications, reporting of results, etc. is something that should be addressed separately in a set of administrative rules or other criteria developed, updated and administered by RESNET. A focus, for instance, on Section 5.3.2 clearly indicates that these provisions are outside the stated purpose and scope of the standard. How is this to be implemented and enforced? What are the penalties if the rater does not comply? How will RESNET oversee the providership for which the rater works? These are all relevant issues that support the credibility of a rating but are issues that are more appropriately addressed in other RESNET program criteria that can be made available to those that adopt this standard. Section 5.4 also contains similar provisions that again may be relevant to administration and use of the standard but are outside the stated purpose and scope of the standard.

Proposed Change:

Delete Section 5.3.

Response:
Accepted. The proposed change will be incorporated into BSR/RESNET Standard 301-201x.

Comment #109

Page Number: 63
Paragraph / Figure / Table / Note: Section 6.0
Comment Type: Technical

Comment:

The inclusion of criteria by which software tools would be accredited is outside the scope of this standard. The scope of this standard is to “establish national residential energy rating and labeling Standards, consistent with the provisions of the Energy Policy Act of 1992, which any provider of home energy ratings may follow to produce uniform energy ratings and energy performance labels for residential buildings.” Certainly the accuracy of software tools plays an important role in applying the provisions of this standard but the standards and procedures by which software tools are considered acceptable for application and use should be addressed in a separate standard or other vehicle. For instance ASHRAE Standard 90.1, in addressing the issue of energy simulation associated with the performance path to compliance, does not include in that standard another standard to govern how those programs are to be accredited. It does indicate that the adopting authority of standard 90.1 has the authority to approve simulation programs and it does provide a list of things the software must be able to model. Also note if Section 6 is to be retained and this comment not accepted then the provisions in the section need to be considered for revision in a manner appropriate for a standard. For instance Sections 6.3.4 through 6.3.10, which exist solely to summarize test suites (that are detailed in normative annexes) and/or explain how they were developed; and everywhere “such as”, which is open ended and does not provide a specific and uniform basis for a standard, need to be addressed.

Proposed Change:

Delete all of Section 6.

Response:
Accepted. Software verification and testing standards will be removed from BSR/RESNET Standard 301-201x and all text within BSR/RESNET Standard 301-201x stating that software tools shall be “accredited” will be modified to state that software tools shall be “approved.”

Comment #110

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(5)
Comment Type: Editorial

Comment:

Define the term "white" in the definitions section or insert a footnote in the table explaining the term for the purposes of the table.

Proposed Change:

It is suggested "white" be defined within the table

Response:
Rejected. This table provides conservative estimates of absorptance based upon casual observation of roof type and color. It is not intended to support precise definitions of color or substitute for test data.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #111

Page Number: 20
Paragraph / Figure / Table / Note: Table 4.2.2(5)
Comment Type: Editorial

Comment:

Define the term "white" in the definitions section or insert a footnote in the table explaining the term for the purposes of the table.

Proposed Change:

It is suggested "white" be defined within the table

Comment #112

Page Number: 48 - 49
Comment Type: Technical

Comment:

The proposed revision changes the reference dataset in the eGRID database from state averages to national average for the HERS index, and eGRID non-baseload values by eGRID subregion for emission savings attributable to changes in a home such as energy conservation measures.

A key aspect of a home rating and evaluation of savings due to energy conservation and efficiency measures is the home’s impact on the environment and the reduction of its impact due to improved energy efficiency. Providing pollution emissions and savings information to the homeowner and other stakeholders is necessary to achieve this objective. Codes and standards implementing GHG emissions compliance requirements include the EPA Energy Star Buildings program, the International Green Construction Code, and ASHRAE Standard 189.1.

For inventory and rating purposes (the label), national average values provide an indicator of the home’s performance relative to homes that are built the same. National averages avoid rewarding or penalizing a home simply based on its location (similar to the EPA Energy Star Buildings and ASHRAE Standard 189.1 methodology).

Average calculations may be appropriate for inventory and ratings purposes, but they do not provide appropriate information when deciding what energy efficiency or conservation measures to include in new building designs or to implement in retrofit programs or to quantify the impact of energy efficiency measures on emissions. For instance, according to the eGRID 2010 database, the average 2007 generation mix in Pennsylvania was 54% coal and 34% nuclear, with gas and oil contributing 9% combined. Using state averages, the impact of a reduction in electricity consumption would seem to be shared mainly by coal and nuclear. However, economic dispatch of electricity by the ISO typically brings on plants through the PJM interconnect in the following order: Renewable first, then nuclear, followed by coal, and finally gas and oil plants. In this case, the electricity saved would likely be from either a gas or oil plant during peak periods. During base load periods (evenings, weekends), the marginal plant would likely be either gas or coal. It is unlikely that either hydro or nuclear plants would be affected by the power reduction associated with an energy efficiency or conservation measure. Avoided generation represents the next generation plant used, built, or avoided with that particular fuel type and heat rate, and may be location specific. Avoided generation is a more appropriate increment on which energy investment decisions can be made and generation avoided.

A public domain avoided electricity generation emissions analysis methodology is available from EPA to quantify the emission reduction due to energy efficiency measures (i.e., pollution savings). EPA’s interest in this methodology arose from its understanding that clean energy policies and energy efficiency improvements reduce emissions at the marginal or non-baseload electric generating units. Analysts and EPA staff have noted that non-baseload emission factors may be better for estimating emission reductions rather than average emission factors[1][2][3]. Average electricity generation emission factors can be used appropriately to determine carbon footprint or GHG inventory. However, average emission rates typically under-predict the emission reduction when used for energy savings through efficiency improvements because these averages include baseload generation such as nuclear or hydro power, which would not be affected by the efficiency improvement.[4]

EPA recognizes several valid and established approaches to quantify emission reductions using the non-baseload electricity mix.[5] Non-baseload CO₂emission factors are published by the EPA to facilitate the calculation of emissions reduction due to energy efficiency improvements. The use of eGRID sub-region non-baseload emission factors is recommended by the EPA as a simple, low-cost method to estimate emission reduction potential, to explain emission benefits to the general public, or to determine annual emission reductions or regional / national estimates. [6]

eGRID subregion level data provides an appropriate granularity for primary energy and greenhouse gas emissions calculations for electricity. Power is frequently wheeled within these subregions, and much less frequently wheeled across subregions. State level data is misleading because power flows between states, and generators located in one state supply dedicated power to an adjacent state (such as CAMX generation from Nevada supplying the state of California). EPA uses eGRID subregions in its greenhouse gas inventory and tracking emissions calculation methodology. The 2012 International Green Construction Code also uses eGRID subregions for energy and emission conversion factors for electricity.

EPA’s non-baseload emission rates and methodology are currently used in several tools, including EPA’s Greenhouse Gas Equivalencies Calculator (http://epa.gov/cleanenergy/energy-resources/calculator.html) and Green Power Partnership’s Green Power Equivalency Calculator (http://www.epa.gov/greenpower/pubs/calculator.htm).[7]

[1] Jacobson, D. and High, C. , U.S. Policy Action Necessary to Ensure Accurate Assessment of the Air Emission Reduction Benefits of Increased Use of Energy Efficiency and Renewable Energy Technology, Journal of Energy and Environmental Law, Vol. 1:1, 2010. (http://www.rsginc.com/assets/Reports--Publications/RSG-Modeling-of-Air-Emission-Reduction-in-the-Electricity-Sector.pdf)

[2] DeYoung, R., Deciding an Approach for Quantifying Emission Impacts of Clean Energy Policies and Programs, U.S. Environmental Protection Agency, State Climate and Energy Program, January 30, 2012. (http://www.epa.gov/statelocalclimate/documents/pdf/DeYoung_presentation_1-30-2012.pdf)

[3] Rothschild, S. and Diam, A., Total, Non-baseload, eGRID Sub-region, State? Guidance on the Use of eGRID Output Emission Rates, Prepared for the U.S. Environmental Protection Agency, Climate Protection Partnership Division, Washington, DC, 2008. (http://www.epa.gov/ttn/chief/conference/ei18/session5/rothschild.pdf)

[4] Jacobson, D., Flawed Methodologies in Calculating Avoided Emissions from Renewable Energy , The GW Solar Institute, October 24, 2009. (http://solar.gwu.edu/index_files/Resources_files/DJ_REILPresentation.pdf)

[4] DeYoung, R., Deciding an Approach for Quantifying Emission Impacts of Clean Energy Policies and Programs, U.S. Environmental Protection Agency, State Climate and Energy Program, January 30, 2012. (http://www.epa.gov/statelocalclimate/documents/pdf/DeYoung_presentation_1-30-2012.pdf)

[5] DeYoung, R., Deciding an Approach for Quantifying Emission Impacts of Clean Energy Policies and Programs, U.S. Environmental Protection Agency, State Climate and Energy Program, January 30, 2012. (http://www.epa.gov/statelocalclimate/documents/pdf/DeYoung_presentation_1-30-2012.pdf)

[6] DeYoung, R., Quantification Methods using eGRID State and Local Examples, U.S. Environmental Protection Agency, State Climate and Energy Program, March 31, 2011. (http://www.epa.gov/statelocalclimate/documents/pdf/DeYoung_presentation_3-31-11.pdf)

[7] Collison, B., Green Power 101, US EPA Green Power Partnership, Renewable Energy Markets Conference, Atlanta, GA, September 13, 2009 (http://www.renewableenergymarkets.com/docs/presentations/2010/Wed_RE%20101_Blaine%20Collison.pdf)

Proposed Change:

5.1.2.2. Pollution Emissions and Savings. If pPollution emissions and savings for the Rated Home ~~are calculated, they~~ shall be calculated using the following Procedures.

5.1.2.2.1. Pollution Emissions. Pollution emissions for all homes shall be calculated using the following procedures.

5.1.2.2.1.1. For electricity use, pollution emission for the HERS index shall be calculated using the national ~~statewide~~ average emission rates provided by the Environmental Protection Agency’s ~~most recent~~ eGrid 2012 database¹⁶ for electricity generation. Pollution emission for emission savings shall be calculated using the eGRID subregion non-baseload emission rates provided by the Environmental Protection Agency’s eGrid 2012 database¹⁶ for electricity generation.

Response:
Accepted as modified. The proposed change is modified as follows:

5.1.2.2. Pollution Emissions and Savings. Where determined, the pollution emission savings for the Rated Home are calculated, they shall be calculated in accordance with Sections 5.1.2.2.1 and 5.1.2.2.2.

5.1.2.2.1. Pollution Emissions. Pollution emissions for all homes shall be calculated in accordance with Sections 5.1.2.2.1.1 and 5.1.2.2.1.2.

5.1.2.2.1.1. For electricity use, data for the sub region annual total output emission rates published by the Environmental Protection Agency’s eGrid database1 for electricity generation shall be used to calculate emissions.2

1 (Informative Reference) http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html

2 (Informative Note) RESNET will compile and publish annual total output pollution rate data for NOx, SO2 and CO2 in accordance with the provisions of this Section that can be used by Approved Software Rating Tools for the calculation of emissions.

5.1.2.2. Pollution Emissions and Savings. If pPollution emissions and savings for the Rated Home are calculated, they shall be calculated using the following Procedures.
5.1.2.2.1. Pollution Emissions. Pollution emissions for all homes shall be calculated using the following procedures.
5.1.2.2.1.1. For electricity use, pollution emission for the HERS index shall be calculated using the national statewide average emission rates provided by the Environmental Protection Agency’s most recent eGrid 2012 database16 for electricity generation. Pollution emission for emission savings shall be calculated using the eGRID subregion non-baseload emission rates provided by the Environmental Protection Agency’s eGrid 2012 database16 for electricity generation.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #113

Page Number: various
Comment Type: Technical

Comment:

This revision shifts from a technically flawed normalized modified loads method (NMLM) to a technically robust primary energy consumption methodology for rating homes and evaluating the impact of energy savings initiatives in a home. Shifting to the primary energy consumption methodology provides equitable treatment of all technologies based on their impact on primary energy resources rather than on site energy consumption.

NMLM was a valiant and somewhat successful attempt to address known serious flaws in the original site energy-based HERS index in the 1990’s. The initial modification to the original site energy methodology (the modified loads method) addressed some of the flaws but unfortunately, it added new ones. NMLM recognized the state of the art and limitations on efficiency improvement for advanced natural gas and propane heating and water heating technologies that were, and remain, cost-effective and very efficient based on consumption of primary energy resources. As implemented in HERS, NMLM meaningfully adjusts only gas technologies, not electric technologies, and as such the method retains the inherent flaws in site energy methodologies for electric technologies while adding new flaws for gas technologies. NMLM facilitated recognition of condensing gas furnaces in Energy Star Homes, even though the improvement in energy performance was not enough to qualify compared to the already primary energy efficient and cost-effective non-condensing furnaces in the HERS reference home. The original HERS Council committee had also chosen to require a single heat pump baseline for electric heating systems (rather than allowing electric resistance heating systems to be the reference if installed in the rated home), considering heat pumps and furnaces to always be about equivalent for consumer energy benefits (even though this is a case by case determination). However, it did not address the service water heater inequities at all. The overall impact of NMLM was to reward “best efforts” and technology limitations, while at the same time acknowledging, at least for heating, the poor energy efficiency and high energy cost of resistance heating.

Unfortunately, the NMLM methodology is also inherently flawed and creates its own set of biases that cannot be justified if the HERS goal is to equitably rate the impact of home energy use on primary energy resource consumption, both as designed and in operation. For example, homes using NAECA minimum efficiency electric resistance storage water heating receive an identical HERS score as a NAECA minimum gas storage water heater, even though both the annual energy costs and primary energy consumption are much higher for the resistance water heater than for the gas water heater (typically twice as high). It is this “best efforts” bias, along with normalizing biases favoring ultra-high efficiency gas technologies (such as gas heat pumps) that the proposed shift to primary energy performance methodology fully corrects.

Site measurement methods—a calculation of the energy consumed by an appliance at the end-use point (in the home)—do not properly or equitably account for the total energy consumed when more than one energy source is used in an appliance (such as a gas furnace) or when comparing the consumption of different fuels that can be used for the same application (such as water heating or combined heat and power). In addition, site measurement does not account for the energy lost and emissions created throughout the extraction, processing, transportation, conversion, and distribution of energy to the home. On the other hand, primary(full-fuel-cycle) measurement of the energy consumption of appliances and the overall building from the point of extraction to the point of use does account for energy losses that occur (e.g., in the production of natural gas or in the generation of electricity).

Site energy would be a sufficient metric only if the energy at the meter were the only parameter of concern. However, energy required for generating and delivering electricity does not originate at the meter, but at one of the primary energy sources (natural gas, oil, propane, nuclear energy, hydro energy, and solar energy). To ignore the original source of the energy leads to the unsupportable argument that energy is created at the meter, and upstream energy losses are not relevant to the building. Using that argument, 1 Btu of electricity would be considered the same as 1 Btu of natural gas, propane, or fuel oil. This would be fine if each form of energy were equivalent. But they are not equivalent. Electricity is considered a high value energy form because of its versatility and ability to convert directly to mechanical energy, light, and heat through devices such as motors, semiconductors, lamps, and resistance heating elements. Primary energy sources, including natural gas, propane, nuclear, and coal, are much more limited in their direct conversion capability, typically burned or split to convert chemical or nuclear energy to heat. It is this difference that is valued by consumers, who are willing to pay a much higher price per Btu delivered at the meter for electricity than for other forms of energy such as natural gas.

Focusing on site energy efficiency alone without consideration of upstream energy consumption and emissions perversely incentivizes the decision maker to choose the less expensive “efficient” technology. The unintended consequence is to promote irrational fuel switching in the design decision away from more full-fuel-cycle energy efficient and lower GHG emitting technologies toward more site energy efficient technologies. Codes, standards, regulations, voluntary initiatives, and incentive programs that focus on site energy create and maintain an unfair and unearned market advantage to qualifying technologies such as electric resistance heating (used to supplement a heat pump in winter) and water heating that are lower initial cost, but that have higher operating cost, lower full-fuel-cycle efficiency and higher GHG emissions. This is a key reason source energy-based criteria are used by several private and public sector stakeholders, including RESNET in its pollutant emissions calculation.

The primary energy performance methodology addresses the inherent flaws in the current NMLM without substituting new ones. It provides equitable treatment of ALL energy consuming technologies based on their primary energy impact, not their site energy impact (or normalized modified site energy load impact). It does not prohibit any technology, but equitably rewards and penalizes technologies in the home rating based on their primary energy performance. It uses single national primary energy factors to avoid rewarding or penalizing a home simply based on its location (similar to the EPA Energy Star Buildings methodology as well as other programs noted below).

The primary energy factors in proposed Table 4.2.1 are from Table J.1 of ANSI/ASHRAE Standard 105-2007R Public Review Draft. That document also contains a full discussion of the rationale and application of primary energy performance methodologies and factors that can be used in standards such as RESNET PDS 301-01.

Shifting to the primary energy performance methodology also makes the calculation of on-site power production moot as this power production (whether renewable or depletable) is within the site boundary and its effects are fully and equitably captured in the summation by energy form of net imported and exported energy at the site boundary, including associated primary energy factors.

Primary energy methodologies are easily implemented and are now widely recognized and used both in the United States and internationally. The following list illustrates the numerous US and international codes, standards, and initiatives that are successfully incorporating primary energy methodologies:

International Green Construction Code. 2012. International Code Council. http://www.iccsafe.org/cs/igcc/pages/default.aspx.

EPA Energy Star Buildings and Plants rating and labeling program (including Portfolio Manager and Target Finder). 2012. US Environmental Protection Agency. http://www.energystar.gov/index.cfm?c=business.bus_index

ASHRAE Building Energy Quotient Labeling Program (As Designed, and In Operation). 2012. ASHRAE. http://buildingenergyquotient.org/index.html

DOE Home Energy Score Tool. 2010. US Department of Energy.
https://sites.google.com/a/lbl.gov/hes-public/home-energy-scoring-tool

DOE Commercial Building Asset Rating Program. 2012. US Department of Energy. http://apps1.eere.energy.gov/buildings/publications/pdfs/commercial_initiative/asset_rating_pilot.pdf

LEED Programs. 2012. US Green Building Council https://new.usgbc.org/leed

Green Globes for Commercial Buildings. 2012. Green Building Initiative.
http://www.thegbi.org/green-globes/

2012 California Green Building Standards Code (CALGreen), 2012. California Department of Housing and Community Development. http://www.hcd.ca.gov/CALGreen.html

PlaNYC’s Greener, Greater Buildings Plan (annual benchmarking and disclosure of energy usage). 2012. http://www.nyc.gov/html/gbee/html/home/home.shtml

Standard Methods of Determining, Expressing and Comparing Building Energy Performance and Greenhouse Gas Emissions. ANSI/ASHRAE Standard 105-2007R Public Review Draft

Benchmarking of Federal Facilities Building Energy Use Benchmarking Guidance. 2010. EISA Section 432. US Dept of Energy/Energy Efficiency & Renewable Energy (EERE). http://www1.eere.energy.gov/femp/pdfs/eisa432_guidance.pdf.

National Academy of Sciences Review of Site (Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building Appliance Energy-Efficiency Standards. 2009. The National Academies Press. http://www.nap.edu/catalog.php?record_id=12670#toc

DOE Policy to use full-fuel-cycle measures of energy use and greenhouse gas and other emissions in the national impact analyses and environmental assessments included in rulemakings for future energy conservation standards http://www.gpo.gov/fdsys/pkg/FR-2011-08-18/html/2011-21078.htm

The Greenhouse Gases, Regulated Emissions and Energy Use in Transportation Model. 2011. Argonne National Laboratory – Transportation R & D center. http://greet.es.anl.gov/

Source Energy and Emission Factors for Energy Use in Buildings. 2007. National Renewable Energy Laboratory, Authors M. Deru and P. Torcellini. http://www.nrel.gov/docs/fy07osti/38617.pdf

Providing Credit Toward Energy Efficiency Goals for Cost-Effective Projects Where Source Energy Use Declines But Site Energy Use Increases. Section 502(e) Guidance. 2004. US Department of Energy/Energy Efficiency & Renewable Energy (EERE). http://www1.eere.energy.gov/femp/pdfs/sec502e_%20guidance.pdf

European Standard EN 15603 Energy performance of buildings. Overall energy use and definition of energy ratings. 2008. European Committee for Standardization. Brussels, Belgium:

European Standard EN 15217 Energy Performance of Buildings – Methods for Expressing Energy Performance and for Energy Certification of Buildings. 2007. European Committee for Standardization. Brussels, Belgium:

All of these codes, standards, rating programs, and policies acknowledge the limitations and deficiencies of site energy-based metrics in achieving their energy efficiency and GHG emission reduction objectives, and have selected primary energy efficiency metrics and related GHG emission calculations as the technical basis of compliance requirements or analysis methodology. These voluntary and regulatory initiatives illustrate the strong technical justification and support for the use of primary energy as the basis of the RESNET PDS 301-01 HERS Index in place of the technically flawed and inequitable NMLM.

Proposed Change:

Page 4:

HERS Index – A numerical integer value that represents the relative energy use of a Rated Home as compared with the energy use of the HERS Reference Home and where an Index value of 100 represents the primary energy use of the HERS Reference Home and an Index value of 0 (zero) represents a home that uses zero net ~~purchased~~ primary energy.

Page 6:

~~On-Site Power Production (OPP)~~ – Electric power produced at the site of a Rated Home. OPP shall be the net electrical power production, such that it equals the gross electrical power production minus any purchased fossil fuel energy, converted to its Equivalent Electric Power, used to produce the on-site power.

Primary Energy – energy consumed by a home as measured at the meter plus the energy consumed in the extraction, processing, and transport of primary fuels such as coal, oil, and natural gas; energy losses in thermal combustion in power-generation plants; and energy losses in transmission and distribution to the building site.

Page 7:

~~Reference Electricity Production Efficiency –~~ Electric power production efficiency, including all production and distribution losses, of 40%, approximating the efficiency of a modern, high-efficiency, central power plant. The Reference Electricity Production Efficiency is to be used only to convert site fossil fuel energy uses to an Equivalent Electric Power for the sole purposes of providing home energy rating system credit for On-site Power Production.

Page 8:

Site Energy – energy consumed by a home as measured at the home’s utility meter or bulk delivery point plus or minus the net change in stored energy inventory.

Pages 9-11:

4. Home Energy Rating Calculation Procedures.

4.1. Determining the HERS Index. The HERS Index shall be a numerical integer value that is based on a linear scale constructed such that the HERS Reference Home has an Index value of 100 and a home that uses no net ~~purchased~~ primary energy has an Index value of 0 (zero). Each integer value on the scale shall represent a 1% change in the total primary energy use of the Rated Home relative to the total primary energy use of the Reference home. ~~Except in states or territories whose laws or regulations require a specific alternative method, which shall control,~~ equations 4.1-1 through 4.1-3 ~~and 4.1-2~~ shall be used ~~in a 2 step process~~ to calculate the HERS Index for the Rated Home, as follows:

HERS Index = PEC / RPEC * 100 (Eq 4.1-1)

where:

PEC = Total primary energy consumption of the Rated Home = Σ(TEUef * PEFef) (Eq 4.1-2)

RPEC = Total primary energy consumption of the Reference Home = Σ(RTEUef * PEFef) (Eq 4.1-3)

TEU_ef = Total site energy use for each energy form of the Rated Home including all rated and non-rated energy features

RTEU_ef = Total site energy use for each energy form of the Reference Home including all rated and non-rated energy features

PEF_ef = Primary energy conversion factor for each energy form as defined by Table 4.2.1 below.

TABLE 4.2.1 Primary Energy Factors by Energy Form

Energy Form	Primary Energy Factor (PEF_ef)
Imported Electricity	3.15
Imported Natural gas	1.09
Imported Steam	1.45
Imported Hot Water	1.35
Imported Chilled Water	1.04
Imported Fuel Oil	1.19
Imported Propane	1.15
Imported Coal and Other	1.05
Exported Electricity	3.15
Exported Steam	1.45
Exported Hot Water	1.35
Exported Chilled Water	1.04

~~4.1.1. Calculating End Use Loads.~~ ~~Calculate the individual normalized Modified End Use Loads (nMEUL) for heating, cooling, and hot water using equation 4.1-1:~~

~~nMEUL = REUL * (nEC_x / EC_r) (Eq 4.1-1)~~

~~where:~~

~~nMEUL = normalized Modified End Use Loads (for heating, cooling, or hot water) as computed using accredited simulation tools.~~

~~REUL = Reference Home End Use Loads (for heating, cooling or hot water) as computed using accredited simulation tools.~~

~~nEC_x = normalized Energy Consumption for Rated Home’s end uses (for heating, including auxiliary electric consumption, cooling or hot water) as computed using accredited simulation tools.~~

~~EC_r = estimated Energy Consumption for Reference Home’s end uses (for heating, including auxiliary electric consumption, cooling or hot water) as computed using accredited simulation tools.~~

~~and where:~~

~~nEC_x = (a* EEC_x – b)*(EC_x * EC_r * DSE_r) / (EEC_x * REUL) (Eq 4.1-1a)~~

~~where:~~

~~EC_x = estimated Energy Consumption for the Rated Home’s end uses (for heating, including auxiliary electric consumption, cooling or hot water) as computed using accredited simulation tools.~~

EEC_x = Equipment Efficiency Coefficient for the Rated Home’s equipment, such that EEC_x equals the energy consumption per unit load in like units as the load, and as derived from the Manufacturer’s Equipment Performance Rating (MEPR) such that EEC_x equals 1.0 / MEPR for AFUE, COP or EF ratings, or such that EEC_x equals 3.413 / MEPR for HSPF, EER or SEER ratings.

~~DSE_r = REUL/EC_r * EEC_r~~

For simplified system performance methods, DSE_r equals 0.80 for heating and cooling systems and 1.00 for hot water systems [see Table 4.2.2(1)]. However, for detailed modeling of heating and cooling systems, DSE_r may be less than 0.80 as a result of part load performance degradation, coil air flow degradation, improper system charge and auxiliary resistance heating for heat pumps. Except as otherwise provided by these Standards, where detailed systems modeling is employed, it must be applied equally to both the Reference and the Rated Homes.

EEC_r = Equipment Efficiency Coefficient for the Reference Home’s equipment, such that EEC_r equals the energy consumption per unit load in like units as the load, and as derived from the Manufacturer’s Equipment Performance Rating (MEPR) such that EEC_r equals 1.0 / MEPR for AFUE, COP or EF ratings, or such that EEC_r equals 3.413 / MEPR for HSPF, EER or SEER ratings and where the coefficients ‘a’ and ‘b’ are as defined by Table 4.2.1(1) below:

~~Table 4.2.1(1) Coefficients ‘a’ and ‘b’~~

~~Fuel type and End Use~~	a	b
~~Electric space heating~~	~~2.2561~~	0
~~Fossil fuel* space heating~~	~~1.0943~~	~~0.4030~~
~~Biomass space heating~~	~~0.8850~~	~~0.4047~~
~~Electric air conditioning~~	~~3.8090~~	0
~~Electric water heating~~	~~0.9200~~	0
~~Fossil fuel* water heating~~	~~1.1877~~	~~1.0130~~

*Such as natural gas, liquid propane gas, fuel oil

~~4.1.2. Calculating the HERS Index.~~ ~~Determine the HERS Index using equation 4.1-2:~~

~~HERS Index = PEfrac * (TnML / TRL) * 100 (Eq 4.1-2)~~

~~where:~~

~~TnML = nMEULHEAT + nMEULCOOL + nMEULHW + EULLA (MBtu/yr).~~

~~TRL = REULHEAT + REULCOOL + REULHW + REULLA (MBtu/yr).~~

~~and where:~~

~~EULLA = Rated Home end use loads for lighting, appliances and MELs as defined by Section 4.2.2.5.2, converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293 or (therms/yr)/10, as appropriate.~~

~~REULLA = Reference Home end use loads for lighting, appliances and MELs as defined by Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293 or (therms/yr)/10, as appropriate.~~

~~and where:~~

~~PEfrac = (TEU - OPP) / TEU~~

TEU = Total energy use of the Rated Home including all rated and non-rated energy features where all fossil fuel site energy uses are converted to Equivalent Electric Energy by multiplying them by the Reference Electricity Production Efficiency of 40%

~~OPP = On-Site Power Production as defined by Section 5.1.1.5 of this Standard.~~

Pg. 17 – 18

(m) For a Rated Home with a non-storage type water heater, a 40-gallon storage-type water heater with the prevailing federal minimum efficiency ~~and with the same fuel as the proposed water heater~~ shall be assumed for the HERS Reference Home. For a Rated Home without a proposed water heater, a 40-gallon storage-type water heater with the prevailing federal minimum efficiency with the same fuel as the ~~predominant~~ heating ~~fuel type~~ system shall be assumed for both the Rated and HERS Reference Homes.

Pg. 23 – 24

Table 4.2.2.5(1) Lighting, Appliance and Miscellaneous Electric Loads (kWh/yr) in ~~electric~~ HERS Reference Homes

End Use Component(a)	Equation Coefficients
End Use Component(a)	a	b	c
Residual MELs		0.91
Interior lighting	455		0.80
Exterior lighting	100		0.05
Refrigerator	637		18
Televisions	413		69
~~Range/Oven~~	~~331~~		39
~~Clothes Dryer~~	~~524~~		~~149~~
Dish Washer	78		31
Clothes Washer	38		10

4.2.2.5.1.2. Reference Homes with Electric or Natural Gas Appliances. ~~Where the Rated Home is equipped with natural gas cooking or clothes drying appliances, the~~ Reference Home cooking and clothes drying loads ~~defined above in Table 4.2.2.5(1)~~ shall ~~be replaced by~~ include the natural gas and electric appliance loads provided below in Table 4.2.2.5(2), as applicable.

Table 4.2.2.5(2) ~~Natural Gas~~ Appliance Loads ~~(therms/yr)~~ for HERS Reference Homes with electric or gas appliances

End Use Component(a)	Equation Coefficients
End Use Component(a)	a	b	c
Gas Range/Oven (therms)	22.6		2.7
Gas Range/Oven (kWh)	~~22.6~~ 1.0		~~2.7~~ 0.1
Gas Clothes Dryer (therms)	18.8		5.3
Gas Clothes Dryer (kWh)	41		11.7
Electric Range/Oven (kWh)	331		39
Electric Clothes Dryer (kWh)	524		149

4.2.2.5.1.4. Mechanical Ventilation. Where mechanical ventilation is provided in the Rated home, ~~REULLA shall be modified~~ ~~for~~ the Reference Home ~~by adding~~ shall include [0.03942*CFA + 29.565*(Nbr+1)] kWh/yr for ventilation fan operation~~, converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293~~.

Pg. 25

~~For the purpose of adjusting the annual interior lighting energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~IL, which shall be calculated as the annual interior lighting energy use derived by the procedures in this section minus the annual interior lighting energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293.

For Interior lighting, internal gains in the Rated home shall be modified by 100% of the interior lighting energy use.~~ΔEULIL converted to Btu/day as follows:~~ ~~ΔEULIL * 106 / 365.~~

Pg. 25

~~For the purpose of adjusting the annual exterior lighting energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~EL, which shall be calculated as the annual exterior lighting energy use derived by the procedures in this section minus the annual exterior lighting energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293.

Pg. 26

~~For the purpose of adjusting the annual garage lighting energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~GL, which shall be calculated as the annual garage lighting energy use derived by the procedures in this section minus the annual garage lighting energy use derived for the HERS Reference Home in Section 4.2.2.5.1 (i.e. 100 kWh/yr), converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293.

Pg. 27

~~For the purpose of adjusting the annual refrigerator energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~FRIG, which shall be calculated as the annual refrigerator energy use derived by the procedures in this section minus the annual refrigerator energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr)/293.

For refrigerator energy use, internal gains ~~in the Rated home~~ shall be modified by 100% of the refrigerator energy use. ~~ΔEULFRIG converted to Btu/day as follows:~~ ~~ΔEULFRIG * 106 / 365.~~ Internal gains shall not be modified for refrigerators located in unconditioned spaces (e.g. unconditioned garages, etc.)

Pg. 27

~~For the purpose of adjusting the annual Range/Oven energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~RO, which shall be calculated as the annual Range/Oven energy use derived by the procedures in this section minus the annual Range/Oven energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr) / 293 or (therms/yr) / 10, whichever is applicable.

For Range/Oven energy use, internal gains ~~in the Rated Home~~ shall be modified by 80% of the Range/Oven energy use. ~~ΔEULRO converted to Btu/day as follows:~~ ~~ΔEULRO * 106 / 365.~~ Of this total amount, internal gains shall be apportioned as follows, depending on fuel type:

a) For electric Range/Ovens, 90% sensible internal gains and 10% latent internal gains

b) For gas Range/Ovens, 80% sensible internal gains and 20% latent internal gains.

Pg. 28 – 29

~~For the purpose of adjusting the annual Clothes Dryer energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~CD, which shall be calculated as the annual Clothes Dryer energy use derived by the procedures in this section minus the annual Clothes Dryer energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr) / 293 or (therms/yr) / 10, whichever is applicable.

For Clothes Dryer energy use, total internal gains ~~in the Rated Home~~ shall be modified by 15% of the Clothes Dryer energy use. ~~ΔEULCD converted to Btu/day as follows:~~ ~~ΔEULCD * 106 / 365.~~ Of this total amount, 90% shall be apportioned to sensible internal gains and 10% to latent internal gains. Internal gains shall not be modified for Clothes Dryers located in unconditioned spaces (e.g. unconditioned garages, etc.)

Pg. 29

~~For the purpose of adjusting the annual Dishwasher energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~DW, which shall be calculated as the annual Dishwasher energy use derived by the procedures in this section minus the annual Clothes Dishwasher energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr) / 293 or (therms/yr) / 10, whichever is applicable.

For the purpose of adjusting the daily hot water use for calculating the rating, the daily hot water use change shall be ‘ΔGPD_DW’ as calculated above.

For Dishwasher energy use, total internal gains ~~in the Rated Home~~ shall be modified by 60% of the Dishwasher energy use. ~~ΔEULDW converted to Btu/day as follows: ΔEULDW * 106 / 365.~~ Of this total amount, 50% shall be apportioned to sensible internal gains and 50% to latent internal gains.

Pg. 30

~~For the purpose of adjusting the annual Clothes Washer energy consumption for calculating the rating, EULLA shall be adjusted by~~ ~~ΔEUL~~CW, which shall be calculated as the annual Clothes Washer energy use derived by the procedures in this section minus the annual Clothes Washer energy use derived for the HERS Reference Home in Section 4.2.2.5.1, converted to MBtu/yr, where MBtu/yr = (kWh/yr) / 293 or (therms/yr) / 10, whichever is applicable.

For the purpose of adjusting the daily hot water use for calculating the rating, the daily hot water use change shall be calculated as the daily hot water use derived by the procedures in this section minus 3.97 gallons per day for the reference standard clothes washer.

For Clothes Washer energy use, total internal gains ~~in the Rated Home~~ shall be modified by 30% of the Clothes Washer energy use. ~~ΔEULCW converted to Btu/day as follows:~~ ~~ΔEULCW * 106 / 365.~~ Of this total amount, 90% shall be apportioned to sensible internal gains and 10% to latent internal gains. Internal gains shall not be modified for Clothes Washers located in unconditioned spaces (e.g. unconditioned garages, etc.)

Pg. 31

During periods of fan operation, the fan wattage, at 100% internal gain fraction, shall be added to internal gains ~~for both the Reference and Rated Homes~~. In addition, annual ceiling fan energy use~~, in MBtu/yr [(kWh/yr)/293], for both the Rated and Reference homes~~ shall be added to the lighting and appliance ~~end~~ energy use ~~loads (EULLA and REULLA, as appropriate) as specified by Equation 5.2-2, Section 5.2 of this Standard~~.

4.2.2.5.2.12. Mechanical Ventilation System Fans. If ventilation fans are present in the Rated Home, lighting and appliance energy use ~~EUL~~LA shall be adjusted by adding total annual kWh energy consumption of the ventilation system in the Rated Home~~, converted to MBtu/yr, where MBtu/yr = (kWh/yr) / 293~~.

~~4.2.2.6.~~ If the Rated Home includes On-site Power Production, the Purchased Energy Fraction for the Rated Home (see Section 5.2) shall be used to determine the impact of the On-site Power Production on the HERS Index.

Pg. 43

4.5.4. Energy Savings Calculation

~~4.5.4.1.~~ Energy units used in the calculation of energy savings shall be units of Equivalent Electric Energy using the Reference Electricity Production Efficiency for fossil fuels. Equivalent electric energy use shall be calculated using Equation 4.5-1.

~~kWh_eq = kWh_elec + Btu_fossil*0.40/3412 (Eq 4.5-1)~~

~~4.5.4.2.~~ Energy savings shall be calculated as the difference between the whole-house projected equivalent electric energy use of the Baseline Existing Home and the whole-house projected equivalent electric energy use of the Improved Home.

~~4.5.4.3.~~ The energy savings percentage of the retrofit shall be calculated as the whole-house equivalent electric energy savings as determined by Section 4.5.4.2 above divided by the whole-house equivalent electric energy use of the Baseline Existing Home.

4.5.4.1. The Baseline Home’s total primary energy consumption (BPEC) shall be compared with the Improved Home’s primary energy consumption (PEC) using equations 4.5-1 and 4.5-2 to determine the energy savings and % energy savings:

Energy Saving = BPEC – PEC (Eq 4.5-1)

% Energy Saving = [(BPEC – PEC) / (BPEC)] * 100 (Eq 4.5-2)

where:

BPEC = Σ(BTEU_ef * PEF_ef)

PEC= Σ(TEU_ef * PEF_ef)

TEU_ef = Total site energy use for each energy form of the Improved Home including all rated and non-rated energy features

BTEU_ef = Total site energy use for each energy form of the Baseline Home including all rated and non-rated energy features

PEF_ef = Primary energy conversion factor for each energy form as defined by Table 4.5.4(1) below.

TABLE 4.5.4(1) Primary Energy Factors by Energy Form

Energy Form	Primary Energy Factor (PEF_ef)
Imported Electricity	3.15
Imported Natural gas	1.09
Imported Steam	1.45
Imported Hot Water	1.35
Imported Chilled Water	1.04
Imported Fuel Oil	1.19
Imported Propane	1.15
Imported Coal and Other	1.05
Exported Electricity	3.15
Exported Steam	1.45
Exported Hot Water	1.35
Exported Chilled Water	1.04

Page 47:

5.1.1.4. If the Rated Home includes On-site Power Production (OPP), then OPP shall be calculated as the gross electric power produced minus the Equivalent Electric Power of any purchased fuels used to produce the electric power. The HERS Reference Home shall not include On-site Power Production.

For example, assume 1000 kWh (3413 kBtu or 3.413 MBtu) of gross electrical power is produced using 60 therms (6 MBtu) of natural gas to operate a high-efficiency fuel cell system. Using these assumptions, OPP = 3.413 MBtu - (6 MBtu * 0.4) = 1.0 MBtu.

Pg. 53

5.2.1.3.5. The estimated annual primary energy savings as compared to the home with a HERS Index of 100 (reference home).

5.2.1.3.6. The estimated annual primary energy savings as compared to the home with a HERS Index of 130 (typical existing home).

Pg 54 – 55

5.3.1.2. The Rating results, including but not limited to the following:

a) Registration ID (provided by the Registry)

b) HERS Index

c) Annual Rated Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type

d) Annual Rated Home energy costs for heating, cooling, hot water and lighting and appliance energy end uses by fuel type

e) Annual Rated Home ~~on-site power production~~ primary energy use

f) Energy prices used to calculate costs by fuel type

g) Annual total cost to operate the Rated home

~~h) Annual Rated Home normalized Modified End Use Loads~~

~~i) Annual HERS Reference Home End Use Loads~~

jh) Annual HERS Reference Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type

ki) Annual HERS Reference Home energy costs for heating, cooling, hot water and lighting and appliance energy end uses by fuel type

j) Annual total cost to operate the HERS Reference home

k) Annual HERS Reference Home primary energy use

Pg. 63 (Normative Annex A)

4.2.4 Test Case 5

Test case 5 requires that each of the Reference Homes for test cases 1-4 be stored or recreated in the software tool as a Rated Home and simulated as any other rated home would be simulated. If the resulting Rated Home is correctly configured to be identical to its appropriate Reference Home, rating calculations arising from normal operation of the software tool should produce virtually identical scoring criteria for both the Reference Home and the Rated Home for this round of tests. For test case 5, the ~~modified loads~~ primary energy e-Ratio shall be calculated separately from the simulation results, as follows:

e-Ratio = ~~(Total normalized Modified Loads) / (Total Reference Loads)~~ PEU / RPEU

Pg. 66 – 68 (Normative Annex B)

2. Computation of Energy Savings

2.1. The Reference Home’s total primary energy consumption for heating and cooling (RPEC_hc) shall be compared with the Qualifying Home’s primary energy consumption for heating and cooling (PEC_hc) using the following formula to determine the % Energy Reduction:

% Energy Reduction = [(RPEC_hc – PEC_hc) / (RPEC_hc)] * 100

where:

RPEC_hc = Σ(RTEU_ef * PEF_ef)

PEC_hc= Σ(TEU_ef * PEF_ef)

TEU_ef = Total site energy use for each energy form of the Rated Home for heating or cooling

RTEU_ef = Total site energy use for each energy form of the Reference Home for heating or cooling

PEF_ef = Primary energy conversion factor for each energy form as defined by Table 2.1 below.

TABLE 2.1 Primary Energy Factors by Energy Form

Energy Form	Primary Energy Factor (PEF_ef)
Imported Electricity	3.15
Imported Natural gas	1.09
Imported Steam	1.45
Imported Hot Water	1.35
Imported Chilled Water	1.04
Imported Fuel Oil	1.19
Imported Propane	1.15
Imported Coal and Other	1.05
Exported Electricity	3.15
Exported Steam	1.45
Exported Hot Water	1.35
Exported Chilled Water	1.04

~~2.1.~~ The energy loads for heating and cooling in the Qualifying Home shall be normalized to account for the differences in improvement potential that exist across equipment types using the following formula:23

~~nMEUL = REUL * (nEC_x /EC_r)~~

~~where:~~

~~nMEUL = normalized Modified End Use Loads (for heating or cooling) as computed using accredited simulation tools.~~

~~REUL = Reference Home End Use Loads (for heating or cooling) as computed using accredited simulation tools.~~

~~EC_r = estimated Energy Consumption for Reference Home’s end uses (for heating, including auxiliary electric consumption, or cooling) as computed using accredited simulation tools.~~

~~and where:~~

~~nEC_x = (a* EEC_x – b)*(EC_x * EC_r * DSE_r) / ( EEC_x * REUL)~~

~~where:~~

~~22 HERS BESTEST has been adopted by RESNET as a test suite requirement for all rating software tools that are accredited by RESNET.~~

23 Source: Fairey, P., J. Tait, D. Goldstein, D. Tracey, M. Holtz, and R. Judkoff, "The HERS Rating Method and the Derivation of the Normalized Modified Loads Method." Research Report No. FSEC-RR-54-00, Florida Solar Energy Center, Cocoa, FL, October 11, 2000. Available online at: ~~http://www.fsec.ucf.edu/bldg/pubs/hers_meth/~~

~~nEC_x = normalized Energy Consumption for Qualifying Home’s end uses (for heating, including auxiliary electric consumption, or cooling) as computed using accredited simulation tools.~~

~~EC_r = estimated Energy Consumption for Reference Home’s end uses (for heating, including auxiliary electric consumption, or cooling) as computed using accredited simulation tools.~~

~~EC_x = estimated Energy Consumption for the Qualifying Home’s end uses (for heating, including auxiliary electric consumption, or cooling) as computed using accredited simulation tools.~~

~~EEC_x = Equipment Efficiency Coefficient for the Qualifying Home’s equipment, such that~~

~~EEC_x equals the energy consumption per unit load in like units as the load, and as derived from the Manufacturer’s Equipment Performance Rating (MEPR) such that~~

~~EEC_x equals 1.0 / MEPR for AFUE or COP ratings, or such that EEC_x equals 3.413 / MEPR for HSPF, EER or SEER ratings.~~

~~DSE_r = REUL/EC_r * EEC_r~~

For simplified system performance methods, DSE_r equals 0.80 for heating and cooling systems. However, for detailed modeling of heating and cooling systems, DSE_r may be less than 0.80 as a result of part load performance degradation, coil air flow degradation, improper system charge and auxiliary resistance heating for heat pumps. Except as otherwise provided by these Standards, where detailed systems modeling is employed, it must be applied equally to both the Reference and the Qualifying Homes.

~~EEC_r equals 1.0 / MEPR for AFUE or COP ratings, or such that~~

~~EEC_r equals 3.413 / MEPR for HSPF, EER or SEER ratings.~~

~~REUL = Reference Home End Use Loads (for heating or cooling) as computed using accredited simulation tools.~~

~~and where the coefficients ‘a’ and ‘b’ are as defined by Table 2.1 below:~~

~~Table 2.1 Coefficients ‘a’ and ‘b’~~

~~Fuel type and End Use~~	a	b
~~Electric space heating~~	~~2.2561~~	0
~~Fossil fuel* space heating~~	~~1.0943~~	~~0.4030~~
~~Biomass space heating~~	~~0.8850~~	~~0.4047~~
~~Electric air conditioning~~	~~3.8090~~	0
~~Electric water heating~~	~~0.9200~~	0
~~Fossil fuel* water heating~~	~~1.1877~~	~~1.0130~~

*Such as natural gas, liquid propane gas, fuel oil

~~2.2.~~ Following normalization of the heating and cooling energy consumptions for the Qualifying Home as specified in section 2.1 above, the Reference Home’s total reference end use loads for heating and cooling (REULtot) shall be compared with the Qualifying Home’s total normalized modified end use loads for heating and cooling (nMEULtot) using the following formula to determine the % Energy Reduction:

~~% Energy Reduction = [(REULtot – nMEULtot) / (REULtot)] * 100~~

Pg. 79

e-Ratio = (Qualifying Home ~~energy use~~ PEC) / (Reference Home ~~Energy Use~~ RPEC)

Pg. 82

e-Ratio = (Proposed Home ~~energy use~~ PEC) / (Standard Reference Design ~~Energy Use~~ RPEC)

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #114

Page Number: various
Comment Type: Technical

Comment:

This revision is a companion revision to the primary energy consumption methodology comment 113 and specifies a single standard reference design for heating and service water heating systems, using technologies with high primary energy efficiency and low associated pollutant emissions as the baseline in the heating and service water heating component categories. The cooling category already uses a single electric reference system.

The proposed revision:

Establishes a single baseline building performance requirement
- for all service hot water (SHW) and HVAC systems
- independent of making the system choice for the rated home
- at a realistic and achievable level using current technologies.
Addresses the inconsistent mix of multiple baseline building technology performance requirements in RESNET PDS 301-01.
Provides equitable and consistent treatment of all SHW and HVAC system options, including conventional, renewable energy, hybrid technology, and waste heat recovery options.
Is indifferent to the SHW and HVAC system choice in the rated home, comparing all SHW and HVAC system options against a single energy efficient reference home energy performance requirement.
Aligns the SHW and HVAC system performance requirement methodology with the cooling and envelope single reference home requirement methodology.
Achieves the goal of reducing the site energy cost, national energy consumption, and global pollution emissions related to the operation of the home in a cost-effective and equitable manner.

PDS 301-01 currently uses multiple reference mechanical systems, depending on fuel type, for heating and service water heating (but not cooling) – considering all reference systems to be equivalent to each other. However, none of the systems has the same annual primary energy consumption, energy cost, or pollutant emissions. This mix of equivalencies is a counter-productive and inconsistent approach that can be mitigated by shifting to a single reference design for all rated home design alternatives. The existing provisions also may be subject to various interpretations on the appropriate reference design for advanced multi-fuel appliance options, waste heat recovery options, or emerging technologies that reduce energy costs significantly compared to options that currently qualify. The impact is to establish the reference design building AFTER technology category and energy design choices are made. This is an inequitable application of prescriptive requirements in setting rating and energy savings levels. By applying the reference baseline methodology inconsistently and inequitably, the current HERS Index and energy savings methodology rewards electric heating and service water heating technology options and penalizes other heating and water heater options in spite of their advantageous energy and environmental performance. This constraint eliminates the credit for creative design choices that would significantly reduce energy cost, energy use, and pollutant emissions.

A single technology-blind baseline performance requirement is the most technically defensible methodology for ratings and savings evaluations, and it is critical for equitable implementation of the RESNET PDS 301-01 requirements. Shifting to a single baseline design provides an equitable credit to all technologies that have lower annual primary energy consumption compared to the single baseline level irrespective of energy form or technology design. It establishes fixed reference home performance requirements BEFORE making the technology and energy choices for the rated home. It is critical for equitable implementation of energy cost, primary energy consumption, or pollution emission compliance requirements. A single reference design methodology creates a level playing field for all technology and energy forms and provides equitable treatment of advanced renewable, waste heat recovery, hybrid, and multi-fuel technology options. It is especially important for equitable and consistent evaluation of on-site power generation and combined heat and power systems.

This revision is consistent with the single reference building methodology in ASHRAE’s bEQ program, EUI calculations from the EPA in the Energy Star Buildings program, and the DOE Home Energy Score Tool. Each of these methodologies establishes a single reference building using primary energy conversion factors for different fuels as the basis of their energy rating and efficiency compliance requirements. A consistent single standard reference design methodology will improve the adoptability of PDS 301-01 by ensuring transparency and equity for all technologies and eliminating confusion at jurisdictional levels.

The baseline systems in the proposed revision were selected to ensure an equitable and level playing field for all technologies at a reasonable and achievable level of primary energy efficiency and pollution emissions performance. The single reference designs were each set at a primary energy efficiency level that minimizes “backsliding” while providing earned credit for high efficiency and low carbon emission technologies, within and across energy choices.

The revised table applies a single reference design consistently to all technology and energy options without prohibiting any technology or energy choice. For example, the baseline does not prohibit primary energy-inefficient and higher pollutant emitting water heating options such as electric resistance water heaters. It correctly still allows electric resistance storage water heaters, but places them at an equitable disadvantage compared to the baseline building technology based on primary energy efficiency. A designer who wanted to use an electric resistance water heater would only need to reduce the full-fuel-cycle energy consumption and pollution emissions to a level equivalent to the gas water heater in the reference building, and could do so through whatever combination of improved energy efficiency options they chose, including mechanical system or envelope tradeoffs.

At the same time, a designer choosing to put in a higher efficiency heat pump water heater would get a reasonably equivalent energy performance to the baseline gas water heater, preventing unintended backsliding in the envelope or other mechanical system efficiencies. Higher cost, higher efficiency options such as gas tankless and condensing water heaters would get consistent earned credit, allowing the designer to further improve the rating of the home or implement tradeoffs, thereby encouraging rather than discouraging their installation.

The economic, energy, and environmental benefits of adopting the approach proposed in this revision are positive and significant. For example, in a typical Chicago home configuration that currently scores 100 in the current HERS Index, one all-electric and one with gas heating and water heating, shifting to a single reference home would reduce the source energy consumption from 240.5 MMBtu to 200 MMBtu in the all-electric home (a 20 percent reduction). Pollution emissions are reduced even further (from 38,840 pounds CO2 equivalent emissions to 28,550 pounds – a 27 percent reduction).

The revision completely decouples the proposed building design choices from the standard reference design building’s energy performance requirement. The reference energy and technology choices in the revised tables were selected to provide a practical and effective requirement to meet the intent of the standard while still offering appropriate incentives for the best available technologies based on their primary energy consumption benefits. Encouraging rather than discouraging this design flexibility aligns closely with RESNET’s stated goal of reducing comprehensive improvements to the energy performance of homes.

Proposed Change:

Pg. 14

Heating systems (h),(i)

Fuel type: ~~same as Rated Home~~ natural gas

Efficienc~~ies~~y:

~~Electric: air source heat pump in accordance with Table 4.2.2(1a)~~

~~Non-electric furnaces:~~ Nnatural gas furnace in accordance with Table 4.2.2(1a)

~~Non-electric boilers: natural gas boiler in accordance with Table 4.2.2(1a)~~

Same as Rated Home (i)

Pg. 15

Service water heating systems (h) (m)

Fuel type: ~~same as Rated Home~~ natural gas

Efficiency

~~Electric: EF = 0.97 - (0.00132 * store gal)~~

~~Fossil fuel~~ Natural Gas: EF = 0.67 - (0.0019 * store gal)

Same as Rated Home (m)

Pg. 17 – 18

Pg. 71

Heating systems (h),(i)

Fuel type: ~~same as Qualifying Home~~ Natural gas

Efficienc~~ies~~y:

~~Electric: air source heat pump with prevailing federal minimum efficiency~~

~~Non-electric furnaces:~~ nNatural gas furnace with prevailing federal minimum efficiency

~~Non-electric boilers: natural gas boiler with prevailing federal minimum efficiency~~

Capacity: sized in accordance with Section 303.5.1.5, RESNET Standards (2005).

Same as Qualifying Home (i)

Same as Qualifying Home ~~Same as Qualifying Home~~

~~Same as Qualifying Home~~

Same as Qualifying Home

Service water heating systems (h) (n)

Fuel type: natural gas

Efficiency: in accordance with prevailing federal minimum standards

Capacity: sized in accordance with Section 303.5.1.5, RESNET Standards (2005).

Same as Qualifying Home (n)

Pg. 74

(n) For a Qualifying Home with a non-storage type water heater, a 40-gallon storage-type water heater with the prevailing federal minimum efficiency shall be assumed for the HERS Reference Home. For a Qualifying Home without a proposed water heater, a 40-gallon storage-type water heater with the prevailing federal minimum efficiency with the same fuel as the heating system shall be assumed for both the Qualifying and HERS Reference Homes.

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #115

Page Number: 36
Paragraph / Figure / Table / Note: Table 4.4.2(1) Minimum Rated Features
Comment Type: General

Comment:

Oven/range, clothes washer and clothes dryer should be added to Table 4.4.2(1). These are called out as rated features in Sections 4.2.2.5.2.7, 4.2.2.5.2.8 and 4.2.2.5.2.10.

Response:
Accepted. The suggested rated appliances will be added to Table 4.4.2(1) in the final committee draft of BSR/RESNET 301-201x.

Comment #116

Page Number: 1
Paragraph / Figure / Table / Note: 2. Scope
Comment Type: General

Comment:

The Energy Commission’s concern with the proposed standard is that this Standard fails to fully recognize the HERS processes that are legally required in California.

Section 4.1: The scale discussed is very different from what is used in California. It is endeavors to be neutral across fuels and indifferent of time of use – whereas California’s serious summer peak demand problem has led the State to emphasize seasonal and time of use implications to utility costs that apply to each fuel. Failure to do this leads to valuation of energy efficiency measures that conflict with state energy policy and maintaining a reliable energy system.

We strongly support Section 4.1 statement: “Except in states or territories whose laws or regulations require a specific alternative method, which shall control, equations 4.1-1 and 4.1.2 shall be used in a 2 step process to calculate the HERS Index for the Rated Home …” That is a very important feature that should readily apply to implementation of the Standard.

Section 2 says: “This Standard is a companion to the RESNET Mortgage Industry National Home Energy Rating Systems Standards.” Section 101.1.1 of those “Mortgage Standards” says, “Relationship to State Law. These Standards specifically recognize the authority of states that have laws requiring certification or licensing of home energy rating Providers. To the extent that state laws differ from these Standards, state laws shall govern.”

California’s HERS regulations and HERS Technical Manual differ from RESNET standards in ways that have developed through a great deal of field research in California, analysis by the Commission, IOU consultants and stakeholders, and have been extensively vetted and ruled upon by the Commission in establishing legal requirements for Standards for completing HERS ratings for existing buildings. RESNET’s proposed standard shouldn’t require California to abandon all that has already been established in California. In particular, the Commission has gone to great efforts to improve the construction/installation quality of specific energy efficiency measures that are subject to defect. We assume in our calculations that normal industry practice that results in defects, will occur in the absence of specific installer attention to overcoming them, and third party field verification by HERS raters to diagnostically test that those defects have not occurred – we give credit in our calculations when those defects are verified to have been avoided. The RESNET standards do not include much of what California has developed, and in the areas where RESNET has developed some type of quality determination, the methods are different from what California has put into law. California wants the ability to rely on the methods that have been developed by the Commission, California researchers, and stakeholders and is state law, as a means of showing compliance with RESNET’s standard. We would like to have this ANSI Standard to be made consistent with section 101.1.1 of RESNET’s “Mortgage Standards.”

Proposed Change:

2. Scope. This standard is applicable to all single family residences and to all multifamily residences three stories or less in height above ground excepting hotels and motels. This Standard is a companion to the RESNET Mortgage Industry National Home Energy Rating Systems Standards.

Consistent with section 101.1.1 of those “Mortgage Standards,” this Standard specifically recognizes the authority of states that have laws requiring certification or licensing of home energy rating Providers. To the extent that state laws differ from this Standard, state laws shall govern.

Response:
Rejected. State laws and regulations may take precedence over a national consensus standard without regard to the standard making this an explicit specification of the standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #117

Page Number: Whole Document
Comment Type: General

Comment:

The first sentence in the Standard (RESNET PDS 301-01) states

“1. Purpose. The provisions of this document are intended to establish national residential energy rating and labeling Standards, …. “

Either this Standard is intended to have broad use by many organizations and parties; or, the Standard defines the process and procedures for RESNET and those associated with it. The Standard cannot do both. As stated in the Purpose, RESNET wants to produce a standard for general use, not a document only for RESNET and RESNET-affiliated parties.

The Standard should not contain commercial terms and conditions. The Standard is full of proprietary elements and requirements that are inappropriate for a “national residential energy rating and labeling standard”. (Specific proprietary elements are named in other comments.) The proprietary elements include many terms and processes defined to require RESNET procedures or approval, requirements to use RESNET trained and approved professionals, descriptions of RESNET committees, etc. The first two RESNET-specific elements occur on page 1 in the Section 2, Scope, and the definition of “Accreditation Categories (software tools)”, others occur frequently though out the Standard.

Many proprietary parts of the Standard are added by normative (mandatory) reference to the Mortgage Industry National Home Energy Rating Systems Standard.

The heavily proprietary nature of the Standard violates both the RESNET Standards Development Policy and Procedures Manual and the ANSI Essential Requirements, especially those requirements in the sections titled “Commercial Terms and Conditions”. These requirements state:

“ … The appearance that a standard endorses any particular products, services or companies shall be avoided. Therefore, it is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent). … In connection with standards that relate to the determination of whether products or services conform to one or more standards, the process or criteria for determining conformity can be standardized as long as the description of the process or criteria is limited to technical and engineering concerns and does not include what would otherwise be a commercial term.”

If there are parts of the Standard or its normative reference to the Mortgage Industry National Home Energy Rating Systems Standard that specify a “sole source”, then the Standard should follow the RESNET and ANSI requirements for sole-source references. Both the RESNET Standards Development Policy and Procedures Manual and the ANSI Essential Requirements specify a sole source should be in a footnote or informative (non-mandatory) annex along with the words “or the equivalent”. In their section on “Commercial Terms and Conditions” RESNET and ANSI state:

“Where a sole source exists for essential equipment, materials or services necessary to comply with or to determine compliance with the standard, it is permissible to supply the name and address of the source in a footnote or informative annex as long as the words “or the equivalent” are added to the reference.”

Since there are other programs that provide procedures and services to demonstrate residential energy efficiency; RESNET, RESNET procedures and processes and those associated with RESNET do not generally qualify as a “sole source” for residential energy rating and labeling standards. Examples of other sources include Energy Star, the energy chapter of ICC 700, LEED for Homes, the Building Performance Institute (BPI), Environments for Living, etc. There are also regional or local programs that have similar functions, such as the energy portion of Built Green, Earth Advantage with its Energy Performance Score, etc. Some of these other programs may choose to use RESNET, RESNET procedures, or those associated with RESNET; however, that does not make RESNET a “sole source” for everyone.

So much of the Standard will have to be changed to alter its proprietary nature that the public review process of the full Standard should be given at least 60 days after the non-proprietary version of the Standard is posted.

The elements of the Standard that are specific to or associated with RESNET can be retained in other “RESNET specific” documents. However those provisions of those other documents should not be called “consensus” unless they have followed the RESNET and ANSI specified consensus development process. Those RESNET-specific documents should not be made normative (mandatory) by the Standard’s reference to another document.

Proposed Change:

The commercial terms and conditions of the Standard that specify functions that are necessary should be restated in generic, non-proprietary technical and engineering terms. The proprietary elements of the Standard not required as part of the technical and engineering concerns of the Standard should be removed from the Standard. The normative references should not themselves include proprietary requirements.

Response:
Accepted with modification. All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. however, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #118

Page Number: 66 and elsewhere
Paragraph / Figure / Table / Note: 2.1 and elsewhere
Comment Type: Technical

Comment:

Laclede is very supportive of RESNET PDS 301-01 efforts for moving closer to full fuel-cycle energy and emissions analyses. Having read all the posted comments to date, it is evident that there is an organized/repetitive attempt to move this effort backwards towards scientifically indefensible site-based efficiency and emissions.

Laclede endorses comments 112, 113 and 114 but does not want to waste the time of RESNET PDS 301-01 reviewers by repeating these comments. However, it would be appropriate to summarize what those comments are intended to provide as follows:

Comment 112: provides a more robust/public domain-based methodology for reporting emissions

Comment 113: updates the “normalized modified loads method” (NMLM) to full fuel-cycle efficiency

Comment 114: levels the gas vs. electric playing field through the introduction of comfort heating and domestic hot water single reference home

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #119

Page Number: 43
Paragraph / Figure / Table / Note: 4.5.4.1
Comment Type: Technical

Comment:

The proposed standard converts on-site fossil fuel consumption to Equivalent Electric Energy by discounting fossil consumption by 60% (multiplying fossil consumption by 40%). The policy reason for including the fossil fuel discount is, apparently, an attempt to account for upstream losses in the conversion of primary fuels into electricity. The “site vs. source” argument has been debated for many years and reasonable arguments can be made for use of both approaches under appropriate circumstances.

The U.S. Energy Information Agency has stated

[s]ite energy data are most useful to building engineers, energy managers, building owners and others concerned with consumption directly related to the buildings; e.g., the energy efficiency of end-use equipment. Primary energy data are useful to policymakers and energy analysts who are concerned with broader energy or environmental issues, such as carbon emissions from energy sources. http://www.eia.gov/emeu/consumptionbriefs/cbecs/cbecs_trends/primary_site.html

Using EIA’s philosophy, my preference would be for RESNET HERS to use a site energy approach. Among other things, use of a source energy approach can lead to absurd results. For instance, if a customer elects to purchase 100% wind power (as is possible in many locations), use of a source energy approach by the RESNET HERS could suggest that a gas furnace would still be preferable to an electric heat pump.

The example above is illustrative of one of the many challenges to the use of a source energy approach to rate homes for energy efficiency, namely, that electricity is derived from many “sources” including coal, gas, oil, biomass, wind, solar, hydro, nuclear, geothermal and other sources. Each of these primary sources has its own unique characteristics and the attempt to blend them all into a single composite descriptor is relatively unhelpful, particularly as it tends to blur the distinction between efficiency that a homeowner has some control over (his or her house) with efficiency of a remote power plant (over which that homeowner has no control).

If, however, RESNET decides to continue to use a 60% discount for on-site fossil fuel usage in a home, then it should consider revising the 60% discount to a more appropriate number.

Using the formula on section 4.5.4.1 implies a delivered electrical efficiency of 8,532 btu’s/kwh (3,412 btu’s / 40%).

In several recent rulemakings by the U.S. Department of Energy, it assumed a delivered electrical efficiency of about 6,700 btu’s/kwh.

For example, see http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/ff_prelim_ch_10_nia_2012_06_21.pdf at p.8.

These conversion factors are based on both historical data and projections of future power plant heat rates and they represent the fossil fuel component of electric generation. As noted above, electricity derives from many sources but treating a kwh generated from coal the same as a kwh generated from wind, or from hydro or nuclear, is unhelpful to users. DOE has chosen to focus on the use of non-renewable, fossil fuels in its site-to-source conversions.

If RESNET chooses to continue to discount fossil fuel consumption in the calculation of HERS scores, I propose to modify the discount to 52% (3,412 btu’s/kwh/6600 btu’s source energy) which roughly represents the fossil fuel component of electric generation.

This same justification would support changes to the definition of Reference Electricity Production Efficiency and the TEU.

Proposed Change:

kwh eq = kwh elec + btu elec + (btu fossil * .52 / 3412)

Comment #120

Page Number: 48
Paragraph / Figure / Table / Note: 5.1.2.1.1. Energy Prices.
Comment Type: Technical

Comment:

In addition to supporting comments 112, 113 and 114, Laclede is also concerned with Sec. 5.1.2.1.1. Energy Prices which states:

Energy costs for all homes shall be calculated using revenue-based energy price rate data published annually by RESNET as derived from the U.S. Department of Energy (DOE) Energy Information Administration (EIA).

A source should be referenced for “revenue-based energy price rate data.” Moreover, if this date is based upon average utility costs, RESNET should address the fact that the use of average utility costs tends to overinflate customer savings thereby misleading customer as to the real value of reducing or displacing utility energy purchases. To accurately estimate consumer savings, RESNET should employ the use of consumer marginal energy rates (CMER) Any Internet search engine (such as Google) will provide all the necessary background on this term and its importance in calculating utility savings. Suffice it to say for the moment that at least in some cases, using average costs instead of CMER can inflate consumer savings by as much as 50%.

Proposed Change:

5.1.2.1.1. Energy Prices. Energy costs for all homes shall be calculated using ~~revenue-based energy price rate data published annually by RESNET as derived from the U.S. Department of Energy (DOE) Energy Information Administration (EIA)~~ consumer marginal energy rates provided by the local utility.

Response:
Rejected. The use of local consumer marginal energy rates (CMER) provided by the local utility for household energy costs will not produce the level of independent utility price verification needed by BSR/RESNET Standard 301-201x. It will also work a hardship on energy Raters and rating Software tool providers and Quality Assurance Designees in collecting, maintaining and quality assuring the utility price data used in Ratings.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #121

Page Number: 14
Paragraph / Figure / Table / Note: 4.2.2(1)
Comment Type: Technical

Comment:

Table 4.2.2(1)

As it is written, Table 4.2.2(1) requires a modeler to assume a heat pump system whenever a designer proposes to use electric heat, even if the builder wanted to use electric resistance or electric radiant heating (collectively “ERH”). While perhaps serving a valuable function in some fashion (elimination of gaming where a modeler assumed an electric furnace for the reference house and then proposes a heat pump allowing a less stringent envelope), the limitation on use of ERH in the modeling is overly restrictive. ERH is available in many different applications and the performance characteristics of non-ducted ERH are very different from the performance characteristics of ducted heating systems, whether fueled by electricity, gas, or any other fuel. In addition to no duct energy losses, non-ducted ERH also enjoys significant energy savings from zoning. This proposal attempts to preserve the benefit of eliminating gaming while still recognizing the energy savings potential of non-ducted ERH.

Substantiation: ERH is available in a number of different configurations, including electric furnace, baseboard, radiant and PTAC. For purposes of this proposal, however, only non-ducted ERH is being considered. The operational and energy consumption characteristics of ducted vs. non-ducted ERH are significant and are at the core of the rationale behind this code change proposal. Unfortunately, ducted and non-ducted ERH systems are often grouped together (as they are in the existing code language).

Language like that found currently in Table 4.2.2(1) that requires a modeler to assume a heat pump in the reference house, even if the designer intends to use electric baseboard heating in the proposed house, has been in HERS and other like documents (IECC, ASHRAE Standard 90.2, etc.) for many years. The justification cited historically for that modeling limitation is:

· That modelers will game the system by assuming ERH in the reference house but a heat pump in the proposed house, thereby allowing a less stringent envelope, and/or

· That a heat pump will consume on the order of half the energy of an electric furnace installed in the same house so the code should discourage designers from specifying ERH and instead should specify a heat pump.

With respect to the former of these justifications, the current language requiring the same equipment to be modeled in both the reference and the proposed designs denies any opportunity to game the system as described above.

That leaves the latter as the sole justification for the modeling restriction against using electric resistance heating as the equipment assumption in the reference house. To some extent, this seems appropriate. If, for instance, in a heating dominated climate, a designer is proposing to install a ducted electric furnace with central air-conditioning, then incenting that designer to use a heat pump instead would probably be expected to save significant amounts of energy at a relatively modest cost.

But there are significant operational and energy consumption characteristics that separate ducted vs. non-ducted ERH as described in more detail below.

Ducted vs. non-ducted heating systems. Non-ducted ERH has significant operational and energy consumption characteristics from ducted heating systems as described in more detail below:

Fan Power. Numerous studies over the last decade have identified furnace fan energy usage as more significant than before believed. As a result, the U.S. Department of Energy has initiated a rulemaking to establish a test procedure for determining furnace fan energy. Likewise, the Environmental Protection Agency now has an Energy Star rating for efficient furnace fans. Of course, non-ducted ERH like baseboard or radiant doesn’t use a fan. On this basis, a reasonable person could conclude that, all other things being held constant, a non-ducted ERH system (without a fan) would consume less energy than a ducted electric furnace with a fan.

Duct loss and fan induced infiltration. Energy losses through ductwork are recognized as significant and come from two distinct sources; air lost through ductwork to the outside and induced infiltration/exfiltration caused by duct pressurization. Air lost to the outside is self-explanatory and is, in fact, already recognized by the RESNET where distribution system efficiency is discounted under certain common conditions. In addition, there is growing recognition that ductwork design can have a significant impact on infiltration/exfiltration. On this basis, a reasonable person could conclude that, all other things being held constant, a non-ducted ERH system would consume less energy than a ducted electric furnace.

Zoning. Ducted, central heating, whether it be a ducted heat pump, electric furnace, gas furnace or other, is designed to serve large areas, most often an entire house. Non-ducted ERH, on the other hand, generally divides a house up into numerous independently controlled zones. The energy efficiency benefits of zoning are well documented as it allows users to heat only those areas that are occupied resulting in significant savings. On this basis, a reasonable person could conclude that, all other things being held constant, a zoned, non-ducted ERH system (without ductwork) would consume less energy than a non-zoned, ducted electric furnace.

Additional considerations. Few people would argue that, at the margin, a zoned, non-ducted ERH would be expected to consume fewer but’s over the course of a winter than a ducted electric furnace. In addition to these operational differences, however, (no fan energy, no duct losses, benefits of zoning), there are other reasons why ERH should be treated differently from ducted heating systems as noted below.

Cooling. There are still a non-trivial amount of new homes built in the United States every year without central cooling. According to the EIA, over 800,000 new homes were built between 2000 and 2009 without air-conditioning. A recent study in the Pacific Northwest revealed a relationship between increased use of cooling energy in homes that use heat pumps vis-à-vis electric furnaces. While there are a number of potential explanations, at least one explanation is that people using ERH consciously decline to install air conditioning. Thus, incenting the use of heat pumps over ERH may have the unintended result of increasing summer cooling energy.

Cooling dominated climate. In cooling dominated climates, with relatively few heating degree days (DOE Climate Zones 1 & 2), driving a builder to use a heat pump which would save relatively little – if any – heating energy due to the warm climate would result in fewer dollars for that builder to spend on other things like more attic insulation or higher SEER air-conditioning – something that would actually result in energy savings.

Non-ducted ERH has significantly different operating characteristics than ducted heating systems.

With respect to the assumption that a heat pump system will consume less than half the btus’s of an electric resistance heating system because the heat pump has a COP of 2 or better, this assumption may be valid for a comparison between a ducted heat pump and a ducted electric resistance furnace, but it not accurate for non-ducted, zoned ERH (See Note 1 below)

In a study conducted by the National Association of Home Builders Research Center for the U.S. Department of Energy, an occupied house in the Washington, D.C. area was monitored for performance over a winter. The house contained three distinct heating systems; central electric heat pump, electric radiant heat, and electric baseboard heat. After the data was weather normalized, it revealed that, under actual homeowner controlled conditions, the electric radiant system used 33% percent less energy than the heat pump system and 52% less than the electric baseboard system. Thus, the heat pump only saved about 36% the energy consumed by the electric baseboard system.

Heat pumps are a great option when a person wants a central, ducted hearing and cooling system but they having different operating characteristics from a non-ducted ERH system.

Note 1. Recent field data from a large survey of homes suggests that the actual (vs. theoretical) relationship may not be as well understood as previously believed. See study at http://www.nwcouncil.org/energy/rtf/meetings/2009/04/Draft%202008%20NEEM%20Study_040608.pdf (p. 21) where observed heat pump energy savings were far short of expectations and the report said “For the heat pump cases, however, the apparent similarity between electric resistance and heat pump systems suggest minimal savings for the more efficient heat pump option. Some form of behavioral ?takeback?, poor heat pump installations or increased summer cooling load for heat pumps vis-à-vis resistance houses seem the likeliest explanations. Given that a number of the zone 1 sites (e.g.: Medford, Oregon; Yakima, Washington; and The Dalles, Oregon), have cooling climates, the latter seems plausible. A possible alternate contributing explanation is that these heat pump units do not in fact achieve an average COP of as much as 2 under actual operating conditions. Field notes from heat pump cases in the Oregon sample (a high percentage of heat pumps) mentioned occupants who complained about a lack of comfort to their heating contractor and were told by their heating contractors to switch the heat pumps to run in electric resistance heating mode.”

Bibliography

Study of manufactured housing in the Pacific Northwest, http://www.nwcouncil.org/energy/rtf/meetings/2009/04/Draft%202008%20NEEM%20Study_040608.pdf

NAHB Radiant Heat Study, http://www.toolbase.org/PDF/CaseStudies/enerjoy_case_study.pdf

For an Alliance to Save Energy video on the benefits of zoning see http://www.energynow.com/video/2011/11/16/home-efficiency-tips-heating-and-cooling-zones where the moderator quotes the Department of Energy as saying that zoning can save up to 30% on home heating and cooling bills.

For information on duct leakage see http://www.greenbuildingadvisor.com/blogs/dept/musings/duct-leakage-testing. Also see EPA Energy Star guidance at http://www.energystar.gov/index.cfm?c=home_improvement.hm_improvement_ducts.

For information on fan induced infiltration into buildings see http://www.buildingscience.com/documents/digests/bsd-014-air-flow-control-in-buildings/files/bsd-014_air-flow-control_ed.pdf.

For an article on the significance of furnace fan energy see http://aceee.org/proceedings-paper/ss08/panel02/paper09. Also see U.S. Department of Energy Appliance Efficiency furnace fan docket at http://www1.eere.energy.gov/buildings/appliance_standards/residential/furnace_fans.html.

Proposed Change:

Table 4.2.2(1)

Heating systems

Electric: air source heat pump in accordance with Table 4.2.2(1) Exception: where the proposed design is for an electric heating system that does not use a duct system, the standard reference design shall be as proposed.

Response:
Rejected. The proposed change would materially degrade the benefit of systems that do not have air distribution system losses and misrepresent the efficiency of such homes with respect to typical homes with ducted air distributions systems. The proposed standard does not intend to have a standard reference design that is less stringent than Section 404 of the 2006 IECC.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #122

Page Number: 14
Paragraph / Figure / Table / Note: 4.2.2(1)
Comment Type: Technical

Comment:

Substantiation: ETS systems have significantly different operational and energy consumption characteristics versus other types of heating systems. These differences are at the core of the rationale behind this change proposal. In particular, ETS systems have the ability to respond to the needs of the utility and electric grid by storing energy during preferential times of the day or night and turn on or off as needed. This is very beneficial in improving efficiency of power generation, transmission and distribution, for integration of renewable energy and for providing grid power balancing services. Unfortunately, ETS systems are generally lumped together with traditional heating systems (as they are in the existing HERS language).

Language like that found currently in Table 4.2.2(1) that requires a modeler to assume a heat pump in the reference house, even if the designer intends to use electric resistance heating, including an ETS in the proposed house, has been in HERS and other like documents (IECC, ASHRAE Standard 90.2, etc.) for many years. The justification cited historically for that modeling limitation is:

· That modelers will game the system by assuming ERH in the reference house but a heat pump in the proposed house, thereby allowing a less stringent envelope, and/or

That leaves the latter as the potential justification for the restriction against modeling the use of electric resistance heating in the reference house. To some extent, this seems appropriate. If, for instance, in some heating dominated climates, a designer is proposing to install a ducted electric furnace with central air-conditioning, then incenting that designer to use a heat pump instead of an electric furnace might be expected to save some amount of energy at a relatively modest cost.

But there are significant operational and energy consumption characteristics that distinguish ETS from traditional heating systems (whether fueled by electricity, gas, oil or other fuel) as described in more detail below.

Grid-interactive electric thermal systems (“ETS”). ETS have significantly different operational and energy consumption characteristics from traditional electric and fossil heating systems.

Thermal battery. Electric utilities dispatch their generators in the order from the most cost efficient (base load generation) to the least cost efficient (peaking load generation). ETS complements the efficient dispatch of generation by utilities by allowing the storage of energy that is produced more efficiently for use later, and by avoiding the requirement to operate less efficient generators at peak load conditions. ETS accomplishes this feat by charging (heating bricks, water, or other storage media) at times when utilities have excess capacity. Often this is at night but it can vary between utilities. Because the system is grid-interactive, an ETS can charge at times that are optimum for the utility, allowing utilities to efficiently manage their peak demands and their customer costs. Heat that is stored for later use effectively makes ETS a thermal battery.

Renewable energy. ETS is a unique complement to the generation of electricity from renewable energy like wind and solar. Many times peak power production from renewable energy sources does not coincide with a utility’s demand for electricity. As an example, wind generation usually peaks at night when demand for energy is not usually the greatest. For that reason, Bonneville Power last year was forced to curtail the generation from wind generators at certain times because it didn’t need all the electricity the wind generators were producing! ETS is a good fit for storing excess renewable energy and has been successfully deployed in Bonneville’s service territory as well as the service territory of other electric utilities.

Reduces winter peak. When electrical demands on a utility’s system grow, it is forced to dispatch less efficient generators to meet that demand, so to the extent demand is reduced the utility avoids costs (that would ultimately be passed on to customers) and saves energy. ETS allows the storage of energy produced by more efficient generators.

Replaces fossil fuel in utility grid control. When electrical demand on a utility’s grid changes (up or down), the most immediate system response is for the grid’s frequency to drift away from ideal (60 cycles per second). To control these frequency excursions, utilities have traditionally operated fossil fuels generators to add voltage to the grid to raise the frequency as it falls away from 60 cycles. Grid-interactive ETS can be dispatched in lieu of fossil fuel generators to remedy frequency excursions, thereby saving energy and costs. According to a Kema report, usage of a non-carbon emitting resource such as ETS for providing regulation services can reduce carbon emissions for regulation by nearly 65%.

ETS offer significant benefits to customers, including the ability to store renewable energy, the ability to reduce utility costs, and the ability to reduce the consumption of fossil fuel by utilities in the regulation of system frequency.

Bibliography

See article at http://www.pjm.com/about-pjm/exploring-tomorrows-grid/electricity-storage.aspx?p=1 for information on the value of ETS in the PJM Interconnection service territory.

See article at http://www.sustainablebusinessoregon.com/articles/2012/04/bonneville-power-calls-for-first-wind.html?page=all for information on Bonneville Power curtailment of wind generation amounting to almost 100,000 MWH’s in 2011.

See Kema Consulting report (Commissioned by the U.S. Department of Energy under the supervision of Sandia National Laboratory) noting significant reduction in carbon emissions at http://prod.sandia.gov/techlib/access-control.cgi/2008/088229.pdf.

See http://www.steffes.com/off-peak-heating/ets.html for more information on utility benefits of WTS, including energy savings associated with thermal storage and frequency regulation.

See Sandia National Laboratory website at http://www.sandia.gov/ess/ for information on the contributions of energy storage to electric grid stability.

For a detailed description of frequency regulation in North America see Department of Energy / National Energy Technology Laboratory Report Frequency Instability Problems in North American Interconnections, DOE/NETL-2011/1473, Final Report dated May 1, 2011 found at http://www.netl.doe.gov/energy-analyses/pubs/TransmissionFreqProb.pdf

Proposed Change:

Table 4.2.2(1)

Heating systems - Electric: air source heat pump in accordance with Table 4.2.2(1a). Exception: where the proposed design is for an electric heating system that is Grid-interactive electric thermal storage (ETS), the standard reference shall be as proposed.

Add definition: Grid-interactive electric thermal storage. A device designed for the storage of electrical energy that has been converted into heat, and that has the ability to turn on or off in response to the needs of the utility or the electric grid.

Response:
Rejected. BSR/RESNET Standard 301-201x does not prohibit the use of ETS in Rated Homes. When any efficiency exists, they can be included in the Rated Home. However, this proposal does not go to the benefit of enhanced efficiency in the Rated Home, but rather it proposes to alter the Reference Home specification such that there is no possible differentiation between the Reference and Rated Homes. The proposed standard does not intend to have a standard reference design that is less stringent than Section 404 of the 2006 IECC.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #123

Page Number: 43
Paragraph / Figure / Table / Note: 4.6.2.9
Comment Type: Technical

Comment:

The improvement cost should be standardized by region as the cost of the improvement can swing the effectiveness of the upgrade. If I get the cost of improvement from source x and someone else get them from source y, or better yet they are made up, then our ability to truly say that an energy improvement is cost affective is almost impossible.

Secondly the credibility of the calculation and the mortgage is lost. Why would a lender loan money if they knew that the cost of upgrades is randomly generated for each mortgage?

A source for regional cost of upgrades maintained on a quarterly basis would give consistency and credibility to the process. If this does not seem practical then a standardized process for capturing the cost of improvements should be created so that all Raters are going through the same process to generate the numbers they base the improvement cost on.

Response:
Rejected. The comment states that improvement cost should be standardized. However, no reasonable method of accomplishing this very difficult goal is proposed and no change to the draft BSR/RESNET Standards 301-201x language is proposed.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #124

Page Number: Whole document
Paragraph / Figure / Table / Note: Whole document
Comment Type: General

Comment:

The Standard (RESNET PDS 301-01) must avoid proprietary terms. Both RESNET and ANSI standards development requirements state:

“… The appearance that a standard endorses any particular products, services or companies must be avoided. Therefore, it generally is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent). …”

From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements.

The Standard is full of terms explicitly naming RESNET’s proprietary procedures, lists, and organizational structures thereby requiring only RESNET products, the RESNET organizational structure or RESNET-approved individuals and organizations. Examples of terms that are proprietary include the following: “national RESNET registry”, “RESNET registration ID”, “RESNET Standing Technical Committee”, “RESNET Board of Directors”, “RESNET Energy Smart Builder”, “EnergySmart Contractor” and others.

Even common terms are defined to require RESNET, RESNET processes, or RESNET approval. For example, the terms “Builders Name”, “Community Name”, “Rating Certification”, “Software Tool”, and “Technical Committee” are all defined to require or apply only to RESNET or RESNET-approved processes, products or professionals. Because the term HERS is trademarked, any term with “HERS”, such as “HERS index” is proprietary.

Proposed Change:

Proprietary requirements and wording needs to be removed or replaced with non-proprietary text. Common terms defined to be proprietary need to be removed, redefined in generic and non-proprietary language, or not defined so that the terms revert back to their common usage.

Comment #125

Page Number: Page 6
Paragraph / Figure / Table / Note: definition of “Mortgage Industry National Home Energy Rating Standards”
Comment Type: General

Comment:

The definition of “Mortgage Industry National Home Energy Rating Systems Standards” is poorly worded. Because the definition uses the word “shall” the definition could be taken to require the whole of the Mortgage Industry National Home Rating Systems Standards” in the Standard. This is unlikely to be the intent of that definition.

Proposed Change:

~~Mortgage Industry National Home Energy Rating Standards –~~ ~~National consensus Standards promulgated by RESNET that specify the methods, procedures and practices that shall be used by entities who purport to evaluate the energy performance of homes.~~

Remove the definition of “Mortgage Industry National Home Energy Rating Systems Standards” as unnecessary since there will be a direct reference to the document. Or change the definition so that the definition does not appear to make a normative reference to the whole document.

Response:
Accepted. Since the Mortgage Industry National Home energy Rating System Standards is specified as a normative reference Standard in Section 7, the definition in Section 3 is duplicative and will be stricken in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #126

Page Number: 1 and throughout entire document
Paragraph / Figure / Table / Note: Entire Document as an example; RESNET Standard 301-CD02 Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index
Comment Type: General

Comment:

The proposed standard as written is a clear violation of both the RESNET Standards Development Policy and the ANSI Essential Requirements. The proprietary nature of the document which relies on proprietary processes using a single acceptable organization (RESNET) violates Section 3.2 of the ANSI Essential Requirements: Due process requirement for American National Standard and Section 10.16 of the RESNET Standards Development Policy and Procedures Manual which states, “it is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent).”

In addition, the use of a National RESENET Registry also violates the same sections of the previously mentioned standards development policy. There are requirements for use of the National RESNET Registry in several parts of RESNET PDS 301-01, the registry functions as a sole-source list, and is therefore unacceptable based on the RESNET and ANSI procedures.

There are currently over 200 references to HERS and 100 references to RESNET in the proposed standard. Many of these proprietary requirements make it necessary for raters to pay money to be affiliated with RESNET. For example, to be placed on their National RESNET Registry as a HERS rater, HERS provider or to get a rating certification currently require various registration and/or certification fees.

The most desirable solution would be to remove the references to RESNET and HERS, leaving generic definitions. RESNET could then use its own standard to address specifics of how to handle various proprietary items such as quality control, certifications, database tracking and any other RESNET specific requirements.

Another, less desirable, alternative would be to add the words “or equivalent” when referring to a HERS/RESNET proprietary requirement; however, this would apply only where RESNET is truly a “sole source” for the function specified in the proposed standard. In most cases RESNET is not a sole source.

Proposed Change:

The proposed standard must be changed to come into compliance with ANSI as well as RESNET requirements. The most desirable solution would be to remove the references to RESNET and HERS, leaving generic definitions. RESNET could then use its own standard to address specifics of how to handle various proprietary items such as quality control, certifications, database tracking and any other RESNET specific requirements.

Another, less desirable, alternative would be to add the words “or equivalent” throughout the document when referring to a HERS/RESNET proprietary requirement, but only when RESNET is truly a “sole source”.

Response:
Accepted with modification. All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. However, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #127

Page Number: 46
Paragraph / Figure / Table / Note: 4.6.2.2. Discount Rate (DR)
Comment Type: Technical

Comment:

NAHB policy on cost effective energy efficiency code provisions specifically requires that the simple payback period to the home buyer not exceed 10 years. Because this is equivalent to a discount rate of 10 percent over an infinite horizon, NAHB considers it unreasonable to use a discount rate of less than 10 percent in a life cycle cost analysis of housing, especially if discounting over an analysis period that substantially exceeds the time most buyers remain in their homes—roughly 12 years, according to NAHB analysis of American Housing Survey data(“How Long Buyers Remain in Their Homes” http://www.nahb.org/generic.aspx?sectionID=734&genericContentID=110770&channelID=311).

This 10 percent discount rate is based on the longest relevant payback period that can be found in an NAHB home buyer preference survey:

How much extra would you pay up front, in the purchase price for your next home, if it would save $1,000 every year in utility costs?

	Household Income
	Less than $30,000	$30,000 to $49,999	$50,000 to $99,999	$100,000 to $149,999	$150,000 or more
	Less than $30,000	$30,000 to $49,999	$50,000 to $99,999	$100,000 to $149,999	$150,000 or more
Mean	$7,528	$8,419	$9,156	$9,303	$10,142
Median	$5,000	$5,000	$5,000	$6,000	$5,000
Responses	259	366	1,040	383	206

	Price Expect to Pay
	Less than $150,000	$150,000 to $249,999	$250,000 to $499,999	$500,000 to $999,999	$1 million or more
	Less than $150,000	$150,000 to $249,999	$250,000 to $499,999	$500,000 to $999,999	$1 million or more
Mean	$8,274	$7,675	$9,964	$10,568	$16,662
Median	$5,000	$5,000	$5,000	$6,000	$10,000
Responses	542	619	719	211	37

	Homes Owned
	None	One	Two or more
	None	One	Two or more
Mean	$10,081	$9,506	$8,308
Median	$5,000	$5,000	$5,000
Responses	283	816	1,155
Source: NAHB 2007 Consumer Preference Survey

The table shows that the required payback period generally rises with income and price of the home purchased a result broadly consistent with the literature on implicit discount rates (Electric Power Research Institute, Implicit Discount Rates in Residential Customer Choices Volume 1: Investments in Conservation Measures.) The mean payback period required by home buyers does not reach 10 years until buyers have at least $150,000 in income, or are purchasing homes price at $500,000 or above. This category does not in general represent the marginal, first-time buyer. However, the table also shows an average payback period of 10 years for buyers who have not yet owned a home, although this is actually higher than the payback period for previous owners. This relatively high, 10-year payback for first-time buyers is an anomalous result that is not confirmed by any of our other surveys. In other words, a discount rate of 10 percent is as low as we can possibly justify, stretching NAHB survey results as far as possible.

Evidence that a discount rate of at least 10 percent is appropriate is also available from other sources. For units that are rented, the last Residential Finance Survey conducted by the Census Bureau (http://www.census.gov/prod/2005pubs/censr-27.pdf) shows that the median return owners were realizing on rental properties was 11 percent of the property’s value for single-family and 2-4 unit properties, and somewhat higher for properties with at least five units. This implies that investors in residential property typically require a return of 11 percent or more or they will put their money elsewhere and the new energy efficient buildings will not get built.

For owner-occupied properties, the Federal Reserve Board’s 2007 Survey of Consumer Finances shows that well over half of homeowners (59 percent) carry a positive balance on credit cards on which they on average pay an interest rate of 13.26 percent. Because these owners have an option to pay off credit card balances, this implies that the implicit discount rate for typical homeowners is at least as high as 13 percent.

Proposed Change:

shall be equal to the General Inflation Rate plus 2% 10%.

Response:
Rejected. The committee believes that the provisions of Section 4.6.2.2 for the Discount Rate are very reasonable considering the relative low risk of investment in home ownership. A real discount rate of 2% over inflation is consistent with the historical behavior of long-term U.S. Treasury bonds, which represent similar low financial risk. A discount rate that is back-calculated from a simple payback period of 10 years badly misrepresents the value of energy investments in homes likely to remain in the market for 80 to 100 years.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #128

Page Number: Whole document
Paragraph / Figure / Table / Note: Whole document
Comment Type: General

Comment:

HERS^® is a registered trademark of RESNET. The term “HERS” is used more that 150 times in the Standard (RESNET PDS 301-01).

A registered trademark is a commercial term and violates both RESNET and ANSI consensus standard development guidelines. Both RESNET and ANSI state:

“In connection with standards that relate to the determination of whether products or services conform to one or more standards, the process or criteria for determining conformity can be standardized as long as the description of the process or criteria is limited to technical and engineering concerns and does not include what would otherwise be a commercial term.”

From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements:?Due process requirements for American National Standards.

RESNET attempted to trademark the term HERS in 2007. The term HERS was in common use prior to that date, so it is unlikely RESNET's trademark would stand.

Proposed Change:

2 ~~HERS® is a registered U.S. Trademark of Residential Energy Services Network, Inc.~~

This is note 2 on page 4 of the Standard.

Use a generic term that is not trademarked rather than “HERS” throughout the Standard. Or release the trademark on the term “HERS”.

Response:
Rejected. There is no substantive reason that RESNET should relinquish the trademark on HERS. The Committee does not agree that HERS is a commercial term. The ANSI Essential Requirements define commercial terms as “Provisions involving business relations between buyer and seller such as guarantees, warranties, and other commercial terms and conditions shall not be included in an American National Standard.” The term HERS does not imply a “business relation between buyer and seller.” The commentator has used a general definition of the word “term” meaning terminology while the ANSI Essential Requirements clearly defines “term” as a business relationship such as “terms” of a contract between buyer and seller. ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #129

Page Number: 46
Paragraph / Figure / Table / Note: 4.6.2.8. Remaining Life Fraction (RLFrac)
Comment Type: Technical

Comment:

At the long end, improvements to the thermal envelope are generally assumed to last the life of the home, which could be 100 years and lead to a very large salvage value and offset to the cost, the proposed standard is applied as published without modification. In fact in this case, Eq 4.6-10 would imply that the improvement has more than 100 percent of its useful life left at the end of the analysis period, probably.

Proposed Change:

4.6.2.8. Remaining Life Fraction (RLFrac) shall be calculated as follows:

RLFrac = (nAP/Life) – (Integer (nAP/Life)) (Eq 4.6-10)

or if Life > nAP

RLFrac = (Life-nAP) / ~~nAP~~ Life

where:

Life = useful service life of the improvement(s)

Response:
Rejected. The Remaining Life Fraction is defined in Section 4.6.1 under Eq. 4.6-8d as the Remaining Life Fraction following the end of the analysis period (nAP). As a result, the calculation provided in Section 4.6.2.8 is correct

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #130

Page Number: as example page 21 an throughout the whole document
Paragraph / Figure / Table / Note: as an example; section 4.2.2.2.1 refers to RESNET insulation inspection. This occurs throughout the whole document.
Comment Type: General

Comment:

The first sentence in the Standard (RESNET PDS 301-01) states

“1. Purpose. The provisions of this document are intended to establish national residential energy rating and labeling Standards, …. “

Many proprietary parts of the Standard are added by normative (mandatory) reference to the Mortgage Industry National Home Energy Rating Systems Standard.

“ … The appearance that a standard endorses any particular products, services or companies shall be avoided. Therefore, it is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent). … In connection with standards that relate to the determination of whether products or services conform to one or more standards, the process or criteria for determining conformity can be standardized as long as the description of the process or criteria is limited to technical and engineering concerns and does not include what would otherwise be a commercial term.”

Proposed Change:

Response:
Accepted with modification. (Identical to comment #117.) All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. However, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #131

The Standard (RESNET PDS 301-01) must avoid proprietary terms. Both RESNET and ANSI standards development requirements state:

From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements.

Proposed Change:

Response:
Accepted with modification. (Identical to comment #135.) All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. However, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #132

Page Number: Page 6
Paragraph / Figure / Table / Note: definition of “Mortgage Industry National Home Energy Rating Standards”
Comment Type: General

Comment:

Proposed Change:

Response:
Accepted. (Duplication of comment #125.) Since the Mortgage Industry National Home Energy Rating Systems Standards is specified as a normative reference Standard in Section 7, the definition in Section 3 is duplicative and will be stricken in the final committee draft of BSR/RESNET Standard 301-201x.

Comment #133

Page Number: 9
Comment Type: General

Comment:

Primary Energy Performance Methodology

(Please refer to comment # 113 for technical considerations)

The current normalized modified loads method (NMLM) rewards best efforts and accounts for technology limitations, while acknowledging, at least for heating, the poor energy efficiency and cost of resistance heating. However, if the goal of the Home Energy Rating System (HERS) is to equitably rate the impact of home energy use on primary energy resource consumption, HERS should adopt a primary energy performance methodology.

Site measurement methods calculate the energy consumed by an appliance at the end-use point (in the home) and do not properly account for the total energy consumed when more than one energy source is used in an appliance (such as a gas furnace) or when comparing the consumption of different fuels that can be used for the same application (such as water heating or combined heat and power). In addition, site measurement does not account for the energy lost and emissions created throughout the extraction, processing, transportation, conversion, and distribution of energy to the home. Source (full-fuel-cycle) measurement of the energy consumption of appliances and the overall building from the point of extraction to the point of use does account for energy losses that occur (e.g., in the production of natural gas or in the generation of electricity).

Furthermore, a unit of primary and a unit of secondary energy consumed at the site are not directly comparable because one represents a raw fuel while the other represents a converted fuel. When primary energy is consumed on site, the conversion to source energy must account for losses that are incurred in the storage, transport and delivery of fuel to the building. When secondary energy is consumed on site, the conversion must account for losses incurred in the production, transmission, and delivery to the site. Therefore, in order to assess the relative efficiencies of buildings with varying proportions of primary and secondary energy consumption, it is necessary to convert these two types of energy into equivalent units of raw fuel consumed to generate that one unit of energy consumed on-site. To achieve this equivalency, a full fuel cycle methodology should be used.

Focusing on site energy efficiency alone without consideration of upstream energy consumption and emissions perversely incentivizes the decision maker to choose the less expensive “efficient” technology. The consequence of using a site-based metric is to promote fuel switching in the design decision away from more full-fuel-cycle energy efficient and lower greenhouse gas emitting technologies toward more site energy efficient technologies. Codes, standards, regulations, voluntary initiatives, and incentive programs that focus on site energy create and maintain an unfair and unearned market advantage to qualifying technologies such as electric resistance heating and water heating that are lower initial cost, but that have higher operating cost, lower full-fuel-cycle efficiency and higher GHG emissions. To promote energy efficiency and lower greenhouse gas emissions, a full fuel cycle metric should be used. This is a key reason source energy-based criteria are used by several private and public sector stakeholders, including RESNET.

Moreover, the Department of Energy (DOE) issued a Statement of Policy on August 18, 2011 announcing its plans to adopt full-fuel-cycle analyses into their Energy Conservation Standards Program, based on recommendations to that effect by The National Academies (of Science, of Engineering, Institute of Medicine and the National Research Council). DOE intends to use source-based measures of energy use and emissions, rather than site energy measures. This more accurate full-fuel-cycle measurement will provide consumers with more complete information on energy use and environmental impacts. For this reason, the EPA uses source energy in calculating the ENERGY STAR performance rating for buildings, designed to improve building efficiency and reduce carbon emissions nationally.

Existing and developing codes reject site-based energy metrics in favor of full-fuel-cycle energy metrics. Such reliance on site-based energy metrics is contrary to LEED O&M, IgCC, DOE’s stated policy, and even ASHRAE’s bEQ. At present, the IgCC represents the more comprehensive implementation of full fuel-cycle analyses. However, LEED O&M and bEQ, which incorporate EPA’s Portfolio Manager, are also moving in the right direction.

The primary energy performance methodology provides equitable treatment of all energy consuming technologies based on their primary energy impact, not their site energy impact (or normalized modified site energy load impact). Primary energy methodologies are easily implemented and are widely used both in the United States and internationally.

Proposed Change:

HERS should adopt a primary energy performance methodology instead of the current normalized modified loads method for evaulting end use loads.

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #134

Page Number: See below
Paragraph / Figure / Table / Note: See below
Comment Type: General

Comment:

The following references/web-based files were not in the locations named in the Standard (RESNET PDS 301-01). The Standard should be updated with their correct location. Some references are informative instead of normative and the standard should clearly differentiate between normative and informative references. These changes are required by the RESNET standards development document in Sections “Normative Standard”, “Normative References”, and “Informative References”.

The references below are from the Standard:

Note 9:

http://www.energy.ca.gov/appliances/database/excel_based_files/

Page 31: http://www.energy.ca.gov/appliances/database/excel_based_files/Clothes_Washers/

Note 24:

Source: Parker, D S, J E R McIlvaine, S F Barkaszi, D J Beal and M T Anello (2000). Laboratory Testing of the Reflectance Properties of Roofing Material. FSEC-CR670-00. Florida Solar Energy Center, Cocoa, FL. Available online at: http://www.fsec.ucf.edu/bldg/pubs/cr670/

Note 33:

Fairey, P., D.S. Parker, B. Wilcox and M. Lombardi, "Climate Impacts on Heating Seasonal Performance Factor (HSPF) and Seasonal Energy Efficiency Ratio (SEER) for Air Source Heat Pumps." ASHRAE Transactions, American Society of Heating, Refrigerating and Air Conditioning Engineers, Inc., Atlanta, GA, June 2004. (Also available online at http://www.fsec.ucf.edu/bldg/pubs/hspf/)

Note 35:

See http://www.eere.energy.gov/buildings/building_america/benchmark_def.html

3. California Measurement Advisory Council (CALMAC): CALMAC Protocols. “Appendix F: Effective Useful Life Values for Major Energy Efficiency Measures.” 1994-2007. http://www.calmac.org/events/APX _F.pdf May 10, 2012

Note 36:

NREL, “Building America Research Benchmark Definition.” National Renewable Energy Laboratory, Golden, CO, December 29, 2004. May be found online at: http://www.eere.energy.gov/buildings/building_america/pa_resources.html

Proposed Change:

Give the proper version of the Mortgage Industry National Home Energy Rating Systems Standards a version and date. Do not include “2006” in the name of the proper version. Refer to the proper version of the Mortgage Industry National Home Energy Rating Systems Standards in the Standard. Place information on where to acquire the correctly referenced document in the Standard.

Remove the word “consensus” from the second page of the referenced version of the Mortgage Industry National Home Energy Rating Systems Standards, as that document does not meet RESNET or ANSI consensus standard requirements.

Response:
Accepted. The proper location of the files and documents used in BSR/RESNET Standard 301-201x will be identified and listed. Informative references will be identified separately from normative references. The word consensus will be removed from the referenced version of the Mortgage Industry National Home Energy Rating Systems Standards.

Comment #135

Page Number: Page 9
Paragraph / Figure / Table / Note: As an example section 4.1. Determining the HERS Index and throughout the document
Comment Type: General

Comment:

The Standard (RESNET PDS 301-01) must avoid proprietary terms. Both RESNET and ANSI standards development requirements state:

From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements.

Proposed Change:

Response:
Accepted with modification. (Identical to comment #131.) All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. However, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #136

Page Number: 7, 8, 50, 51
Paragraph / Figure / Table / Note: definitions of ”Rating Certification”, “Rating Provider”, “Sampled Rating” Sections 5.1.4.2, 5.1.4.1.1, 5.1.4.2.1
Comment Type: General

Comment:

References in the Standard (RESNET PDS 301-01) include many commercial terms and conditions, which is contrary to RESNET and ANSI guidelines.

Section 900 (Chapter 9) of the Mortgage Industry National Home Energy Rating Systems Standards is a normative (mandatory) reference of the standard in the definition of “Rating Certification”, Section 5.1.4.1.1, and Section 5.1.4.2.1. The stated purpose of Chapter 9 of the is Mortgage Industry National Home Energy Rating Systems Standards is:

“901.1 Purpose. RESNET has the responsibility of accrediting Providers. This chapter outlines the quality assurance responsibilities of RESNET and Providers , the role and responsibility of the Quality Assurance and Ethics Committee, the role and responsibility of the Accreditation Committee, the RESNET Accreditation Process for all Providers, the RESNET policies and procedures for Probation, Suspension and Revocation of Provider Accreditation, and the Appeals process for each of these disciplinary actions.”

The requirement of Section 900 of the Mortgage Industry National Home Energy Rating Systems Standards is in conflict with the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements:?Due process requirements for American National Standards. Normative references to Section 900 should be removed from the Standard.

Section 600 (Chapter 6) of the Mortgage Industry National Home Energy Rating Systems Standards is a normative (mandatory) reference of the Standard in the definition of “Rating Provider”, the definition of “Sampled Rating”, and Section 5.1.4.2.

Elements of Section 600 of the Mortgage Industry National Home Energy Rating Systems Standards are commercial terms and conditions. Section 601.2 specifies warranties and liabilities to be assumed by “Sampling Providers”. Section 604.1.4 specifies an amount of insurance coverage for providers who are themselves regulated by RESNET. 604.1.5 applies criteria based on the builder’s financial interests. “Sampling Providers” are required to be associated with RESNET by definition. There are several references to section 900 in Section 600, with Section 900 specifying how RESNET will regulate the “Sampling Providers”.

Proposed Change:

Remove or revise normative references to the requirements of Section 900 and the proprietary parts of Section 600 of the Mortgage Industry National Home Energy Rating Systems Standards that are in conflict with the “Commercial Terms and Conditions” Section of RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements. To the extent normative references are retained to the Mortgage Industry National Home Energy Rating Systems Standards they should also be explicitly made part of the public review process.

Response:
Accepted with modification. (Identical to comment #146.) All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. However, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #137

Page Number: various
Comment Type: General

Comment:

Single Gas Reference

(Please refer to comment # 114 for technical considerations)

PDS 301-01 currently uses multiple reference mechanical systems, depending on fuel type, for heating and service water heating (but not cooling). These systems have varying annual primary energy consumption, energy cost, and pollutant emissions, and are thus not equivalent. Instead of this mix of equivalencies, HERS should shift to a single reference design for all rated home design alternatives. The current HERS Index and energy savings methodology rewards electric heating and service water heating technology options and penalizes other heating and water heater options, including natural gas, in spite of their advantageous energy and environmental performance. This constraint eliminates the credit for creative design choices that would significantly reduce energy cost, energy use, and pollutant emissions.

Natural gas is the cleanest, safest, and most useful of all fossil fuels. The inherent cleanliness of natural gas compared to other fossil fuels, as well strong domestic supply projections and superior wells-to-wheels efficiency of natural gas equipment, means that substituting gas for the other fuels will reduce the emissions of the air pollutants that produce smog, acid rain and exacerbate the "greenhouse" effect. Natural gas is the lowest CO2 emission source per BTU delivered of any fossil fuel. Using gas-fired appliances for homes instead of electric ultimately reduces greenhouse gas emissions by one-half to two thirds. Simply put, increasing the direct-use of natural gas is the surest, quickest, and most cost-effective avenue to achieve significant reductions in greenhouse gases and therefore should be a critical component of any energy efficiency standards.

A single technology-blind baseline would provide an equitable credit to all technologies that have lower annual primary energy consumption compared to the single baseline level irrespective of energy form or technology design. It would promote better consumer choices by establishing fixed reference home performance requirements prior to making the technology and energy choices for the rated home

A single reference design would apply consistently to all technology and energy options without prohibiting any technology or energy choice. At the same time, a designer choosing to put in a higher efficiency heat pump water heater would get a reasonably equivalent energy performance to the baseline gas water heater, preventing unintended backsliding in the envelope or other mechanical system efficiencies. Higher cost, higher efficiency options such as gas tankless and condensing water heaters would get earned credit, allowing the designer to further improve the rating of the home or implement tradeoffs, thereby encouraging rather than discouraging their installation.

A single reference design methodology would create an even playing field for all technology and energy forms and provides equitable treatment of advanced renewable, waste heat recovery, hybrid, and multi-fuel technology options. Furthermore, such a methodology will improve the adoptability of PDS 301-01 by ensuring transparency and equity for all technologies and eliminating confusion at jurisdictional levels.

Proposed Change:

HERS should shift to a single reference design for all rated home design alternatives.

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #138

Page Number: Pages 6, 7, 56, 58, 59, Annex B, Annex I.
Paragraph / Figure / Table / Note: definition “New Home Tax Credit Reference”, definition “Qualifying Home”, Section 6.1.2, Section 6.3.2, Annex B, Annex I.
Comment Type: Technical

Comment:

Why does the Standard (RESNET PDS 301-01) have Tax Credit sections for a tax credit that is no longer available? A future tax for especially efficient residences may be different. Remove the old tax credit.

Proposed Change:

Delete the sections dealing only with tax credits, including the definition, Section 6.1.2, Section 6.3.2, and Annex B.

~~New Home Tax Credit Reference~~ – The hypothetical home model that is the basis of comparison for new homes seeking to qualify for the federal tax credit for highly efficient new homes. The New Home Tax Credit Reference has the same geometry and gross areas as the Qualifying Home with component and equipment efficiencies as prescribed by the U.S. Congress in the law(s) governing the Tax Credit.

~~Qualifying Home~~ – The actual, as-built home seeking to qualify for the federal tax credit for highly efficient new homes that has been field-verified to assure that all minimum rated features of the home have been installed as specified.

~~6.1.2. New Home Tax Credit Software Tools.~~ This software tool accreditation category shall apply to all software used to qualify new homes for the Federal tax credit for highly efficient new homes. Calculation procedures used to comply with this Standard shall be computer-based software tools capable of calculating the annual energy consumption of all building elements that differ between the Tax Credit Reference Home and the Qualifying Home and shall include the following capabilities:

~~6.1.2.1.~~ ~~Compliance with all provisions of the IRS Notice pertaining to qualification for the Federal Tax Credit.~~

~~6.1.2.2.~~ Automated computer generation of the Tax Credit Reference Home using only the input for the Qualifying Home. The software tool shall not allow the user to directly modify the building component characteristics of the Tax Credit Reference Home.

~~6.1.2.3.~~ ~~HVAC system sizing and annual purchased energy consumption calculations in accordance with sections 4.3 and 4.4 of this Standard.~~

~~6.1.2.4.~~ ~~Computer generation of all verification reports required by the IRS Notice pertaining to qualification for the Federal Tax Credit.~~

~~6.3.2. New Home Tax Credit Reference Home AutoGen.~~ These tests verify the ability of the software tool to automatically generate the New Home Tax Credit Reference given only the characteristics of the Qualifying Home. See normative Annex B for the test cases and for the established acceptance criteria for this auto-generation test suite.

~~Annex B~~

~~Annex I~~

Response:
Accepted. The entire Section 6 and Annex A-I are being withdrawn from the final Committee draft of BSR/RESNET Standard 301-201x

Comment #139

Page Number: 9
Paragraph / Figure / Table / Note: Section 3
Comment Type: Technical

Comment:

The International Window Film Association (IWFA) would like to submit the following comment to include window films in the RESNET 301 Standard. Window films are a common, cost-effective and valuable part of residential retrofit technology.

Window film should be defined in this section.

Proposed Change:

Window Film – fenestration attachment products which consist of a flexible adhesive-backed polymer film which may be applied to the interior or exterior surface of an existing glazing system.

Response:
Accepted. The proposed change will be included in the final Committee draft of BSR/RESNET Standard 301-201x.

Comment #140

Page Number: Pages 10, 11, 54, 66 and 67
Paragraph / Figure / Table / Note: Sections 4.1.1, 4.1.2 and 5.3.1.2. Sections 2.1 and 2.2 in Annex B.
Comment Type: Technical

Comment:

The Standard (RESNET PDS 301-01) uses the “Normalized Modified End Use Loads” calculations in computing the HERS index. The calculations are as confusing as their name. The “Normalized Modified End Use Loads” (NMEUL) deviate from energy calculations, complicate the Standard, are difficult to understand, need adjustment over time, and impede using the HERS score for IECC compliance. The NMEUL should be removed from the Standard, with the HERS score based on energy cost as is done in the IECC.

The NMELU “adjusts” the energy calculation such that an energy $1 for heating, is different from an energy $1 for cooling, which is different from an energy $1 for water heating. To the consumer a $1 is a $1.

There is no evidence the NMEUL makes the HERS index a better predictor of energy use. One study of several energy-efficiency analysis methods admits “A disadvantage of the HERS Index is that the ‘scoring method’ used by the rule set does not use energy use as the metric.” That method “was derived as a compromise consensus method of avoiding the fight between site energy use and source energy use”¹ and was intended to avoid contention “in the form of the ongoing ‘fuel wars’ between the electric and gas industries”².

A better way to avoid “fuel wars” is to follow the IECC. The IECC performance calculation is based on energy cost. Using the IECC approach has the additional advantage of helping align the HERS index with the IECC for those who want to use a HERS score, or a range of HERS scores, as an alternative performance calculation to show compliance with the IECC. The author of this comment presumes the equipment efficiency in the 2006 IECC performance calculation (but not the 2009 or 2012 IECC) will be restored in the 2015 IECC and further align HERS scores and IECC compliance.

Energy Star provides further evidence that the HERS rating with the NMEUL is too variable to use in a performance calculation. In its latest version Energy Star Qualified Homes does not give a specific HERS score that is equivalent to Energy Star, rather it requires the rating to be recomputed to set a new based for each home.^{3, 4}

It is confusing to follow the NMEUL. The referenced paper “explaining” the NMEUL is not at the location named in the Standard.⁵ However the paper can be found online.⁶ The paper discuss the evolution of the NMEUL, but this paper referenced by the Standard has different numbers (coefficients) than the Standard⁷.

The difference between the Standard’s referenced paper and the values in the Standard highlights another disadvantage of the NMEUL. The NMEUL changes over time. Therefore, the HERS score for a particular building will also change over time. When the range of available equipment efficiency changes or the minimum Federal equipment efficiency requirements change, the calculation changes and the HERS score may change. Apparently the Mortgage Industry National Home Energy Rating Systems Standards’ NMEUL calculation was changed in about 2006, which is why the values in the Standard don’t match the paper cited in the Standard. Now we are in the year 2012 and the available equipment efficiencies have improved, even worse (better?) the minimum Federal equipment efficiency for furnaces and air conditioners will change in 2013. So the NMEUL in the Standard is due for another update and that update should happen in this version of the Standard to be ready in 2013. That update that will change how the Standard calculates Hers scores. Further complicating the problem, the NMEUL will have to deal with the new minimum Federal furnace efficiencies and air conditioner efficiencies that as of 2013 vary with region. So either the Standard needs to be changed to reflect the new NMEUL calculation, or the NMEUL calculation can be eliminated as a confusing part of the HERS index. Better not to set up a Standard that yields a moving HERS score as it changes over time.

“HERS index” is defined in the Standard as “… representing the relative energy use of a Rated Home as compared with the energy use of the HERS Reference Home … ”. Including the NMELU makes that statement about “energy” less than true. The HERS index should not claim to be an energy-based rating unless it does an energy or energy-cost calculation. Although perhaps stating the obvious, HERS stands for Home ENERGY Rating System. Lets put the “Energy” back in HERS by eliminating the confusing NMEUL.

1. Philip Fairey, P., C. Colon, E Martin, and S. Chandra, “Comparing Apples, Oranges and Grapefruit: “An Analysis of Current Building Energy Analysis Standards for Building America, Home Energy Ratings and the 2006 International Energy Conservation Code.”

FSEC-CR-1650-06, Florida Solar Energy Center, Cocoa, FL, September 2006.

2. Fairey, P., J. Tait, D. Goldstein, D. Tracey, M. Holtz, and R. Judkoff, "The HERS Rating Method and the Derivation of the Normalized Modified Loads Method." Research Report No. FSEC-RR-54-00, Florida Solar Energy Center, Cocoa, FL, October 11, 2000.

3. “ENERGY STAR Qualified Homes, Version 3 (Rev. 06) National Program Requirements”

http://www.energystar.gov/ia/partners/bldrs_lenders_raters/ES_Combined_Path_v_65_clean_508.pdf?42dd-e750

4. “ENERGY STAR Qualified Homes, Version 3 (Rev. 06) HERS Index Target Procedure?for National Program Requirements”

http://www.energystar.gov/ia/partners/bldrs_lenders_raters/downloads/ES_HERS_Index_Target_Procedure_v23_clean_508.pdf

5. "The HERS Rating Method and the Derivation of the Normalized Modified Loads Method." is not available online at location given by Standard: http://www.fsec.ucf.edu/bldg/pubs/hers_meth/

6. However the "The HERS Rating Method and the Derivation of the Normalized Modified Loads Method" is at: http://www.fsec.ucf.edu/en/publications/html/FSEC-RR-54-00/index.htm

as noted on the HERS web site.

7. Page 10, Table 4.2.1(1) titled “Coefficients ‘a’ and ‘b’ ”. Also Page 67, Table 2.1. titled “Coefficients ‘a’ and ‘b’ ”.

Proposed Change:

Modify Sections 4.1.1 and 4.1.2, pages 10 and 11 to eliminate NMEUL. Modify Sections 2.1 and 2.2, Annex B, pages 66 and 67 to eliminate NMEUL. Calculate the HERS scores based on energy cost, as is specified in the IECC. Eliminate the requirement to keep the NMEUL in the national HERS registry in Section 5.3.1.2, page 54.

Response:
Rejected. While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #141

Page Number: 48
Paragraph / Figure / Table / Note: 4.1.2
Comment Type: Technical

Comment:

5.1.2 Savings Estimates

Thank you for including standard section 5.1.2.1.1 that requires all Raters to go to the EIA to get utility cost information. At least that is house I am reading this section.

I believe that this should be included as well as a Minimum Rated Feature to ensure that all Raters get the utility rates from the same source for their state. In addition, the standard should require that Raters update their utility rates based on the EIA data at a minimum on a quarterly basis. It should be clear in the standard how the EIA data works because Raters might not read the fine print that says the published rates are a state wide average that includes all fees and service charges.

This is very important as Raters are getting the utility rates from all kinds of sources and the estimated energy cost calculations for houses in the same market are wildly different based on this utility data. Again to continue to make the HERS Index and process more main stream these kinds of differences that show up on reports that are controllable based on the standard, should be implemented.

Response:
Noted. The comment does not propose any change to the draft BSR/RESNET Standard 301-201x.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #142

Page Number: Page 33
Paragraph / Figure / Table / Note: Section 4.3.3.2.6 Windows
Comment Type: Technical

Comment:

Include in this section how to determine the properties of windows with window film installed.

Proposed Change:

Windows shall include observed blinds/draperies. For new homes, all windows shall assume blinds/draperies that are positioned in a manner that gives an Internal Shade Coefficient (ISC) of 0.70 in the summer and an ISC of 0.85 in the winter. (These values are represented in ACCA Manual J Eighth Edition as “dark closed blinds” in the summer and “dark fully drawn roller shades” in the winter.) For existing windows with window film, the NFRC rated value shall be used for U-value (NFRC 100 -2010), solar heat gain coefficient and visible transmittance (NFRC 200-2010).

Response:

Rejected. It's unclear how the NFRC rated value of an existing window with window film would be known or determined. Therefore, the proposed change will not improve the standard..

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #143

Page Number: Page 2, Page 6, Page 7,Page 8, Page 16, Page 21, Page 50, Page 51, Page 53, Page 50, Page 74, Page 102, Annex X, Note 1
Paragraph / Figure / Table / Note: definitions
Comment Type: General

Comment:

Page numbers: Page 2, definition of “Conditioned floor area”, Page 6, definition of “Mortgage Industry National Home Energy Rating Standards” Page 7, definition of “Rating Provider” Page 8, definition of “Sampled Rating” Page 16, Table 4.2.2(1) “e” Page 21, Sections 4.2.2.2 and 4.2.2.2.1 Page 50, Section 5.1.4.1.1 Page 51, Sections 5.1.4.2 and 5.1.4.2.1 Page 53, Section 5.2.2.2.7 Page 50, “Normative Reference Documents” Page 74, Table 3.2(1), note “(m)” Page 102, Annex X, Note 1

Sections: definitions of “Conditioned floor area”, “Mortgage Industry National Home Energy Rating Standards”, “Rating Certification”, “Rating Provider”, “Sampled Rating” Table 4.2.2(1) “e” Sections 4.2.2.2, 4.2.2.2.1, 5.1.4.1.1, 5.1.4.2, 5.1.4.2.1, 5.2.2.2.7 Page 50, “Normative Reference Documents” Page 74, Table 3.2(1), note “(m)” Annex X, Note 1

The Standard’s (RESNET PDS 301-01) references to the 2006 Mortgage Industry National Home Energy Rating Systems Standards are inconsistent with the RESNET consensus standard requirements. Many different versions with the same title are in circulation. The version to be referenced is not identified in the Standard.

The Standard makes multiple normative (mandatory) references to the 2006 Mortgage Industry National Home Energy Rating Systems Standards. The Standard incorporates large parts of the 2006 Mortgage Industry National Home Energy Rating Systems Standards by reference including Sections 600 and 900, parts of Appendix A, and the definitions in Appendix B. Many different versions of the 2006 Mortgage Industry National Home Energy Rating Systems Standards, all named “2006” are in circulation.

It is worth noting that the name of the “Mortgage Industry National Home Energy Rating Systems Standards” is used inconsistently in the Standard. Sometimes the word “Systems” is included, sometimes the word “Systems” is not included.

No date or version number is given for the “2006 Mortgage Industry National Home Energy Rating Systems Standards” in the Standard. The “2006” in the title does not establish a year or date, with most versions were produced after the year 2006. There appears to be at least one version for each year since 2006. Some years, such as the year 2012, may to have 2 versions. None of these versions say “draft” or anything similar. The Standard does not refer to the location of the proper version.

Many interested parties may have documents with the correct name (2006 Mortgage Industry National Home Energy Rating Systems Standards) and may incorrectly conclude that they have a correct version. For example the author of this comment had a version that was probably produced in 2007 on his computer. The RESNET web site includes one version probably from the year 2009 at http://www.resnet.us/standards/RESNET_Standards-2006.pdf

Some affiliated with RESNET have pre-2012 versions on their web site. For example:

http://virginiahomeperformance.com/yahoo_site_admin/assets/docs/RESNET_Mortgage_Industry_National_HERS_Standards.185174259.pdf

with a version probably from 2009

http://www.nrglogic.com/articles/RESNET_Standards-2006.pdf

has a version that is probably from 2005.

Some versions of the 2006 Mortgage Industry National Home Energy Rating Systems Standards even appear to reference older versions of themselves. In the definition of “Industry Accepted Standards for Chapter 10” on page B-14, the reference is to “Mortgage Industry National Home Energy Rating Standard, 2009”. The Standard apparently references an earlier version of itself in informative Annex X, note 1 “Mortgage Industry National Home Energy Rating Systems Standards, March 2, 2012”.

RESNET requires dated versions of normative references be specified along with the location to obtain those specific versions. Therefore the main normative reference document in the Standard is not compliant with RESNET states the following in the section on “Normative References”:

“Reference documents included in the normative section shall include a specific version with a date. Information on where to acquire the referenced document shall be included in the standard. ...”

RESNET should put out a notice that multiple different non-draft documents were given the name “2006 Mortgage Industry National Home Energy Rating Systems Standards”, even though the documents were different. To clear up potential confusion, the referenced version should be identified on the RESNET web page, by email to any who downloaded or commented on the RESNET Standards web page, and by email to those who received the RESNET email with the subject “RESNET is Seeking Public Comments on Proposed Standard on Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index (PDS 301-01)”.

RESNET should also contact those who have used, or attempted to use, the Mortgage Industry National Home Energy Rating Systems Standards as part of their local regulations and make sure their reference is clear, including letting them know there are multiple documents with the same name. For example, New Mexico used an imprecise name, “chapter 6 of the national standard for home energy ratings” (14.7.6.12 A (3) (b)). Another example, is a Kansas form that references a July 1 2006 version.

http://www.kcc.state.ks.us/energy/energy_efficiency_disclosure.pdf

Parts of the Mortgage Industry National Home Energy Rating Systems Standards that remain a normative (mandatory) reference in the Standard should be clearly identified and included as part of the consensus public review with adequate time provided for comment.

Proposed Change:

Response:
Accepted. Since the Mortgage Industry National Home Energy Rating Systems Standards is specified as a normative reference Standard in Section 7, the definition in Section 3 is duplicative and will be stricken in the final committee draft of BSR/RESNET Standard 301-201x. References to this standard will be made consistent throughout the Standard and the reference in Section 7 will be updated to provide the corrected title and specific date. The word consensus will be removed from the referenced version of the Mortgage Industry National Home Energy Rating Systems Standards.

Comment #144

Page Number: Page 36
Paragraph / Figure / Table / Note: Table 4.4.2(1) Minimum Rated Features
Comment Type: Technical

Comment:

Add window film to entry 6 in the table.

Proposed Change:

6. Windows and Window Films

Construction type, orientation, U-value (of complete assembly), solar heat gain coefficient, shading.

Response:
Rejected. The proposed change is not warranted as the complete fenestration assembly is already specified by the right-hand column of the table.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #145

Page Number: Note 9, Page 31, Note 24, Note 33, Note 35, Note 36
Paragraph / Figure / Table / Note: See Below
Comment Type: Technical

Comment:

The references below are from the Standard:

Note 9:

http://www.energy.ca.gov/appliances/database/excel_based_files/

Page 31: http://www.energy.ca.gov/appliances/database/excel_based_files/Clothes_Washers/

Note 24:

Note 33:

Note 35:

See http://www.eere.energy.gov/buildings/building_america/benchmark_def.html

Note 36:

Proposed Change:

Correct the locations for the references. Clearly note which references which are informative and which references are normative.

Response:
Accepted. (Duplication of comment #134.) The proper location of the files and documents used in BSR/RESNET Standard 301-201x will be identified and listed. Informative references will be identified separately from normative references. The word consensus will be removed from the referenced version of the Mortgage Industry National Home Energy Rating Systems Standards.

Comment #146

References in the Standard (RESNET PDS 301-01) include many commercial terms and conditions, which is contrary to RESNET and ANSI guidelines.

Proposed Change:

Response:
Accepted with modification. (Identical to comment #136.) All objectionable references to proprietary products, systems, programs or commercial entities will be removed from BSR/RESNET Standard 301-201x. However, ANSI Essential Requirements allows the use of a sole source for essential services necessary to comply with or to determine compliance with BSR/RESNET Standard 301-201x and where that situation occurs, BSR/RESNET Standard 301-201x will incorporate such sources.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #147

Proposed Change:

Delete the sections dealing only with tax credits, including the definition, Section 6.1.2, Section 6.3.2, and Annex B.

~~6.1.2.1.~~ ~~Compliance with all provisions of the IRS Notice pertaining to qualification for the Federal Tax Credit.~~

~~6.1.2.3.~~ ~~HVAC system sizing and annual purchased energy consumption calculations in accordance with sections 4.3 and 4.4 of this Standard.~~

~~6.1.2.4.~~ ~~Computer generation of all verification reports required by the IRS Notice pertaining to qualification for the Federal Tax Credit.~~

~~Annex B~~

~~Annex I~~

Response:
Accepted. (Identical to Comment #138.) The entire Section 6 and Annex A-I are being withdrawn from the final Committee draft of BSR/RESNET Standard 301-201x

Comment #148

Page Number: Page 60
Paragraph / Figure / Table / Note: Section 7. Normative Reference Documents
Comment Type: Technical

Comment:

The NFRC reference documents should be included in this section in order to be referenced elsewhere in the Standard.

Proposed Change:

NFRC, 100-2010 “Procedure for Determining Fenestration Product U-factors”

NFRC, 200-2010 “Procedure for Determining Fenestration Product Solar Heat Gain Coefficient and Visible Transmittance at Normal Incidence”

Response:

Rejected. Due to the rejection of comment #142, the proposed NFRC standards are not referenced in BSR/RESNET Standard 301-201x. It is not appropriate to include documents that are not referenced as normative references within a standard.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #149

Page Number: Whole document as applied to existing homes.
Paragraph / Figure / Table / Note: Whole document as applied to existing homes.
Comment Type: General

Comment:

Some argue that the process of rating a home is overly complex, or at least should allow some simpler options for some situations. I would argue that the rating process itself has costs and its value should be judged partly on the basis of whether those costs are justified. A simpler process that gave equivalent or better result would be a more cost-effective process.

This applies particularly to existing homes, where many energy projections over estimate the energy savings for upgrades to existing homes. Possible reasons for over estimation have been suggested, including overestimating the energy consumption of the existing home. However, the bottom line is that a requirement for a complex process is not justified if a simple process produces equivalent or better results.

Limited studies suggest that the HERS rating / energy projection process may be no better than some simpler processes for projecting energy savings from retrofits. The best example is a study done for the Energy Trust of Oregon, a non-profit group that supports energy efficiency.¹ The study compared several tools, including one common software tool that would pass the Standard with simpler tools that would not pass the Standard. This study concluded that the most accurate results in terms of the percentage error in the predicted total energy use came from the simplest tool. If simple works better, then requiring a complex process is not itself cost-effective, and the Standard will tend to discourage improvements in existing homes by adding unjustified expense to the process.

The Standard should allow much simpler processes, especially for existing buildings. Simpler processes that yield equal or better results will be a more cost-effective approach to delivering large scale improvements in energy efficiency.

1. “Energy Performance Score: 2008 Pilot Findings & Recommendations Report”. August, 2009. Energy Trust of Oregon, 421 SW Oak Street?Suite 300?Portland, OR.

Proposed Change:

Revise the Standard to allow for much simpler processes of projecting energy savings in upgrading existing homes.

Response:
Rejected. The commentator proposes no specific change to the draft BSR/RESNET Standard 301-201x but rather makes a general non-specific proposal to revise the standard without providing a cogent method for how the revision should be accomplished.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #150

Page Number: Pages 10, 11, 54, 66 and 67
Paragraph / Figure / Table / Note: Sections 4.1.1, 4.1.2 and 5.3.1.2. Sections 2.1 and 2.2 in Annex B.
Comment Type: General

Comment:

FSEC-CR-1650-06, Florida Solar Energy Center, Cocoa, FL, September 2006.

3. “ENERGY STAR Qualified Homes, Version 3 (Rev. 06) National Program Requirements”

http://www.energystar.gov/ia/partners/bldrs_lenders_raters/ES_Combined_Path_v_65_clean_508.pdf?42dd-e750

4. “ENERGY STAR Qualified Homes, Version 3 (Rev. 06) HERS Index Target Procedure?for National Program Requirements”

http://www.energystar.gov/ia/partners/bldrs_lenders_raters/downloads/ES_HERS_Index_Target_Procedure_v23_clean_508.pdf

5. "The HERS Rating Method and the Derivation of the Normalized Modified Loads Method." is not available online at location given by Standard: http://www.fsec.ucf.edu/bldg/pubs/hers_meth/

6. However the "The HERS Rating Method and the Derivation of the Normalized Modified Loads Method" is at: http://www.fsec.ucf.edu/en/publications/html/FSEC-RR-54-00/index.htm

as noted on the HERS web site.

7. Page 10, Table 4.2.1(1) titled “Coefficients ‘a’ and ‘b’ ”. Also Page 67, Table 2.1. titled “Coefficients ‘a’ and ‘b’ ”.

Proposed Change:

Response:
Rejected. (Identical to Comment #140.) While alternative rating methods may be available, the rating method proposed by this comment is not considered persuasive. The commentator’s proposed change to the rating method neither improves on the proposed Standard nor does it offer evidence that the proposed Standard is technically deficient.

There is a long history of argument between the electric industry and the natural gas industry about how energy use should be counted. The electric industry favors counting energy units based site energy and the natural gas industry favors counting energy units based source (or primary) energy. In 1999, the method that RESNET uses was developed to solve a number of problems related to “rating’ the energy performance of homes. It is called the normalized modified end use loads method (see http://www.resnet.us/professional/ratings/ratingmethod). It relies on using the sum of building end use loads for the Reference Home as the denominator of the “scoring fraction.” It then normalizes the energy end uses of the Rated Home with respect to the minimum and best available efficiencies for electric and natural gas equipment technologies. The method is not completely suitable to either the electric industry or the gas industry and, thus, we have received public comments from both parties to change the rating method to an alternative method that would advantage their particular industry in the marketplace. While the normalized modified end use loads (nMEUL) method may be difficult to explain in lay terms, it has been in effect and widely used by RESNET since 1999 when it was first adopted by the National Association of State Energy Officials (NASEO).

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #151

Page Number: Pages 2, 4, 59. Annexes A to F, Annex H, Annex I
Paragraph / Figure / Table / Note: Definitions for BESTEST and HERS BESTEST. Sections 6.3.4 and 6.3.5. Annexes A to F, Annex H, Annex I.
Comment Type: General

Comment:

BESTEST should not be required as part of the Standard (RESNET PDS 301-01).

Any requirement that adds time, complexity, or effort should add more in “value” than the “cost”. Unless it is shown that predictions made with software tested by BESTEST perform significantly better, there is no justification to require BESTEST.

Requiring BESTEST restricts innovation in software, potentially eliminating improvements in software. BESTEST does not compare final results, rather it compares intermediate calculations. Prospective software is not judged by getting the answer “correct”. There are unintended consequences of specifying an intermediate calculation, rather than the final result. A different method that yielded a more accurate final result or was simpler to use could be eliminated simply because it didn’t do some (apparently) unnecessary intermediate calculation.

What kind of innovations might be possible? We cannot know for sure.

Could software accomplish the energy-performance projection with fewer inputs, perhaps yielding a less expensive process?

Most tools overestimate energy savings in existing buildings, which also over-estimates cost-effectiveness- What about a simple multiplier times savings projections to cure (on average) the overestimation of savings in the situations where the overestimation is know to occur?

What about a tool that did a better job of integrating typical behavior, especially in estimating the impact of upgrades to existing homes?

What about software partly based on existing bills that better projected energy savings in existing buildings as part of the cost-effectiveness calculation?

How about a tool whose focus was on very-low energy homes outside the range BESTEST even looks at?

Maybe the model for heat flow in the ground, crawl spaces or basements can be improved?

Is the presumption that an existing home is at the code-minimum applicable to when it was built reasonable? Probably not, on average homes are likely slightly above code.

Is it possible to have a simple tool that only estimates the impact of simple upgrades to existing housing with very limited data input?

Whatever turns out to be possible should not be limited by requirements for intermediate results and a certain level of complexity.

There are a variety of tools that may help a software developers, including BESTEST, but they should not be a requirement. The requirement for BESTEST should be removed from the Standard.

Proposed Change:

Remove the requirement for BESTEST from the Standard. This includes removing the ANSI/ASHRAE Standard 140, Class II, Tier 1 Tests, which are based on BESTEST.

BESTEST – Building Energy Simulation Test (see also HERS BESTEST) page 2

HERS BESTEST – The Home Energy Ratings System Building Energy Simulation Test protocol published as NREL Report No. NREL/TP-472-7332 page 4

Delete Sections 6.3.4 and 6.3.5. Page 59

Revise Annex A, B, C, E, F, H, I to eliminate BESTEST.

Delete Annex D.

Response:
Accepted. (Identical to comment #158.) Software verification and testing standards will be removed from BSR/RESNET Standard 301-201x and all text within BSR/RESNET Standard 301-201x stating that software tools shall be “accredited” will be modified to state that software tools shall be “approved.”

Comment #152

Page Number: Page 72
Paragraph / Figure / Table / Note: Table 3.2 (1) Notes
Comment Type: Technical

Comment:

In this section, tell how existing windows with window film will be defined in calcualtions (using NFRC values).

Proposed Change:

....

(h) For a Qualifying Home with multiple heating, cooling, or water heating systems using different fuel types, the applicable system capacities and fuel types shall be weighted in accordance with the loads distribution (as calculated by accepted engineering practice for that equipment and fuel type) of the subject multiple systems. For the Reference Home, the prevailing federal minimum efficiency shall be assumed except that the efficiencies given in Table 3.2(1)(a) below will be assumed when:

1) A type of device not covered by NAECA is found in the Qualifying Home;

2) The Qualifying Home is heated by electricity using a device other than an air source heat pump; or

3) The Qualifying Home does

(i) For existing windows with window film, the NFRC rated value shall be used for U-value (NFRC 100 -2010), solar heat gain coefficient and visible transmittance (NFRC 200-2010).

Comment #153

Page Number: Whole document. Also RESNET Standards Development Policy and Procedures Manual pages 3 and 5.
Paragraph / Figure / Table / Note: Whole document. Also RESNET Standards Development Policy and Procedures Manual Section 2.6 and Section 3.
Comment Type: General

Comment:

The Standard’s (RESNET PDS 301-01) development process was overly dominated by RESNET and those associated with RESNET to the exclusion of others that provide similar functions related to home energy performance. Even the RESNET policy manual shows unacceptable bias. Parties such as the homebuilders and those with products that compete with RESNET and RESNET-associated parties should have had a more substantial role. The views of these underrepresented parties were not fairly considered.

The Standard’s development process was dominated by RESNET and those associated with RESNET. This would not be an issue, or inappropriate, if the document was to be used only by RESNET and RESNET-associated parties. However for a prospective ANSI consensus standard, the highly proprietary and repeated requirements for RESNET-documents, procedures, approvals, etc. is a big problem. The proprietary nature of the Standard is strong evidence that RESNET and RESNET-associated parties dominated the development, as it is hard to understand how non-RESNET interests that compete with RESNET would allow repeated RESNET-specific references which are clearly contrary to both the RESNET Standards Development Policy and Procedures Manual and the ANSI Essential Requirements section titled “Commercial Terms and Conditions” that state:

“ … The appearance that a standard endorses any particular products, services or companies shall be avoided. Therefore, it is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent). … In connection with standards that relate to the determination of whether products or services conform to one or more standards, the process or criteria for determining conformity can be standardized as long as the description of the process or criteria is limited to technical and engineering concerns and does not include what would otherwise be a commercial term.”

The evidence for dominance extends (inappropriately) into RESNET’s own written policy on the development of standards. The RESNET Standards Development Policy and Procedures Manual violates its own rule against proprietary elements (quoted above). For example, the RESNET Standards Development Policy and Procedures Manual Section 3.1 states:

“The RESNET website is a one-stop solution where homeowners can learn about the energy audit and rating processes, and search the RESNET directory to find certified energy auditors and raters and qualified contractors and builders. To be included in the directory, these independent, unbiased professionals must complete the required energy training to meet the high standards of excellence that RESNET demands. All RESNET-certified and RESNET-qualified professionals agree to abide by the RESNET Code of Ethics and Standards of Practice.”

The statement above is inappropriate in a document that is supposed to avoid even the appearance of endorsing any particular products, services or companies. The statement above and a few related statements need to be deleted.

The RESNET Standards Development Policy and Procedures Manual lists interests that need to be represented. It is surprising that homebuilders are not one of the “producers” listed. The number of homebuilders actively included in the development of the Standard has been insufficient. For example, a member representing the National Association of Home Builders, or the National Association of Home Builders would seem likely but is absent. The interests of homebuilders will include keeping the Standard simple and inexpensive, including limiting the new types of professionals that have to be integrated into the complex process of building a home. While some in what might be called the “home rating industry” will have an interest in selling more of their services, the homebuilders want any required expense or requirement that somehow increases the overhead to use the Standard, the products required by the Standard, or professionals associate with the Standard to deliver value.

Producing a non-proprietary Standard will require extensive revision of the Standard. There are many technical issues in other comments that should also lead to significant changes. Interests not included in the development of the Standard need to be included in making substantial revisions. If the Standard is to become an ANSI consensus standard, then RESNET’s competitors must be included, including many of the regional/local programs. Representatives of the ANSI approved ICC 700, whose energy chapter and supporting processes includes many of the functions within RESNET’s scope, should also be included. Homebuilders need to be much better represented.

Proposed Change:

In the RESNET Standards Development Policy and Procedures Manual, Section 3.1

The RESNET website is a one-stop solution where homeowners can learn about the energy audit and rating processes, and search the RESNET directory to find certified energy auditors and raters and qualified contractors and builders. To be included in the directory, these independent, unbiased professionals must complete the required energy training to meet the high standards of excellence that RESNET demands. All RESNET-certified and RESNET-qualified professionals agree to abide by the RESNET Code of Ethics and Standards of Practice.

Remove or revise other parts of sections 3.1 and 3.2 of the RESNET Standards Development Policy and Procedures Manual that are inconsistent with Section 10.16 of the RESNET Standards Development Policy and Procedures Manual.

In the RESNET Standards Development Policy and Procedures Manual, Section 2.6 add “homebuilders” as one of the interests named. In one or more of the interests named specify non-RESNET home energy performance assessment organizations, procedures, software, and parties.

Add or revise the membership of the technical committee(s) that perform the extensive revision of the Standard to include homebuilders, an ICC 700 representative, and RESNET’s competitors.

Response:
Rejected. The comment made by this commentator is not specific to BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #154

Page Number: as an example page 40 and all other locations throughout the whole document as applied to existing homes.
Paragraph / Figure / Table / Note: 4.5. Existing Home Retrofit Savings and throughout the whole document as applied to existing homes.
Comment Type: General

Comment:

1. “Energy Performance Score: 2008 Pilot Findings & Recommendations Report”. August, 2009. Energy Trust of Oregon, 421 SW Oak Street?Suite 300?Portland, OR.

Proposed Change:

Revise the Standard to allow for much simpler processes of projecting energy savings in upgrading existing homes. Such as the examples cited in the above comment. There are many examples that have been created for local conditions, One example would be a prescriptive approach with driven energy efficiency measures for common situations such that a full analysis of the building is not required, i.e. as approved by the authority having jurisdiction.

Response:
Rejected. (Identical to Comment #149.) The commentator proposes no specific change to the draft BSR/RESNET Standard 301-201x but rather makes a general non-specific proposal to revise the standard without providing a cogent method for how the revision should be accomplished.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #155

Page Number: 15
Paragraph / Figure / Table / Note: 4.2.2(1)
Comment Type: Technical

Comment:

Table 4.2.2(1) - Service water heating.

The assumptions for service water heating approximate the current NAECA minimum standards for water heaters. Unfortunately, the use of EF's to estimate hot water eneregy usage tends to understate energy consumption, especially in fossil fuel water heaters because actual consumption of hot water in a home rarely replicates the precise laboratory assumptions used by the Department of Energy to establish EF's. Cycling losses for fossil fuel water heaters under actuall field conditions tends to greatly exceed those losses determined under the DOE test procedure. (See http://www.energystar.gov/ia/partners/prod_development/new_specs/downloads/water_heaters/LBNL_052907.pdf for a brief discussion.

HERS should discount electric water heaters by an additional 3% and fossil fuel water heaters by an addtional 6% to account for actual field conditions.

Proposed Change:

Table 4.2.2(1)

Service water heating - Electric: EF = 0.97 - (0.00132*store gal) * .97

Fossil fuel: EF = 0.67 - (0.0019*store gal) * .94

Response:
Rejected. The rated performance of service hot water heaters is not used directly in calculations of hot water energy use. RESNET requires that software used for HERS Ratings pass a hot water test suite that ensures that the manufacturer’s EF rating is not used directly to calculate hot water use but rather that the EF is used to calculate the tank loss factor and recovery efficiency and that representative actual hot water use (gpd) and inlet mains water temperature are used instead. These factor are climate sensitive and result in projected hot water energy use being a fairly strong function of climate rather than the manufacturer’s EF alone.
You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #156

Page Number: Page 77
Paragraph / Figure / Table / Note: Section 4.3, footnote 25
Comment Type: Technical

Comment:

Include window film in the SHGC calculation refered to in this footnote.

Proposed Change:

25 The overall solar heat gain coefficient (SHGC) of a fenestration is defined as the solar heat gain coefficient (SHGC) of the fenestration product, and window film, if present, taken in combination with the interior shade fraction for the fenestration.

Response:
Rejected. These provisions pertain to software verification testing which is being withdrawn from BSR/RESNET Standard 301-201x due to the fact that software testing and verification is not part of the authorized scope of BSR/RESNET Standard 301-201x. However, under Table 4.4.2(1), Minimum Rated Features, item 6, Windows, the language will be changed to account for the SHGC of the entire assembly, as follows:

6. Windows Construction type, orientation, U-value (of complete assembly), solar heat gain coefficient (of complete assembly), shading.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #157

Page Number: Standards Development Policy and Procedures Manual
Paragraph / Figure / Table / Note: sec 2.6
Comment Type: General

Comment:

In the RESNET Standards Development Policy and Procedures Manual, Section 2.6 add “utilities” as one of the interests named.

Utilities, especially electric utilities, are very involved in the energy efficiency community and their programs likely use HERS scores to qualify homes for incentives.

Electric utilities have a vested interest in the outcome of the standard and should be part of the consensus body.

Response:
Rejected. The comment made by this commentator is not specific to BSR/RESNET Standard 301-201x.

You have the right to file an appeal within 30 days with the RESNET Standards Management Board in accordance with Section 12 of the RESNET Standards Development Policy and Procedures Manual.

Comment #158

Page Number: 2, 4, 59, Annexes A to F, Annex H, Annex I
Comment Type: General

Comment:

BESTEST should not be required as part of the Standard (RESNET PDS 301-01).

Multiple versions of BESTEST are referenced in the Standard, which is at best confusing. The versions end with the values “7332”, “7332a” and “7332b”. On page 4 the definition of HERS BESTEST references NREL Report No. NREL/TP-472-7332. On page 59 the Standard references both “a” and “b” in the same section, one in the text and one in the note #19. Annex D may contain yet another version.