The following comments have been submitted:
Comment #1Page Number: A-6 A25 and othersComment Intent: ObjectionComment Type: TechnicalComment: Why is RESNET continueing to use 68 degrees for heating and 78 degrees for cooling when ACCA and the IECC reference design temperatures of 70 degrees for hewating and 75 degrees for cooling? When doing code work I need to reference the IECC for temperature calculations in the software. Having the same numbers needs worked out. Proposed Change: Use 75 degrees for cooling and 70 degrees for heating.
Why is RESNET continueing to use 68 degrees for heating and 78 degrees for cooling when ACCA and the IECC reference design temperatures of 70 degrees for hewating and 75 degrees for cooling? When doing code work I need to reference the IECC for temperature calculations in the software. Having the same numbers needs worked out.
Use 75 degrees for cooling and 70 degrees for heating.
Comment #2Page Number: A-23Comment Intent: Not an ObjectionComment Type: EditorialComment: Rated feature / Floor type /Identify floor over full basement...States verticle dimension is greater than 46 feet. I assume it should read 6 feet not 46
Rated feature / Floor type /Identify floor over full basement...States verticle dimension is greater than 46 feet. I assume it should read 6 feet not 46
Comment #3Page Number: A-46Comment Intent: Not an ObjectionComment Type: EditorialComment: In the middle of the table, U value (struck through) Factor put in its place. TThe next two section continue with value, this should be either factor or value to make it consistant.
In the middle of the table, U value (struck through) Factor put in its place. TThe next two section continue with value, this should be either factor or value to make it consistant.
Comment #4Page Number: A-46Comment Intent: Not an ObjectionComment Type: EditorialComment: In the middle of the table, U value (struck through) Factor put in its place. TThe next two section continue with value, this should be either factor or value to make it consistant.
Comment #5Page Number: A-47Comment Intent: Not an ObjectionComment Type: EditorialComment: Keep with either value of Factor As in U value Factor
Keep with either value of Factor
As in U value Factor
Comment #6Page Number: A-21Paragraph / Figure / Table / Note: NORMATIVE APPENDIX B / GENERALComment Intent: ObjectionComment Type: GeneralComment: We are writing to express our strong objection to the language proposed in page A-21 of Draft PDS-02 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features, which require that each photo and/or report shall be time/date stamped and geo tagged. This proposed change represents a major change to the HERS Industry and raises the following issues: Actual Accuracy of Geotagging Using Standard Methods of Photo Capture (Cell Phone/Tablet) The main argument from PDS01 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features for adding a timestamp and a geotag to photos it is that it will allow RESNET Quality Assurance and Providers to “confirm that the on-site inspection has taken place, and that the minimum rated features have been observed”. The intent of this statement is noble, but it does not realistically consider the level of accuracy this method of data capture provides using standardly available tools, and more importantly the ease at which this information can be deleted or changed. Geotagging and Timestamping are examples of Exchangeable Image File Format Data, commonly referred to as EXIF Data. Geotagging captures the latitude and longitude of where a photo occurred (measured in degrees, minutes, and seconds), and elevation (measured in meters). We provided the standard format for latitude and longitude for a few famous locations below to give an example of what it looks like: Time Squares (New York) – 40° 45' 32” N, 73° 59' 6” W Bourbon Street (New Orleans) – 29° 57' 17” N, 90° 04' 8” W Space Needle (Seattle) – 47° 37' 13” N, 122° 20' 56” W The level of accuracy can be increased by adding a decimal after the second (“) value, however all of the smartphone apps that we researched provided the above level of accuracy. So what level of location accuracy does this really provide for RESNET Quality Assurance purposes? The answer is tricky, and it actually can change based off your location. Times Square – One second of latitude = 31 meters, one second of longitude = 24 meters Bourbon Street – One second of latitude = 31 meters, one second of longitude = 27 meters Space Needle – One second of latitude = 31 meters, one second of longitude = 21 meters (The below website was used to calculate these) https://stevemorse.org/nearest/distance.php This means, at these locations using an app on a standard smartphone to apply a geotag with the standard accuracy, we can expect the photos we take to be within the below accuracy: Times Square – 31 meters x 24 meters = 744 m² = 8008.3494 ft² Bourbon Street – 31 meters x 27 meters = 837 m² = 9009.3930 ft² Space Needle – 31 meters x 21 meters = 651 m² = 7007.3057 ft² Considering this level of accuracy, there are several problems with using this requirement as a method of verification: For a standard size home, the majority of the photos taken will realistically display the same geotag location, or within one second of each other. More on this later. For homes built close together, or for multifamily units, there will be little ability for RESNET Quality Assurance or Providers to 100% prove that photos taken in one home (for instance that might have Grade I insulation or a passing Blower Door value) were not applied next door to a home that does not. Verifying a physical address against a geotag location is not quick process, and will add minutes onto every single Quality Assurance file reviewed by Providers throughout the RESNET network, increasing all of our labor per file and cost to set up this new process. With the displayed level of accuracy available, we will also have to determine the true location under certain circumstances which will take even longer. The assumption that all Rating Companies will understand this process and have the correct hardware and software to carry it out upon approval of this amendment is not realistic. Ability to Falsify Timestamp and Geotag Data Coming back to the fact that all of the homes will have the same (or near enough) geotag location, the biggest issue with all of this is that a geotag and a timestamp for photos can be changed, in mass, with the correct app or software. After a simple Google Search, we found several websites (like the ones below) that walk you through the entire process, and found apps within the Google Play Store that could do them as soon as a photo was added to your phone. https://www.howtogeek.com/203592/what-is-exif-data-and-how-to-remove-it/ https://gadgets.ndtv.com/apps/features/remove-location-data-from-photos-view-edit-exif-android-windows-mac-iphone-1821872 This would effectively allow someone to have several stock pictures saved of wall or roof assembly insulation grading, equipment data plates, blower door test values, etc., at different angles and under different lighting, and just to pick and apply the correct pictures for the file and change the geotag and timestamp as needed. The reasoning behind the argument for using a timestamp and a geotag, which is really the elephant in the room at most QA Meetings during the RESNET Conference, is that 99% of the Raters in this industry try to do the right thing and follow the Standards, while 1% of them cheat. We went to this level of detail in this public comment to show that regardless of its intent, this requirement will not stop these individuals from trying to cheat the system, and will only greatly increase the cost and time required for the rest of us to verify that it is being done correctly, without actually adding value to or affecting the score of a HERS Rating at all. Proposed Change: On-Site Inspection Protocol Each photo and/or report shall be time/date stamped and geo tagged. Where documentation is required to be recorded in this Appendix, that documentation shall include a photo.
We are writing to express our strong objection to the language proposed in page A-21 of Draft PDS-02 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features, which require that each photo and/or report shall be time/date stamped and geo tagged.
This proposed change represents a major change to the HERS Industry and raises the following issues:
Actual Accuracy of Geotagging Using Standard Methods of Photo Capture (Cell Phone/Tablet)
The main argument from PDS01 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features for adding a timestamp and a geotag to photos it is that it will allow RESNET Quality Assurance and Providers to “confirm that the on-site inspection has taken place, and that the minimum rated features have been observed”.
The intent of this statement is noble, but it does not realistically consider the level of accuracy this method of data capture provides using standardly available tools, and more importantly the ease at which this information can be deleted or changed.
Geotagging and Timestamping are examples of Exchangeable Image File Format Data, commonly referred to as EXIF Data.
Geotagging captures the latitude and longitude of where a photo occurred (measured in degrees, minutes, and seconds), and elevation (measured in meters). We provided the standard format for latitude and longitude for a few famous locations below to give an example of what it looks like:
Time Squares (New York) – 40° 45' 32” N, 73° 59' 6” W
Bourbon Street (New Orleans) – 29° 57' 17” N, 90° 04' 8” W
Space Needle (Seattle) – 47° 37' 13” N, 122° 20' 56” W
The level of accuracy can be increased by adding a decimal after the second (“) value, however all of the smartphone apps that we researched provided the above level of accuracy. So what level of location accuracy does this really provide for RESNET Quality Assurance purposes? The answer is tricky, and it actually can change based off your location.
Times Square – One second of latitude = 31 meters, one second of longitude = 24 meters
Bourbon Street – One second of latitude = 31 meters, one second of longitude = 27 meters
Space Needle – One second of latitude = 31 meters, one second of longitude = 21 meters
(The below website was used to calculate these)
https://stevemorse.org/nearest/distance.php
This means, at these locations using an app on a standard smartphone to apply a geotag with the standard accuracy, we can expect the photos we take to be within the below accuracy:
Times Square – 31 meters x 24 meters = 744 m² = 8008.3494 ft²
Bourbon Street – 31 meters x 27 meters = 837 m² = 9009.3930 ft²
Space Needle – 31 meters x 21 meters = 651 m² = 7007.3057 ft²
Considering this level of accuracy, there are several problems with using this requirement as a method of verification:
Ability to Falsify Timestamp and Geotag Data
Coming back to the fact that all of the homes will have the same (or near enough) geotag location, the biggest issue with all of this is that a geotag and a timestamp for photos can be changed, in mass, with the correct app or software. After a simple Google Search, we found several websites (like the ones below) that walk you through the entire process, and found apps within the Google Play Store that could do them as soon as a photo was added to your phone.
https://www.howtogeek.com/203592/what-is-exif-data-and-how-to-remove-it/
https://gadgets.ndtv.com/apps/features/remove-location-data-from-photos-view-edit-exif-android-windows-mac-iphone-1821872
This would effectively allow someone to have several stock pictures saved of wall or roof assembly insulation grading, equipment data plates, blower door test values, etc., at different angles and under different lighting, and just to pick and apply the correct pictures for the file and change the geotag and timestamp as needed.
The reasoning behind the argument for using a timestamp and a geotag, which is really the elephant in the room at most QA Meetings during the RESNET Conference, is that 99% of the Raters in this industry try to do the right thing and follow the Standards, while 1% of them cheat.
We went to this level of detail in this public comment to show that regardless of its intent, this requirement will not stop these individuals from trying to cheat the system, and will only greatly increase the cost and time required for the rest of us to verify that it is being done correctly, without actually adding value to or affecting the score of a HERS Rating at all.
On-Site Inspection Protocol
Each photo and/or report shall be time/date stamped and geo tagged. Where documentation is required to be recorded in this Appendix, that documentation shall include a photo.
Comment #7Page Number: A-21Paragraph / Figure / Table / Note: NORMATIVE APPENDIX B / GENERALComment Intent: ObjectionComment Type: GeneralComment: We are writing to express our strong objection to the language proposed in page A-21 of Draft PDS-02 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features, which require the use of digital/electronic means for field inspections and performance tests. This proposed change represents a major change to the HERS Industry and raises the following issues: Cost At the end of the day, every Rating Company apart of RESNET and that utilizes the HERS Index is here to make money. These organizations may also have altruistic goals, care deeply about RESNET’s mission, and want to help improve our environment by reducing home energy consumption, but without a successful/solvent business model none of us would exist. For those companies that do not use them, the requirement to use digital/electronic means for field inspections and performance tests adds costs, both hidden and actual, and we disagree with some of the comments made in support of this proposed change from the previous draft (PDS01) that these would be negligible. No one Rating Company can speak for another on the true impact that this proposed change would have on their business model. Below are just a few examples of costs that this would create: Costs in employee time towards internally identifying how their Rating Company would meet this proposed change, and the resulting loss in productivity towards their actual work. Costs in training employees how to carry out this proposed change, whether that be in a classroom setting or in the field. Costs for procuring the needed hardware / software to implement this change. Several of the comments from PDS01 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features in favor of this proposed change flippantly dismissed the hardware question, assuming everyone has access to a smart phone/tablet, but this can be a real cost for some organizations that still use pen/paper data collection followed by manual data input into a software program. On the software side, while there are multiple free software programs out there that can do different aspects of this process (data collection on mobile form, photo taking with timestamp and geotagging, data transfer from mobile hardware to desktop software program, electronic form and photo storage) that can be cobbled together into a business process, none of them offer an all in one solution tailored to the Rating Industry. There are however paid software programs geared towards the HERS Industry that do offer one. This proposed change would obviously benefit them greatly from a sales perspective. I greatly hope that this this is not the hidden intent of this requirement. Costs in employee time towards external coordination between Rating Companies and Providers and Providers and RESNET on how to meet this proposed change. Costs for Data Storage and Data Transfer. Again, some of the comments from PDS01 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features in support of this proposed change downplayed the impact of this requirement. However, consider that newer smart phones/tablets take photos at higher and higher resolutions the more advanced they get. This means the file size for these photos will increase. That means that the larger a Rating Company gets or the more photos they are required to take, store, and submit for Quality Assurance purposes, the greater their data transfer and storage requirements will be. Beyond Scope of SDC 300 Looking at the RESNET website, the scope of SDC 300 is defined below: SDC 300 Scope: Oversee the technical development, public review, adoption and interpretation of RESNET American National Standards (ANSI) related to the energy performance of new and existing single-family residences and new and existing multifamily residences three stories or less in height above ground excepting hotels and motels. The proposed requirement mandating data collection by digital/electronic means for field inspections and performance tests is beyond the scope of this committee, as it is attempting to dictate administrative business processes to Rating Companies, not technical standards. If a Rating Company’s business model is to hand write all of their data on a data collection sheet and then to enter it directly into a RESNET approved software tool, that is their decision to make. If they are performing the technical aspect of ratings in accordance to the RESNET standards, their Provider is able to perform quality assurance on them in accordance with the RESNET standards, and they are commercially successful, then their business model is successful. While many within the RESNET industry may consider it a best practice to use electronic data collection tools, we as an industry should not be in the business of pushing successful Raters away from using the HERS Index that are comfortable with another method. Proposed Change: Task Record Ffield inspections and performance tests shall be recorded by digital/electronic means All records shall be kept for a minimum of 53 years
We are writing to express our strong objection to the language proposed in page A-21 of Draft PDS-02 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features, which require the use of digital/electronic means for field inspections and performance tests.
Cost
At the end of the day, every Rating Company apart of RESNET and that utilizes the HERS Index is here to make money. These organizations may also have altruistic goals, care deeply about RESNET’s mission, and want to help improve our environment by reducing home energy consumption, but without a successful/solvent business model none of us would exist. For those companies that do not use them, the requirement to use digital/electronic means for field inspections and performance tests adds costs, both hidden and actual, and we disagree with some of the comments made in support of this proposed change from the previous draft (PDS01) that these would be negligible. No one Rating Company can speak for another on the true impact that this proposed change would have on their business model. Below are just a few examples of costs that this would create:
Beyond Scope of SDC 300
Looking at the RESNET website, the scope of SDC 300 is defined below:
SDC 300 Scope: Oversee the technical development, public review, adoption and interpretation of RESNET American National Standards (ANSI) related to the energy performance of new and existing single-family residences and new and existing multifamily residences three stories or less in height above ground excepting hotels and motels.
The proposed requirement mandating data collection by digital/electronic means for field inspections and performance tests is beyond the scope of this committee, as it is attempting to dictate administrative business processes to Rating Companies, not technical standards. If a Rating Company’s business model is to hand write all of their data on a data collection sheet and then to enter it directly into a RESNET approved software tool, that is their decision to make. If they are performing the technical aspect of ratings in accordance to the RESNET standards, their Provider is able to perform quality assurance on them in accordance with the RESNET standards, and they are commercially successful, then their business model is successful. While many within the RESNET industry may consider it a best practice to use electronic data collection tools, we as an industry should not be in the business of pushing successful Raters away from using the HERS Index that are comfortable with another method.
Task
Record Ffield inspections and performance tests shall be recorded by digital/electronic means
All records shall be kept for a minimum of 53 years
Comment #8Page Number: A-78Paragraph / Figure / Table / Note: Central Fan Integrated SupplyComment Intent: ObjectionComment Type: GeneralComment: Use of HVAC Blower for Ventilation in High Radon Areas Exposure to radon is the second leading cause of lung cancer in the U.S., second only to smoking. Negative pressures within buildings tend to increase radon flow across concrete slabs floors and basement walls. Typical houses already have many exhaust fans (kitchen, baths) that tend to cause depressurization. These fans are commonly associated with exhaust flues containing gravity dampers. Such dampers will open to normalize positive house pressures. However, they will not relieve negative house pressures. In areas of the country with high radon potential, ventilation systems that contribute to hous negative pressures should be avoided (and perhaps illegal). Consideration must also be given to long term reliability and use of any ventilation system. Houses will typically last and be occupied for decades. It is very likely that many of them will not be maintained in their “just built” condition. 1.How long will the ventilation system fan motor last? 2. How likely are occupants to know if it fails? 3. How likely are occupants to get it fixed when it does fail? All the above, make the use of fresh air vents on the return side of HVAC blower fans a preferred method of suppling ventilation air in areas of high radon potential. This strategy tends to result in positive house pressures. HVAC blower fans typically last for decades. Occupants will know when the blower fan fails. Occupants are highly likely to get it fixed when it fails. RESNET should be concerned with insuring that its standards and policies do not unknowingly and/or unjustly encourage ventilation strategies that could potentially result in harm to the occupants in the name of saving a few bucks up front. This can potentially occur in two ways. 1. Overestimating HVAC blower fan energy consumption. All proposed RESNET measures record full load amps. Systems should never operate in this range. Running load amps (wattages) are more appropriate. 2. Over assigning HVAC blower fan energy consumption to ventilation (especially during times with heating and cooling loads are low). RESNET should consider that even in shoulder months when space conditioning loads are low, HVAC blower fans also function to provide filtration and avoid air stagnation and stratification. It is not realistic to assign 100% of blower fan energy to ventilation even during periods when heating and cooling are not required. Proposed Change: ADD THE FOLLOWING As an option, the actual voltage and wattage of the fan motor operating in fan only mode can be measured and recorded. Whatever method used, the percentage of fan energy applied to ventilation shall be calculated by the following equation: CFM(outside air)/CFM (total system).
Use of HVAC Blower for Ventilation in High Radon Areas
In areas of the country with high radon potential, ventilation systems that contribute to hous negative pressures should be avoided (and perhaps illegal).
Consideration must also be given to long term reliability and use of any ventilation system. Houses will typically last and be occupied for decades. It is very likely that many of them will not be maintained in their “just built” condition.
1.How long will the ventilation system fan motor last?
2. How likely are occupants to know if it fails?
3. How likely are occupants to get it fixed when it does fail?
All the above, make the use of fresh air vents on the return side of HVAC blower fans a preferred method of suppling ventilation air in areas of high radon potential.
RESNET should be concerned with insuring that its standards and policies do not unknowingly and/or unjustly encourage ventilation strategies that could potentially result in harm to the occupants in the name of saving a few bucks up front.
This can potentially occur in two ways.
1. Overestimating HVAC blower fan energy consumption. All proposed RESNET measures record full load amps. Systems should never operate in this range. Running load amps (wattages) are more appropriate.
2. Over assigning HVAC blower fan energy consumption to ventilation (especially during times with heating and cooling loads are low).
RESNET should consider that even in shoulder months when space conditioning loads are low, HVAC blower fans also function to provide filtration and avoid air stagnation and stratification. It is not realistic to assign 100% of blower fan energy to ventilation even during periods when heating and cooling are not required.
ADD THE FOLLOWING
As an option, the actual voltage and wattage of the fan motor operating in fan only mode can be measured and recorded. Whatever method used, the percentage of fan energy applied to ventilation shall be calculated by the following equation:
CFM(outside air)/CFM (total system).
Comment #9Page Number: A-21Paragraph / Figure / Table / Note: NORMATIVE APPENDIX B / GENERALComment Intent: ObjectionComment Type: GeneralComment: We are writing to express our objection to the language proposed in page A-21 of Draft PDS-02 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features, which require representative photos of Minimum Rated Features (MRF) #2 (Wall Assembly) and #3 (Roof/Ceiling Assembly). While we agree with the intent of this proposed change, that certain photos can help confirm that a rating actually took place, we disagree with the requirement for these specific photos for the following reasons. Timing of MRF #2 (Wall Assembly) and #3 (Roof/Ceiling Assembly) Photos Require Rough Inspections As written, the proposed amendment stipulates that one representative photo is required of Minimum Rated Features (MRF) #2 (Wall Assembly) and #3 (Roof/Ceiling Assembly). The presumed intent of this proposed amendment is to provide photographic evidence for the Insulation Grading applied in the Confirmed Rating for these MRFs. However, the current version of ANSI-RESNET 301-2014 allows for the eventuality that a Rating Company can perform a Confirmed Rating without performing a Rough Inspection, so long as they follow the below guidelines with regards to Insulation Grading. From ANSI-RESNET 301-2014: 4.2.2.2.1. The insulation of the HERS Reference Home enclosure elements shall be modeled as Grade I. The insulation of the Rated Home shall either be inspected according to procedures such as or equivalent to Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards or, if not inspected, shall be modeled as Grade III and shall be recorded as “not inspected” in the rating. Our issue with the proposed amendment as written is it conflicts with this part of the standards when applied to real life situations that face Rating Companies, namely: The only way to realistically capture any photos for Insulation Grading of Wall Assemblies is during a Rough Inspection of the Rated Home. Either due to scheduling limitations that keep a Rating Company from performing a Rough Inspection, situations when a Rating Company is brought onto a new construction project after drywall is installed, or during the Rating of an existing home, there are instances where capturing these photos will be impossible. While you can capture photos of Insulation Grading of Ceiling Assemblies via an attic access port, you cannot always get a good enough angle from the attic access to adequately show an entire assembly, or be able to see around different parts of the attic to show an entire assembly without traversing over it, which is not always advisable for safety reasons as well adds the potential to damage the insulation. Because the current standard allows for the eventuality that a Rough Inspection may not be performed, we should not include the requirement on our Rating Companies for photos that can only be captured during a Rough Inspection. We should instead allow the RESNET QAD and Provider networks to enforce the prescribed Insulation Grading rules already prescribed in ANSI-RESNET 301-2014 and to further educate our Rating Companies on their correct use. Photos of MRF #11, 12, 14 (Mechanicals) and #9, 10 (Air Leakage / Distribution System Test Results) Sufficient to Prove Rating Occurred As we had stated above, we agree with the intent of this proposed change, that certain photos can help confirm that a rating actually took place. We believe that requiring a photo of either one of the installed pieces of mechanical equipment present at the time of the Rating would allow for the data plate information to be confirmed by a follow-on Field QA visit, proving that a Rating Company was present in that home. Additionally, a photo of the recorded test results would allow for a follow-on Field QA duplication of the test to show either confirmation of the values recorded during the Confirmed Rating, or provide the Field QAD the ability to catch that the test was performed incorrectly. Proposed Change: On-Site Inspection Protocol Clearly document the following: If included in the Energy Rating and present in the Dwelling Unit, a minimum of Oone representative photo of each building element from Table 4.5.2(1) that is included in the Energy Rating items #2 (Wall Assembly); #3 (Roof/Ceiling Assembly); and either #11 (Heating Equipment), #12 (Cooling Equipment), or #14 (Service Hot Water Equipment) from Table 4.5.2(1) that reflect the reported data If testing is conducted in the Dwelling Unit, a photo of the recorded test results or a report generated by automated software that communicates with the testing device showing the test result
We are writing to express our objection to the language proposed in page A-21 of Draft PDS-02 BSR/RESNET/ICC 301-2014 Addendum N-201x, Normative Appendix B, Inspection Procedures for Minimum Rated Features, which require representative photos of Minimum Rated Features (MRF) #2 (Wall Assembly) and #3 (Roof/Ceiling Assembly).
While we agree with the intent of this proposed change, that certain photos can help confirm that a rating actually took place, we disagree with the requirement for these specific photos for the following reasons.
Timing of MRF #2 (Wall Assembly) and #3 (Roof/Ceiling Assembly) Photos Require Rough Inspections
As written, the proposed amendment stipulates that one representative photo is required of Minimum Rated Features (MRF) #2 (Wall Assembly) and #3 (Roof/Ceiling Assembly). The presumed intent of this proposed amendment is to provide photographic evidence for the Insulation Grading applied in the Confirmed Rating for these MRFs.
However, the current version of ANSI-RESNET 301-2014 allows for the eventuality that a Rating Company can perform a Confirmed Rating without performing a Rough Inspection, so long as they follow the below guidelines with regards to Insulation Grading.
From ANSI-RESNET 301-2014:
4.2.2.2.1. The insulation of the HERS Reference Home enclosure elements shall be modeled as Grade I. The insulation of the Rated Home shall either be inspected according to procedures such as or equivalent to Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards or, if not inspected, shall be modeled as Grade III and shall be recorded as “not inspected” in the rating.
Our issue with the proposed amendment as written is it conflicts with this part of the standards when applied to real life situations that face Rating Companies, namely:
Because the current standard allows for the eventuality that a Rough Inspection may not be performed, we should not include the requirement on our Rating Companies for photos that can only be captured during a Rough Inspection. We should instead allow the RESNET QAD and Provider networks to enforce the prescribed Insulation Grading rules already prescribed in ANSI-RESNET 301-2014 and to further educate our Rating Companies on their correct use.
Photos of MRF #11, 12, 14 (Mechanicals) and #9, 10 (Air Leakage / Distribution System Test Results) Sufficient to Prove Rating Occurred
As we had stated above, we agree with the intent of this proposed change, that certain photos can help confirm that a rating actually took place.
We believe that requiring a photo of either one of the installed pieces of mechanical equipment present at the time of the Rating would allow for the data plate information to be confirmed by a follow-on Field QA visit, proving that a Rating Company was present in that home.
Additionally, a photo of the recorded test results would allow for a follow-on Field QA duplication of the test to show either confirmation of the values recorded during the Confirmed Rating, or provide the Field QAD the ability to catch that the test was performed incorrectly.
Clearly document the following: