Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"

Comment #1

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 1
Paragraph / Figure / Table / Note: 1
Comment Type: General

Comment:

Copytright or Trademark EnergySmart

Justification for Change:

GE has Energy Smart trademarked but I don't believe EnergySmart is.


Comment #2

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 1
Paragraph / Figure / Table / Note: 1003.3
Comment Type: Technical

Comment:

CHERS should be changed to HERS as the Chapter 2 revisions effective Jan 1, 2013 will combine CHERS and Home Performance Auditor into HERS.  Throughout the document.

Justification for Change:

Chapter 2 revisions effective Jan 1, 2013.

Proposed Change:

Replace CHERS with HERS here and througout the document.


Comment #3

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 3
Paragraph / Figure / Table / Note: 1004.2.5.1 e
Comment Type: Editorial

Comment:

The word "consequences" is used.  This has a negative connotation.  If this is the intent, then "practices" should be changed to "mistakes" or "errors". 

Justification for Change:

If the intent is market transformation, the sentence should convey that thought.

Proposed Change:

reword to:  "Energy related consequences of inefficient construction design and application."


Comment #4

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 5
Paragraph / Figure / Table / Note: 1004.5.6
Comment Type: Technical

Comment:

1004.5.2 states that "a certified CHERS Rater/BPA" is the person to perform the inital audit of the home.  

1004.5.6 reads "A Final Verifier", this does not explicitly state that the individual is to be BPI or RESNET CAZ certified, or a HERS Rater and performs essentially the actions as the "certified CHERS Rater/BPA".

Justification for Change:

Increase clarity.

Proposed Change:

reword:  A Final Verifier who is a 3rd party certified HERS Rater/BPA.


Comment #5

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 6
Paragraph / Figure / Table / Note: 1004.7
Comment Type: Technical

Comment:

Is "Rating Provider" the same as "CEQ Provider"

Why create another training providership when Rater Training Providers will have to soon add CAZ and workscope to Rater training?  Why not let the current business model conform to the new standard?

Justification for Change:

Clarity, if a CEQ Provider does not certify the Ratings for an ES Project/Home, this needs to be explicitly stated in section 1003.1

Proposed Change:

Delete CEQ Provider and wrap that into the Rater Training Provider's responsibilities.


Comment #6

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 6
Paragraph / Figure / Table / Note: 1004.7.3
Comment Type: Technical

Comment:

What is the definition of "independent of"?

Does this mean the CEQ Provider cannot employ a:  Project Manager, CHERS Rater, BPA, ES Contractor, Independent Rater/Auditor that works on an ES Project?

Does this mean the Rating Provider cannot employ a: Project Manager, CHERS Rater, BPA, ES Contractor, Independent Rater/Auditor that works on an ES Project?

Does this mean the CEQ Provider cannot QA a:  Project Manager, CHERS Rater, BPA, ES Contractor, Independent Rater/Auditor that works on an ES Project?

Does this mean the Rating Provider cannot QA a: Project Manager, CHERS Rater, BPA, ES Contractor, Independent Rater/Auditor that works on an ES Project?

If conflict of interest is the goal, RESNET already has developed a Standard Disclosure.

Justification for Change:

This will not allow CEQ Providers or Rating Providers, that employ their own Rating staff, to perform ES Projects.

Proposed Change:

Allow Providers to utilize their own staff to perform ES projects and utilize the Standard Disclosure.


Comment #7

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 7
Paragraph / Figure / Table / Note: 1004.9.1
Comment Type: Technical

Comment:

Why does the Final Verifier have to be an independent Rater/Auditor? 

On a HERS Rating where a Rater consults a builder on how to meet a set of program guidelines such as ENERGY STAR, and recommends a package of upgrades to meet that standard, a 3rd party independent Rater does not then come in and perform the Final inspection on the house and give it to a 4th party Rater for certification.

Justification for Change:

Adding the additional independence of a 3rd party Final Verifier will not only limit the financial potential of the initial CHERS Rater, but will create additional costs to ES Projects to the detriment of the ES program.

This again outlaws Providers from employing their own Raters and owning entire projects and does not help to grow the industry, but chop it up into little niches that increase the cost of projects and decrease their salability.

Proposed Change:

Delete the Final Verify and allow the initial CHERS Rater to perform the final testing and certification.


Comment #8

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 8
Paragraph / Figure / Table / Note: 1004.9.2.6 c
Comment Type: Technical

Comment:

Is RESNET developing the "final verification checklist"?

Is this up to the "Project Manager", CHERS Rater, or "Final Verifier" to create?

Justification for Change:

create consistency in the program

Proposed Change:

Have the RESNET Technical Committee develop the "final verification checklist"


Comment #9

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 8
Paragraph / Figure / Table / Note: 1005.1.5
Comment Type: Technical

Comment:

Recommendation of a full home audit.  This contradicts section 1004.6.4 that says the Project Manager "Must ensure that the initial rating or audit is performed on each Project in accordance with the QA Standard."  The QH Standard does not allow for a partial audit.

Justification for Change:

remove a contradiction

Proposed Change:

Delete 1005.1.5 as it is unnecessary.


Comment #10

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 13
Paragraph / Figure / Table / Note: 1006.5.3.1 a
Comment Type: Technical

Comment:

"When the Rating Provider's QA Designee conducts the QA Field Review projects shall review at least one  QA Field Review of each EnergySmart Contractors and EnergySmart Teams;"

This sentence does not make sense.  Is the point that Field QA is not only of the Final Verifier, but also the ES Contractor and ES Team?  The ES Contractor is part of the ES Team.  If the point is that during Field QA the QA Designee reviews at least one ES Contractor who is a member of the ES Team, then that should be stated.

Justification for Change:

provide clarity.

Proposed Change:

It depends on what the original point of the sentence was. 

reword:  When the Rating Provider's QA Designee conducts the QA Field Review of an EnergySmart Project, he shall review at least one EnergySmart Contractor who is a member of the EnergySmart Team.


Comment #11

Amendment: Proposed Amendment on Adopting Chapter 10 "RESNET Energy Smart Contractor Standard"
Page Number: 14
Paragraph / Figure / Table / Note: 1006.5.3.4 c
Comment Type: Technical

Comment:

A 5% tolerance between the QAD and Final Verifier's results (the results being the Confirmed Rating) is very narrow.  Adding the tolerances between the house take-off (what is the acceptable percentage range between the Rater and QAD?), REM/Rate libraries (if insulation is installed then covered over, the Rater will give it one grade, but the QAD must give it Grade III since it is not verifiable), improvement analysis (QAD must create his own based on the work scope), blower door and duct blaster results.  Unless the QAD goes to the same site pre and post air sealing, he will not have accurate data to input for savings calculations.  Are savings calculations part of the 5% tolerance?

Justification for Change:

Exactly what results does the QAD have to Field Verify that the Final Verifier documented?

Proposed Change:

Explicitly document the parameters that must be Field Verified by the QAD and be within the 5% tolerance.


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