Comments Submitted Name: Mark Newey Organization: Center for Ecological Technology Amendment: TECH-2005-08 I do not think this amendment is a good idea because of these reasons: 1. The building code does not prohibit conditioned crawlspaces. There are 5 exceptions to venting crawlspaces listed, and several of these are feasible. The energy code has a column in all of the insulation tables indicating the insulation levels for a crawlspace wall if the crawlspace is conditioned. 2. Basement wall insulation affects heat flow through foundations regardless of whether the basement is conditioned or not. 3. There are many basements that have no direct heating or cooling but have insulation in the walls. A rater might describe this as a conditioned basement, but a builder definitely would not. In my opinion, the rating software needs to allow the user to input conditioned basements, unconditioned basements, and semiconditioned basements. Basement wall insulation needs to be assessed in all three types because it affects the heat flow through the foundation system. (in semiconditioned and unconditioned basements it affects the “delta T” between the basement and the house) Name: Mark Newey Organization: Center for Ecological Technology Amendment: ADMIN-2005-1 I think changing the effective date of the RESNET changes to match the EPA change in Energy Star standards is a great idea! Name: Tom Woltjer Organization: North Coast Electric Amendment: TECH-2005-01 If your goal is endless bureaucracy…have lots of highly technical and complex standards. If your hope is to have real energy savings…which comes from real-world market interest and support…have ONE standard that non-technical people, who make up the vast majority of those at the end of the path to actual energy savings, can understand and implement. Name: Mron Katz Amendment: TECH-2005-09 If RESNET wants to adopt the goal of minimizing “energy use” rather than maximizing “energy efficiency”, then more attention needs to be placed upon CONTROL. FOR EXAMPLE: A home with two AC units of the same efficiency will have less energy use than a home with one unit of the same efficiency. How do you want to quantify this? Name: Brian Christensen Organization: Lightly Treading, Inc. Amendment: ADMIN-2005-1 This extension is ESSENTIAL for the sake of Builders, if any of the 2005 proposed amendments are implemented at this time. They need time to adjust their construction choices to adapt to such changes, or there is a risk of mass non-compliance with programs like Energy Star. In order for Builders to be able to prepare, the Rating community needs time to start working with the CHANGED rating software. We need to show Builders how their existing practices perform on the CHANGED software, so that they have time to adapt. Given this, an early deadline for the availability of the CHANGED software is needed. January 1, 2006 would be a great choice for this software deadline… Name: Neil Leslie, P.E. Organization: Gas Technology Institute Amendment: TECH-2005-09 I am especially interested in the impact of the 100-0 HERS® score change. Score compression was a non-trivial concern at technical committee meetings, but the decision to use 80 was made to be consistent with existing rating systems at the time, and to provide a spread of scores in existing homes, among other reasons. If that argument no longer has merit, any consensus scoring method would be fine. The main benefit of the 100 score seems to be its ability to provide more granularity. I don’t know how big that factor is. One item that may add market confusion is the old 80 score would represent a significantly better score than the new 100 score in the proposed approach. There still will be an opportunity for market confusion unless all previously rated homes are given a new score by the HERS® providers. Name: Bruce Chyka Organization: Performance Plus Homes Amendment: TECH-2005-09 If the HERS® reference home has an index of 100 what will a home that does not meet the reference home requirements score? 125…150? What is the upper limit? Name: Bill Hill Organization: Air By Design Amendment: TECH-2005-09 Thank you very much for the opportunity. The expanded HERS® score appears to be good. I do not believe that most builders or customers could care less about whether their HERS® score is 86 or, perhaps 54 on the expanded scale. They just want to know whether is passes or not, and sometimes by how much. Name: Rob DeKieffer Organization: Boulder Design Alliance Amendment: TECH-2005-09 The good news in most of the stakeholders play golf, so this should be easy to understand. Name: JEFF KNUTSON Organization: A-A EXTERIORS.COM Amendment: TECH-2005-08 Crawl spaceses should be treated like basements. they should not have ventlation. In summer the hot moist air hits 50 degree foundation walls and condenses causing mold and mildue. In winter you let in cold air causing cold floors and energy loss. We make crawl spaces like basements because the have to be that way Jeff Knutson Name: Philip Fairey Organization: FSEC Amendment: TECH-2005-08 There seems to be some misunderstanding regarding what this proposed amendment DOES and DOES NOT do. It DOES NOT limit the treatment of crawlspaces in Rated homes beyond the limitations of the IRC code. It DOES NOT specify where the insulation is to be placed in the Rated home crawlspace. It DOES NOT prohibit or disallow conditioned or “semi-conditioned” crawlspaces or basements. It DOES specify that the Reference Home will have a fully vented crawlspace with insulation in the floor over the crawlspace. Thus, if the Rated Home’s crawlspace configuration is more energy efficient than this, it will receive credit for that increase in efficiency. Name: Steve Saunders Organization: TexEnergy Solutions Amendment: TECH-2005-09 I really like the idea of changing the HERS® Index and moving the reference home to 100. Name: Richard Amendment: TECH-2005-09 Name: Richard Faesy Organization: Vermont Energy Investment Corp. Amendment: TECH-2005-09 I feel that this a grave mistake to turn the rating score upside down. The common understanding in the marketplace for most everything (report card, car mileage, salary…) is that more is better. It will be very difficult to simply explain to the home buying market that lower scores actually mean better-performing homes. We need to keep our message simple and understandable. If we want to provide more definintion in rating scores, let’s report them in 0.1 increments. I believe it is much easier to understand that a score of 91.4 is good, rather than the corresponsing score of 43. A 43 is supposed to be good? Well, maybe to the engineers among us, but not to the broad, general public, which is the audience we need to keep at the top of our minds with this crucial decision. Even though the survey conducted by RESNET seems to report support for this index approach, I believe that the way it was presented was confusing and suggest that we take the results with some trepidation. If we are to change the rating score, from it’s current configuration (which I do not suggest), we at least need to present is as higher scores indicating better performance. However, I think that the best approach would be to leave it as is and require that scores be reported in 0.1 points. Name: Pat Dundon Organization: Dundon Insulation, Inc. Amendment: TECH-2005-09 I think the proposal to invert the rating scoring system and stretch it to a 0-100 limit is ludicrous. Consumers are not that smart. Several Builders are selling houses that score exactly 86. Consumers are reading their ads with the logo and believing they are getting better quality with higher scores. Many builders have learned that they can cheap it out by outting high efficiency applinces in a leaky house, and the house will still pass with an 86. It is easy to buffalo consumers now. Why would you want to throw more confusion in the mix by inverting the scale? A better solution is to advertise a higher score is a better score, and set the highest limit somewhere above 100. Zero energy could still be the best, but you don’t make someone who just spent an extra 7 or 8 grand to get an Energy Star home have to mutter and try to explain why the advertising in 2015 says a “0” is the best score, and a 90 is terrible, but his 89 house from 2003 is very very good. Or worse yet the builder who built a house that was rated in December of 2005 at 90 has to market that score in spring 2006 when the scoring system says the 90 is very poor. Why confuse the market? Not everyone lives and breathes this trivial stuff. Lots of people just want a number for comparison, and if you make those comparisons meaningless you will just lose the progress we have made so far. Raising the max from 100 to 110 or 120 is more intuitive to the disinterested and ignorant homeowner. Name: martin bakowski Organization: home performance professionals inc Amendment: TECH-2005-09 Do not change the existing scoring procedure. The existing system works and will not be improved upon by changing the procedure.This idea should wilt on the vine.Sincerely,Martin Bakowski HPP Inc. Name: Jeffrey Gephart Organization: Efficiency Vermont Amendment: TECH-2005-09 As a program implementer for Efficiency Vermont’s Vermont ENERGY STAR Homes service I have been persuading builders and home owners to build efficiently for years and see no benefit of reversing the rating score sufficient to counter the confusion that such an action would create. While it may well be true that many, if not most builders don’t really care what their point score is or share it with their buyer as long as they achieve their certification and incentive payments, most do know what the scoring structure is due to the years of effort we have made to educate them about it. In Vermont compliance with our residential energy code can be documented with an energy rating. A change in the scoring of the magnitude suggested will wreck havoc with code compliance efforts here as it will completely confuse those involved in these real estate transactions but only marginally knowledgeable about energy ratings. With the U.S. EPA/DOE ENERGY STAR Homes program making major changes to try to ensure that the issuance of their label means an efficient and durable home is what’s labeled and with RESNET expanding the rating to capture additional energy usage, these changes alone will challenge builders and program implementers charged with reaching them. Changing the scale to make lower scores better is not necessary and will prove counter productive to our efforts. I urge you to keep it simple, address the expanded score within RESNET and enable us to better address that and the EPA’s changes. Name: Frank A. Migneco Organization: EAM Associates Inc Amendment: TECH-2005-01 TECH-2005-01 At this current period of change in the national Program standard, as defined by Washington DC, it would not be in the best interest of the Rating Industry, and the end-user to impose a change as proposed by this amendment. A change of this nature should be advanced once it has more than antidotal information from the various market actors that would be affected by the discontinued use of the classic score, and an awareness and educational plan to assist the Rating Industry in making the transition as seamless as possible. To advance a change of this nature to support a limited sector of the current industry composition of the organization is at this time without merit. Name: Frank A. Migneco Organization: EAM Associates Inc Amendment: TECH-2005-09 TECH-2005-09 Being unfamiliar to the online process – we inadvertently filed the following, which has since been amended, as relating to TECH-2005-01. It applies to this Proposed Technical Amendment: TECH-2005-09. Any inconvenienced caused was not intentional. At this current period of change in the national Program standard, as defined by Washington DC, it would not be in the best interest of the Rating Industry, and the end-user to impose a change as proposed by this amendment. A change of this nature should be advanced once it has more than antidotal information from the various market actors that would be affected by the discontinued use of the classic score (inclusive of being vetted with those unfamiliar to the nomenclature, thereby absent of any preconceived bias). An awareness/educational plan to assist the Rating Industry in making the transition as seamless as possible should be part of a proposed amendment change of this type. Perhaps a HERS® Score for new construction, and a HERS® Index in the existing residential marketplace may be a solution that maintains equity to To advance a change of this nature to support a limited sector of the current industry composition of the organization is at this time without merit. Name: Don Swift Organization: MaGrann Associates Amendment: TECH-2005-09 With the large majority of the MaGrann ratings being performed for Energy Star compliance and builders being only concerned with acheiving a qualifying score of 86.0+, it does not matter if the actual score is 86.1 or 86.2 or higher. The other small portion of ratings we perform are for homeowners that want to decrease their energy comsumption, again the actual score does not really matter, only the percentage of enery usage reduction matters. Under the current scoring system it has to be expained that each 1 point represents 5% energy comsumption. If the current scoring system remains or it is changed to the index, we will still be rating to a threshold (83.0 points) and talking to homeowners about percent reductions. The only difference would be that the index, even with lower is better, appears that it would be easier for the average homeowner to understand. Organization: NYSERDA Amendment: TECH-2005-09 The following is a copy of a letter submitted by NYSERDA to RESNET concerning Proposal TECH-2005-09. September 30, 2005 Steve Baden Executive Director Residential Energy Services Network P.O. Box 4561 Oceanside, CA 92052-4561 Dear Mr. Baden: The New York State Energy Research and Development Authority (NYSERDA) is providing comments, through this letter, on RESNET’s proposal to revise the Home Energy Rating System (HERS) scoring system from the current model to a “HERS® Index”. NYSERDA supports the need for RESNET to enhance the scoring system to reflect energy consumption rather than energy efficiency, however, the proposed change to the scoring system from an ascending to descending scale will only confuse the mid-stream and end users of the ENERGY STAR® Labeled Homes Program, not simplify the system. NYSERDA, realtors, homeowners, raters and over 300 ENERGY STAR builders in New York have supported and promoted the ENERGY STAR platform throughout New York State for the past seven years and have successfully constructed more than 6,000 ENERGY STAR® homes. In 2004, NYSERDA’s annual production of ENERGY STAR® Homes exceeds 10% of the market share for single-family new construction in New York State. These homes have historically not only exceeded the national specifications but, in 2005, include a hybrid approach that is based on a fixed HERS® score AND a prescriptive set of performance standards. NYSERDA strongly opposes the recent RESNET proposal to revise the system as stated due to the confusion that will occur within the housing market. Realtors, builders and HERS® raters market and promote these homes on the current ascending scoring system, and homeowners are familiar with and understand that a high score relates to a “better than average home”. To the general public “less” is not “more”. Society accepts and recognizes the fact that an ascending numeric scoring system typically promotes improvement. The amount of training and programming that will be necessary to align all parties involved will be an enormous lift and require a complete reversal of logical analysis. NYSERDA recommends RESNET keep the current ascending scoring system in place for the following reasons: *It is fully vetted (i.e. it is familiar to the builder, rater, homeowner, realtor); *It has been well established and in use for over a decade; *It is logical (i.e. it is ascending where a score of 100 is the best); and *Inverting the scale would be counter intuitive (i.e. how do you explain that a low score is best). The RESNET proposal states it is designed to anticipate more inclusive and complete energy assessments of homes for decades to come that will not require further change in the fundamental rating scale. NYSERDA strongly asserts that consistency encourages participation. When marketing a product within an industry where a higher score means better insulation R-values, HVAC AFUE and SEER ratings, etc. (the exception being windows), perception by the consumer of the product will be highly scrutinized when marketing “zero means zero” except to those who can decipher the true meaning. It is unclear how a descending 100 point scale where “0” is best will be better able to anticipate “more inclusive and complete energy assessments of homes” than the ascending 100 point incremental scale currently in place. It would seem that the ascending scoring system would have similar flexibility as the descending system and be as fundamentally equipped to incorporate any future enhancements. NYSERDA thanks RESNET for the opportunity to comment on the proposed amendment to modify the HERS® score calculation and change its nomenclature from “HERS® Score” to “HERS® Index”. Please contact me or NYSERDA’s Single Family Homes Program Manager Andrew Fisk at (518) 862-1090 ext. 3351 with any questions regarding these comments. Sincerely, Rick Gerardi, Director Residential Programs cc: Andrew Fisk (NYSERDA) Name: Ethan MacCormick Organization: Performance Systems Development Amendment: TECH-2005-09 I oppose the change to a “100-0” HERS® index. I feel that the current method better reflects the relationship between a “decent” home (80) to a superior home (higher score). When consumers/builders can correlate it to grades, a “B-” house makes sense as one meeting code, and a “B+” or an “A-” (88 or 91, for example) makes sense as a superior house. In general, the correlation between “better” and lower numbers is counterintuitive. I have a contractor/designer who specifies windows with “a minimum U-factor of .35” In my own reading of the survey, I see that respondents were asked to decide which method best represented (e.g.) 20% less energy consumption. They weren’t asked to say which method would represent a home that is 20% more efficient. I think if they were asked which better indicated a better home, they would choose something that showed a higher score for that home compared to a standard home. For those of my builders who care about score vs. thresholds, they take pride in getting higher scores. The 200 graduations between 80 and 100 are more than sufficient for the tolerances of a rating. I do appreciate the confusion relating to score differences between the old and new methodology; 84 (new) might be better than 85 (old) but with the elimination of the “Classic” score, it will be simple to explain that the new score accounts for all the energy consumption, and the old score did not. Name: Richard Faesy Organization: VEIC Amendment: TECH-2005-09 If I may, I would like to submit an additional comment that I think the RESNET Board needs to address before making any changes to the rating score. Is there a compelling reason why we need to change the score? I suggest that there needs to be a very strong case made that we NEED to change, before embarking on making any changes to the rating system. Name: Patrick Haller Organization: Vermont Energy Investment Corporation Amendment: TECH-2005-09 Thank you for taking my comments into consideration. I would like to first be sure to note that this comment is supported by a group of people at VEIC doing business as Efficiency Vermont, and working in partnership with Vermont Gas Systems in delivering the Vermont Energy Star Home Service (VESH). The technical standard to create a rating index to be significantly different from the existing HERS® score could set us back several years in our educating builders about standard and threshold scores, and be at a cost of realized energy savings, and significant financial resources of rating providers such as VEIC. We have three points to make, the first being difficulties in managing and explaining very different scoring points, the second being the lack of intuitiveness of “flipping” the score from highest being most efficient to lowest being most efficient, and the third being mis-timed adoption while EPA has significantly modified the requirements of Estar labeling. Each point will be taken in turn below: Point 1, Managing and explaining very different scores We have over 1000 active builders in Vermont, few building more than 4 homes per year. We also have a state energy code that offers a HER as a track to meet code. With respect to the code, the state energy office has been slow to adopt changes to code and after recently describing that there may be a new HERS® scoring system and that 82 points will not be the code compliance score, the State rejected the propsect of amending the existing code in less than a year. Their grounds are the simple lack of sufficient resources and the numerous competing priorities of the State legislature. Our agreement with the state is now to find a solution, a bypass of some sort, after all of the HERS® changes and EStar changes are known. Not only will we be forced to find a non-linear solution, we are forced to delay the solution until RESNET and EPA formally have the same baseline score. This is related to Point 3 With regard to builders, working with the large numbers of builders to educate them about a very different scoring system is unrealistic, especially at the same time as the Energy Star changes (point 3). Builders, as most people, resist change but if the changes are seamless or at least minor, then the discussions and reinforcement can make the changes understandable. Over the last 8 years builders have come to understand the nature of ratings and various thresholds. This new indexing score is going to reduce our ability to reinforce our long standing messages without confusing their basis. We expect to lose participation due to this confusion. If the bar were simply being raised and participation decreased due to a higher standard, that would be acceptable. Decrease due to confusing changes is not acceptable. Our attempts to make the changes as understandable as possible poses many financial burdens on us. Financially this is going to be costly. There will need to be increased labor time in working with builders directly to explain the sytem – many times, costs to create and print literature to capture the audience and create awareness and understanding, costs to expedite the message to meet the timeline for Estar changes but having to wait for RESNET changes, etc. Point 2 Lack of intuitiveness of a “flipped” score. We continue to be stunned with the decision to create a system where the lower the score, the better the effiency. We have heard the logic at various times that it only makes sense to have a Net Zero home to have a rating Score (Index) of Zero, or similar arguments that less energy use would equate to a lesser score. In black and white, these arguments are logical. However, in various grading systems we have been conditioned to strive to achieve the highest “Rating” number, or “Scoring” number. We have been teaching the building community this same message. They would rather hear they got a score of 90 points than a score of 50. I would rather get a 90 on the RESNET rater test than a 10. The cause to rethink what scores mean will cost our staff substantial time to introduce the concept and reinforce the concept to the very large pool of professionals in our state. Again, much ground could be lost. Point 3 Mis-timed with EPA’s Energy Star changes All in all, the vast changes in EPA’s Estar Qualified homes is by far the highest priority for HERS® providers. Since the initial proposal this spring we have been effectively on call to react to the changes as quickly as possible in order to support our builders and, in Vermont, to support our State’s Energy Efficiency Utility and it’s energy savings targets for 2006. Although we now have the “Final” requirements for Energy Star labeling of homes, we do not have the ability to deliver a clear and consistant message to the building community (code officials included) since the RESNET indexing score has been proposed but will not be finalized for a month or more. How are we to introduce the new EStar performance path without the high risk of confusing our builders in the very near future? How are we to create appropriate marketing materials, energy code solutions, etc. unless we wait until RESNET (and in-step EPA) adopt a new scoring system? Much time will be squandered in the interim between EPA’s announcement of their changes and RESNET’s changing of the rating score. We currently do not feel comfortable in introducing the EPA’s changes because the scoring system that we have exclusively been using to show ESTAR compliance is radically changing. Providers like us don’t have enough information to give to our customers to properly craft the correct message. The solution: “Give them BOPs” is not entirely applicable to providers that have such disparate customers as we do. Efficiency Vermont has never had a BOP package. We intend to move to BOPs incrementally but we need a clear performance path as well. The performance path is a very important tool for us. In the least, it assists us in ushering builders and contracters from mere code compliant homes to higher performance homes. We see BOPs as a very good delivery mechanism for “proven” builders, but not the best scenario for many of our customers that build infrequently and rely heavily upon our support. Thank you for considering these points. Sincerly, Patrick Haller Residential New Construction Market Manager Efficiency Vermont Vermont Energy Investment Corporation Name: Rita Ransom Organization: Southwest Gas Corporatopm Amendment: TECH-2005-09 Here are comments on behalf of Southwest Gas Corporation, the HERS® provider for Energy Advantage PLUS in Tucson, AZ. We are in agreement with the amendments, as they would have little, if any, effect in Tucson where improved building practices and better equipment and materials have become the norm, and HERS® scores continue to be meaningless. Rating point and star scores have never had any traction in Tucson so an expanded HERS® score would remain meaningless in the majority of cases. Builders are concerned only with whether they “pass” or not (usually ENERGY STAR) and do not use their rating in the sales process to differentiate their homes. If however, a builder did choose to market the point score, the revised system may be easier to explain in that the less energy the home uses, the lower the score. Consumers are an unpredictable lot, so it remains to be seen! We believe it makes sense to implement the new amendments at the same time the new ENERGY STAR guidelines go into effect; however, the same grandfather period should also be allowed for consistency with ENERGY STAR. We have recommended at least one year of grandfathering. Thanks for the opportunity to comment. Please contact me if there are any questions. Name: Adam Gifford Organization: Conservation Services Group Amendment: TECH-2005-09 I’m actually a proponent of the change; it just strikes me as being more sensible in it’s linkage to the scores of 0 and 100, rather than to a comparitively random 80. Right now, a HERS® score of 0 means that the house uses 400% more energy than the reference home. That just doesn’t make sense to me. With the new methodology, 0 would represent the threshold between varying amounts of net energy use (positive numbers) and net energy production (negative numbers). It’s more “metric” in thinking. Some people seem to be worried about having to explain the change to “builders”, “consumers” and the “home buying market”. I would argue that the only people that really need to understand this change would be HERS® raters, and that the actual HERS® score means so much less to anyone else that it doesn’t deserve nearly the same amount of consideration. In my opinion, the change would be nearly invisible to anyone who isn’t directly plugged into the rating industry. Even if you don’t share this opinion, you can still communicate with your clients using more of a report card-like approach by saying that the home is approximately __% better or more efficient than code (rather than simply telling them a score). ENERGY STAR homes will still be approximately 30% better than code minimum, regardless of the scoring methodology. A certain % beyond code would certainly convey more information than the HERS® score (which requires a lengthy explanation – again – regardless of the scoring methodology). Name: Bruce Harley Organization: Conservation Services Group Amendment: TECH-2005-09 I disagree with Richard’s comments on the RESNET web site that the survey that was done was confusing. The current scoring scheme and the proposed index were shown graphically, with simple descriptions, like “your home uses twice as much as the American Standard home” or “your house uses half as much as the American Standard home.” Ratings don’t mean anything to consumers–most have never even heard of them. If they are to become meaningful, then simple graphical representations really are a good tool–these are like the ones on the energy guide labels on appliances (only I think the way the ones in the RESNET survey were done were much more understandable). The fact is, that an overwhelming majority of people who were previously unfamiliar with HERS® understood and preferred the index over the present score method. Even a majority of those who were familiar with HERS® (who were presumably biased against change) chose the index. As for me (the proponent of the third option from the survey)–I expected to like my own proposal better, but when I took the survey and saw it in graphical terms, I had to choose the proposed index option. I was surprised, but it really made the most sense visually. I really don’t see this as an “engineers vs. regular people” issue–I see it as a “status quo vs.change for the better” issue. When you explain it in words, a score might be easier to understand. But when you put it in a one-bar graph like a thermometer, it’s so simple. I encourage people to look at the survey questions, graphics, and results at I encourage people to look at the survey questions, graphics, and results at I encourage people to look for themselves at the survey questions, graphics, and results at http://www.natresnet.org/hotnews/amendments/survey.pdf. The complaint that people who are already familiar with HERS® will have to re-orient themselves is valid–except when you consider that they will have to re-orient themselves anyway. All the scores will change and shift, and even some of the signals that affect scores will change relative to each other. Those of us who have HERS-score tied code compliance (VT and MA for example) will have to change the numeric value for code compliance anyway. Folks are going to be confused anyway, and we’ll have to explain the changes anyway. If we’re going to do anything like this, now is the time. In fact, explaining the changes from a score to an index may help us divert attention from some of the more arcane technical reasons for the changes–which are GOING to happen, and have already been approved, regardless of the outcome on this particular issue. One way to help make this transition, and to address the idea of “more is better”, would be to get away from thinking of it as a score. It’s not a “score” at all. Express it as a “standardized measure of how much energy your home uses.” Then folks will really get that lower is better. We shouldn’t avoid change because it’s inconvenient–we should look at how we can use the changes that are already happening to leverage HERS® ratings to be more understandable, and potentially more valuable, to a general population that we’re hoping someday will actually pay attention to ratings.
