TEST Draft PDS-01, MINHERS Addendum 46, Sampling Update (Comment opens July 24, 2023)

testing country code issue

Test

The increase of 30-days to 90-days within a sample set is a great improvement as construction has changed drastically in the past few years.
Arranging the sample set by stage of construction though seems complicated. For production builders, the timeline for each stage of construction per home can vary dramatically. Trying to track each home's progress and then rearrange sample sets based on that would be a large undertaking. For example, we have one builder that currently has over 600 active homes. Rearranging sample sets constantly would be difficult.
Some builders also do not release a schedule when they release a start to us. This would mean we could not create a sample set for those homes until the schedule is released.
Builder's are also notorious for not having accurate construction schedules. Even though most use scheduling software , the reality is probably 90% or more of it is inaccurate. Depending on the superintendents ability to keep schedules updated, or even answer their phones, for a Rater to be able to create accurate sample sets is going to create problems.
Also, the inconsistency of construction stage could affect the sample plan. We price based on sample set size at the beginning of a community. With the flexibility of construction stage, and depending on the market, this could mean batches could be smaller which would change our sampling rate.
Though we understand where this idea of sample set by construction is coming from, applying it with the current inconsistent production building schedules is going to make creating sample sets complicated and time consuming.
Many production builders release houses in batches for construction. Creating sample sets by start date, a fixed date, instead of construction stage, a flexible date, seems the best way.

A group of Dwelling Units at the same stage of construction (e.g., pre-drywall, final) within a 90-day period that the Sampling rate is applied to.

A group of Dwelling Units with a start date within a 90-day period that the Sampling rate is applied to.

Remove this section

606.2.1

A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature prior to conducting a Qualification Set for each Sampled Feature.

to determine if a project is ready to qualify for sampling is a good practice but seems overly burdensome to require it

606.2.1   

A builder or developer shall complete and have verified the installation of a minimum of five (5) of each Sampled Feature prior to conducting a Qualification Set for each Sampled Feature.

This section uses the word "chapter" the changes to "standard".  A chapter does not establish procedures, a standard does.  The more correct word to use is "standard".

600.2 Scope

This chapter standard establishes the procedures for energy modeling, labeling, inspections, testing, quality assurance by Sampling Providers, and Sampling Provider Accreditation criteria as they pertain to Sampling.  The procedures described in this chapter are applicable to the following Dwelling Units:

• single family homes (attached and detached)
• units within a multifamily building or within multiple buildings.

This chapter standard does not provide any warranty, either explicit or implied, that Sampled Dwelling Units will meet or exceed the Threshold Specifications for the Sample Set. There may be instances in which local laws or regulations differ from these Standards. In such instances, local law or regulation shall take precedence over this standard.

The proposed addendum does not address the implementation timeline for the changes.  Since many projects that pursue sampling have a long design and construction period, and Rating companies are already contracted to pursue sampling on projects that have not started construction. It is important that a clear implementation timeline be implemented so that Raters and project teams can account for this and that projects do not incur additional costs due to these amendments.

Please see the attached pdf & word doc with multiple comments.