11/17/2017 Comments from Wrightsoft Corporation
Comments on Energy Simulation Tool Approval Technical Assistance Manual, November 15, 2017
These comments address Appendix R-6, Energy Rating Index Alternative Method, Pages R-47 – R-63.
1. TAM Section 6.3 refers to a results spreadsheet (Florida ERI-Test_Results-form.xlsx) that ERI software is required to submit for acceptance, but the spreadsheet is not available. Because Section 6.3 contains multiple undocumented criteria and methods presumably behind the spreadsheet, it is premature to issue this Section R406 of the TAM for approval. Since the authors of the acceptance criteria are also vendors of Energy Gauge, this creates an unfair advantage for our competitors.
Answer:
The spreadsheet was submitted with
the TAM. DBPR did not share the link in
the agenda. It is here: http://www.fsec.ucf.edu/download/tam2017/
2. The author of the TAM (Florida Solar Energy Center) has converted the R406 ERI report to a RESNET HERS document based on Energy Gauge and can only be provided by a RESNET Rater. This action excludes ERI Raters certified by other organizations than RESNET. Section R406 of the Florida Code makes no mention of RESNET or HERS:
Answer:
FEC Section R406.4 indicates “The
rated design shall be determined in accordance with ANSI/RESNET/ICC 301,
including Addendum a-2015 and be shown to have an ERI less than or equal to the
appropriate value in Table R406.4”.
Under ANSI/RESNET/ICC 301 – 2014
Section 5.1.3 Reports
Per ANSI/RESNET/ICC 301 – 2014,
Section 5.1.3.2 The name of the certified rater conducting the rating.
Section 5.1.3.3 The name of the
Approved Rating Provider under whose auspices the rater is certified.
Section 5.1.3.6 The following statement in no less than 10 point font, “The Home Energy Rating Standard Disclosure for this home is available from the Rating Provider.: At a minimum, this statement shall also include the Rating Provider’s mailing address and phone number.
§ The sample report (Form R406-2017) provided on page R-58 uses a RESNET copyrighted HERS graphic that can only be used by a RESNET-approved software vendor.
Answer:
The RESNET logo is optional and software vendors are not expected to create exact copy of the report sample forms and format.
§ The Rating Provider section of the form shows a location for a seal, “Insert RESNET Rating Provider Seal Here”, “RESNET QA PROVIDER”, “The Home Energy Rating Standard Disclosure for this home is available from the Rating Provider.”
Answer:
This is an example report. For other approved third parties it could be something else.
§ Finally, “To determine if a provider is properly accredited go to: www.resnet.us/professional/programs/search_directory.
Answer:
We recommend a link to where building officials can find the approved third party provider consistent with ANSI/RESNET/ICC 301. It would not need to be the link shown in the sample report.
3. According to recommendations in Section R6.6, “large variance” from the sample reports provided “is not recommended”. Since the sample reports are slightly modified versions of existing Energy Gauge ERI reports and contain additional data not required by ANSI 301 reports, the TAM is forcing competitors of Energy Gauge to use their format and their preferred data presentation even if the RESNET HERS references are removed. Since the Energy Gauge documents are already generated, other vendors are forced to invest in new development to match up with Energy Gauge documents. This gives an unfair advantage to Florida Solar Energy Center.
These reports should be reviewed and revised to conform to actual reporting requirements required by the Florida Code.
Answer:
The TAM acknowledges that variation are expected but large variation is not recommended for convenience to the code officials. Ultimately it is up to the software vendor to assure it meets the minimum requirements and can optionally look like the one in the TAM. There was no intention that the ERI report has to look just like the sample provided. Perhaps the next code mod cycle could provide a report format. The ERI report shown is three pages. Although pages 1 and 2 were modeled after ones in EnergyGauge, there is no three-page report like this in EnergyGauge. Two alternative page three reports are provided based on the unique Florida exceptions for on-site renewable energy. It would be our recommendation that the TAC be flexible to minimize work by other vendors and accept ERI reports that provide all the information required by the code without requiring vendors to match this format.