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By understanding how much energy an older home needs for heating, cooling and other uses, consumers can make more informed choices — whether they are in the market for a new home or thinking about making improvements to their own.
However, the plan will meet with greater success if it avoids certain pitfalls, NAHB told the agency, and avails itself of existing programs that have proven successful and credible. Among the association's recommendations:
- Labeling. NAHB suggests that DOE look at its own Builders Challenge EnergySmart Home Scale (E-Scale), an easy-to-read tool for home buyers and home owners to determine the energy efficiency of the home and that is uniform, credible and marketable.
NAHB also urged the agency to use a modified E-Scale as the basis for an energy performance label for existing housing, including broadening the scale to a score of at least 250 to accommodate older, existing homes that tend to be less energy-efficient than new homes.
NAHB also suggests that DOE employ commercially available software rather than developing specialized software and to require the National Renewable Energy Laboratory to establish a benchmark to meet specific criteria for retrofit energy analysis.
- Auditing and Testing. Currently, the DOE rating program does not specify a full-blow audit using blower door, duct blaster or other testing. But if DOE does consider an expanded audit for compliance, NAHB suggests the option of sampling — rather than requiring before-and-after tests of every home — which can significantly increase expenses associated with retrofit projects and diminish the overall effectiveness of the program.
“DOE should recognize that any requirement for two energy audits (test-in/test-out) per home would be an expensive process that would consume a considerable portion of any rebate,” the comments said.
In addition, any list of contractors approved to do the testing should encompass a number of approved providers, including the Home Builders Institute, RESNET (Residential Energy Services Network) and established state programs, as well as the Building Performance Institute (BPI), as named in the proposal.
“NAHB would also urge DOE to evaluate and approve a retrofit training curriculum using quality assurance metrics developed by HBI, BPI, RESNET or a state-approved equivalent,” the comments said.
- Home Registry. DOE has proposed creating a National Building Performance Registry to make detailed information about a home’s efficiency available to lenders. “NAHB can support a national registry if it is not duplicative of existing provider (RESNET, BPI, HBI, etc.) registries/databases,” the comments said.
“NAHB also wants to minimize administrative burdens on contractors, auditors and providers as they fulfill the data-entry requirements by making certain that DOE specifies the minimum data requirements for registries,” the comments said.
In addition, “NAHB supports allowing the data to be available to all and not become the sequestered or proprietary property of DOE. There is a great benefit in DOE providing access to national registry/databases for retrofit data analysis and program review purposes,” the comments said.
- Training, Certification. NAHB asked the agency to ensure that a variety of different certification programs be qualified for a remodeler or contractor to do weatherization work and energy-efficiency improvements to ensure “a sufficient number of certified contractors, as well as to recognize the variety of factors, expertise and competencies needed for retrofit activities across the country,” the comments said.
The goal of any training program should be to ensure that the activities are performed correctly, without requiring unnecessary certifications for activities that will not be performed, or that are already well understood. DOE should accept any energy-efficiency program accepted by a state energy agency or offered by a state or local HBA to be deemed sufficient under any federal energy-retrofit program,” the comments said.
For more information, e-mail John Ritterpusch at NAHB, or call him at 800-368-5242 x8325.