While I was originally planning to do a Clif Notes version of the Workforce Guidelines, that idea was looking less & less likely after hitting two pages of notes. When I was less than 200 pages in & a computer problem destroyed over three pages of notes, the idea officially hit the scrap bin. As a reminder, the NRRG (National Residential Retrofit Guidelines) is part of the Recovery through Retrofit program and is open for Public Comment until January 7th.
Leaving a public comment:
Unlike other items that go through the Federal Registrar, this one is exempt as it is a “voluntary” guideline. In order to comment you must visit DOE’s website, register and then choose how you wish to respond. The main option that comes up first (as shown in the main picture) is to comment on each applicable section. The option we choose was to address the whole document (link is on the right of the page). I really do like how they laid this out, but the 1500 character limit might pose an issue.
As is our custom, we have attached a copy of our Public Comment below and we encourage everyone else impacted for the better or worse to leave a comment.
Our Public Comment:
I must admit, when I first heard about this program via a webinar in earlier August it really sounded great. As I started writing up the original blog article on it, I was actually optimistic. When I started reviewing the few pages provided during the seminar some major issues popped up. Now, after reading through and reviewing all 632 pages, I think I have boiled down almost all the issues in the document into two simple problems that might also help explain the bulk of the issues you are facing with your current systems.
Reinventing the wheel:
Seriously, why are you trying to reinvent the wheel? While trying to listen into your “training” webcast today one slide caught my attention where you list that “Government and industry cannot keep putting money into retrofit programs and workforce training without; Work Quality Guidelines, Work Force Competency Guidelines, and Training Program Accreditation” which this document is supposed to help correct. The last line item we can simply eliminate as both BPI & RESNET have received said “accreditation” as of a few months ago.
While you list “Work Quality Guidelines” as a major issue, and a primary driving force for this document, many of them listed are simply not realistic (i.e. one quick example – venting can’t always point to the exit directly as reality has something to say about that) nor do some of them even meet current codes. While reviewing this document I had over three pages of code & reality issues before I even hit section 5. What is even more startling is the building codes were only listed once in any of the “guidelines” and obtaining a building permit or inspection was never listed. If you truly want “Work Quality Guidelines” that you can apply across the entire “weatherization” and government sponsored retrofits programs, may I humbly suggest that you simply adopt the 2009 IECC (which all states that took stimulus money are supposed to be adopting), the 2009 IRC, and other applicable codebooks and manufacturer’s directions. You know would have your quality guidelines that can easily be adopted nationwide, and actually be seen as a leader. Just like local jurisdictions, if there is a section that you think could be better, is not needed, etc… than modify it and add it as your minimum standard that applies to said programs.
The final issue you bring up is the “Workforce Competency” which in all honesty is an insult to the hundreds of thousands of trade professionals out there. There are two working systems out there that deal with this and employee advancement; the unions and their apprenticeship programs, and in the real world a little thing, we like to call OJT (On the Job Training). While there are numerous causes of bad workmanship, two stick out in regards to the Weatherization program. The first is you are trying to reinvent the wheel again. See in the real world, I as a General Contractor, would hire specialty trade contractors for the work we did not accomplish / not qualified to do, and call for inspections. In your case, well we now get to the second root problem…
Jack-of-all-trades, masters of none:
Except for “licensed electricians”, there is not a single listing for any other licensed trade or contractor in the entire document. Most state programs I have seen are based on one company coming in & doing all this weatherization work. The issue with this is, most of these individuals never get an opportunity to really learn one trade and why things are done a certain way, much less the four or five other trades worth of work they may try to do in a day. The kicker is if a regular contractor tried to do this (especially with no permits), they would be in some legal hot water. One quick example is that in many states including mine, only a licensed HVAC company can touch, maintain, diagnose, or repair any duct or ventilation system and the associated equipment.
I know one of your primary goals is to help come up with a training and certification that individuals can use to advance their careers. I can quite simply tell you and so can many others; there is no amount of classroom training that can replace the experience one gains working in the field. I have been in the field for over 20 years now & I can tell you I do not know it all, nor have I seen it all yet. While it is laudable that you want to add 250,000 or whatever “green” jobs, the only training that truly matters, is learned in the field.
Health & Safety Issues:
Safety first, do no harm, etc… are great mantras, but unfortunately lacking when one looks into the details. Beside the points made above, the biggest one revolves around gas-fired appliances. As one individual, so eloquently put it “That being said, CAZ testing is a new frontier for energy auditors and folks like me who were involved in this project. We took the BPI guidelines to read straight up, when in reality, practice, and academia, the vagueness of the document produced by BPI for CAZ testing, has created much confusion. The basics are understood by most, that is not the issue here, it is the protocol.”
I cannot tell you how many YouTube videos I have seen where “trained” individuals are doing it wrong, (i.e. drilling into PVC exhaust vents, double walled venting & then sealing it improperly, etc…)or in my case where instructors miss a part or simply contradict one another, etc… In all honesty, the testing of the actual appliances for CO, spillage, and drafting needs to be done by a licensed individual. The worst case test, visual checks, CO monitoring & gas leak checks are about the only thing most “trained” auditors should even attempt or do.
This of course leads me to some important questions I think need to be answered; why is the yearly maintenance of a furnace listed under Energy Efficiency, but not under Health & Safety? Why isn’t a proper tune-up & maintenance a requirement of any program? Why are you leaving out a trained individual with experience that will probably notice a venting issue, or problem that many “certified” individuals would miss? Why are you allowing people with no background in this arena to drill into vent stacks, furnaces, and other items that they do not even know how to properly seal? If testing all these items is so important for an occupant’s health and safety, why are we not pushing for them to be done as part of their yearly maintenance, instead of just once when an “Energy Audit” is done? (Last I checked, more furnaces, boilers, etc… get an annual checkup than houses get an energy audit)
While I truly do believe a guide like this is necessary for your programs only, this one is truly overkill and unfortunately a big mess. You could quite easily create this guide in 30 to 50 pages by trimming up a lot of the fat. For example – the Safe Work Practices is repeated at least 8 times resulting in at least 32 pages worth of info that is the same. Many of the other “practices” are just repeating the same old information seen in a prior page also, with only a line or two of applicable information.
As mentioned above, you should adopt the 2009 IECC as your primary standard and adapt it to meet your goals. All you would need to do is put a reference to the applicable section or your modifications and move on. The nice part about the 2009 IECC is that your agency has already made it available for anyone to download free so that does not put a burden on anyone. The other great thing with adopting that code, is now you will have a group of individuals in each state to help them adopt it, when they fulfill there part of the stimulus bargain.
Another idea along the same lines is to adopt your own ENERGY STAR program for older homes and tie it into the retrofit market. As a, we can easily rate a house to get an appropriate number and verify work that is done. Now you have not only a specialized trained rater verifying the work but a trusted number and name that is still lacking in your current program.
I do love one saying from Microsoft & that is how they eat their own dog food (in this case they beta test the software they create in house first). If you truly want this field to take off, you need to start practicing what you preach & even share the results. I really cannot believe when I walk into one of your buildings, another agency, and simply look up or out at the desks and see older fluorescents & incandescent light bulbs among other issues tends to send the wrong message.