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Quality Assurance and the (R406) ERI

Quality Assurance and the (R406) ERI

I’ve heard recently some disturbing news: that the R406 ERI compliance path in the 2015, 2018, 2021, and now 2024 IECC Residential Codes do NOT require quality assurance.

First: that’s news to me.

Second: that’s a bold-faced lie if I ever heard it.

Let me provide some background if you’re unfamiliar with the R406 ERI. The International Energy Conservation Code (IECC) added a compliance path called the R406 Energy Rating Index (ERI) starting in the 2015 IECC. This compliance path uses a snapshot of the ANSI 301 Standard, with some tweaks.

This allows jurisdictions to have a performance path and builders get more flexibility. Which they almost always appreciate. It also means there is a consistent calculation (in theory) for that specific compliance path – as the ANSI 301 Standard is a “constant maintenance” standard, receiving addenda and the possibility of modifications after a publication date. So rather than having the calculation modified a year after the code is adopted, it is consistent throughout a given three-year cycle.

Very nice!

Importantly, the code specifically references ANSI 301 in R406.4, and if you have a copy with commentary, it’ll tell you that in the added language.

And then it starts using language such as “confirmed as-built dwelling unit”. This is used a couple times in R405, but almost all uses of it occur in Section R406.

Here are some examples I’ve pulled from the 2021 and 2024 IECC:

Here you can see that “confirmed” is mentioned as part of the R406.5 ERI-based compliance. But you know what isn’t found? A definition for the term “confirmed”.

That’s because it is pulled directly from ANSI 301, that standard that underpins this specific compliance path. Let’s take a gander at what ANSI 301-2022 defines a “Confirmed” rating as:

That definition seems fairly cohesive with what we see in the R406 Compliance path, no? A “confirmed rating” appears equivalent to a “confirmed, as-built dwelling unit”. To me, that means a “confirmed compliance report” will necessarily need to comply with ANSI 301’s requirements for a confirmed report and label.

Since it appears that the R406 ERI compliance path concurs with the ANSI 301 Standard’s definition of Confirmed, let’s see what else is required of a confirmed rating…

Wait, what’s this: a confirmed rating shall be subjected to Quality Assurance requirements?

But I was reliably informed that such as thing was NOT required in ANSI 301, let alone the R406 compliance path!

Look, at this point maybe ask yourself some questions. Like:

  • Who is this message about the “lack of QA in R406” coming from?
  • Why is this particular message being spread?
  • What could the messenger possibly gain by spreading it?

And if it appears that there is a push to require a proprietary variant of the ANSI 301 Standard, rather than the continuous maintenance of ANSI 301, maybe the messenger isn’t sharing it for good cause…

Until next time!

Citations:

  1. 2024 IECC: https://codes.iccsafe.org/content/IECC2024P1/chapter-4-re-residential-energy-efficiency#IECC2024P1_RE_Ch04_SecR406
  2. 2021 IECC: https://codes.iccsafe.org/content/IECC2021V1.0/chapter-4-re-residential-energy-efficiency#IECC2021V1.0_RE_Ch04_SecR406.1
  3. ANSI 301-2022: https://codes.iccsafe.org/content/RESNET3012022P1/chapter-7-certification-and-labeling

Notes:

  1. You may hear in response to this informative post that no, in fact there has NEVER been a QA requirement for the R406 compliance path. I can tell you from personal experience that since the 2015 IECC included it, Verifiers were mandated by the oversight entities they operated under to register any R406 ERI projects with their oversight entity’s Registry. You would be able to generate final compliance reports for the Prescriptive, Performance, and UA paths, but you could NOT do that for the R406 ERI unless it was registered – hence the term “confirmed” was included. Whether that has changed in the last year and a half is irrelevant – the expectation was always that additional QA would be performed on an R406 ERI project due to the requirements of ANSI 301 itself. So even if the R406 ERI compliance path itself didn’t require it, the oversight entities wouldn’t allow software tools to generate an R406 ERI confirmed certificate unless it was registered with them. The more you know!
  2. And for what it’s worth, any project pursuing R406 ERI compliance under BSI has always and will always receive oversight from BSI, due exactly to the language found in ANSI 301 regarding requirements on confirmed ratings. As an EPA- and DOE-recognized National Home Certification Organization (HCO), we are considered an Approved Rating Provider, since the EPA and DOE are actual regulatory bodies and not some self-appointed organization.
  3. Shameless plug: if you’re interested in learning more about the history of home energy rating systems, check out our page!

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BUILDING SCIENCE INSTITUTE, LTD. CO. RECEIVES RECOGNITION BY THE EPA AS AN ENERGY STAR® HOME CERTIFICATION ORGANIZATION

Professional Quality Management For The Energy Rating Industry

[SAN ANTONIO, TX, MAY 18, 2022] — The Building Science Institute, Ltd. Co. has been recognized by the Environmental Protection Agency as an ENERGY STAR® Home Certification Organization with responsibility to provide quality management and certification oversight for the ENERGY STAR New Homes program. For the first time since 1995, verification organizations and homebuilders have a choice for professional quality management oversight in the energy rating industry.

ENERGY STAR certified homes and apartments are designed and built to deliver peace of mind, improved comfort, enduring quality, and energy efficiency. The ENERGY STAR label is a symbol of trust, quality, and responsible environmental stewardship recognized by consumers, manufacturers, and homebuilders.

Home Certification Organizations, such as the Building Science Institute, Ltd. Co., are independent organizations recognized by the EPA to implement an ENERGY STAR certification program based on the ENERGY STAR Residential New Construction program requirements for single-family and multifamily homes and apartments.

“We deliver greater consistency, transparency, and confidence to our clients through our robust quality management system based on internationally recognized standards,” said General Manager Brett Dillon. “We are thrilled to offer the industry a choice for the first time in almost 30 years.”

Brett is the former chair of the committee responsible for writing the American National Standards for Energy Rating Index calculations, inspections, and testing. 

The Building Science Institute, Ltd. Co. was created to improve the quality, consistency, and impartiality of the energy efficiency certification industry and, as members of the American Society for Quality, the team is focused on improving the process to deliver professional quality management.

To ensure consistency in the home certification program, the Building Science Institute partnered with HouseRater, a software development company based in Minnesota. HouseRater uses EnergyPlus, a calculation engine developed by the Department of Energy at the National Renewable Energy Laboratory, to produce the code compliance calculations and the Energy Rating Index (ERI) for the ENERGY STAR home certification program.

“At HouseRater, we’ve worked closely with the Building Science Institute’s Quality Council to develop the tools to support BSI’s mission. We’re excited to offer the first comprehensive software solution. From project creation, scheduling site visits, performing inspections, generating and sending inspection reports, to final ENERGY STAR verification, BSI’s clients can do it all in HouseRater.” said Erik Straite, business development manager for HouseRater.

The Building Science Institute’s ENERGY STAR certification program is guided by the Institute’s Quality Council, a group of industry experts charged with independent oversight of the program.

The Quality Council members are Col. Kevin Burk, US Army (Ret.), CEO of RK Burk Consulting, Inc.; Amber Wood, Director of Buildings at the American Council for an Energy-Efficient Economy (ACEEE); Brian Christensen, Product Director and Chief Building Scientist of Residential Energy Management Services; Erik Straite, Business Development Manager, HouseRater, LLC; and non-voting chair Brett Dillon, General Manager of the Building Science Institute, Ltd. Co.

Col. Kevin Burk served in the US Army for 28 years, retiring as a colonel of Military Police before starting his business in the building science and home energy rating industry. He is a certified energy rater and International Code Council-certified Residential Energy Code Plans Examiner and Inspector.

Amber Wood directs the Buildings Program at the American Council for an Energy-Efficient Economy (ACEEE). Amber holds a Master of Science in engineering systems from the Colorado School of Mines and is a registered professional engineer.

Brian Christensen has worked in the field of residential building science for over 20 years, applying his background in physics and mechanical engineering. He now develops software products that aim to serve the unique needs of home performance verification businesses.

Erik Straite began working in the energy rating industry as a financial auditor, then moved into roles in utility program design, implementation, and quality assurance. Erik continues his work on utility programs and provides technical support for HouseRater’s users and energy code guidance for its developers. He holds a degree in economics from Arizona State University.

Building Science Institute, Ltd. Co. is a privately held company headquartered in the San Antonio, TX area.

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