California Association of HERS Raters

This is a response to Efficiency First' Concerns about HERS II

HERS II and the Home Performance Industry

California’s leadership and action for energy efficiency has been noticed globally. California has always set the standard for energy efficiency in the United States dating back to the vision of Art Rosenfeld in 1978. Since then, the state has stayed the course with standardized energy policy that is on par with stellar European energy efficiency standards.

The California Association of HERS Raters (CalHERS) supports the California Certified Energy Rating and Testing Service (CalCERTS) with some reservation.

As per the Memo sent to EUC Stakeholders on August 25, 2011, it appears that the HERS II program will be in review over the coming months and CalHERS looks forward to participating in this review as a group of significant stakeholders in this industry. The rating system will have a major impact on how CalHERS members plan their businesses. We believe that public comment and stakeholder involvement is a key prerequisite to moving the HERS II program forward to its pre-ordained conclusion.

Conditional Approval of CalCERTS HERS Building Performance Contractors curriculum

The building performance contractor path, as proposed, could create an elite legion of contractors hence increasing this path’s credibility and build upon the BPI national standard. Cross training Contractors and incorporating the HERS II certification (and related Title 24 knowledge) from CalCERTS will continue the trend toward a standardized and globally leading system that is better for California than national standards. Prerequisites for the training should be high such as 5 years as a working, licensed contractor.

We believe this approach builds upon the Commission’s substantial ARRA investments in the HERS industry. This would benefit many including California’s BPI contractors who have invested heavily in working within California’s system to achieve real, credible, and standardized energy savings by virtue of third party verification. The HERS II system has helped California consumers by offering unbiased, standardized methodologies of ensuring quality and performance.

In consideration of the August 25th memo on the future of HERS II, we believe that the commission should continue to invest in - and stay the course rolling out- a system that that has been in development for so many years.

Fast Track CHEERS Approval

CalHERS requests that the CEC use its resources to “fast track” CHEERS’ certification and make this a priority within the department. Doing this will foster competition and bring back a dynamic force in the HERS industry. The best interest of California will be served by rolling out the long-planned labeling system whose momentum has been increasing. CHEERS was far ahead of CalCerts in 2008 and losing them has handicapped the industry. A CHEER was well on its way transforming markets, consumer attitudes, and making inroads into the Real Estate industry.

Given the infrastructure that exists in the current HERS II system, we urge the Commission to move forward with HERS II implementation.

HERS II should take precedence over BPI

The HERS II certificate produces a score that is standardized and takes into account Time Dependent Valuation and the building dispassionately. TDV is the ultimate goal of California according to the CPUCs Strategic Plan and must be nurtured. Building new plants is costly. A standards based on DOE2 ensures objectivity is maintained and will populate our state’s growing and valuable HERS registry. Consumers should be educated to understand that the label has value at many stages of the building’s life including transfer. This standardized system, unique to California and it’s varied climates, has and will continue to enhance the HERS II program’s objectivity and credibility with consumers.

Consumers that know about the third party verification system demand it. This reaction is driven by having an agent ensure that their individual investments in energy efficiency improvement projects are done correctly. Consumer awareness of HERS Raters, however, is low. The HERS II system adds significant assurance of energy savings for the state and to consumers while offering a standardized Rating unique to their climate zone.

The economic climate in California calls for the nurturing and expansion of the third party verification system called HERS II. California must stay the course and examine the implications of adopting a “one size fits all” national standard. The Building Performance Contracting (BPC) industry should focus their attention on transforming the quality and skill of contractors and the shoddy work performed that HERS Raters witness on a daily basis throughout California. The greatest barrier to the success of individual BPCs has more to do with cut throat contractors than from HERS II. The many individuals that have invested their heart and soul in HERS II have created jobs, helped define the long-term program, and helped consumers get what they paid for.

The CEC’s rollout of HERS II started in 1999 with the establishment of the California Home Energy Rating Services and was the basis for Energy Efficiency Mortgages in California. In February 2008 CHEERS conducted the first modern HERS II class (5 days instead of 3 days) and these strides have proven effective. BPI is a relatively new standard that does not take into account California’s big bold plans.

The well-established path of HERS II has been a long-term investment for California and is well on its way to being embraced by industry and consumers. The ball is rolling for Green jobs creation for entry level workers into family wage jobs and the potential to transform the market is close at hand. Please consider getting CHEERS back online a priority and stay the course by approving CalCerts’ new training.

We thank the Commission for consideration of the HERS Industry, and hope that the HERS II path will be solidified and continue.

Sincerely,

The California Association of HERS Rater