Workforce Guidelines for Home Energy Upgrades

1.1.1 "A: The specification of the BPI protocol is inappropriate for the following reasons: 1. It is not adequately identified or otherwise provided as a reviewable reference such as those provided on page 2. Consequently, it is impossible to validate the appropriateness of this nebulous reference. 2. Referenced standards should be properly vetted and accredited by ANSI. B. For the same reasons listed above, the term ""other equivalent protocol"" is unacceptable. Combustion testing will be conducted in accordance with the Building Performance Institute (BPI) protocol or other equivalent protocol" 2.8.1 "The same concerns provided under 1.1.1 regarding the inappropriateness of the BPI protocol or equivalent apply equally here. Likewise, the term CAZ combustion safety testing and it related footnote 26 is inadequate. Is footnote 26 the only CAZ combustion safety testing methodology or the only equivalent? A Google search of the term CAZ combustion safety testing provided a link to one web site for a BPI adherent who advocated for a worst case scenario test. It is left to the imagination of what that might entail. Under such nebulous definitions, it is possible that proper appliance drafting could be forced to malfunction. Footnote 27 under Annex H provides an appropriate methodology rather than the language presently provided under Section 2.8.1" 2.9.1 Basically Section 2.9.1 suffers from the same problems as those previously discussed under 2.8.1. Therefore, these concerns apply equally here. 2.9.3 Our concerns and comments are essentially the same as those submitted under Section 2.9.1. Therefore, they apply here equally. 2.10.4 Our concerns and comments are essentially the same as those submitted under Section 2.9.3. Therefore, they apply here equally. 5.39.1 Our concerns and comments are essentially the same as those submitted under Section 2.10.4. Therefore, they apply here equally. 5.39.7 It is now become a reoccurring theme that any and all "accepted protocol (e.g., BPI, NATE)" should be fully provided as required references for evaluating their appropriateness in this proceeding. As they are not provided, they should not be deemed appropriate. 5.39.8 Again, cited references and/or footnoted references should be provided via web link or attached so that public comments can be made as to the suitability of such references. 5.40.1 This is the same redundant concern: Referenced documents are not being provided for review. 7.12.4 the same concerns regarding the lack of references and ANSI accreditation regarding the "BPI protocol" apply here. Additionally, the footnote number 489 appears out of sequence. 8.16.1 Please insert the same concerns provided in comments regarding 7.12.4 8.17.1 Again, the appropriateness of the BPI protocol is impossible to determine given it is not provided.