ACCA vs BPI—The Brouhaha Over Home Energy Audit Standards
Probably the biggest news I heard at the 2013 RESNET conference this year was that the Air Conditioning Contractors of America (ACCA) and 12 other organizations had asked the American National Standards Institute (ANSI) to have the Building Performance Institute's (BPI) accreditation as a Standards Development Organization (SDO) revoked. Really!
That was big news. This year, RESNET combined its conference with ACCA's, and that was great. The HVAC industry is critical to the success of fixing existing homes and building new homes that perform as they should. I know there's always rivalry among organizations that are doing work in the same arena, but I didn't expect to see one organization in our fold taking on another in such dramatic form.
Before we get into this, let me say that I have connections to several parties involved. Energy Vanguard is a member of ACCA, and we're a BPI Test Center, too. I also write articles for ACCA's IE3 magazine and have been asked to speak at ACCA's Building Performance Forum in Austin this year. We also are involved with energy codes, although we have no formal affiliation with the International Code Council, and we're a RESNET accredited training provider and quality assurance provider. RESNET isn't listed on the letter, but they helped ACCA to develop Standard 12 (see next section).
A little background
RESNET and BPI offer certifications for people who want to be home energy auditors, under various names: home energy rater, building analyst, envelope professional, home energy survey professional, and more. ACCA is one of the main trade associations for HVAC contractors.
ACCA has a standard for doing energy audits on existing homes. It's called ACCA Standard 12 and was approved by ANSI.
BPI has been working on getting ANSI approval for its existing homes energy auditing standard, BPI Standard 1100.
Who are the 13 signatories?
The 13 organizations that signed the letter are:
The 5 Standards Development Organizations (SDOs)
- Air Conditioning Contractors of America (ACCA)
- Air Movement and Control Association International
- American Gas Association
- International Code Council (ICC)
- Air Conditioning, Heating, and Refrigeration Institute (AHRI)
The 8 Materially-Affected Organizations
- American Public Gas Association
- National Propane Gas Association
- Heating, Air-conditioning and Refrigeration Distributors International
- North American Technician Excellence (NATE)
- Institute of Heating and Air Conditioning Industries
- Plumbing-Heating-Cooling Contractors Association
- National Air Filtration Association
- Refrigeration Service Engineers Society
As mentioned above, RESNET is not a signatory on the letter, but they're involved peripherally in that they helped ACCA develop their Standard 12, and the RESNET logo is on the cover.
The letter indicates no organization as the primary one. They're divided only by those that are SDOs and those that aren't. However, the email sent to ANSI came from Glenn Hourahan at ACCA, and and it looks to me like ACCA is the main instigator.
Update 4/10/13: I just heard from Mr. Hourahan, who wrote, "It was the letter of 13 organizations where ACCA was a signer to the letter. Additionally, ACCA was not the one who suggested the letter…but, rather ACCA was approached by others to join the effort."
Their beef with BPI
The day after the RESNET conference ended, I received a copy of the letter in my email. The thirteen organizations above signed this letter to "respectfully request the withdrawal of BPI’s Accreditation as an SDO."
The 12 points given in the letter are:
- BPI’s On-line Tool Hinders the Due Diligence Process
- BPI Does Not Identify its Consensus Body
- BPI’s Development and Oversight Committees Lack Balance
- BPI’s non-Adherence to ANSI Procedures Precludes Due Process
- BPI Review Instructions Impedes Due Process
- BPI Concurrent Reviews Caused Widespread Confusion and Hindered Due Process
- BPI Guidance Limits Due Process
- BPI Appeals Procedures Obstructs Due Process
"Due process requirements for American National Standards have been subverted by BPI at every point in its standards development process," they wrote.
Glenn Hourahan of ACCA
I spoke with two people involved with the letter: Glenn Hourahan, PE, of ACCA and David Karmol of the International Code Council (ICC).
Mr. Hourahan told me that they'd spent hundreds of hours of staff time reviewing and commenting on BPI 1100 and he felt like they got no traction in the process. He also said that, "We need one standard, not two." Rather than allowing BPI to develop that standard on their own, however, he said, "The only reason we came out with 12 is that it became obvious that there was a bad standard being dropped on the street."
About the letter, "It doesn’t really matter who wins in the end," he said. "We had to send a message to ANSI." According to Hourahan, there were probably ten more organizations that wanted to sign but couldn't.
As we talked further, another interesting point came out. "DOE [US Department of Energy] is the 800 pound gorilla. They’re waiting for 1100 to get ANSI certified so they can put their seal of approval on it," Mr. Hourahan said. He then told me that he thought the DOE would like BPI's standard better because it's easier. (See below for more on the DOE connection.)
David Karmol of ICC
When I spoke with ICC's David Karmol yesterday, he sounded extremely frustrated. "We have trouble filing comments with BPI," he said. "They changed their process midstream." One aspect he mentioned in particular was that he couldn't leave a comment on the standard as a whole. If he wanted to do that, he had to enter that comment into every comment box throughout the whole document.
Another complaint he raised was that BPI 1100 would have requirements that are in direct conflict with building codes. Although he couldn't think of any specific examples, he said they were mainly related to safety.
I also spoke with people on the BPI side. In a conference call with BPI's CEO Larry Zarker as well as staff members John Jones and Leslie McDowell, I was told that they don't understand how the 13 organizations can make such claims. If BPI really violated ANSI's due process as badly as the letter states, they asked, how could they have gotten accredited by ANSI in the first place?
Regarding the vetting process of BPI 1100, Ms. McDowell said, "We responded in good faith to each of the 511 comments we received in the first round. It did take us a while because there were so many." According to BPI, the vast majority of those comments came from ACCA, and one of their big problems with BPI 1100, they believe, is that, although BPI responded to all the comments, they didn't make all the revisions that ACCA wanted.
Another interesting thing that I learned in this call is that this is not the first time that ACCA has filed a formal complaint against BPI. On the two previous occasions, ACCA's complaints were dismissed. The second of those was heard by a three-person panel, all of whom were members of ACCA. I believe at least two of them are also involved with BPI.
The BPI folks on the call indicated to me that they know their process isn't perfect, but their approval as an SDO and the documents that support it are all in compliance with ANSI guidelines. They feel that working with ANSI to iron out any wrinkles in the process is the best way to go about this, not having their SDO accreditation revoked.
BPI feels that they will survive this complaint, if it goes further. "Should they file an appeal, we are ready. We feel very ready to talk about them, point by point," Mr. Zarker said.
ANSI's response to the letter
Zarker referred to an appeal because ANSI responded to the letter by saying that they would take no action on it, as it was not filed in accordance with their procedures. I've asked ACCA if the group intends to pursue the matter.
Update 4/10/13: Glenn Hourahan responded to my request with this statement:
"So, as initially, a follow-up response to ANSI is really up to the group to execute. And, like all things involving diverse groups with diverse pressures on individuals’ times, responding on a redirected letter to ANSI is on a schedule of its own. There is even a thread of discussion that the initial, errantly-directed letter to ANSI…albeit, not publicly released by any of the 13 (to my knowledge)…may have achieved an objective of indicating concerns and allowing an opportunity for better engagement by all parties."
Is this all about the DOE's Home Performance with ENERGY STAR program?
Mr. Hourahan brought up the DOE when I spoke with him, calling them the 800 pound gorilla, and he was most likely referring to the Home Performance with ENERGY STAR (HPwES) program. This program has been around for nearly a decade and is undergoing an extensive rewrite of the guidelines. I know a lot of people, both inside and outside the DOE, involved with working on the new guidelines, so I spoke with one of them recently. He wanted to remain anonymous, though, because he works with both sides in this debate.
One of the first things he said is that it's not true that DOE will give a 'seal of approval' to BPI only. Yes, he thinks the DOE would like to see BPI’s standard get approved, but they also want ACCA involved. He also said the DOE would like to have only one standard to work with but, "It’s not likely to occur so they’re trying to find a way to make the standards complementary and not be conflicting." Also important is that they would like both standards to reflect the HPwES guidelines.
My HPwES source also said that the plaintiffs would probably have a difficult time proving their claims. The actual problems were probably just BPI oversight, he said, echoing what I heard from BPI.
Although he values ACCA and their work, "The idea of revoking ANSI SDO status is crazy. It seems like an inappropriate way to go about things."
Can't we all just get along?
Wow! Is your head spinning? Mine is—and not just because of all the acronyms and abbreviations! Here we have one group of organizations going after another organization, fighting over whose standard for energy audits of existing homes will win out. ACCA wants to have only one standard, and theirs is already published. BPI wants to get theirs published and then 'harmonize' the two.
Another point of contention is that ACCA says BPI 1100 is too easy. BPI says that ACCA 12 is too difficult and expensive.
This sounds like a perfect situation for compromise to me. BPI, like any organization, has its problems. So does ACCA. Each, however, brings value to the table to make energy audits, and thus homes, better.
There's a lot of work to do to analyze and improve existing homes. I think this kind of kerfuffle isn't the best use of time and resources. Let me give the last word here to BPI's Larry Zarker, who said:
"We should figure out ways to collaborate and cooperate across industry sectors. This will become mainstream and we want to make sure the work is done well."