EPA QAQC Discussion Paper


When the U.S. Environmental Protection Agency (EPA) first developed the ENERGY STAR Certification System for Homes and Apartments Using an Energy Rating Index or Dwelling Unit Modeling Compliance Path[1] in 2018, it included requirements for Home Certification Organization (HCO) “Quality Control Protocols”.[2] Since that time, compliance matters have brought additional information to light that suggests room for improvement in those requirements. In addition, the 45L tax credit’s newfound reliance on the ENERGY STAR program is expected to put the quality and reliability of ENERGY STAR certifications under greater scrutiny than ever before.

Based on this, EPA believes it is necessary and appropriate at this time to strengthen the ENERGY STAR Certification System’s quality assurance/quality control (QAQC) requirements. This document lays out a draft proposal designed to improve the effectiveness of current QAQC activities, give HCOs new tools to oversee participants operating in their ENERGY STAR certification programs, and ultimately create more confidence in the quality of ENERGY STAR certifications.[3]

As the day-to-day implementers of the program, EPA greatly values HCOs’ input on this important effort. This preliminary concept is being provided in the spirit of spurring discussions with our HCO partners. EPA would value feedback on the proposed elements described below, as well as welcome any new or alternative ideas for achieving the same outcomes via other means. At this stage, EPA seeks feedback on the broad concepts and direction of the proposal. Based on this feedback and additional discussions with HCOs, EPA will prepare detailed edits to the Certification System document, which will ultimately be made available for public stakeholder feedback. Finally, EPA will set reasonable timelines for implementing any new requirements, recognizing that some elements may require more time to put into practice than others.

[1] Find the current revision of the ENERGY STAR Certification System at: https://www.energystar.gov/partner_resources/residential_new/working/other_participants/hco/become_hco

[2] For the purposes of this document, “quality control” refers to processes that evaluate the end product, which, in this case, are the homes being certified as ENERGY STAR. File Review and Field Review are examples of quality control activities. In contrast, “quality assurance” will be used to refer to efforts that are focused on the certification process, including things like training, credentialing, and equipment calibration.

[3] In addition to this QAQC proposal, EPA also identified quality-driven improvements to its technical specifications, which it is actively evaluating for rollout over the next two annual program revisions.


Submit your comments or suggested changes below. The deadline to submit comments is August 4th, 2023.

The comment period ended on August 4th, 2023.

First Name:Last Name:AffiliationComment: Proposed Change to Document:Entry creation date
AmyMusserVandemusser Design

I think the requirement for photos is probably a good one, but would suggest that they put something on the energy star rater checklist so that it’s very obvious in the field which things need a photo (like a little camera icon).

July 17, 2023 at 11:25 AM
MichaelHarrisGroup14 Engineering

Group14 Engineering supports increased quality assurance work being completed on ENERGY STAR certified homes and apartments.  Of particular interest to our firm is the integration of ENERGY STAR paperwork into modeling software and RESNET review protocols to streamline the quality assurance process.

July 17, 2023 at 7:17 PM
ConnorDillonThe Dillon Group, Inc.

As a third-party QAD that has worked with QA Providers across the country, I believe the proposed modifications to the HCO program are necessary and timely.

And frankly, something that should have happened years ago.

Far too long have “drive by” ratings occurred, self-reported quality assurance that found no issues, and crappy inspectors bouncing from rating company to rating company. With the 45L being tied to ENERGY STAR and DOE Zero Energy Ready Home, it’s necessary for people to UP their game.

Some of these proposed changes are directly related to the problems we’ve faced, and with the technology improvements that’ve occurred, these changes are easily managed.

N/A, accept as is within 6 months.

July 31, 2023 at 4:48 PM
DanielConnerSouthern Energy Management

In general: improving QA and photo documentation is probably a good idea. SEM, and I believe, most high quality QA providers are already doing blind QAs and additional qa checks beyond resnet standards, including implementing some sort of on-site verification (extra photos, gps, time on job site, etc). But, many of these recommended changes come with extra costs, asking our builders to pay more is never a fun conversation. Making sure the client/builder gets value for what they are paying for should stay central to this conversation. #askabuilder

We’re not in favor of moving who prints the label from the rating provider to the HCO, seems unnecessary and takes the final deliverable, and the importance of that, out of the providers hands – allowing us to provide all deliverables to our clients without going through another party makes a lot sense. Addressing those who are sending certifications without registering them or qa’ing them can be achieved in other ways that don’t punish those who are doing it right. We are in favor of EPA’s recommendation to remove the printed label requirement. We’ve found that our builders do not see a lot of value in that printed label. It’s costly, wastes paper/resources, and provides little value. 

HCO centralized collection of E* checklist data: It will be necessary to support all digital pdfs, paper checklists, and digital options. We evaluate digital form software yearly and have yet to find an option that does what we need to do, without workarounds. Requiring a software/process that doesn’t meet the needs of the rater partner is unwise to say the least. 

Regarding frequency of blind QA checks: We advocate that they could simply require the same QA requirements (rough and final) but require 50% blind and unannounced and the other 50% side by side. Then without upending the whole process you can achieve both the mentoring opportunity and the regular QA checks.

Time needed to ramp up the QA team to address these changes is dependent on what’s asked, it’s not the challenge of it, but the additional time per review it could add. 5-10 minutes per review adds up real quick when you’re doing a lot of QA. 

There are multiple statements requiring the use of a specific software. Knowing that all these requirements come with added software costs it would make sense to have some sort of price guarantee from the EPA/HCO to ensure prices aren’t raised above what they would be should those software offerings be optional; ie, if required, what’s stopping the software provider from pricing it above what the market would bear otherwise. Or keeping it broad and allowing for multiple options that would allow the rating/QA provider to choose a software that best meets their needs and cost requirements.

August 3, 2023 at 4:40 PM