It is not clear how to perform 5 energy audits under the supervision of a licensed individual to meet the requirements of the license application in part (2) if there are no licensed individuals in the state currently.  

Can some clarity on this be provided in the regulation? 

Or at the very least, what will be accepted as proof of this for the initial auditor applications?

I ask that Residntial Energy Services Network (RESNET) Accreditied Training Providers.be allowed to provide the training. RESNET Training Providers are the only trainers reconized by the EPA New Homes Energy Star Program to provide training to HERS Raters and the Energy Star vs. 3 training

All HERS training includes use of blower door, duct leakage testing, use of software for energy modeling, basic building science, and basic HVAC operation, for both new homes and existing homes.

Each trainer has had to meet the following requirements:

1. Pass RESNET National Exam - 100 question, 2 hr tine limit, must score 90 or above
2. Complete Adult Education Class - min. 16 hr
3. Pass RESNET Combustion Saftey Exam
4. Must have completed 25 confirmed HERS rating with 3% under going a file review and 1% passing a field review
5. Must have 12 CE hrs of RESNET approved class or 36 hours of class room traing yearly

I request current RESNET Hers Raters be be "grandfathered". Current raters have been isued a "RTIN number" by RESNET, their ratings have been entered into a national database, their work is reviewed by a QA Provider (10% file review and 1% field of their work.

Each HERS Rater has passed a RESNETR Nation Exam, 50 question, 2 hr. time limit, pass ing grade 80 or above, must have performed 2 rating in the presence of the instructor and performed at least three rating in the presence of thier QA Provider, before being approved as a rater and receiving their RTIN number.

All raters have received training that covers all the license requirements of the State Code as written.

HERS Raters are required to be used for the Energy Star New Homes Program, The New Homes tax credit, DOE Builder's Challange Program, are listed in the "Save Act" bill currently pending in Congress and the only people appreoved to produce a RESNET Home Energy Rating