Comment response to the published Request for information
Kenneth KrantzSupportBusiness
Summary: Kenneth Roger Krantz, representing TeraSun Systems LLC, supports the DOE's objectives of improving affordability and reducing regulatory burden in building energy codes. He argues that the DOE should adopt real-time, batch-level digital verification systems to replace static, paper-based documentation for capturing cost and compliance data.
I submit this comment in response to Docket No. EERE-2026-BT-BC-0034. I am a certificated building contractor with more than 43 years of industry experience, an ASTM International workgroup contributor on manufactured building material standards, and the developer of a patent-pending real-time digital verification platform for factory-built and industrialized construction.
My full comment is attached as a separate document. In summary: the methodology questions raised in this RFI — on cost data accuracy (Q01), the absence of a centralized cost database (Q02), regional cost variation (Q03), economic benefits to consumers (Q04), evaluation period (Q09), permitting delays (Q11), and broader cost drivers of new construction (Q12) — collectively describe the symptoms of a single structural problem. The industry's cost and compliance infrastructure is built on static, after-the-fact paper documentation at a moment when the data needed to verify both cost and compliance can be captured continuously and at the source through real-time digital verification systems.
I respectfully urge DOE to consider real-time, batch-level digital verification as a direct and scalable response to the affordability, transparency, and regulatory-burden objectives stated throughout this RFI. My full analysis and specific recommendations are provided in the attached document.