2026-07-22 Comment response to the published Request for information

Persistence Analytics Group LLCSupportBusiness
Summary: Neil P. Osnato of Persistence Analytics Group LLC / United Grid supports the DOE's effort to improve the methodology for assessing building energy code affordability. He argues that the DOE should incorporate an "implementation-verification layer" that accounts for real market costs, realized savings, and regional variations rather than relying solely on modeled predictions.
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