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1 U.S. Department of Energy 

2 

3 

4 

5 

6 Manufactured Housing Working Group 

7 

8 

9 

10 9:08 to 4:22 p.m. 

11 Wednesday, September 10, 2014 

12 

13 1000 Independence Avenue, S.W. 

14 Washington, D.C. 20585 

15 

16 

17 

18 

19 

20 

21 

22 
2 

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1 CONTENTS 

2 PAGE 

3 MANUEL SANTANA, Subcommittee Report 7 

4 MICHAEL EMANUEL LEVY, Recommendations 104 

5 RICHARD MENDLEN, Public Comment 328 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 
3 

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1 P R O C E E D I N G S 

2 MS. HOFFMAN: Good morning. This is our 

3 second day of meetings this week for the 

4 Manufactured Housing Working Group, chartered by 

5 ASRAC to look at energy efficient standards for 

6 manufactured housing, sponsored by the Department 

7 of Energy. 

8 I'm Eileen Barkas Hoffman. I'm here with 

9 my co-facilitators. 

10 MR. BANTLE: Ted Bantle. 

11 MR. RAMIREZ: And Javier Ramirez. 

12 MS. HOFFMAN: And I think we'll just 

13 briefly go around the room to see who's here in 

14 person, and then I'll mention who's here on line. 

15 Thank you. 

16 MR. WEISS: Mark Weiss, MHARR. 

17 MS. EPPERSON: Stacey Epperson, Next Step 

18 Network. 

19 MR. ROY: Robin Roy, Natural Resources 

20 Defense Council. 

21 MR. WALKER: Matthew Walker, Navigant. 

22 MS. VAIDYANATHAN: Kavita Vaidyanathan, 
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1 DOE General Counsel's Office. 

2 MS. STARKEY: Lois Starkey, the 

3 Manufactured Housing Institute. 

4 MR. LACEY: Eric Lacey, Responsible 

5 Energy Codes Alliance. 

6 MR. UNGER: Lowell Unger, American 

7 Council for an Energy Efficient Economy. 

8 MR. BARBOUR: Ed Barbour, Navigant 

9 Consulting. 

10 MR. HAGERMAN: Joe Hagerman, DOE. 

11 MS. HOFFMAN: Okay. Thank you. 

12 MR. HAGERMAN: And I just got a note from 

13 Keith. He's running about 15 minutes late now. 

14 MS. HOFFMAN: Okay. Okay. So he'll join 

15 us in 15 minutes. 

16 Let me just read who I believe is on the 

17 line and make sure that they -- I think, are they 

18 muted now? I'm muting them now. 

19 Scott Drake from East Kentucky Power 

20 Cooperative; Mark Ezzo, Clayton Homes; Richard 

21 Hanger, Housing Technology Standards; Burt 

22 Kessler, Palm Harbor Homes; Eric Lacey is here; 
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1 Michael Emanuel Levy, Systems Building Research 

2 Alliance; Michael Lubliner, or "Luby," Washington 

3 State University Extension Energy Program; Robert 

4 Luter, Rob Luter, Lippert Components, Inc.; 

5 Richard Potts, Virginia Department of Housing and 

6 Community Development; Manual "Manny" Santana, 

7 CAVCO Industries; Peter Schneider, Efficiency 

8 Vermont; David Tompos, NTA, Inc.; Michael Wade, 

9 Cavalier Home Builders; and Isabel Dickens. 

10 Have I missed anyone? 

11 [Inaudible interjection.] 

12 MS. VAIDYANATHAN: I'm sorry. That was 

13 completely garbled, but I think you were telling 

14 us to mute our phones. 

15 MS. HOFFMAN: That sounds good. I was 

16 thinking it. 

17 [Laughter.] 

18 MS. HOFFMAN: Yes. Isabel, thank you. 

19 MR. HAGERMAN: That's Peter Schneider. 

20 MS. HOFFMAN: Oh. Peter Schneider, would 

21 you mute your phone, please? 

22 And let's see. Are these folks on the 
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1 line? Members of the public, Robert Lucas, 

2 Robert Preston. And are the other two not here 

3 today? 

4 MR. HAGERMAN: Is this Amy Barnard? 

5 MS. HOFFMAN: No, they're here. 

6 MR. HAGERMAN: Yeah, they're here. 

7 Michael Kociolek? 

8 MS. HOFFMAN: Michael Kociolek and Amy 

9 Barnard. Okay. Great. Welcome. And members of 

10 the public over there, come on just tell us who 

11 you are. 

12 [Pause.] 

13 MR. HUANG: David Huang, FMCS. 

14 MS. PONTILLO: Pam Pontillo, Department 

15 of Energy Office of Conflict Prevention and 

16 Resolution. 

17 MS. HOFFMAN: Okay. One more. 

18 MR. MENDLEN: Rick Mendlen with HUD. 

19 MS. HOFFMAN: Great. Thank you. 

20 Okay. Javier has changed the agenda 

21 based on what we discussed yesterday. And let me 

22 turn it over to you, Javier. 
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1 MR. RAMIREZ: All right. So I guess 

2 we'll start off on that first point. Are there 

3 any comments from the working group members 

4 before we get rolling into the continuation of 

5 subcommittee reports? 

6 [Pause.] 

7 MR. RAMIREZ: All right. Then, Manny, 

8 I'm going to turn it over to you to walk us 

9 through what you and your subcommittee have been 

10 able to put together on the 2015 IECC standard. 

11 [Pause, audio feedback.] 

12 MR. SANTANA: Okay. Am I the cause of 

13 that feedback? 

14 MR. HAGERMAN: Not sure. But we'll mute 

15 our microphones on this end. So that way, we 

16 will hopefully reduce the chance of that 

17 happening. 

18 MR. SANTANA: Okay. Well, my 

19 subcommittee was tasked with going through 

20 Section 4, which is the Residential Energy 

21 Efficiency Section of the IECC and identifying 

22 which sections are labeled specifically as 
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1 mandatory, and going through those to see which 

2 ones we can agree can be included in the term 

3 sheet for manufactured housing, and which ones we 

4 can all agree should be excluded because they 

5 don't apply one way or another. 

6 By my count, we have there are 25 

7 sections. And out of those 25 sections, we were 

8 able to reach consensus on about 10 of them. And 

9 those were distributed in an email by Javier to 

10 the group last week. So we should all have 

11 those. 

12 So what we'll do is we'll go through the 

13 ones that we reached consensus on, if that's 

14 okay. And what do you want to do? Do you want 

15 to go through each individual section? 

16 MR. RAMIREZ: Yeah. If you could just 

17 start from the beginning and walk us right 

18 through it. 

19 MS. HOFFMAN: And, Manny, do you want to 

20 mention who was on your committee? 

21 MR. SANTANA: Yeah, yeah. The committee 

22 is a subcommittee. It was composed of Mark Ezzo, 
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1 Eric Lacey, Michael Luby, Mark Weiss, Burt 

2 Kessler, and myself. 

3 MS. HOFFMAN: Okay. Thank you. 

4 MR. SANTANA: So, the items that we were 

5 able to agree that should be excluded from, 

6 section R403. That deals with systems that serve 

7 multiple dwelling units. Manufactured homes are 

8 defined as being for a single-family unit; so 

9 then, this doesn't apply. So that was an easy 

10 one that we were able to exclude. 

11 And I'm just going to go on. You know, I 

12 don't know if you want to un-mute everybody's 

13 mic's in case they have anything to add or they 

14 want to interject. Otherwise, I'll just keep 

15 going. 

16 [Pause.] 

17 MR. SANTANA: Okay. Section R403.9, that 

18 was snow and ice system controls, which are 

19 external to the manufacturing home, and then they 

20 don't apply for that. 

21 MR. RAMIREZ: Manny? 

22 MR. SANTANA: Yeah. 
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1 MR. RAMIREZ: Could you hold on one 

2 second? I just want to make sure that everyone 

3 is following along with you on the book. 

4 Are you able to identify the page number 

5 in the book? 

6 MR. SANTANA: Yes. 

7 MR. RAMIREZ: Then pause and give the 

8 folks just a moment to catch up on the page. 

9 MR. SANTANA: Okay. Okay. So, you know, 

10 what I should do is I should start at the 

11 beginning. 

12 So, section 4, Chapter 4 of the 

13 residential portion of the IECC deals with -- 

14 well, there's a commercial section. There's a 

15 residential section. So we're only concerned 

16 with the residential right now. 

17 If you go to R401.2, and if everybody 

18 goes to R401.2, it's titled Compliance. And it 

19 reads that it gives you three ways to comply with 

20 the IECC. You know, and so, item number 2 says 

21 you can comply with section R405, as well as the 

22 mandatory provisions of R401 through R404. And 
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1 those are the ones that we're trying to hit. 

2 Because even if you look at item 3, it 

3 allows you to prove compliance using the approach 

4 in section 406. 406 also requires you to meet 

5 the mandatory provisions that are specified in 

6 401 through 404. 

7 And that's what we're doing today. We 

8 went through the mandatory provisions, and we're 

9 trying to identify which ones we can just ignore 

10 and not spend any more time on and which ones we 

11 all agree are okay and include in any final term 

12 sheet. 

13 Are we all on the same page? 

14 MR. RAMIREZ: Okay. Yeah. 

15 MR. SANTANA: Okay. And again, we're not 

16 going to start with the first mandatory 

17 provision. We're going to start with the first 

18 mandatory provision that we could -- that we 

19 agreed on. And that was R403.8. And R403.8 is 

20 on page R-36. 

21 [Pause.] 

22 MR. SANTANA: So, R403.8 on page R-36 is 
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1 titled Systems Serving Multiple Dwelling Units. 

2 And that isn't applied to MH. And that was an 

3 easy one to exclude. 

4 Okay. Moving on, R403.9, also on page R5 36, is titled Snow Melt and Ice Control Systems, 

6 or Ice Systems Controls. 

7 And it deals with pavement temperature. 

8 And so, this is control systems which are 

9 external to the home. And these energy standards 

10 should really be concerned with what affects the 

11 dwelling. That's what the manufacturers' concern 

12 is. Everything outside is outside of our scope. 

13 So we excluded it for that reason. 

14 Okay. R403.10 is on page R-37. And that 

15 one deals with pools and permanent spas. And 

16 that goes without saying. And that incorporates 

17 the subparts of our 403.10. So that includes 

18 403.10.1 through 403.10.4, which all deal with 

19 pools and spas, which we don't build yet. So 

20 they don't apply to MH. 

21 Okay. 403.11, on page R-37, also deals 

22 with portable spas. And so that was easy to 
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1 exclude as well. 

2 MR. RAMIREZ: Okay. Manny, before we go 

3 on to the questions that you have included, which 

4 would be next, correct? 

5 MR. SANTANA: Well, I was going to circle 

6 back to Chapter 1. 

7 MR. RAMIREZ: Okay. 

8 MR. SANTANA: Which deals with scope and 

9 administration. But what did you want to add? 

10 MR. RAMIREZ: No, go ahead. Go ahead and 

11 do that. 

12 MR. SANTANA: Okay. So one of the things 

13 that we realized when we -- we realized that 

14 sections of Chapter 4 are labeled as mandatory. 

15 But Chapters 1, 2, and 3 are not labeled as 

16 mandatory, but still apply to the entire section. 

17 So then they are mandatory, for all intents and 

18 purposes. So we started to go through those, as 

19 well. 

20 And so, Chapter 1 -- and again, this is 

21 going off of the mandate that DOE was tasked 

22 with, developing energy standard based on the 
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1 IECC. So then we -- you know, the entire IECC's 

2 residential section was fair game, in our mind, 

3 in our collective mind. 

4 Anyway, Chapter 1 deals with scope and 

5 administration. And we went through it and 

6 agreed that, although we believe that an MH scope 

7 and administration chapter may need to be 

8 developed, Chapter 1 as it stands right now can 

9 be excluded in its entirety, because it deals 

10 with the local infrastructure and doesn't 

11 consider -- it isn't concerned itself with the 

12 infrastructure that HUD code units deal with. 

13 We would have done more with sections 2 

14 and 3, but there wasn't anything that we can 

15 obviously either include or exclude. 

16 Okay. So now I'm going to jump to the 

17 sections that we could include. 

18 MR. RAMIREZ: Okay. 

19 MR. SANTANA: Turn it from mute in case 

20 you want to interject. 

21 MR. RAMIREZ: Before you do that, I want 

22 to go back to those items on exclusion. I want 
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1 to see if there's any discussion on them, because 

2 I'd like to see if maybe we could even reach 

3 consensus that everyone is okay with excluding 

4 those that the subcommittee had already, through 

5 consensus, agreed to. 

6 So, before I ask the group if you're okay 

7 with excluding these, let's have some discussion 

8 on them. So, what questions or concerns might 

9 you have with excluding those? 

10 [Pause.] 

11 MR. RAMIREZ: Or the subcommittee did a 

12 great job. 

13 MR. POTTS: This is Richard Potts. 

14 MR. RAMIREZ: Go ahead. 

15 MR. POTTS: You can hear me? 

16 MR. RAMIREZ: Yeah. 

17 MR. POTTS: Like Manny said, I think 

18 those are no-brainer exclusions. Unless we have 

19 some obvious connections to them, I think it's an 

20 easy vote, at least from my perspective. But go 

21 ahead. 

22 MR. RAMIREZ: Okay. So I believe what 
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1 you're saying is that in your opinion, it's easy 

2 to exclude those that have been identified, 

3 correct? 

4 MR. POTTS: Correct. 

5 MR. RAMIREZ: Eric, did you have 

6 something? 

7 MR. LACEY: Eric Lacey from RICA. 

8 I was just going to add that we would 

9 delete this on the assumption that there are 

10 already, you know, kind of administration 

11 requirements in the HUD code. 

12 And we didn't see any need to try to 

13 retrofit these to fit that, that we should 

14 probably start with the HUD administrative 

15 requirements. This thing was -- you know, I 

16 don't think anybody opposed to deleting this. 

17 MR. RAMIREZ: Right. Well, then, in that 

18 case, this is potentially your first live 

19 consensus vote here. Right? So let's see a show 

20 of thumbs if you're okay with excluding the items 

21 that Manny and the subcommittee have identified 

22 as sections that can be excluded. Let's see a 
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1 show of thumbs. 

2 [Pause.] 

3 MR. RAMIREZ: All right. Now, folks, 

4 voting members that are on line, if anyone is 

5 objectionable, just speak up. Otherwise, we're 

6 assuming that your thumb is either up or 

7 sideways. 

8 MS. HOFFMAN: It's not that you're 

9 objectionable; if you have any objection. 

10 MR. RAMIREZ: Thank you. 

11 [Laughter.] 

12 MR. RAMIREZ: Okay. So let's show that 

13 that was a unanimous approval to exclude those 

14 sections. Okay? 

15 So, Manny, with that, can you go ahead 

16 and look at the -- walk us through the next 

17 section? 

18 MR. SANTANA: Okay. So that the next 

19 sections are ones that we feel can be included in 

20 a final term sheet for MH. And we're 

21 recommending that to the working group as a 

22 whole. 
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1 So, starting with section 403.1, 403.1 is 

2 found on page R-35. And it's titled Controls. 

3 [Pause.] 

4 MR. SANTANA: Okay. Assuming that gives 

5 enough time, this section requires at least one 

6 thermostat to be provided for each separate 

7 heating and cooling systems. We had some 

8 discussions on pros and cons. And all came to 

9 agreement that this would be fine for MH. We 

10 don't believe that anybody would have an issue 

11 with this being a mandatory requirement. 

12 MR. RAMIREZ: Let's do this. Let's take 

13 them one by one, right? So, again, the group, 

14 are there any questions or concerns for 403.1 

15 that we would want to discuss before we gauge the 

16 consensus for approval to include it in the 

17 whole? 

18 Yeah, Mark. 

19 MR. WEISS: Thank you. Mark Weiss, 

20 MHARR. 

21 I'll just repeat here what I said during 

22 the subcommittee meeting when we discussed, 
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1 quote-unquote, "including these provisions." And 

2 that is that I don't have an objection to putting 

3 these provisions -- and this is a clarification 

4 -- putting these provisions on the table for 

5 consideration by the committee. 

6 That is subject, however, to relevant 

7 cost analysis with respect to each one of these. 

8 So in other words, in terms of their potential 

9 technical applicability to this exercise, I don't 

10 have a problem with that. But as always, for 

11 each one of these, their ultimate inclusion is 

12 going to be impacted by the cost aspect of it. 

13 MR. RAMIREZ: So, are you saying that you 

14 want to look at what the absolute total final 

15 result is before you give the ultimate approval? 

16 Is that it? 

17 MR. WEISS: No. What I'm saying is, 

18 based on the input from the technical folks, I 

19 don't have a problem with saying these provisions 

20 should be considered as part of what we're doing. 

21 These provisions of the 2015 IECC should be 

22 considered as part of what we're doing. 
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1 Their ultimate acceptability, however, 

2 also has to address their cost impact. So what 

3 I'm saying is any vote I would have up or down on 

4 any of these ultimately would have to also factor 

5 into cost. 

6 I don't think that should be a 

7 controversial position. 

8 MR. RAMIREZ: Okay. 

9 MR. LEVY: Javier? 

10 MR. RAMIREZ: Yeah. 

11 MR. LEVY: It's Emanuel. I want to add a 

12 comment here. 

13 MR. RAMIREZ: Okay. 

14 MR. LEVY: Two things. To Mark's point, 

15 I think it would be nice to be able to do cost16 benefit analysis on a lot of these items. 

17 I'm skeptical, and maybe as we go through 

18 them individually, we can talk about them on this 

19 basis, that we'll be able to come up with energy20 savings figures. We may have to rely upon our 

21 consensus of what best practice would be. So, a 

22 couple of these, I'm skeptical we'll be able to 
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1 come up with real data. 

2 And also, there are a few items here 

3 which we will talk about in depth on some of the 

4 straw-men papers. I'm assuming that whatever we 

5 talk about later could supersede whatever 

6 decision we make now as a group. 

7 MR. RAMIREZ: Yeah. I would say that if 

8 that does happen and it does impact something 

9 that the group has already reached consensus on, 

10 then the group would just have to make us aware 

11 of that so we could go back and address that. 

12 MR. LEVY: Thank you. 

13 MR. HAGERMAN: This is Joe Hagerman. 

14 I was just wondering if some of the 

15 manufacturers, as we go through these, could 

16 comment whether or not, you know, these are 

17 abnormal to what they already do. Like, for the 

18 first one, I would assume that you ship a 

19 thermostat with the furnace, right? Else you 

20 can't use the furnace, right? 

21 So it would be nice to say, "Hey, we 

22 already do this. Or it's already in the HUD 
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1 code." And that might speed things up. 

2 MR. LUTER: This is Robert Luter. 

3 To expound on that, I'm wondering, does 

4 recommendation for inclusion of R403.1, for 

5 example, include subordinate clauses? Because 

6 that entire clause not only says one thermostat 

7 should be provided, which is very reasonable, and 

8 I'm sure done pretty much 100 percent of the 

9 time. 

10 But R403.1.1 says it has to be a 

11 programmable thermostat, with some specific 

12 operational attributes, which may not be done. 

13 MR. SANTANA: Rob, I can answer that. I 

14 can answer that in terms of what the subcommittee 

15 considered. 

16 What the subcommittee considered was that 

17 if the section that was mandatory would be titled 

18 as such. And I'll give you an example that 

19 applies directly here. R403.1, Controls, has 

20 "mandatory" right beside it. R403.1.1 does not. 

21 R403.1.2 does. So we talked about R403.1.2. We 

22 did not talk about R403.1.1. 
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1 So when the subcommittee recommends that 

2 we adopt 403.1, that's just 403.1. The other 

3 ones stand alone. And if they are inclusive, 

4 then we would state so. 

5 MR. LUTER: Right. Thanks for that 

6 clarification, Manny. 

7 MR. RAMIREZ: Okay. Lois? 

8 MS. STARKEY: I'm sorry I wasn't here 

9 last time. But in my discussions with my 

10 members, most of whom are on the phone, I thought 

11 that we were doing this exercise and putting this 

12 as, these are things that would be included as a 

13 part of an overall standard that we would -- you 

14 know, because it's only partial. 

15 And that we may or may not find it, for 

16 example, cost effective. So I sort of agree with 

17 Mark, that I just want to make sure that this is 

18 not saying that this, these things will be in the 

19 standard, but they should be included in an 

20 overall standard that we will be coming to 

21 consensus on. 

22 Does that make sense? 
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1 MR. RAMIREZ: Um-hm. 

2 MS. STARKEY: Because there might be some 

3 things that we might look at and it might get 

4 into the discussion that's in the parking lot, as 

5 well. 

6 So I just want to make it clear that, 

7 from my perspective, and I think MHI's 

8 perspective, is that, you know, you need to look 

9 at these pieces as an overall part of a package, 

10 right? We're not saying, "This will be a part of 

11 the standard," because you have to look at it as 

12 a whole. 

13 MR. RAMIREZ: All right. Then, I guess, 

14 to try and eliminate some confusion then, we 

15 probably should not do a consensus vote on these, 

16 at least reaching an agreement that, yeah, these 

17 are the ones that we're going to discuss. But as 

18 the overall package, at some point we'll have to 

19 gauge the consensus on this for a final approval. 

20 Okay? But at least we get an 

21 understanding of what it is we're doing. 

22 MR. WEISS: Yeah. And my understanding 
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1 is this is essentially a technical exercise to 

2 determine which sections are potentially 

3 applicable here and should be considered versus 

4 those that are not applicable and we can 

5 essentially discard from our analysis. 

6 And then once we have that understanding, 

7 then the analysis goes on from there to the other 

8 issues. 

9 MR. RAMIREZ: Okay. But I do want to 

10 clarify that on the exclusion -- 

11 MS. HOFFMAN: There's agreement on the 

12 exclusions, so we can move ahead. Yeah. Yeah. 

13 It's Eileen Hoffman. 

14 MR. EZZO: This is Mark. I've got a 

15 comment about all this. 

16 On the subcommittee, Mark Weiss brought 

17 up a good point that I think we need to capture 

18 here. And that is, as we go through all these 

19 items where we're putting, quote-unquote, 

20 "include" on them, if there is a potential for a 

21 cost impact, I think we need to have some way of 

22 flagging that. 
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1 So we have -- we probably need to have 

2 some column on our spreadsheet when we come to an 

3 item and we all say, or the subcommittee has 

4 suggested that it be included, if there is a cost 

5 impact, I think we need to know. This needs to 

6 be costed and it needs to be included in anything 

7 Navigant is performing, where they're showing, 

8 you know, the initial cost to the consumer. 

9 And in this particular section, so, for 

10 instance, like Manny said, the section is 

11 Controls, 403.1. And it talks about thermostats 

12 in general. And we're saying, as a subcommittee, 

13 we think that should be included. 

14 Joe, to your question, manufacturers are 

15 doing that on every home already today. So I 

16 think it's pretty easy to say that that's an easy 

17 one, right? This is not a cost issue. We're 

18 already doing this. Thermostats are required in 

19 the HUD code. So I think we could probably get 

20 everybody to, you know, come to consensus on that 

21 one. 

22 But the subpart under that that says you 
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1 got to have a programmable thermostat, that's 

2 where Manny pointed out that that section, that 

3 subsection is not necessarily part of what we're 

4 recommending be included. 

5 And if it were, okay, because 

6 programmable thermostats are not part of the HUD 

7 code currently, if we did have that as something 

8 that the subcommittee says that we want to 

9 include, then that would be flagged as, "Hey, 

10 that's an item that we need to perform a cost 

11 on." 

12 But in this case, since the committee is 

13 not recommending the programmable thermostat, 

14 that we're only mentioning the thermostat part, 

15 that I think we could probably put this one up 

16 for vote right now. 

17 And that's kind of the way I think we 

18 should do all of these, where were saying there's 

19 an inclusion. If there's an inclusion and it 

20 doesn't impact cost, and it's something that 

21 we're already doing, then why not vote on it now 

22 and get it done? 
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1 MR. SANTANA: Right, and I agree. And I 

2 think that's -- that's the way that I was 

3 approaching this, is that we're submitting items 

4 that we think, just as a whole, a lot of these 

5 items are just general, you know. And, ducts, 

6 you should seal ducts. You know, we all think 

7 that's a good idea. 

8 One way or another, unless I'm mistaken, 

9 I think that the HUD code even requires that. 

10 So, there could be a cost if you had more 

11 specific requirements. Like, you know, for 

12 controls, it just says, if you include an 

13 appliance to heat or cool, you have to send a 

14 thermostat with it. That's a good idea. 

15 You know, HUD doesn't specify what kind 

16 of thermostat or how expensive. But we will do 

17 what Mark said, and I think that's what we should 

18 do. If there's something here in general that we 

19 think is a good idea, you know, these are going 

20 to be mandatory provisions, which are going to 

21 probably apply to any path that we ultimately 

22 agree on, or agree to. 
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1 You know, if we could identify general 

2 statements that we can vote on and then have as 

3 part of a final potential term sheet, then I 

4 think we should. And the ones that -- you know, 

5 if there is anything that we thought could have 

6 an increase in cost that wasn't being done now or 

7 wasn't required now uniformly, we would flag it, 

8 definitely. 

9 MR. RAMIREZ: Okay. Mark? 

10 MR. WEISS: Mark Weiss, MHARR. 

11 I mean, I certainly don't have a problem, 

12 and if anything is constructive, as Mark Ezzo 

13 suggested, to flag items where we believe there 

14 will be no cost impact, based on the information 

15 that we have at this point. 

16 I do have a problem with taking piecemeal 

17 votes on parts of this, even if the current 

18 thinking is that it will have no impact until we 

19 see the entire broader package. If any votes we 

20 take at this point are not binding, if they're 

21 subject to revision later, that's one thing. But 

22 I'd be very hesitant to start trying to nail down 
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1 a consensus right now, piecemeal, based on the 

2 current state of the record. 

3 MR. RAMIREZ: Lois. 

4 MS. STARKEY: If there's a way, I mean, 

5 maybe we can just, you know, do it like the IRC 

6 groups, the ANSI groups do and just agree 

7 informally that we all agree. There's a word for 

8 it; I don't know what it is because I don't serve 

9 on any of those committees. 

10 But I think maybe, if there's a way we 

11 can just -- so we don't have to go back and go 

12 through every item. But I do think we need to be 

13 careful about -- I'd like to -- maybe just we say 

14 "no impact." 

15 Maybe on the side of each, instead of 

16 agreeing, voting on items that we know we want in 

17 or we think aren't going to have an impact, just 

18 say "no impact" or "cost impact." And then we'll 

19 know which ones we have to look at. 

20 And then, when we get it, we'll have -- I 

21 just don't like the idea of doing it piecemeal 

22 either. I'm uncomfortable with that in terms of 
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1 taking votes. 

2 MR. WEISS: Yeah. I think that makes a 

3 lot of sense. I think we should note, with these 

4 specific items, if the subcommittee folks, the 

5 technical folks think there is no cost impact, 

6 particularly because if something that's already 

7 being done now under the HUD code, that should be 

8 duly noted. 

9 That's a pretty good indication that 

10 probably there is not going to be any cost 

11 impact. But I think that's the way to do it 

12 rather than trying to nail down consensus right 

13 now on each particular item. I would simply flag 

14 that as following up basically on Joe's 

15 suggestion earlier. 

16 MR. RAMIREZ: What about having an 

17 exclusion, and the only exclusion or the only 

18 thing that could overturn a consensus would be 

19 that if there is a cost impact that the group 

20 would say is not acceptable, right? 

21 So, in other words, what we're saying 

22 here is that, "Hey, look. It's reviewed. The 
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1 group, the subcommittee is saying, "Yeah, it's 

2 going to be included there in some format." But 

3 the only thing then later that would overturn it 

4 if the cost associated with it was not tolerable. 

5 So that way it doesn't open it up to a 

6 bunch of other stuff, and we could start 

7 narrowing the focus. 

8 Yeah, Mark. 

9 MR. WEISS: Well, for my part, I still 

10 have some technical consultations I need to do. 

11 I don't think that those will result -- I don't 

12 think those will result in changing what the 

13 technical folks on this committee have said. But 

14 I'd be reluctant to do that. 

15 MR. RAMIREZ: Is someone on the phone? 

16 [Pause.] 

17 MR. RAMIREZ: Okay. So, look. As part 

18 of what, as a facilitator, we need to try to do 

19 is to help you get to agreement, right? Or at 

20 least agree that there is no agreement, right? 

21 But some conclusion. 

22 And if we can't start to narrow stuff 
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1 down, we're never going to get there or it's 

2 going to take too long to get there. 

3 And I understand the concern of the 

4 overall. You know, the affordability is front 

5 and center. We get that. And for that reason, 

6 I'm suggesting that if, later on, a cost 

7 associated with it is not acceptable by the 

8 committee, for that reason alone then could we 

9 overrule a consensus. 

10 MR. LUTER: This is Rob at Lippert. 

11 Are we not discussing just whether or not 

12 to include these are part of the conversation? 

13 MR. WEISS: Mark Weiss. Right. That's 

14 what I'm getting at. 

15 MS. HOFFMAN: Right. Yeah, first we want 

16 to thank the committee, who worked very hard on 

17 this. And it's really -- I think your original 

18 charge was, what in the IECC 2015 code concerns 

19 manufactured housing, and what do we have to deal 

20 with? 

21 So we're going through this. We've 

22 agreed on, approved your exclusions. And now 
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1 we're talking about your inclusions. 

2 Now, obviously, some of them are going to 

3 have some cost impact, and others are what you're 

4 already doing. So, yes. I think that's true. 

5 MR. WEISS: Well, that being the case, 

6 there's really not a lot of downside risk than to 

7 consensus that we ought to talk about these 

8 things. I'll add one caveat, that we probably 

9 ought to clarify the inclusion or exclusion of 

10 subordinate clauses just as a matter of 

11 recordkeeping. 

12 MR. RAMIREZ: Yeah, and that's kind of 

13 what was muddying it up there, right? 

14 MR. WEISS: Yeah. 

15 MR. RAMIREZ: But I understand, too, that 

16 the group, that there's 10 items, 10 sections 

17 that are identified out of 25. Is that correct, 

18 Manny? 

19 MR. SANTANA: Yeah. 

20 MR. RAMIREZ: And the reason that those 

21 others were not in here was because there may be 

22 some cost or further discussion that you would 
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1 have to have on them, correct? 

2 MR. SANTANA: That's exactly correct. 

3 MR. RAMIREZ: Yeah. So these are the 

4 ones that the group -- 

5 MS. HOFFMAN: These are the easy ones. 

6 [Laughter.] 

7 MR. RAMIREZ: Yeah, that the group would 

8 supposedly look at and say, "You know what? 

9 Either yeah, these should be included fairly 

10 easily because it has none or very minimal cost 

11 impact." 

12 MR. LUBLINER: This is Mike Lubliner. 

13 MR. RAMIREZ: Yeah. 

14 MR. LUBLINER: I'd like to speak about 

15 what Joe originally noted and Mark Ezzo 

16 suggested. I support -- these were no-brainers 

17 that we're talking about that we approved in this 

18 committee. I don't understand why we shouldn't 

19 be able to move forward and deal with those, and 

20 really deal with the more controversial stuff. 

21 If we continue this, we're never going to 

22 get anywhere with this committee. So I have some 
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1 concern. I support what Mark said. 

2 Thermostats, everybody puts a thermostat 

3 in a house. Let's vote on it. And I do believe 

4 that this is the process we should be using, or 

5 we're really going to be wasting a lot of time 

6 and drawing things out that don't need to be 

7 drawn out. 

8 Having said that, I'd like to just make 

9 one last point, and then I'll be fine. 

10 MR. RAMIREZ: Go ahead, Michael. We'll 

11 hear you. 

12 MR. LUBLINER: And that gets to Joe's 

13 question and Mark -- I think it's important that 

14 if there's an item that has a cost, the first 

15 cost impact, or an energy savings impact, that 

16 needs to be noted and discussed with the full 

17 committee. 

18 I also think it's important that not only 

19 we identify if there's a cost impact or a thermal 

20 impact, but whether or not, as it's been noted, 

21 that it's required in code already, so if it's 

22 the status quo, or it's being offered as an 
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1 option, like a thermostat that's programmable or 

2 a duct test or a duct sealing that's beyond 

3 minimum code. 

4 So I'd like to see sort of four metrics 

5 for these. You know, is it something they build? 

6 Is it something that's required in the minimum 

7 code? And I guess, is there a cost implication 

8 and is there an energy savings implication? 

9 So those are my two points. Thank you. 

10 MR. RAMIREZ: All right. Let's get 

11 Isabel, then Mark. 

12 MS. DICKENS: Thanks, Javier, this is 

13 Isabel Dickens, NMHOA. 

14 So, I agree with Mike and Mark. I think 

15 it's important that as we go through the process, 

16 to the extent that we can we should start to 

17 practice having consensus on some of these 

18 issues. 

19 And I think it's sort of like, you know, 

20 Javier, you talked about how you eat an elephant 

21 one bite at a time. Well, how do you create an 

22 elephant? You add the tusks. You create a 
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1 trunk. You add a tail. You create some, you 

2 know, legs and feet, whatever. 

3 I think we can start to build our 

4 picture, our jigsaw puzzle, and put the pieces 

5 together so that we end up with our ultimate term 

6 sheet. 

7 And I know there may be things that we 

8 can sort of -- you know, let's practice. Let's 

9 put some things on the -- you know, it won't 

10 quite be the proxy model, it will be the 

11 consensus term sheet, whatever we want to call 

12 it, and just start putting some things in there. 

13 Maybe we'll have to readjust it as we go 

14 along. But I'm worried that we might almost lose 

15 things if we don't start to actually practice 

16 consensus and put them somewhere, save them 

17 somewhere so that we have them for the ultimate 

18 product, ultimate term sheet. 

19 So if this is indeed -- it feels as if 

20 this could be a fairly easy one to get consensus 

21 on right now. Everyone appears to be doing it. 

22 Let's just practice consensus and -- because 
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1 otherwise, we aren't going to get everything done 

2 within the timeline that we're supposed to. 

3 Thank you. 

4 MR. RAMIREZ: Thank you. 

5 Mark? 

6 MR. WEISS: Yeah. Thanks, Isabel. 

7 I think perhaps the greatest danger to 

8 achieving consensus is trying to eat the elephant 

9 too fast. And I didn't mean to get into this 

10 whole extended discussion. I was just trying to 

11 clarify that the way I was looking at this, and 

12 in terms of voting on the subcommittee, voting 

13 here today. 

14 And essentially, the way I see it is 

15 there are two aspects to this. You have the 

16 technical aspect. What parts of the IECC 

17 mandatory provisions simply are not applicable or 

18 appropriate for manufactured housing and are 

19 excluded? And which sections are potentially 

20 applicable and potentially relevant and something 

21 we want to consider? And those are, quote22 unquote, "included." 
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1 When you start getting into cost, that 

2 gets into all sorts of judgments and into other 

3 data and values that are not directly relevant to 

4 the technical -- at least right now, to the 

5 technical issue of what we're putting in and what 

6 we're putting out. 

7 Once we decide what's on the table and 

8 what we're going to consider for the ultimate 

9 part of the term sheet, then the cost aspects can 

10 be applied to those sections and considered 

11 individually or cumulatively or however they need 

12 to be considered. 

13 But to start getting into cost now and 

14 trying to push this too far too fast, I think, 

15 presents a problem. 

16 I'll leave it at that for now. 

17 MR. RAMIREZ: Okay. So, just to be 

18 clear, Manny, were you saying that what you have 

19 on in your 403.1 is 403.1, not 403.1.1 or 

20 403.1.2.? 

21 MR. SANTANA: Exactly. 

22 MR. RAMIREZ: Okay. 
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1 MR. SANTANA: Yeah. It's only 403.1. So 

2 that's only the statement that says, "At least 

3 one thermostat should be provided for each 

4 heating and cooling system." So I guess, just so 

5 that it doesn't run all the time or never run, or 

6 so you don't have to, you know, hit a switch when 

7 you want it on or off. 

8 MR. RAMIREZ: Okay. Got you. 

9 Mark? 

10 MR. WEISS: I just thought of the one 

11 thing that I forgot in what I said a minute ago. 

12 I don't have any objection whatsoever to 

13 flagging what is current practice and-or 

14 currently required under the HUD code. If that's 

15 what's being done now, that's a relevant factor 

16 that should be flagged and considered by the full 

17 committee. So I have no problem with that at 

18 all. 

19 MR. RAMIREZ: Lowell? 

20 MR. UNGER: Two things. I really hate to 

21 prolong this. But I heard Manny say what seems 

22 contradictory things on the last question of 
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1 what's included. But for 403.1, 403.1.2 is also 

2 mandatory. So I had understood that that was 

3 included, but 403.1.1 was not, because that's not 

4 mandatory. 

5 MR. RAMIREZ: Okay. 

6 MR. SANTANA: Okay. What I meant is that 

7 403.1.2 was included in consideration. It wasn't 

8 included in a recommendation, because we didn't 

9 come to a consensus. And we didn't come to a 

10 consensus, you know, because there was cost 

11 impacts and other stuff. 

12 So anything mandatory, the working group 

13 or the subcommittee considered. But just, we 

14 only presented stuff that we can agree to. 

15 And, you know, I will say that the 

16 subcommittee is composed of a kind of a cross 

17 section of our membership. You know, we're not 

18 all one faction, you know. Not everybody voted 

19 unanimously. I think, Mark, why he had his thumb 

20 sideways on a few of these. But it just wasn't 

21 down. So it allowed us to present. 

22 MR. UNGER: So that gets to my second 
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1 question, which was, there's still this list, as 

2 has been pointed out, of roughly 15 items. And 

3 that's a third list. And I'm told that 403.1.2 

4 was on that. 

5 So, if this -- I mean, I'm trying to 

6 understand the two lists. I had understood that 

7 the third list of 15 were items that are relevant 

8 to manufactured housing, but there wasn't 

9 agreement that they should be part of the 

10 standard, in which case that would mean to me 

11 that the subcommittee is recommending for this 

12 list of 10 or so items that they are both 

13 relevant and should be included. 

14 But am I misunderstanding that? 

15 Otherwise, I'm trying to hear what the difference 

16 is between these two lists. 

17 MR. SANTANA: Okay. When you say 

18 "lists," you mean the lists that are on the 

19 screen right now? 

20 MR. UNGER: I mean it was my 

21 understanding that there were 30-something 

22 mandatory provisions. 
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1 MR. SANTANA: Correct. 

2 MR. UNGER: We already went through the 

3 list of provisions which the subcommittee 

4 believes are not relevant to manufactured 

5 housing. 

6 This is now the rest of them, presumably, 

7 are -- my understanding -- are relevant to 

8 manufactured housing. 

9 MR. SANTANA: Correct. 

10 MR. UNGER: But there's a list that were 

11 agreed by the subcommittee. And I mean, I'm 

12 confused now, because some people are presenting 

13 these as agreed that they're relevant. But 

14 there's this whole other list, which I thought 

15 was relevant. 

16 So I had understood that these were 

17 agreed that they should be included. 

18 MR. SANTANA: Okay. I see what you mean. 

19 Right, right. 

20 So there's 25 sections which are labeled 

21 "mandatory" in Chapter 4, correct. And out of 

22 those 25, we, the subcommittee, discussed all 25 
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1 of them. 

2 When anywhere where we could have either 

3 uniform or a vast majority, or at least no 

4 dissenting opinions on an item, then we either 

5 regrouped them, which either exclude or include. 

6 It was easier to exclude, because they obviously 

7 don't apply. They're not, you know, so they're 

8 not appropriate. 

9 It was harder to include, because we had 

10 some of these concerns. You know, the only ones 

11 that we're presenting are items that we came to a 

12 consensus and are able to recommend. 

13 The other items are still under 

14 discussion. But -- and I'll back up a little 

15 bit. But I understand. 

16 MR. UNGER: I'm sorry. When you say that 

17 "the subcommittee is recommending to include," 

18 you mean the subcommittee is recommending that 

19 these provisions be included in the manufactured 

20 housing standard? 

21 MR. SANTANA: To the working group. 

22 Right, right. So the subcommittee is 
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1 recommending to the working group that these 

2 provisions either be included or excluded. Or we 

3 feel that, as written in its entirety in the 2015 

4 IECC, as they exist today, they can be considered 

5 and voted on by the working group. 

6 That's the recommendation. We're saying, 

7 these things -- the other sections, the 

8 subcommittee won't be comfortable submitting them 

9 without some kind of revision. 

10 MR. UNGER: Right. Thanks, Manny. 

11 MR. SANTANA: So, you know, if the 

12 subcommittee is allowed to continue its work, the 

13 next submittal or the next set of recommendations 

14 to the working group are going to be actual 

15 sections that have modifications to them. 

16 Make sense? 

17 MS. STARKEY: Yes, yes. 

18 MR. RAMIREZ: So this is the fruit that 

19 you could grab without a stepladder? 

20 [Laughter.] 

21 MR. SANTANA: Exactly. We got this off 

22 the ground. 
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1 MR. RAMIREZ: Oh, okay. All right. 

2 Good. 

3 MS. STARKEY: Then I would suggest that 

4 we vote on it as a package, but we change the 

5 title. And that would satisfy me and the rest of 

6 my members, to say items to include for 

7 consideration in an MHI energy standard. 

8 MR. RAMIREZ: And maybe I'm missing 

9 something, but that's somewhat the reverse of 

10 what I just heard, was that this is the fruit 

11 that was on the ground that we should be able to 

12 easily agree on, that these are included. 

13 And again, 403.1, that's 403.1. That's 

14 not 403.1 and 403.1.1 and 403.1.2. That's 403.1, 

15 which states, "At least one thermostat shall be 

16 provided for each separate heating and cooling 

17 system," period. That's it. 

18 MR. ROY: This is Robin. I have a 

19 question for Lois. 

20 MS. STARKEY: Yeah. 

21 MR. ROY: Am I hearing you right that 

22 then it's some question about whether a heating 
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1 and cooling system should have a thermostat? Is 

2 there any question at all? 

3 MS. STARKEY: No. No. In fact, I'm 

4 leaving it up to the technical people to decide 

5 that. I just want to make sure that we're clear 

6 that these items, that we're not voting on a part 

7 of a standard until we see the whole standard. 

8 And so -- but I don't want to belabor it 

9 anymore, because it put it on the record that 

10 that's my only point, that I don't want to have 

11 at some point come back the possibility, and say, 

12 "Well, Jesus, now that we've done this to the 

13 standard, we don't want to do this." 

14 But then somebody's going to come back 

15 and say, "Well, we've already done consensus on 

16 this." 

17 MR. ROY: Yeah. I understand. Right. 

18 MS. STARKEY: So I think everybody 

19 understands that. I just want to make it clear 

20 for the record, that this is only a piece of the 

21 standard. 

22 MR. SANTANA: This is Manny again. 
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1 You know, one of the things that came up 

2 during our discussion was, you know, how do we 

3 make sure that we're not going to recommend a 

4 section that might run counter to something that 

5 Emanuel's proposing or something that Robin is 

6 proposing? 

7 So we were sensitive to that. And we 

8 just thought, well, if something gets through our 

9 little subcommittee and it comes to the main 

10 working group, and it contradicts or conflicts, 

11 then it will get struck down there. We're just 

12 bringing this up for discussion. 

13 You know, we think that this thing is -- 

14 you know, we got it off the ground, and we think 

15 it's edible. And now we can talk about it. 

16 MR. RAMIREZ: Okay. Let me get Keith and 

17 Mark. 

18 MR. WEISS: Would it be possible just to 

19 move things along to just call it "preliminary 

20 consensus"? And then later on, just do a quick 

21 vote at the end, like along the lines of what -- 

22 because I think we can vote preliminarily and 
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1 then say it's not binding. 

2 MR. HAGERMAN: Joe Hagerman. 

3 I agree with that, as long as we just 

4 also flag the cost-no-cost. And then also make 

5 sure that when you do put up a number, like 403.1 

6 up there, that everybody's clear that it doesn't 

7 include the subordinate clauses. Or if it does, 

8 we explicitly say it includes the subordinate 

9 clauses. 

10 MR. RAMIREZ: Yeah, we could put in the 

11 numbers. If it does include subordinate ones, 

12 then we'll put those in there specifically, in 

13 that far left column. 

14 MS. HOFFMAN: There's a proposal to do 

15 PC, or preliminary consensus, for all of these 

16 items once we go through that. Is that 

17 agreeable? Let's get a vote on that so we can 

18 move ahead. 

19 And from our folks at home and on line? 

20 MR. WEISS: Thumbs up. 

21 MS. HOFFMAN: Okay. Preliminary 

22 consensus. 
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1 MR. WEISS: We're going with preliminary 

2 consensus. 

3 MR. SANTANA: We'll note -- Javier, is 

4 there any way you can scroll up on your screen 

5 here? If you scrolled up to the exclusions, if 

6 you take a look at 403.10, you know. So we're 

7 going to -- the way that I saw this is that the 

8 section only applies to the section. That's one 

9 of our standing rules, I guess, unspoken. 

10 But it only applies to the section. And 

11 whenever it includes any of the subordinate 

12 sections, we would state so, such as 403.10. We 

13 said there that exclusion includes everything 

14 that's a subset of that. It's important to make 

15 that distinction, though, yes. 

16 MR. RAMIREZ: Thank you, Manny. 

17 MR. WEISS: And one other point, this is 

18 what Joe said. I think the more important thing 

19 at this point is to indicate whether it's current 

20 practice or not, or required by the HUD code 

21 currently or not. 

22 MR. RAMIREZ: Okay. So, 403.1, is this 
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1 current practice? You could put a yes in there. 

2 Okay. The PC for consensus is 403. 

3 MS. HOFFMAN: Is there -- there is. Is 

4 there preliminary consensus on that? 

5 MR. RAMIREZ: On 403.1. Okay. And there 

6 is no potential, additional potential cost 

7 impact, right, of providing a thermostat? That 

8 is current practice. So we'll talk about 

9 additional costs. 

10 Now, 403.1, that might be another story. 

11 Is that -- 1.1. Is that accurate? 

12 MR. SANTANA: 403.1.1 wasn't on the list. 

13 MR. RAMIREZ: Right. Right. So I'm 

14 drawing that distinction then. So, 403.1, there 

15 is no additional cost impact. It is the current 

16 practice. Is that accurate? Mark? 

17 MR. SANTANA: Yes. 

18 MR. WEISS: I mean, I'll rely on the 

19 engineers on this. You know, I don't know if it 

20 makes a difference going through two-by-six studs 

21 instead of two-by-four in this installation 

22 versus that installation, or where it might be 
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1 put and whether there's other labor or not. 

2 You know, they're the ones that tell. 

3 Like I said earlier, I'd be happier saying 

4 current practice, not current practice -- HUD 

5 code, not HUD code. And you know, there's 

6 probably no cost impact, but it's got to be 

7 considered as to, you know, part of the final 

8 package. 

9 But since it's all preliminary, I'll just 

10 put that on the record and be quiet. 

11 MR. RAMIREZ: All right. Good thing 

12 we're starting off with the easy stuff, right? 

13 [Laughter.] 

14 MS. HOFFMAN: That elephant, a little 

15 Tabasco works. 

16 MR. RAMIREZ: Okay. So let's go on to 

17 403.3.2. 

18 MR. SANTANA: Okay. 403.3.2 is on page 

19 R-35. And it also includes two exceptions. So 

20 403.3.2 includes the two exceptions. 

21 This deals with the sealing of ducts, 

22 filter boxes, and air handlers. We believe that 
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1 the section can be included, but there's a 

2 sentence there, if you see the second sentence of 

3 403.3.2, it says, "Joints and seams shall comply 

4 with either the IMC or the IRC as applicable." 

5 We believe that sentence should be omitted. 

6 [Pause.] 

7 MR. LUBLINER: Manny, Mike Lubliner here. 

8 Could you share with the group why you 

9 believe that the provisions in the IMC and the 

10 IRC should be omitted? I thought what we said is 

11 we didn't even look at those. 

12 MR. SANTANA: Right. And you were going 

13 to look at those, as I recall. 

14 MR. LUBLINER: Yes. 

15 MR. SANTANA: The reason why I wanted to 

16 omit that sentence is because it references 

17 standards that aren't referenced in the HUD code. 

18 So including any kind of reference to another 

19 standard is just going to -- you know, and again, 

20 keeping it in the spirit of generalizations, 

21 generalities, right? 

22 Duct air handlers and filter boxes shall 
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1 be sealed -- that was the important concept. You 

2 know, how that's to be done or to what tightness, 

3 it doesn't get into that. It just says, you 

4 know, do you want to have sealed ducts and air 

5 handlers? 

6 MR. LUBLINER: Yeah, I agree that -- 

7 MR. SANTANA: Right. 

8 MR. LUBLINER: I guess my point there is 

9 that we didn't look at whether there were 

10 positive improvements if we adopted language in 

11 the IRC or the IMC. I personally believe there 

12 are with respect to the subject. 

13 We didn't look at that. And so -- 

14 MR. SANTANA: That's correct. 

15 MR. LUBLINER: But what you're saying is 

16 that we're removing it just because the current 

17 HUD doesn't reference the IMC and IRC, not 

18 because there's not value in some of the things 

19 in there. I just want to clarify that. 

20 MR. SANTANA: Right, right. 

21 MR. LUBLINER: Okay. Thank you. 

22 MR. SANTANA: We didn't get into the IMC 
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1 or the IRC to see what exactly they require of 

2 how you seal it or, you know, anything else. 

3 We're -- you know, as it stands, we said this was 

4 acceptable. 

5 MR. LUTER: This is Rob at Lippert. 

6 Aren't we tasked with evaluating this against the 

7 IECC and not the IMC and not the IRC and not any 

8 other code that might exist? 

9 MR. SANTANA: Yes. 

10 MR. LEVY: It's Emanuel. Can I just 

11 interject? Can I make a recommendation we drop 

12 this discussion, because we're going to talk 

13 about specific language later to supersede this 

14 entire section? 

15 MR. RAMIREZ: Okay, Eric? 

16 MR. LUTER: I'm good with that. 

17 MR. LACEY: This is Eric Lacey from RECA. 

18 As to the issue of referenced standards, 

19 there are a number of standards referenced in 

20 here, and I don't think that we can say that just 

21 because the scope is focused on the IECC that we 

22 can ignore all the standards that are referenced 
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1 in the IECC. 

2 In this case, I thought it made sense to 

3 drop a for-now provisionally. If we want to put 

4 specific requirements in there, or add it to the 

5 duct testing or other requirements, it would make 

6 more sense to put the requirements right in the 

7 standard rather than reference another code book. 

8 But there are other labeling standards 

9 and things that are referenced in here that I 

10 think we should be evaluating and including. I 

11 just wanted to include that. 

12 MR. RAMIREZ: Manny, did you say, is this 

13 going to be in one of your straw men? 

14 MR. LEVY: That's right. 

15 MR. RAMIREZ: I'm sorry, Emanuel, yeah. 

16 MR. LEVY: Yes. 

17 MR. RAMIREZ: Yeah. So is the group okay 

18 with tabling 403.3.2 to deal with it in Emanuel's 

19 straw men? 

20 [Pause.] 

21 MR. RAMIREZ: All right. Let's do that. 

22 All right. 403.3.5. 
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1 MR. SANTANA: Okay. 403.3.5, that's on 

2 page R-35 as well. This section deals with 

3 building cavities. And it reads, "Building 

4 framing cavities shall not be used as ducts or 

5 plenums." 

6 We don't know, or the members of the 

7 subcommittee didn't -- weren't aware of any 

8 manufacturers that are currently using framing 

9 cavities as ducts or plenums. So we didn't 

10 believe this was going to be a cost issue. 

11 MR. RAMIREZ: Okay. Is this the current 

12 practice? 

13 MR. SANTANA: We believe so, yes. 

14 MR. RAMIREZ: Okay. Let's go and put yes 

15 on this. 

16 [Inaudible interjection.] 

17 MR. RAMIREZ: That is the current 

18 practice, so we'll just put yes that it's the 

19 current practice. So if that is the current 

20 practice, then in order to adopt this, there 

21 would not be any additional costs, correct? 

22 Mark? 
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1 MR. WEISS: I had a question, if I can 

2 call on Rick. And you may not know. Are you 

3 aware of any approved designs that have anything 

4 different than what these guys are saying? 

5 MR. MENDLEN: At one time, return-air 

6 plenums were used for framing. I don't know 

7 whether that's still being used or everybody's 

8 still returning air through the undercut doors. 

9 So it's possible. 

10 MR. WEISS: Yes, so that's something 

11 we'll have to check and follow up on, that I 

12 will. 

13 MR. RAMIREZ: So then, as far as 

14 potential cost impact, you're saying that's a 

15 question mark? 

16 MR. WEISS: Yes, as to whether it's 

17 current practice and a potential cost impact, I 

18 guess those two go hand in hand. But it's 

19 something I'll have to address with my members. 

20 MR. RAMIREZ: Okay. 

21 Eric? 

22 MR. LACEY: This is Eric with RECO. 
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1 MR. LUBLINER: This is Mike Lubliner. 

2 MR. RAMIREZ: Mike, hold on one second. 

3 MR. LUBLINER: Okay. 

4 MR. RAMIREZ: Go ahead, Eric. 

5 MR. LACEY: Could I just suggest that on 

6 these issues, could we just say, "No, subject to 

7 check"? And put the onus on, if you're concerned 

8 about it or if you want to follow up on it, you 

9 know, you take it on yourself to go look it up. 

10 But if all the manufacturers are saying 

11 this is current practice, there shouldn't be a 

12 cost impact, you know, it may be that there's a 

13 cost impact. And we should find that out. But 

14 I'm afraid that we're just going to be bombarding 

15 DOE with follow-up items on a lot of issues that 

16 we may not need to. 

17 And if it really is going to be a cost, 

18 and if there are lots of designs out there that 

19 we're not aware of, we should find out. But can 

20 we, in the name of consensus, say, "No, subject 

21 to check"? 

22 MR. WEISS: That's fine with me. You can 
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1 even put my name on there, so as -- they already 

2 did -- so I'll know I have to check it rather 

3 than digging through all this. 

4 [Laughter.] 

5 MS. HOFFMAN: Are you saying there's a 

6 preliminary consensus on this item and we can 

7 move ahead? Or -- okay? All right. 

8 Let's go on, please. We've got a lot to 

9 do today. 

10 MR. LUBLINER: This is Mike Lubliner. 

11 MR. RAMIREZ: Yeah, Michael. 

12 MR. LUBLINER: Yeah. I had suggested 

13 that, besides saying whether there's a cost 

14 impact with any of these, we also note whether or 

15 not there's an energy savings impact, because 

16 costs cut both ways. 

17 So, you know, here's one. If you were 

18 going to do that, this is clearly one where 

19 you're going to get some potential significant 

20 energy savings if you don't use a pan joist for 

21 your duct work. 

22 I'm just proposing that we also, if we're 
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1 going to be tracking costs, first costs, saying 

2 that the costs need to -- 

3 MR. RAMIREZ: You faded out there, but I 

4 think we got the gist of it. 

5 MR. LUBLINER: Also, I support where Eric 

6 has gone on his comment. Thank you. 

7 MR. RAMIREZ: So, I guess we can modify 

8 the "energy savings" to "energy impact," right? 

9 Because it might actually -- 

10 MR. UNGER: Yeah, just have cost and 

11 savings collectively, and not try to be too 

12 precise here. 

13 MR. RAMIREZ: Okay. 

14 MR. UNGER: I'm good with what I see now. 

15 MR. RAMIREZ: Okay. All right. Yeah, so 

16 you could delete that column. 

17 [Pause.] 

18 MR. SANTANA: Am I clear to continue? 

19 MR. UNGER: Yeah, I think 403.5, they're 

20 both -- there's energy savings implications as 

21 well as cost implications. 

22 MR. RAMIREZ: Right. 
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1 Okay. 403.4. 

2 MR. SANTANA: Okay. 403.4, it's on page 

3 R-35. It deals with insulation for mechanical 

4 system piping. Requires an R3 of insulation 

5 whenever a piping for mechanical system has the 

6 ability to convey fluids above 105 degrees 

7 Fahrenheit or below 55 degrees Fahrenheit. 

8 MR. RAMIREZ: And is that current 

9 practice? 

10 MR. SANTANA: I think that's current 

11 practice, because the system would require that 

12 to be insulated. And, you know, we'll add that 

13 R-403.4 does not include R-403.4.1. 

14 MR. RAMIREZ: Okay. So solely at 403.4, 

15 you're under the understanding that that is 

16 current practice? 

17 MR. SANTANA: We believe it to either, 

18 one, be current practice, or not very applicable, 

19 because, you know, there isn't a whole lot of 

20 inclusion of mechanical systems in the plant that 

21 would require this insulation. 

22 MR. LUBLINER: Manny, Mike Lubliner here. 
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1 One thing, I think you're right. If we 

2 were, say, putting in a mini-split heat pump in 

3 the factory and shipping it with the home, which 

4 is starting to get done by some people in the 

5 country in this sector -- but very few, you know, 

6 a half-dozen homes. 

7 You know, basically, we're going to be 

8 required that that refrigeration piping, the live 

9 set, is insulated. But that's part of the heat 

10 pump manufacturer's installation, right, 

11 requirements. 

12 So I think, by default, those kind of 

13 things, if it's required in the installation of 

14 the manufacture of the product, then you guys are 

15 required to put it into that. 

16 So I think, yeah, you're absolutely 

17 right. Here's a situation where, you know, 

18 you're not doing a lot of it. But if you were, 

19 it wouldn't matter whether or not we had this in 

20 here because it's required based on the policy, I 

21 believe, the HUD policy, that if something is 

22 required in an installation manual by a 
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1 manufacture of heating equipment, then you have 

2 to comply with that. 

3 And if I'm wrong, maybe Rick or one of 

4 the manufacturers can clarify that. Thank you. 

5 MR. RAMIREZ: All right. Let's see a 

6 show of thumbs if you're okay with 403.4. 

7 Okay. We're okay with that one. 

8 MR. SANTANA: Okay. R-401.4 is on page 

9 R-37. 401.4 is going to have a cost impact, so 

10 we could just go ahead and flag that now. 

11 Whether the cost impact is to the manufacture or 

12 the retailer, that's a distinction. But it will 

13 be a cost impact for the consumer. 

14 So now, what this says is, it requires 

15 that not less than a certain percentage of the 

16 lamps which are installed be high efficacy. 

17 MR. WEISS: Just for the record, that's 

18 401.1. 

19 MS. HOFFMAN: That's 404.1. 

20 MR. WEISS: Not point-four. 

21 MS. HOFFMAN: Yeah. So, R-404.1 on page 

22 R-37. 
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1 MR. RAMIREZ: All right, so -- 

2 MR. SCHNEIDER: This is Peter. I'm just 

3 saying this is Peter. 

4 The same lamp, we're talking about the 

5 bulb, really. I mean, as far as meeting the 

6 least-cost path to meet this requirement would be 

7 to stick with the exact same lamps you're using 

8 and to put in screw-in compact fluorescent bulbs. 

9 MR. SANTANA: Right, it actually has two 

10 ways. It says that not less than 75 percent of 

11 the lamps, or the bulbs, in permanent fixtures be 

12 high efficacy, or not less than 75 percent of the 

13 fixtures are only able to take high-efficacy 

14 bulbs. 

15 MR. SCHNEIDER: Right. So, I wouldn't 

16 recommend, you know, you could do like GU-24, 

17 which have sort of the hockey-puck type thin-base 

18 bulbs. But typical screw-based compact 

19 fluorescent bulbs are allowable with the typical 

20 lamps that are already being used. 

21 So, the incremental cost to meet this 

22 standard, at the bare minimum, that is the least-
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1 cost approach, would be a very small incremental 

2 cost. 

3 MR. SANTANA: Well, you know, it could 

4 just be the cost of the bulbs. You know, because 

5 if you take -- one scenario is that a 

6 manufacturer installs the exact same thing he 

7 installs now, which are the lithium, that's the 

8 screw-type bulb. And they ship to home typically 

9 without any of the bulbs. 

10 You know, so the cost would be incurred 

11 by whoever installs the bulbs. But then an 

12 argument can be made, should this requirement be 

13 in the standard if it doesn't apply to the 

14 manufacturer if the manufacturer doesn't ship the 

15 bulbs? You know, how do you enforce it once -- 

16 but then, you know, we figured that's a question 

17 for enforcement. 

18 MR. SCHNEIDER: Why are the bulbs not 

19 included, Manny? 

20 MR. SANTANA: Because they break. 

21 MR. LACEY: This is Eric Lacey from RECA. 

22 Just a note to DOE on this one. We had 
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1 some discussion about when the bulbs actually get 

2 installed. Historically, DOE has assigned some 

3 energy savings to the bulbs. Now, I'm not sure 

4 how much energy savings you get, given the 

5 federal standards updating and so on, but I 

6 thought I would just flag this for you on the 

7 energy savings impact. 

8 And I don't know what the right answer is 

9 on this. You know, if they eventually -- if they 

10 get put in by the retailer, for example, and not 

11 the manufacturer, do you assign those savings to 

12 the overall cost-benefit analysis or not? It's 

13 an issue that we didn't really resolve on the 

14 call, but it's something that we should continue 

15 to think about. 

16 MR. LEVY: It's Emanuel. 

17 Manny, is it your intent here that this 

18 provision only apply if the manufacturer 

19 installed bulbs? And it not be construed to mean 

20 the manufacturer must install bulbs? 

21 MR. SANTANA: That is correct. 

22 MR. LEVY: I wonder if we should add the 
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1 language that "If the manufacturer installs 

2 bulbs, then"? 

3 MR. SANTANA: Well, you know, I don't 

4 want to get into the weeds. But with the HUD 

5 program, the manufacture is technically still 

6 responsible to the house up until the first sale. 

7 So anything the dealer does to it, the dealer 

8 can't take it out of compliance with the HUD 

9 standard. 

10 And assuming this -- my statements are 

11 making a lot of assumptions. It's assuming that 

12 HUD is going to be enforcing this or that the 

13 existing HUD requirements are still going to be 

14 enforced. 

15 So, you know, to give you another 

16 scenario, if a manufacturer built a home, and all 

17 the fixtures are screw-in, and ships the home 

18 without any bulbs, and retailer, he installs the 

19 bulbs before he gives it to the consumer, and he 

20 does not install 75 percent high-efficacy lamps, 

21 that home is out of compliance. And the 

22 manufacturer is still responsible for that home. 
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1 You know, but like I said, I don't want 

2 to get too far into the weeds. But, so I think 

3 it's a good idea to -- I don't know if we can 

4 state that it's not mandatory that the 

5 manufacturer install the bulbs. You know, the 

6 way that I read it, it doesn't require that the 

7 manufacturer install the bulbs. Don't know if 

8 that's something we want to add or not. 

9 MR. LUTER: Manny, this is Rob. 

10 Did I misunderstand you? You indicated, 

11 and I don't have the 2015 IECC in front of me. 

12 You indicated there were two paths to compliance. 

13 One was supplying 75 percent high efficacy, and 

14 the other was supplying fixtures that would not 

15 accept anything but high efficacy. Did I hear 

16 that correctly? 

17 MR. SANTANA: Right. Right. That is the 

18 way that I understand it. 

19 You know, the bottom line is that the 

20 code wants 75 percent of the permanently 

21 installed lamps-slash-fixtures to be high 

22 efficacy. Whether it's a fixture that will only 
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1 accept high efficacy or whether it's, you know, 

2 CFL's or screw-in type lamps. 

3 MR. LUTER: Am I correct in assuming that 

4 the permanent fixtures that will only accept 

5 high-efficacy bulbs would also be a cost impact 

6 versus a standard fixture? 

7 MR. SANTANA: Yeah, that will, sure. 

8 That will be a cost impact to the manufacture. 

9 MR. LUTER: So, in other words, no matter 

10 which way this shakes out, whether the 

11 manufacture furnishes bulbs, the dealer furnishes 

12 bulbs, or the manufacturer furnishes high13 efficacy fixtures, there's going to be a cost 

14 impact, period? 

15 MR. SANTANA: There's going to be a cost 

16 impact to the consumer whichever way this shakes 

17 out. 

18 MR. LUTER: Okay. That's what I thought. 

19 Thank you. 

20 MR. SCHNEIDER: There will be, but -- 

21 this is Peter -- it's just a very small, 

22 incremental cost. 
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1 I mean, I use these GU-24 adaptors. If 

2 you didn't want to ship your homes with bulbs, 

3 you can take every fixture that you're currently 

4 using and, for a very low cost -- and this is 

5 just off the shelf one-off -- you can get a GU-24 

6 adaptor that screws into the socket of any 

7 typical fixture that would just accommodate a GU8 24 bulb. 

9 I'm not suggesting we do that, because 

10 ultimately, I don't think that you can access GU11 24 compatible bulbs everywhere. We had them in 

12 every hardware store in Vermont. But my guess it 

13 that's not the case everywhere in the U.S. 

14 But I'd be really interested to delve 

15 into bulbs breaking all the time in homes that 

16 are being delivered. I'm just thinking about a 

17 surface ceiling dome fixture, and that home would 

18 really have to be shaking and moving a lot for 

19 that bulb to break. And I'm just surprised. I 

20 would be interested in seeing the data on that. 

21 MR. RAMIREZ: Eric? 

22 MR. LACEY: This is Eric. 
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1 And I hate to belabor the point here. 

2 But I think there's -- I have a different 

3 understanding of this section and how it 

4 operates. The section doesn't require you to put 

5 in any fixtures that will only accept high6 efficacy bulbs. 

7 What it does is it gives you two options. 

8 One is 75 percent of all the bulbs that are 

9 installed shall be high efficacy, or 75 percent 

10 of the total fixtures will have only high11 efficacy bulbs. That doesn't say "high-efficacy 

12 fixtures," but the bulbs, the lamps, they call 

13 them. 

14 Basically, the bulbs in there, 75 percent 

15 either of all the bulbs installed or all of the 

16 fixtures have to have high-efficacy bulbs. Does 

17 that make sense? 

18 So, for example, if you have a chandelier 

19 that has 20 bulbs in it, you might opt for the 75 

20 percent of -- I don't know which way you'd go, 

21 actually. You could either choose to have all 

22 the bulbs in that chandelier be high efficacy and 
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1 have that be part of your total 75 percent of all 

2 the fixtures. 

3 Or you could include those in the total 

4 count of all the bulbs. I know it's getting into 

5 the weeds here. But I wanted to make sure that 

6 nothing in here requires you to put in a high7 efficacy fixture that wouldn't allow you to put 

8 in a screw-in bulb. 

9 MR. RAMIREZ: Let me just ask one 

10 clarification question here. Maybe it's because 

11 I don't understand the industry. But first of 

12 all, I'd be curious to see the manufactured house 

13 that has a chandelier. 

14 [Pause.] 

15 MR. RAMIREZ: But apart from that, so 

16 apart from that, though, if you screw in one 

17 bulb, aren't you at 100 percent? 

18 MR. SANTANA: So, I mean, if you don't 

19 screw in any bulbs, I guess I'm trying to 

20 understand why we're debating this so much if the 

21 manufacturer has the choice of how many bulbs to 

22 screw in, if any. 
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1 Mark? 

2 MR. LUTER: This is Rob. 

3 I'd like to see the language of the code 

4 up on the screen, if possible. But my guess is 

5 that Manny's original interpretation about 

6 fixtures precluding the installation of anything 

7 but high-efficacy bulbs is probably correct. 

8 You don't write items into a code that 

9 can easily be defeated. If they want high10 efficacy bulbs, and you can get around it by just 

11 not furnishing them, nobody's going to furnish 

12 them, because they cost more than standard 

13 incandescents and they break. 

14 MR. RAMIREZ: Mark? 

15 MR. LUTER: Now, that said, again I don't 

16 have the 2015 code in front of me. 

17 MR. WEISS: Mark Weiss, MHARR. 

18 Eric -- all right. 

19 When we talk about high-efficacy lamps, 

20 we're talking about the whatchamacallit, neon, 

21 whatever, CFL bulbs you see in the store, right? 

22 Okay. Is that base different from the base of an 
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1 incandescent bulb? No. Okay. 

2 So, bottom line here, I think in all 

3 likelihood is, whether you ship them or don't 

4 ship them or whatever, given consumer 

5 predilections, you're probably going to have them 

6 taken out anyway when they get there, I would 

7 expect. But in any event, thanks for answering 

8 the question. 

9 MR. LUBLINER: It's Mike Lubliner. 

10 Our research suggests that most of the 

11 bulbs are retained by the consumers, that there 

12 are some consumers that will take them out. But 

13 I wouldn't characterize that as typical, Mark. 

14 I do totally agree with you, though, 

15 Mark, that this is a no-brainer. I mean, we can 

16 sit here and make the joke, "How many federal 

17 advisory committee members does it take to screw 

18 in a light bulb?" 

19 [Laughter.] 

20 MR. LUBLINER: But if the manufacturer 

21 doesn't need to put it in, then why are we 

22 talking about it? There's always going to be -- 
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1 MR. WEISS: I was setting you up for 

2 that, Mike. Thank you. 

3 [Laughter.] 

4 MR. LUBLINER: Thank you. You, Jay Leno, 

5 Ed McMahon, and Johnny Carson, thank you. 

6 MR. RAMIREZ: So, are you all ready to 

7 gauge the level of consensus on this one? 

8 [Pause.] 

9 MR. RAMIREZ: Let's see if everyone is 

10 okay with 404.1. Let's see a show of thumbs. 

11 [Pause.] 

12 MR. RAMIREZ: Okay. I don't see or hear 

13 any thumbs down. So we're okay with that. 

14 MR. LUTER: I'd just add the comment 

15 that, as if it's truly as written beneath the 

16 table, it's not relevant. Both those statements 

17 say the exact same thing. 

18 [Pause.] 

19 MR. LUTER: And if all you have to do is 

20 not supply the lamps, then -- then, you know, 

21 it's easy to defeat that clause. 

22 MR. RAMIREZ: You mean comply with. 
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1 Right? 

2 MR. LUTER: I don't have any heartburn 

3 leaving it in. 

4 [Laughter.] 

5 MR. LUTER: But we'll both -- if a 

6 manufacturer or homeowner, in the interest of 

7 cost savings, decides to not use $8-apiece 

8 compact fluorescents, or whatever they're selling 

9 for now, then they just -- nothing is making them 

10 do it. 

11 MR. RAMIREZ: Right. Okay. 

12 [Cross-talk.] 

13 MR. LUTER: That said, my thumb is off to 

14 the side. It makes no difference to me either 

15 way. 

16 MR. HAGERMAN: So, this is Joe Hagerman, 

17 DOE. 

18 Let's move on to the next topic, because 

19 we've got a lot to do here. And if you have 

20 further discussion, why don't you just call the 

21 member? 

22 MR. RAMIREZ: And not only that, 405.2, 
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1 and after this one, we'll take a break. 

2 Okay. 405.2. Manny? 

3 MR. SANTANA: Okay. 405.2. 405.2. You 

4 know, actually, I think we might be able to 

5 remove this one. 405.2 is on page R-37. And I 

6 just realized earlier that 405.2 is outside of 

7 the -- well, actually, we can go through it. 

8 405, section 405 deals with another 

9 alcoholic compliance path, you know. So what it 

10 is, it's a little redundant. It just says that 

11 if you use 405 as your way to comply with the 

12 IECC, you still have to comply with the mandatory 

13 requirements that are in -- let me see -- that 

14 are identified in 401.2, which fiddles you back 

15 to the ones that we've just been discussing. 

16 [Pause.] 

17 MR. RAMIREZ: Did everyone follow that? 

18 MS. HOFFMAN: Eileen Hoffman. 

19 Are those the three compliance paths? 

20 MR. SANTANA: Yeah. Yeah. 

21 MS. HOFFMAN: 401.2, which we'll get to? 

22 MR. SANTANA: And we'll call them 
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1 "compliance paths" for lack of a better term. 

2 But if you go back to 401.2 on page R-29, the one 

3 titled "Compliance." 

4 So you see there's three ways to prove 

5 compliance, right? One is to go through sections 

6 R-401 through R-404. The other one is to comply 

7 with section R-405 and the provisions of R-401 

8 through R-404 labeled "Mandatory." 

9 So that second item there, section R10 405.2, requires the same thing. 

11 MR. LEVY: Manny, Emanuel Levy, if I can 

12 interject here. 

13 This whole section is under the 

14 performance path. This is about setting up the 

15 assumptions for the performance path. And we 

16 talked about this as one of the possible paths. 

17 I'm sure we're going to come back and 

18 revisit all these individual issues if we decide 

19 to include a performance path. And I would 

20 recommend that we table this. 

21 This is a detail within the performance 

22 compliance path, and I don't think we need to 
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1 deal with it now. 

2 [Pause.] 

3 MR. DRAKE: I'll agree. 

4 MR. RAMIREZ: Okay. So then, we'll just 

5 put on here, "Hold for compliance path 

6 discussion"? 

7 MR. SANTANA: I would agree with that. 

8 MR. RAMIREZ: Okay. Manny, you're not 

9 quite off the hook yet. But let's go ahead and 

10 take a one function. Let's take 10 minutes, and 

11 then we'll come back. And I want to have a 

12 little bit further discussion on where we go from 

13 here with the 2015 IECC. 

14 [Recess taken from 10:31 to 10:36 a.m.] 

15 MS. HOFFMAN: We're back on the record. 

16 Okay. 

17 MR. RAMIREZ: All right. So I want to 

18 thank the working group, sorry, the subcommittee 

19 for all the work that they did. You know, to me, 

20 I look at that and I'm thinking that wasn't a lot 

21 of stuff, looking at everything that's on here, 

22 but I know how labor intensive it is to even get 
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1 to what you all did, and I know there's more work 

2 behind the scenes there. 

3 Which goes to where I want to go next as 

4 far as that subcommittee goes. Can you continue 

5 with the work that you're doing? 

6 I think that there might be some benefit 

7 to bringing recommendations to the working group 

8 rather than the working group having to work 

9 through all of that initially and bringing those 

10 -- trying to cipher it down to what you all could 

11 do in probably a lot less time. 

12 Is the subcommittee okay with continuing 

13 to identify possible areas of agreement? 

14 [Pause.] 

15 MS. HOFFMAN: Manny? 

16 MR. SANTANA: I don't want to speak for 

17 the committee as a whole. But I will. 

18 [Laughter.] 

19 MR. SANTANA: Just because -- and I will 

20 because we went over this. You know, when we 

21 were going through this work, it was hard for us 

22 to kind of -- we had to pull back on the reins a 
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1 little bit and try to keep the scope narrow. 

2 Because I think the members saw the benefit to 

3 this type of forum, you know, and wanted to 

4 expand our scope to other portions of the code 

5 which we thought were important, but not 

6 necessarily labeled "Mandatory." 

7 So I think the membership would be in 

8 agreement to continuing the work. You know, it 

9 is a slow process, and it's a drawn-out process. 

10 And we talked about a lot of the things that the 

11 working group discussed here. 

12 But we also, you know, recognized that if 

13 we don't come to some kind of consensus and bring 

14 something forward for the working group to 

15 discuss, it's just going to take the group as a 

16 whole more time. 

17 So I guess that's a very long, drawn-out 

18 way to say that we think continuing is a good 

19 idea. 

20 MR. RAMIREZ: Okay, great. 

21 MS. HOFFMAN: And that might mean, Manny, 

22 more phone calls and more meetings with you and 
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1 the working group before our next meeting. 

2 MR. SANTANA: Yeah. 

3 MS. HOFFMAN: Okay. 

4 MR. SANTANA: But, you know, there's 

5 always benefits to that. You know, we're 

6 smaller. You can have -- you know, you're off 

7 the record. You can work independently and then 

8 come together, you know, from one day to the next 

9 for a quick call. It's not as hard to manage as 

10 a bigger group. 

11 MR. RAMIREZ: So I would ask the group, 

12 then, what guidance or assistance do you need 

13 from the -- I'm sorry. 

14 I'll ask the subcommittee, what guidance 

15 or assistance do you need from the working group? 

16 Whether it be any analysis or even just 

17 direction? 

18 Because I know that some of this really 

19 is contingent on what compliance paths you're all 

20 going to use. That would be one example; I don't 

21 know if we're going to get an answer on that 

22 today, right? But what other assistance might 
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1 you need? 

2 [Pause.] 

3 MR. RAMIREZ: I guess any of the 

4 subcommittee members could chime in on that. 

5 [Pause.] 

6 MR. SANTANA: This is Manny again. I'll 

7 speak up again. 

8 I think, you know, as far as assistance 

9 or direction, I don't think we need a whole lot. 

10 We're trying to tiptoe around the whole 

11 compliance path options and focus on what's 

12 mandatory, you know. And there's -- like I said, 

13 there are 25 sections, and we really only came to 

14 a consensus on 10. 

15 So, you know, just going through the 

16 remainder of the mandatory provisions, and going 

17 through the installation table, and definitions, 

18 without even getting into the climate zones or 

19 anything that might have an impact on what 

20 Emanuel is doing or what Robert suggested, that's 

21 going to keep us pretty busy. 

22 MR. RAMIREZ: Okay. 
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1 MS. HOFFMAN: Eileen Hoffman. 

2 Does any other member of the working 

3 group want something back? What would you like 

4 to ideally see from the subcommittee for our next 

5 meeting? Any guidance? Lois? 

6 [Pause.] 

7 MR. UNGER: This is Lowell Unger. 

8 I was just going to say it seems to me 

9 that we really wanted to come close to having a 

10 draft standard in the next meeting. And there's 

11 just a lot of issues. I mean, certainly the kind 

12 of overall OU or R-values or however you want to 

13 do it are separate. 

14 But there's just a lot of provisions 

15 here. There's certainly a number of mandatory 

16 ones, and then, as we were talking during the 

17 break, there's a lot of provisions in that if we 

18 have a prescriptive pass, that are also in the 

19 prescriptive, that are required in the 

20 prescriptive pass that we can't possibly deal 

21 with as a full committee to go one by one and 

22 work it through. 
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1 And so, I would really hope that the 

2 subcommittee, by next meeting, could certainly 

3 for the mandatory, and ideally, then moving on to 

4 the prescriptive items, if we're going to have a 

5 prescriptive path, to have a recommendation for 

6 the full committee that these are the ones that 

7 we should include, so that we can, you know, just 

8 clearly identify. 

9 Maybe there's one or two issues we need 

10 to talk about, but not 50. 

11 MR. RAMIREZ: Does that sound doable from 

12 the subcommittee? 

13 [Pause.] 

14 MR. RAMIREZ: Lois? 

15 MS. STARKEY: Just in terms of our 

16 timing, I know I just want to emphasize that I 

17 know that MHI's members really, really want to 

18 have a performance path. So we do not want to 

19 have a standard that ends up to be just a 

20 prescriptive standard. 

21 And I'm just putting that out there if, 

22 in the interests of time, as this -- as Manny's 
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1 group goes through this, that there may be, we 

2 may want to, you know, move to discussion about a 

3 performance path. 

4 I'm just in terms of -- I just don't want 

5 that to get lost and we're at the end of our time 

6 and we decide we're just going to not have -- we 

7 don't have enough time to discuss it or, you 

8 know, really get into it. 

9 Because that's really the -- that's 

10 fundamental to what our industry does and the 

11 code that it builds to now. And it would be a 

12 real shame if the HUD -- if this group adopted -- 

13 recommended a code that was really the IRC. 

14 MR. HAGERMAN: Just real quick, this is 

15 Joe Hagerman. 

16 I don't think we've heard that from this 

17 group, though, have we? I mean, I think this 

18 whole group has been supportive of a prescriptive 

19 path. And then having the option of -- I'm 

20 sorry, a performance path -- within an option of 

21 a prescriptive path for the first time, sorry. 

22 MS. STARKEY: We're spending an awful lot 
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1 of time on the -- I just don't -- I just want to 

2 be sensitive to time to make sure that we can 

3 address the performance aspect. 

4 MR. HAGERMAN: Absolutely. 

5 MR. UNGER: This is Lowell. 

6 Just that, I mean, what we have talked 

7 about so far are provisions that apply for any 

8 path. So it does include part of the performance 

9 path, is all. 

10 MS. STARKEY: Right, right, right. 

11 MR. UNGER: Okay. 

12 MR. RAMIREZ: Okay. Mark? 

13 MR. WEISS: Mark Weiss, MHARR. 

14 I just want to point out that the timed 

15 deadline we're operating under is, in reality, an 

16 arbitrary one. The only statutory deadline was 

17 in 2011. And we've gone long past that, which is 

18 not to say that there isn't some urgency to 

19 addressing this, but there is no deadline 

20 prescribed in statute or regulation. 

21 The only deadline is the September 30th 

22 date picked by ASRAC, and if you go back to the 
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1 notes, to the transcript of the June 6th meeting, 

2 which I attended, there was no magic to that 

3 date. 

4 So I will reiterate what I said yesterday 

5 at the start. And that is, in our view, it's 

6 more important that we get this right than we 

7 necessarily blow through things that we should be 

8 considering to meet some sort of arbitrary 

9 deadline. 

10 MR. RAMIREZ: You know, as a facilitator 

11 for what we were charged to do, I would just 

12 caution that we do have until the end of 

13 September, if -- okay, the end of September. 

14 And if we do -- whether it was arbitrary 

15 or not, that's what we were given, right? And if 

16 -- we would need approval in order to go beyond 

17 that. 

18 And I think that the only way that we 

19 would get approval, and hopefully John could talk 

20 more later if he gets here, is that we need to 

21 show that we are going to, in more likelihood 

22 than not, reach a consensus on a term sheet for 
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1 that extended period. Otherwise, what's the use 

2 of prolonging it? 

3 But -- so I just wanted to make sure that 

4 the group really, truly sees the big picture 

5 here. 

6 [Cross-talk.] 

7 MR. WEISS: And I don't disagree with 

8 what you said. I don't disagree with it. 

9 MR. RAMIREZ: Okay. 

10 MR. ROY: This is Robin. 

11 I presume, but I don't know, that ASRAC 

12 was being sensitive to the value of the folks' 

13 time in this room and really being thoughtful 

14 about how much they would be imposing on us. 

15 I think they probably were also quite 

16 aware at ASRAC, as they are drawn from a bunch of 

17 industry and other interest groups that spent a 

18 lot of time in this space, they have familiarity 

19 with the nature of developing standards, that DOE 

20 is working on a standard in parallel with the 

21 work of this working group, and in parallel with 

22 the work of ASRAC and that DOE has got all sorts 
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1 of data sources. 

2 This is very helpful in informing that. 

3 And I suspect, but don't know, that they have a 

4 sense in putting that time constraint, that 

5 there's no real advantage, unless we come up with 

6 a strong view amongst ourselves that we have 

7 something that's going to be a consensus that 

8 just after a couple of extra weeks we'll deliver. 

9 I think they're trying to be sensitive to 

10 us as opposed to imposing hard deadlines. 

11 MR. RAMIREZ: Yeah. 

12 MR. ROY: Because DOE is already going to 

13 do this anyway. And their schedule is such. 

14 MR. RAMIREZ: Right. Okay. Thank you. 

15 Lois? 

16 Mark, anything? Okay. 

17 Okay, great. 

18 MR. EZZO: Hey, Javier, this is Mark 

19 Ezzo. Can I make a comment? 

20 MR. RAMIREZ: Yeah. Mark, hold on one 

21 second. 

22 [Pause.] 
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1 MR. HAGERMAN: Yeah, so Robin is 

2 absolutely correct. I mean, you know, this 

3 committee has an expiration date. We can ask 

4 ASRAC to extend that. But I think we'd have to 

5 have a very clear, you know, time horizon. We're 

6 not going to just say, "I don't think ASRAC is 

7 going to be supportive and say, you know, we can 

8 extend this to the end of the year." 

9 I think they would need something like, 

10 we're going to extend this by two meetings, and 

11 we're going to get agreement, right? They want 

12 to see some evidence that we're all operating and 

13 negotiating in good faith and we can, you know, 

14 reach a term sheet. 

15 Absent of that, they're not going to 

16 extend it. And we'll just continue with our 

17 rule. 

18 MR. RAMIREZ: Okay. I'm sorry. Who was 

19 going to talk? 

20 MR. EZZO: It's Mark Ezzo, Clayton Homes. 

21 MR. RAMIREZ: Okay. 

22 MR. EZZO: As part of Manny's 
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1 subcommittee, and I'm on that, and to Lois's 

2 point about performance approaches, in the IECC, 

3 there are different paths to take. And 

4 obviously, one of them is prescriptive. There's 

5 also a UA approach, and there's performance 

6 approaches. So those are already in there. 

7 What I'd like people's input on and what 

8 I'd like to suggest is, the part of the energy 

9 code, the IECC, that have the prescriptive 

10 approach, we were given a proposal from Mike 

11 Lubliner that I'd like to recommend be inserted. 

12 Mike's prescriptive path, I'd like to see 

13 us insert that prescriptive approach into the 

14 IECC in lieu of the current IECC prescriptive 

15 approach, which is not really geared or does not 

16 accommodate factory-built housing. 

17 MR. RAMIREZ: Okay. 

18 Eric? 

19 MR. LACEY: This is Eric from RECA. 

20 I certainly support the prescriptive R21 value table that Luby put forward. But I would 

22 just remind you that the prescriptive path is not 
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1 just a table. There's another long list of 

2 requirements and exceptions that also apply to 

3 that. 

4 And I think that our subgroup is 

5 eventually going to go through all of those and 

6 decide what works for manufactured housing and 

7 what doesn't. And I mean, some of the exclusions 

8 you might really like. They might be new. And 

9 some of the requirements might be new as well. 

10 But I just wanted to remind you that it's 

11 not just about the R-value table. Even though I 

12 thought it was a great start, there are other 

13 requirements and provisions that still apply. 

14 MR. RAMIREZ: Yeah, I understand. 

15 MR. LUBLINER: This is Mike Lubliner. 

16 I agree with Eric. We need to look at 

17 all of them. And I just put that up as a straw 

18 man just to get some progress and dialog. Thank 

19 you. 

20 MR. EZZO: This is Mark again. 

21 I just want to make sure we don't lose 

22 sight of it. Because it seems like, since Mike 
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1 made that recommendation, it's kind of gone by 

2 the wayside. And I don't know if we were going 

3 to pick back up and talk about it more. I just 

4 don't want to get -- I just don't want to see it 

5 get lost. 

6 So, Eric, to your point, yeah. Let's 

7 make sure we include that in the further 

8 discussions that we have on the subcommittee. 

9 Thanks. 

10 MS. HOFFMAN: Eileen Hoffman. 

11 My impression was that Ed at Navigant was 

12 using -- were you including the Lubliner straw 

13 man? Just to check. 

14 MR. HAGERMAN: This is Joe Hagerman, DOE. 

15 I can comment. 

16 So, we did energy simulations for the 

17 Lubliner proposal and then the derivatives, where 

18 we looked at different things like maybe some 

19 different installation options and solar heat 

20 gain coefficients and what-not. 

21 So you should have all those annual 

22 energy consumption numbers. And, you know, we 
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1 did that in parallel with Matthew, who was 

2 constructing the life cycle spreadsheet. He has 

3 not had time to copy those numbers into the life 

4 cycle, you know, spreadsheets, partially because 

5 he's waiting for more accurate cost data from the 

6 manufacturer, right? 

7 He didn't want to -- I instructed him to 

8 wait until we get better cost data, and not spend 

9 his time monkeying around with fictitious data, 

10 right? 

11 So, as soon as we get cost data, he'll go 

12 and do that. He'll put those proposals into the 

13 life cycle spreadsheet, and then you can see, you 

14 know, those simulations analyzed in comparison to 

15 the other ones that are already in there. All 

16 right? 

17 So, hopefully, once we get that cost 

18 data, it will take them probably a couple of days 

19 to put that in and one day for us to review it. 

20 And then we can go from there. 

21 But it's my -- I agree with Lubliner and 

22 Mark Ezzo. I mean, I think that straw man for 
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1 the packages was really good and really 

2 important. And it actually compared very nicely 

3 to the 2015. So, you know, I'd like us -- I'd 

4 recommend that we stick with that until we see a 

5 reason not too, right? Or if the costs come back 

6 bad, so. 

7 MR. SANTANA: This is Manny with CAVCO, 

8 if I can speak. 

9 MR. RAMIREZ: Yeah. 

10 MR. SANTANA: I'd like to speak in 

11 support of Mark's comment, you know. But then, 

12 also I think what Eric brought up was really 

13 critical, where I'd like the concept behind 

14 Mike's proposal. But the path that's in the IECC 

15 is based on -- well, one is based on all those 

16 mandatory provisions that we've been trying to 

17 get through, and a bunch of other kinds of 

18 assumptions. 

19 I think in order to advance Mike's 

20 proposal, we might have to have it be the chart 

21 and include what other -- the assumptions that it 

22 entails. So what we might need to do is, in 
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1 order to consider the prescriptive path, we might 

2 have to find out what portions of the IECC apply 

3 to it, and then revise those and submit that as a 

4 kind of prescriptive package of sorts to replace 

5 what's in the IECC. 

6 So I think Mark is correct. But 

7 considering what Eric said, it's going to take a 

8 little bit of work to get that to the point where 

9 we can -- you know, where it's a comprehensive 

10 standalone prescriptive path. 

11 MR. RAMIREZ: And is that something that 

12 you are going to lead with your subcommittee? 

13 MR. SANTANA: Hah -- that's a way to sign 

14 me up for some stuff. I think we can, you know. 

15 I'd hate to take something that Michael conceived 

16 of and just change it, you know. 

17 So, Mike, is there any way that you would 

18 want to, I guess, expand your idea? 

19 [Pause.] 

20 MR. LUBLINER: Yeah, I would. I do think 

21 that Joe's right. Next step is to cost that out. 

22 I don't want to go too far into that right now. 
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1 But, yeah. I believe that we can discuss the 

2 technical details of that. 

3 As I said yesterday, I think one of the 

4 issues is how much insulation is displaced with 

5 tapering assumptions and what the impact is on 

6 the compression in the floor and whether it would 

7 truly need to go to a two-by-eight floor joist to 

8 just account for the compression. So, yeah, at 

9 some point, I think that's appropriate. 

10 But the next step, I believe, is to try 

11 to get some estimates either using the existing 

12 cost data if no more cost data is produced, 

13 delivered, or presented, or try to get the 

14 manufacturers to cost out these package relative 

15 to minimum HUD and see where we go. 

16 I hope that answered your question. 

17 MR. SANTANA: Well, you know, I guess in 

18 response to that, I think it would be really 

19 tough to get any kind of cost based on just the, 

20 you know, KISS-Luby proposal as it stands, 

21 because there's a lot of unsaid assumptions that 

22 are behind the scenes that weren't part of that 
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1 packet. 

2 MR. LUBLINER: Yeah, correct. I agree. 

3 That's why we need to talk about those 

4 assumptions and make sure we're clear on them and 

5 then get cost data. 

6 Right now, what I understand is Joe's 

7 going to be using the cost data that they already 

8 have that they've been running to see how this 

9 compares with the other stuff. 

10 But, yes. It's absolutely critical that 

11 we define the parameters before we can arrive at 

12 agreements on what the factors are that go into 

13 the costs, and then cost it out. 

14 MR. RAMIREZ: Michael, are you currently 

15 on that subcommittee for the -- 

16 MS. HOFFMAN: I think, Mike, Luby, you're 

17 on the committee, right? 

18 MR. LUBLINER: Yes, I am. And I'm 

19 thinking, since I have this separate committee 

20 that's supposed to be, I think, focusing on this 

21 issue, maybe rather than having two committees, 

22 we -- 
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1 MR. RAMIREZ: Just merge it. 

2 MR. LUBLINER: Yeah, let's just merge it. 

3 I think that would be a great idea, if others are 

4 comfortable with that. 

5 Manny's done a great job of leading the 

6 committee. And I think we're functional and we 

7 have good manufacturer and cross sectional input 

8 on the committee. 

9 I would open it up to others that may 

10 want to be on the committee to move in as well, 

11 that were presently on the group that was going 

12 to look at this, as a separate committee. 

13 MR. HAGERMAN: This is Joe Hagerman, DOE. 

14 Just wondering, guys, if some of the 

15 assumptions that Manny has questions about, and 

16 Michael, I know that you need to work through, 

17 are these some of the assumptions and discussions 

18 that we're about to go into as Emanuel Levy goes 

19 through these, you know, proposed requirements? 

20 Then we sort of start having those discussions 

21 and the assumptions as we go through this other 

22 material? 
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1 MR. LUBLINER: Joe, you're right. Mike 

2 Lubliner here. I think we're going to flesh some 

3 of these out, based on what Emanuel's going to 

4 propose. I wouldn't say that we're going to 

5 resolve everything. But it's a good starting 

6 point. I would suggest we start there. 

7 MR. RAMIREZ: Well, let's start fleshing 

8 then. 

9 MR. LUBLINER: Fleshing? 

10 MR. RAMIREZ: Yeah. 

11 [Laughter.] 

12 MR. LUBLINER: Manny, do you agree? 

13 MR. SANTANA: Well, I want to go back to 

14 fleshing out. So, you know, I don't know. 

15 Because there are different paths. The 

16 prescriptive path can have its own standalone 

17 assumptions that may not necessarily hand it over 

18 to the performance. 

19 But the prescriptive path can have 

20 whatever assumptions it wants. You know, it can 

21 say this package is based on a two-by-eight floor 

22 joist with R-19 throughout, and it's based on, 
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1 you know, this assumed section with -- and this 

2 percentage of glazing. Where the performance 

3 path won't have any of those assumptions because 

4 those are all going to be inputs. 

5 MR. RAMIREZ: All right. So then with 

6 that, Emanuel, do you want to go ahead and start 

7 sharing with us what you've put together? 

8 MR. LEVY: I'm glad to. Do you want to 

9 pull the first one up on the screen, Javier? 

10 I just wanted to add a comment to Manny's 

11 last statement. The prescriptive path, whatever 

12 it happens to be, if it's the Lubliner proposal, 

13 that becomes the touchstone for everything else 

14 in terms of thermal performance compliance so 

15 that if there's a performance path or a UA 

16 compliance path or a UO compliance path, they all 

17 have to be internally consistent with what's in 

18 that prescriptive path. 

19 So that is a vitally important decision 

20 that the committee makes as to what's in that 

21 package. I don't know if that was obvious when 

22 you were talking about it. 
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1 MR. RAMIREZ: Emanuel, now, before you 

2 start here, of the three documents that you have, 

3 is there one of them that you think that we could 

4 get through in 45 minutes? 

5 MR. LEVY: Yeah. Let's do the first one 

6 to the left, the solar heat gain coefficient. 

7 MR. RAMIREZ: This one? 

8 MR. LEVY: Yes. But I can't guarantee it 

9 will take 45 minutes, with this group. 

10 MR. RAMIREZ: But you think it can? 

11 MS. HOFFMAN: Yeah. Otherwise, we'll 

12 break for lunch and finish when we come back. 

13 [Laughter.] 

14 MR. RAMIREZ: Okay. 

15 MR. LEVY: All right. Okay. So, let me 

16 just mention what I was attempting to do here, 

17 which is to take some of these issues that are 

18 clearly related to the manufactured housing 

19 standard, and put a straw man on the table as to 

20 what this might look like. Obviously, these are 

21 starting points for discussion. I try to provide 

22 enough background information here to put this in 
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1 context. 

2 There are three different papers that 

3 we'll be talking about today. One of them, this 

4 first one, is on solar heat gain coefficient, the 

5 glazing. And they all follow the same format. 

6 They start with a short summary of what the 

7 background is on this issue, very graphically 

8 oriented. 

9 Then there's a proposal, which is section 

10 2, which we'll get to in a minute or two. A 

11 specific proposal about how we handle, in this 

12 case, solar heat gain coefficients in the 

13 standard. And a third part, which is somewhat of 

14 a justification for what the proposal is. 

15 So, I'll try to go through here quickly, 

16 go through this quickly and get right to the 

17 commentary on this. But please, do stop me, and 

18 on this one in particular I'm going to probably 

19 ask Rob to clarify some points because he and I 

20 put our heads together on this one. He knows a 

21 lot more about these issues than I do. 

22 Solar heat gain coefficient is basically 
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1 the physical property of the glazing system, 

2 which is the glass and the frame, and it tells 

3 you how much of the impingent light actually 

4 penetrates into the space so that a lower value 

5 means less of the sunlight hitting the window is 

6 going to get through the glass and into the space 

7 and turn into heat, where heat can turn into 

8 usable heat. 

9 This, obviously, is -- I don't know how 

10 obvious it is. But this is a much more important 

11 issue, what this characteristic of the window is 

12 in the south, where high solar loads can really 

13 add to your cooling load than in the north. So 

14 as a result, I think you'll see that IECC right 

15 now has no -- they don't care what the solar heat 

16 gain coefficient number is for the glazing in the 

17 North. They're mainly just focused on the South. 

18 So, it's not only the glass and the 

19 properties of the glass. It's also the rest of 

20 the glazing system, the frame. And in 

21 particular, for example, a window that has grids 

22 in it will, obviously, block more light, so it 
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1 will have a higher solar heat gain coefficient. 

2 So the same window with the same glass, with and 

3 without grids in it -- everybody knows what grids 

4 are? 

5 [Pause.] 

6 MS. HOFFMAN: No. 

7 MR. LEVY: Will have different solar heat 

8 gain coefficient. 

9 MS. HOFFMAN: What are grids? 

10 MR. LEVY: So, a grid is, when you see a 

11 window with no hatching in it. Usually, older 

12 windows have that hatching, so they have smaller 

13 panes of glass for the same -- Rob, you want to 

14 take over? 

15 MR. LUTER: This is Rob. 

16 Simulated divided lights is what grids 

17 are. 

18 MR. LEVY: So they make it look like you 

19 actually -- in a window frame, instead of having 

20 a big piece of glass, there's a grid that divides 

21 that big piece of glass, usually into six parts 

22 or four parts. It's a cosmetic change. But that 
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1 grid that overlays on top of the window blocks 

2 some of the sunlight, so it affects the amount of 

3 light that's going through the window and 

4 therefore turns into heat inside the home. 

5 So is that reasonable? 

6 [Pause.] 

7 MR. LEVY: Okay. Go ahead, Rob. 

8 MR. LUTER: No, I was just going to 

9 expound a little bit. The solar heat gain 

10 coefficient is specific to the amount of solar 

11 energy coming through, thermal energy. There's a 

12 visual transmittance component to that as well, 

13 which typically will go down. That is to say 

14 less visible light comes in as the solar heat 

15 gain coefficient goes down. 

16 To Emanuel's comments about frame and 

17 grids, the same-size window will have a different 

18 solar heat gain dependent on the operator type. 

19 A picture window, for example, which has a much 

20 greater percentage of glazing-to-frame will often 

21 have a higher solar heat gain of a comparably 

22 equipped double-hung window or a casement window, 
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1 which typically has much less glazed area as 

2 compared to the whole unit. 

3 And the ratings that are developed by the 

4 NFRCR whole unit ratings, it's not just the 

5 glazing. As Emanuel mentioned, the addition of 

6 grids or simulated divided lights also reduces 

7 the solar heat gain, as well as the visual 

8 transmittance. 

9 MR. LEVY: Javier, if you can go to the 

10 bottom of this document, I think before we get 

11 into the specific proposal, the idea is -- just 

12 all the way to the bottom, the entire document. 

13 There's a table down here, right here, right 

14 there. Hold on. Come back to the table, two 

15 tables. Okay. 

16 So, this is what Rob is talking about. 

17 There are two companies that distribute windows, 

18 sell windows to the industry that -- and those 

19 two companies claim about 90-plus percent of the 

20 total sales. So we really need to just focus on 

21 the products that are sold by these companies. 

22 And here's a listing of -- a simple 
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1 listing of the products that are being offered, 

2 and with their U values and their corresponding 

3 solar heat gain coefficients. 

4 And these are in order of, the ones at 

5 the top are the least efficient from an energy 

6 thermal standpoint. And the ones at the bottom 

7 are the most efficient, or approximately. They 

8 get more efficient as you go down the list. 

9 But you can see, for corresponding 

10 windows, what the solar heat gain coefficients 

11 become. So if you only have an aluminum frame 

12 window with clear glass in it, you have a value 

13 of 1.08 for the first company and a solar heat 

14 gain coefficient of 0.7. That's a pretty high 

15 solar heat gain coefficient, which means it's 

16 allowing a lot of the thermal radiation into the 

17 home. 

18 On the bottom, you can see Window Company 

19 A, they're a vinyl frame with enhanced low-E 

20 glass, has a much lower U value, which means it's 

21 about three times as efficient as the single 

22 glass. And you can see the solar heat gain 
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1 coefficient for that product is also much lower. 

2 So there is -- they're not totally 

3 correlated. But the more -- generally, the least 

4 efficient units have the higher solar heat gain 

5 coefficient, and the more efficient ones, by 

6 virtue of the glass that's being used in there, 

7 have lower solar heat gain coefficients. 

8 And they're shown in a range for the 

9 reason that Rob mentioned, because some -- you 

10 know, the same product, window type, in different 

11 sizes or different grid combinations, less solar 

12 heat gain coefficient. So we've shown the range 

13 there. 

14 So, for vinyl frame with low-E dual 

15 glass, the range is, for that product, has a U 

16 value of 0.32 to 0.35 and a solar heat gain 

17 coefficient of 0.26 to 0.33. 

18 Any questions about that? 

19 [Pause.] 

20 MR. LEVY: Okay. So, we'll go back to 

21 the top of this paper. 

22 [Pause.] 
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1 MR. LEVY: So, this is what the various 

2 standards say about solar heat gain coefficient. 

3 The HUD code is silent on it at the moment, and 

4 you can see the progression from the '06 to the 

5 '15 code, IECC code. 

6 It started out that, in zones 1 through 

7 3, the Southern zones, it started out in '06 at 

8 0.4. And over time, that's been ratcheted down 

9 to what is today, for the '12 and '15 code, 0.25. 

10 So, over time, the IECC committee has made that 

11 requirement more stringent, allowed less solar 

12 heat gain through the glass in those Southern 

13 zones. 

14 It's also, over time, added a requirement 

15 for zone 4, which is now getting up into the 

16 middle of the country, of a 0.4 solar heat gain 

17 coefficient. So you can see that that's the 

18 context that we're working, that's in the code 

19 right now, or what's in the proposed 2015 code. 

20 If you go down, Javier, to the map, stop 

21 right there. You can see that if you take the 

22 current HUD map, which is the bottom one, and you 
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1 overlay it on top of the IECC map, there is some 

2 alignment there of zones 1, the HUD zone 1 with 

3 zones 1, 2, and 3 for the IECC. And you can see 

4 what the alignments are there in terms of zones. 

5 There's overlap, obviously, between 

6 zones. So it's not simple to say that zone 2 HUD 

7 is in zone 3 or 4 IECC. It does touch on parts 

8 of 5, and you can see that there's a little more 

9 complexity to that. So any statement about 

10 overlaps is kind of a simplification. 

11 So that's the context. So now if we can 

12 go down. Any questions about that? I'm going to 

13 get right to the proposal. 

14 [Pause.] 

15 MR. LEVY: Okay. So, here's the 

16 proposal. This is what might be the beginning of 

17 what the language might be in the term sheet. 

18 This actually is very similar to what's in the 

19 IECC standard, with a small change. 

20 The proposal is that, for HUD climate 

21 zones 1 and 2, that we use a solar heat gain 

22 coefficient that does not exceed 0.33. Where 
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1 does that number come from? If you look at the 

2 table right there for Window Company A, you can 

3 see that they have three products, their bottom 

4 three products, that would comply with that. 

5 The current requirement, as you remember 

6 from above, in the 2015 and the 2012 IECC, is 

7 0.3. What I'm suggesting is we raise that to 

8 0.33 to allow all the windows that are currently 

9 in the market in those three categories, vinyl 

10 frame with dual low-E, the argon option, and the 

11 enhanced low-E, that all the products be able to 

12 be used. 

13 I'm also suggesting that there be no 

14 solar heat gain coefficient requirement for zone 

15 3, and that's pretty much in line with what is 

16 being proposed -- or what's in the IECC 

17 provision. Not exactly, but pretty close. 

18 The third point is the fenestration 

19 permitted to satisfy the requirements be based on 

20 an area-weighted average, which means you could 

21 have some product that has higher solar heat gain 

22 coefficient, some that's lower. But as long as 
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1 the area weighting of those windows is no greater 

2 than the target of 0.33, you're okay. That again 

3 is out of the IECC. 

4 And fourth, that at 15 square feet, that 

5 the glazing be eliminated from these 

6 requirements. That's also out of the IECC. 

7 So, it's pretty close with the adjustment 

8 made at 0.33, up to the 0.33 to what's in the 

9 IECC. So that is the proposal. You've had the 

10 context, and that's where the conversations 

11 start. 

12 MR. RAMIREZ: Comments? 

13 MR. ROY: Emanuel, this is Robin. 

14 Thanks. That's very helpful. 

15 I have a question. For example, on the 

16 0.33 for zones 1 and 2, is your proposal based on 

17 a presumption or some analysis that having the 

18 requirement be no greater than 0.25 wouldn't be 

19 economic? Or is it -- I mean, what's the basis 

20 for choosing 0.33 instead of 0.25, which would 

21 still leave one on the top of the window? 

22 MR. LEVY: Javier, if you can go back to 
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1 the top. 

2 [Pause.] 

3 MR. LEVY: First, you see that the 

4 requirement -- I'm sorry, the requirement in the 

5 IECC is 0.25, not 0.30. I misspoke earlier. So 

6 it's 0.25. 

7 There is not a simple overlay here, 

8 because the zones we're talking about, 1 and 2, 

9 for HUD, overlay -- we can go down and look at 

10 the maps, or we can just shrink that page a 

11 little bit so we can see everything. 

12 [Pause.] 

13 MR. LEVY: Yeah. So you can see that HUD 

14 zones -- we're trying to overlay zones here. And 

15 keep in mind that the requirement, as you can 

16 see, for the IECC, it's for zones 1, 2, and 3, 

17 which is parts of Oklahoma, Florida, Texas, 

18 little parts of California. Those are 0.25. The 

19 0.4 is for zone 4, which is the yellow area. 

20 And those areas overlap with HUD zones 1 

21 and 2. So, in fact, for some of those areas, 

22 where the yellow overlaps with the black, we're 
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1 actually proposing a lower standard. And for the 

2 areas where the red and the maroon, or whatever 

3 that color is, on the IECC overlap with zones 1 

4 and 2 in HUD, we're proposing a higher standard. 

5 But this is not based -- Robin, to answer 

6 your answer, this is not based on a cost-benefit 

7 analysis. Based upon the products that are 

8 there, and having some kind of soft focus on how 

9 to align the requirements given the differences 

10 in the zone mapping. 

11 MR. ROY: There are products that are 

12 there at the 0.25, right? I mean, there are 

13 products. 

14 MR. LEVY: Right. 

15 MR. ROY: I'm just wondering how we make 

16 the choice between 0.25 and 0.33. 

17 And the other question, which was going 

18 to be my second set, was does this analysis that 

19 underpins your choice -- if we didn't go with the 

20 HUD zone basis, but instead went with an IECC 

21 basis, what would we be giving -- what are we 

22 giving up in choosing a HUD zone basis rather 
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1 than an IECC more -- more broken up? 

2 MR. LEVY: Well, okay. 

3 MR. ROY: But that's the second question. 

4 MR. LEVY: Right. 

5 MR. ROY: The first question really 

6 stands either way. I mean, what sort of analysis 

7 could we reference to support the choice of 0.25 

8 or 0.33, or in your case, 0.33? 

9 MR. LEVY: Javier, if you can go down to 

10 the table down below. 

11 We could do analysis here. And I think 

12 it would probably be prudent to do analysis. 

13 What we're implying here, Robin, whether it's 

14 requiring -- you can see the bottom window there, 

15 as you pointed out, would meet the 0.25 

16 requirement in the IECC. 

17 But we are talking about windows in the 

18 South. And by and large, the U values that 

19 correspond to those windows, we're now requiring, 

20 implicitly in our conversation, we're requiring 

21 at all the windows in the South at least double-E 

22 dual glazed. And that's a more expensive window 
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1 than the ones above it. 

2 So we're now implying, by whatever solar 

3 heat gain coefficient we choose, that the U value 

4 is going to be much lower than the windows that 

5 are used today. 

6 So the first question is, if you require 

7 a solar heat gain coefficient of even 0.26 to the 

8 0.33, those two options there, are they cost9 effective both in terms of the benefit from the 

10 solar heat gain coefficient and the requirement 

11 of a fairly low U value for the windows? 

12 So, that's kind of a double-edged sword 

13 there, or two-pronged analysis that would be 

14 required to be part of that assessment you're 

15 talking about. 

16 And then further, if you we take it down 

17 to a 0.25, in which there's only one window that 

18 qualifies -- and I can tell you that's a very 

19 expensive window. And Rob can talk more about 

20 that. If that was the requirement, and now we're 

21 talking about in the very South, you'd have a 

22 very high-efficiency window in the South, fairly 
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1 expensive to get to your solar heat gain 

2 coefficient. 

3 It's possible to do analysis for each of 

4 the zones to see whether that's cost effective, 

5 but I imagine it's going to be an expensive 

6 proposition to replace windows to get there. 

7 MR. LUBLINER: Emanuel, Mike Lubliner 

8 here. 

9 To follow up on that, is your cost group 

10 going to be getting the incremental cost for both 

11 of those low-E products, the less-expensive low-E 

12 and the more expensive 0.25? And if so, it seems 

13 like it's prudent for the analysis to look at 

14 that, given what the discussion that just went 

15 on. 

16 MR. LEVY: Yeah, Mike. The short answer 

17 is yes, we'll have those costs tomorrow. And so 

18 we will have the material that is needed to do 

19 that analysis. 

20 MR. LUBLINER: Excellent. Thank you. 

21 The other follow-up is, is there a window 

22 schedule assumed in the thermal analysis? I 
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1 guess this is for Joe Hagerman. Or is it just an 

2 assumption of the glazing area? 

3 I think that, as we start to get into the 

4 weeds a little bit more here, and looking at some 

5 of these things, it would be useful if we had 

6 like, what is the window schedule? How many 

7 windows? What's their size? What's the operator 

8 type? -- for both of the prototype floor plans. 

9 And it's a side question, but I think it 

10 will help in this discussion in the ultimate 

11 evaluation. Thank you. 

12 MR. HAGERMAN: So this is Joe Hagerman. 

13 Yeah, the modeling document that I 

14 circulated should talk about the windows. And I 

15 want to remember that it's a total square footage 

16 of window area per facade. But I need to relook 

17 at that, I agree. 

18 MR. RAMIREZ: Okay. Let me get Eric and 

19 then Mark. 

20 MR. LACEY: Thanks. This is Eric. 

21 You know, looking at the standard, when 

22 we first started getting involved in this, what 
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1 really stood out to our organization was the 

2 fenestration requirements and the potential 

3 opportunity here to make these homes much more 

4 efficient, particularly on the SHGC, because 

5 there's not a requirement. 

6 Now, I think if I'm understanding this 

7 correctly, both of the companies here do make a 

8 product with an SHGC that gets us down into where 

9 it would comply with the 2012 or 2015 IECC. And 

10 I know that when this was debated in the 2012 

11 IECC process, a lot of the manufacturers stood up 

12 and said, "This is going to be expensive. You 

13 know, it's proprietary technology. We don't know 

14 how to do this." 

15 And when the code was published, 

16 everybody had a window that complied. In fact, 

17 there was a tax credit associated with the 2009 

18 Recovery Act that required 30 U factor, 30 SHGC 

19 windows for a pretty big tax credit. And almost 

20 overnight, all the manufacturers of windows had 

21 windows that complied. 

22 And so, it's one of those things, like 
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1 airbags in cars, that, you know, I think that at 

2 least for the stick-built homes, the debate has 

3 largely been settled on this. In the 2015 

4 process, there's almost no opposition to the 25 

5 staying in place. It wasn't driven any lower; it 

6 just stayed at 25. 

7 And the 40 SHGC has been part of the 

8 ENERGY STAR standard for a very long time. And 

9 it's been part of the I-code since, I think, 

10 2012. 

11 So I'd hate to give up on this 25 SHGC 

12 without considering not only today's costs, but 

13 the likelihood that, as you set the standard and 

14 processes are streamlined, that that cost could 

15 come down substantially. 

16 I'd also point out that there are several 

17 ways of getting to a low SHGC, several 

18 technologies, several different types of 

19 constructions that would get you there. It's not 

20 just one specific product. And I hope we would 

21 consider all of those options. 

22 It's not just the dual glazing with argon 
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1 and all of these things. There are other ways of 

2 getting there. So, anyway, this is an issue that 

3 I'm obviously interested in because I felt like 

4 we had a real opportunity here to make these 

5 homes far more efficient, especially assuming 

6 that they're going to be air-conditioned at some 

7 point, and to reduce some of those peak loads and 

8 high costs over the long term for these people. 

9 So, anyway, this is an issue that I think 

10 we need to, you know, to really put some thought 

11 into. 

12 MR. RAMIREZ: Mark? 

13 MR. WEISS: Thank you. Mark Weiss, 

14 MHARR. I have some questions for both Emanuel 

15 and Rob. 

16 Emanuel, I'm sure I understand this, but 

17 just to be 100 percent clear. The lower the 

18 number, the more stringent, the more demanding it 

19 is, correct, on the coefficient number? 

20 MR. LEVY: Yes. 

21 MR. WEISS: Okay. Now, going to your 

22 chart, near the bottom, that's up on the display 
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1 right now. So, as I read that, under what you're 

2 proposing under Company A, the first three types 

3 of windows would be excluded, correct? 

4 MR. LEVY: That is correct. 

5 MR. WEISS: And I'm talking zones 1 and 2 

6 now. 

7 And on the second, Company B, just the 

8 first one would be excluded, correct? 

9 MR. LEVY: That's right. 

10 MR. WEISS: Okay. 

11 Rob, what are the two companies involved 

12 here? I assume yours is one. But can you tell 

13 us what they are? Because I'm going to have to 

14 ask some folks about this. And now they tell me 

15 I have Joe Blow's windows, you know, I don't know 

16 who Company B are. So, who are we talking about? 

17 MR. LUTER: Well, I think those names 

18 were excluded for a reason. We can talk about 

19 that offline. 

20 MR. WEISS: That's fine. 

21 MR. LUTER: But what -- I would like to 

22 offer some commentary both to Eric's points 
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1 regarding the seeming overnight development of 

2 low-E. I think that if you query your member 

3 guardian industries, you'll find that it was a 

4 lot of nights in a row that it took for them to 

5 develop their triple-silver product. 

6 That said, his point is correct that 

7 these products are commercially available. Solar 

8 heat gain, performance of 0.25 and below is 

9 available. There are enhanced low-E products 

10 that are used every day that do this. I think 

11 the point here is that the cost of those versus a 

12 dual-silver low-E or commodity low-E, there's 

13 some significance to that. 

14 Now, whether it will be significant to 

15 this group as a whole or part of the group 

16 remains to be seen. That will come out in the 

17 analysis. 

18 I wanted to offer just a couple of 

19 comments on the window schedule that was brought 

20 up and the costing that I believe Emanuel is 

21 going to be presenting later this week. 

22 I was one of the companies that he worked 
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1 with on this. And one of the challenges we found 

2 was to somehow develop a uniform or an average 

3 cost per square foot at fenestration. And what 

4 we found was there's really no such thing. 

5 Windows, as they get larger, actually 

6 cost a little less per square foot because the 

7 waiver content is, by and large, level, and 

8 materials, obviously, go up. As windows decrease 

9 in size, the cost per square foot goes up. 

10 Different operator sizes have different 

11 material and labor contents. I shouldn't say 

12 operator sizes -- operator types, a double-hung 

13 compared to a picture window, for example. So 

14 there's quite a range of costs per square foot. 

15 And as we get into shaped windows, 

16 there's quite a bit of cost in those. And we 

17 have specialty shapes that go in these homes, 

18 too. So the effort was to create a 

19 representative window schedule that included some 

20 large windows, small windows, shaped windows, 

21 rectangular windows, representative of a year's 

22 worth of production. 
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1 I think that at the end of the day you'll 

2 find that perhaps very few houses hit that exact 

3 window schedule, but more often than not it's 

4 close. 

5 MR. RAMIREZ: Okay. Thank you. 

6 Mark? 

7 MR. WEISS: Thanks. At this point, I at 

8 least want just one more question. 

9 You've indicated in the commentary that 

10 the two companies that are referenced in the 

11 charts hold 90-plus percent of the market share. 

12 But that's only part of the analysis. 

13 Can either one of you, or anybody there, 

14 tell me what is the relative market share of the 

15 types of windows that would be excluded versus 

16 the ones that would pass muster under what you're 

17 proposing? 

18 MR. LUTER: At this point, I can only 

19 speak in generalities to a study that I did on 

20 our production to the HUD code market, a couple 

21 of observations. 

22 The type of windows that include low-E 
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1 represent about 70 percent of what I make. Now, 

2 where are those going? I don't have statistics 

3 on, exactly, are they HUD, or are they mods, or 

4 are they after-market? But that's about as fine 

5 a point as I can put on it. 

6 The windows that might be represented in 

7 the ones captioned aluminum frame with single 

8 clear glazing, by and large, are going to shed 

9 builders, people making lawnmower sheds. That 

10 same window with a companion storm, there are 

11 some HUD builders using those. 

12 Again, I don't have any statistics on who 

13 or how many. The manufacturers themselves would 

14 have a better feel for that. 

15 MR. WEISS: Yeah. I mean, my question 

16 was specifically with respect to manufactured 

17 housing HUD code market. 

18 MR. LUTER: Yeah. 

19 MR. WEISS: I just want to follow up. Do 

20 I understand correctly that you are doing cost 

21 analysis with respect to the relative costs of 

22 the high SHGC windows versus the lower ones that 
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1 you are currently producing? 

2 MR. LUTER: That is correct. There's 

3 incremental cost increases that can be associated 

4 with the construction attributes that impact both 

5 U value and solar heat gain. And as I mentioned 

6 yesterday, there are occasions where in order to 

7 achieve one of those metrics, the other one 

8 essentially comes along for the ride at no 

9 increased cost. 

10 Low E glass, for example, is commonly 

11 used to reduce U value. And one of the side 

12 effects is solar heat gain goes down as well. 

13 MR. WEISS: Okay. But that -- 

14 MR. LUTER: You can see that from the 

15 charts here. 

16 MR. WEISS: Okay. But you are looking at 

17 those cost issues? 

18 MR. LUTER: Yes, yes, we are. 

19 MR. WEISS: Thank you. 

20 MR. RAMIREZ: Lois? 

21 MR. LUBLINER: It's Mike Lubliner. 

22 MR. RAMIREZ: Michael, hold on one 
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1 second. 

2 Go ahead, Lois. 

3 MR. LUBLINER: Okay. 

4 [Pause.] 

5 MR. RAMIREZ: I'm sorry. I don't think 

6 -- is your mic on? 

7 MS. STARKEY: Hi. Lois from MHI. 

8 Just wanted to thank you, Emanuel, for 

9 all the work you've put into this with your group 

10 that you needed to get together with, which were 

11 manufacturers and Rob Luter and others. So I 

12 know you put a lot of work into this. 

13 Recognizing that the HUD code doesn't 

14 have any such requirement now, that this 

15 certainly is a good, you know, compromise to 

16 going all the way to the 2015 IECC. And I think 

17 it's really important that we do look at the 

18 costs of this proposal versus the IRC. So I like 

19 that suggestion just to see where we are. 

20 And again, to say that, you know, it may 

21 be that going to the 0.25 may -- and when we 

22 compare those costs back to this proposal in the 
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1 mix of the entire package, you know, it may be 

2 something that we -- you know, we may even have 

3 to consider going in an entirely different 

4 direction with this particular window issue. 

5 But thanks for your work, and I look 

6 forward to getting more information. 

7 MR. RAMIREZ: Anything else on -- I'm 

8 sorry. Go ahead. 

9 MR. UNGER: Lowell Unger. 

10 I'll start with my thanks. I wanted to 

11 check. There presumably will be either in a 

12 prescriptive factual U value requirements or else 

13 that will factor into the performance. 

14 Looking at Luby's straw man, which was 

15 aimed at low-E, I would anticipate that we're 

16 looking, apart from any SHGC requirements, we're 

17 probably looking at low-E windows, for the most 

18 part, if not universally, under a new standard. 

19 Looking at the charts for the two window 

20 companies, Emanuel, it looks to me like if you 

21 assume that, because of the U value, we're going 

22 to have low-E windows, your SHGC of 0.33 would 
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1 not add any further restriction. That is, any 

2 window which you would be using for its U value 

3 would meet the 0.33 SHGC. 

4 Is that a fair understanding? 

5 MR. LEVY: Yes, that's accurate. 

6 MR. UNGER: And it also looks to me like, 

7 you know, and I assume these numbers might vary 

8 due to technology changes or for other companies 

9 other than these two. But if we're looking at 

10 0.25 or below, it would be this, what you're 

11 calling enhanced low-E dual glazing. But if we 

12 had some SHGC that was between 0.25 and 0.33, it 

13 would allow a low-E dual glazing, not enhanced, 

14 to qualify, but would be lower. 

15 You know, you could lower the SHGC below 

16 0.33 without pushing the whole market into the 

17 enhanced and potentially more expensive product. 

18 MR. LUTER: You mean there would have to 

19 be some enhanced windows in it, but not the 

20 entire building? 

21 MR. UNGER: No. I'm saying if you had a 

22 -- yeah, that's a good point. If you were 
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1 averaging, then that changes it. But even apart 

2 from that, if you had a 0.28 or 0.3 SHGC, that 

3 you would still allow low-E Milan-enhanced 

4 [phonetic] products could still meet that 

5 criterion, potentially at lower cost. 

6 MR. LUTER: Right. I mean, you might be 

7 cutting out things like grids in windows, which 

8 are contributing to the higher levels. You might 

9 be making some implicit cosmetic restrictions. 

10 But you're correct. 

11 MR. UNGER: Thanks. 

12 MR. RAMIREZ: Michael? 

13 MR. LUBLINER: Yeah, Mike Lubliner here. 

14 A couple of things. First, I want to 

15 make a point that, you know, it gets back to a 

16 standardization reduces the cost to the consumer, 

17 and I know that there are a lot of plants in the 

18 Northwest that do both modular and HUD code. 

19 And we've found, implementing the ENERGY 

20 STAR program over the years there that it's 

21 somewhat problematic of having to do different 

22 types of windows in the plant. You know, so I 
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1 encourage people to think about that. 

2 Specifically, I guess the question for 

3 Rob and, you know, it would be as from a 

4 manufacturer of the windows standard, if the site 

5 building industry is requiring 0.25 in the I6 codes and that's the bulk of your market, 

7 manufactured housing representing, you know, less 

8 than 15 percent of all the housing in the 

9 country, it seems to me that there is some cost 

10 savings and some economies of scale of staying 

11 with the same number and at least doing the 

12 assessment, as has been recommended by everyone, 

13 comparing the two types of low-E glasses. 

14 And finally, Rob, and then I'll let you 

15 call it. I just want to get this last one in. 

16 Finally, in the discussion of options for, say, 

17 people that don't want to go to a dual-frame, I 

18 guess, in response to the solar heat gain 

19 criteria, I have a question. 

20 And that is, we've used -- and I know the 

21 industry historically has used exterior awnings 

22 over windows for a number of reasons, and shading 
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1 for air-conditioning load is a predominant 

2 reason. 

3 And I'm just wondering if that's a viable 

4 potential option or exception. So if you had a 

5 manufacturer, an interrelated manufacturer that 

6 clearly optimized it without a dual-pane window, 

7 vinyl window, and they wanted to meet the solar 

8 heat gain coefficient, would it be acceptable for 

9 them to ship loose the awnings for the house that 

10 would cover the windows, and comply as an 

11 alternate? 

12 In the same light, I know that there are 

13 some new storm windows with low-E coatings that 

14 are a little more problematic. I know that 

15 Department of Energy's laboratory is testing them 

16 in manufactured homes right now. But it seems to 

17 me that might be another viable option for the 

18 small exception of people that aren't going to 

19 use a prime window. 

20 So those are observations. Rob, I'd like 

21 to get your feedback in terms of standardization 

22 and the impact. I'm assuming whatever costs come 
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1 out of this, they kind of take into consideration 

2 the buying power of the industry and the fact 

3 that there's consistency, then, with the site4 building industry product you're producing. 

5 Thank you. 

6 MR. LUTER: Well, let me comment on all 

7 three points. 

8 First of all, economies of scale. While 

9 it's true that with a number of raw material 

10 items, you know, the larger the quantities, the 

11 better your buying power is, I can't speak for 

12 the other manufacturers that serve the industry, 

13 but as a company, we buy literally millions of 

14 square feet of glazing a year, including low-E. 

15 Believe me, we're on the Christmas card 

16 list of the glass companies. 

17 [Laughter.] 

18 MR. LUTER: We simply can't get into a 

19 buying bracket that gets us better buying power. 

20 We're kind of already at the top of the heap. 

21 With respect to the price difference 

22 between the two low-E's, what we're calling 
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1 commodity low-E or the dual-silver low-E compared 

2 to the enhanced or triple-silver product, the 

3 reality is that, from a manufacturing perspective 

4 at the low-E glass producer, there's significant 

5 cost differences in manufacturing the two 

6 products that result in a different price to 

7 market. 

8 There's also a value add of the 

9 performance that gets factored into the price to 

10 market. 

11 Now, that's not to say that if that was 

12 the only thing they made, things wouldn't change 

13 somewhat. But most of these companies are now 

14 going to market with many, many different low-E 

15 products. So you can literally tailor the U 

16 value and the solar heat gain for whatever 

17 climate you're in, from the Yukon clear down to 

18 Key West. 

19 The second point, Mike, was what again, 

20 please? 

21 MR. RAMIREZ: I think it was awnings. 

22 MR. LEVY: Talking about awnings, or low-
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1 E -- 

2 MR. LUTER: Okay. Let's talk just a 

3 little bit about awnings. The solar heat gain 

4 and U value performance numbers that are 

5 typically called for in this or any code require 

6 substantiation by a third party. 

7 Right now, there really doesn't exist a 

8 means to test and rate attachments. I know the 

9 NFRC is looking at it. The -- don't recall if 

10 it's DOE or EPA wasn't happy with progress there, 

11 and they're looking at another organization to 

12 develop these standards. But it's a long way 

13 off. 

14 Now, that's not to say that awnings 

15 aren't effective. They've been used for 100 

16 years. Shade is better than direct sun. So, but 

17 with respect to certified ratings, I don't know 

18 where we could go with that. 

19 In the absence of certified ratings, the 

20 code that exists directed you to use ASHRAE 

21 defaults, which are, by design, punitive. They 

22 want you to use certified product. And I don't 
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1 know that I disagree with that. 

2 With respect to the low-E storm windows, 

3 I'm familiar with the study that Mike cites. And 

4 it's encouraging. However, the hard-coat low-E 

5 products that are used on an add-on storm, while 

6 they can benefit you on the U-value side, they 

7 have negligible impact on solar heat gain. They 

8 do reduce it some, but just a couple of points. 

9 It really takes the embedded dual-silver 

10 products that are on the inside of a sealed 

11 insulating glass unit to knock the solar heat 

12 gain down appreciably. 

13 MR. RAMIREZ: Thanks, Rob. 

14 MR. LUTER: Yeah. 

15 MR. RAMIREZ: Eric? 

16 MR. LACEY: This is Eric again. Just a 

17 couple of points. 

18 To follow up on Luby's suggestion of 

19 awnings, you know, we see those used in the 

20 stick-built housing market, because there you 

21 know what the orientation of the house is going 

22 to be. And there's actually a tradeoff path 
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1 built into the IECC for residential and 

2 commercial, where once you know what the 

3 orientation is, you can apply the awnings or the 

4 overhangs in a way that would reduce the solar 

5 gain. 

6 The challenge for a manufactured home, I 

7 think, is you don't know how it's going to be 

8 oriented. And it's going to be really hard -- I 

9 mean, it would have to be a really long overhang 

10 to, you know, ensure that it would have an 

11 impact. 

12 So if there were some mechanism for 

13 controlling that on the side, I think that would 

14 be another good suggestion. But I'm not sure 

15 it's really in the scope of what we're talking 

16 about here. 

17 The other thing I would talk about is, 

18 there's been some discussion about the 

19 relationship between the U factors and the 

20 SHGC's. And it's interesting hearing the numbers 

21 about the percentage of the windows that are 

22 actually already low-E that are going into these 
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1 homes and that have sealed insulated glass units. 

2 I suspect that one reason why you're 

3 seeing a lot more low-E windows used is because 

4 you get a huge benefit in your use of O 

5 calculation. If you're putting in really low U6 factor windows, that makes it a lot easier to 

7 comply around the rest of the house, because 

8 windows are the weakest element in the building 

9 envelope. They're much weaker than the wall. 

10 The best windows are like an R-3 wall. 

11 You know, if you think about that, if you have a 

12 lot of glazing area, and your windows are a 

13 really low U factor, you're getting a huge 

14 benefit in that use of O calculation. 

15 And so, I think there's already kind of 

16 an incentive built into the HUD code to have low17 E windows, or very low U-factor windows. And a 

18 side benefit of that is you do get low SHGC as 

19 part of that. 

20 So what I'm going to suggest is that I 

21 think there's already pretty good incentives to 

22 get low-E windows, insulated glass units, in 
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1 homes. And I think it would be great to have 

2 them in every home, regardless of the compliance 

3 option you take. 

4 And I'd like to push the SHGC a little 

5 more. I think that -- I don't know who the two 

6 companies are here, and what all their 

7 manufacturing processes are. But I do know that 

8 the vast -- you know, the industry for the stick9 built homes has moved in that direction of 

10 applying one more coating to this glass. And 

11 it's been very cost effective. 

12 So it's an issue that I don't want to let 

13 go of quite yet. I think that we can still push 

14 a little more here on the SHGC. 

15 MR. RAMIREZ: Okay. Any other questions 

16 or comments? 

17 MR. LUBLINER: Yeah, I had a question for 

18 Rob, a follow-up. This is Mike Lubliner. 

19 When you were talking about the higher 

20 cost of the non-commodity low-E, does that assume 

21 the same frame, in other words, the same window? 

22 My understanding is that the commodity window 
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1 also, in many times, isn't the same window frame. 

2 In other words, when you add the higher-priced 

3 low-E, you're building a heftier frame. 

4 But I'm not clear if that's the case in 

5 your industry here, Rob. So I want to make sure 

6 that whatever we do, it's apples and apples. If 

7 we're looking at the incremental cost of the low8 E versus the commodity one, that we look at an 

9 apples-and-apples frame size. 

10 The second thing I wanted to point out on 

11 the cost analysis that I would encourage DOE to 

12 do is to look at the reduction in air13 conditioning load and the cost benefit to the 

14 consumer of a smaller air conditioner associated 

15 with any low-E product. 

16 And I understand from work that I've seen 

17 from Emanuel Levy's group over the years that, in 

18 the sizing of manufactured homes and their 

19 guidelines for sizing the heating and air 

20 conditioning equipment, they do have provisions 

21 for a smaller air conditioner if you use a lower 

22 solar heat gain coefficient. And, Emanuel, you 
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1 might want to talk about that. 

2 But I want to make sure that when we do 

3 the cost analysis, and I would encourage 

4 comparison of these two low-E's, that we consider 

5 these factors. Thank you. 

6 MR. LUTER: Mike, I can respond to those. 

7 Mike Luter with Lippert. 

8 With respect to the incremental cost 

9 increases for the enhanced low-E that I've shared 

10 with Emanuel, it reflects only the change in the 

11 glazing. Literally, the only difference between 

12 the window with the standard low-E and the window 

13 with the enhanced low-E are the panes of glass in 

14 the inside the glass units. 

15 MR. LUBLINER: Thanks, Rob, for that 

16 clarification. 

17 MR. LUTER: Now, let me expound on that a 

18 little bit. There are companies that perhaps 

19 have multiple lines of windows that they take to 

20 market, a good-better-best scenario, not 

21 uncommon. 

22 And in those cases, they may choose to go 
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1 with a more robust frame in combination with 

2 different glazing to affect overall performance. 

3 In the case of the windows I go to market with, I 

4 have a single product that I can change various 

5 construction attributes on within the same frame 

6 in order to achieve different thermal goals. 

7 MR. ROY: This is Robin. A quick 

8 question for Eric. Perhaps you've already 

9 answered this question; I just didn't hear it. 

10 But have you polled your members to get 

11 their sense of what their experience was in the 

12 incremental cost of these lower SHGC? And if so, 

13 can you provide that to DOE, that insight that's 

14 maybe gleaned from that? 

15 MR. LACEY: This is Eric. 

16 I've certainly had anecdotal discussions 

17 with them, and I can tell you that the cost 

18 difference between -- basically, what we're 

19 talking about is spraying two layers of ionized 

20 silver onto a piece of glass versus spraying a 

21 third layer in that same process. 

22 And once that's incorporated into the 
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1 process -- and obviously, there are some R&D 

2 costs and some upgrade costs to the manufacturer. 

3 Once you incorporate that in there, it's very 

4 minimal, very minimal cost. 

5 I can see if I can pull together some 

6 information on that. I did provide the ENERGY 

7 STAR 3.0 numbers to DOE, the analysis that ENERGY 

8 STAR did compare in the 2009 IECC to the ENERGY 

9 STAR version 3.0. And that included some SHGC 

10 incremental changes and what the costs were 

11 there. 

12 And in that case, they were very minimal, 

13 in the range of like 10 cents a square foot, or 

14 something like that, to drop the SHGC three or 

15 five hundredths of a point. And, you know, that 

16 was used for a different process, and maybe there 

17 are some differences. But I can continue to look 

18 into that. I don't think it will be very much in 

19 the long run. 

20 MR. LUTER: Eric, this is Rob again, at 

21 Lippert. 

22 I would encourage the receipt of 
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1 information like that from a supplier to be -- 

2 not taken with a grain of salt; I shouldn't say 

3 that. But what anecdotally someone says they 

4 will sell something for, versus what it really 

5 costs the first purchaser, versus what it really 

6 costs the ultimate consumer are radically 

7 different things. 

8 The low-E glass supplier, what they're 

9 not telling you is that, in addition to that 10-

10 cents-a-square-foot, there are fuel gas 

11 surcharges and shipping costs and any number of 

12 other fine-print costs to get that into a window 

13 manufacturer's facility. 

14 It's not just some off-the-cuff, "Oh, 

15 it's about a dime a square foot more," because 

16 it's just not. 

17 So as I've offered to some in discussions 

18 of costs, rather than relying on anecdotal 

19 evidence or hearsay, get a firm quotation, an 

20 offer to sell, with all the fine print. And that 

21 will tell you what the real cost is. 

22 MR. RAMIREZ: Eric. 
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1 MR. LUBLINER: This is Mike Lubliner. 

2 MR. LACEY: Hold on. This is Eric. I 

3 just want to clarify. Maybe I wasn't being 

4 clear. 

5 The information I provided to DOE was 

6 ENERGY STAR's analysis in preparation for their 

7 version 3.0. I assumed that incorporated in that 

8 analysis were all the costs. And this is not 

9 anecdotal evidence that I gave to DOE. This is 

10 ENERGY STAR's analysis. 

11 So I have not provided anecdotal evidence 

12 so far in this process related to the costs of 

13 low-E, and that's why. Because I agree. 

14 MR. LUTER: Okay. My misunderstanding. 

15 I don't know what went into that development. 

16 But I know if the assumption was that it cost a 

17 dime a square foot to the end user, it was wrong. 

18 I'll leave it at that. 

19 MR. RAMIREZ: Emanuel. 

20 [Cross-talk.] 

21 MR. LUBLINER: This is Mike Lubliner -- 

22 let me just -- in light of, I think, what is 
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1 happening with our time here, I wanted to make a 

2 suggestion on an action item to go forward. 

3 And that would be that, we have two 

4 glazing solutions, the low-E of dual glazing, 

5 which is at the 26, 33. And the enhanced dual 

6 glazing unit of 0.25. And we just compared those 

7 two homes with those two glazing units from a 

8 cost-benefit standpoint, using the criteria that 

9 we have for the life cycle cost analysis. 

10 Just take a home with 0.33 in all the 

11 windows and a home with the 0.25, a single and a 

12 multi section, and let's do an energy comparison 

13 of those two and see what the real benefit is and 

14 see if it pays for itself. And you can do that 

15 in all the locations, IECC locations that are in 

16 the overlap for zones 1 through 3. 

17 MR. RAMIREZ: Okay. 

18 [Cross-talk.] 

19 MR. RAMIREZ: I'm going to ask Ed if 

20 that's something they could turn around pretty 

21 quick. 

22 But let me get Michael, then Mark. 
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1 MR. LUBLINER: Yeah, I totally support 

2 what Emanuel has said. I think we've articulated 

3 a need for this analysis. I don't hear any 

4 disagreement. 

5 I do think there needs to be some more 

6 discussion going on about the cost implications, 

7 my comment regarding the fuels surcharge cost and 

8 some of the other information regarding what may 

9 impact the cost to the consumer. They all need 

10 to be accountable. We need to really make sure 

11 that we're all in agreement on these assumptions. 

12 I guess my question, Rob, is how does a 

13 fuel cost -- I mean, I want to make sure that 

14 we're talking about a steady-state market. In 

15 other words, if you're shipping products, now the 

16 choice is, can you standardize and ship one 

17 product? 

18 So I guess I need to understand the 

19 factors that you're talking about and what impact 

20 they have and what percentage impact they have 

21 on, typically, once we're in a steady-state kind 

22 of market where you're producing in it, and you 
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1 have contracts to sell either the 0.25 or the 

2 0.33. 

3 But I think we're on the right path here. 

4 Thank you. 

5 MR. HAGERMAN: Can I interject here just 

6 for two seconds real quick? Because I think that 

7 we've performed a little bit of this analysis 

8 already. And so, maybe we can sort of get to the 

9 point. 

10 When we did the KISS Luby runs, package 

11 number one, we simulated in zone 1 a 0.28. And 

12 then we did a KISS Luby-Eric Lacey proposal for 

13 package number two that included 0.28. So the 

14 data is out there already, from going from 0.28 

15 to 0.25. 

16 We can do another run of 0.33, like, you 

17 know, a package, which would be new package five, 

18 so you could see package one and two in 

19 comparison to package five. But you just got to 

20 ask me for it, all right? 

21 I'm not sure, really -- you know, I'd 

22 encourage everybody to look at the data that's in 
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1 package one and two first, before you ask me to 

2 do that, right? 

3 MR. LEVY: Joe, I for one think that that 

4 would be valuable. But also to do a sensitivity 

5 analysis of different orientations, because the 

6 results will differ by orientation. 

7 MR. RAMIREZ: Mark? 

8 MR. WEISS: Mark Weiss, MHARR. 

9 That analysis is fine as far as it goes. 

10 But since we're using HUD code as a baseline for 

11 cost considerations, I think the analysis has to 

12 include the differential going up from the lowest 

13 whatever, on the scale that's in current use, not 

14 just from 33 to 20, 25, whatever, based on what's 

15 currently in use from the least expensive, the 

16 least SHGC coefficient effect of window that's 

17 currently in use up to the more stringent level. 

18 MR. RAMIREZ: Eric? 

19 MR. LACEY: First, to Mark's point, yeah. 

20 You'd probably be up in the 0.80 range or higher. 

21 And there would be pretty significant savings 

22 from that to a 33 or 25. 
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1 I would like to dig in maybe a little bit 

2 deeper into the modeling and specifically what 

3 types of products were used in the modeling. I 

4 mean, I know there wasn't a huge difference 

5 shown, and I'm not sure if that's based on the 

6 fact that they're using the same type of 

7 application of silver and different frames or 

8 something else. 

9 But, yeah, some follow-on would be good. 

10 MR. HAGERMAN: So, let's do this, just in 

11 the interests of time. We're already getting 

12 Bing at PNNL. She's in charge of all of this, 

13 this analysis. She's going to talk to Mike 

14 Lubliner on the insulation. I'll have her talk 

15 to you about the windows as well, all right? So, 

16 two separate phone calls, okay? 

17 MR. RAMIREZ: All right. So, keeping in 

18 mind the possibility of paralysis by over19 analysis, let me ask you. Because I wasn't quite 

20 sure that, do you need the 0.33 run? Or do you 

21 want to first look at the runs one and two that 

22 already have the 0.28 and 0.25 before you 
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1 formally request for the 0.33? 

2 MR. HAGERMAN: For the HUD baseline, we 

3 already modeled 0.6, which is conservative. 

4 [Cross-talk and laughter.] 

5 MR. HAGERMAN: We were conservative, good 

6 conservative. 

7 MR. RAMIREZ: So, is there enough data 

8 out there for you all to look at? 

9 MR. HAGERMAN: I've got another idea, 

10 just a quick little audible. Why not, over 

11 lunch, the people that are concerned about the 

12 values, can you look at the data that we've 

13 already provided? And then right when we come 

14 back from lunch, you can kind of re-talk through 

15 this issue. All right? 

16 If you're still not happy with the 

17 modeling, then, you know, it's going to take a 

18 phone call to PNNL to get you what you need. 

19 MS. HOFFMAN: You also mentioned -- 

20 Eileen Hoffman -- the magic word "lunch." I 

21 think it might be -- Javier, do you agree? 

22 MR. RAMIREZ: Yeah. 
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1 MS. HOFFMAN: I think it might be a good 

2 idea. I see John Caskey has joined us, too, 

3 which is -- a good idea to adjourn for lunch. 

4 Come back in an hour. 

5 So, what do we have now, 12:10? Please 

6 come back at 1:10. Thank you. 

7 [Luncheon recess taken from 12:10 to 1:19 

8 p.m.] 

9 AFTERNOON SESSION 

10 MR. RAMIREZ: Okay. Let's go ahead and 

11 start pulling this back in. 

12 MS. HOFFMAN: We're back on the record. 

13 MR. RAMIREZ: Okay. Emanuel, we were 

14 going to have you continue on with your other two 

15 straw boys, or -- I guess it was less than a 

16 straw man. 

17 [Laughter.] 

18 MR. RAMIREZ: But before we do, we have 

19 John Caskey here from ASRAC, and we wanted to 

20 just do a quick summary on the roadmap. John 

21 wasn't with us yesterday when we prepared at 

22 least the sketches of a roadmap, right. 
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1 I'm hoping that by the end of today, we 

2 have a little bit of time where we could revisit 

3 the roadmap and put a little bit more detail on 

4 it, right, what needs to be done exactly by when 

5 and by who. And maybe put in some timelines in 

6 there as well. 

7 So, let me do a quick review of that. 

8 And then, John, if you have any questions or 

9 thoughts or comments on that, then you could 

10 chime in from there. 

11 [Inaudible interjection.] 

12 MR. RAMIREZ: Okay. All right. So, on 

13 the 9-9 -- let me just make this a little bigger 

14 here, which is today, that should be 9-10, 

15 actually. But this is just the agenda items that 

16 we're doing today, which we've done Manny's 

17 subcommittee here. Emanuel is in the process of 

18 presenting his straw boys. 

19 And then we're going to go over a 

20 template of a term sheet and possibly some 

21 definitions, and Navigant is going to walk us 

22 through that. 
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1 MR. HAGERMAN: Yeah, this is Joe 

2 Hagerman. 

3 We're just going to circulate that. 

4 It's, honestly, an outline. So I don't think 

5 anybody's going to have any problems. But we can 

6 talk about it for five or ten minutes. 

7 MR. RAMIREZ: Yeah. 

8 MR. HAGERMAN: I just think it's going to 

9 be a short conversation. 

10 MR. RAMIREZ: Okay. That's fine. 

11 And then, as we were having our 

12 discussion, there were some items that we were 

13 hopeful that, once some cost data is provided, 

14 and I know that Lois and Emanuel have been 

15 working on some of that cost data information, 

16 we're hopefully going to have that by the end of 

17 the week. 

18 And then we're going to be able to plug 

19 those figures into the life cycle cost analysis 

20 and the other areas where that may be beneficial. 

21 But then we'll get that information out 

22 to the workgroup, and that might help bring some 
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1 focus on the different compliance approaches that 

2 the group may be taking, and then also maybe some 

3 additional detail on the 2015 IECC of what 

4 numbers could be plugged in there. So, it's the 

5 past and actual performance pieces right there. 

6 Also, discussion on affordability, where 

7 Robin had presented the possibility of an LO 

8 model. What was that, limited options? 

9 [Inaudible interjection.] 

10 MR. RAMIREZ: And then the FO was the 

11 full options. 

12 So, depending on what that cost data 

13 yields, we may look at two different product 

14 options to help solve that affordability issue. 

15 Some additional items came up as far as 

16 labeling, we have to have a discussion on that. 

17 Enforcement and compliance -- hopefully, 

18 we end up with a term sheet, and then maybe have 

19 ASRAC extend the authority of this workgroup to 

20 include enforcement and compliance. 

21 We also need to have a discussion on 

22 space water heating and items that are included 
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1 in the shipped product. 

2 And I think we're doing some of the 

3 window types now. 

4 So those are some of the issues. And so 

5 what I'm hoping is that, by the end of today, 

6 we'll have some time to revisit this with the 

7 group and try to put some additional detail and 

8 timelines, specific timelines on every component 

9 that's on there. So that's more or less where 

10 we're at at this moment. 

11 Do you have any questions or comments? 

12 MR. CASKEY: I think I'm on the record as 

13 saying I've always got comments. So bear with me 

14 if you will. So I guess my observation is, this 

15 -- and John Caskey from NEMA for those on the 

16 phone -- is that it's been a very worthwhile 

17 effort. I think there's been a lot of work done 

18 to get us this far. 

19 I think, from what I observe, is that 

20 you're bringing up a lot of great topics. You're 

21 bringing up a lot of, you know, good issues, 

22 whether it's about wall insulation or floor 
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1 insulation or windows or whatever. I mean, 

2 you're sort of discovering a lot of issues and 

3 you're bringing them to the forefront. So I 

4 think that in itself is really valuable. 

5 I can see where you are today, but I 

6 think you've still got a lot of discussions. I 

7 think -- you know, I see a lot of -- as you're 

8 getting into discussions, you get down in the 

9 weeds sometimes. And that's sort of -- I'm not 

10 sure how beneficial that is in the long term. 

11 So I see where you are today. I see that 

12 by the end of the week you may have better cost 

13 data for some of the analysis that needs to be 

14 done. So you've got sort of some good starting 

15 points for the analysis. But the analysis still 

16 needs to be done, and I'm not clear whether it's 

17 Navigant or PN&L that does the analysis; they may 

18 do different features of it. 

19 But anyway, you've got a relatively huge 

20 amount of analysis to do. So I see that as sort 

21 of the starting point of where we are today, if 

22 you will, going forward. 
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1 I also see on the other end, is that 

2 basically DOE is under obligations to try and 

3 make some recommendations or initiate some 

4 regulations relative to manufactured housing. 

5 You know, that has a sort of a clause. That has 

6 a time frame that they need to respond to. 

7 And if, I think -- and I'm telling you my 

8 opinion, but I really don't speak for DOE. 

9 But I think if the results of this group, 

10 it looks very positive in terms of a term sheet, 

11 something that they can effectively work with, 

12 then they would love -- I mean, if we can hand 

13 them that on a sliver platter, they would love 

14 that in order for them to accomplish what they 

15 need to accomplish at some point in the near 

16 future. 

17 If they're not confident that we're 

18 getting to that term sheet, then they've 

19 basically got to start working their butts off to 

20 try and sort of do the work that they were hoping 

21 would get accomplished by this group. I mean, 

22 certainly, getting this group together of the 
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1 industry experts is extremely valuable. 

2 You've got the most knowledgeable people, 

3 the most concerned people, and the people with 

4 some track records on this particular industry. 

5 So, I mean, ideally, they would love all the 

6 input. Again, I can't speak for DOE. But as I 

7 understand it, they would love to get the input 

8 from this group, particularly if you can reach a 

9 consensus. 

10 So we got that, from my perspective, as 

11 sort of the end game. But in order to get from 

12 where we are today, we need to refine the cost 

13 data, hopefully by the end of the week; start 

14 running the analysis. And then you as a group 

15 need to get together and say, "I think the life 

16 cycle cost analysis for, you know, this package 

17 of improvements is cost effective, and this other 

18 one isn't very cost effective or isn't an optimum 

19 solution." 

20 And then from there, you've probably got 

21 to refine some additional details. So I just see 

22 you've got a lot of work to do between now and 
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1 when DOE ideally wants the work done, by October 

2 1st. 

3 So I would love if somebody could sort of 

4 lay out how they picture all of this coming 

5 together in a fairly short period of time. So 

6 personally, I'm happy to go to the ASRAC group 

7 and basically say, "Well, we want an extension 

8 for, say, a month, you know, through the month of 

9 October, so that the final product is due on 

10 November 1." 

11 I'm happy to argue. And from sitting in 

12 these meetings, I think I can effectively argue 

13 the ASRAC to extend it to November 1. Beyond 

14 that, it's problematic because then we're 

15 starting to get close to Christmas and then the 

16 other holidays. And then you're all the way to 

17 the next year. 

18 And then if you guys try and meet in 

19 January and February, you've got to deal with ice 

20 storms and snow and coming out of Chicago and 

21 whatever else it is. But it's really difficult 

22 to have effective meetings in January and 
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1 February with, you know, the weather patterns 

2 that we have in this area, as well as, you know, 

3 the Northeast. So that concerns me. 

4 So, again, I can support an extension -- 

5 and it's just me as an individual. But I can 

6 easily support and argue for an extension till 

7 November 1, if you want me to do that for you 

8 all. 

9 But that still means that I would like to 

10 leave here with a better understanding of how 

11 you're going to go from, you know, today's work 

12 to get the cost stuff done by the end of the 

13 week, to who's doing the analysis, and how long 

14 is that going to take? 

15 And then as you start reviewing those 

16 numbers, you know, how long is it going to take 

17 for you as a group to get together and look at 

18 those numbers and make sense out of them and see, 

19 is there clarity in there that you can go forward 

20 to translating some of those, hopefully, good 

21 life cycle cost savings into a term sheet that 

22 the you can pass over to DOE on a silver platter 
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1 to sort of help them wrap up their work? 

2 So, Joe, did I say anything out of school 

3 our out of line? 

4 MR. HAGERMAN: No, I think that was well 

5 said. This is Joe Hagerman from DOE. 

6 I just want to reiterate that we DOE 

7 employees always work our butts off, no matter. 

8 [Laughter.] 

9 MR. CASKEY: Oh, sorry about that. You'd 

10 be working your butt off on another topic. 

11 MR. HAGERMAN: That's right. 

12 No, you summarized things very 

13 succinctly, right. And I agree. I think we've 

14 got a lot of decisions to make between now and 

15 when we get the term sheet done. 

16 And realistically, you know, we have one 

17 more meeting in this month, and then we've 

18 already scheduled a meeting for the first of the 

19 next month, which I think is -- 

20 MS. HOFFMAN: First and second. 

21 MR. HAGERMAN: First and second, which I 

22 think is in keeping with ASRAC. I don't think 
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1 they would get us in trouble for keeping those on 

2 the books. 

3 So, but realistically, I think we're 

4 probably three meetings away from finalizing that 

5 term sheet, right? We still have to hear back 

6 from Manny's subcommittee on the IECC provisions, 

7 which is just going to take a little bit more 

8 time to go through those. 

9 And then we still have to have a couple 

10 of meetings after we get the cost information, 

11 after we get that this week. There's going to be 

12 at least a meeting in two weeks, or whatever, to 

13 go over that material. 

14 So, I just don't see us being anywhere 

15 without three meetings from today. And we've 

16 only had, this is our third meeting, fourth 

17 meeting? Third meeting. And we've made heroic 

18 effort in the three meetings already. So I think 

19 it's very doable. 

20 MR. CASKEY: Yeah. So I think if we 

21 could get some of the analysis done between now 

22 and the 22nd and 23rd and get it out to people 
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1 beforehand, then people can start thinking about 

2 that and deciding what their perspective is, and 

3 then come to the table and work on that, and 

4 hopefully, you know, come to some consensus 

5 around some of those issues, and then refine 

6 those. 

7 And then that would give you another 

8 meeting to sort of put pen to paper and get them 

9 straightened out before, you know, like middle of 

10 October or something like that, and be ready to 

11 wrap up by, you know, the first of November. 

12 But the other thing I caution you about, 

13 this more my personal opinion, is dealing with 

14 the parking lot, the approach to analyze data, 

15 incremental, you know, slash-package. 

16 So, I mean, that's a good example where, 

17 certainly in the ideal world, I could see this 

18 group working for another year to go through and 

19 look at all the incremental benefits of each of 

20 the various technologies associated with energy 

21 efficiency inside the manufactured housing 

22 industry. 
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1 But you don't really have the time to do 

2 that, from my perspective. And the packages sort 

3 of get you in the right ball park. Yes, there's 

4 always a possibility that there can be, I would 

5 call a turkey in one of those packages that 

6 doesn't really come to the surface, that if the 

7 overall package is cost effective. 

8 So I think that is a concern. But I 

9 think some of those details are sort of -- and 

10 I'm actually -- my undergraduate is in physics 

11 and math. So I'm not normally like, you know, a 

12 just good-enough type guy. I mean, I like the 

13 details and the analysis. 

14 But in reality, I just don't know that 

15 you can do that effectively in the time that 

16 you've got to delve into that level of detail. 

17 But on top of that, you know, one of the 

18 examples I came up with is fracking. You know, 

19 fracking radically reduced the cost of natural 

20 gas in the United States. I mean, it's actually 

21 helping people, helping corporations move from 

22 England and Europe over to the United States for 
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1 their businesses because the price of energy here 

2 is cheaper than in Europe now. 

3 So, I mean, that's radically changed the 

4 marketplace. And I don't know what the next 

5 thing like that is going to be. I mean, if 

6 there's a moratorium on nuclear or a moratorium 

7 totally on coal, I mean, that could throw all 

8 your numbers out, you know, overnight. 

9 So, I mean, it's not a perfect world, and 

10 you're doing the best you can with regard to 

11 discount rates and, you know, inflation and 

12 energy rise and everything else. So I think 

13 getting into some of the details that some 

14 engineers would like to get into, you just can't 

15 afford to do that at this point. 

16 It's just going to bog you down and 

17 you're not going to accomplish your end goal, 

18 which is hopefully reaching a consensus on what 

19 you can do effectively in the manufactured 

20 housing sector to improve energy efficiency, save 

21 operating costs, and still create an affordable 

22 product all at the same time. 
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1 So that's, as I say, my lecture for the 

2 day. 

3 MR. RAMIREZ: Great. Anyone have any 

4 thoughts or comments or questions? 

5 [Laughter.] 

6 [Pause.] 

7 MR. RAMIREZ: Okay. Then, as a 

8 facilitator, I guess what we're going to then do 

9 is to drive you all of it, right? As far as 

10 maybe pushing you and having you rely on some of 

11 the expertise that we've assembled. It may not 

12 necessarily be your expertise, but we probably do 

13 have some in the room that could really, truly 

14 speak on that. 

15 And hopefully, we'll just have to put a 

16 little bit more reliance on some of those folks, 

17 whichever area of expertise they have. 

18 Okay. 

19 MS. HOFFMAN: Before we get started, I 

20 just want to get a feel -- we heard -- thank you, 

21 John -- for his input, his personal input, 

22 because he would then go to ASRAC as the rep here 
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1 to ask for the extension till November 1. 

2 And I'd sort of like to get a sense. We 

3 don't want to stay unless it will be productive. 

4 That's our view. What is the sense in the room? 

5 Do you think we can get it done? 

6 [Pause.] 

7 MR. UNGER: You mean by October 1st? 

8 MS. HOFFMAN: No, by November 1. 

9 [Pause.] 

10 MR. LUTER: This is Rob. 

11 Look, I think we can have some work 

12 product done. Will it be to the level of detail 

13 that some of us might want? Perhaps not. 

14 MS. HOFFMAN: Yeah. 

15 MR. LUTER: But to the points raised by 

16 others earlier, you know, for a couple more 

17 meetings, and we're going to have some meaningful 

18 output. 

19 MR. RAMIREZ: Mark, did you have 

20 something? 

21 MR. WEISS: Yeah. I don't want to 

22 prejudge anything, but I certainly think it's 
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1 helpful having more time than less. Any 

2 additional time we have, as Rob just alluded to, 

3 will increase the work product that we do put 

4 out, ultimately. They will be available to DOE 

5 ultimately. 

6 MR. HAGERMAN: This is Joe Hagerman, DOE. 

7 Just remember, too, after our term sheet 

8 is delivered, and if it's accepted by ASRAC and 

9 accepted by the secretary, we still have to do 

10 the rule, right? And so you're going to see the 

11 analysis that our team has to generate to support 

12 that rule. And you'll be able to comment on 

13 that, right? 

14 That's why I think that the packages make 

15 a lot of sense. Use your professional judgment 

16 as engineers. Don't necessarily go into the 

17 engineering weeds, like some engineers like to 

18 go. And let's just arrive at, you know, what we 

19 think the best solution is. 

20 I mean, you're all here because you're 

21 experts in the sector, you know. It would be a 

22 different story if we just pulled out some 
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1 unknown people off the street. But we didn't do 

2 that. 

3 MR. RAMIREZ: Lois? 

4 MS. STARKEY: I guess, speaking for MHI, 

5 I've observed that this group and all of the 

6 little working groups have done really -- have 

7 worked very hard to get where we are. 

8 And so I feel confident that, you know, 

9 we'll do the best we can. I think everybody is 

10 really committed to having this project be a 

11 success in terms of coming up with something that 

12 we can all agree on. 

13 So, I think it's very doable, and 

14 appreciate the clarification and the offer for 

15 additional time. 

16 MR. CASKEY: This is John Caskey, NEMA. 

17 I know you guys are the facilitators. But maybe 

18 the other way to say it is, is there anyone 

19 opposed to me going to ASRAC to get essentially a 

20 one-month extension until November 1st for this 

21 team to wrap up its work and propose that back to 

22 ASRAC for consideration? 
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1 [Pause.] 

2 MR. CASKEY: I don't see anybody raising 

3 their hands or anybody chiming in from the phone. 

4 So I guess it's a consensus that you do want me 

5 to do that. 

6 MR. UNGER: This is Lowell. 

7 I would just say it's very hard to know 

8 at this point. I mean, we've raised a lot of 

9 issues, but we really haven't resolved any issues 

10 yet. And so, I would be more comfortable, you 

11 know, if it felt like we were two-thirds of the 

12 way there and we had one more third, and I'd say, 

13 "Yeah, we can probably get there." 

14 Right now, I just have no idea, because 

15 we haven't -- you know, we haven't made any 

16 compromises. We haven't, you know, found 

17 creative solutions. We've just surfaced a lot of 

18 good things. 

19 And so the timing, you know -- so in that 

20 sense, I don't think we'll know until maybe the 

21 October meeting as to whether we're on the path. 

22 And by that point, it may be too late to go back. 
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1 So you may need to go -- as often, in the 

2 lack -- you know, without the necessary 

3 information. But that would be my perception at 

4 this date. 

5 MS. HOFFMAN: Yeah, and just to say -- 

6 Eileen Hoffman -- what our job is is to push you, 

7 once the date is in, as much as is possible, to 

8 start working with you to see if we can do the 

9 kind of thing you're asking, to try to reach some 

10 resolutions you can all live with. 

11 And that's the key to consensus. We 

12 understand you represent many, many 

13 constituencies. And you've probably been 

14 communicating with them. And to make sure that 

15 this is a rule you can all live with and you feel 

16 good about. 

17 So that's what we're going to do. We're 

18 not going to keep you late today. But we are 

19 going to push you, make sure the committees meet, 

20 and work with you as best we can to get this 

21 going. 

22 Thank you. 
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1 MR. LUBLINER: This is Mike Lubliner. 

2 I kind of share Lowell's concerns or 

3 comments. It's hard for me until I see 

4 specifically, I think, the cost data to make book 

5 on this. 

6 I do think we've got some great data 

7 that's coming in and discussion regarding data 

8 sources. But I agree that we really haven't come 

9 to agreement on very much yet. So I think it's 

10 like two things. 

11 One is, we're getting good data. This is 

12 a good process. But I'm not sure until I see 

13 specific information, particularly the cost data 

14 and the subsequent analysis. 

15 But I think it would be prudent, John, to 

16 start looking into that, making sure that's a 

17 contingency that we can take advantage of. And I 

18 certainly, if I was a betting man, would bet that 

19 we're going to extend this out. 

20 We've got issues of labeling, a whole 

21 bunch of other things as well that are important, 

22 that need to be addressed. So, that's my 
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1 thoughts. Thank you. 

2 MR. HAGERMAN: This is Joe Hagerman, DOE. 

3 Let's not forget just -- I know we 

4 haven't necessarily agreed on a lot of specifics. 

5 We have agreed on some really important specifics 

6 in terms of what we all need as a group to see, 

7 to make a decision, right? I mean, that's some 

8 of what this mind-map that we made yesterday is, 

9 all those items of what analysis we need to see 

10 so we can start specifying levels and reach that 

11 agreement, right? 

12 MR. LUBLINER: That's right. 

13 MR. HAGERMAN: Which you're going to see 

14 those things being delivered, you know, 

15 hopefully, by the end of the week, right? 

16 So I mean, I'm -- you know, I understand 

17 Lowell's position and Mike Lubliner's position. 

18 But, John, I would really encourage, go get us 

19 the additional month. Because I have confidence 

20 that all our friends here will get us to a good 

21 term sheet that we're all going to be comfortable 

22 with. 
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1 MR. RAMIREZ: And that doesn't mean we 

2 have to use the full month, right? 

3 MS. HOFFMAN: No. I'm all for good 

4 behavior. 

5 MR. RAMIREZ: All right. 

6 Anything else, then, before we move on? 

7 MR. WEISS: Very briefly, Mark Weiss, 

8 MHARR. 

9 And if I didn't do so before, thank you, 

10 John. I appreciate it. 

11 Something that I mentioned yesterday I 

12 wanted to correct. I was referring to American 

13 housing survey data with respect to purchase 

14 price of manufactured homes, and the question 

15 came up, well, were those new homes? 

16 And reviewing AHS today, my answer was 

17 yes, they are new homes. And reviewing the AHS 

18 today, I just want to clarify, the sample 

19 includes new construction within the current 

20 sampling period, but it also includes sampling of 

21 people who are already in their homes, as 

22 apparently it adds to the purchase price of the 
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1 home when they bought it. 

2 So, yeah, it's all new home purchase 

3 prices. But some of it goes back to earlier 

4 periods, going as far back, apparently, as 1973. 

5 So what I said yesterday, it's new, yeah. 

6 Technically, that's correct. But it's not all 

7 new homes within the current sampling period. 

8 MR. RAMIREZ: I appreciate that 

9 clarification. 

10 MR. UNGER: This is Lowell. 

11 I'd just note that I think the MHI fact 

12 sheet that was sent around yesterday includes 

13 prices for new homes. 

14 MR. RAMIREZ: Okay. But is it that same 

15 dynamic of new homes? It's new home sales from a 

16 tight time period? Or are we dealing with the 

17 same dynamic that Mark just clarified? 

18 MS. STARKEY: No, it's new homes. And I 

19 don't know how far back we -- I would think we 

20 can go back pretty far if you want historical 

21 data. 

22 MR. RAMIREZ: Okay. Okay. I just wasn't 
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1 sure if it was the same issue that Mark was 

2 talking about. 

3 MR. WEISS: No, no. That's current 

4 period. 

5 MR. RAMIREZ: Okay. 

6 MR. WEISS: The way I read AHS, they 

7 basically have a rolling sample of purchase 

8 prices going all the way back to '73, updated 

9 through 2011. 

10 MR. RAMIREZ: Okay. Thank you. 

11 MR. LUBLINER: Mark, Mike Lubliner. I 

12 had a question on that. 

13 Does that sample also include procurement 

14 by the Federal Government of HUD code homes, say 

15 by FEMA or other federal agencies, Army Corps of 

16 Engineers? And to what extent could that have an 

17 impact, if any, on this analysis? 

18 MR. WEISS: Don't know, from what I've 

19 read in the AHS, I can take a look at it. I want 

20 to say no, but I'm not sure, is the answer 

21 sitting here right now. 

22 MR. UNGER: Thanks, Mark. 
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1 MR. RAMIREZ: Okay, great. 

2 Manny, which document do you want to go 

3 through next? Sorry -- Emanuel. 

4 MR. LEVY: Let's start with the ducts, 

5 proposed requirements for ducts. 

6 Yeah, thanks. And, Javier, during the 

7 break, I sent you an email with the suggested -- 

8 MR. RAMIREZ: One -- Emanuel, I'm sorry. 

9 Before we do that, we had left off last 

10 time with the group was going to look at some of 

11 the data that was already provided to see if we 

12 needed to do an additional analysis for the 0.33 

13 window. 

14 MR. LEVY: Yeah. 

15 MR. RAMIREZ: Did the folks get an 

16 opportunity to look at the current data? I think 

17 it's runs one and two. 

18 [Pause.] 

19 MR. LUBLINER: Say that again? 

20 MR. RAMIREZ: The folks were going to 

21 look at runs that were already provided to look 

22 at the efficiencies for 0.25 and -- what was the 
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1 other value? 

2 MR. LUBLINER: Three-three. 

3 MR. RAMIREZ: Two-eight. To see if there 

4 was a need to do an additional run with 0.33. 

5 [Pause.] 

6 MR. RAMIREZ: Yeah, Eric? 

7 MR. LACEY: Can we wait on that for maybe 

8 another couple of days? I do want to spend a 

9 little more time with that. Eventually, you 

10 know, if we're driving forward with 0.33 as the 

11 straw man, I'd really like to see the difference 

12 between that and a 25. But I want to make sure 

13 before they do the runs that we have the right 

14 information in place, if that makes sense. 

15 MR. RAMIREZ: Okay. 

16 Mark? 

17 MR. LEVY: Javier? 

18 MR. RAMIREZ: Yes. 

19 MR. LEVY: I sent you during the break an 

20 email with a table that would be populated by a 

21 sensitivity analysis, just a suggested approach 

22 to doing that analysis. 
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1 Some of that data, as you point out, we 

2 may have already. I think it might make sense to 

3 circulate that to the committee as a starting 

4 point for getting agreement on what the 

5 sensitivity analysis should consist of. 

6 MR. RAMIREZ: Okay. 

7 MR. LEVY: And I'll have a cost for you 

8 at the end of the day here. So you'll have all 

9 the data you need to do the analysis. 

10 MR. RAMIREZ: I'll send that out to the 

11 group. 

12 Mark? 

13 MR. HAGERMAN: So, over the break, I had 

14 Navigant pull out the numbers -- this is Joe 

15 Hagerman, DOE -- pull out the numbers from the 

16 previous runs to see if we could get a good 

17 indication of how much of an impact, going from 

18 0.28, I believe, to 0.30 or 0.33, whatever the 

19 numbers were, right? 

20 And so, they started trying to pull those 

21 numbers out. And it's a little bit more 

22 complicated, given that some of the ducts, you 
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1 know, and stuff may have changed. Some other 

2 factors may have changed in there. Not 

3 radically, but just enough that we'd have to look 

4 at the data a little bit more closely. 

5 It does look like there's, in some 

6 climate zones, like in Miami, it has an impact 

7 large enough that, you know, the group should 

8 talk about it, right? Because it is probably 5 

9 percent. I just -- by kind of looking at the 

10 numbers. 

11 So let us, let Matthew and Ed kind of 

12 look through the data again and maybe circulate 

13 something over the next few days over this. 

14 MR. LUTER: Joe, this is Robin at 

15 Lippert. Could I offer a comment, please? 

16 MR. RAMIREZ: Absolutely. 

17 MR. LUTER: On the solar heat gain 

18 analysis, if you look at the chart that Emanuel 

19 showed earlier, you've got a low and a high. The 

20 high figure shown represents what you would be 

21 able to achieve, less grids and with the least22 forgiving frame arrangement. 
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1 So if you focused on those high-threshold 

2 numbers in the analysis, you could be assured 

3 that, whatever the type of window the homebuilder 

4 would select, that it would be an achievable 

5 number. 

6 For example, you'd hit folks on 0.28, 

7 only to find out that the home builder could now 

8 not use picture windows just because, by virtue 

9 of their construction, they wouldn't hit the 

10 number. 

11 Another way to look at that is -- well, 

12 no. I'll just leave it at that. 

13 MR. HAGERMAN: This is Joe Hagerman. 

14 I think that's a great comment. We'll 

15 take that into account. We'll take into account 

16 item number 3, or proposed standard bullet 3 

17 here, this "permitted to satisfy the solar heat 

18 gain requirement on the basis of the area 

19 weighted solar heat gain coefficient average," 

20 too. So -- but I think I understand. 

21 MR. LUTER: Do you? Okay. I'll defer to 

22 the manufacturers on this. 
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1 But it's my understanding that, with the 

2 various issues they have to comply with out 

3 there, we have situations right now where, for 

4 example, on a particular window operator type, 

5 they're forced to go with grids in order to 

6 achieve the solar heat gain number targets that 

7 they need, where it's an aesthetic choice that 

8 perhaps the homeowner wouldn't otherwise make. 

9 And we want to avoid things like that. 

10 Emanuel or Mark, if you could -- 

11 MR. UNGER: Sorry. Who is forced to go 

12 with grids? I just didn't understand that 

13 comment. 

14 MR. LUTER: It's my understanding that 

15 there are situations where, in order to hit a 

16 solar heat gain target, for example, a home 

17 builder needs to add grids to a window because of 

18 the benefit that that adds, where they otherwise 

19 might choose not to for aesthetic or cost 

20 reasons. 

21 MR. UNGER: Like for ENERGY STAR? Or who 

22 has a solar heat gain target currently? 
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1 MR. LUTER: Manny or Mark, can you chime 

2 in there? 

3 MR. EZZO: Yeah, this is Mark. 

4 The issue is certain manufacturers' 

5 windows have better solar heat gain coefficient 

6 values with grids than they do without. 

7 So if you're -- in some circumstances, 

8 depending on the zone you're shipping to, if you 

9 need to hit a certain heat gain coefficient 

10 number, sometimes you're forced into having to 

11 buy the window with grid because that's the only 

12 one the window manufacturer has available to hit 

13 that heat gain coefficient target. 

14 Does that make sense? The heat gain 

15 numbers get better, lower, when you have grids. 

16 MR. UNGER: Sorry. This is Lowell. 

17 I'm confused on the assumption of why the 

18 manufacturer has to hit a solar heat gain target 

19 to begin with, here at the moment. 

20 MR. LEVY: Mark, this is Emanuel. 

21 Are we talking about for modular homes? 

22 MR. EZZO: Oh, excuse me, for modular 
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1 homes. Yeah, for modular homes where we're right 

2 now complying with mostly the '09 energy code, 

3 there are specific requirements for heat gain 

4 coefficient we have to hit, not for HUD. 

5 MR. UNGER: Thanks. So you're saying for 

6 some modular homes, in order to meet the IECC, or 

7 whatever the relevant code in the state, that 

8 you're limited in your type of window choice in 

9 order to meet that? 

10 MR. EZZO: Exactly. 

11 MR. UNGER: Thanks. 

12 MR. LACEY: This is Eric -- 

13 MR. LUBLINER: This is Mike Lubliner. 

14 MR. RAMIREZ: Go ahead, Michael. 

15 MR. LUBLINER: I was just going to say I 

16 think this highlights the reason I asked to see 

17 the specific window schedule for the two 

18 prototypes that are being modeled, or create one, 

19 so that we have an idea. 

20 And I would recommend that the 

21 manufacturers suggest what's fairly typical in 

22 that floor plan, no special windows, and then the 
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1 operator type, whether it has grids or not. Then 

2 we can assess that window schedule and see if we 

3 have a problem, typically. 

4 I think that's an important step. Thank 

5 you. 

6 MR. RAMIREZ: All right. Let's get Eric, 

7 and then Mark. 

8 MR. LACEY: This is Eric. 

9 Just one more question to qualify. I'm 

10 kind of as puzzled as Lowell was on this issue of 

11 being forced to put in grids. 

12 Is the issue that the window that was 

13 stocked, you may not have had a window in stock 

14 that met the SHGC requirements other than one 

15 that had grids? Or is the issue that the 

16 manufacturers can't achieve that low of an SHGC 

17 without grids? 

18 Because I thought I had heard earlier 

19 that the enhanced products are available. There 

20 are several levels of enhanced products that meet 

21 SHGC's, probably in the low 3s or high 2 range. 

22 I'm still trying to wrap my brain around 
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1 this instance you brought up and would 

2 appreciate, you know, maybe some more specifics 

3 on the whole grid issue. Maybe we can follow up 

4 after this call. 

5 MR. EZZO: I can give you -- this is 

6 Mark. I can tell you, Eric, real quick. 

7 One of the suppliers we buy windows from, 

8 okay, they don't have on the shelf an enhanced 

9 low-E glass. So in the '09 IECC, when I have to 

10 hit 0.30, I have to buy their gridded product to 

11 hit that number. Because their non-gridded 

12 product has a 0.32, I think the number is -- 

13 don't quote me on that. 

14 It's not to say they can't go and buy 

15 enhanced glass and do that. But that's not 

16 something that they do today. 

17 MR. RAMIREZ: Okay. Thank you. 

18 Mark? 

19 MR. EZZO: Or that's not something they 

20 offer today, I guess I should say. 

21 MR. RAMIREZ: Yeah. Mark? 

22 MR. WEISS: If that discussion is played 
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1 out? 

2 MR. RAMIREZ: I think so. 

3 MR. WEISS: Okay. Going back to Joe's 

4 original statement, the point -- analysis point 

5 28, the 33, whatever. 

6 Anyway, your comments also pertain to the 

7 HUD baseline calculation, correct? When you say 

8 you've got to go back and look at it? 

9 Okay. Thanks. 

10 MR. HAGERMAN: Yeah. We've provided the 

11 HUD baseline. So we can add that to the table, 

12 too. It's like 0.60 or 0.80. It's way away. 

13 MR. RAMIREZ: Okay. All right. 

14 Anything additional before we have 

15 Emanuel continue? 

16 [Pause.] 

17 MR. RAMIREZ: All right. Okay, Emanuel, 

18 you're back on. 

19 MR. LEVY: I'm glad we got past the easy 

20 one. 

21 [Laughter.] 

22 MR. LEVY: Let's move along to ducts. So 
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1 the issue here is actually two related, two 

2 issues, both that deal with ducts. One is the -- 

3 and I brought them together on this table. We 

4 can take them in pieces. 

5 The first at the installation level at 

6 the exterior ducts, the amount of insulation 

7 that's wrapped around those ducts. And the 

8 second issue is the amount of leakage from the 

9 duct system itself. 

10 So, again, following the same format, you 

11 can see that at the top I've listed out here the 

12 survey of the current requirements. 

13 There's a typo. And, Mark, I know you 

14 and I talked about this. Just to confirm, the 

15 HUD code current requirement is R-8 for supply 

16 and return ducts? Mark Ezzo? 

17 MR. EZZO: That's correct. 

18 MR. LEVY: So if you would type an 8 in 

19 there and correct your sheets. 

20 MR. RAMIREZ: Yeah, that's a PDF form, so 

21 we can't change it. 

22 MR. LEVY: Okay. But for everybody's 
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1 benefit, that should be an 8 instead of a 4. 

2 [Pause.] 

3 MR. LEVY: Okay. So, let's talk about 

4 the installation piece -- 

5 MR. LUBLINER: Emanuel? 

6 MR. LEVY: Yes, go ahead. 

7 MR. LUBLINER: Mark Lubliner. 

8 I just want to -- just background for 

9 some of the folks. The reason that the HUD code 

10 started with R-4 in 1994 and changed to R-8 was 

11 the result of work that the NFPA 501 originally 

12 did on a proposal I had made and also then 

13 adoption by the consensus committee of HUD. And 

14 then, promulgation of that by HUD. 

15 So just a little background that we've 

16 made some progress even without the DOE efforts 

17 here on that one. 

18 Thank you. 

19 MR. LEVY: Thanks for that, Mike. 

20 Okay. So if we look down a little bit on 

21 the sheet, I think this is a pretty easy one for 

22 us to wrap up. What we're suggesting is under 
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1 section A-1 there, that ducts be insulated to R2 8, which is basically maintaining the requirement 

3 that we have today. 

4 And as you can see from the table above, 

5 that that is consistent with what's in the IECC. 

6 Actually, it's a little bit better than the IECC 

7 15. And this is both for -- this is for exterior 

8 ducts now. This is ducts that run outside of the 

9 thermal envelope of the home, that it's 

10 consistent with what's in the IECC, or even 

11 superior. 

12 So that's the proposal there, no change. 

13 Any comments? 

14 MR. RAMIREZ: Yeah. Let me ask the 

15 group. What do you think of that? 

16 [Pause.] 

17 MR. WEISS: This is for Rick. The R-8, 

18 is that the prescriptive? 

19 MR. MENDLEN: It's prescriptive, and it's 

20 put into effect. 

21 MR. WEISS: Okay. 

22 MR. RAMIREZ: So, does this look okay to 
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1 everybody? 

2 [Pause.] 

3 MR. RAMIREZ: Let me ask the question and 

4 clarify that I'd like to see some thumbs. 

5 Is R-8 for exterior insulation for the 

6 ventilation okay with everybody, for the duct 

7 systems? Let me see a show of thumbs. 

8 [Pause.] 

9 MR. RAMIREZ: Okay. Going once -- 

10 MR. HAGERMAN: Let's get the -- since he 

11 put his placard up, I'd assume he has a question 

12 or a comment before we take a vote, right? 

13 [Cross-talk.] 

14 MR. RAMIREZ: Yeah. You know what? 

15 MR. LACEY: Rather than giving a thumbs16 down. 

17 MR. RAMIREZ: And that's okay. If you 

18 remember, thumbs-down could be just that you have 

19 a question or -- yeah. That's fine. Because, 

20 remember, there's going to be some onus on you. 

21 Either ask a question or explain why your thumb 

22 is down, and offer alternatives if need be. 
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1 Okay. So go ahead and ask the question. 

2 MR. LACEY: All right. Eric Lacey from 

3 RECA. 

4 This looks fine, except the one question 

5 I had is this clause, "and exposed to outside 

6 air." I'm wondering, and I'm not as familiar 

7 with the construction of manufactured homes as I 

8 am with site-built homes. But outside the 

9 building thermal envelope, you know, a stick10 built home might be the attic. It might be 

11 someplace other than completely outside the 

12 building. 

13 So what I'm wondering is, are there areas 

14 within the manufactured home that aren't 

15 completely exposed to outside air that would 

16 still be considered outside the building thermal 

17 envelope? And how much of the duct is going to 

18 be in that area? 

19 I think that's important, because if 

20 you're not required to insulate, but it's in an 

21 area that's semi-conditioned or unconditioned, 

22 then you're going to lose a lot of duct 
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1 efficiency. That's the only reason I ask. 

2 But honestly, I don't know how they're 

3 constructed like that. 

4 MR. RAMIREZ: Emanuel, do you have an 

5 answer for that? 

6 MR. LUBLINER: Mike Lubliner. 

7 MR. LEVY: I would defer to the 

8 manufacturers to explain that. 

9 MR. SANTANA: This is Manny with 

10 CAVCO, and I think that I can field that one. 

11 I think the only part of a manufactured 

12 home that would be in question is going to be the 

13 un-insulated duct that is in the belly. You 

14 know, and this might be something that we want to 

15 talk about. 

16 You know, the definitions in Chapter 2 of 

17 the IECC, the one for conditioned space would 

18 still count the ducts in the belly as being in 

19 conditioned space. So it's the belly being the 

20 area in between the two main rails that has a 

21 bottom board with insulation. 

22 So since that is typically insulated 
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1 outside of the duct, that would fall into a 

2 conditioned space area, even though we don't have 

3 conditioned air going into that area. 

4 [Pause.] 

5 MR. RAMIREZ: So then, if I understand 

6 correctly, then that would not be required to be 

7 insulated. 

8 MR. SANTANA: Right. That's the way that 

9 I see it. 

10 MR. RAMIREZ: Okay. Lowell, do you have 

11 a question? 

12 MR. UNGER: Yeah. I'm still not sure I 

13 understand. You're saying under either IECC or 

14 this straw man, the duct in the belly would not 

15 be -- 

16 MR. RAMIREZ: I'm sorry, Lowell. 

17 [Inaudible interjections.] 

18 MR. RAMIREZ: Rick. Rick. Rick. Rick! 

19 Okay. I'm sorry. Lowell? 

20 MR. UNGER: Did I understand that you're 

21 saying that a duct in the belly would not be 

22 required to be insulated under either the IECC or 
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1 this straw man? 

2 MR. SANTANA: Right. 

3 MR. UNGER: So, I'll leave it to the 

4 building experts whether that's a problem. But I 

5 did have a question. So I think the original 

6 question was, this says, "outside the building 

7 thermal envelope," which is, I think, a normal 

8 description for codes as to what you're talking 

9 about, "and exposed to outside air." 

10 The question is, why does it say, "and 

11 exposed to outside air," and what difference does 

12 that phrase make? 

13 [Pause.] 

14 MR. LUBLINER: This is Mike Lubliner. 

15 You know, I don't see that we need to 

16 have the "and exposed to outside air" in there. 

17 My read of that is that, as long as the attic is 

18 vented or the crawl space is vented, it's exposed 

19 to outside air. And those are going to need to 

20 have the RA crossover. 

21 If the duct is in the attic and it's 

22 above the insulation, it's exposed to outside air 
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1 and needs to be RA. If the duct is in the belly 

2 and there's at least RA insulation of the belly, 

3 then it wouldn't be. That's kind of my read of 

4 what this is, where this is. 

5 MR. RAMIREZ: And does that work? 

6 MR. LUBLINER: Does it work to take the 

7 "and exposed to outside air" out? Is that the 

8 question? 

9 MR. RAMIREZ: Either that, or is it okay 

10 if it's underneath the insulation of the belly? 

11 Right? If it's between the insulation and the 

12 frame, and not covered, right? That's how it 

13 would state there. 

14 So is it okay as is, or do we need to 

15 strike "and exposed to outside air"? 

16 MR. HAGERMAN: This is Joe Hagerman. I 

17 have a question for the manufacturers about that. 

18 Is the phrase "outside the building 

19 thermal envelope and exposed to outside air" an 

20 artifact of the HUD code and-or an artifact of 

21 the IECC code? Or vice-versa? 

22 [Pause.] 
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1 MR. EZZO: Hey, this is Mark Ezzo. 

2 Does anybody there have the IECC handy 

3 that we can look at? 

4 MALE VOICE: Yeah. I'm looking at it 

5 right now. 

6 MR. RAMIREZ: We have quite a few people. 

7 MALE VOICE: We all do. 

8 MR. EZZO: It's 403.3.1. Supply and 

9 return ducts in attics shall be insulated to 

10 minimum R-8 where three-inch in diameter or 

11 greater, in R-6 where less than three inches in 

12 diameter. Supply and return ducts in other 

13 portions of the building shall be insulated to 

14 minimum R-6. 

15 MR. RAMIREZ: Mark, could you repeat that 

16 reference? 

17 MR. EZZO: 403.3.1. It's on page R-35 of 

18 the IECC. 

19 And then the exception says, "Ducts or 

20 portions thereof located completely inside the 

21 building thermal envelope." So that's IECC 

22 version. 
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1 [Pause.] 

2 MR. LACEY: This is Eric. 

3 Then, just to clarify, "building thermal 

4 envelope" is a defined term. So you can look in 

5 Chapter 2, and it's the basement walls, exterior 

6 walls, roof, floor roof, and any other building 

7 elements that enclose conditioned space or 

8 provide a boundary. 

9 And so, I don't have a dog in the fight 

10 here. I just wanted to make sure we were being 

11 consistent and find out how much of the ducts 

12 might be in this space in between being 

13 completely exposed and being inside the thermal 

14 envelope. That was all. 

15 MR. LUBLINER: This is Mike Lubliner 

16 again. 

17 And in the definition of sub-part F of 

18 the HUD code, there's both a definition for 

19 "thermal envelope area," which gets into the 

20 definition of "thermal envelope," but a separate 

21 definition for "pressure envelope." 

22 And that's going to come up later. So 
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1 I'm just putting that on the radar screen. 

2 That's going to come up later as we talk about, 

3 are we trying to limit the pressure? Or is it 

4 the thermal envelope? 

5 I think that Mark Ezzo has pretty much, 

6 if I understand, confirmed what I was saying, is 

7 that if it's in the attic and the attic is vented 

8 and it's above the insulation, it needs to be 

9 insulated to a minimum of R-8. 

10 If it's within the conditioned space, or 

11 the pressure envelope, meaning it's within the 

12 insulation in the drywall like a chase within the 

13 drywall of a house, which is rarely done at this 

14 point, except for some test homes that I know 

15 that the manufacturers have built, that would be 

16 totally in the conditioned space. 

17 I think that the other issue is in the 

18 crawl space. Are we talking about the crossover 

19 duct, period? If there's a through-the-rim 

20 system, then I wouldn't expect this provision 

21 would apply because the rim joist is within that 

22 space and has full insulation because of the 
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1 floor insulation. 

2 So I'm thinking this really applies. The 

3 R-8 would apply to the crossover, or when the 

4 ducts are in the attic above the insulation. 

5 MR. EZZO: This is Mark Ezzo. I agree 

6 with that as well. I think that's the intent. 

7 And I think that's consistent with what's in the 

8 HUD code. 

9 MR. RAMIREZ: Would that intent be more 

10 clear if that was deleted then and exposed to 

11 outside air? 

12 MR. LEVY: Yeah. Let's take that out, 

13 and then we're completely consistent with IECC. 

14 And I think it's the simplest way to say that. 

15 MR. RAMIREZ: Okay. So, with that 

16 understanding, what I'm trying to do is to see if 

17 we get agreement on this so that can be plugged 

18 into any future models so we don't have to keep 

19 on going back and forth on this. 

20 Yeah, Mark? 

21 MR. WEISS: Okay. That raises two 

22 questions that I was actually going to save till 
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1 the end. But I think we'll need to bring them up 

2 now. 

3 These three documents we have, these are 

4 being proposed as substitutes for presumably 

5 parallel provisions of the IECC; is that correct? 

6 MR. LEVY: That's correct. 

7 MR. WEISS: Okay. So, based on that, to 

8 me these should go into the same chart that we 

9 did for the stuff that Manny had earlier, subject 

10 to what's in that chart. 

11 MR. RAMIREZ: Okay. 

12 MR. WEISS: As proposed parallel 

13 replacements for specified IECC provisions. 

14 MR. RAMIREZ: Right. And then, Manny, I 

15 would ask you -- not Emanuel, I got it right this 

16 time. Manny, is that something that then you 

17 would incorporate with your subcommittee as 

18 you're outlining the 2015 IECC stuff? 

19 MR. SANTANA: Can I use the "I spaced 

20 out" card, and can you repeat that? 

21 [Laughter.] 

22 MR. RAMIREZ: Exactly. Thank you. 
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1 So, that was a thumbs-down, and that was 

2 exactly why you would choose it, right, to ask 

3 that question? 

4 So, as we're sitting here, if the group 

5 is saying, "Yeah, we're okay with this component 

6 here to insulate to R-8 when you have the ducts 

7 that are outside the envelope," then what you 

8 would do is, when you're going through the 2015 

9 IECC stuff and you're looking for where to make 

10 the changes, this would be one that you'd 

11 incorporate in there because the group has agreed 

12 to go along with this. 

13 MR. SANTANA: Yeah, right. That is 

14 correct. 

15 MR. RAMIREZ: Okay. Okay, great. 

16 So then, we'll -- 

17 MR. HAGERMAN: But on that note, I mean, 

18 this is one that's already in the manufactured 

19 housing code, correct? And so this would not be 

20 a cost increase. Right? 

21 [Inaudible interjections and laughter.] 

22 MR. SANTANA: You know, that is correct 
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1 as well. And, you know, in all fairness, I think 

2 this is one of the prescriptive portions of it. 

3 So, you know, with so much to go through on the 

4 mandatory side, I don't know that we have time to 

5 get to it. 

6 But if we were to, it might be one of the 

7 ones that we just kind of gloss over because it's 

8 already in the HUD code. And I'm not exactly 

9 sure how we would address it. We might take the 

10 position that there are more important things to 

11 worry about. This is almost done. 

12 MR. RAMIREZ: Okay. Then we'll update 

13 that then and get that out. Okay? 

14 MR. WEISS: Just for clarification, the 

15 parallel provisions we're talking about for this 

16 one, the ducts. 403.3.1 and 403.3.3, that's the 

17 stuff we haven't discussed yet on the testing, 

18 correct? It looks that way to me. 

19 MR. SANTANA: Correct. 

20 MR. WEISS: It looks that way to me. 

21 On the SHGC, which you've already 

22 discussed, it looks like the parallel provision 
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1 is 402.1.2 in the corresponding table. 

2 MR. RAMIREZ: 402. -- 

3 MR. WEISS: 402.1.2 in the corresponding 

4 table, which I don't have the number of. Where 

5 is that one? 402.1.2. Yeah, same. Table is the 

6 same reference. 

7 MR. RAMIREZ: Okay. So, for 

8 clarification, everyone is okay with that, to 

9 plug that in for future references, correct? 

10 Show of thumbs? 

11 [Pause.] 

12 MR. RAMIREZ: All right. I sparked up 

13 that steamroller and went over a couple of people 

14 because I didn't see any thumbs. So we're moving 

15 on. 

16 All right. Great. So what else do you 

17 have on your document there, Emanuel? 

18 MR. LEVY: Well, first I want to 

19 congratulate the committee. It took us only 45 

20 minutes to agree on something that's already in 

21 the standard. So we're in good shape. 

22 [Laughter.] 
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1 MR. LEVY: Okay. So, under duct leakage, 

2 and this is a much more substantive part, because 

3 it has to do not only with what the requirement 

4 is, but how -- and it gets into the verification 

5 of that requirement. 

6 And if you look above -- Javier, if you 

7 can go back up to the table above? You'll see 

8 that maximum duct leakage, there's not currently 

9 a requirement -- I believe that's correct -- in 

10 the HUD code. 

11 And the 2009, there was a requirement set 

12 that the duct system couldn't leak more than 8 

13 cubic feet per minute per 100 square feet of 

14 conditioned floor area. This is kind of a 

15 universal metric for measuring air leakage from 

16 duct systems. 

17 That was reduced to four, a level of 

18 four, for both the 2012 and 2015 IECC. 

19 The proposal on the table is recognizing 

20 that the leakage will be -- can only be measured 

21 under the statute in the plant. I've suggested 

22 in two parts. One is to maintain the four when 
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1 the measurement is done without the air handler 

2 in place, and a target of six cubic feet when the 

3 air handler is in place. 

4 There's a section, before I turn this 

5 back to comments, there's two sections below this 

6 that I'll touch on in a minute. One of them has 

7 to do with sealing instructions, which is more of 

8 a prescriptive direction on how you get to those 

9 lower leakage levels. 

10 And then in section B, right there, is a 

11 description of how the leakage is actually 

12 measured. It's a protocol for measuring leakage. 

13 This is a fairly standard protocol. 

14 So that's the proposal on the table, is 

15 four CFM for leakage, maximum leakage, without 

16 the air handler, and six with the air handler in 

17 place. Let me stop there. 

18 MR. LUBLINER: Emanuel, Mike Lubliner. 

19 I think this is real good. I do have one 

20 constructive suggestion based on communications 

21 on this with some of the folks I work on at the 

22 ASHRAE that developed these testing standards, 
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1 ASTM, and manufacturer of the testing systems. 

2 It seems like that the six cubic foot per 

3 minute per 100 square foot varies with the size 

4 of the house. And I'm just wondering. You know, 

5 a furnace is a furnace. It leaks. Whether it's 

6 a 16 KW electric furnace or something else, it 

7 tends to have a leakage value. 

8 And I'm just wondering -- and if it 

9 doesn't vary with the size of the house, I'm just 

10 wondering whether it would be more appropriate, 

11 as I think we do in the Northwest in our ENERGY 

12 STAR program when we test the house with the 

13 furnace in place, is to consider something that's 

14 a fixed number, not variable with, per square 

15 foot. 

16 I'm just wondering if that's a friendly 

17 amendment or something that we could put in as 

18 technical leads, but agree to look into something 

19 equivalent to the six feet per minute that's more 

20 reflecting of the physics of the furnace being a 

21 fixed leakage. 

22 MR. SANTANA: You mean a percentage lost 
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1 or percentage of the leakage type? 

2 MR. LUBLINER: Well, like what we do, I 

3 think -- and I have to double-check with the guys 

4 that run the program in the Northwest. But I 

5 think they just subtract 40 CFM for the furnace, 

6 period. They don't have a variable of that 

7 that's based on the house size, because a furnace 

8 is a furnace. 

9 So anyway, I'm just wondering where that 

10 six came from. And maybe suggesting that, from a 

11 physics standpoint, since it's a fixed leakage, 

12 it shouldn't vary with the home. It should be a 

13 fixed number. What that number is I'm open for 

14 suggestion. 

15 Emanuel, do you understand where I'm 

16 going with that? 

17 MR. LEVY: Yeah. Absolutely. 

18 MR. LUBLINER: Okay. Thank you. 

19 MR. LEVY: I mean, there's one furnace. 

20 There's one place for leakage to occur. Sure. 

21 MR. LUBLINER: The other thing is, there 

22 is a standard, 193, an ASHRAE standard, which is 
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1 a method of test to determine the air leakage 

2 rate of an HVAC box. And that's standard 193. I 

3 chaired that committee. 

4 And that standard is referenced in the I5 codes in the State of California as the method of 

6 test to determine what those codes are prescribed 

7 for as a, quote, "tight box," just an FYI. I 

8 don't know that we need to get into those weeds 

9 now. 

10 But I would suggest that we just look at 

11 whether or not we could substitute CFM in there 

12 and then get back on what that appropriate CFM 

13 would be from some discussions we can have 

14 offline. 

15 Anyway, I don't want to hold things up 

16 with that weeds, technical weeds discussion, but 

17 I think it's important. Thank you. 

18 MR. RAMIREZ: So then, where do we go 

19 with this? Manny has this up here. If we're 

20 going to look at just one number -- I'm sorry, 

21 Emanuel. 

22 Emanuel, is that something that you would 
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1 dig up? Or Luby, is that on you to get Emanuel a 

2 number? 

3 MR. LUBLINER: I will get the information 

4 on what the number is we use from the Northwest 

5 program and share it with Emanuel. And then we 

6 can decide whether or not it's appropriate. 

7 MR. RAMIREZ: Okay. 

8 MR. LEVY: Yeah, I think that's 

9 appropriate. I understand, Michael, what you're 

10 saying. And I'm just trying to think about what 

11 that number might be to be representative of the 

12 range of cases that we would be -- that would 

13 actually be encountered. But I'd certainly be 

14 open to that. 

15 MR. LUBLINER: Thank you. 

16 MR. RAMIREZ: Okay. What do you have 

17 next? 

18 I'm sorry. Eric, then Lowell, and then 

19 Mark. 

20 MR. LACEY: This is Eric. Just for 

21 Emanuel, one clarifying question. 

22 In the IECC, there's an exception to the 
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1 duct testing requirement if all ducts and air 

2 handlers are located inside conditioned space. 

3 And I'm wondering if you intended to include that 

4 exception, or if the intent here is to have the 

5 ducts tested in every manufactured home. 

6 MR. LEVY: You know, that's a very good 

7 point. Eric, I'm glad you brought that up 

8 because that is something that should be in here, 

9 and it's not. So I will add that after this 

10 call. 

11 Does everybody understand what Eric has 

12 just suggested? 

13 MR. LACEY: I mean, personally, I'd 

14 prefer that every system be tested. I think it's 

15 better. But that is something that I know a lot 

16 of builders take advantage of. And it's -- you 

17 know, locating inside conditioned space is by far 

18 the most efficient way to do it. 

19 MR. LEVY: And that encourages 

20 manufacturers to do that. So I think that would 

21 be a good thing to include. 

22 MR. RAMIREZ: Okay. And again, Emanuel, 
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1 will you dig that up and throw it in there? 

2 MR. LEVY: Yes. 

3 MR. RAMIREZ: Okay. 

4 MR. LEVY: Yes. I'll add that into the 

5 language here. 

6 [Pause.] 

7 MR. LUBLINER: This is Mike Lubliner. 

8 I had mentioned ducts and the conditions 

9 based on one of our first meetings. I totally 

10 support where both you guys are going. 

11 MR. RAMIREZ: Mike, hold off for a 

12 second. We've got Lowell and then you, okay? 

13 MR. LUBLINER: Sorry. 

14 MR. EZZO: This is Mark. 

15 I think he were just supporting what was 

16 just said. 

17 I had a couple of questions that were 

18 different. One is, at the beginning of 2, it 

19 says, "the prescriptive and-or performance 

20 targets." And I'm wondering whether you meant 

21 "and" or "or." I don't see how it can be both 

22 "and" and "or." 
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1 [Pause.] 

2 MR. LEVY: Yeah. I think that's an 

3 artifact. I had an earlier version. Let me just 

4 see if I'm looking at that. There's one more 

5 section to this. Maybe we can come back to this, 

6 because there's one more section I want to talk 

7 about, which is the sampling procedure. 

8 MR. EZZO: So, leave that for the moment. 

9 So the second question is, you have the 

10 detailed duct leakage test procedures. 

11 MR. LEVY: Yes. 

12 MR. EZZO: And I wasn't sure where those 

13 -- since I'm certainly not qualified to judge the 

14 details of them, I'm wondering where they came 

15 from. 

16 MR. LEVY: Yeah. This is a fairly 

17 standard protocol for doing testing. You know, 

18 this is how the tests are actually done. And I 

19 don't know. Michael, does this -- I've used this 

20 in so many different places, I can't tell you 

21 exactly what the origin of it is. It is 

22 referenced from a number of different standards. 
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1 Mike Lubliner, do you know? 

2 MR. LUBLINER: Yeah, I'm here. You're 

3 talking about the protocol, the section B, 

4 basically, the duct procedure? 

5 MR. LEVY: Right. Um-hm. 

6 MR. LUBLINER: Yeah. I mean, I think 

7 it's -- there's different references there. But 

8 it seems to be what I see is out there. There is 

9 a requirement that only test method B in the STM 

10 standard be used. There are other approaches, 

11 but not ones that I want to raise at this point. 

12 So I'm pretty good with that. 

13 My question on this one really gets back 

14 to the question of where HUD is at. At one 

15 point, the consensus committee went ahead and 

16 approved the requirement for duct leakage and 

17 actually had promulgated some wording that I 

18 thought was awaiting HUD to decide if they were 

19 going to promulgate it as a standard. 

20 So I didn't want to put Rick on the spot. 

21 But if Rick felt comfortable talking about what 

22 status of that, maybe it would be good for some 
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1 background to let people know that, like the RA 

2 crossover, the consensus committee work with HUD 

3 to adopt. We're in the process of something on 

4 the duct leakage. And we might be able to learn 

5 from that. That's the one point. 

6 And the other point is that I do think 

7 that when you move the ducts totally in the 

8 conditioned space, and I think this would be 

9 applicable in a single-section home if you could 

10 drop a chase for the duct trunk, that there's 

11 really large energy savings potential there that 

12 could possibly be traded off against other 

13 measures. 

14 It's not just the air leakage. It's the 

15 conduction of the ducts. The ducts are no longer 

16 in a 160-degree attic running air-conditioning 

17 air with R-8. They're inside the building at 78 

18 degrees. 

19 So that's an area that I would encourage 

20 DOE to look at from the analysis standpoint 

21 issue. What's the energy savings associated with 

22 moving those ducts that are R-8 out of the attic 
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1 and into the house? And it may be beyond the 

2 scope, because as I understand, all the modeling 

3 looked at the ducts being in the floor, not in 

4 the attic at all. 

5 So, but getting back to your question, 

6 Emanuel -- I took the liberty of rambling on here 

7 -- yeah, I think it's adequate. 

8 MR. WEISS: Just getting to the good 

9 part. 

10 [Laughter.] 

11 MR. RAMIREZ: You faded out there. 

12 MR. UNGER: I had two additional, besides 

13 the response to my question, I saw a couple more. 

14 I heard two additional questions that were added 

15 there. So if you want to deal with those first? 

16 MR. RAMIREZ: Yeah. Go ahead, Mark. 

17 MR. WEISS: I'll wait. I have a much 

18 less-technical question. 

19 MR. UNGER: I also had a couple more 

20 things. 

21 MR. RAMIREZ: Go ahead. 

22 MR. LEVY: Let me just answer that 
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1 earlier question about the performance and 

2 prescriptive. 

3 MR. UNGER: Yeah. 

4 MR. LEVY: This is just a wording change. 

5 The duct leakage 82 is a performance standard. 

6 The additional requirements for sealing, which 

7 are prescriptive in nature, they're prescriptive, 

8 so it's "and," prescriptive and performance 

9 targets. You have to go both of those things. 

10 MR. UNGER: Thanks. 

11 MR. LEVY: What we're suggesting is that 

12 there's a series of sealing measures that ought 

13 to be undertaken consistently, regardless of what 

14 the performance target is. 

15 MR. UNGER: Emanuel, if I understand, the 

16 prescriptive happens on every house. The testing 

17 happens on a sampling basis. 

18 MR. LEVY: That's correct. 

19 MR. RAMIREZ: Okay. 

20 MR. LEVY: And that we'll get to in a 

21 moment. That's a piece we'll get to in a minute. 

22 That's in section C. 
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1 MR. UNGER: So, I also was just looking 

2 at IECC. And if I understand, post-construction 

3 they don't refer to air handlers. But pre4 construction, it's actually four cubic feet per 

5 minute with an air handler, or three if there's 

6 not an air handler. Is that correct? 

7 So in some -- so if I understand it, the 

8 equivalent for IECC would be four and three, 

9 where this proposal is six and four. 

10 [Pause.] 

11 MR. UNGER: And so I guess my question 

12 there would be, my follow-up question is why does 

13 this need to be -- you know, if we're starting 

14 from IECC, is there a reason why manufactured 

15 homes can't meet the same standard? Or is this a 

16 case where argument is it's not cost effective or 

17 something? 

18 MR. LUBLINER: This is Mike Lubliner. I 

19 could try to answer that. 

20 I think that, you know, in the assumption 

21 the IECC is that the air handler may be in the 

22 unconditioned space. I don't know that that's 
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1 the case for this industry. It's always within 

2 the building. 

3 There may be some Southern climates, 

4 Miami, where they used to have some air handler 

5 that was outside the building. But I don't know 

6 if that's even around anymore. I could go to 

7 manufacturers. But I think that that's kind of 

8 an apples-and-oranges. The IECC was broad or it 

9 was looking at homes where the air handler may 

10 not be in the conditioned space. 

11 But I'm not really clear. I wasn't 

12 involved in that with the I-codes. 

13 MR. RAMIREZ: Okay. Now, you had a 

14 question for Rick? Michael? 

15 MR. LUBLINER: Yeah. I was just 

16 wondering if Rick was in a position to update us 

17 on this status of the duct leakage testing 

18 proposal that the consensus committee approved in 

19 2009. It's been awaiting HUD action, I believe. 

20 Clarify for me if I'm wrong, Rick. 

21 MR. RAMIREZ: Okay. Okay. Rick, hold on 

22 a second because -- 
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1 MR. HAGERMAN: Let me interject. You 

2 know, Mike, I think just so that we can move this 

3 committee along, I think if you need to ask him 

4 that question, you should do -- I don't think 

5 that's really necessarily germane. I mean, this 

6 is the consensus committee for DOE's standard, 

7 not the MHCC. 

8 MR. LUBLINER: Yeah, I totally respect 

9 that. If it's not appropriate, I'll withdraw the 

10 question. I was thinking one of the comments 

11 made the other day by Mark Weiss was better 

12 communications with HUD. When Mr. Mendlen has 

13 come over, I thought that information would be 

14 useful for the group. 

15 But I respect that totally. Thank you. 

16 MR. RAMIREZ: All right. Thank you. 

17 Mark? 

18 MR. LEVY: This is Emanuel. 

19 Lowell, I wanted to take a shot at 

20 answering your question. 

21 MR. RAMIREZ: Go ahead, Emanuel. 

22 MR. LEVY: Okay. In the IECC, I'm 
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1 looking at the '09. I'm not sure if the '12 is 

2 worded exactly the same way. You have two 

3 options for verifying duct tightness. The first 

4 is a post-construction test. And I'm assuming, 

5 because of when the homes would be tested, that 

6 that would be more relevant to our case. 

7 In that case, it says, "Total leakage 

8 shall be less than or equal to four CFM of 

9 conditioned floor area when tested at a pressure 

10 differential," et cetera. "All register boots 

11 shall be taped or otherwise sealed under this 

12 test." 

13 So that's an option -- that's option one 

14 that would be available to builders. 

15 There's a second test, as you said, 

16 during rough-in, which I didn't bother to consult 

17 because I thought the point at which they would 

18 be tested in the plant would be more analogous to 

19 post-construction testing. 

20 MR. RAMIREZ: Okay. 

21 MR. UNGER: I'm not sure that answers. I 

22 assume that would typically be with an air 
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1 handler. And so, that you're recommending that 

2 in that case -- and I don't know which is more 

3 difficult for manufactured homes. But in 

4 essence, you're recommending six rather than four 

5 CFM. And I wasn't sure why what you were 

6 recommending would not follow IECC in this case. 

7 [Pause.] 

8 MR. LEVY: Yeah. That's right. To be 

9 consistent with IECC, would be four at the upper 

10 limit. 

11 MR. ROY: This is Robin. Do we have a 

12 sense of what the energy implications of six 

13 versus four are? 

14 [Pause.] 

15 MR. WEISS: Well, that kind of verges 

16 into my question. The first one is, just to 

17 clarify, I mean, the testing would be a new 

18 requirement. Is that right? Is that correct, 

19 Emanuel? 

20 MR. LEVY: Yes. I think many of the 

21 manufacturers already do testing. 

22 MR. WEISS: Okay. 
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1 MR. LEVY: I don't think it's mandatory, 

2 but I would defer to the manufacturers on that. 

3 MR. WEISS: Okay. So it would be a new 

4 mandatory requirement. 

5 And the next question is to the meat of 

6 it. Why four? Why not two, three, one, six, 

7 ten? Is this four just to be consistent with 

8 IECC, or is there some other rationale behind 

9 that number? And have the cost implications of 

10 four versus some other number been considered 

11 already, or is that something that's pending? 

12 MR. LEVY: My take on that is that four 

13 is one of those things that has come out of 

14 practice as to what is possible on a routine 

15 basis to achieve, with good sealing measures. 

16 It's probably not easily cost 

17 quantifiable or cost-benefit quantifiable because 

18 it's difficult to put your finger on what the 

19 cost would be for any one building to achieve one 

20 number versus another. 

21 So I think this is one of those more 

22 professional judgmental issues than anything 
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1 else. 

2 MR. WEISS: Okay. And I mean, you can 

3 understand my concern. Just because something is 

4 possible doesn't mean it's cost effective. It 

5 could involve significant costs. It's not 

6 necessarily worth it. 

7 MR. LEVY: It could. And just to answer 

8 your question, I don't think we will really know 

9 how difficult this is on a routine basis until 

10 it's administered in the plans and required for 

11 compliance. 

12 MR. WEISS: That sounds like you don't 

13 know what's in it till you read it, I don't know, 

14 till we pass it, rather. 

15 MR. LEVY: Well, perhaps some of the 

16 manufacturers can speak to it, who have done this 

17 testing, can speak to that as an issue. But -- 

18 MR. WEISS: That's fine. I appreciate 

19 your answer. Thanks. 

20 MR. LEVY: Yep. 

21 MR. SANTANA: Can we scroll up a little 

22 bit to the comparison of the duct leakage from 
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1 the HUD? This is Manny, by the way. From the 

2 HUD to the -- you know, so when you look at this 

3 chart, in table 1, you see that the IECC kind of 

4 went through a progression. They went from 

5 nothing to eight to four to four. 

6 And I think that reinforces what Emanuel 

7 said, that it was, kind of learn what you can do 

8 as you go along. 

9 You know, as far as what we've been able 

10 to achieve with testing, I haven't been able to 

11 gather up enough evidence to have anything 

12 concrete to show, that illustrates a trend. But 

13 I'd be a proponent to also have a kind of a 

14 tiered approach, similar to what the IECC did. 

15 You know, what do you guys think about starting 

16 with eight and then seeing how that goes before 

17 we just jump right into four? 

18 MR. LUBLINER: This is Mike Lubliner. I 

19 could comment on my feeling on that. 

20 I'm not real keen on that. My 

21 understanding -- and I'd like the manufacturers 

22 to provide feedback, if they would -- is that the 
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1 reason that the manufacturers, part of the reason 

2 the manufacturers are testing voluntarily their 

3 ductwork, particularly in the hot, humid 

4 climates, is to avoid callbacks and potential 

5 moisture litigation due to a number of things. 

6 And so that there's some economic benefit 

7 of doing this, to them, regardless of energy 

8 savings. And this is in response to Mark's 

9 comment about hidden costs. There's also hidden 

10 savings. 

11 I'd like the manufacturers, if they're 

12 willing, to explain why they are currently 

13 testing for ducts and whether or not it's 

14 benefiting them on the moisture and callback 

15 issue, as well as their experience testing ducts, 

16 which I understand is a requirement for ENERGY 

17 STAR. 

18 There's been thousands and thousands of 

19 ENERGY STAR homes built by this industry. So I'm 

20 assuming that there is some experiencing testing 

21 these ducts in the factory. 

22 Emanuel, I'd love to get your perspective 
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1 as well, because I know you've looked at the 

2 implications of moisture issues in supply duct 

3 leakage in hot, humid climates. Thank you. 

4 MR. SANTANA: Yeah, this is Manny again. 

5 And I could answer, I guess, to a degree 

6 just -- and this is just on the personal basis 

7 with the knowledge that I have. It doesn't speak 

8 to the industry as a whole. 

9 But the answer to that is that it really 

10 does depend on the region. You know, certain 

11 parts of the country where it's hot and wet, you 

12 know, hot and humid are really susceptible to 

13 having moisture issues in the house. And those 

14 plans, in order to -- you know, exactly what Mike 

15 said. 

16 In order to combat service calls and 

17 those kinds of issues, you know, they found that 

18 even in their ducts and having tight ducts helps 

19 to mitigate that. You know, we have some other 

20 plants in areas where it's dry that don't have to 

21 worry about that. 

22 So I really -- you know, it comes back 
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1 to, you know, building what's required for your 

2 area. It isn't an issue throughout the entire 

3 country. So some plants do it, and some plants 

4 don't. You know, it's a good idea to have a 

5 tight duct. That goes without saying. But just 

6 the level of which is what I'm talking about. 

7 MR. RAMIREZ: Okay. 

8 MR. EZZO: It's Mark at Clayton Homes. 

9 I agree with what Manny said. We do the 

10 same thing. We have a lot of plants that do an 

11 awful lot of duct testing. And, Mike, to your 

12 question, it's primarily to fix some of the 

13 problems that we've had mainly in the hot, humid 

14 climates. But we have carried that to a lot of 

15 facilities that are in other parts of the country 

16 as well. 

17 But I do agree with what Manny suggested 

18 about a tier approach. Just starting off and 

19 going all the way down to four right out of the 

20 gate for an industry that's never required this, 

21 I think that's a pretty big leap. 

22 I'm not saying it can't be done, and I'm 
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1 not saying that it's impossible to do. But I 

2 think our proposal, which is to start at six -- 

3 is it six, Emanuel? 

4 MR. LEVY: Well, it's four without the 

5 air handler, and six with air handler. 

6 MR. EZZO: Six with air handler? 

7 MR. LEVY: Yep. 

8 MR. EZZO: I think that's a pretty fair 

9 compromise. 

10 MR. ROY: It's Robin. 

11 Mark, that sounds sensible to me, too. 

12 But I'm curious. I am curious what we're giving 

13 up in terms of energy. I like the idea of 

14 staging down, but I'd also like to know what 

15 we're giving up and how important it is to ever 

16 get to four, in fact, if it's even worth leaving 

17 it at six. 

18 MR. LEVY: Robin, I can't answer that 

19 because I have no idea. 

20 MR. ROY: No, I'm looking over at Joe 

21 still to see if they've done that analysis. 

22 MR. LEVY: Oh, okay. 
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1 MR. ROY: Have you done that energy 

2 analysis? 

3 MR. HAGERMAN: We just pulled up the 

4 numbers and we looked through it. It looked like 

5 there's max, depending on the climate zone and 

6 everything, two KBTU's per square foot per year. 

7 So in my opinion, it's not widely significant. 

8 But you'd have to come up with your own 

9 conclusions. 

10 MR. ROY: Thanks for that. 

11 MR. HAGERMAN: Going from eight to four. 

12 MR. LUBLINER: And what is two KBTU 

13 relative to the total per square foot? 

14 [Pause.] 

15 MR. BARBOUR: This is Ed Barbour. Yeah, 

16 anywhere from 10 percent in the Southern climate 

17 zones to -- 

18 MR. LUBLINER: Two percent? 

19 MR. BARBOUR: Two percent in the Northern 

20 climate zones. 

21 MR. UNGER: This is Lowell. Ten percent 

22 for one measure sounds like a lot to me. 
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1 MR. BARBOUR: That's of the total annual. 

2 I mean, approximately if you do two -- ballpark. 

3 Keeping in mind that there's multiple measures 

4 still called in there. So we're just kind of 

5 trying to eyeball what it is. 

6 MR. UNGER: Yeah, the total is 28. 

7 MR. BARBOUR: Yeah, I understand. So two 

8 would be -- if it's 24, about 10 percent. 

9 MR. LUBLINER: So, not so significant in 

10 the North, but fairly -- quite significant in the 

11 South is what your eyeball is telling you? 

12 MR. BARBOUR: Based on the eyeball test, 

13 yeah. 

14 MR. LUBLINER: Right. 

15 [Cross-talk.] 

16 MR. RAMIREZ: Let me get Eric, then Mark. 

17 MR. LACEY: All right. Thanks. This is 

18 Eric. 

19 One of the questions that I was thinking 

20 about for so long that I totally forgot what it 

21 was. Can you come back to me? 

22 [Laughter.] 
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1 MR. RAMIREZ: No problem. 

2 Mark? 

3 MR. WEISS: Yeah, Eric, I've been there, 

4 too. 

5 [Laughter.] 

6 MR. WEISS: And it gets worse as you get 

7 older, believe me. Mark Weiss, MHARR. 

8 Just a point. I mean, if some folks are 

9 doing this already, it would seem to me that 

10 there must be some way to get some relative cost 

11 information related to this rather than just 

12 relying on, you know, luck and hope and, you 

13 know, see what we find out in the future. 

14 MR. RAMIREZ: Okay. Eric, are you ready? 

15 MR. LACEY: Yeah, it came back. Thanks. 

16 MR. RAMIREZ: Okay. 

17 MR. LACEY: Sorry. I wasn't planning on 

18 talking this much. 

19 One other question. And I'm not sure if 

20 folks realize this. But the duct testing 

21 requirement actually, in some way it's got a 

22 little less efficient or a little less stringent 
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1 in 2015 in the IECC. And it's not really 

2 reflected up there. 

3 Even though the tested leakage level is 

4 the same at four CFM, it was turned from a 

5 mandatory level to a prescriptive level. 

6 What that means is, if you don't think 

7 you can routinely hit four, or if when you test 

8 it, it doesn't hit four, you can trade that off. 

9 So if you're concerned about whether you can hit 

10 whatever level this group sets, you know, I don't 

11 know where you'll end up on that. 

12 But if it's just, you know, a little bit 

13 too tight or something, you can make up for that 

14 energy savings in another way, in the thermal 

15 envelope or somewhere else. 

16 You know, in the 2012 IECC, you 

17 absolutely had to hit that level and there was no 

18 exception to it unless you had all the ducts 

19 inside conditioned space. In 2015, that 

20 mandatory designation was removed so that you 

21 could trade off. Even though the standard level 

22 was set at four, you could make up for that 
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1 somewhere else if you failed. 

2 I just wanted to clarify. 

3 MR. LEVY: Eric, yeah, the danger of 

4 that, of course, is that you don't know what 

5 you're going to hit until you build a home. 

6 And if you want to do what you're 

7 suggesting, which is to be ultra-conservative and 

8 say, "All right, I assume I'll get to a six or an 

9 eight because I'm pretty sure I can do that 

10 routinely," then you're basically having to over11 insulate the rest of your building because you 

12 have this fear that you won't make the target for 

13 duct leakage. 

14 MR. LACEY: I think you're in a much more 

15 controlled environment in a manufacturing 

16 facility than you are in the stick-built onsite 

17 where every home is built, you know, from the 

18 ground up and it may be by different contractors 

19 and so on. 

20 I tend to think that the ducts would be 

21 more easily controlled and the quality control 

22 would be much better in a manufacturer. But I 
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1 can't comment on what the appropriate level of 

2 leakage should be. That's for you all. 

3 MR. HAGERMAN: Let me clarify something I 

4 said -- Joe Hagerman. 

5 We re-eyeballed the data here just for 

6 better measures. And it looks like in Houston, 

7 it's two KBTU's per square foot per year, which 

8 is about 7 percent. Now, it's sort of hard to 

9 disaggregate specifically the number that you're 

10 talking about. So I would range it by saying 5 

11 to 7 percent. 

12 But that's going from eight to four. The 

13 proposal that Emanuel is talking about is six. 

14 So you're not quite all the way at eight, right? 

15 And what the code says is four, so you're not -- 

16 so you have to take that into account. So I'd 

17 say you're anywhere from 2.5 to 5 percent, in 

18 Houston, which would be worst-case. Use your own 

19 eyeballs. 

20 MR. LUBLINER: This is Mike Lubliner. 

21 MR. RAMIREZ: Yeah, Mike. 

22 MR. LUBLINER: Yeah. I think one of the 
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1 points to make when we're comparing it to the 

2 IECC is that the home that we're testing in final 

3 is complete when it's a site-built home. But we 

4 still have the cross-over duct or the rim joist 

5 leakage associated with a through-the-rim system. 

6 So when we're talking about this, we're 

7 really not talking about the final leakage of the 

8 home. We're just talking about the component 

9 that the manufacturer is building. And our 

10 experience is that a significant amount of 

11 leakage happens after the fact. So I think it's 

12 important that we remember that as we're 

13 comparing the site-built. 

14 Our program standards for ENERGY STAR 

15 NEEM program in the Northwest are 5 percent, I 

16 believe. And maybe that's an appropriate number. 

17 If we go ahead and come up with a factor for the 

18 furnace testing, you know, I think we can work in 

19 this. 

20 But the bottom line is that if you use 

21 mastic and you have a good prescriptive 

22 procedure, you're going to find it is what it is. 
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1 And you're going to be periodically testing. 

2 And I think what you find if you were to 

3 do testing over and over and over is, the 

4 variability is going to be there for -- it could 

5 be between three and six on any given day on any 

6 given house. So we need to be a little clear on 

7 understanding this. 

8 I'm very comfortable, if there was a 

9 commitment from DOE that they're going to do some 

10 evaluation if this code gets adopted of what the 

11 leakage is in the factory and adjust it 

12 accordingly, based on what we find. So I'd 

13 rather start with a conservative number like 4 or 

14 5 percent. And then if they find that we can't 

15 get there, we can make some provisions down the 

16 road. 

17 But I guess I would like to get a better 

18 handle. If the manufacturers say 5 or 4 percent 

19 isn't going to cut it, 5 percent without the 

20 furnace, then we're going to have to work through 

21 our differences here. 

22 Sorry for the ramble. Thank you. 
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1 MR. RAMIREZ: Mark? 

2 MR. WEISS: Yeah, a few questions. 

3 Joe, you said Houston was worst-case. 

4 Why is Houston worst-case? Because of the 

5 humidity? So in different climates, the impact 

6 is going to be different, correct? 

7 Okay. So my question, first to Emanuel, 

8 is the four figure for the IECC, that's across 

9 all zones; is that correct? 

10 MR. LEVY: That's correct. 

11 MR. WEISS: Okay. Is this something that 

12 perhaps -- and I'm just putting this out there, 

13 as a nontechnical person. Is this something that 

14 perhaps we should be looking at in terms of 

15 different zones in that ultimate discussion? 

16 Should it be different for different zones, or is 

17 that just too much of a hassle to -- okay. 

18 MR. LEVY: Well, and it probably is 

19 easier for plants to develop standard protocol 

20 for installation of duct systems to achieve a 

21 certain target and not have to worry about where 

22 the home is going. 
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1 MR. WEISS: All right. I understand. 

2 MR. LUBLINER: This is Mike Lubliner. 

3 One minor comment I'd like to make. 

4 And that's a question to Joe. Joe, when 

5 this modeling was done, this all assumes all the 

6 ductwork is in the belly. None of it, in other 

7 words, there's no modeling that I saw where it 

8 assumed ducts in the attic. 

9 And that's really the area, when there's 

10 duct leakage in the attic, that you really get 

11 into significant higher energy savings by sealing 

12 the ducts, relative. 

13 So I think the modeling -- the numbers 

14 you're coming up with are reflective and probably 

15 accurate for that scenario where the ducts are in 

16 the floor. I'm trying to get a sense of if 

17 that's going to give us a story when the ducts 

18 are in the attic. Maybe there's not a lot of 

19 homes out here with ducts in the attic, and maybe 

20 I should just not worry about it. 

21 I'd like to get some input from you on 

22 the analysis, and the manufacturers on the 
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1 prevalence of ducts in attics versus floors, and 

2 the adequacy of modeling it only as a floor 

3 system. 

4 MR. RAMIREZ: So, it looks like we need 

5 to -- sorry, Emanuel. You did some great work 

6 here. But it looks like you're probably going to 

7 have to do a little bit of cleanup based on some 

8 of the discussion that we had here, and also that 

9 the working group needs to look at the test 

10 procedures to see if they're okay with that as 

11 well. There's quite a bit there. 

12 And then, Lowell, you have a comment? Go 

13 ahead. 

14 MR. UNGER: Just one more. I mean, so 

15 what I've understood, I think, from this 

16 discussion is that the IECC four is actually 

17 including an air handler. And so the equivalent 

18 number for your typical manufactured house would 

19 actually be more like three without the air 

20 handler, in terms of what would be comparable to 

21 IECC 2015. 

22 I also haven't heard any reason why 
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1 that's not achievable. What I heard was that, 

2 for manufacturers that haven't been doing this, 

3 there may be a learning period to get there, 

4 which suggests to me that, you know, if that's 

5 the issue, that one should set a low standard, 

6 but then either ratchet it in, a little higher 

7 standard the first year or an exception the first 

8 year or something, something which allows for a 

9 period of learning, but with still the lower 

10 ultimate standard. Thanks. 

11 MS. HOFFMAN: We've got a request from 

12 some of our folks on line for a one function 

13 break. So let's come back in 10 minutes. Thank 

14 you. So it's three o'clock. Come back at three. 

15 Thank you. 

16 [Recess taken from 2:42 to 3:01 p.m.] 

17 MR. RAMIREZ: All right. Let's go ahead 

18 and get started. 

19 And we left off with trying to do a quick 

20 little summary of where we're at on some of the 

21 items here under the duct leakage. And I think 

22 Lowell, trying to summarize it for us, basically 
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1 we're looking at the possibility of a step-in to 

2 allow for a learning curve for the manufacturers. 

3 Those numbers or time hasn't been 

4 tightened up. But either way, based on some of 

5 the discussion that we had, it looks like, 

6 Emanuel, I really appreciate all your hard work. 

7 If I could impose on you a little bit more just 

8 to help clean up some of the areas that the group 

9 spoke of, that would be greatly appreciated. 

10 Are you okay with that, Emanuel? 

11 MR. LEVY: Yeah, of course. 

12 MR. RAMIREZ: Okay. Thank you. 

13 And then, on the other two pieces, on the 

14 duct leakage and test procedures, as well as the 

15 compliance piece, those two areas, although those 

16 could be, you know, recommendations that go to 

17 ASRAC, fall outside of the scope of this working 

18 group. And so at this time, is everyone okay 

19 with setting those aside? 

20 Hopefully, we show them how functional we 

21 are and we end up with a great term sheet, and 

22 they say, "You know what? Keep going at it, and 
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1 deal with the compliance piece." But if we do, 

2 then that's the time when we'll discuss those 

3 items in greater detail. 

4 MR. HAGERMAN: This is Joe Hagerman, DOE. 

5 I've always made the point to say when we 

6 put that final term sheet together, I think that 

7 it's going to include also a -- I would 

8 hypothesize it would include a memo that this 

9 committee writes that says, "This committee also, 

10 you know, wants to make some other 

11 recommendations to ASRAC, as DOE has to put forth 

12 an enforcement and compliance rule as well," 

13 right. 

14 But just to be clear, the enforcement and 

15 compliance is outside the scope of the current 

16 charter. So I say we don't discuss that, just in 

17 time's sake. We don't discuss it. And if the 

18 group wants to add this to the memo, then you 

19 approach it that way. 

20 MR. RAMIREZ: Is everyone okay with that? 

21 [Pause.] 

22 MR. RAMIREZ: Okay. Hearing no 
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1 objections -- sorry. 

2 MR. LEVY: Javier, it's Emanuel. 

3 Just let me add that the duct leakage 

4 procedures and the compliance and the 

5 requirements are kind of all of a piece. You 

6 know, the requirements make sense if you do this 

7 kind of -- if you run this kind of test, and this 

8 is the way you would evaluate that number. 

9 And the compliance piece is a part of 

10 that because it has to do with how the industry 

11 itself conforms to meeting that requirement. 

12 So I really hear what you're saying about 

13 it has to be handled a particular way from a 

14 bookkeeping standpoint, or a presentation 

15 standpoint. But I'd hate to see this go out and 

16 not include all those pieces of it in some 

17 fashion. 

18 MR. HAGERMAN: This is Joe Hagerman. 

19 I agree. I mean, the test procedure and 

20 the enforcement, you know, are essential to 

21 getting a good standard, right? The standard is 

22 only as good as the test procedure and 
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1 enforcement. 

2 That's why I don't think we lose it. We 

3 just add it to the memo and then let ASRAC 

4 decide. It's my hope that ASRAC would extend 

5 this working group if the members, you know, feel 

6 interest in that. So this group could start 

7 dealing with enforcement and compliance after we 

8 deal with the standards. 

9 MR. LEVY: So, are you saying, Joe, that 

10 we should not talk any more about those pieces at 

11 this point? 

12 MR. RAMIREZ: Yeah. We'll set those 

13 aside, and those go into the recommendation, 

14 along with what we ultimately agree upon for the 

15 duct leakage requirements that you've set up 

16 here. 

17 MR. LEVY: Okay. Yeah. 

18 MR. RAMIREZ: Sound all right? 

19 MR. LEVY: Good. 

20 MS. HOFFMAN: Eileen Hoffman. 

21 They're not lost. They'll be appended, 

22 perhaps, to a recommendation, but they'll be 
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1 there, but not formally discussed at this moment. 

2 MR. RAMIREZ: Okay. So then, move on to 

3 whole-house leakage? 

4 MR. LEVY: Yep. 

5 MR. RAMIREZ: Okay, Emanuel. You're on 

6 again. 

7 MR. LEVY: All right. So we know the 

8 routine already. We're just talking about how 

9 much leakage is allowed from the entire house 

10 when tested with something like a blower door. 

11 And here you can see, from this survey of 

12 current requirements, what the history has been 

13 in terms of HUD code. There is no specific 

14 requirements in the IECC, which in the '09 

15 version started out with a target of 7/8th ACH 

16 added pressure difference of 50 Pascals and has 

17 now been modified for the '12 and '15 versions to 

18 five and three, respectively, for zones 1, 2, and 

19 3 through 8. 

20 So that's the starting point. And again, 

21 we can just actually go right down to -- we can 

22 stop here at any point you want. But I was just 
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1 going to say here, for the testing -- and this is 

2 the essence of what the proposal is -- is kind of 

3 in the same vein as our discussion about the duct 

4 leakage. 

5 It's kind of a phase-in, for a couple of 

6 reasons. For the manufacturers, to seven and 

7 five, seven being for zone 1 and five for zones 2 

8 and 3, these are obviously above where the 

9 current IECC. 

10 And the idea would be that this would, 

11 again, give the industry a chance to figure out 

12 how they are going to meet these standards and 

13 give them some insight into how they're going to 

14 meet more stringent standards in the future. 

15 The rough part about this one, maybe even 

16 harder than the ducts, is that single sections 

17 are one challenge to do that. Because this is 

18 being done in the plant. It's not being done in 

19 the field. 

20 But multi-sections are even a bit more of 

21 a challenge because it means that the plant would 

22 have to do something they don't typically do, 
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1 which is to put both halves, if there are only 

2 two halves, there are all the pieces together of 

3 a home on a temporary basis to test it. 

4 And that means they have to seal it up 

5 analogous to how it would be sealed up on the 

6 site. That could be a very time-consuming 

7 process. And we don't know exactly how that will 

8 turn out. 

9 There's been some limited testing in 

10 plants, but it's not nearly enough to know what 

11 the track record would be here. So we're kind of 

12 tiptoeing into this one a little bit. And I 

13 think we need some experience before we're 

14 confident that these levels or something lower 

15 than these levels are practical. 

16 Again, there are other pieces associated 

17 with this, a visual inspection, which would be 

18 additional prescriptive things that we know that 

19 are routine areas of potential leakage that would 

20 be addressed. So all these would be prescriptive 

21 requirements. 

22 And then, of course, as with the ducts, 
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1 there would be a testing procedure and a 

2 compliance sampling procedure. But it sounds 

3 like we're just confining our comments for the 

4 moment to section A at the top. 

5 Let me stop there. 

6 MR. ROY: This is Robin. A quick 

7 question for Joe, again. 

8 Do you have a rough sense of what the 

9 energy implications of different home leakage 

10 are, just the same eyeball test? 

11 MR. HAGERMAN: We'll put our eyeballs to 

12 it. 

13 [Laughter.] 

14 MR. RAMIREZ: They're coming up with the 

15 SWAG number? Scientific wild-ass guess. 

16 Mark? 

17 MR. WEISS: Just real quick, what's the 

18 parallel IECC provision? I see something -- I'm 

19 sorry. I turned the page. 403.6 about 

20 mechanical ventilation, but where are you getting 

21 the five and the three from? 

22 MR. LEVY: It's the -- and I'm looking 
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1 right at it, Mark. It comes out of the IECC. 

2 [Cross-talk.] 

3 MR. EZZO: Mark, it's 402.4, Air Leakage, 

4 on page R-33. 

5 MR. WEISS: Okay, thanks. 

6 MR. LUBLINER: This is Mike Lubliner. 

7 Question for Emanuel. 

8 Why is it that it's harder to, or you 

9 have more concern about, building to five ACH 50 

10 in climate zones 2 and 3 than 1? 

11 MR. LEVY: Is that a question for the 

12 IECC? 

13 MR. LUBLINER: Well, I'm just -- well, 

14 you were talking about -- you know, the IECC, I 

15 think, has five and three in it. And I had 

16 proposed five for everywhere, and I think just 

17 kind of as a compromise. And what I was seeing 

18 here was seven and five. 

19 And I'm just wondering, you know, from a 

20 physics standpoint, you build a house. You build 

21 it so tight. Is there a reason that it won't be 

22 as tight if you build it in climate zone 1? What 
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1 was driving the distinction? 

2 I was kind of hoping we could just leave 

3 it at five everywhere, and maybe a provision that 

4 if we find that's too -- not achievable, that 

5 those could be addressed in the future by DOE. 

6 I would think that, in the first couple 

7 of years -- and this will, obviously, get 

8 synergy, of course, by the compliance side, that 

9 DOE will be looking at this as a learning 

10 experience and not being vindictive in the way 

11 that they enforce this if it's a good-faith 

12 effort to meet the prescriptive path and you just 

13 happen don't get to the five. 

14 What we do in the site build codes in 

15 Washington State is we required the blower test, 

16 but we don't red-tag them if they don't pass. We 

17 explore the root cause and fix it. Thank you. 

18 MR. LEVY: Well, I'm sure, in part, the 

19 root cause is one of energy. I mean, seven is 

20 the ENERGY STAR standard right now. And in the 

21 South, you know, you pay less of a penalty 

22 energy-wise for a little more air leakage. 
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1 So the seven is right now for what's 

2 being built a step up. But the five reflects the 

3 fact that those air changes are a little more 

4 precious from an energy standpoint in the North. 

5 MR. RAMIREZ: Emanuel, what do you think 

6 of that? 

7 [Pause.] 

8 MR. LEVY: Javier, was that question 

9 directed at me? 

10 MR. RAMIREZ: Yeah. 

11 MR. LEVY: Did you hear my answer? 

12 MS. HOFFMAN: That was his answer. That 

13 was Emanuel. 

14 MR. LUBLINER: I think she was directing 

15 that at me, Emanuel, and see if I was satisfied. 

16 Yeah, I appreciate that. So it's really being 

17 driven by your assumption of this energy savings, 

18 not the technical feasibility of building to a 

19 tightness level. 

20 There shouldn't be any distinction 

21 whether you're building in zone 1 or zone 3 in 

22 terms of its technical feasibility of getting 
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1 there. It more was driven by your assumption 

2 that you don't save as much from going to the 

3 tighter level in the warmer climate. Is that 

4 right? 

5 MR. LEVY: Well, in effect, that's 

6 correct. We're in effect asking plants to go 

7 through more gymnastics or more careful procedure 

8 of sealing, recognizing that we're doing that 

9 mainly for an energy benefit. 

10 And that it's going to be a bit of a 

11 challenge to do that anywhere because, as you 

12 recognized doing that in the Northwest, because 

13 you're, you know, artificially putting together a 

14 home just for the purposes of testing. So you 

15 already have quite a hump to get over, you know, 

16 to reach that level within the plant. 

17 So it's kind of what is reasonable, given 

18 all the factors involved. And ultimately, this 

19 is a judgment call as much as a cost-benefit 

20 call. 

21 MR. LUBLINER: Thank you. I think that 

22 answered my question. I think that the criteria 
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1 in the Northwest is less than five for our ENERGY 

2 STAR homes program, and I can provide that 

3 information back. Thank you. 

4 MR. LACEY: This is Eric. Just some 

5 clarifying questions, Emanuel. 

6 I want to make sure I understand this 

7 correctly. You're saying that you either test or 

8 get a visual inspection. There's two options. 

9 You're not necessarily requiring that every home 

10 be tested. And even if you take the testing 

11 option, there's some kind of sampling protocol. 

12 Is that the intent here? 

13 MR. LEVY: That's the intent, yep. 

14 MR. LACEY: Okay. So the intent is that 

15 if you wanted to avoid the test entirely, you 

16 could just do a visual inspection. 

17 And then I guess my follow-up question 

18 is, I know that our prescriptive requirements or 

19 mandatory requirements subgroup has been working 

20 on the thermal envelope requirements and the 

21 specific list of insulation and installation 

22 measures. 
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1 And I'm wondering if there's some 

2 duplication here with your visual inspection, and 

3 if we could combine the two. I mean, I guess 

4 maybe that's something that we can work out 

5 later. But I just wanted to make sure. 

6 What you're showing here is an approach 

7 more like the 2009 IECC, where you or a code 

8 official or somebody would inspect them. In this 

9 case, it would be one of the manufacturer's 

10 internal folks doing just a visual inspection, 

11 looking at specific spots, rather than testing 

12 every home. 

13 MR. LEVY: Yes, I agree. And I think we 

14 ought to put those pieces together to make sure 

15 they're not in two places. 

16 MR. SANTANA: You know, I will add, if I 

17 can -- this is Manny -- that there's going to be 

18 a lot more than just the plant personnel with 

19 their own quality control. You know, you've got 

20 third parties, as well as government third 

21 parties, that go and conduct these kinds of 

22 inspections. 
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1 So it's quite a bit when you talk about 

2 the inspections that are going to be done. And I 

3 think it's a good approach to have. 

4 MR. RAMIREZ: Okay. Let me get Lowell. 

5 But for the folks that are on line, we need for 

6 you to identify yourself for the Court Reporter 

7 before you speak. 

8 Lowell? 

9 MR. UNGER: Thanks. So, if this is an 

10 either-or, that the visual can be instead of 

11 testing, let me ask again. Where did this list 

12 of visual prescriptive measures come from? 

13 MR. LEVY: This has been, Lowell, kind of 

14 the result of -- it's partly the result of years 

15 of having worked with the industry on identifying 

16 techniques that are effective at keeping leakage 

17 at the lowest possible levels. So it partly 

18 comes from our experience; it partly comes from 

19 ENERGY STAR. It's sort of a conglomeration of 

20 different sources here. 

21 But we thought this was a pretty good 

22 list of the items that are essential to make sure 
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1 that the home is tight. And there are a couple 

2 of others. 

3 MR. UNGER: And is there testing 

4 experienced with people trying to implement a 

5 list similar to this? I understand it may not be 

6 exactly the same as to what kind of leakage one 

7 typically can achieve through the prescriptive 

8 measures? 

9 MR. LEVY: Yeah. We have tested homes 

10 under ENERGY STAR. We have 500 or so homes out 

11 in the field which we've tested. And we have had 

12 good results from those homes. And that's part 

13 of what this is predicated on. 

14 Again, those are out in the field; 

15 they're not in the plant. But it should be 

16 harder to reach these goals in the field. 

17 So, this information is borrowed from a 

18 number of different studies and efforts that 

19 we've done. It wouldn't be a bad thing to build 

20 a bunch of homes in the plant, using these 

21 prescriptions, and test them, you know, 

22 specifically for this effort if we have the 
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1 luxury of doing that. 

2 So, again, what this represents is our 

3 best experience thus far as to how best to seal 

4 homes for leakage. 

5 MR. UNGER: So you're saying that your 

6 experience is that you can get, I think you said 

7 ENERGY STAR is seven, and that you can achieve 

8 that in the field through these measures? 

9 MR. LEVY: That's right. And, you know, 

10 with the testing we have done in the plant, and 

11 Michael maybe have some experience here, too, has 

12 been pretty compelling in terms of the homes 

13 being very tight. In fact, I think one of the 

14 issues often is that homes are so tight that we 

15 really need to start looking at some ventilation 

16 strategies that provide for more air change. 

17 But you know, because of the materials 

18 and the products that are used in the plant 

19 today, the homes tend to be extremely tight to 

20 begin with. And these are the areas that could 

21 more readily not be routine or slip through the 

22 cracks. 
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1 MR. LUBLINER: This is Mike Lubliner. 

2 My experience -- 

3 MR. POTTS: This is Richard Potts, 

4 Emanuel. 

5 MR. RAMIREZ: I'm sorry. Go ahead, 

6 Michael. 

7 MR. LUBLINER: I was going to say our 

8 experience in the Northwest is that five in the 

9 field is achievable if you stick to a 

10 prescriptive option and the plants are engaged in 

11 implementing a quality assurance plan, 

12 specifically, what things need to be caulked, 

13 when, with what material, and who inspects. 

14 You can get to five readily. I think 

15 that's something that we should really be 

16 thinking about, that because our ENERGY STAR 

17 experience is suggesting that you're able to 

18 achieve that, on average, out in the field, from 

19 random testing of homes. 

20 So it may be a little tougher with 

21 single-section homes because it's an air change 

22 metric, which means that the volume is a little 
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1 tougher. We might be exploring flexibility. 

2 Maybe we shouldn't be looking at air change at 50 

3 Pascals. Maybe we should be looking at the 

4 leakage area per foot or something. 

5 But I do think that we really need to 

6 consider that five is achievable. That's what 

7 we're seeing, not in the factory, but actually in 

8 the field, from random testing. And our 

9 specifications have ramped down over the years 

10 from seven down to five. And actually, in our 

11 test homes without ductwork, we're down as low as 

12 three. 

13 I do agree that the homes need mechanical 

14 ventilation, and I believe that there's a HUD 

15 requirement for that mechanical ventilation 

16 attempted. And it's been in the HUD code since 

17 '94. So I think that we're on our way to 

18 ventilating right. And I'm just trying to define 

19 what "build tight" is. 

20 Our motto is, "Build tight, ventilate 

21 right." And we need to define what "tight" is 

22 here. 
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1 MR. LEVY: This is Emanuel. 

2 Mike, I just want to say that your 

3 experience, you know, having had experience over 

4 the years of doing this, is the kind of thing 

5 that we're talking about emulating here. Where 

6 in other parts of the country hasn't had the 

7 benefit of those years of experience, this would 

8 be an opportunity to move the industry towards 

9 the kinds of things you're doing in the 

10 Northwest. 

11 MR. LUBLINER: I agree. Thank you. 

12 MR. RAMIREZ: Was there somebody else on 

13 line that wanted to chime in? Richard? 

14 MR. POTTS: Yeah, this is Richard Potts. 

15 Can you hear me? 

16 MR. RAMIREZ: Yeah. 

17 MR. POTTS: Okay. So have we -- maybe 

18 I'm jumping ahead. You know, we were talking a 

19 little bit about mechanical ventilation. Is this 

20 section correlating with the mechanical 

21 ventilation requirements of, you know, requiring 

22 either whole house or some sort of mechanical 
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1 ventilation? I believe it's under five air 

2 changes. And if not, definitely something that 

3 we're going to have to deal with. 

4 And earlier in the meeting, we had 

5 mentioned cross references. And in the IECC, the 

6 residential code is referenced for mechanical 

7 ventilation. So it's another thing that we'll 

8 have to make sure that we're, I guess, cross 

9 referencing and making sure that we get the 

10 correct information and not miss anything that's 

11 required. 

12 Another part of my question is, 

13 basically, you know, what is involved with 

14 testing multiple sections time-wise? I mean, are 

15 we talking about -- you know, it seems like a 

16 daunting undertaking. So I'd just like to get an 

17 idea. 

18 I'm trying to imagine. I've done factory 

19 audits for the states. And I know how the 

20 assembly is set up. I'm just trying to visualize 

21 the testing procedure if anybody can help me out 

22 with that. 
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1 [Pause.] 

2 MR. LEVY: Richard, let me take the first 

3 part of your question, and maybe one of the 

4 manufacturers who have done some testing will 

5 weigh in on the second part. 

6 I think the ventilation piece is part and 

7 parcel of leakage, related to leakage, as Mike 

8 Lubliner mentioned earlier. As far as I 

9 understand, it's on our PBD list to come up with 

10 a straw man for ventilation. So that will be a 

11 subject of probably the next meeting. We'll have 

12 something for the committee to look at. 

13 Do any of the manufacturers want to talk 

14 about, speak to the testing of homes in the plant 

15 for leakage? 

16 MR. RAMIREZ: Let me chime in right 

17 there. Because it sounds like that probably a 

18 little bit more education, where we could try and 

19 do some of that stuff off line. But I want to 

20 try and see if what we need to do on here to try 

21 to bring this to a conclusion or see if there's 

22 some more detailed questions on that. 
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1 Is everyone okay with -- 

2 MR. POTTS: This is Richard. There's a 

3 little bit behind that. You know, it's kind of 

4 maybe deciding whether some more so a visual 

5 inspection approach might be, I don't know, more 

6 cost effective. I mean, I know we're talking 

7 about testing a class of homes or sampling, and 

8 that's probably a good balanced approach. 

9 But I wouldn't consider it just 

10 educational. It might be good for the whole 

11 group if we're really trying to decide long-term 

12 strategies for testing. But it's up to you guys. 

13 MR. RAMIREZ: Are you trying to find out 

14 if it's labor intensive or costly? 

15 MR. POTTS: Exactly. You know, is it 

16 like a half-a-day to really set these things up 

17 and run your blower, go over testing? Or is it 

18 simple? They're right there, you know, you make 

19 the units together. They might get in the groove 

20 of things and it might only take an hour. I 

21 don't know. 

22 MR. RAMIREZ: Is there anybody that can 
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1 give an elevator response on that? 

2 MR. EZZO: This is Mark Ezzo, Clayton 

3 Homes. 

4 I don't have any experience with it. I 

5 mean, on the surface, it sounds -- and I would 

6 suspect it's a pretty labor-some and cumbersome 

7 process to take multi-section homes, take them 

8 out into the yard somewhere. I suppose there are 

9 some facilities that could do it in-plant. 

10 But putting them together, sealing them 

11 properly at all the connection points -- 

12 underneath, at the ends, at the top, at the ridge 

13 line -- and then performing, you know, the 

14 corresponding tests, we're talking about 

15 something that's pretty labor intensive. 

16 I'm not going to say I know how long it 

17 would take to do one or to do, you know, three a 

18 day or one a day or one a week. But I think it 

19 would be something that would be a fairly big 

20 burden on manufacturers to try to accomplish in 

21 the plant. 

22 MR. RAMIREZ: Let me go to Lois. I think 
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1 she probably wants to add something here. 

2 MS. STARKEY: Yeah. And also, it doesn't 

3 really achieve the objective. Because really, 

4 you're talking about ultimately siting the home 

5 and a consumer living in it. And that's when all 

6 the -- that's when you're concerned about how the 

7 house is performing. 

8 So the idea of doing it in the factory is 

9 just -- it just seems so infeasible and really 

10 not -- doesn't really meet the objective that 

11 you're trying to meet. 

12 MS. HOFFMAN: Quick question -- Eileen 

13 Hoffman. 

14 Is testing -- maybe just help me. 

15 Sampling, testing, inspection, is that part of 

16 compliance and enforcement? Or is that part of 

17 the charter of this committee for standards? 

18 Just so I know. 

19 MR. HAGERMAN: I mean, DOE's official 

20 position is it's not within the scope here of 

21 this working group. This working group can make 

22 recommendations to ASRAC. But that's a separate 
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1 rule. 

2 MS. HOFFMAN: I just meant discussing 

3 testing and sampling. That's out of the scope. 

4 MR. HAGERMAN: That's our understanding. 

5 MS. HOFFMAN: Okay. Okay. 

6 MR. HAGERMAN: That's our position. 

7 MS. HOFFMAN: So then, although it's very 

8 important, in the interest of time, perhaps it 

9 would be good to move on then. I see we have a 

10 number of folks commenting, though. 

11 MR. HAGERMAN: Just let me offer this up. 

12 So we've been eyeballing all this data. And it's 

13 a little bit hard to specifically pull out some 

14 of the impacts of these individual measures with 

15 the runs that we currently have, given that, you 

16 know, they just are what they are. 

17 So what I'm going to offer is, and I've 

18 been communicating with PNNL -- they can get us 

19 the results, we hope, by Friday -- to do some 

20 additional runs first on the solar heat gain 

21 issue. So I've already issued that to them. And 

22 then I'm going to ask them specifically to do 
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1 some models of this whole-house air leakage, and 

2 then also the duct leakage. 

3 So the duct leakage would be a six, four, 

4 and three; and the whole house would be seven, 

5 five, and three. So then by Friday we can see 

6 the annual results. And then you'll know the 

7 impacts. And then we'll just have to get the 

8 costs. So is that good enough for everybody? 

9 I hate to -- you know, today I've tried 

10 to say, let's try to make some decisions and not 

11 just kick the can down the road. But this is the 

12 one that I think we're going to have to kick it 

13 down a little bit to get you the analysis that 

14 you need to see. Because my eyeballs are getting 

15 tired. 

16 [Laughter.] 

17 MR. RAMIREZ: All right. Lowell, then 

18 Eric? 

19 MR. UNGAR: Take Eric, because his is an 

20 immediate response. 

21 MR. RAMIREZ: Okay. 

22 Go ahead, Eric. 
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1 MR. LACEY: Immediate, positive response? 

2 No, I guess just a general question about this. 

3 I'm really struggling to see what 

4 incentive a manufacturer would have to test any 

5 home for air leakage. Because if there's a 

6 visual inspection option that includes a handful 

7 of measures that are already probably going to be 

8 included in the air barrier and insulation 

9 installation table, which we're kind of working 

10 on right now, I'm still not seeing why you would 

11 ever test a home. 

12 I mean, regardless of what the air 

13 leakage number is, I think it's a good thing to 

14 know how much air leakage the home is getting, 

15 not only for energy efficiency, but also for 

16 sick-building issues and whether you need 

17 mechanical ventilation. 

18 And in the 2009 era of the IECC when you 

19 had a visual inspection, there was a bit of an 

20 incentive to still test, because you didn't want 

21 to wait on a code official to have to come in and 

22 do the visual inspection for you. You might as 
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1 well just get it tested, check the box, and move 

2 forward with production. 

3 I don't see that as being the same 

4 incentive-disincentive for a manufacturer, where 

5 you're probably just doing the testing or the 

6 visual inspection yourself. 

7 Does anybody have a sense, or Emanuel, is 

8 there any incentive here to actually do the test? 

9 Or is this intended to not be an incentive to do 

10 the test and push people towards just doing a 

11 visual inspection? 

12 MR. LEVY: Yeah, I can tell you my take 

13 on it, which would be the latter. If companies 

14 were routinely doing a whole list of things, 

15 which we know from experience results in a tight 

16 home, why would we want to make them test, and 

17 the cost and expenses associated with that? 

18 I do think there's a difference here 

19 between site-built and manufactured homes, where 

20 site-built runs the gamut, routinely, of 

21 different designs and level of quality 

22 construction. And it's done outside, and all 
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1 those other things that mean that there's high 

2 variability in how tight the homes are going to 

3 likely be. 

4 With the factory-built home, you know, 

5 from our experience, it's -- the band of 

6 tightness is much tighter. It's much more 

7 limited. And if companies routinely do certain 

8 things, and it's in their DAPI [phonetic] package 

9 and it's part of their routine construction, you 

10 can test them all day, yeah. But you're going to 

11 hit those marks very consistently. 

12 And if that's the case, and we can 

13 demonstrate that that's the case, why require 

14 testing that is just going to be costly? And 

15 frankly, in the case of whole-house testing, not 

16 entirely informative, because the home is going 

17 to be taken apart and shipped and set up again a 

18 second time. 

19 MR. LUBLINER: This is Mike Lubliner. 

20 I do think that there's value in testing 

21 from a feedback-loop standpoint, regardless of 

22 what level you're presently achieving. 
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1 To be clarified, there is a requirement 

2 for whole-house mechanical ventilation, installed 

3 capacity, in the HUD code since 1994, of 0.35 CFM 

4 per square foot. So we have a requirement 

5 already in the base case that these mechanical 

6 ventilation is in there regardless of how tight 

7 the home is. 

8 But what we find is that the benefit of 

9 testing is providing feedback periodically to the 

10 manufacturers to, "Oh, we have a QA issue with 

11 our P-trap." Or, "Oh, we're not doing this door. 

12 We're seeing daylight through the front-door 

13 weather stripping." It's that kind of feedback 

14 that you can get from the testing. 

15 And I think if you did a quarterly test 

16 of a cross section of homes, I don't know, 

17 single-wide homes do not have the problems that 

18 Mark Ezzo articulated, so I suggest we focus on 

19 constructive feedback from single-wides. 

20 But at a minimum, four times a year to do 

21 a blower test in the factory and pull a double22 wide together, if that's what you're building, I 
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1 don't think is that burdensome, and I think it 

2 provides an amazing amount of feedback to improve 

3 your quality assurance plan and ensure that 

4 you're meeting the metrics. 

5 That's my feeling on this. 

6 MR. LEVY: And Mike -- this is Emanuel -- 

7 I agree with you. And that was the intent of the 

8 compliance sampling procedure, section C. 

9 MR. RAMIREZ: Lowell? 

10 MR. UNGER: Yeah, first thing is, I think 

11 the last exchange has been very illuminating and 

12 helpful. 

13 It strikes me, one thing in Emanuel's 

14 argument, is that manufactured homes are 

15 different, is very interesting. I had understood 

16 from the discussion, I guess it was on the duct 

17 leakage, that there was a huge range and that 

18 there was no consistency. And if you did three, 

19 tested three homes, they're all going to be 

20 different. 

21 Is the whole-house leakage different? I 

22 mean, is the whole-house leakage very consistent, 
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1 but the duct leakage very inconsistent? 

2 MR. LEVY: You know, I would say the same 

3 thing goes for ducts, too. I think once -- and 

4 this is again why we had to be heavily biased 

5 toward the prescriptive measures. 

6 Once you do that and you check that, just 

7 like Mike has just described, on a routine basis, 

8 you know, once you set up those protocols and you 

9 have people doing things the same way every time 

10 at every home coming down the line, you're going 

11 to get fairly consistent results. 

12 And I know some of the manufacturers here 

13 have done some testing. I mean, it would be 

14 interesting to hear what their experience is. 

15 But I think the same can be said for ducts and 

16 whole-house. 

17 MR. LUBLINER: Mike Lubliner. I was just 

18 going to try to reply. 

19 We look at -- when we go out in the field 

20 to look at duct leakage and envelope leakage, we 

21 do a random sample from thousands of homes built 

22 under the program. And we get, you know, 30 to 
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1 100 homes. And we go out and we test them. So 

2 we get an average. We get a distribution and max 

3 them in. And we get a standard deviation. 

4 The standard deviation for the duct 

5 variability and the envelope variability are 

6 comparable. But I think exactly what Emanuel 

7 says is right, that if you do the periodic 

8 testing in the factory -- and we can argue how 

9 periodic that is or how that varies with your 

10 compliance -- you do learn from that. 

11 And if there are criteria in the quality 

12 assurance plan that allow you to go back to and 

13 say, "We're missing this criteria in the quality 

14 assurance plan," I'm comfortable with that. 

15 How about if we were able to come up -- I 

16 mean, I think we're arguing about five to seven 

17 here in zone 1. How about if we were able to 

18 come up with something that we provide a maximum 

19 range, and we say, you know, "Our goal is five, 

20 but we want a couple of years of evaluation. And 

21 if we go above seven, we're bad. But if we go 

22 above five and we're within seven, we're okay." 
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1 And again, this is more of a technical 

2 assistance technology transfer effort, 

3 educational effort. It's not meant to be red4 tagging people for trying their best to implement 

5 a quality assurance program. Thank you. 

6 MR. RAMIREZ: All right. So then -- 

7 MR. UNGER: Sorry. So I guess on that, I 

8 would just note, as I said before, if there's a 

9 transitional issue, it seems to me that to set a 

10 temporary standard or temporary exception, and 

11 then a final, more stringent standard, makes 

12 sense. 

13 The other thing is, from the descriptions 

14 I've heard, it sounds to me that universal visual 

15 -- universal prescription measures or visual 

16 inspection, combined with testing of a sample, 

17 and here I recognize that that sample is a 

18 question, and whether that means only testing 

19 single-wide homes or testing a small sample in 

20 the field, or I don't know what the solution is. 

21 And sounds like perhaps we can't get into 

22 that here. But it seems to me that a combination 
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1 of a testing of a sample with the prescriptive 

2 measures makes logical sense to me, rather than, 

3 or -- and that's what I understood the proposal 

4 was on the ducts. And I would wonder whether we 

5 could do the same kind of approach here as well. 

6 MR. RAMIREZ: So then, similar to ducts, 

7 we're looking at the possibility of a step-in 

8 phase, although it's a little bit different. 

9 We're talking about a goal of a five with a max 

10 of a seven, but aligned for some type of step-in. 

11 Nothing concrete on that one yet, but at 

12 least that's what's being thrown out there. 

13 Anything additional that we need to cover 

14 on this one, or should we move on to next steps? 

15 MR. HAGERMAN: Let me just reiterate that 

16 I just issued the orders to PNNL to run those 

17 additional simulations with the HUD code 

18 baseline. So that was a good add. So you should 

19 hopefully get those by Friday. It might take 

20 them a little bit longer if they run into 

21 problems. But we'll see. I mean, we're trying 

22 to be as fast as possible. 
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1 MR. RAMIREZ: Great. Thank you. 

2 MR. LUBLINER: Thanks, Joe. 

3 MR. RAMIREZ: Okay. Then, as far as next 

4 step goes, it seems like Emanuel and Lois are 

5 going to get getting those cost figures in pretty 

6 quick. And then we're going to get that 

7 information out. 

8 What's your comfort level with doing 

9 something similar that we did last time, as far 

10 as, let's see what actual data we get, what 

11 information is disseminated to the group, and 

12 build the agenda a few days before to see if 

13 there's any modifications that you all come up 

14 with? Everyone okay with that approach? 

15 MR. HAGERMAN: This is Joe Hagerman, DOE. 

16 I think we have to be comfortable with 

17 that, given that we're still outstanding so many 

18 items. 

19 MR. RAMIREZ: Um-hm. 

20 MR. HAGERMAN: Let me just conjure up 

21 John Caskey and say, you know, we hope everybody 

22 comes next time ready to make the hard decisions, 
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1 right? Because we will have gotten all that 

2 data. So hopefully, we can move down the field a 

3 little bit farther. 

4 MR. RAMIREZ: And I'll piggyback on that, 

5 right, that again, you all are the subject matter 

6 experts on this. And so we're going to have 

7 quite a bit of data. And I'm going to be pushing 

8 you a little bit more to, "Look. Based on what 

9 we have, what do you think? What's your 

10 recommendation, what's your suggestion?" 

11 MS. HOFFMAN: Eileen Hoffman. We'll be 

12 looking at costs and energy efficiencies, and 

13 using your expertise to work on these standards. 

14 MR. RAMIREZ: And if I understand 

15 correctly, Eileen's a little squeamish with 

16 blood. So she won't be here at the next meeting. 

17 [Laughter.] 

18 MS. HOFFMAN: I will tell you, Ted 

19 Bantle, who you've seen behind me, is going to be 

20 a very welcome substitute. So. Duty calls. 

21 MR. RAMIREZ: Go ahead, Mike. 

22 MR. LUBLINER: This is Mike Lubliner. 
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1 Yeah, I just want to make one suggestion 

2 as we look for consensus that I would be 

3 comfortable with, is if we were able to change 

4 under A requirements from "or" to say "either," 

5 where it says, "by periodic testing and visual 

6 inspection of each house," I think that addresses 

7 the concern that Lowell and I had. 

8 And then down under testing for climate 

9 zone 1, I would put five to seven air changes per 

10 hour and leave that range, and leave it up to DOE 

11 to decide how to enforce that, or discussion in 

12 the spinoff group. 

13 I think that would be adequate to making 

14 this comfortable to my likings. Thank you. 

15 MR. RAMIREZ: Mark? 

16 MR. EZZO: Mark Ezzo. Could you say the 

17 first part of that again, please? 

18 MR. LUBLINER: Sure. It would be, for 

19 compliance with the leakage targets that can be 

20 demonstrated by VI, get rid of the word "either" 

21 and say, "periodic testing and visual inspection 

22 of each home by prescriptive air sealing." 
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1 MR. EZZO: Okay. I got it. Thank you. 

2 MR. LUBLINER: And then under one, it 

3 would just say -- 

4 MR. RAMIREZ: I'm sorry. Hold on a 

5 second, Michael. 

6 Look on the screen here. Ted's doing a 

7 great job of trying to write with the mouse. 

8 Right? 

9 [Laughter.] 

10 MR. RAMIREZ: You see that where the 

11 cross-out is, and there's a plus there? That's 

12 "and." And then under testing, number one would 

13 be a range of five to seven. 

14 [Pause.] 

15 MR. RAMIREZ: Yeah, that's it. That's 

16 PDF shorthand. 

17 [Pause.] 

18 MR. WEISS: Yeah, just to respond to 

19 that. Mark Weiss, MHARR. 

20 I guess it goes under the heading of, 

21 "Burn me once, burn me twice." And I'm not 

22 suggesting that DOE is going to act or interpret 
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1 things the same way as HUD. 

2 But we recently had a recommendation for 

3 HUD for periodic something, and that became 

4 monthly inspections versus periodic inspections. 

5 So having been alerted thusly, I am very 

6 concerned, not inclined to use the term 

7 "periodic" if I can avoid it. No offense, Rick. 

8 MR. EZZO: How about "random"? 

9 MR. RAMIREZ: "Random" versus "periodic"? 

10 MR. WEISS: That might be even worse. 

11 [Laughter.] 

12 MR. RAMIREZ: All right. So we're not 

13 going to be getting consensus on this right at 

14 this moment, right? There's going to be a little 

15 bit of cleanup. But just to kind of give you a 

16 heads-up, though. That's the type of holding17 your-feet-to-the-fire that I'm going to be doing 

18 with you next. 

19 I would ask you, Mark, "What would you 

20 put there instead?" Right? 

21 Not right now. But there's an example of 

22 how we're going to be doing that so that we can 
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1 try to bring things to closure. Okay? 

2 All right. So, thank you for those 

3 recommendations, Michael. 

4 Now, just looking at the map here, we had 

5 started off yesterday with trying to identify, 

6 what roadmap do we need? What do we need to do 

7 in order to reach an agreement by -- and just as 

8 we're discussing today, I put 10/2 on there. But 

9 it sounds like we might have a little bit more 

10 time. But I don't want to push it all the way to 

11 the end of November. 

12 So what if we're saying like that the 

13 10th of November, right? What do we need to have 

14 something done by the 10th of November, as a term 

15 sheet, regardless of that actual -- 

16 MS. HOFFMAN: So, you don't mean 

17 November; you mean October? 

18 MR. RAMIREZ: I'm sorry. October, the 

19 end of October. Right. So, say October 10th. 

20 Again, regardless of that specific 

21 timeline there, what else do we need to put on 

22 here in order to try to reach that goal? 
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1 [Pause.] 

2 MR. RAMIREZ: So, we have on there the 

3 cost data that's going to be provided. And once 

4 that cost data is provided, which is going to be 

5 by the end of this week, when we do some 

6 additional runs, that might help clarify the 

7 climate zones. 

8 So I'm hoping that when we get together 

9 on 9/22, also going on climate zones is something 

10 that we could walk out of here with on that day, 

11 right, maybe even some of the actual performance 

12 levels. 

13 And Manny and your subgroup, I'm hoping 

14 that you're going to be able to bring in some 

15 fairly tight recommendations of what we could do 

16 for either the low-hanging fruit or even maybe 

17 the ones that we need a little step-stool for, 

18 right? 

19 MR. SANTANA: This is Manny again. You 

20 know, regarding that, can we assume -- you know, 

21 I'm not there, so I couldn't gauge what was going 

22 on. But did we obtain tacit approval for the 
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1 Emanuel proposal? 

2 You know, because a lot of that stuff, 

3 you know, it incorporates duct sealing, you know, 

4 tightness value, stuff like that that's in the 

5 IECC. Can we assume that there was approval for 

6 that so then we won't have to worry about those 

7 sections? 

8 MR. RAMIREZ: Yeah. I think what we're 

9 talking about was to use that one to plug in 

10 those values, those numbers. And then we'll see 

11 how that looks. We haven't approved it, right? 

12 But we're saying, "Yeah, use that as the starting 

13 point." 

14 MR. HAGERMAN: I think he's specifically 

15 asking if his working group can skip over those 

16 sections, because we're going to use -- 

17 MR. RAMIREZ: Plug in those numbers. 

18 MR. HAGERMAN: -- Emanuel's proposal in 

19 replacement. 

20 MR. RAMIREZ: Yes. 

21 MR. HAGERMAN: And I think that, largely, 

22 the group would probably be comfortable with 
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1 that. I just would recommend that committee to 

2 at least skim those provisions again and just to 

3 see that, you know, you didn't leave out 

4 something in there. 

5 MS. HOFFMAN: Right. And I would also 

6 suggest that you relook at it in the two weeks 

7 and see what it looks like, and write it up. 

8 Now, who will do that? Just to write up 

9 Emanuel's -- maybe he will -- and put it in a 

10 format so they can look at it, as well as the 

11 IECC? 

12 MR. RAMIREZ: Manny's subcommittee is 

13 going to be tackling that. 

14 MS. HOFFMAN: Manny's subcommittee, all 

15 right. 

16 The other thing is the definitions. You 

17 may want to decide what kinds of definitions 

18 you'll need in this rule. You don't have to make 

19 up new definitions. But you may want to locate 

20 where they are. 

21 MR. RAMIREZ: Yeah, Mark. 

22 MR. WEISS: Mark Weiss, just a follow-on 
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1 to that. 

2 Yeah, I mean, if folks have term-of-art 

3 definitions or definitions from other codes or 

4 things that they want to reference, it would be 

5 good to get those out on the table and know where 

6 they're coming from and exactly what folks are 

7 putting forward, if there are. 

8 MR. HAGERMAN: I think definitions are 

9 critical, too -- 

10 MR. WEISS: I'm sorry. I mean aside from 

11 what's sitting in the book here, other stuff. 

12 MR. HAGERMAN: Joe Hagerman, DOE. 

13 I think definitions are critical, too, if 

14 the group decides to go the Robin Roy route of 

15 this type LO, type full option, right? We're 

16 going to have to, as a group, define what those 

17 two things are, right? 

18 MR. RAMIREZ: Um-hm. 

19 MR. HAGERMAN: So I think definitions 

20 here are critical. 

21 MR. RAMIREZ: And as far as that approach 

22 of the two products, how are we going to try to 
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1 capture that so that we have some structure that 

2 we could really look at versus something 

3 conceptual and having the group trying to come up 

4 with detail? 

5 MS. HOFFMAN: Eileen Hoffman. Maybe 

6 Robin's committee could come up with some 

7 language beyond what you had done already, but 

8 some language -- 

9 MR. RAMIREZ: Developing a straw man? 

10 MS. HOFFMAN: With a proposal. 

11 MR. ROY: That was the intent. And we 

12 tried to lay out a general framework of what 

13 would be the targets for the LO and FO. 

14 MR. RAMIREZ: Okay. 

15 MR. ROY: Product types. And we'll have 

16 conversations about whether those definitions are 

17 suitable and the analysis, which is being done, 

18 you know, fits. You know, it was designed to fit 

19 into the analysis, or to take what comes from the 

20 analysis. We'll have conversations about whether 

21 that still seems suitable. I mean, that's the 

22 intent. 
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1 MR. RAMIREZ: Okay. And as any of these 

2 things, documents are made available, if you 

3 could forward them on to us so that we could send 

4 them out to the entire work group so that that 

5 way they have a chance to chew on it before we 

6 get together on the 22nd, that would be great. 

7 What about on the other discussions? 

8 What needs to be done there? How do we handle 

9 labeling the space water heating piece? Well, 

10 window types, we discussed a little bit of that 

11 today. 

12 MR. LEVY: Javier? Emanuel. 

13 MR. RAMIREZ: Yeah. 

14 MR. LEVY: Can I ask a question before we 

15 move on to that? Just a clarification on the two 

16 items that seem like the big-ticket items to me 

17 on the 9-22 list. Climate zones and actual 

18 performance levels, I assume that's the 

19 prescriptive packages of U values we're 

20 describing them as. Some were requirements. 

21 My understanding is that you need our 

22 costs to start getting clarification of what 
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1 those things are. 

2 MR. RAMIREZ: Right. 

3 MR. LEVY: And I'm just asking whether it 

4 would be useful, if the laboratory expects to 

5 have results sooner rather than later, to have a 

6 call with the group -- and maybe there's a 

7 committee looking at this already -- to look at 

8 those interim results and maybe iterate through 

9 that before the next meeting to try to accelerate 

10 things a bit, rather than wait until the 9-22 

11 meeting to start talking about this. 

12 MR. RAMIREZ: So a subcommittee on 

13 climate zones and compliance paths? 

14 MR. LEVY: Well, yes. Well -- 

15 MS. HOFFMAN: You're thinking the whole 

16 committee, through a GoToMeeting, some kind of 

17 system to discuss it for maybe an hour or so? Is 

18 that what I'm hearing? Before the -- 

19 MR. LEVY: Just to get an understanding. 

20 Yes. At minimum to get an understanding of what 

21 kinds of results are coming out. And at best, to 

22 be able to provide feedback that -- so maybe 
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1 there's an iteration cycle that goes on before 

2 the meeting, and some additional information can 

3 be generated to anticipate questions that will 

4 come up in the meeting. 

5 I just think that that is going to be the 

6 most difficult piece to deal with, the most 

7 controversial, require the most input and 

8 analysis. 

9 MR. ROY: This is Robin. I tend to 

10 concur. I mean, part of this affordability to 

11 product types is driven by a presumption that the 

12 different cost effectiveness perspective that 

13 you're looking at, that you're doing analysis on, 

14 will end up with reasonably different performance 

15 levels. 

16 We're going to continue on that 

17 presumption for awhile until we see otherwise. 

18 But as soon as we get some of those results, the 

19 sooner we can talk more concretely within our 

20 little group. 

21 MR. UNGER: This is Lowell. It seems to 

22 me that the climate zones and perhaps the 
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1 compliance paths are structural issues. It's 

2 actually not even clear to me how useful more 

3 data will be in order to decide those. So we do 

4 have, at least, energy data. 

5 But I think it would be useful to the 

6 extent that we could get at least a preliminary 

7 revolution on what those are, that would then 

8 help deal with all the other issues, because we 

9 would at least know more about what the structure 

10 is that we're trying to fill in. 

11 The performance levels is much more 

12 substantive. And, you know, it would be great to 

13 make progress on that, too. But that's kind of 

14 at a different level I certainly don't think 

15 we're going to be able to resolve in between 

16 meetings. 

17 But I wonder for the climate zones in 

18 particular, and potentially past the compliance, 

19 if there would be a way of wrapping those up or 

20 at least getting people's views on the table or 

21 something, to see if we can resolve those in 

22 order just to make it easier to deal with the 
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1 other questions. 

2 MR. RAMIREZ: Joe, did you have 

3 something? 

4 MR. HAGERMAN: So, Joe Hagerman, DOE. 

5 What I did, what -- if you just remember 

6 things here. The KISS Luby proposal that was run 

7 was specified in the three HUD climate zones. So 

8 then, PNNL modeled that in the eight climate 

9 zones with the IECC, right? 

10 If you look at those results, there's, in 

11 my opinion, wild swings going from the three 

12 climate zones to the eight climate zones that I 

13 think you should look at the results. I think 

14 everybody should look at the results. But I 

15 think you should look at the results in 

16 particular, right? 

17 Because in one location of the IECC 

18 climate zones, the HUD climate zones are kind of 

19 wacky, right, and may not be cost effective. Or, 

20 you know, they're not as aggressively cost 

21 effective, however you want to say that, right? 

22 So what I did for the new analysis that 
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1 the group just requested, which is actually a lot 

2 of runs, but I think we simplified it here, I 

3 took the KISS Luby proposal as the basis. And 

4 then I'm changing the solar heat gain 

5 coefficient, all right, and going back to the 

6 original proposal, changing the duct leakage, all 

7 right, going back to the original proposal, and 

8 changing the air leakage, right? 

9 So you'll see everything baselined off of 

10 that in terms of insulation values and all that, 

11 right? That's my base. That's my new interim 

12 baseline. Okay? Does that sound fair? 

13 And then you'll also see the duct leakage 

14 if it was at the HUD minimum, or if the windows 

15 are at the HUD minimum. But the insulation 

16 levels are pegged to that last proposal, which I 

17 think is the only reasonable way to do this right 

18 now. But I just want full understanding of that 

19 from everybody, that ya'll agree to that, so. 

20 MR. RAMIREZ: I think that the thinking 

21 of the group was that if we could just plug in 

22 some of the cost numbers on there, that that 
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1 might actually bring out which of the climate 

2 zones, IECC or HUD, would make sense. 

3 And I think that that was going to become 

4 a little bit more clear once the cost numbers 

5 were put in. 

6 MR. HAGERMAN: This is Joe Hagerman, DOE, 

7 again. 

8 And remember, Matthew is going to be 

9 plugging in the cost numbers for that KISS Luby 

10 proposal, right? So again, you'll have the cost 

11 numbers for that baseline proposal as well. 

12 MR. LUBLINER: Rob Luter with Lippert? 

13 MR. RAMIREZ: Yeah. 

14 MR. LUBLINER: Pardon me for the 

15 timeliness issues. I've been trying to get 

16 unmuted for a little while. 

17 Regarding the two-tiered compliance that 

18 was discussed here a few minutes ago, the LO and 

19 the FO, is anyone else troubled by that? Trying 

20 to come up with two different standards? I mean, 

21 right now the industry has to deal with the I22 code modulars and the HUD code homes to break the 
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1 HUD down into two tiers, if you will. 

2 I know from my perspective, it will be 

3 more complex than I think it really needs to be, 

4 especially in light of the fact we're supposed to 

5 be developing, as I understood, a standard, not a 

6 sliding scale based on some set of criteria. 

7 MR. SANTANA: This is Manny with CAVCO. 

8 It would also seem to me that Robin's 

9 proposal and Emanuel's proposal were kind of 

10 competing proposals. Is there any way we can try 

11 to -- you know, we're not going to end up with 

12 two. Given the short, you know, the imminent 

13 deadline that we have, is there any way we can 

14 maybe parry that down to one and focus our 

15 attention? 

16 MR. RAMIREZ: Okay, if I remember 

17 correctly, the reason for the whole idea of the 

18 two different products was to deal with the 

19 affordability issue, you know, which Mark has 

20 been stating all along, is that increased costs 

21 is going to impact the affordability point. Are 

22 we going to be excluding folks from the market? 
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1 And I think the idea there was to say, 

2 "Okay, fine. Let's come up with this low 

3 option," is that low option that would allow for 

4 those folks that are at the entry level to still 

5 be able to afford one of these units. 

6 But folks that are not quite at that 

7 level, then they could absorb the initial up8 front costs, knowing that they're going to save 

9 it on the back end with the efficiencies. 

10 So we're trying to -- I think the idea 

11 there was to try to capture both the 

12 affordability as well as the energy efficiencies 

13 over the long run. 

14 MR. WEISS: Yeah, Mark Weiss, MHARR. 

15 Without prejudging anything, we're not, 

16 obviously, committing to anything, I would like 

17 to see more information on that and see it 

18 further developed. So. 

19 MR. RAMIREZ: Okay. 

20 MR. HAGERMAN: Joe Hagerman, DOE. 

21 It's not two different standards. It's 

22 just a product type, right? Just like side-by-
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1 side refrigerator is different than a top-mount 

2 freezer-refrigerator, right, which is still 

3 covered by one standard. We call it, you know -- 

4 we call it product types, or product classes. 

5 MR. RAMIREZ: Okay. So, as far as 

6 continuing on with the next step, so it sounds 

7 like we need to get some of this data out. And 

8 then we can try and arrange a conference call 

9 somewhere before, or GoToMeeting with the entire 

10 group to discuss the zones and the compliance 

11 paths. 

12 And then we'll have to schedule that, 

13 because we don't know exactly when the data is 

14 going to be coming out in the runs. 

15 Mark, you had something on that? 

16 MR. WEISS: Just a heads-up. I became 

17 aware of earlier that probably a number of us are 

18 going to be on another conference call on 

19 September 16th in the afternoon that HUD is 

20 running. So if we could avoid that, it would be 

21 helpful. 

22 MR. RAMIREZ: Okay. 
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1 [Pause.] 

2 MR. RAMIREZ: Okay. What else needs to 

3 go up here to make sure that it's either on our 

4 minds or that we need to gather information or 

5 prepare for for the next meeting? 

6 [Pause.] 

7 MR. HAGERMAN: This is Joe Hagerman, DOE. 

8 We were going to circulate this outline 

9 of the term sheet. But I was talking to Ed 

10 Barbour of Navigant, and he suggested that, you 

11 know, we go back after we've heard from everybody 

12 for the last two days and tweak the outline that 

13 he's presented to more reflect the current 

14 conversation. 

15 MR. RAMIREZ: Okay. 

16 MR. HAGERMAN: So I suggest we do that, 

17 and then we can circulate it by email to 

18 everybody. 

19 MR. RAMIREZ: Okay. 

20 MR. HAGERMAN: It should not shock you. 

21 I mean, there's nothing -- it's just an outline, 

22 right? 
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1 MS. HOFFMAN: Excuse me. Eileen Hoffman. 

2 But it gives you an idea of what the term 

3 sheet might look like. It doesn't have the 

4 numbers, but it does have the words. So at least 

5 it gives you an idea of the template that might 

6 be followed. 

7 MR. RAMIREZ: Okay. Is there anything 

8 else then before we open up the floor for public 

9 comment? 

10 I'm sorry, Mark. 

11 MR. WEISS: Mark Weiss, MHARR. 

12 And since Eileen won't be here for the 

13 next meeting, I just wanted to thank all of you 

14 for your efforts in facilitation. I think 

15 they've been excellent. 

16 MR. RAMIREZ: Thank you. And she will be 

17 back, though. 

18 [Laughter.] 

19 MS. HOFFMAN: How much did I pay him? 

20 No, no. 

21 [Laughter.] 

22 MR. LUBLINER: This is Mike Lubliner. I 
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1 want to echo that as well. 

2 And I want to make an observation, if 

3 it's appropriate here. Back in the '90s after 

4 Hurricane Andrew, there was a significant amount 

5 of property loss due to the windstorm, wind 

6 damage. And the manufactured housing industry 

7 took a big hit and some really bad PR. 

8 And as a result of that, they were 

9 forced, in a way, dragging and kicking, by HUD to 

10 update higher structural efficiency in the homes. 

11 And as a result of that, my understanding is, 

12 after Hurricane Charlie, that we had much, much 

13 better success of getting through these disasters 

14 without structural damage. 

15 The argument that was being made at the 

16 time when that was being proposed was that this 

17 was going to price us out of the market, and it 

18 was going to address affordability, and it was 

19 going to hurt our buyers. 

20 And I just think we need to reflect on 

21 experiences that we've had in this industry, 

22 because my understanding is that wasn't the case 
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1 at all, that it made it a better product, a 

2 better industry, and cost society less when we 

3 have these catastrophic events, which seem to be 

4 happening more and more. 

5 Just a thought so that we can reflect on 

6 what we've learned from the past. And I 

7 appreciate you guys taking that with a grain of 

8 salt, based on my value system. So, thank you. 

9 MR. RAMIREZ: Okay. Thank you for those 

10 comments. All right. 

11 MR. LUTER: I have one item as well, 

12 please. 

13 MR. RAMIREZ: Okay. Go ahead, Rob. 

14 MR. LUTER: For those of us doing the 

15 GoToMeeting, I know that there in the conference 

16 room there have been copies of the 2015 IECC made 

17 available. So those present can follow along. 

18 Are those available for those of us that 

19 joined the call remotely? Like can I get a copy 

20 of whatever you have copies of mailed to me? 

21 MR. RAMIREZ: We have books here. And I 

22 was assuming these were on loan. So I was going 
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1 to give them back here. But, Joe? 

2 MR. HAGERMAN: The books are on loan. So 

3 we'd appreciate them back. I mean, we're not 

4 going to hunt you down if you don't -- I guess I 

5 shouldn't say that. 

6 [Laughter.] 

7 MR. HAGERMAN: But -- 

8 MR. RAMIREZ: I'll gladly turn mine back 

9 in. 

10 MR. HAGERMAN: We can -- I guess if 

11 there's a member that needs a copy, we can 

12 possibly mail you a copy. 

13 MR. LUTER: Well, that, or if there's an 

14 electronic resource, I'm more than happy if you 

15 just have a view-only copy on a screen. I just 

16 like to follow along and keep up with 

17 developments. 

18 MS. HOFFMAN: Eric, did you have copies 

19 we could unofficially have? 

20 MR. LACEY: I am working on that. I just 

21 had a voice mail this morning that I wasn't able 

22 to return from the guy at IECC I'm trying to work 
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1 with. I think there is an online view-only 

2 version. But I haven't been able to find it, and 

3 I haven't been able to connect with the right 

4 person there. So. 

5 MS. HOFFMAN: But can we ask you to come 

6 up with it? 

7 MR. LUBLINER: A couple of months ago, 

8 there was one. 

9 MS. HOFFMAN: Yeah. 

10 MR. LUTER: I'm cognizant of copyright 

11 issues and all that. I respect those. 

12 MR. RAMIREZ: Yeah. That's what we're 

13 dealing with. But I think that Eric is trying to 

14 get approval for this working group so that we 

15 could get some copies there. 

16 MR. LUTER: It's not without precedent 

17 for that to happen. That's for sure. 

18 MR. LUBLINER: Rob, Mike Lubliner. I had 

19 to spend 50 bucks to buy the electronic version 

20 last week in preparation for Manny's meeting. 

21 MR. LUTER: Well, you got a deal. 

22 [Laughter.] 
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1 MR. RAMIREZ: Mark? 

2 Go ahead, Isabel. 

3 MS. DICKENS: Can you all hear me? I'm 

4 sorry. I've been trying to get in a little bit. 

5 I am just -- I can't afford to come out 

6 to all these meetings. I had to reserve a flight 

7 for the 22nd and 23rd of September meeting. But 

8 I'm wondering if we can set dates today for the 

9 future meetings that we're going to have into 

10 October. 

11 And I may end up having to just change a 

12 flight, because I'm not sure I can come out more 

13 than one more time and whether coming on the 22nd 

14 makes more sense or coming in mid-October makes 

15 better sense. 

16 So, can we set those dates right now? 

17 MR. RAMIREZ: Before we get there, Mark, 

18 you had a comment? 

19 MR. WEISS: Yeah, just before we move on. 

20 Turn back the booklets in at the end of the 

21 proceeding. 

22 MR. HAGERMAN: Yeah, at the end. We're 
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1 at the honor system here. At the end of the 

2 proceeding, turn back your books. 

3 MR. WEISS: Right. Right. 

4 MR. HAGERMAN: Or you fail the class. 

5 And yes, I agree. We should talk about 

6 the future dates and locations. The offer is on 

7 the table that we could meet at another DOE 

8 facility. We have a facility in Chicago at the 

9 Argon National Lab. It's pretty easy. And then 

10 there's also a facility, a very nice facility, 

11 brand-new facility in Golden, Colorado, at the 

12 National Renewable Lab. 

13 MS. DICKENS: I would vote for Colorado. 

14 MR. HAGERMAN: Colorado is very easy for 

15 a lot of us to get to. So. 

16 MR. RAMIREZ: All right. Well, I'll tell 

17 you what. Let's look at dates, and then we could 

18 determine location. 

19 MR. HAGERMAN: I think the next meeting 

20 we set last time to be here. So the future, the 

21 next future meeting that we haven't set yet is 

22 October 1st or October 2nd, something like that. 
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1 MS. HOFFMAN: Yeah. Eileen Hoffman. 

2 We have it in the registrar as being 

3 here, but that doesn't mean that couldn't change. 

4 But we do have both for September 22nd and 23rd 

5 in a ground-floor address here, and October 1 and 

6 2 here. 

7 MR. RAMIREZ: Right. So, let's look at 

8 the next dates beyond October 1st and 2nd. What 

9 other dates do you all want to -- 

10 MR. HAGERMAN: October 1 and 2 are on the 

11 table for being at a different location. If the 

12 committee -- if the working group tells me ahead 

13 of time, I could work with our contractors to get 

14 us a discounted room rate at some of the local 

15 hotels there. So. 

16 MR. RAMIREZ: So, is everyone okay with 

17 changing the location? It sounds like Denver is 

18 the preferred spot? Is there any objection to 

19 holding the October 1st and 2nd meetings in 

20 Denver? 

21 [Cross-talk.] 

22 MS. DICKENS: Although I said Colorado, 
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1 if I come out to D.C. in September, I wouldn't be 

2 able to get to Colorado in October. So it 

3 doesn't really matter. You should decide. 

4 MR. RAMIREZ: Okay. Anyone else? 

5 MR. LUBLINER: Mike Lubliner here. 

6 I have already made my plans, my travel 

7 plans, for D.C. on October 1st and 2nd. And 

8 because I'm not being reimbursed by DOE for this, 

9 I've tried to use that time back in D.C. to meet 

10 with other clients, which I've already scheduled 

11 meetings for on the 3rd. 

12 So it would be a real disruption to me to 

13 have to change that end route for Golden, 

14 Colorado. But I would be very willing, if we 

15 have future meetings beyond that, to consider 

16 doing the next one in Golden, Colorado, say the 

17 third week in October. 

18 MR. RAMIREZ: Okay. So is everyone okay, 

19 then, keeping the October 1st and 2nd here in 

20 D.C.? 

21 MR. SANTANA: Well, did we already set 

22 the date for October 1st and 2nd? 
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1 MS. HOFFMAN: Yes, we did. 

2 MR. SANTANA: Was that already 

3 established? 

4 MS. HOFFMAN: Well, we had it down, yes. 

5 And it wasn't affirmed, but it was pretty close. 

6 MR. RAMIREZ: Yeah. So I think that we 

7 did have that one down. 

8 MR. SANTANA: Well, you know, that's only 

9 a week-and-a-half after the 22nd meeting. So I 

10 can make it to the 22nd and probably not to the 

11 1st. 

12 MR. LUBLINER: It's actually five 

13 business days later. I just wonder whether 

14 something can be accomplished in that period. 

15 [Pause.] 

16 MR. RAMIREZ: Yeah, because I think part 

17 of the reason that we were scheduling with these 

18 two-week increments was because of the concern 

19 that we were going to be requesting quite a bit 

20 of analysis. By then, I'm hoping that we have 

21 the numbers that we need in order to start making 

22 decisions. 
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1 So, as a facilitator, I don't see why we 

2 couldn't have it that tight unless someone else 

3 -- and I guess I'd have to defer more to Joe and 

4 some of the other folks that, if that's not going 

5 to be productive, then, yeah, let's give it a 

6 little bit more space. But if we can, let's move 

7 forward. 

8 [Pause.] 

9 MR. RAMIREZ: So, let's keep the 1st and 

10 2nd then. All right. 

11 So, beyond the 1st and 2nd, when do you 

12 want to look again? What other date? 

13 [Pause.] 

14 MS. DICKENS: Do you think it would be 

15 one more being after the 1st and 2nd? Do you 

16 think we can do it? I mean, that would be our 

17 third meeting from today, right? 

18 MR. RAMIREZ: Yeah. When you talk about 

19 sets, yeah. 

20 MS. DICKENS: Yeah. So maybe we -- do we 

21 want to go into the third week of October, the 

22 week starting October the 20th? 
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1 MR. LUBLINER: This is Mike Lubliner. 

2 That's the soonest that I could -- my 

3 October is full. I had to defer everything that 

4 I was going to do in September to October for my 

5 clients, my paying clients. 

6 [Laughter.] 

7 MR. LUBLINER: So, yeah, I'd like to -- 

8 I'd certainly like to go to the third week. That 

9 will give me a couple of weeks to catch up on my 

10 back order from that meeting on the 1st. And I 

11 think that gives us a good amount of time to 

12 really get some of the subcommittee wheelings and 

13 dealings done so that I'm -- 

14 MS. HOFFMAN: Are we talking then -- 

15 Michael, are we talking about the week of October 

16 20th? That's a Monday. 

17 MR. LUBLINER: Yeah. That would be my 

18 preference. Yeah, thank you. 

19 MR. LUTER: I'd echo that preference. 

20 This is Rob. 

21 MR. EZZO: Mark Ezzo. That week works 

22 for me, too. 
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1 MR. RAMIREZ: All right. So which days 

2 do you want to look at on there? 

3 MALE VOICE: Not Monday. 

4 MR. WEISS: Not Friday. 

5 MR. LUTER: The 21st, 22nd. 

6 MR. RAMIREZ: Yes. We're looking at 

7 Tuesday, Wednesday, Thursday. Of those three 

8 days, which ones work best for everybody? 

9 MS. DICKENS: I'd like Wednesday and 

10 Thursday. But I can be flexible. 

11 MR. RAMIREZ: Stacey? 

12 MALE VOICE: Tuesday, Wednesday, or 

13 Thursday are fine. 

14 MS. EPPERSON: Wednesday, I'm out. But I 

15 could possibly do an alternate. But I imagine 

16 this is our final vote, too, isn't it? Okay. 

17 MR. RAMIREZ: That's the hope. 

18 MS. EPPERSON: Um-hm. 

19 MS. DICKENS: Would Thursday-Friday work 

20 for people, the 23rd and 24th? 

21 MS. EPPERSON: Yes. 

22 MR. RAMIREZ: I heard somebody say not 
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1 Friday. 

2 MR. WEISS: That was a preference. 

3 MR. RAMIREZ: Yeah. Let me beat you up 

4 on that one, Mark, then, right? If it's a 

5 preference -- 

6 MR. WEISS: I'm flexible. 

7 MR. RAMIREZ: Because Stacey does have a 

8 conflict on Wednesday. 

9 So how does the 23rd and the 24th look? 

10 MR. HAGERMAN: Would it help if we 

11 proposed, just as an option, you fly in the 22nd, 

12 the meeting starts at 1:00, and you fly out the 

13 24th? 

14 MALE VOICE: Are we flying into Golden? 

15 MS. HOFFMAN: Or is this going to be -- 

16 MR. HAGERMAN: In Denver. 

17 MR. RAMIREZ: So a half-day on Wednesday, 

18 full day on Thursday, half-day on Friday? 

19 MR. HAGERMAN: Sure. 

20 MS. EPPERSON: I'm out on the 22nd, all 

21 day. I could fly that night. 

22 MR. LEVY: I want to suggest Chicago as 
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1 an option. I'm more interested in whether other 

2 people who haven't been able to make the meetings 

3 could come to that meeting if it was closer to 

4 them. 

5 MR. ROY: I'm getting tired of flying 

6 from the West Coast, but there you go. 

7 MR. LUTER: I'd vote for Chicago 

8 wholeheartedly, but I'm selfish. I can drive. 

9 MR. EZZO: This is Mark. I could do 

10 either Denver or Chicago. 

11 MR. SANTANA: Manny here. I can do 

12 either as well. And I think in late October, I'm 

13 pretty much open. So whatever you guys decide, 

14 I'll be pretty good. 

15 MR. LUBLINER: This is Mike Lubliner. 

16 My preference would be Denver. But I 

17 would say either flip a coin or come to 

18 consensus. I would attend Chicago as well if the 

19 group feels it's appropriate. 

20 MS. DICKENS: This is Isabel. I'm more 

21 likely to attend in person in Denver. I'm more 

22 likely to attend by telephone if it's Chicago, 
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1 just because of other issues in the cities, where 

2 I can do more work or not. 

3 MR. RAMIREZ: And Michael Wade chimed in 

4 that Golden was a preference. 

5 [Cross-talk.] 

6 MR. RAMIREZ: And Dave Tompos was for 

7 Chicago. 

8 MS. HOFFMAN: It's about half and half. 

9 MR. RAMIREZ: Yeah. It sounds like it's 

10 a fairly even split. 

11 Now, the folks that are saying Chicago, 

12 is it a preference thing where it's just easier 

13 to fly in and out of? Because I'm hearing some 

14 folks say that Chicago would be very similar to 

15 D.C. as far as ability to attend or not attend, 

16 meaning that Denver would be a better location. 

17 Selfishly, Argon, I could walk there if 

18 we had it there. That's how close it is to my 

19 house. But it sounds like the majority of the 

20 folks, we'd probably get the greatest attendance 

21 with Denver. 

22 MR. LUBLINER: Javier, Mike Lubliner 
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1 here. 

2 My preference is Denver because of the 

3 shorter plane flight. But also, it's much less 

4 expensive for me, both in terms of flight and, 

5 you know, accommodations and logistics and 

6 everything, and time change. 

7 MS. DICKENS: Ditto for Isabel. 

8 MS. HOFFMAN: Well, why don't we make an 

9 executive decision? 

10 MR. RAMIREZ: Yeah. So let's pull the 

11 trigger on Denver unless somebody really wants to 

12 rip my head off for that. 

13 MR. LUTER: Can I throw out something a 

14 little unorthodox? Could we have a conference 

15 room at both locations and hook up, do a 

16 videoconference? We have the technology. 

17 MR. RAMIREZ: I have no idea. I don't 

18 know. 

19 MR. LUTER: Let the West Coast folks go 

20 to Denver and the East Coast folks go to Chicago? 

21 MS. HOFFMAN: I hear you. There's a 

22 synergy, I think, in having everyone, if 
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1 possible, in the same room so we can actually 

2 craft this final, you know, our final meeting. 

3 MR. LUTER: I don't disagree. What I 

4 seem to be hearing, though, is that for at least 

5 a contingent, either place means GoToMeeting. 

6 But if it could be both places, we could have 

7 more people actually sitting in rooms next to one 

8 another. 

9 MR. RAMIREZ: Yeah. Let me hear the 

10 folks that, if it was in Denver, that you would 

11 absolutely have to do a GoToMeeting. And I don't 

12 want to hear from you if regardless of where 

13 we're having the meeting, it would be GoToMeeting 

14 anyway. In fact, there's a number of you that 

15 are doing that anyways. 

16 But if it was Denver versus Chicago, how 

17 many of you would then have to say, "I can't do 

18 that. I'd have to do a GoToMeeting"? 

19 MR. LUTER: It would probably be 

20 GoToMeeting for me, Rob Luter, in Denver. 

21 [Pause.] 

22 [Inaudible interjection.] 
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1 MR. RAMIREZ: And the other way, it 

2 sounded like there was at least two that if it 

3 was Chicago versus Denver, that it would have to 

4 be a GoToMeeting, which was Isabel and Michael. 

5 Was there anyone else that if it was in 

6 Chicago, then you would have to do a GoToMeeting 

7 then? 

8 [Inaudible interjection.] 

9 MR. RAMIREZ: No, no. Rob would go to 

10 Chicago. 

11 MR. TOMPOS: Dave Tompos. I favor 

12 Chicago as well. 

13 MR. RAMIREZ: What do you think, Eileen? 

14 Well, let me ask Joe. All right. So 

15 we're looking at the 23rd and 24th. But, Joe, 

16 which has better facilities? 

17 MR. HAGERMAN: Colorado. 

18 MR. RAMIREZ: Let's do Colorado then. 

19 All right? 

20 MS. HOFFMAN: Joe, you'll be in charge of 

21 getting the facilities. And you're also 

22 recommending where to stay. 
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1 MR. RAMIREZ: Joe is saying that they 

2 have better facilities over in Colorado. 

3 MS. HOFFMAN: Can you fly in that 

4 morning? You can get -- no. You have to go the 

5 night before. Okay. 

6 MR. HAGERMAN: Well, it depends on the 

7 start time, right? 

8 MR. LUTER: Yeah. It's a little bit of a 

9 hike from the airport over to Golden. 

10 MR. RAMIREZ: It is? 

11 MR. LUTER: Not as convenient as D.C. in 

12 that regard. The meeting would be at NREL? 

13 MR. HAGERMAN: The meeting would be at 

14 NREL. 

15 MR. LUTER: Yeah, it's about 50 minutes 

16 from the airport, 50 minutes to an hour from the 

17 airport. 

18 MR. RAMIREZ: You could take longer than 

19 that in traffic in Chicago. 

20 [Laughter.] 

21 MR. RAMIREZ: Isabel, you had something? 

22 MS. DICKENS: Yeah, I just thought we 
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1 could meet at the airport and carpool. 

2 MR. LUBLINER: I really think it would be 

3 -- since we're talking about energy efficiency, I 

4 think it would be a really good learning exposure 

5 for a lot of people to tour the National 

6 Renewable Energy Lab there. It's quite 

7 impressive and might kind of sensitize us to some 

8 of the discussions we're having about energy and 

9 the opportunities here. 

10 So that's my plug on a value system 

11 basis. 

12 MR. RAMIREZ: Okay. I think that will 

13 have to be an optional field trip at the end of 

14 our meetings, right? But I would sign up for it 

15 if we did. 

16 Okay. So then we're looking at Thursday17 Friday in Denver. We'll get out those details, 

18 the 23rd and the 24th. 

19 [Pause.] 

20 MR. RAMIREZ: Yeah. Okay. So then -- 

21 MS. HOFFMAN: Are we going to 

22 tentatively, for tickets purposes, say it's nine 
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1 to five or nine to three? Nine to five the first 

2 day, nine to three on a Friday? I don't know. I 

3 just think we might want to -- 

4 MR. HAGERMAN: I think for flights out, 

5 back to D.C., we'd have to leave the facility 

6 around noon or one to make the direct back. 

7 MR. RAMIREZ: Yeah. That's going to make 

8 for a pretty short meeting that day. 

9 MS. DICKENS: We could start early. 

10 MR. EZZO: We could start at eight. 

11 MS. DICKENS: We could start an hour 

12 earlier on Friday, since West Coast people 

13 wouldn't be as impacted by an 8:00 a.m. start as 

14 we would be if we had an 8:00 a.m. start in D.C. 

15 and they were on the phone. An 8:00 a.m. start 

16 in Denver would be okay, I think, for anyone who 

17 is on the phone, as well as who was there in 

18 person. 

19 MR. EZZO: How about starting early on 

20 both days and ending early on Friday? 

21 MR. RAMIREZ: So, a marathon session on 

22 Thursday, the 23rd. 
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1 MALE VOICE: Eight to six. 

2 MR. EZZO: Yeah, that's helpful for 

3 people flying out on Friday. 

4 MR. RAMIREZ: And then eight to noon on 

5 Friday. So eight to six on the 23rd, eight to 

6 noon on Friday. 

7 MR. WEISS: So is there a shuttle? 

8 [Cross-talk.] 

9 MR. RAMIREZ: Okay. All right. Anything 

10 else before we open the floor for public comment? 

11 [Pause.] 

12 MR. RAMIREZ: All right. Any public 

13 comment? 

14 All right, Rick. Rick you could just use 

15 the mic there. Just turn that one on. 

16 MS. HOFFMAN: Just identify yourself. 

17 MR. MENDLEN: Rick Mendlen. I'm just 

18 going to sit. 

19 I've been listening very attentively for 

20 the last couple of days. And the one thing 

21 that's on our front page in the HUD code is 

22 affordability. 
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1 I got to say -- and unfortunately, Rob 

2 left before I could get this out. I really do 

3 appreciate his efforts and his thoughts about 

4 having this sort of a two-tier product type. But 

5 I am extremely concerned, as is my manager, about 

6 some kind of a dual -- enforcing a dual set of 

7 requirements. 

8 Call them product types, call them 

9 whatever you are. We're going to have enough 

10 trouble integrating between the two agencies on 

11 one enforcement mechanism or a dual-enforced 

12 mechanism that's going to work effectively. 

13 And complicating it with yet another set 

14 of requirements that have to be evaluated by this 

15 system I think is asking for more trouble than 

16 our agency wants to deal with, I can tell you. 

17 Thank you. 

18 MR. RAMIREZ: Okay. All right. 

19 MR. MENDLEN: Also, I can't make the 

20 meeting because I'm committed to see my 

21 grandchildren on the 23rd. 

22 MS. HOFFMAN: What about the other day? 
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1 Will you be on phone? 

2 MR. MENDLEN: I think I'll be on a plane. 

3 MS. HOFFMAN: Oh, okay. 

4 MR. RAMIREZ: Okay. Then, that's it, and 

5 we'll have our communications back and forth. As 

6 soon as we get data, as we have been, we'll send 

7 it out as soon as possible. And as soon as you 

8 can get something to Joe, the better. So that 

9 way we could -- 

10 MS. HOFFMAN: And if we want to do that 

11 conference call, we'll get back to you about that 

12 as well. We understand not the 16th. But it 

13 might be later that week. 

14 MR. HAGERMAN: And I would just like to 

15 say for DOE, we really appreciate your time and 

16 your commitment and your hard work at helping us 

17 all come up to this consensus standard. So we 

18 appreciate everything you're doing for us. 

19 MS. HOFFMAN: Want to thank you all. 

20 Thank you. 

21 [Whereupon, at 4:22 p.m., the conference 

22 concluded.] 
331 

1 CERTIFICATE OF NOTARY PUBLIC 

2 I, Oscar Johnson, Notary Public in and 

3 for the District of Columbia, the officer before 

4 whom the foregoing testimony was taken, do hereby 

s certify that the testimony which appears in the 

6 foregoing transcript was taken by me and 

7 thereafter reduced to typewriting under my 

s direction; that said testimony is a true record 

9 of the testimony given; that I am neither counsel 

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1s outcome of the action. 

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