1

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### U.S. Department of Energy 1

2

3

4

5 

### Manufactured Housing Working Group 6

7

8

9 

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

### Wednesday, September 10, 2014 11

12 

### 1000 Independence Avenue, S.W. 13 

### Washington, D.C. 20585 14

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### CONTENTS 1


### PAGE 2 

### MANUEL SANTANA, Subcommittee Report 7 3 

### MICHAEL EMANUEL LEVY, Recommendations 104 4 

### RICHARD MENDLEN, Public Comment 328 5

6

7

8

9

10

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

### MS. HOFFMAN: Good morning. This is our 2 

### second day of meetings this week for the 3 

### Manufactured Housing Working Group, chartered by 4 

### ASRAC to look at energy efficient standards for 5 

### manufactured housing, sponsored by the Department 6 

### of Energy. 7 

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

### my co-facilitators. 9 

### MR. BANTLE: Ted Bantle. 10 

### MR. RAMIREZ: And Javier Ramirez. 11 

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

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

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

### Thank you. 15 

### MR. WEISS: Mark Weiss, MHARR. 16 

### MS. EPPERSON: Stacey Epperson, Next Step 17 

### Network. 18 

### MR. ROY: Robin Roy, Natural Resources 19 

### Defense Council. 20 

### MR. WALKER: Matthew Walker, Navigant. 21 

### MS. VAIDYANATHAN: Kavita Vaidyanathan, 224

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### DOE General Counsel's Office. 1 

### MS. STARKEY: Lois Starkey, the 2 

### Manufactured Housing Institute. 3 

### MR. LACEY: Eric Lacey, Responsible 4 

### Energy Codes Alliance. 5 

### MR. UNGER: Lowell Unger, American 6 

### Council for an Energy Efficient Economy. 7 

### MR. BARBOUR: Ed Barbour, Navigant 8 

### Consulting. 9 

### MR. HAGERMAN: Joe Hagerman, DOE. 10 

### MS. HOFFMAN: Okay. Thank you. 11 

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

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

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

### us in 15 minutes. 15 

### Let me just read who I believe is on the 16 

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

### muted now? I'm muting them now. 18 

### Scott Drake from East Kentucky Power 19 

### Cooperative; Mark Ezzo, Clayton Homes; Richard 20 

### Hanger, Housing Technology Standards; Burt 21 

### Kessler, Palm Harbor Homes; Eric Lacey is here; 225

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### Michael Emanuel Levy, Systems Building Research 1 

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

### State University Extension Energy Program; Robert 3 

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

### Richard Potts, Virginia Department of Housing and 5 

### Community Development; Manual "Manny" Santana, 6 

### CAVCO Industries; Peter Schneider, Efficiency 7 

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

### Cavalier Home Builders; and Isabel Dickens. 9 

### Have I missed anyone? 10 

### [Inaudible interjection.] 11 

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

### completely garbled, but I think you were telling 13 

### us to mute our phones. 14 

### MS. HOFFMAN: That sounds good. I was 15 

### thinking it. 16 

### [Laughter.] 17 

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

### MR. HAGERMAN: That's Peter Schneider. 19 

### MS. HOFFMAN: Oh. Peter Schneider, would 20 

### you mute your phone, please? 21 

### And let's see. Are these folks on the 226

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### line? Members of the public, Robert Lucas, 1 

### Robert Preston. And are the other two not here 2 

### today? 3 

### MR. HAGERMAN: Is this Amy Barnard? 4 

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

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

### Michael Kociolek? 7 

### MS. HOFFMAN: Michael Kociolek and Amy 8 

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

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


### you are. 11 

### [Pause.] 12 

### MR. HUANG: David Huang, FMCS. 13 

### MS. PONTILLO: Pam Pontillo, Department 14 

### of Energy Office of Conflict Prevention and 15 

### Resolution. 16 

### MS. HOFFMAN: Okay. One more. 17 

### MR. MENDLEN: Rick Mendlen with HUD. 18 

### MS. HOFFMAN: Great. Thank you. 19 

### Okay. Javier has changed the agenda 20 

### based on what we discussed yesterday. And let me 21 

### turn it over to you, Javier. 227

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### MR. RAMIREZ: All right. So I guess 1 

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

### any comments from the working group members 3 

### before we get rolling into the continuation of 4 

### subcommittee reports? 5 

### [Pause.] 6 

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

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

### through what you and your subcommittee have been 9 

### able to put together on the 2015 IECC standard. 10 

### [Pause, audio feedback.] 11 

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

### that feedback? 13 

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

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

### will hopefully reduce the chance of that 16 

### happening. 17 

### MR. SANTANA: Okay. Well, my 18 

### subcommittee was tasked with going through 19 

### Section 4, which is the Residential Energy 20 

### Efficiency Section of the IECC and identifying 21 

### which sections are labeled specifically as 228

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### mandatory, and going through those to see which 1 

### ones we can agree can be included in the term 2 

### sheet for manufactured housing, and which ones we 3 

### can all agree should be excluded because they 4 

### don't apply one way or another. 5 

### By my count, we have there are 25 6 

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

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

### those were distributed in an email by Javier to 9 

### the group last week. So we should all have 10 

### those. 11 

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

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

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

### to go through each individual section? 15 

### MR. RAMIREZ: Yeah. If you could just 16 

### start from the beginning and walk us right 17 

### through it. 18 

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

### mention who was on your committee? 20 

### MR. SANTANA: Yeah, yeah. The committee 21 

### is a subcommittee. It was composed of Mark Ezzo, 229

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### Eric Lacey, Michael Luby, Mark Weiss, Burt 1 

### Kessler, and myself. 2 

### MS. HOFFMAN: Okay. Thank you. 3 

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

### able to agree that should be excluded from, 5 

### section R403. That deals with systems that serve 6 

### multiple dwelling units. Manufactured homes are 7 

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

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

### one that we were able to exclude. 10 

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

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

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

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

### going. 15 

### [Pause.] 16 

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

### was snow and ice system controls, which are 18 

### external to the manufacturing home, and then they 19 

### don't apply for that. 20 

### MR. RAMIREZ: Manny? 21 

### MR. SANTANA: Yeah. 2210

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### MR. RAMIREZ: Could you hold on one 1 

### second? I just want to make sure that everyone 2 

### is following along with you on the book. 3 

### Are you able to identify the page number 4 

### in the book? 5


### MR. SANTANA: Yes. 6 

### MR. RAMIREZ: Then pause and give the 7 

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

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

### what I should do is I should start at the 10 

### beginning. 11 

### So, section 4, Chapter 4 of the 12 

### residential portion of the IECC deals with -- 13 

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

### residential section. So we're only concerned 15 

### with the residential right now. 16 

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

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

### reads that it gives you three ways to comply with 19 

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

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

### mandatory provisions of R401 through R404. And 2211

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### those are the ones that we're trying to hit. 1 

### Because even if you look at item 3, it 2 

### allows you to prove compliance using the approach 3 

### in section 406. 406 also requires you to meet 4 

### the mandatory provisions that are specified in 5 

### 401 through 404. 6 

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

### went through the mandatory provisions, and we're 8 

### trying to identify which ones we can just ignore 9 

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

### all agree are okay and include in any final term 11 

### sheet. 12 

### Are we all on the same page? 13 

### MR. RAMIREZ: Okay. Yeah. 14 

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

### going to start with the first mandatory 16 

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

### mandatory provision that we could -- that we 18 

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

### on page R-36. 20 

### [Pause.] 21 

### MR. SANTANA: So, R403.8 on page R-36 is 2212

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### titled Systems Serving Multiple Dwelling Units. 1 

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

### easy one to exclude. 3 

### Okay. Moving on, R403.9, also on page R4 

### 36, is titled Snow Melt and Ice Control Systems, 5 

### or Ice Systems Controls. 6 

### And it deals with pavement temperature. 7 

### And so, this is control systems which are 8 

### external to the home. And these energy standards 9 

### should really be concerned with what affects the 10 

### dwelling. That's what the manufacturers' concern 11 

### is. Everything outside is outside of our scope. 12 

### So we excluded it for that reason. 13 

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

### one deals with pools and permanent spas. And 15 

### that goes without saying. And that incorporates 16 

### the subparts of our 403.10. So that includes 17 

### 403.10.1 through 403.10.4, which all deal with 18 

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

### they don't apply to MH. 20 

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

### with portable spas. And so that was easy to 2213

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### exclude as well. 1 

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

### on to the questions that you have included, which 3 

### would be next, correct? 4 

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

### back to Chapter 1. 6 

### MR. RAMIREZ: Okay. 7 

### MR. SANTANA: Which deals with scope and 8 

### administration. But what did you want to add? 9 

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

### do that. 11 

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

### that we realized when we -- we realized that 13 

### sections of Chapter 4 are labeled as mandatory. 14 

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

### mandatory, but still apply to the entire section. 16 

### So then they are mandatory, for all intents and 17 

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

### well. 19 

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

### going off of the mandate that DOE was tasked 21 

### with, developing energy standard based on the 2214

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### IECC. So then we -- you know, the entire IECC's 1 

### residential section was fair game, in our mind, 2 

### in our collective mind. 3 

### Anyway, Chapter 1 deals with scope and 4 

### administration. And we went through it and 5 

### agreed that, although we believe that an MH scope 6 

### and administration chapter may need to be 7 

### developed, Chapter 1 as it stands right now can 8 

### be excluded in its entirety, because it deals 9 

### with the local infrastructure and doesn't 10 

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

### infrastructure that HUD code units deal with. 12 

### We would have done more with sections 2 13 

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

### obviously either include or exclude. 15 

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

### sections that we could include. 17 

### MR. RAMIREZ: Okay. 18 

### MR. SANTANA: Turn it from mute in case 19 

### you want to interject. 20 

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

### to go back to those items on exclusion. I want 2215

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### to see if there's any discussion on them, because 1 

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

### consensus that everyone is okay with excluding 3 

### those that the subcommittee had already, through 4 

### consensus, agreed to. 5 

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

### with excluding these, let's have some discussion 7 

### on them. So, what questions or concerns might 8 

### you have with excluding those? 9 

### [Pause.] 10 

### MR. RAMIREZ: Or the subcommittee did a 11 

### great job. 12 

### MR. POTTS: This is Richard Potts. 13 

### MR. RAMIREZ: Go ahead. 14 

### MR. POTTS: You can hear me? 15 

### MR. RAMIREZ: Yeah. 16 

### MR. POTTS: Like Manny said, I think 17 

### those are no-brainer exclusions. Unless we have 18 

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

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

### ahead. 21 

### MR. RAMIREZ: Okay. So I believe what 2216

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### you're saying is that in your opinion, it's easy 1 

### to exclude those that have been identified, 2


### correct? 3


### MR. POTTS: Correct. 4 

### MR. RAMIREZ: Eric, did you have 5 

### something? 6 

### MR. LACEY: Eric Lacey from RICA. 7 

### I was just going to add that we would 8 

### delete this on the assumption that there are 9 

### already, you know, kind of administration 10 

### requirements in the HUD code. 11 

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

### retrofit these to fit that, that we should 13 

### probably start with the HUD administrative 14 

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

### don't think anybody opposed to deleting this. 16 

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

### case, this is potentially your first live 18 

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

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

### that Manny and the subcommittee have identified 21 

### as sections that can be excluded. Let's see a 2217

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### show of thumbs. 1 

### [Pause.] 2 

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

### voting members that are on line, if anyone is 4 

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

### assuming that your thumb is either up or 6 

### sideways. 7 

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

### objectionable; if you have any objection. 9 

### MR. RAMIREZ: Thank you. 10 

### [Laughter.] 11 

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

### that was a unanimous approval to exclude those 13 

### sections. Okay? 14 

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

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

### section? 17 

### MR. SANTANA: Okay. So that the next 18 

### sections are ones that we feel can be included in 19 

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

### recommending that to the working group as a 21 

### whole. 2218

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### So, starting with section 403.1, 403.1 is 1 

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

### [Pause.] 3 

### MR. SANTANA: Okay. Assuming that gives 4 

### enough time, this section requires at least one 5 

### thermostat to be provided for each separate 6 

### heating and cooling systems. We had some 7 

### discussions on pros and cons. And all came to 8 

### agreement that this would be fine for MH. We 9 

### don't believe that anybody would have an issue 10 

### with this being a mandatory requirement. 11 

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

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

### are there any questions or concerns for 403.1 14 

### that we would want to discuss before we gauge the 15 

### consensus for approval to include it in the 16 

### whole? 17 

### Yeah, Mark. 18 

### MR. WEISS: Thank you. Mark Weiss, 19


### MHARR. 20 

### I'll just repeat here what I said during 21 

### the subcommittee meeting when we discussed, 2219

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### quote-unquote, "including these provisions." And 1 

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

### these provisions -- and this is a clarification 3 

### -- putting these provisions on the table for 4 

### consideration by the committee. 5 

### That is subject, however, to relevant 6 

### cost analysis with respect to each one of these. 7 

### So in other words, in terms of their potential 8 

### technical applicability to this exercise, I don't 9 

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

### each one of these, their ultimate inclusion is 11 

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

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

### want to look at what the absolute total final 14 

### result is before you give the ultimate approval? 15 

### Is that it? 16 

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

### based on the input from the technical folks, I 18 

### don't have a problem with saying these provisions 19 

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

### These provisions of the 2015 IECC should be 21 

### considered as part of what we're doing. 2220

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### Their ultimate acceptability, however, 1 

### also has to address their cost impact. So what 2 

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

### any of these ultimately would have to also factor 4 

### into cost. 5 

### I don't think that should be a 6 

### controversial position. 7 

### MR. RAMIREZ: Okay. 8 

### MR. LEVY: Javier? 9 

### MR. RAMIREZ: Yeah. 10 

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

### comment here. 12 

### MR. RAMIREZ: Okay. 13 

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

### I think it would be nice to be able to do cost15 

### benefit analysis on a lot of these items. 16 

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

### them individually, we can talk about them on this 18 

### basis, that we'll be able to come up with energy19 

### savings figures. We may have to rely upon our 20 

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

### couple of these, I'm skeptical we'll be able to 2221

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### come up with real data. 1 

### And also, there are a few items here 2 

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

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

### talk about later could supersede whatever 5 

### decision we make now as a group. 6 

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

### that does happen and it does impact something 8 

### that the group has already reached consensus on, 9 

### then the group would just have to make us aware 10 

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

### MR. LEVY: Thank you. 12 

### MR. HAGERMAN: This is Joe Hagerman. 13 

### I was just wondering if some of the 14 

### manufacturers, as we go through these, could 15 

### comment whether or not, you know, these are 16 

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

### first one, I would assume that you ship a 18 

### thermostat with the furnace, right? Else you 19 

### can't use the furnace, right? 20 

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

### already do this. Or it's already in the HUD 2222

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### code." And that might speed things up. 1 

### MR. LUTER: This is Robert Luter. 2 

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

### recommendation for inclusion of R403.1, for 4 

### example, include subordinate clauses? Because 5 

### that entire clause not only says one thermostat 6 

### should be provided, which is very reasonable, and 7 

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

### time. 9 

### But R403.1.1 says it has to be a 10 

### programmable thermostat, with some specific 11 

### operational attributes, which may not be done. 12 

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

### can answer that in terms of what the subcommittee 14 

### considered. 15 

### What the subcommittee considered was that 16 

### if the section that was mandatory would be titled 17 

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

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

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

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

### did not talk about R403.1.1. 2223

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### So when the subcommittee recommends that 1 

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

### ones stand alone. And if they are inclusive, 3 

### then we would state so. 4 

### MR. LUTER: Right. Thanks for that 5 

### clarification, Manny. 6 

### MR. RAMIREZ: Okay. Lois? 7 

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

### last time. But in my discussions with my 9 

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

### that we were doing this exercise and putting this 11 

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

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

### know, because it's only partial. 14 

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

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

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

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

### standard, but they should be included in an 19 

### overall standard that we will be coming to 20



### consensus on. 21 

### Does that make sense? 2224

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### MR. RAMIREZ: Um-hm. 1 

### MS. STARKEY: Because there might be some 2 

### things that we might look at and it might get 3 

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

### well. 5 

### So I just want to make it clear that, 6 

### from my perspective, and I think MHI's 7 

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

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

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

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

### a whole. 12 

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

### to try and eliminate some confusion then, we 14 

### probably should not do a consensus vote on these, 15 

### at least reaching an agreement that, yeah, these 16 

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

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

### gauge the consensus on this for a final approval. 19 

### Okay? But at least we get an 20 

### understanding of what it is we're doing. 21 

### MR. WEISS: Yeah. And my understanding 2225

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### is this is essentially a technical exercise to 1 

### determine which sections are potentially 2 

### applicable here and should be considered versus 3 

### those that are not applicable and we can 4 

### essentially discard from our analysis. 5 

### And then once we have that understanding, 6 

### then the analysis goes on from there to the other 7 

### issues. 8 

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

### clarify that on the exclusion -- 10 

### MS. HOFFMAN: There's agreement on the 11 

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

### It's Eileen Hoffman. 13 

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

### comment about all this. 15 

### On the subcommittee, Mark Weiss brought 16 

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

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

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

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

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

### flagging that. 2226

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### So we have -- we probably need to have 1 

### some column on our spreadsheet when we come to an 2 

### item and we all say, or the subcommittee has 3 

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

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

### be costed and it needs to be included in anything 6 

### Navigant is performing, where they're showing, 7 

### you know, the initial cost to the consumer. 8 

### And in this particular section, so, for 9 

### instance, like Manny said, the section is 10 

### Controls, 403.1. And it talks about thermostats 11 

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

### we think that should be included. 13 

### Joe, to your question, manufacturers are 14 

### doing that on every home already today. So I 15 

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

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

### already doing this. Thermostats are required in 18 

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

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



### one. 21 

### But the subpart under that that says you 2227

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### got to have a programmable thermostat, that's 1 

### where Manny pointed out that that section, that 2 

### subsection is not necessarily part of what we're 3 

### recommending be included. 4 

### And if it were, okay, because 5 

### programmable thermostats are not part of the HUD 6 

### code currently, if we did have that as something 7 

### that the subcommittee says that we want to 8 

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

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

### on." 11 

### But in this case, since the committee is 12 

### not recommending the programmable thermostat, 13 

### that we're only mentioning the thermostat part, 14 

### that I think we could probably put this one up 15 

### for vote right now. 16 

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

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

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

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

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

### and get it done? 2228

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### MR. SANTANA: Right, and I agree. And I 1 

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

### approaching this, is that we're submitting items 3 

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

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

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

### that's a good idea. 7 

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

### I think that the HUD code even requires that. 9 

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

### specific requirements. Like, you know, for 11 

### controls, it just says, if you include an 12 

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

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

### You know, HUD doesn't specify what kind 15 

### of thermostat or how expensive. But we will do 16 

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

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

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

### to be mandatory provisions, which are going to 20 

### probably apply to any path that we ultimately 21 

### agree on, or agree to. 2229

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### You know, if we could identify general 1 

### statements that we can vote on and then have as 2 

### part of a final potential term sheet, then I 3 

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

### if there is anything that we thought could have 5 

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

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

### definitely. 8 

### MR. RAMIREZ: Okay. Mark? 9 

### MR. WEISS: Mark Weiss, MHARR. 10 

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

### and if anything is constructive, as Mark Ezzo 12 

### suggested, to flag items where we believe there 13 

### will be no cost impact, based on the information 14 

### that we have at this point. 15 

### I do have a problem with taking piecemeal 16 

### votes on parts of this, even if the current 17 

### thinking is that it will have no impact until we 18 

### see the entire broader package. If any votes we 19 

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

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

### I'd be very hesitant to start trying to nail down 2230

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### a consensus right now, piecemeal, based on the 1 

### current state of the record. 2 

### MR. RAMIREZ: Lois. 3 

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

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

### groups, the ANSI groups do and just agree 6 

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

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

### on any of those committees. 9 

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

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

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

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

### "no impact." 14 

### Maybe on the side of each, instead of 15 

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

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

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

### know which ones we have to look at. 19 

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

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

### either. I'm uncomfortable with that in terms of 2231

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### taking votes. 1 

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

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

### specific items, if the subcommittee folks, the 4 

### technical folks think there is no cost impact, 5 

### particularly because if something that's already 6 

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

### duly noted. 8 

### That's a pretty good indication that 9 

### probably there is not going to be any cost 10 

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

### rather than trying to nail down consensus right 12 

### now on each particular item. I would simply flag 13 

### that as following up basically on Joe's 14 

### suggestion earlier. 15 

### MR. RAMIREZ: What about having an 16 

### exclusion, and the only exclusion or the only 17 

### thing that could overturn a consensus would be 18 

### that if there is a cost impact that the group 19 

### would say is not acceptable, right? 20 

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

### here is that, "Hey, look. It's reviewed. The 2232

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### group, the subcommittee is saying, "Yeah, it's 1 

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

### the only thing then later that would overturn it 3 

### if the cost associated with it was not tolerable. 4 

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

### bunch of other stuff, and we could start 6 

### narrowing the focus. 7 

### Yeah, Mark. 8 

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

### have some technical consultations I need to do. 10 

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

### think those will result in changing what the 12 

### technical folks on this committee have said. But 13 

### I'd be reluctant to do that. 14 

### MR. RAMIREZ: Is someone on the phone? 15 

### [Pause.] 16 

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

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

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

### least agree that there is no agreement, right? 20 

### But some conclusion. 21 

### And if we can't start to narrow stuff 2233

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### down, we're never going to get there or it's 1 

### going to take too long to get there. 2 

### And I understand the concern of the 3 

### overall. You know, the affordability is front 4 

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

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

### associated with it is not acceptable by the 7 

### committee, for that reason alone then could we 8 

### overrule a consensus. 9 

### MR. LUTER: This is Rob at Lippert. 10 

### Are we not discussing just whether or not 11 

### to include these are part of the conversation? 12 

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

### what I'm getting at. 14 

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

### to thank the committee, who worked very hard on 16 

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

### charge was, what in the IECC 2015 code concerns 18 

### manufactured housing, and what do we have to deal 19 

### with? 20 

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

### agreed on, approved your exclusions. And now 2234

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### we're talking about your inclusions. 1 

### Now, obviously, some of them are going to 2 

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

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

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

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

### consensus that we ought to talk about these 7 

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

### ought to clarify the inclusion or exclusion of 9 

### subordinate clauses just as a matter of 10 

### recordkeeping. 11 

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

### what was muddying it up there, right? 13 

### MR. WEISS: Yeah. 14 

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

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

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

### Manny? 18 

### MR. SANTANA: Yeah. 19 

### MR. RAMIREZ: And the reason that those 20 

### others were not in here was because there may be 21 

### some cost or further discussion that you would 2235

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### have to have on them, correct? 1 

### MR. SANTANA: That's exactly correct. 2 

### MR. RAMIREZ: Yeah. So these are the 3 

### ones that the group -- 4 

### MS. HOFFMAN: These are the easy ones. 5 

### [Laughter.] 6 

### MR. RAMIREZ: Yeah, that the group would 7 

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

### Either yeah, these should be included fairly 9 

### easily because it has none or very minimal cost 10 

### impact." 11 

### MR. LUBLINER: This is Mike Lubliner. 12 

### MR. RAMIREZ: Yeah. 13 

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

### what Joe originally noted and Mark Ezzo 15 

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

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

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

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

### really deal with the more controversial stuff. 20 

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

### get anywhere with this committee. So I have some 2236

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### concern. I support what Mark said. 1 

### Thermostats, everybody puts a thermostat 2 

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

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

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

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

### drawn out. 7 

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

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

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

### hear you. 11 

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

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

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

### cost impact, or an energy savings impact, that 15 

### needs to be noted and discussed with the full 16 

### committee. 17 

### I also think it's important that not only 18 

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

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

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

### the status quo, or it's being offered as an 2237

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### option, like a thermostat that's programmable or 1 

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

### minimum code. 3 

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

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

### Is it something that's required in the minimum 6 

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

### and is there an energy savings implication? 8 

### So those are my two points. Thank you. 9 

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

### Isabel, then Mark. 11 

### MS. DICKENS: Thanks, Javier, this is 12 

### Isabel Dickens, NMHOA. 13 

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

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

### to the extent that we can we should start to 16 

### practice having consensus on some of these 17 

### issues. 18 

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

### Javier, you talked about how you eat an elephant 20 

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

### elephant? You add the tusks. You create a 2238

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### trunk. You add a tail. You create some, you 1 

### know, legs and feet, whatever. 2 

### I think we can start to build our 3 

### picture, our jigsaw puzzle, and put the pieces 4 

### together so that we end up with our ultimate term 5 

### sheet. 6 

### And I know there may be things that we 7 

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

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

### quite be the proxy model, it will be the 10 

### consensus term sheet, whatever we want to call 11 

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

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

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

### things if we don't start to actually practice 15 

### consensus and put them somewhere, save them 16 

### somewhere so that we have them for the ultimate 17 

### product, ultimate term sheet. 18 

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

### this could be a fairly easy one to get consensus 20 

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

### Let's just practice consensus and -- because 2239

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### otherwise, we aren't going to get everything done 1 

### within the timeline that we're supposed to. 2 

### Thank you. 3 

### MR. RAMIREZ: Thank you. 4 

### Mark? 5 

### MR. WEISS: Yeah. Thanks, Isabel. 6 

### I think perhaps the greatest danger to 7 

### achieving consensus is trying to eat the elephant 8 

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

### whole extended discussion. I was just trying to 10 

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

### in terms of voting on the subcommittee, voting 12 

### here today. 13 

### And essentially, the way I see it is 14 

### there are two aspects to this. You have the 15 

### technical aspect. What parts of the IECC 16 

### mandatory provisions simply are not applicable or 17 

### appropriate for manufactured housing and are 18 

### excluded? And which sections are potentially 19 

### applicable and potentially relevant and something 20 

### we want to consider? And those are, quote21 

### unquote, "included." 2240

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### When you start getting into cost, that 1 

### gets into all sorts of judgments and into other 2 

### data and values that are not directly relevant to 3 

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

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

### we're putting out. 6 

### Once we decide what's on the table and 7 

### what we're going to consider for the ultimate 8 

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

### be applied to those sections and considered 10 

### individually or cumulatively or however they need 11 

### to be considered. 12 

### But to start getting into cost now and 13 

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

### presents a problem. 15 

### I'll leave it at that for now. 16 

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

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

### on in your 403.1 is 403.1, not 403.1.1 or 19 

### 403.1.2.? 20 

### MR. SANTANA: Exactly. 21 

### MR. RAMIREZ: Okay. 2241

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### MR. SANTANA: Yeah. It's only 403.1. So 1 

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

### one thermostat should be provided for each 3 

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

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

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

### you want it on or off. 7 

### MR. RAMIREZ: Okay. Got you. 8 

### Mark? 9 

### MR. WEISS: I just thought of the one 10 

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

### I don't have any objection whatsoever to 12 

### flagging what is current practice and-or 13 

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

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

### that should be flagged and considered by the full 16 

### committee. So I have no problem with that at 17 

### all. 18 

### MR. RAMIREZ: Lowell? 19 

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

### prolong this. But I heard Manny say what seems 21 

### contradictory things on the last question of 2242

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### what's included. But for 403.1, 403.1.2 is also 1 

### mandatory. So I had understood that that was 2 

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

### mandatory. 4 

### MR. RAMIREZ: Okay. 5 

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

### 403.1.2 was included in consideration. It wasn't 7 

### included in a recommendation, because we didn't 8 

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

### consensus, you know, because there was cost 10 

### impacts and other stuff. 11 

### So anything mandatory, the working group 12 

### or the subcommittee considered. But just, we 13 

### only presented stuff that we can agree to. 14 

### And, you know, I will say that the 15 

### subcommittee is composed of a kind of a cross 16 

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

### all one faction, you know. Not everybody voted 18 

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

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

### down. So it allowed us to present. 21 

### MR. UNGER: So that gets to my second 2243

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### question, which was, there's still this list, as 1 

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

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

### was on that. 4 

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

### understand the two lists. I had understood that 6 

### the third list of 15 were items that are relevant 7 

### to manufactured housing, but there wasn't 8 

### agreement that they should be part of the 9 

### standard, in which case that would mean to me 10 

### that the subcommittee is recommending for this 11 

### list of 10 or so items that they are both 12 

### relevant and should be included. 13 

### But am I misunderstanding that? 14 

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

### is between these two lists. 16 

### MR. SANTANA: Okay. When you say 17 

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

### screen right now? 19 

### MR. UNGER: I mean it was my 20 

### understanding that there were 30-something 21 

### mandatory provisions. 2244

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### MR. SANTANA: Correct. 1 

### MR. UNGER: We already went through the 2 

### list of provisions which the subcommittee 3 

### believes are not relevant to manufactured 4 

### housing. 5 

### This is now the rest of them, presumably, 6 

### are -- my understanding -- are relevant to 7 

### manufactured housing. 8


### MR. SANTANA: Correct. 9 

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

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

### confused now, because some people are presenting 12 

### these as agreed that they're relevant. But 13 

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

### was relevant. 15 

### So I had understood that these were 16 

### agreed that they should be included. 17 

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

### Right, right. 19 

### So there's 25 sections which are labeled 20 

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

### those 25, we, the subcommittee, discussed all 25 2245

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### of them. 1 

### When anywhere where we could have either 2 

### uniform or a vast majority, or at least no 3 

### dissenting opinions on an item, then we either 4 

### regrouped them, which either exclude or include. 5 

### It was easier to exclude, because they obviously 6 

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

### not appropriate. 8 

### It was harder to include, because we had 9 

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

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

### consensus and are able to recommend. 12 

### The other items are still under 13 

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

### bit. But I understand. 15 

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

### "the subcommittee is recommending to include," 17 

### you mean the subcommittee is recommending that 18 

### these provisions be included in the manufactured 19 

### housing standard? 20 

### MR. SANTANA: To the working group. 21 

### Right, right. So the subcommittee is 2246

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### recommending to the working group that these 1 

### provisions either be included or excluded. Or we 2 

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

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

### and voted on by the working group. 5 

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

### these things -- the other sections, the 7 

### subcommittee won't be comfortable submitting them 8 

### without some kind of revision. 9 

### MR. UNGER: Right. Thanks, Manny. 10 

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

### subcommittee is allowed to continue its work, the 12 

### next submittal or the next set of recommendations 13 

### to the working group are going to be actual 14 

### sections that have modifications to them. 15 

### Make sense? 16 

### MS. STARKEY: Yes, yes. 17 

### MR. RAMIREZ: So this is the fruit that 18 

### you could grab without a stepladder? 19 

### [Laughter.] 20 

### MR. SANTANA: Exactly. We got this off 21 

### the ground. 2247

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### MR. RAMIREZ: Oh, okay. All right. 1 

### Good. 2 

### MS. STARKEY: Then I would suggest that 3 

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

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

### my members, to say items to include for 6 

### consideration in an MHI energy standard. 7 

### MR. RAMIREZ: And maybe I'm missing 8 

### something, but that's somewhat the reverse of 9 

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

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

### easily agree on, that these are included. 12 

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

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

### which states, "At least one thermostat shall be 15 

### provided for each separate heating and cooling 16 

### system," period. That's it. 17 

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

### question for Lois. 19 

### MS. STARKEY: Yeah. 20 

### MR. ROY: Am I hearing you right that 21 

### then it's some question about whether a heating 2248

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### and cooling system should have a thermostat? Is 1 

### there any question at all? 2 

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

### leaving it up to the technical people to decide 4 

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

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

### of a standard until we see the whole standard. 7 

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

### anymore, because it put it on the record that 9 

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

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

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

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

### But then somebody's going to come back 14 

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

### this." 16 

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

### MS. STARKEY: So I think everybody 18 

### understands that. I just want to make it clear 19 

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

### standard. 21 

### MR. SANTANA: This is Manny again. 2249

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### You know, one of the things that came up 1 

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

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

### section that might run counter to something that 4 

### Emanuel's proposing or something that Robin is 5 

### proposing? 6 

### So we were sensitive to that. And we 7 

### just thought, well, if something gets through our 8 

### little subcommittee and it comes to the main 9 

### working group, and it contradicts or conflicts, 10 

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

### bringing this up for discussion. 12 

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

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

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

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

### Mark. 17 

### MR. WEISS: Would it be possible just to 18 

### move things along to just call it "preliminary 19 

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

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

### because I think we can vote preliminarily and 2250

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### then say it's not binding. 1 

### MR. HAGERMAN: Joe Hagerman. 2 

### I agree with that, as long as we just 3 

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

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

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

### include the subordinate clauses. Or if it does, 7 

### we explicitly say it includes the subordinate 8 

### clauses. 9 

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

### numbers. If it does include subordinate ones, 11 

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

### that far left column. 13 

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

### PC, or preliminary consensus, for all of these 15 

### items once we go through that. Is that 16 

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

### move ahead. 18 

### And from our folks at home and on line? 19 

### MR. WEISS: Thumbs up. 20 

### MS. HOFFMAN: Okay. Preliminary 21



### consensus. 2251

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### MR. WEISS: We're going with preliminary 1



### consensus. 2 

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

### there any way you can scroll up on your screen 4 

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

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

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

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

### of our standing rules, I guess, unspoken. 9 

### But it only applies to the section. And 10 

### whenever it includes any of the subordinate 11 

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

### said there that exclusion includes everything 13 

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

### that distinction, though, yes. 15 

### MR. RAMIREZ: Thank you, Manny. 16 

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

### what Joe said. I think the more important thing 18 

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

### practice or not, or required by the HUD code 20 

### currently or not. 21 

### MR. RAMIREZ: Okay. So, 403.1, is this 2252

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### current practice? You could put a yes in there. 1 

### Okay. The PC for consensus is 403. 2 

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

### there preliminary consensus on that? 4 

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

### is no potential, additional potential cost 6 

### impact, right, of providing a thermostat? That 7 

### is current practice. So we'll talk about 8 

### additional costs. 9 

### Now, 403.1, that might be another story. 10 

### Is that -- 1.1. Is that accurate? 11 

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

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

### drawing that distinction then. So, 403.1, there 14 

### is no additional cost impact. It is the current 15 

### practice. Is that accurate? Mark? 16


### MR. SANTANA: Yes. 17 

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

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

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

### instead of two-by-four in this installation 21 

### versus that installation, or where it might be 2253

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### put and whether there's other labor or not. 1 

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

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

### current practice, not current practice -- HUD 4 

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

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

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

### package. 8 

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

### put that on the record and be quiet. 10 

### MR. RAMIREZ: All right. Good thing 11 

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

### [Laughter.] 13 

### MS. HOFFMAN: That elephant, a little 14 

### Tabasco works. 15 

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

### 403.3.2. 17 

### MR. SANTANA: Okay. 403.3.2 is on page 18 

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

### 403.3.2 includes the two exceptions. 20 

### This deals with the sealing of ducts, 21 

### filter boxes, and air handlers. We believe that 2254

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### the section can be included, but there's a 1 

### sentence there, if you see the second sentence of 2 

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

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

### We believe that sentence should be omitted. 5 

### [Pause.] 6 

### MR. LUBLINER: Manny, Mike Lubliner here. 7 

### Could you share with the group why you 8 

### believe that the provisions in the IMC and the 9 

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

### we didn't even look at those. 11 

### MR. SANTANA: Right. And you were going 12 

### to look at those, as I recall. 13


### MR. LUBLINER: Yes. 14 

### MR. SANTANA: The reason why I wanted to 15 

### omit that sentence is because it references 16 

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

### So including any kind of reference to another 18 

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

### keeping it in the spirit of generalizations, 20 

### generalities, right? 21 

### Duct air handlers and filter boxes shall 2255

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### be sealed -- that was the important concept. You 1 

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

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

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

### handlers? 5 

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

### MR. SANTANA: Right. 7 

### MR. LUBLINER: I guess my point there is 8 

### that we didn't look at whether there were 9 

### positive improvements if we adopted language in 10 

### the IRC or the IMC. I personally believe there 11 

### are with respect to the subject. 12 

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

### MR. SANTANA: That's correct. 14 

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

### that we're removing it just because the current 16 

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

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

### in there. I just want to clarify that. 19 

### MR. SANTANA: Right, right. 20 

### MR. LUBLINER: Okay. Thank you. 21 

### MR. SANTANA: We didn't get into the IMC 2256

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### or the IRC to see what exactly they require of 1 

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

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

### acceptable. 4 

### MR. LUTER: This is Rob at Lippert. 5 

### Aren't we tasked with evaluating this against the 6 

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

### other code that might exist? 8


### MR. SANTANA: Yes. 9 

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

### interject? Can I make a recommendation we drop 11 

### this discussion, because we're going to talk 12 

### about specific language later to supersede this 13 

### entire section? 14 

### MR. RAMIREZ: Okay, Eric? 15 

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

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

### As to the issue of referenced standards, 18 

### there are a number of standards referenced in 19 

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

### because the scope is focused on the IECC that we 21 

### can ignore all the standards that are referenced 2257

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### in the IECC. 1 

### In this case, I thought it made sense to 2 

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

### specific requirements in there, or add it to the 4 

### duct testing or other requirements, it would make 5 

### more sense to put the requirements right in the 6 

### standard rather than reference another code book. 7 

### But there are other labeling standards 8 

### and things that are referenced in here that I 9 

### think we should be evaluating and including. I 10 

### just wanted to include that. 11 

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

### going to be in one of your straw men? 13 

### MR. LEVY: That's right. 14 

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


### MR. LEVY: Yes. 16 

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

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


### straw men? 19 

### [Pause.] 20 

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

### All right. 403.3.5. 2258

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### MR. SANTANA: Okay. 403.3.5, that's on 1 

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

### building cavities. And it reads, "Building 3 

### framing cavities shall not be used as ducts or 4 

### plenums." 5 

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

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

### manufacturers that are currently using framing 8 

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

### believe this was going to be a cost issue. 10 

### MR. RAMIREZ: Okay. Is this the current 11 

### practice? 12 

### MR. SANTANA: We believe so, yes. 13 

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

### on this. 15 

### [Inaudible interjection.] 16 

### MR. RAMIREZ: That is the current 17 

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

### current practice. So if that is the current 19 

### practice, then in order to adopt this, there 20 

### would not be any additional costs, correct? 21 

### Mark? 2259

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### MR. WEISS: I had a question, if I can 1 

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

### aware of any approved designs that have anything 3 

### different than what these guys are saying? 4 

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

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

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

### still returning air through the undercut doors. 8 

### So it's possible. 9 

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

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

### will. 12 

### MR. RAMIREZ: So then, as far as 13 

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

### question mark? 15 

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

### current practice and a potential cost impact, I 17 

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

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

### MR. RAMIREZ: Okay. 20 

### Eric? 21 

### MR. LACEY: This is Eric with RECO. 2260

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### MR. LUBLINER: This is Mike Lubliner. 1 

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

### MR. LUBLINER: Okay. 3 

### MR. RAMIREZ: Go ahead, Eric. 4 

### MR. LACEY: Could I just suggest that on 5 

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

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

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

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

### But if all the manufacturers are saying 10 

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

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

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

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

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

### we may not need to. 16 

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

### and if there are lots of designs out there that 18 

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

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

### to check"? 21 

### MR. WEISS: That's fine with me. You can 2261

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### even put my name on there, so as -- they already 1 

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

### than digging through all this. 3 

### [Laughter.] 4 

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

### preliminary consensus on this item and we can 6 

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

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

### do today. 9 

### MR. LUBLINER: This is Mike Lubliner. 10 

### MR. RAMIREZ: Yeah, Michael. 11 

### MR. LUBLINER: Yeah. I had suggested 12 

### that, besides saying whether there's a cost 13 

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

### not there's an energy savings impact, because 15 

### costs cut both ways. 16 

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

### going to do that, this is clearly one where 18 

### you're going to get some potential significant 19 

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

### your duct work. 21 

### I'm just proposing that we also, if we're 2262

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### going to be tracking costs, first costs, saying 1 

### that the costs need to -- 2 

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

### think we got the gist of it. 4 

### MR. LUBLINER: Also, I support where Eric 5 

### has gone on his comment. Thank you. 6 

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

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

### Because it might actually -- 9 

### MR. UNGER: Yeah, just have cost and 10 

### savings collectively, and not try to be too 11 

### precise here. 12 

### MR. RAMIREZ: Okay. 13 

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

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

### you could delete that column. 16 

### [Pause.] 17 

### MR. SANTANA: Am I clear to continue? 18 

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

### both -- there's energy savings implications as 20 

### well as cost implications. 21 

### MR. RAMIREZ: Right. 2263

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### Okay. 403.4. 1 

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

### R-35. It deals with insulation for mechanical 3 

### system piping. Requires an R3 of insulation 4 

### whenever a piping for mechanical system has the 5 

### ability to convey fluids above 105 degrees 6 

### Fahrenheit or below 55 degrees Fahrenheit. 7 

### MR. RAMIREZ: And is that current 8 

### practice? 9 

### MR. SANTANA: I think that's current 10 

### practice, because the system would require that 11 

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

### R-403.4 does not include R-403.4.1. 13 

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

### you're under the understanding that that is 15 

### current practice? 16 

### MR. SANTANA: We believe it to either, 17 

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

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

### inclusion of mechanical systems in the plant that 20 

### would require this insulation. 21 

### MR. LUBLINER: Manny, Mike Lubliner here. 2264

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### One thing, I think you're right. If we 1 

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

### the factory and shipping it with the home, which 3 

### is starting to get done by some people in the 4 

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

### a half-dozen homes. 6 

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

### required that that refrigeration piping, the live 8 

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

### pump manufacturer's installation, right, 10 

### requirements. 11 

### So I think, by default, those kind of 12 

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

### the manufacture of the product, then you guys are 14 

### required to put it into that. 15 

### So I think, yeah, you're absolutely 16 

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

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

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

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

### believe, the HUD policy, that if something is 21 

### required in an installation manual by a 2265

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### manufacture of heating equipment, then you have 1 

### to comply with that. 2 

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

### the manufacturers can clarify that. Thank you. 4 

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

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

### Okay. We're okay with that one. 7 

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

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

### we could just go ahead and flag that now. 10 

### Whether the cost impact is to the manufacture or 11 

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

### be a cost impact for the consumer. 13 

### So now, what this says is, it requires 14 

### that not less than a certain percentage of the 15 

### lamps which are installed be high efficacy. 16 

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

### 401.1. 18 

### MS. HOFFMAN: That's 404.1. 19 

### MR. WEISS: Not point-four. 20 

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

### R-37. 2266

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### MR. RAMIREZ: All right, so -- 1 

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

### saying this is Peter. 3 

### The same lamp, we're talking about the 4 

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

### least-cost path to meet this requirement would be 6 

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

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

### MR. SANTANA: Right, it actually has two 9 

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

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

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

### fixtures are only able to take high-efficacy 13 

### bulbs. 14 

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

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

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

### bulbs. But typical screw-based compact 18 

### fluorescent bulbs are allowable with the typical 19 

### lamps that are already being used. 20 

### So, the incremental cost to meet this 21 

### standard, at the bare minimum, that is the least- 2267

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### cost approach, would be a very small incremental 1


### cost. 2 

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

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

### if you take -- one scenario is that a 5 

### manufacturer installs the exact same thing he 6 

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

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

### without any of the bulbs. 9 

### You know, so the cost would be incurred 10 

### by whoever installs the bulbs. But then an 11 

### argument can be made, should this requirement be 12 

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

### manufacturer if the manufacturer doesn't ship the 14 

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

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

### for enforcement. 17 

### MR. SCHNEIDER: Why are the bulbs not 18 

### included, Manny? 19 

### MR. SANTANA: Because they break. 20 

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

### Just a note to DOE on this one. We had 2268

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### some discussion about when the bulbs actually get 1 

### installed. Historically, DOE has assigned some 2 

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

### how much energy savings you get, given the 4 

### federal standards updating and so on, but I 5 

### thought I would just flag this for you on the 6 

### energy savings impact. 7 

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

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

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

### the manufacturer, do you assign those savings to 11 

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

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

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

### to think about. 15 

### MR. LEVY: It's Emanuel. 16 

### Manny, is it your intent here that this 17 

### provision only apply if the manufacturer 18 

### installed bulbs? And it not be construed to mean 19 

### the manufacturer must install bulbs? 20 

### MR. SANTANA: That is correct. 21 

### MR. LEVY: I wonder if we should add the 2269

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### language that "If the manufacturer installs 1 

### bulbs, then"? 2 

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

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

### program, the manufacture is technically still 5 

### responsible to the house up until the first sale. 6 

### So anything the dealer does to it, the dealer 7 

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

### standard. 9 

### And assuming this -- my statements are 10 

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

### HUD is going to be enforcing this or that the 12 

### existing HUD requirements are still going to be 13 

### enforced. 14 

### So, you know, to give you another 15 

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

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

### without any bulbs, and retailer, he installs the 18 

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

### does not install 75 percent high-efficacy lamps, 20 

### that home is out of compliance. And the 21 

### manufacturer is still responsible for that home. 2270

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### You know, but like I said, I don't want 1 

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

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

### state that it's not mandatory that the 4 

### manufacturer install the bulbs. You know, the 5 

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

### manufacturer install the bulbs. Don't know if 7 

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

### MR. LUTER: Manny, this is Rob. 9 

### Did I misunderstand you? You indicated, 10 

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

### You indicated there were two paths to compliance. 12 

### One was supplying 75 percent high efficacy, and 13 

### the other was supplying fixtures that would not 14 

### accept anything but high efficacy. Did I hear 15 

### that correctly? 16 

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

### way that I understand it. 18 

### You know, the bottom line is that the 19 

### code wants 75 percent of the permanently 20 

### installed lamps-slash-fixtures to be high 21 

### efficacy. Whether it's a fixture that will only 2271

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### accept high efficacy or whether it's, you know, 1 

### CFL's or screw-in type lamps. 2 

### MR. LUTER: Am I correct in assuming that 3 

### the permanent fixtures that will only accept 4 

### high-efficacy bulbs would also be a cost impact 5 

### versus a standard fixture? 6 

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

### That will be a cost impact to the manufacture. 8 

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

### which way this shakes out, whether the 10 

### manufacture furnishes bulbs, the dealer furnishes 11 

### bulbs, or the manufacturer furnishes high12 

### efficacy fixtures, there's going to be a cost 13 

### impact, period? 14 

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

### impact to the consumer whichever way this shakes 16


### out. 17 

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

### Thank you. 19 

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

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

### incremental cost. 2272

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### I mean, I use these GU-24 adaptors. If 1 

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

### you can take every fixture that you're currently 3 

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

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

### adaptor that screws into the socket of any 6 

### typical fixture that would just accommodate a GU7 

### 24 bulb. 8 

### I'm not suggesting we do that, because 9 

### ultimately, I don't think that you can access GU10 

### 24 compatible bulbs everywhere. We had them in 11 

### every hardware store in Vermont. But my guess it 12 

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

### But I'd be really interested to delve 14 

### into bulbs breaking all the time in homes that 15 

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

### surface ceiling dome fixture, and that home would 17 

### really have to be shaking and moving a lot for 18 

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

### would be interested in seeing the data on that. 20 

### MR. RAMIREZ: Eric? 21 

### MR. LACEY: This is Eric. 2273

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### And I hate to belabor the point here. 1 

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

### understanding of this section and how it 3 

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

### in any fixtures that will only accept high5 

### efficacy bulbs. 6 

### What it does is it gives you two options. 7 

### One is 75 percent of all the bulbs that are 8 

### installed shall be high efficacy, or 75 percent 9 

### of the total fixtures will have only high10 

### efficacy bulbs. That doesn't say "high-efficacy 11 

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

### them. 13 

### Basically, the bulbs in there, 75 percent 14 

### either of all the bulbs installed or all of the 15 

### fixtures have to have high-efficacy bulbs. Does 16 

### that make sense? 17 

### So, for example, if you have a chandelier 18 

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

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

### actually. You could either choose to have all 21 

### the bulbs in that chandelier be high efficacy and 2274

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### have that be part of your total 75 percent of all 1 

### the fixtures. 2 

### Or you could include those in the total 3 

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

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

### nothing in here requires you to put in a high6 

### efficacy fixture that wouldn't allow you to put 7 

### in a screw-in bulb. 8 

### MR. RAMIREZ: Let me just ask one 9 

### clarification question here. Maybe it's because 10 

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

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

### that has a chandelier. 13 

### [Pause.] 14 

### MR. RAMIREZ: But apart from that, so 15 

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

### bulb, aren't you at 100 percent? 17 

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

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

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

### manufacturer has the choice of how many bulbs to 21 

### screw in, if any. 2275

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### Mark? 1 

### MR. LUTER: This is Rob. 2 

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

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

### that Manny's original interpretation about 5 

### fixtures precluding the installation of anything 6 

### but high-efficacy bulbs is probably correct. 7 

### You don't write items into a code that 8 

### can easily be defeated. If they want high9 

### efficacy bulbs, and you can get around it by just 10 

### not furnishing them, nobody's going to furnish 11 

### them, because they cost more than standard 12 

### incandescents and they break. 13 

### MR. RAMIREZ: Mark? 14 

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

### have the 2015 code in front of me. 16 

### MR. WEISS: Mark Weiss, MHARR. 17 

### Eric -- all right. 18 

### When we talk about high-efficacy lamps, 19 

### we're talking about the whatchamacallit, neon, 20 

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

### Okay. Is that base different from the base of an 2276

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### incandescent bulb? No. Okay. 1 

### So, bottom line here, I think in all 2 

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

### ship them or whatever, given consumer 4 

### predilections, you're probably going to have them 5 

### taken out anyway when they get there, I would 6 

### expect. But in any event, thanks for answering 7 

### the question. 8 

### MR. LUBLINER: It's Mike Lubliner. 9 

### Our research suggests that most of the 10 

### bulbs are retained by the consumers, that there 11 

### are some consumers that will take them out. But 12 

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

### I do totally agree with you, though, 14 

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

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

### advisory committee members does it take to screw 17 

### in a light bulb?" 18 

### [Laughter.] 19 

### MR. LUBLINER: But if the manufacturer 20 

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

### talking about it? There's always going to be -- 2277

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### MR. WEISS: I was setting you up for 1 

### that, Mike. Thank you. 2 

### [Laughter.] 3 

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

### Ed McMahon, and Johnny Carson, thank you. 5 

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

### gauge the level of consensus on this one? 7 

### [Pause.] 8 

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

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

### [Pause.] 11 

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

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

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

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

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

### say the exact same thing. 17 

### [Pause.] 18 

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

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

### it's easy to defeat that clause. 21 

### MR. RAMIREZ: You mean comply with. 2278

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### Right? 1 

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

### leaving it in. 3 

### [Laughter.] 4 

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

### manufacturer or homeowner, in the interest of 6 

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

### compact fluorescents, or whatever they're selling 8 

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

### do it. 10 

### MR. RAMIREZ: Right. Okay. 11 

### [Cross-talk.] 12 

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

### the side. It makes no difference to me either 14


### way. 15 

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


### DOE. 17 

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

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

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

### member? 21 

### MR. RAMIREZ: And not only that, 405.2, 2279

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### and after this one, we'll take a break. 1 

### Okay. 405.2. Manny? 2 

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

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

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

### just realized earlier that 405.2 is outside of 6 

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

### 405, section 405 deals with another 8 

### alcoholic compliance path, you know. So what it 9 

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

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

### IECC, you still have to comply with the mandatory 12 

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

### are identified in 401.2, which fiddles you back 14 

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

### [Pause.] 16 

### MR. RAMIREZ: Did everyone follow that? 17 

### MS. HOFFMAN: Eileen Hoffman. 18 

### Are those the three compliance paths? 19 

### MR. SANTANA: Yeah. Yeah. 20 

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

### MR. SANTANA: And we'll call them 2280

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### "compliance paths" for lack of a better term. 1 

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

### titled "Compliance." 3 

### So you see there's three ways to prove 4 

### compliance, right? One is to go through sections 5 

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

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

### through R-404 labeled "Mandatory." 8 

### So that second item there, section R9 

### 405.2, requires the same thing. 10 

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

### interject here. 12 

### This whole section is under the 13 

### performance path. This is about setting up the 14 

### assumptions for the performance path. And we 15 

### talked about this as one of the possible paths. 16 

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

### revisit all these individual issues if we decide 18 

### to include a performance path. And I would 19 

### recommend that we table this. 20 

### This is a detail within the performance 21 

### compliance path, and I don't think we need to 2281

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### deal with it now. 1 

### [Pause.] 2 

### MR. DRAKE: I'll agree. 3 

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

### put on here, "Hold for compliance path 5 

### discussion"? 6 

### MR. SANTANA: I would agree with that. 7 

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

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

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

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

### little bit further discussion on where we go from 12 

### here with the 2015 IECC. 13 

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

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

### Okay. 16 

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

### thank the working group, sorry, the subcommittee 18 

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

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

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

### but I know how labor intensive it is to even get 2282

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### to what you all did, and I know there's more work 1 

### behind the scenes there. 2 

### Which goes to where I want to go next as 3 

### far as that subcommittee goes. Can you continue 4 

### with the work that you're doing? 5 

### I think that there might be some benefit 6 

### to bringing recommendations to the working group 7 

### rather than the working group having to work 8 

### through all of that initially and bringing those 9 

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

### do in probably a lot less time. 11 

### Is the subcommittee okay with continuing 12 

### to identify possible areas of agreement? 13 

### [Pause.] 14 

### MS. HOFFMAN: Manny? 15 

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

### the committee as a whole. But I will. 17 

### [Laughter.] 18 

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

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

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

### to kind of -- we had to pull back on the reins a 2283

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### little bit and try to keep the scope narrow. 1 

### Because I think the members saw the benefit to 2 

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

### expand our scope to other portions of the code 4 

### which we thought were important, but not 5 

### necessarily labeled "Mandatory." 6 

### So I think the membership would be in 7 

### agreement to continuing the work. You know, it 8 

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

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

### working group discussed here. 11 

### But we also, you know, recognized that if 12 

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

### something forward for the working group to 14 

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

### whole more time. 16 

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

### way to say that we think continuing is a good 18 

### idea. 19 

### MR. RAMIREZ: Okay, great. 20 

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

### more phone calls and more meetings with you and 2284

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### the working group before our next meeting. 1 

### MR. SANTANA: Yeah. 2 

### MS. HOFFMAN: Okay. 3 

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

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

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

### the record. You can work independently and then 7 

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

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

### a bigger group. 10 

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

### then, what guidance or assistance do you need 12 

### from the -- I'm sorry. 13 

### I'll ask the subcommittee, what guidance 14 

### or assistance do you need from the working group? 15 

### Whether it be any analysis or even just 16 

### direction? 17 

### Because I know that some of this really 18 

### is contingent on what compliance paths you're all 19 

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

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

### today, right? But what other assistance might 2285

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### you need? 1 

### [Pause.] 2 

### MR. RAMIREZ: I guess any of the 3 

### subcommittee members could chime in on that. 4 

### [Pause.] 5 

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

### speak up again. 7 

### I think, you know, as far as assistance 8 

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

### We're trying to tiptoe around the whole 10 

### compliance path options and focus on what's 11 

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

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

### a consensus on 10. 14 

### So, you know, just going through the 15 

### remainder of the mandatory provisions, and going 16 

### through the installation table, and definitions, 17 

### without even getting into the climate zones or 18 

### anything that might have an impact on what 19 

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

### going to keep us pretty busy. 21 

### MR. RAMIREZ: Okay. 2286

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### MS. HOFFMAN: Eileen Hoffman. 1 

### Does any other member of the working 2 

### group want something back? What would you like 3 

### to ideally see from the subcommittee for our next 4 

### meeting? Any guidance? Lois? 5 

### [Pause.] 6 

### MR. UNGER: This is Lowell Unger. 7 

### I was just going to say it seems to me 8 

### that we really wanted to come close to having a 9 

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

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

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

### do it are separate. 13 

### But there's just a lot of provisions 14 

### here. There's certainly a number of mandatory 15 

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

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

### have a prescriptive pass, that are also in the 18 

### prescriptive, that are required in the 19 

### prescriptive pass that we can't possibly deal 20 

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

### work it through. 2287

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### And so, I would really hope that the 1 

### subcommittee, by next meeting, could certainly 2 

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

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

### prescriptive path, to have a recommendation for 5 

### the full committee that these are the ones that 6 

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

### clearly identify. 8 

### Maybe there's one or two issues we need 9 

### to talk about, but not 50. 10 

### MR. RAMIREZ: Does that sound doable from 11 

### the subcommittee? 12 

### [Pause.] 13 

### MR. RAMIREZ: Lois? 14 

### MS. STARKEY: Just in terms of our 15 

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

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

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

### have a standard that ends up to be just a 19 

### prescriptive standard. 20 

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

### in the interests of time, as this -- as Manny's 2288

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### group goes through this, that there may be, we 1 

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

### performance path. 3 

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

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

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

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

### know, really get into it. 8 

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

### fundamental to what our industry does and the 10 

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

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

### recommended a code that was really the IRC. 13 

### MR. HAGERMAN: Just real quick, this is 14 

### Joe Hagerman. 15 

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

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

### whole group has been supportive of a prescriptive 18 

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

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

### a prescriptive path for the first time, sorry. 21 

### MS. STARKEY: We're spending an awful lot 2289

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### of time on the -- I just don't -- I just want to 1 

### be sensitive to time to make sure that we can 2 

### address the performance aspect. 3 

### MR. HAGERMAN: Absolutely. 4 

### MR. UNGER: This is Lowell. 5 

### Just that, I mean, what we have talked 6 

### about so far are provisions that apply for any 7 

### path. So it does include part of the performance 8 

### path, is all. 9 

### MS. STARKEY: Right, right, right. 10 

### MR. UNGER: Okay. 11 

### MR. RAMIREZ: Okay. Mark? 12 

### MR. WEISS: Mark Weiss, MHARR. 13 

### I just want to point out that the timed 14 

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

### arbitrary one. The only statutory deadline was 16 

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

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

### addressing this, but there is no deadline 19 

### prescribed in statute or regulation. 20 

### The only deadline is the September 30th 21 

### date picked by ASRAC, and if you go back to the 2290

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### notes, to the transcript of the June 6th meeting, 1 

### which I attended, there was no magic to that 2 

### date. 3 

### So I will reiterate what I said yesterday 4 

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

### more important that we get this right than we 6 

### necessarily blow through things that we should be 7 

### considering to meet some sort of arbitrary 8 

### deadline. 9 

### MR. RAMIREZ: You know, as a facilitator 10 

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

### caution that we do have until the end of 12 

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

### And if we do -- whether it was arbitrary 14 

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

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

### that. 17 

### And I think that the only way that we 18 

### would get approval, and hopefully John could talk 19 

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

### show that we are going to, in more likelihood 21 

### than not, reach a consensus on a term sheet for 2291

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### that extended period. Otherwise, what's the use 1 

### of prolonging it? 2 

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

### the group really, truly sees the big picture 4 

### here. 5 

### [Cross-talk.] 6 

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

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

### MR. RAMIREZ: Okay. 9 

### MR. ROY: This is Robin. 10 

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

### was being sensitive to the value of the folks' 12 

### time in this room and really being thoughtful 13 

### about how much they would be imposing on us. 14 

### I think they probably were also quite 15 

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

### industry and other interest groups that spent a 17 

### lot of time in this space, they have familiarity 18 

### with the nature of developing standards, that DOE 19 

### is working on a standard in parallel with the 20 

### work of this working group, and in parallel with 21 

### the work of ASRAC and that DOE has got all sorts 2292

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### of data sources. 1 

### This is very helpful in informing that. 2 

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

### sense in putting that time constraint, that 4 

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

### a strong view amongst ourselves that we have 6 

### something that's going to be a consensus that 7 

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

### I think they're trying to be sensitive to 9 

### us as opposed to imposing hard deadlines. 10 

### MR. RAMIREZ: Yeah. 11 

### MR. ROY: Because DOE is already going to 12 

### do this anyway. And their schedule is such. 13 

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

### Lois? 15 

### Mark, anything? Okay. 16 

### Okay, great. 17 

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

### Ezzo. Can I make a comment? 19 

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

### second. 21 

### [Pause.] 2293

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### MR. HAGERMAN: Yeah, so Robin is 1 

### absolutely correct. I mean, you know, this 2 

### committee has an expiration date. We can ask 3 

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

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

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

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

### extend this to the end of the year." 8 

### I think they would need something like, 9 

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

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

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

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

### reach a term sheet. 14 

### Absent of that, they're not going to 15 

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

### rule. 17 

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

### going to talk? 19 

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

### MR. RAMIREZ: Okay. 21 

### MR. EZZO: As part of Manny's 2294

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### subcommittee, and I'm on that, and to Lois's 1 

### point about performance approaches, in the IECC, 2 

### there are different paths to take. And 3 

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

### also a UA approach, and there's performance 5 

### approaches. So those are already in there. 6 

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

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

### code, the IECC, that have the prescriptive 9 

### approach, we were given a proposal from Mike 10 

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

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

### us insert that prescriptive approach into the 13 

### IECC in lieu of the current IECC prescriptive 14 

### approach, which is not really geared or does not 15 

### accommodate factory-built housing. 16 

### MR. RAMIREZ: Okay. 17 

### Eric? 18 

### MR. LACEY: This is Eric from RECA. 19 

### I certainly support the prescriptive R20 

### value table that Luby put forward. But I would 21 

### just remind you that the prescriptive path is not 2295

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### just a table. There's another long list of 1 

### requirements and exceptions that also apply to 2 

### that. 3 

### And I think that our subgroup is 4 

### eventually going to go through all of those and 5 

### decide what works for manufactured housing and 6 

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

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

### some of the requirements might be new as well. 9 

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

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

### thought it was a great start, there are other 12 

### requirements and provisions that still apply. 13 

### MR. RAMIREZ: Yeah, I understand. 14 

### MR. LUBLINER: This is Mike Lubliner. 15 

### I agree with Eric. We need to look at 16 

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

### man just to get some progress and dialog. Thank 18


### you. 19 

### MR. EZZO: This is Mark again. 20 

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

### sight of it. Because it seems like, since Mike 2296

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### made that recommendation, it's kind of gone by 1 

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

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

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

### get lost. 5 

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

### make sure we include that in the further 7 

### discussions that we have on the subcommittee. 8 

### Thanks. 9 

### MS. HOFFMAN: Eileen Hoffman. 10 

### My impression was that Ed at Navigant was 11 

### using -- were you including the Lubliner straw 12 

### man? Just to check. 13 

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


### I can comment. 15 

### So, we did energy simulations for the 16 

### Lubliner proposal and then the derivatives, where 17 

### we looked at different things like maybe some 18 

### different installation options and solar heat 19 

### gain coefficients and what-not. 20 

### So you should have all those annual 21 

### energy consumption numbers. And, you know, we 2297

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### did that in parallel with Matthew, who was 1 

### constructing the life cycle spreadsheet. He has 2 

### not had time to copy those numbers into the life 3 

### cycle, you know, spreadsheets, partially because 4 

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

### manufacturer, right? 6 

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

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

### his time monkeying around with fictitious data, 9 

### right? 10 

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

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

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

### know, those simulations analyzed in comparison to 14 

### the other ones that are already in there. All 15 

### right? 16 

### So, hopefully, once we get that cost 17 

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

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

### And then we can go from there. 20 

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

### Mark Ezzo. I mean, I think that straw man for 2298

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### the packages was really good and really 1 

### important. And it actually compared very nicely 2 

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

### recommend that we stick with that until we see a 4 

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

### bad, so. 6 

### MR. SANTANA: This is Manny with CAVCO, 7 

### if I can speak. 8 

### MR. RAMIREZ: Yeah. 9 

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

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

### also I think what Eric brought up was really 12 

### critical, where I'd like the concept behind 13 

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

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

### mandatory provisions that we've been trying to 16 

### get through, and a bunch of other kinds of 17 

### assumptions. 18 

### I think in order to advance Mike's 19 

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

### and include what other -- the assumptions that it 21 

### entails. So what we might need to do is, in 2299

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### order to consider the prescriptive path, we might 1 

### have to find out what portions of the IECC apply 2 

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

### kind of prescriptive package of sorts to replace 4 

### what's in the IECC. 5 

### So I think Mark is correct. But 6 

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

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

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

### standalone prescriptive path. 10 

### MR. RAMIREZ: And is that something that 11 

### you are going to lead with your subcommittee? 12 

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

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

### I'd hate to take something that Michael conceived 15 

### of and just change it, you know. 16 

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

### want to, I guess, expand your idea? 18 

### [Pause.] 19 

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

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

### I don't want to go too far into that right now. 22100

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### But, yeah. I believe that we can discuss the 1 

### technical details of that. 2 

### As I said yesterday, I think one of the 3 

### issues is how much insulation is displaced with 4 

### tapering assumptions and what the impact is on 5 

### the compression in the floor and whether it would 6 

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

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

### some point, I think that's appropriate. 9 

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

### to get some estimates either using the existing 11 

### cost data if no more cost data is produced, 12 

### delivered, or presented, or try to get the 13 

### manufacturers to cost out these package relative 14 

### to minimum HUD and see where we go. 15 

### I hope that answered your question. 16 

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

### response to that, I think it would be really 18 

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

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

### because there's a lot of unsaid assumptions that 21 

### are behind the scenes that weren't part of that 22101

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### packet. 1 

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

### That's why we need to talk about those 3 

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

### then get cost data. 5 

### Right now, what I understand is Joe's 6 

### going to be using the cost data that they already 7 

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

### compares with the other stuff. 9 

### But, yes. It's absolutely critical that 10 

### we define the parameters before we can arrive at 11 

### agreements on what the factors are that go into 12 

### the costs, and then cost it out. 13 

### MR. RAMIREZ: Michael, are you currently 14 

### on that subcommittee for the -- 15 

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

### on the committee, right? 17 

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

### thinking, since I have this separate committee 19 

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

### issue, maybe rather than having two committees, 21



### we -- 22102

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### MR. RAMIREZ: Just merge it. 1 

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

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

### comfortable with that. 4 

### Manny's done a great job of leading the 5 

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

### have good manufacturer and cross sectional input 7 

### on the committee. 8 

### I would open it up to others that may 9 

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

### that were presently on the group that was going 11 

### to look at this, as a separate committee. 12 

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

### Just wondering, guys, if some of the 14 

### assumptions that Manny has questions about, and 15 

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

### are these some of the assumptions and discussions 17 

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

### through these, you know, proposed requirements? 19 

### Then we sort of start having those discussions 20 

### and the assumptions as we go through this other 21 

### material? 22103

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### MR. LUBLINER: Joe, you're right. Mike 1 

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

### of these out, based on what Emanuel's going to 3 

### propose. I wouldn't say that we're going to 4 

### resolve everything. But it's a good starting 5 

### point. I would suggest we start there. 6 

### MR. RAMIREZ: Well, let's start fleshing 7 

### then. 8 

### MR. LUBLINER: Fleshing? 9 

### MR. RAMIREZ: Yeah. 10 

### [Laughter.] 11 

### MR. LUBLINER: Manny, do you agree? 12 

### MR. SANTANA: Well, I want to go back to 13 

### fleshing out. So, you know, I don't know. 14 

### Because there are different paths. The 15 

### prescriptive path can have its own standalone 16 

### assumptions that may not necessarily hand it over 17 

### to the performance. 18 

### But the prescriptive path can have 19 

### whatever assumptions it wants. You know, it can 20 

### say this package is based on a two-by-eight floor 21 

### joist with R-19 throughout, and it's based on, 22104

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### you know, this assumed section with -- and this 1 

### percentage of glazing. Where the performance 2 

### path won't have any of those assumptions because 3 

### those are all going to be inputs. 4 

### MR. RAMIREZ: All right. So then with 5 

### that, Emanuel, do you want to go ahead and start 6 

### sharing with us what you've put together? 7 

### MR. LEVY: I'm glad to. Do you want to 8 

### pull the first one up on the screen, Javier? 9 

### I just wanted to add a comment to Manny's 10 

### last statement. The prescriptive path, whatever 11 

### it happens to be, if it's the Lubliner proposal, 12 

### that becomes the touchstone for everything else 13 

### in terms of thermal performance compliance so 14 

### that if there's a performance path or a UA 15 

### compliance path or a UO compliance path, they all 16 

### have to be internally consistent with what's in 17 

### that prescriptive path. 18 

### So that is a vitally important decision 19 

### that the committee makes as to what's in that 20 

### package. I don't know if that was obvious when 21 

### you were talking about it. 22105

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### MR. RAMIREZ: Emanuel, now, before you 1 

### start here, of the three documents that you have, 2 

### is there one of them that you think that we could 3 

### get through in 45 minutes? 4 

### MR. LEVY: Yeah. Let's do the first one 5 

### to the left, the solar heat gain coefficient. 6 

### MR. RAMIREZ: This one? 7 

### MR. LEVY: Yes. But I can't guarantee it 8 

### will take 45 minutes, with this group. 9 

### MR. RAMIREZ: But you think it can? 10 

### MS. HOFFMAN: Yeah. Otherwise, we'll 11 

### break for lunch and finish when we come back. 12 

### [Laughter.] 13 

### MR. RAMIREZ: Okay. 14 

### MR. LEVY: All right. Okay. So, let me 15 

### just mention what I was attempting to do here, 16 

### which is to take some of these issues that are 17 

### clearly related to the manufactured housing 18 

### standard, and put a straw man on the table as to 19 

### what this might look like. Obviously, these are 20 

### starting points for discussion. I try to provide 21 

### enough background information here to put this in 22106

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### context. 1 

### There are three different papers that 2 

### we'll be talking about today. One of them, this 3 

### first one, is on solar heat gain coefficient, the 4 

### glazing. And they all follow the same format. 5 

### They start with a short summary of what the 6 

### background is on this issue, very graphically 7 

### oriented. 8 

### Then there's a proposal, which is section 9 

### 2, which we'll get to in a minute or two. A 10 

### specific proposal about how we handle, in this 11 

### case, solar heat gain coefficients in the 12 

### standard. And a third part, which is somewhat of 13 

### a justification for what the proposal is. 14 

### So, I'll try to go through here quickly, 15 

### go through this quickly and get right to the 16 

### commentary on this. But please, do stop me, and 17 

### on this one in particular I'm going to probably 18 

### ask Rob to clarify some points because he and I 19 

### put our heads together on this one. He knows a 20 

### lot more about these issues than I do. 21 

### Solar heat gain coefficient is basically 22107

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### the physical property of the glazing system, 1 

### which is the glass and the frame, and it tells 2 

### you how much of the impingent light actually 3 

### penetrates into the space so that a lower value 4 

### means less of the sunlight hitting the window is 5 

### going to get through the glass and into the space 6 

### and turn into heat, where heat can turn into 7 

### usable heat. 8 

### This, obviously, is -- I don't know how 9 

### obvious it is. But this is a much more important 10 

### issue, what this characteristic of the window is 11 

### in the south, where high solar loads can really 12 

### add to your cooling load than in the north. So 13 

### as a result, I think you'll see that IECC right 14 

### now has no -- they don't care what the solar heat 15 

### gain coefficient number is for the glazing in the 16 

### North. They're mainly just focused on the South. 17 

### So, it's not only the glass and the 18 

### properties of the glass. It's also the rest of 19 

### the glazing system, the frame. And in 20 

### particular, for example, a window that has grids 21 

### in it will, obviously, block more light, so it 22108

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### will have a higher solar heat gain coefficient. 1 

### So the same window with the same glass, with and 2 

### without grids in it -- everybody knows what grids 3


### are? 4 

### [Pause.] 5


### MS. HOFFMAN: No. 6 

### MR. LEVY: Will have different solar heat 7 

### gain coefficient. 8 

### MS. HOFFMAN: What are grids? 9 

### MR. LEVY: So, a grid is, when you see a 10 

### window with no hatching in it. Usually, older 11 

### windows have that hatching, so they have smaller 12 

### panes of glass for the same -- Rob, you want to 13 

### take over? 14 

### MR. LUTER: This is Rob. 15 

### Simulated divided lights is what grids 16



### are. 17 

### MR. LEVY: So they make it look like you 18 

### actually -- in a window frame, instead of having 19 

### a big piece of glass, there's a grid that divides 20 

### that big piece of glass, usually into six parts 21 

### or four parts. It's a cosmetic change. But that 22109

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### grid that overlays on top of the window blocks 1 

### some of the sunlight, so it affects the amount of 2 

### light that's going through the window and 3 

### therefore turns into heat inside the home. 4 

### So is that reasonable? 5 

### [Pause.] 6 

### MR. LEVY: Okay. Go ahead, Rob. 7 

### MR. LUTER: No, I was just going to 8 

### expound a little bit. The solar heat gain 9 

### coefficient is specific to the amount of solar 10 

### energy coming through, thermal energy. There's a 11 

### visual transmittance component to that as well, 12 

### which typically will go down. That is to say 13 

### less visible light comes in as the solar heat 14 

### gain coefficient goes down. 15 

### To Emanuel's comments about frame and 16 

### grids, the same-size window will have a different 17 

### solar heat gain dependent on the operator type. 18 

### A picture window, for example, which has a much 19 

### greater percentage of glazing-to-frame will often 20 

### have a higher solar heat gain of a comparably 21 

### equipped double-hung window or a casement window, 22110

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### which typically has much less glazed area as 1 

### compared to the whole unit. 2 

### And the ratings that are developed by the 3 

### NFRCR whole unit ratings, it's not just the 4 

### glazing. As Emanuel mentioned, the addition of 5 

### grids or simulated divided lights also reduces 6 

### the solar heat gain, as well as the visual 7 

### transmittance. 8 

### MR. LEVY: Javier, if you can go to the 9 

### bottom of this document, I think before we get 10 

### into the specific proposal, the idea is -- just 11 

### all the way to the bottom, the entire document. 12 

### There's a table down here, right here, right 13 

### there. Hold on. Come back to the table, two 14 

### tables. Okay. 15 

### So, this is what Rob is talking about. 16 

### There are two companies that distribute windows, 17 

### sell windows to the industry that -- and those 18 

### two companies claim about 90-plus percent of the 19 

### total sales. So we really need to just focus on 20 

### the products that are sold by these companies. 21 

### And here's a listing of -- a simple 22111

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### listing of the products that are being offered, 1 

### and with their U values and their corresponding 2 

### solar heat gain coefficients. 3 

### And these are in order of, the ones at 4 

### the top are the least efficient from an energy 5 

### thermal standpoint. And the ones at the bottom 6 

### are the most efficient, or approximately. They 7 

### get more efficient as you go down the list. 8 

### But you can see, for corresponding 9 

### windows, what the solar heat gain coefficients 10 

### become. So if you only have an aluminum frame 11 

### window with clear glass in it, you have a value 12 

### of 1.08 for the first company and a solar heat 13 

### gain coefficient of 0.7. That's a pretty high 14 

### solar heat gain coefficient, which means it's 15 

### allowing a lot of the thermal radiation into the 16 

### home. 17 

### On the bottom, you can see Window Company 18 

### A, they're a vinyl frame with enhanced low-E 19 

### glass, has a much lower U value, which means it's 20 

### about three times as efficient as the single 21 

### glass. And you can see the solar heat gain 22112

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### coefficient for that product is also much lower. 1 

### So there is -- they're not totally 2 

### correlated. But the more -- generally, the least 3 

### efficient units have the higher solar heat gain 4 

### coefficient, and the more efficient ones, by 5 

### virtue of the glass that's being used in there, 6 

### have lower solar heat gain coefficients. 7 

### And they're shown in a range for the 8 

### reason that Rob mentioned, because some -- you 9 

### know, the same product, window type, in different 10 

### sizes or different grid combinations, less solar 11 

### heat gain coefficient. So we've shown the range 12 

### there. 13 

### So, for vinyl frame with low-E dual 14 

### glass, the range is, for that product, has a U 15 

### value of 0.32 to 0.35 and a solar heat gain 16 

### coefficient of 0.26 to 0.33. 17 

### Any questions about that? 18 

### [Pause.] 19 

### MR. LEVY: Okay. So, we'll go back to 20 

### the top of this paper. 21 

### [Pause.] 22113

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### MR. LEVY: So, this is what the various 1 

### standards say about solar heat gain coefficient. 2 

### The HUD code is silent on it at the moment, and 3 

### you can see the progression from the '06 to the 4 

### '15 code, IECC code. 5 

### It started out that, in zones 1 through 6 

### 3, the Southern zones, it started out in '06 at 7 

### 0.4. And over time, that's been ratcheted down 8 

### to what is today, for the '12 and '15 code, 0.25. 9 

### So, over time, the IECC committee has made that 10 

### requirement more stringent, allowed less solar 11 

### heat gain through the glass in those Southern 12



### zones. 13 

### It's also, over time, added a requirement 14 

### for zone 4, which is now getting up into the 15 

### middle of the country, of a 0.4 solar heat gain 16 

### coefficient. So you can see that that's the 17 

### context that we're working, that's in the code 18 

### right now, or what's in the proposed 2015 code. 19 

### If you go down, Javier, to the map, stop 20 

### right there. You can see that if you take the 21 

### current HUD map, which is the bottom one, and you 22114

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### overlay it on top of the IECC map, there is some 1 

### alignment there of zones 1, the HUD zone 1 with 2 

### zones 1, 2, and 3 for the IECC. And you can see 3 

### what the alignments are there in terms of zones. 4 

### There's overlap, obviously, between 5 

### zones. So it's not simple to say that zone 2 HUD 6 

### is in zone 3 or 4 IECC. It does touch on parts 7 

### of 5, and you can see that there's a little more 8 

### complexity to that. So any statement about 9 

### overlaps is kind of a simplification. 10 

### So that's the context. So now if we can 11 

### go down. Any questions about that? I'm going to 12 

### get right to the proposal. 13 

### [Pause.] 14 

### MR. LEVY: Okay. So, here's the 15 

### proposal. This is what might be the beginning of 16 

### what the language might be in the term sheet. 17 

### This actually is very similar to what's in the 18 

### IECC standard, with a small change. 19 

### The proposal is that, for HUD climate 20 

### zones 1 and 2, that we use a solar heat gain 21 

### coefficient that does not exceed 0.33. Where 22115

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### does that number come from? If you look at the 1 

### table right there for Window Company A, you can 2 

### see that they have three products, their bottom 3 

### three products, that would comply with that. 4 

### The current requirement, as you remember 5 

### from above, in the 2015 and the 2012 IECC, is 6 

### 0.3. What I'm suggesting is we raise that to 7 

### 0.33 to allow all the windows that are currently 8 

### in the market in those three categories, vinyl 9 

### frame with dual low-E, the argon option, and the 10 

### enhanced low-E, that all the products be able to 11 

### be used. 12 

### I'm also suggesting that there be no 13 

### solar heat gain coefficient requirement for zone 14 

### 3, and that's pretty much in line with what is 15 

### being proposed -- or what's in the IECC 16 

### provision. Not exactly, but pretty close. 17 

### The third point is the fenestration 18 

### permitted to satisfy the requirements be based on 19 

### an area-weighted average, which means you could 20 

### have some product that has higher solar heat gain 21 

### coefficient, some that's lower. But as long as 22116

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### the area weighting of those windows is no greater 1 

### than the target of 0.33, you're okay. That again 2 

### is out of the IECC. 3 

### And fourth, that at 15 square feet, that 4 

### the glazing be eliminated from these 5 

### requirements. That's also out of the IECC. 6 

### So, it's pretty close with the adjustment 7 

### made at 0.33, up to the 0.33 to what's in the 8 

### IECC. So that is the proposal. You've had the 9 

### context, and that's where the conversations 10


### start. 11


### MR. RAMIREZ: Comments? 12 

### MR. ROY: Emanuel, this is Robin. 13 

### Thanks. That's very helpful. 14 

### I have a question. For example, on the 15 

### 0.33 for zones 1 and 2, is your proposal based on 16 

### a presumption or some analysis that having the 17 

### requirement be no greater than 0.25 wouldn't be 18 

### economic? Or is it -- I mean, what's the basis 19 

### for choosing 0.33 instead of 0.25, which would 20 

### still leave one on the top of the window? 21 

### MR. LEVY: Javier, if you can go back to 22117

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### the top. 1 

### [Pause.] 2 

### MR. LEVY: First, you see that the 3 

### requirement -- I'm sorry, the requirement in the 4 

### IECC is 0.25, not 0.30. I misspoke earlier. So 5 

### it's 0.25. 6 

### There is not a simple overlay here, 7 

### because the zones we're talking about, 1 and 2, 8 

### for HUD, overlay -- we can go down and look at 9 

### the maps, or we can just shrink that page a 10 

### little bit so we can see everything. 11 

### [Pause.] 12 

### MR. LEVY: Yeah. So you can see that HUD 13 

### zones -- we're trying to overlay zones here. And 14 

### keep in mind that the requirement, as you can 15 

### see, for the IECC, it's for zones 1, 2, and 3, 16 

### which is parts of Oklahoma, Florida, Texas, 17 

### little parts of California. Those are 0.25. The 18 

### 0.4 is for zone 4, which is the yellow area. 19 

### And those areas overlap with HUD zones 1 20 

### and 2. So, in fact, for some of those areas, 21 

### where the yellow overlaps with the black, we're 22118

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### actually proposing a lower standard. And for the 1 

### areas where the red and the maroon, or whatever 2 

### that color is, on the IECC overlap with zones 1 3 

### and 2 in HUD, we're proposing a higher standard. 4 

### But this is not based -- Robin, to answer 5 

### your answer, this is not based on a cost-benefit 6 

### analysis. Based upon the products that are 7 

### there, and having some kind of soft focus on how 8 

### to align the requirements given the differences 9 

### in the zone mapping. 10 

### MR. ROY: There are products that are 11 

### there at the 0.25, right? I mean, there are 12 

### products. 13 

### MR. LEVY: Right. 14 

### MR. ROY: I'm just wondering how we make 15 

### the choice between 0.25 and 0.33. 16 

### And the other question, which was going 17 

### to be my second set, was does this analysis that 18 

### underpins your choice -- if we didn't go with the 19 

### HUD zone basis, but instead went with an IECC 20 

### basis, what would we be giving -- what are we 21 

### giving up in choosing a HUD zone basis rather 22119

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### than an IECC more -- more broken up? 1 

### MR. LEVY: Well, okay. 2 

### MR. ROY: But that's the second question. 3 

### MR. LEVY: Right. 4 

### MR. ROY: The first question really 5 

### stands either way. I mean, what sort of analysis 6 

### could we reference to support the choice of 0.25 7 

### or 0.33, or in your case, 0.33? 8 

### MR. LEVY: Javier, if you can go down to 9 

### the table down below. 10 

### We could do analysis here. And I think 11 

### it would probably be prudent to do analysis. 12 

### What we're implying here, Robin, whether it's 13 

### requiring -- you can see the bottom window there, 14 

### as you pointed out, would meet the 0.25 15 

### requirement in the IECC. 16 

### But we are talking about windows in the 17 

### South. And by and large, the U values that 18 

### correspond to those windows, we're now requiring, 19 

### implicitly in our conversation, we're requiring 20 

### at all the windows in the South at least double-E 21 

### dual glazed. And that's a more expensive window 22120

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### than the ones above it. 1 

### So we're now implying, by whatever solar 2 

### heat gain coefficient we choose, that the U value 3 

### is going to be much lower than the windows that 4 

### are used today. 5 

### So the first question is, if you require 6 

### a solar heat gain coefficient of even 0.26 to the 7 

### 0.33, those two options there, are they cost8 

### effective both in terms of the benefit from the 9 

### solar heat gain coefficient and the requirement 10 

### of a fairly low U value for the windows? 11 

### So, that's kind of a double-edged sword 12 

### there, or two-pronged analysis that would be 13 

### required to be part of that assessment you're 14 

### talking about. 15 

### And then further, if you we take it down 16 

### to a 0.25, in which there's only one window that 17 

### qualifies -- and I can tell you that's a very 18 

### expensive window. And Rob can talk more about 19 

### that. If that was the requirement, and now we're 20 

### talking about in the very South, you'd have a 21 

### very high-efficiency window in the South, fairly 22121

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### expensive to get to your solar heat gain 1 

### coefficient. 2 

### It's possible to do analysis for each of 3 

### the zones to see whether that's cost effective, 4 

### but I imagine it's going to be an expensive 5 

### proposition to replace windows to get there. 6 

### MR. LUBLINER: Emanuel, Mike Lubliner 7 

### here. 8 

### To follow up on that, is your cost group 9 

### going to be getting the incremental cost for both 10 

### of those low-E products, the less-expensive low-E 11 

### and the more expensive 0.25? And if so, it seems 12 

### like it's prudent for the analysis to look at 13 

### that, given what the discussion that just went 14



### on. 15 

### MR. LEVY: Yeah, Mike. The short answer 16 

### is yes, we'll have those costs tomorrow. And so 17 

### we will have the material that is needed to do 18 

### that analysis. 19 

### MR. LUBLINER: Excellent. Thank you. 20 

### The other follow-up is, is there a window 21 

### schedule assumed in the thermal analysis? I 22122

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### guess this is for Joe Hagerman. Or is it just an 1 

### assumption of the glazing area? 2 

### I think that, as we start to get into the 3 

### weeds a little bit more here, and looking at some 4 

### of these things, it would be useful if we had 5 

### like, what is the window schedule? How many 6 

### windows? What's their size? What's the operator 7 

### type? -- for both of the prototype floor plans. 8 

### And it's a side question, but I think it 9 

### will help in this discussion in the ultimate 10 

### evaluation. Thank you. 11 

### MR. HAGERMAN: So this is Joe Hagerman. 12 

### Yeah, the modeling document that I 13 

### circulated should talk about the windows. And I 14 

### want to remember that it's a total square footage 15 

### of window area per facade. But I need to relook 16 

### at that, I agree. 17 

### MR. RAMIREZ: Okay. Let me get Eric and 18 

### then Mark. 19 

### MR. LACEY: Thanks. This is Eric. 20 

### You know, looking at the standard, when 21 

### we first started getting involved in this, what 22123

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### really stood out to our organization was the 1 

### fenestration requirements and the potential 2 

### opportunity here to make these homes much more 3 

### efficient, particularly on the SHGC, because 4 

### there's not a requirement. 5 

### Now, I think if I'm understanding this 6 

### correctly, both of the companies here do make a 7 

### product with an SHGC that gets us down into where 8 

### it would comply with the 2012 or 2015 IECC. And 9 

### I know that when this was debated in the 2012 10 

### IECC process, a lot of the manufacturers stood up 11 

### and said, "This is going to be expensive. You 12 

### know, it's proprietary technology. We don't know 13 

### how to do this." 14 

### And when the code was published, 15 

### everybody had a window that complied. In fact, 16 

### there was a tax credit associated with the 2009 17 

### Recovery Act that required 30 U factor, 30 SHGC 18 

### windows for a pretty big tax credit. And almost 19 

### overnight, all the manufacturers of windows had 20 

### windows that complied. 21 

### And so, it's one of those things, like 22124

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### airbags in cars, that, you know, I think that at 1 

### least for the stick-built homes, the debate has 2 

### largely been settled on this. In the 2015 3 

### process, there's almost no opposition to the 25 4 

### staying in place. It wasn't driven any lower; it 5 

### just stayed at 25. 6 

### And the 40 SHGC has been part of the 7 

### ENERGY STAR standard for a very long time. And 8 

### it's been part of the I-code since, I think, 9 

### 2012. 10 

### So I'd hate to give up on this 25 SHGC 11 

### without considering not only today's costs, but 12 

### the likelihood that, as you set the standard and 13 

### processes are streamlined, that that cost could 14 

### come down substantially. 15 

### I'd also point out that there are several 16 

### ways of getting to a low SHGC, several 17 

### technologies, several different types of 18 

### constructions that would get you there. It's not 19 

### just one specific product. And I hope we would 20 

### consider all of those options. 21 

### It's not just the dual glazing with argon 22125

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### and all of these things. There are other ways of 1 

### getting there. So, anyway, this is an issue that 2 

### I'm obviously interested in because I felt like 3 

### we had a real opportunity here to make these 4 

### homes far more efficient, especially assuming 5 

### that they're going to be air-conditioned at some 6 

### point, and to reduce some of those peak loads and 7 

### high costs over the long term for these people. 8 

### So, anyway, this is an issue that I think 9 

### we need to, you know, to really put some thought 10 

### into. 11 

### MR. RAMIREZ: Mark? 12 

### MR. WEISS: Thank you. Mark Weiss, 13 

### MHARR. I have some questions for both Emanuel 14 

### and Rob. 15 

### Emanuel, I'm sure I understand this, but 16 

### just to be 100 percent clear. The lower the 17 

### number, the more stringent, the more demanding it 18 

### is, correct, on the coefficient number? 19


### MR. LEVY: Yes. 20 

### MR. WEISS: Okay. Now, going to your 21 

### chart, near the bottom, that's up on the display 22126

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### right now. So, as I read that, under what you're 1 

### proposing under Company A, the first three types 2 

### of windows would be excluded, correct? 3 

### MR. LEVY: That is correct. 4 

### MR. WEISS: And I'm talking zones 1 and 2 5



### now. 6 

### And on the second, Company B, just the 7 

### first one would be excluded, correct? 8 

### MR. LEVY: That's right. 9 

### MR. WEISS: Okay. 10 

### Rob, what are the two companies involved 11 

### here? I assume yours is one. But can you tell 12 

### us what they are? Because I'm going to have to 13 

### ask some folks about this. And now they tell me 14 

### I have Joe Blow's windows, you know, I don't know 15 

### who Company B are. So, who are we talking about? 16 

### MR. LUTER: Well, I think those names 17 

### were excluded for a reason. We can talk about 18 

### that offline. 19 

### MR. WEISS: That's fine. 20 

### MR. LUTER: But what -- I would like to 21 

### offer some commentary both to Eric's points 22127

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### regarding the seeming overnight development of 1 

### low-E. I think that if you query your member 2 

### guardian industries, you'll find that it was a 3 

### lot of nights in a row that it took for them to 4 

### develop their triple-silver product. 5 

### That said, his point is correct that 6 

### these products are commercially available. Solar 7 

### heat gain, performance of 0.25 and below is 8 

### available. There are enhanced low-E products 9 

### that are used every day that do this. I think 10 

### the point here is that the cost of those versus a 11 

### dual-silver low-E or commodity low-E, there's 12 

### some significance to that. 13 

### Now, whether it will be significant to 14 

### this group as a whole or part of the group 15 

### remains to be seen. That will come out in the 16 

### analysis. 17 

### I wanted to offer just a couple of 18 

### comments on the window schedule that was brought 19 

### up and the costing that I believe Emanuel is 20 

### going to be presenting later this week. 21 

### I was one of the companies that he worked 22128

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### with on this. And one of the challenges we found 1 

### was to somehow develop a uniform or an average 2 

### cost per square foot at fenestration. And what 3 

### we found was there's really no such thing. 4 

### Windows, as they get larger, actually 5 

### cost a little less per square foot because the 6 

### waiver content is, by and large, level, and 7 

### materials, obviously, go up. As windows decrease 8 

### in size, the cost per square foot goes up. 9 

### Different operator sizes have different 10 

### material and labor contents. I shouldn't say 11 

### operator sizes -- operator types, a double-hung 12 

### compared to a picture window, for example. So 13 

### there's quite a range of costs per square foot. 14 

### And as we get into shaped windows, 15 

### there's quite a bit of cost in those. And we 16 

### have specialty shapes that go in these homes, 17 

### too. So the effort was to create a 18 

### representative window schedule that included some 19 

### large windows, small windows, shaped windows, 20 

### rectangular windows, representative of a year's 21 

### worth of production. 22129

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### I think that at the end of the day you'll 1 

### find that perhaps very few houses hit that exact 2 

### window schedule, but more often than not it's 3 

### close. 4 

### MR. RAMIREZ: Okay. Thank you. 5 

### Mark? 6 

### MR. WEISS: Thanks. At this point, I at 7 

### least want just one more question. 8 

### You've indicated in the commentary that 9 

### the two companies that are referenced in the 10 

### charts hold 90-plus percent of the market share. 11 

### But that's only part of the analysis. 12 

### Can either one of you, or anybody there, 13 

### tell me what is the relative market share of the 14 

### types of windows that would be excluded versus 15 

### the ones that would pass muster under what you're 16 

### proposing? 17 

### MR. LUTER: At this point, I can only 18 

### speak in generalities to a study that I did on 19 

### our production to the HUD code market, a couple 20 

### of observations. 21 

### The type of windows that include low-E 22130

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### represent about 70 percent of what I make. Now, 1 

### where are those going? I don't have statistics 2 

### on, exactly, are they HUD, or are they mods, or 3 

### are they after-market? But that's about as fine 4 

### a point as I can put on it. 5 

### The windows that might be represented in 6 

### the ones captioned aluminum frame with single 7 

### clear glazing, by and large, are going to shed 8 

### builders, people making lawnmower sheds. That 9 

### same window with a companion storm, there are 10 

### some HUD builders using those. 11 

### Again, I don't have any statistics on who 12 

### or how many. The manufacturers themselves would 13 

### have a better feel for that. 14 

### MR. WEISS: Yeah. I mean, my question 15 

### was specifically with respect to manufactured 16 

### housing HUD code market. 17 

### MR. LUTER: Yeah. 18 

### MR. WEISS: I just want to follow up. Do 19 

### I understand correctly that you are doing cost 20 

### analysis with respect to the relative costs of 21 

### the high SHGC windows versus the lower ones that 22131

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### you are currently producing? 1 

### MR. LUTER: That is correct. There's 2 

### incremental cost increases that can be associated 3 

### with the construction attributes that impact both 4 

### U value and solar heat gain. And as I mentioned 5 

### yesterday, there are occasions where in order to 6 

### achieve one of those metrics, the other one 7 

### essentially comes along for the ride at no 8 

### increased cost. 9 

### Low E glass, for example, is commonly 10 

### used to reduce U value. And one of the side 11 

### effects is solar heat gain goes down as well. 12 

### MR. WEISS: Okay. But that -- 13 

### MR. LUTER: You can see that from the 14 

### charts here. 15 

### MR. WEISS: Okay. But you are looking at 16 

### those cost issues? 17 

### MR. LUTER: Yes, yes, we are. 18 

### MR. WEISS: Thank you. 19 

### MR. RAMIREZ: Lois? 20 

### MR. LUBLINER: It's Mike Lubliner. 21 

### MR. RAMIREZ: Michael, hold on one 22132

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### second. 1 

### Go ahead, Lois. 2 

### MR. LUBLINER: Okay. 3 

### [Pause.] 4 

### MR. RAMIREZ: I'm sorry. I don't think 5 

### -- is your mic on? 6 

### MS. STARKEY: Hi. Lois from MHI. 7 

### Just wanted to thank you, Emanuel, for 8 

### all the work you've put into this with your group 9 

### that you needed to get together with, which were 10 

### manufacturers and Rob Luter and others. So I 11 

### know you put a lot of work into this. 12 

### Recognizing that the HUD code doesn't 13 

### have any such requirement now, that this 14 

### certainly is a good, you know, compromise to 15 

### going all the way to the 2015 IECC. And I think 16 

### it's really important that we do look at the 17 

### costs of this proposal versus the IRC. So I like 18 

### that suggestion just to see where we are. 19 

### And again, to say that, you know, it may 20 

### be that going to the 0.25 may -- and when we 21 

### compare those costs back to this proposal in the 22133

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### mix of the entire package, you know, it may be 1 

### something that we -- you know, we may even have 2 

### to consider going in an entirely different 3 

### direction with this particular window issue. 4 

### But thanks for your work, and I look 5 

### forward to getting more information. 6 

### MR. RAMIREZ: Anything else on -- I'm 7 

### sorry. Go ahead. 8 

### MR. UNGER: Lowell Unger. 9 

### I'll start with my thanks. I wanted to 10 

### check. There presumably will be either in a 11 

### prescriptive factual U value requirements or else 12 

### that will factor into the performance. 13 

### Looking at Luby's straw man, which was 14 

### aimed at low-E, I would anticipate that we're 15 

### looking, apart from any SHGC requirements, we're 16 

### probably looking at low-E windows, for the most 17 

### part, if not universally, under a new standard. 18 

### Looking at the charts for the two window 19 

### companies, Emanuel, it looks to me like if you 20 

### assume that, because of the U value, we're going 21 

### to have low-E windows, your SHGC of 0.33 would 22134

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### not add any further restriction. That is, any 1 

### window which you would be using for its U value 2 

### would meet the 0.33 SHGC. 3 

### Is that a fair understanding? 4 

### MR. LEVY: Yes, that's accurate. 5 

### MR. UNGER: And it also looks to me like, 6 

### you know, and I assume these numbers might vary 7 

### due to technology changes or for other companies 8 

### other than these two. But if we're looking at 9 

### 0.25 or below, it would be this, what you're 10 

### calling enhanced low-E dual glazing. But if we 11 

### had some SHGC that was between 0.25 and 0.33, it 12 

### would allow a low-E dual glazing, not enhanced, 13 

### to qualify, but would be lower. 14 

### You know, you could lower the SHGC below 15 

### 0.33 without pushing the whole market into the 16 

### enhanced and potentially more expensive product. 17 

### MR. LUTER: You mean there would have to 18 

### be some enhanced windows in it, but not the 19 

### entire building? 20 

### MR. UNGER: No. I'm saying if you had a 21 

### -- yeah, that's a good point. If you were 22135

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### averaging, then that changes it. But even apart 1 

### from that, if you had a 0.28 or 0.3 SHGC, that 2 

### you would still allow low-E Milan-enhanced 3 

### [phonetic] products could still meet that 4 

### criterion, potentially at lower cost. 5 

### MR. LUTER: Right. I mean, you might be 6 

### cutting out things like grids in windows, which 7 

### are contributing to the higher levels. You might 8 

### be making some implicit cosmetic restrictions. 9 

### But you're correct. 10 

### MR. UNGER: Thanks. 11 

### MR. RAMIREZ: Michael? 12 

### MR. LUBLINER: Yeah, Mike Lubliner here. 13 

### A couple of things. First, I want to 14 

### make a point that, you know, it gets back to a 15 

### standardization reduces the cost to the consumer, 16 

### and I know that there are a lot of plants in the 17 

### Northwest that do both modular and HUD code. 18 

### And we've found, implementing the ENERGY 19 

### STAR program over the years there that it's 20 

### somewhat problematic of having to do different 21 

### types of windows in the plant. You know, so I 22136

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### encourage people to think about that. 1 

### Specifically, I guess the question for 2 

### Rob and, you know, it would be as from a 3 

### manufacturer of the windows standard, if the site 4 

### building industry is requiring 0.25 in the I5 

### codes and that's the bulk of your market, 6 

### manufactured housing representing, you know, less 7 

### than 15 percent of all the housing in the 8 

### country, it seems to me that there is some cost 9 

### savings and some economies of scale of staying 10 

### with the same number and at least doing the 11 

### assessment, as has been recommended by everyone, 12 

### comparing the two types of low-E glasses. 13 

### And finally, Rob, and then I'll let you 14 

### call it. I just want to get this last one in. 15 

### Finally, in the discussion of options for, say, 16 

### people that don't want to go to a dual-frame, I 17 

### guess, in response to the solar heat gain 18 

### criteria, I have a question. 19 

### And that is, we've used -- and I know the 20 

### industry historically has used exterior awnings 21 

### over windows for a number of reasons, and shading 22137

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### for air-conditioning load is a predominant 1



### reason. 2 

### And I'm just wondering if that's a viable 3 

### potential option or exception. So if you had a 4 

### manufacturer, an interrelated manufacturer that 5 

### clearly optimized it without a dual-pane window, 6 

### vinyl window, and they wanted to meet the solar 7 

### heat gain coefficient, would it be acceptable for 8 

### them to ship loose the awnings for the house that 9 

### would cover the windows, and comply as an 10 

### alternate? 11 

### In the same light, I know that there are 12 

### some new storm windows with low-E coatings that 13 

### are a little more problematic. I know that 14 

### Department of Energy's laboratory is testing them 15 

### in manufactured homes right now. But it seems to 16 

### me that might be another viable option for the 17 

### small exception of people that aren't going to 18 

### use a prime window. 19 

### So those are observations. Rob, I'd like 20 

### to get your feedback in terms of standardization 21 

### and the impact. I'm assuming whatever costs come 22138

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### out of this, they kind of take into consideration 1 

### the buying power of the industry and the fact 2 

### that there's consistency, then, with the site3 

### building industry product you're producing. 4 

### Thank you. 5 

### MR. LUTER: Well, let me comment on all 6 

### three points. 7 

### First of all, economies of scale. While 8 

### it's true that with a number of raw material 9 

### items, you know, the larger the quantities, the 10 

### better your buying power is, I can't speak for 11 

### the other manufacturers that serve the industry, 12 

### but as a company, we buy literally millions of 13 

### square feet of glazing a year, including low-E. 14 

### Believe me, we're on the Christmas card 15 

### list of the glass companies. 16 

### [Laughter.] 17 

### MR. LUTER: We simply can't get into a 18 

### buying bracket that gets us better buying power. 19 

### We're kind of already at the top of the heap. 20 

### With respect to the price difference 21 

### between the two low-E's, what we're calling 22139

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### commodity low-E or the dual-silver low-E compared 1 

### to the enhanced or triple-silver product, the 2 

### reality is that, from a manufacturing perspective 3 

### at the low-E glass producer, there's significant 4 

### cost differences in manufacturing the two 5 

### products that result in a different price to 6 

### market. 7 

### There's also a value add of the 8 

### performance that gets factored into the price to 9 

### market. 10 

### Now, that's not to say that if that was 11 

### the only thing they made, things wouldn't change 12 

### somewhat. But most of these companies are now 13 

### going to market with many, many different low-E 14 

### products. So you can literally tailor the U 15 

### value and the solar heat gain for whatever 16 

### climate you're in, from the Yukon clear down to 17 

### Key West. 18 

### The second point, Mike, was what again, 19 

### please? 20 

### MR. RAMIREZ: I think it was awnings. 21 

### MR. LEVY: Talking about awnings, or low- 22140

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### E -- 1 

### MR. LUTER: Okay. Let's talk just a 2 

### little bit about awnings. The solar heat gain 3 

### and U value performance numbers that are 4 

### typically called for in this or any code require 5 

### substantiation by a third party. 6 

### Right now, there really doesn't exist a 7 

### means to test and rate attachments. I know the 8 

### NFRC is looking at it. The -- don't recall if 9 

### it's DOE or EPA wasn't happy with progress there, 10 

### and they're looking at another organization to 11 

### develop these standards. But it's a long way 12 

### off. 13 

### Now, that's not to say that awnings 14 

### aren't effective. They've been used for 100 15 

### years. Shade is better than direct sun. So, but 16 

### with respect to certified ratings, I don't know 17 

### where we could go with that. 18 

### In the absence of certified ratings, the 19 

### code that exists directed you to use ASHRAE 20 

### defaults, which are, by design, punitive. They 21 

### want you to use certified product. And I don't 22141

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### know that I disagree with that. 1 

### With respect to the low-E storm windows, 2 

### I'm familiar with the study that Mike cites. And 3 

### it's encouraging. However, the hard-coat low-E 4 

### products that are used on an add-on storm, while 5 

### they can benefit you on the U-value side, they 6 

### have negligible impact on solar heat gain. They 7 

### do reduce it some, but just a couple of points. 8 

### It really takes the embedded dual-silver 9 

### products that are on the inside of a sealed 10 

### insulating glass unit to knock the solar heat 11 

### gain down appreciably. 12 

### MR. RAMIREZ: Thanks, Rob. 13 

### MR. LUTER: Yeah. 14 

### MR. RAMIREZ: Eric? 15 

### MR. LACEY: This is Eric again. Just a 16 

### couple of points. 17 

### To follow up on Luby's suggestion of 18 

### awnings, you know, we see those used in the 19 

### stick-built housing market, because there you 20 

### know what the orientation of the house is going 21 

### to be. And there's actually a tradeoff path 22142

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### built into the IECC for residential and 1 

### commercial, where once you know what the 2 

### orientation is, you can apply the awnings or the 3 

### overhangs in a way that would reduce the solar 4 

### gain. 5 

### The challenge for a manufactured home, I 6 

### think, is you don't know how it's going to be 7 

### oriented. And it's going to be really hard -- I 8 

### mean, it would have to be a really long overhang 9 

### to, you know, ensure that it would have an 10 

### impact. 11 

### So if there were some mechanism for 12 

### controlling that on the side, I think that would 13 

### be another good suggestion. But I'm not sure 14 

### it's really in the scope of what we're talking 15 

### about here. 16 

### The other thing I would talk about is, 17 

### there's been some discussion about the 18 

### relationship between the U factors and the 19 

### SHGC's. And it's interesting hearing the numbers 20 

### about the percentage of the windows that are 21 

### actually already low-E that are going into these 22143

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### homes and that have sealed insulated glass units. 1 

### I suspect that one reason why you're 2 

### seeing a lot more low-E windows used is because 3 

### you get a huge benefit in your use of O 4 

### calculation. If you're putting in really low U5 

### factor windows, that makes it a lot easier to 6 

### comply around the rest of the house, because 7 

### windows are the weakest element in the building 8 

### envelope. They're much weaker than the wall. 9 

### The best windows are like an R-3 wall. 10 

### You know, if you think about that, if you have a 11 

### lot of glazing area, and your windows are a 12 

### really low U factor, you're getting a huge 13 

### benefit in that use of O calculation. 14 

### And so, I think there's already kind of 15 

### an incentive built into the HUD code to have low16 

### E windows, or very low U-factor windows. And a 17 

### side benefit of that is you do get low SHGC as 18 

### part of that. 19 

### So what I'm going to suggest is that I 20 

### think there's already pretty good incentives to 21 

### get low-E windows, insulated glass units, in 22144

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### homes. And I think it would be great to have 1 

### them in every home, regardless of the compliance 2 

### option you take. 3 

### And I'd like to push the SHGC a little 4 

### more. I think that -- I don't know who the two 5 

### companies are here, and what all their 6 

### manufacturing processes are. But I do know that 7 

### the vast -- you know, the industry for the stick8 

### built homes has moved in that direction of 9 

### applying one more coating to this glass. And 10 

### it's been very cost effective. 11 

### So it's an issue that I don't want to let 12 

### go of quite yet. I think that we can still push 13 

### a little more here on the SHGC. 14 

### MR. RAMIREZ: Okay. Any other questions 15


### or comments? 16 

### MR. LUBLINER: Yeah, I had a question for 17 

### Rob, a follow-up. This is Mike Lubliner. 18 

### When you were talking about the higher 19 

### cost of the non-commodity low-E, does that assume 20 

### the same frame, in other words, the same window? 21 

### My understanding is that the commodity window 22145

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### also, in many times, isn't the same window frame. 1 

### In other words, when you add the higher-priced 2 

### low-E, you're building a heftier frame. 3 

### But I'm not clear if that's the case in 4 

### your industry here, Rob. So I want to make sure 5 

### that whatever we do, it's apples and apples. If 6 

### we're looking at the incremental cost of the low7 

### E versus the commodity one, that we look at an 8 

### apples-and-apples frame size. 9 

### The second thing I wanted to point out on 10 

### the cost analysis that I would encourage DOE to 11 

### do is to look at the reduction in air12 

### conditioning load and the cost benefit to the 13 

### consumer of a smaller air conditioner associated 14 

### with any low-E product. 15 

### And I understand from work that I've seen 16 

### from Emanuel Levy's group over the years that, in 17 

### the sizing of manufactured homes and their 18 

### guidelines for sizing the heating and air 19 

### conditioning equipment, they do have provisions 20 

### for a smaller air conditioner if you use a lower 21 

### solar heat gain coefficient. And, Emanuel, you 22146

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### might want to talk about that. 1 

### But I want to make sure that when we do 2 

### the cost analysis, and I would encourage 3 

### comparison of these two low-E's, that we consider 4 

### these factors. Thank you. 5 

### MR. LUTER: Mike, I can respond to those. 6 

### Mike Luter with Lippert. 7 

### With respect to the incremental cost 8 

### increases for the enhanced low-E that I've shared 9 

### with Emanuel, it reflects only the change in the 10 

### glazing. Literally, the only difference between 11 

### the window with the standard low-E and the window 12 

### with the enhanced low-E are the panes of glass in 13 

### the inside the glass units. 14 

### MR. LUBLINER: Thanks, Rob, for that 15 

### clarification. 16 

### MR. LUTER: Now, let me expound on that a 17 

### little bit. There are companies that perhaps 18 

### have multiple lines of windows that they take to 19 

### market, a good-better-best scenario, not 20



### uncommon. 21 

### And in those cases, they may choose to go 22147

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### with a more robust frame in combination with 1 

### different glazing to affect overall performance. 2 

### In the case of the windows I go to market with, I 3 

### have a single product that I can change various 4 

### construction attributes on within the same frame 5 

### in order to achieve different thermal goals. 6 

### MR. ROY: This is Robin. A quick 7 

### question for Eric. Perhaps you've already 8 

### answered this question; I just didn't hear it. 9 

### But have you polled your members to get 10 

### their sense of what their experience was in the 11 

### incremental cost of these lower SHGC? And if so, 12 

### can you provide that to DOE, that insight that's 13 

### maybe gleaned from that? 14 

### MR. LACEY: This is Eric. 15 

### I've certainly had anecdotal discussions 16 

### with them, and I can tell you that the cost 17 

### difference between -- basically, what we're 18 

### talking about is spraying two layers of ionized 19 

### silver onto a piece of glass versus spraying a 20 

### third layer in that same process. 21 

### And once that's incorporated into the 22148

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### process -- and obviously, there are some R&D 1 

### costs and some upgrade costs to the manufacturer. 2 

### Once you incorporate that in there, it's very 3 

### minimal, very minimal cost. 4 

### I can see if I can pull together some 5 

### information on that. I did provide the ENERGY 6 

### STAR 3.0 numbers to DOE, the analysis that ENERGY 7 

### STAR did compare in the 2009 IECC to the ENERGY 8 

### STAR version 3.0. And that included some SHGC 9 

### incremental changes and what the costs were 10 

### there. 11 

### And in that case, they were very minimal, 12 

### in the range of like 10 cents a square foot, or 13 

### something like that, to drop the SHGC three or 14 

### five hundredths of a point. And, you know, that 15 

### was used for a different process, and maybe there 16 

### are some differences. But I can continue to look 17 

### into that. I don't think it will be very much in 18 

### the long run. 19 

### MR. LUTER: Eric, this is Rob again, at 20 

### Lippert. 21 

### I would encourage the receipt of 22149

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### information like that from a supplier to be -- 1 

### not taken with a grain of salt; I shouldn't say 2 

### that. But what anecdotally someone says they 3 

### will sell something for, versus what it really 4 

### costs the first purchaser, versus what it really 5 

### costs the ultimate consumer are radically 6 

### different things. 7 

### The low-E glass supplier, what they're 8 

### not telling you is that, in addition to that 10- 9 

### cents-a-square-foot, there are fuel gas 10 

### surcharges and shipping costs and any number of 11 

### other fine-print costs to get that into a window 12 

### manufacturer's facility. 13 

### It's not just some off-the-cuff, "Oh, 14 

### it's about a dime a square foot more," because 15 

### it's just not. 16 

### So as I've offered to some in discussions 17 

### of costs, rather than relying on anecdotal 18 

### evidence or hearsay, get a firm quotation, an 19 

### offer to sell, with all the fine print. And that 20 

### will tell you what the real cost is. 21 

### MR. RAMIREZ: Eric. 22150

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### MR. LUBLINER: This is Mike Lubliner. 1 

### MR. LACEY: Hold on. This is Eric. I 2 

### just want to clarify. Maybe I wasn't being 3 

### clear. 4 

### The information I provided to DOE was 5 

### ENERGY STAR's analysis in preparation for their 6 

### version 3.0. I assumed that incorporated in that 7 

### analysis were all the costs. And this is not 8 

### anecdotal evidence that I gave to DOE. This is 9 

### ENERGY STAR's analysis. 10 

### So I have not provided anecdotal evidence 11 

### so far in this process related to the costs of 12 

### low-E, and that's why. Because I agree. 13 

### MR. LUTER: Okay. My misunderstanding. 14 

### I don't know what went into that development. 15 

### But I know if the assumption was that it cost a 16 

### dime a square foot to the end user, it was wrong. 17 

### I'll leave it at that. 18 

### MR. RAMIREZ: Emanuel. 19 

### [Cross-talk.] 20 

### MR. LUBLINER: This is Mike Lubliner -- 21 

### let me just -- in light of, I think, what is 22151

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### happening with our time here, I wanted to make a 1 

### suggestion on an action item to go forward. 2 

### And that would be that, we have two 3 

### glazing solutions, the low-E of dual glazing, 4 

### which is at the 26, 33. And the enhanced dual 5 

### glazing unit of 0.25. And we just compared those 6 

### two homes with those two glazing units from a 7 

### cost-benefit standpoint, using the criteria that 8 

### we have for the life cycle cost analysis. 9 

### Just take a home with 0.33 in all the 10 

### windows and a home with the 0.25, a single and a 11 

### multi section, and let's do an energy comparison 12 

### of those two and see what the real benefit is and 13 

### see if it pays for itself. And you can do that 14 

### in all the locations, IECC locations that are in 15 

### the overlap for zones 1 through 3. 16 

### MR. RAMIREZ: Okay. 17 

### [Cross-talk.] 18 

### MR. RAMIREZ: I'm going to ask Ed if 19 

### that's something they could turn around pretty 20 

### quick. 21 

### But let me get Michael, then Mark. 22152

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### MR. LUBLINER: Yeah, I totally support 1 

### what Emanuel has said. I think we've articulated 2 

### a need for this analysis. I don't hear any 3 

### disagreement. 4 

### I do think there needs to be some more 5 

### discussion going on about the cost implications, 6 

### my comment regarding the fuels surcharge cost and 7 

### some of the other information regarding what may 8 

### impact the cost to the consumer. They all need 9 

### to be accountable. We need to really make sure 10 

### that we're all in agreement on these assumptions. 11 

### I guess my question, Rob, is how does a 12 

### fuel cost -- I mean, I want to make sure that 13 

### we're talking about a steady-state market. In 14 

### other words, if you're shipping products, now the 15 

### choice is, can you standardize and ship one 16 

### product? 17 

### So I guess I need to understand the 18 

### factors that you're talking about and what impact 19 

### they have and what percentage impact they have 20 

### on, typically, once we're in a steady-state kind 21 

### of market where you're producing in it, and you 22153

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### have contracts to sell either the 0.25 or the 1 

### 0.33. 2 

### But I think we're on the right path here. 3 

### Thank you. 4 

### MR. HAGERMAN: Can I interject here just 5 

### for two seconds real quick? Because I think that 6 

### we've performed a little bit of this analysis 7 

### already. And so, maybe we can sort of get to the 8 

### point. 9 

### When we did the KISS Luby runs, package 10 

### number one, we simulated in zone 1 a 0.28. And 11 

### then we did a KISS Luby-Eric Lacey proposal for 12 

### package number two that included 0.28. So the 13 

### data is out there already, from going from 0.28 14 

### to 0.25. 15 

### We can do another run of 0.33, like, you 16 

### know, a package, which would be new package five, 17 

### so you could see package one and two in 18 

### comparison to package five. But you just got to 19 

### ask me for it, all right? 20 

### I'm not sure, really -- you know, I'd 21 

### encourage everybody to look at the data that's in 22154

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### package one and two first, before you ask me to 1 

### do that, right? 2 

### MR. LEVY: Joe, I for one think that that 3 

### would be valuable. But also to do a sensitivity 4 

### analysis of different orientations, because the 5 

### results will differ by orientation. 6 

### MR. RAMIREZ: Mark? 7 

### MR. WEISS: Mark Weiss, MHARR. 8 

### That analysis is fine as far as it goes. 9 

### But since we're using HUD code as a baseline for 10 

### cost considerations, I think the analysis has to 11 

### include the differential going up from the lowest 12 

### whatever, on the scale that's in current use, not 13 

### just from 33 to 20, 25, whatever, based on what's 14 

### currently in use from the least expensive, the 15 

### least SHGC coefficient effect of window that's 16 

### currently in use up to the more stringent level. 17 

### MR. RAMIREZ: Eric? 18 

### MR. LACEY: First, to Mark's point, yeah. 19 

### You'd probably be up in the 0.80 range or higher. 20 

### And there would be pretty significant savings 21 

### from that to a 33 or 25. 22155

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### I would like to dig in maybe a little bit 1 

### deeper into the modeling and specifically what 2 

### types of products were used in the modeling. I 3 

### mean, I know there wasn't a huge difference 4 

### shown, and I'm not sure if that's based on the 5 

### fact that they're using the same type of 6 

### application of silver and different frames or 7 

### something else. 8 

### But, yeah, some follow-on would be good. 9 

### MR. HAGERMAN: So, let's do this, just in 10 

### the interests of time. We're already getting 11 

### Bing at PNNL. She's in charge of all of this, 12 

### this analysis. She's going to talk to Mike 13 

### Lubliner on the insulation. I'll have her talk 14 

### to you about the windows as well, all right? So, 15 

### two separate phone calls, okay? 16 

### MR. RAMIREZ: All right. So, keeping in 17 

### mind the possibility of paralysis by over18 

### analysis, let me ask you. Because I wasn't quite 19 

### sure that, do you need the 0.33 run? Or do you 20 

### want to first look at the runs one and two that 21 

### already have the 0.28 and 0.25 before you 22156

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### formally request for the 0.33? 1 

### MR. HAGERMAN: For the HUD baseline, we 2 

### already modeled 0.6, which is conservative. 3 

### [Cross-talk and laughter.] 4 

### MR. HAGERMAN: We were conservative, good 5 

### conservative. 6 

### MR. RAMIREZ: So, is there enough data 7 

### out there for you all to look at? 8 

### MR. HAGERMAN: I've got another idea, 9 

### just a quick little audible. Why not, over 10 

### lunch, the people that are concerned about the 11 

### values, can you look at the data that we've 12 

### already provided? And then right when we come 13 

### back from lunch, you can kind of re-talk through 14 

### this issue. All right? 15 

### If you're still not happy with the 16 

### modeling, then, you know, it's going to take a 17 

### phone call to PNNL to get you what you need. 18 

### MS. HOFFMAN: You also mentioned -- 19 

### Eileen Hoffman -- the magic word "lunch." I 20 

### think it might be -- Javier, do you agree? 21 

### MR. RAMIREZ: Yeah. 22157

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### MS. HOFFMAN: I think it might be a good 1 

### idea. I see John Caskey has joined us, too, 2 

### which is -- a good idea to adjourn for lunch. 3 

### Come back in an hour. 4 

### So, what do we have now, 12:10? Please 5 

### come back at 1:10. Thank you. 6 

### [Luncheon recess taken from 12:10 to 1:19 7 

### p.m.] 8


### AFTERNOON SESSION 9 

### MR. RAMIREZ: Okay. Let's go ahead and 10 

### start pulling this back in. 11 

### MS. HOFFMAN: We're back on the record. 12 

### MR. RAMIREZ: Okay. Emanuel, we were 13 

### going to have you continue on with your other two 14 

### straw boys, or -- I guess it was less than a 15


### straw man. 16 

### [Laughter.] 17 

### MR. RAMIREZ: But before we do, we have 18 

### John Caskey here from ASRAC, and we wanted to 19 

### just do a quick summary on the roadmap. John 20 

### wasn't with us yesterday when we prepared at 21 

### least the sketches of a roadmap, right. 22158

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### I'm hoping that by the end of today, we 1 

### have a little bit of time where we could revisit 2 

### the roadmap and put a little bit more detail on 3 

### it, right, what needs to be done exactly by when 4 

### and by who. And maybe put in some timelines in 5 

### there as well. 6 

### So, let me do a quick review of that. 7 

### And then, John, if you have any questions or 8 

### thoughts or comments on that, then you could 9 

### chime in from there. 10 

### [Inaudible interjection.] 11 

### MR. RAMIREZ: Okay. All right. So, on 12 

### the 9-9 -- let me just make this a little bigger 13 

### here, which is today, that should be 9-10, 14 

### actually. But this is just the agenda items that 15 

### we're doing today, which we've done Manny's 16 

### subcommittee here. Emanuel is in the process of 17 

### presenting his straw boys. 18 

### And then we're going to go over a 19 

### template of a term sheet and possibly some 20 

### definitions, and Navigant is going to walk us 21 

### through that. 22159

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### MR. HAGERMAN: Yeah, this is Joe 1 

### Hagerman. 2 

### We're just going to circulate that. 3 

### It's, honestly, an outline. So I don't think 4 

### anybody's going to have any problems. But we can 5 

### talk about it for five or ten minutes. 6 

### MR. RAMIREZ: Yeah. 7 

### MR. HAGERMAN: I just think it's going to 8 

### be a short conversation. 9 

### MR. RAMIREZ: Okay. That's fine. 10 

### And then, as we were having our 11 

### discussion, there were some items that we were 12 

### hopeful that, once some cost data is provided, 13 

### and I know that Lois and Emanuel have been 14 

### working on some of that cost data information, 15 

### we're hopefully going to have that by the end of 16 

### the week. 17 

### And then we're going to be able to plug 18 

### those figures into the life cycle cost analysis 19 

### and the other areas where that may be beneficial. 20 

### But then we'll get that information out 21 

### to the workgroup, and that might help bring some 22160

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### focus on the different compliance approaches that 1 

### the group may be taking, and then also maybe some 2 

### additional detail on the 2015 IECC of what 3 

### numbers could be plugged in there. So, it's the 4 

### past and actual performance pieces right there. 5 

### Also, discussion on affordability, where 6 

### Robin had presented the possibility of an LO 7 

### model. What was that, limited options? 8 

### [Inaudible interjection.] 9 

### MR. RAMIREZ: And then the FO was the 10 

### full options. 11 

### So, depending on what that cost data 12 

### yields, we may look at two different product 13 

### options to help solve that affordability issue. 14 

### Some additional items came up as far as 15 

### labeling, we have to have a discussion on that. 16 

### Enforcement and compliance -- hopefully, 17 

### we end up with a term sheet, and then maybe have 18 

### ASRAC extend the authority of this workgroup to 19 

### include enforcement and compliance. 20 

### We also need to have a discussion on 21 

### space water heating and items that are included 22161

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### in the shipped product. 1 

### And I think we're doing some of the 2 

### window types now. 3 

### So those are some of the issues. And so 4 

### what I'm hoping is that, by the end of today, 5 

### we'll have some time to revisit this with the 6 

### group and try to put some additional detail and 7 

### timelines, specific timelines on every component 8 

### that's on there. So that's more or less where 9 

### we're at at this moment. 10 

### Do you have any questions or comments? 11 

### MR. CASKEY: I think I'm on the record as 12 

### saying I've always got comments. So bear with me 13 

### if you will. So I guess my observation is, this 14 

### -- and John Caskey from NEMA for those on the 15 

### phone -- is that it's been a very worthwhile 16 

### effort. I think there's been a lot of work done 17 

### to get us this far. 18 

### I think, from what I observe, is that 19 

### you're bringing up a lot of great topics. You're 20 

### bringing up a lot of, you know, good issues, 21 

### whether it's about wall insulation or floor 22162

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### insulation or windows or whatever. I mean, 1 

### you're sort of discovering a lot of issues and 2 

### you're bringing them to the forefront. So I 3 

### think that in itself is really valuable. 4 

### I can see where you are today, but I 5 

### think you've still got a lot of discussions. I 6 

### think -- you know, I see a lot of -- as you're 7 

### getting into discussions, you get down in the 8 

### weeds sometimes. And that's sort of -- I'm not 9 

### sure how beneficial that is in the long term. 10 

### So I see where you are today. I see that 11 

### by the end of the week you may have better cost 12 

### data for some of the analysis that needs to be 13 

### done. So you've got sort of some good starting 14 

### points for the analysis. But the analysis still 15 

### needs to be done, and I'm not clear whether it's 16 

### Navigant or PN&L that does the analysis; they may 17 

### do different features of it. 18 

### But anyway, you've got a relatively huge 19 

### amount of analysis to do. So I see that as sort 20 

### of the starting point of where we are today, if 21 

### you will, going forward. 22163

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### I also see on the other end, is that 1 

### basically DOE is under obligations to try and 2 

### make some recommendations or initiate some 3 

### regulations relative to manufactured housing. 4 

### You know, that has a sort of a clause. That has 5 

### a time frame that they need to respond to. 6 

### And if, I think -- and I'm telling you my 7 

### opinion, but I really don't speak for DOE. 8 

### But I think if the results of this group, 9 

### it looks very positive in terms of a term sheet, 10 

### something that they can effectively work with, 11 

### then they would love -- I mean, if we can hand 12 

### them that on a sliver platter, they would love 13 

### that in order for them to accomplish what they 14 

### need to accomplish at some point in the near 15 

### future. 16 

### If they're not confident that we're 17 

### getting to that term sheet, then they've 18 

### basically got to start working their butts off to 19 

### try and sort of do the work that they were hoping 20 

### would get accomplished by this group. I mean, 21 

### certainly, getting this group together of the 22164

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### industry experts is extremely valuable. 1 

### You've got the most knowledgeable people, 2 

### the most concerned people, and the people with 3 

### some track records on this particular industry. 4 

### So, I mean, ideally, they would love all the 5 

### input. Again, I can't speak for DOE. But as I 6 

### understand it, they would love to get the input 7 

### from this group, particularly if you can reach a 8



### consensus. 9 

### So we got that, from my perspective, as 10 

### sort of the end game. But in order to get from 11 

### where we are today, we need to refine the cost 12 

### data, hopefully by the end of the week; start 13 

### running the analysis. And then you as a group 14 

### need to get together and say, "I think the life 15 

### cycle cost analysis for, you know, this package 16 

### of improvements is cost effective, and this other 17 

### one isn't very cost effective or isn't an optimum 18 

### solution." 19 

### And then from there, you've probably got 20 

### to refine some additional details. So I just see 21 

### you've got a lot of work to do between now and 22165

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### when DOE ideally wants the work done, by October 1 

### 1st. 2 

### So I would love if somebody could sort of 3 

### lay out how they picture all of this coming 4 

### together in a fairly short period of time. So 5 

### personally, I'm happy to go to the ASRAC group 6 

### and basically say, "Well, we want an extension 7 

### for, say, a month, you know, through the month of 8 

### October, so that the final product is due on 9 

### November 1." 10 

### I'm happy to argue. And from sitting in 11 

### these meetings, I think I can effectively argue 12 

### the ASRAC to extend it to November 1. Beyond 13 

### that, it's problematic because then we're 14 

### starting to get close to Christmas and then the 15 

### other holidays. And then you're all the way to 16 

### the next year. 17 

### And then if you guys try and meet in 18 

### January and February, you've got to deal with ice 19 

### storms and snow and coming out of Chicago and 20 

### whatever else it is. But it's really difficult 21 

### to have effective meetings in January and 22166

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### February with, you know, the weather patterns 1 

### that we have in this area, as well as, you know, 2 

### the Northeast. So that concerns me. 3 

### So, again, I can support an extension -- 4 

### and it's just me as an individual. But I can 5 

### easily support and argue for an extension till 6 

### November 1, if you want me to do that for you 7 

### all. 8 

### But that still means that I would like to 9 

### leave here with a better understanding of how 10 

### you're going to go from, you know, today's work 11 

### to get the cost stuff done by the end of the 12 

### week, to who's doing the analysis, and how long 13 

### is that going to take? 14 

### And then as you start reviewing those 15 

### numbers, you know, how long is it going to take 16 

### for you as a group to get together and look at 17 

### those numbers and make sense out of them and see, 18 

### is there clarity in there that you can go forward 19 

### to translating some of those, hopefully, good 20 

### life cycle cost savings into a term sheet that 21 

### the you can pass over to DOE on a silver platter 22167

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### to sort of help them wrap up their work? 1 

### So, Joe, did I say anything out of school 2 

### our out of line? 3 

### MR. HAGERMAN: No, I think that was well 4 

### said. This is Joe Hagerman from DOE. 5 

### I just want to reiterate that we DOE 6 

### employees always work our butts off, no matter. 7 

### [Laughter.] 8 

### MR. CASKEY: Oh, sorry about that. You'd 9 

### be working your butt off on another topic. 10 

### MR. HAGERMAN: That's right. 11 

### No, you summarized things very 12 

### succinctly, right. And I agree. I think we've 13 

### got a lot of decisions to make between now and 14 

### when we get the term sheet done. 15 

### And realistically, you know, we have one 16 

### more meeting in this month, and then we've 17 

### already scheduled a meeting for the first of the 18 

### next month, which I think is -- 19 

### MS. HOFFMAN: First and second. 20 

### MR. HAGERMAN: First and second, which I 21 

### think is in keeping with ASRAC. I don't think 22168

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### they would get us in trouble for keeping those on 1 

### the books. 2 

### So, but realistically, I think we're 3 

### probably three meetings away from finalizing that 4 

### term sheet, right? We still have to hear back 5 

### from Manny's subcommittee on the IECC provisions, 6 

### which is just going to take a little bit more 7 

### time to go through those. 8 

### And then we still have to have a couple 9 

### of meetings after we get the cost information, 10 

### after we get that this week. There's going to be 11 

### at least a meeting in two weeks, or whatever, to 12 

### go over that material. 13 

### So, I just don't see us being anywhere 14 

### without three meetings from today. And we've 15 

### only had, this is our third meeting, fourth 16 

### meeting? Third meeting. And we've made heroic 17 

### effort in the three meetings already. So I think 18 

### it's very doable. 19 

### MR. CASKEY: Yeah. So I think if we 20 

### could get some of the analysis done between now 21 

### and the 22nd and 23rd and get it out to people 22169

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### beforehand, then people can start thinking about 1 

### that and deciding what their perspective is, and 2 

### then come to the table and work on that, and 3 

### hopefully, you know, come to some consensus 4 

### around some of those issues, and then refine 5 

### those. 6 

### And then that would give you another 7 

### meeting to sort of put pen to paper and get them 8 

### straightened out before, you know, like middle of 9 

### October or something like that, and be ready to 10 

### wrap up by, you know, the first of November. 11 

### But the other thing I caution you about, 12 

### this more my personal opinion, is dealing with 13 

### the parking lot, the approach to analyze data, 14 

### incremental, you know, slash-package. 15 

### So, I mean, that's a good example where, 16 

### certainly in the ideal world, I could see this 17 

### group working for another year to go through and 18 

### look at all the incremental benefits of each of 19 

### the various technologies associated with energy 20 

### efficiency inside the manufactured housing 21 

### industry. 22170

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### But you don't really have the time to do 1 

### that, from my perspective. And the packages sort 2 

### of get you in the right ball park. Yes, there's 3 

### always a possibility that there can be, I would 4 

### call a turkey in one of those packages that 5 

### doesn't really come to the surface, that if the 6 

### overall package is cost effective. 7 

### So I think that is a concern. But I 8 

### think some of those details are sort of -- and 9 

### I'm actually -- my undergraduate is in physics 10 

### and math. So I'm not normally like, you know, a 11 

### just good-enough type guy. I mean, I like the 12 

### details and the analysis. 13 

### But in reality, I just don't know that 14 

### you can do that effectively in the time that 15 

### you've got to delve into that level of detail. 16 

### But on top of that, you know, one of the 17 

### examples I came up with is fracking. You know, 18 

### fracking radically reduced the cost of natural 19 

### gas in the United States. I mean, it's actually 20 

### helping people, helping corporations move from 21 

### England and Europe over to the United States for 22171

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### their businesses because the price of energy here 1 

### is cheaper than in Europe now. 2 

### So, I mean, that's radically changed the 3 

### marketplace. And I don't know what the next 4 

### thing like that is going to be. I mean, if 5 

### there's a moratorium on nuclear or a moratorium 6 

### totally on coal, I mean, that could throw all 7 

### your numbers out, you know, overnight. 8 

### So, I mean, it's not a perfect world, and 9 

### you're doing the best you can with regard to 10 

### discount rates and, you know, inflation and 11 

### energy rise and everything else. So I think 12 

### getting into some of the details that some 13 

### engineers would like to get into, you just can't 14 

### afford to do that at this point. 15 

### It's just going to bog you down and 16 

### you're not going to accomplish your end goal, 17 

### which is hopefully reaching a consensus on what 18 

### you can do effectively in the manufactured 19 

### housing sector to improve energy efficiency, save 20 

### operating costs, and still create an affordable 21 

### product all at the same time. 22172

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### So that's, as I say, my lecture for the 1 

### day. 2 

### MR. RAMIREZ: Great. Anyone have any 3 

### thoughts or comments or questions? 4 

### [Laughter.] 5 

### [Pause.] 6 

### MR. RAMIREZ: Okay. Then, as a 7 

### facilitator, I guess what we're going to then do 8 

### is to drive you all of it, right? As far as 9 

### maybe pushing you and having you rely on some of 10 

### the expertise that we've assembled. It may not 11 

### necessarily be your expertise, but we probably do 12 

### have some in the room that could really, truly 13 

### speak on that. 14 

### And hopefully, we'll just have to put a 15 

### little bit more reliance on some of those folks, 16 

### whichever area of expertise they have. 17 

### Okay. 18 

### MS. HOFFMAN: Before we get started, I 19 

### just want to get a feel -- we heard -- thank you, 20 

### John -- for his input, his personal input, 21 

### because he would then go to ASRAC as the rep here 22173

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### to ask for the extension till November 1. 1 

### And I'd sort of like to get a sense. We 2 

### don't want to stay unless it will be productive. 3 

### That's our view. What is the sense in the room? 4 

### Do you think we can get it done? 5 

### [Pause.] 6 

### MR. UNGER: You mean by October 1st? 7 

### MS. HOFFMAN: No, by November 1. 8 

### [Pause.] 9 

### MR. LUTER: This is Rob. 10 

### Look, I think we can have some work 11 

### product done. Will it be to the level of detail 12 

### that some of us might want? Perhaps not. 13 

### MS. HOFFMAN: Yeah. 14 

### MR. LUTER: But to the points raised by 15 

### others earlier, you know, for a couple more 16 

### meetings, and we're going to have some meaningful 17 

### output. 18 

### MR. RAMIREZ: Mark, did you have 19 

### something? 20 

### MR. WEISS: Yeah. I don't want to 21 

### prejudge anything, but I certainly think it's 22174

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### helpful having more time than less. Any 1 

### additional time we have, as Rob just alluded to, 2 

### will increase the work product that we do put 3 

### out, ultimately. They will be available to DOE 4 

### ultimately. 5 

### MR. HAGERMAN: This is Joe Hagerman, DOE. 6 

### Just remember, too, after our term sheet 7 

### is delivered, and if it's accepted by ASRAC and 8 

### accepted by the secretary, we still have to do 9 

### the rule, right? And so you're going to see the 10 

### analysis that our team has to generate to support 11 

### that rule. And you'll be able to comment on 12 

### that, right? 13 

### That's why I think that the packages make 14 

### a lot of sense. Use your professional judgment 15 

### as engineers. Don't necessarily go into the 16 

### engineering weeds, like some engineers like to 17 

### go. And let's just arrive at, you know, what we 18 

### think the best solution is. 19 

### I mean, you're all here because you're 20 

### experts in the sector, you know. It would be a 21 

### different story if we just pulled out some 22175

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### unknown people off the street. But we didn't do 1 

### that. 2 

### MR. RAMIREZ: Lois? 3 

### MS. STARKEY: I guess, speaking for MHI, 4 

### I've observed that this group and all of the 5 

### little working groups have done really -- have 6 

### worked very hard to get where we are. 7 

### And so I feel confident that, you know, 8 

### we'll do the best we can. I think everybody is 9 

### really committed to having this project be a 10 

### success in terms of coming up with something that 11 

### we can all agree on. 12 

### So, I think it's very doable, and 13 

### appreciate the clarification and the offer for 14 

### additional time. 15 

### MR. CASKEY: This is John Caskey, NEMA. 16 

### I know you guys are the facilitators. But maybe 17 

### the other way to say it is, is there anyone 18 

### opposed to me going to ASRAC to get essentially a 19 

### one-month extension until November 1st for this 20 

### team to wrap up its work and propose that back to 21 

### ASRAC for consideration? 22176

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### [Pause.] 1 

### MR. CASKEY: I don't see anybody raising 2 

### their hands or anybody chiming in from the phone. 3 

### So I guess it's a consensus that you do want me 4 

### to do that. 5 

### MR. UNGER: This is Lowell. 6 

### I would just say it's very hard to know 7 

### at this point. I mean, we've raised a lot of 8 

### issues, but we really haven't resolved any issues 9 

### yet. And so, I would be more comfortable, you 10 

### know, if it felt like we were two-thirds of the 11 

### way there and we had one more third, and I'd say, 12 

### "Yeah, we can probably get there." 13 

### Right now, I just have no idea, because 14 

### we haven't -- you know, we haven't made any 15 

### compromises. We haven't, you know, found 16 

### creative solutions. We've just surfaced a lot of 17 

### good things. 18 

### And so the timing, you know -- so in that 19 

### sense, I don't think we'll know until maybe the 20 

### October meeting as to whether we're on the path. 21 

### And by that point, it may be too late to go back. 22177

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### So you may need to go -- as often, in the 1 

### lack -- you know, without the necessary 2 

### information. But that would be my perception at 3 

### this date. 4 

### MS. HOFFMAN: Yeah, and just to say -- 5 

### Eileen Hoffman -- what our job is is to push you, 6 

### once the date is in, as much as is possible, to 7 

### start working with you to see if we can do the 8 

### kind of thing you're asking, to try to reach some 9 

### resolutions you can all live with. 10 

### And that's the key to consensus. We 11 

### understand you represent many, many 12 

### constituencies. And you've probably been 13 

### communicating with them. And to make sure that 14 

### this is a rule you can all live with and you feel 15 

### good about. 16 

### So that's what we're going to do. We're 17 

### not going to keep you late today. But we are 18 

### going to push you, make sure the committees meet, 19 

### and work with you as best we can to get this 20 

### going. 21 

### Thank you. 22178

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### MR. LUBLINER: This is Mike Lubliner. 1 

### I kind of share Lowell's concerns or 2 

### comments. It's hard for me until I see 3 

### specifically, I think, the cost data to make book 4 

### on this. 5 

### I do think we've got some great data 6 

### that's coming in and discussion regarding data 7 

### sources. But I agree that we really haven't come 8 

### to agreement on very much yet. So I think it's 9 

### like two things. 10 

### One is, we're getting good data. This is 11 

### a good process. But I'm not sure until I see 12 

### specific information, particularly the cost data 13 

### and the subsequent analysis. 14 

### But I think it would be prudent, John, to 15 

### start looking into that, making sure that's a 16 

### contingency that we can take advantage of. And I 17 

### certainly, if I was a betting man, would bet that 18 

### we're going to extend this out. 19 

### We've got issues of labeling, a whole 20 

### bunch of other things as well that are important, 21 

### that need to be addressed. So, that's my 22179

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### thoughts. Thank you. 1 

### MR. HAGERMAN: This is Joe Hagerman, DOE. 2 

### Let's not forget just -- I know we 3 

### haven't necessarily agreed on a lot of specifics. 4 

### We have agreed on some really important specifics 5 

### in terms of what we all need as a group to see, 6 

### to make a decision, right? I mean, that's some 7 

### of what this mind-map that we made yesterday is, 8 

### all those items of what analysis we need to see 9 

### so we can start specifying levels and reach that 10 

### agreement, right? 11 

### MR. LUBLINER: That's right. 12 

### MR. HAGERMAN: Which you're going to see 13 

### those things being delivered, you know, 14 

### hopefully, by the end of the week, right? 15 

### So I mean, I'm -- you know, I understand 16 

### Lowell's position and Mike Lubliner's position. 17 

### But, John, I would really encourage, go get us 18 

### the additional month. Because I have confidence 19 

### that all our friends here will get us to a good 20 

### term sheet that we're all going to be comfortable 21 

### with. 22180

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### MR. RAMIREZ: And that doesn't mean we 1 

### have to use the full month, right? 2 

### MS. HOFFMAN: No. I'm all for good 3 

### behavior. 4 

### MR. RAMIREZ: All right. 5 

### Anything else, then, before we move on? 6 

### MR. WEISS: Very briefly, Mark Weiss, 7


### MHARR. 8 

### And if I didn't do so before, thank you, 9 

### John. I appreciate it. 10 

### Something that I mentioned yesterday I 11 

### wanted to correct. I was referring to American 12 

### housing survey data with respect to purchase 13 

### price of manufactured homes, and the question 14 

### came up, well, were those new homes? 15 

### And reviewing AHS today, my answer was 16 

### yes, they are new homes. And reviewing the AHS 17 

### today, I just want to clarify, the sample 18 

### includes new construction within the current 19 

### sampling period, but it also includes sampling of 20 

### people who are already in their homes, as 21 

### apparently it adds to the purchase price of the 22181

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### home when they bought it. 1 

### So, yeah, it's all new home purchase 2 

### prices. But some of it goes back to earlier 3 

### periods, going as far back, apparently, as 1973. 4 

### So what I said yesterday, it's new, yeah. 5 

### Technically, that's correct. But it's not all 6 

### new homes within the current sampling period. 7 

### MR. RAMIREZ: I appreciate that 8 

### clarification. 9 

### MR. UNGER: This is Lowell. 10 

### I'd just note that I think the MHI fact 11 

### sheet that was sent around yesterday includes 12 

### prices for new homes. 13 

### MR. RAMIREZ: Okay. But is it that same 14 

### dynamic of new homes? It's new home sales from a 15 

### tight time period? Or are we dealing with the 16 

### same dynamic that Mark just clarified? 17 

### MS. STARKEY: No, it's new homes. And I 18 

### don't know how far back we -- I would think we 19 

### can go back pretty far if you want historical 20 

### data. 21 

### MR. RAMIREZ: Okay. Okay. I just wasn't 22182

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### sure if it was the same issue that Mark was 1 

### talking about. 2 

### MR. WEISS: No, no. That's current 3 

### period. 4 

### MR. RAMIREZ: Okay. 5 

### MR. WEISS: The way I read AHS, they 6 

### basically have a rolling sample of purchase 7 

### prices going all the way back to '73, updated 8 

### through 2011. 9 

### MR. RAMIREZ: Okay. Thank you. 10 

### MR. LUBLINER: Mark, Mike Lubliner. I 11 

### had a question on that. 12 

### Does that sample also include procurement 13 

### by the Federal Government of HUD code homes, say 14 

### by FEMA or other federal agencies, Army Corps of 15 

### Engineers? And to what extent could that have an 16 

### impact, if any, on this analysis? 17 

### MR. WEISS: Don't know, from what I've 18 

### read in the AHS, I can take a look at it. I want 19 

### to say no, but I'm not sure, is the answer 20 

### sitting here right now. 21 

### MR. UNGER: Thanks, Mark. 22183

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### MR. RAMIREZ: Okay, great. 1 

### Manny, which document do you want to go 2 

### through next? Sorry -- Emanuel. 3 

### MR. LEVY: Let's start with the ducts, 4 

### proposed requirements for ducts. 5 

### Yeah, thanks. And, Javier, during the 6 

### break, I sent you an email with the suggested -- 7 

### MR. RAMIREZ: One -- Emanuel, I'm sorry. 8 

### Before we do that, we had left off last 9 

### time with the group was going to look at some of 10 

### the data that was already provided to see if we 11 

### needed to do an additional analysis for the 0.33 12 

### window. 13 

### MR. LEVY: Yeah. 14 

### MR. RAMIREZ: Did the folks get an 15 

### opportunity to look at the current data? I think 16 

### it's runs one and two. 17 

### [Pause.] 18 

### MR. LUBLINER: Say that again? 19 

### MR. RAMIREZ: The folks were going to 20 

### look at runs that were already provided to look 21 

### at the efficiencies for 0.25 and -- what was the 22184

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### other value? 1 

### MR. LUBLINER: Three-three. 2 

### MR. RAMIREZ: Two-eight. To see if there 3 

### was a need to do an additional run with 0.33. 4 

### [Pause.] 5 

### MR. RAMIREZ: Yeah, Eric? 6 

### MR. LACEY: Can we wait on that for maybe 7 

### another couple of days? I do want to spend a 8 

### little more time with that. Eventually, you 9 

### know, if we're driving forward with 0.33 as the 10 

### straw man, I'd really like to see the difference 11 

### between that and a 25. But I want to make sure 12 

### before they do the runs that we have the right 13 

### information in place, if that makes sense. 14 

### MR. RAMIREZ: Okay. 15 

### Mark? 16 

### MR. LEVY: Javier? 17


### MR. RAMIREZ: Yes. 18 

### MR. LEVY: I sent you during the break an 19 

### email with a table that would be populated by a 20 

### sensitivity analysis, just a suggested approach 21 

### to doing that analysis. 22185

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### Some of that data, as you point out, we 1 

### may have already. I think it might make sense to 2 

### circulate that to the committee as a starting 3 

### point for getting agreement on what the 4 

### sensitivity analysis should consist of. 5 

### MR. RAMIREZ: Okay. 6 

### MR. LEVY: And I'll have a cost for you 7 

### at the end of the day here. So you'll have all 8 

### the data you need to do the analysis. 9 

### MR. RAMIREZ: I'll send that out to the 10


### group. 11 

### Mark? 12 

### MR. HAGERMAN: So, over the break, I had 13 

### Navigant pull out the numbers -- this is Joe 14 

### Hagerman, DOE -- pull out the numbers from the 15 

### previous runs to see if we could get a good 16 

### indication of how much of an impact, going from 17 

### 0.28, I believe, to 0.30 or 0.33, whatever the 18 

### numbers were, right? 19 

### And so, they started trying to pull those 20 

### numbers out. And it's a little bit more 21 

### complicated, given that some of the ducts, you 22186

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### know, and stuff may have changed. Some other 1 

### factors may have changed in there. Not 2 

### radically, but just enough that we'd have to look 3 

### at the data a little bit more closely. 4 

### It does look like there's, in some 5 

### climate zones, like in Miami, it has an impact 6 

### large enough that, you know, the group should 7 

### talk about it, right? Because it is probably 5 8 

### percent. I just -- by kind of looking at the 9 

### numbers. 10 

### So let us, let Matthew and Ed kind of 11 

### look through the data again and maybe circulate 12 

### something over the next few days over this. 13 

### MR. LUTER: Joe, this is Robin at 14 

### Lippert. Could I offer a comment, please? 15 

### MR. RAMIREZ: Absolutely. 16 

### MR. LUTER: On the solar heat gain 17 

### analysis, if you look at the chart that Emanuel 18 

### showed earlier, you've got a low and a high. The 19 

### high figure shown represents what you would be 20 

### able to achieve, less grids and with the least21 

### forgiving frame arrangement. 22187

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### So if you focused on those high-threshold 1 

### numbers in the analysis, you could be assured 2 

### that, whatever the type of window the homebuilder 3 

### would select, that it would be an achievable 4 

### number. 5 

### For example, you'd hit folks on 0.28, 6 

### only to find out that the home builder could now 7 

### not use picture windows just because, by virtue 8 

### of their construction, they wouldn't hit the 9 

### number. 10 

### Another way to look at that is -- well, 11 

### no. I'll just leave it at that. 12 

### MR. HAGERMAN: This is Joe Hagerman. 13 

### I think that's a great comment. We'll 14 

### take that into account. We'll take into account 15 

### item number 3, or proposed standard bullet 3 16 

### here, this "permitted to satisfy the solar heat 17 

### gain requirement on the basis of the area 18 

### weighted solar heat gain coefficient average," 19 

### too. So -- but I think I understand. 20 

### MR. LUTER: Do you? Okay. I'll defer to 21 

### the manufacturers on this. 22188

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### But it's my understanding that, with the 1 

### various issues they have to comply with out 2 

### there, we have situations right now where, for 3 

### example, on a particular window operator type, 4 

### they're forced to go with grids in order to 5 

### achieve the solar heat gain number targets that 6 

### they need, where it's an aesthetic choice that 7 

### perhaps the homeowner wouldn't otherwise make. 8 

### And we want to avoid things like that. 9 

### Emanuel or Mark, if you could -- 10 

### MR. UNGER: Sorry. Who is forced to go 11 

### with grids? I just didn't understand that 12


### comment. 13 

### MR. LUTER: It's my understanding that 14 

### there are situations where, in order to hit a 15 

### solar heat gain target, for example, a home 16 

### builder needs to add grids to a window because of 17 

### the benefit that that adds, where they otherwise 18 

### might choose not to for aesthetic or cost 19



### reasons. 20 

### MR. UNGER: Like for ENERGY STAR? Or who 21 

### has a solar heat gain target currently? 22189

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### MR. LUTER: Manny or Mark, can you chime 1 

### in there? 2 

### MR. EZZO: Yeah, this is Mark. 3 

### The issue is certain manufacturers' 4 

### windows have better solar heat gain coefficient 5 

### values with grids than they do without. 6 

### So if you're -- in some circumstances, 7 

### depending on the zone you're shipping to, if you 8 

### need to hit a certain heat gain coefficient 9 

### number, sometimes you're forced into having to 10 

### buy the window with grid because that's the only 11 

### one the window manufacturer has available to hit 12 

### that heat gain coefficient target. 13 

### Does that make sense? The heat gain 14 

### numbers get better, lower, when you have grids. 15 

### MR. UNGER: Sorry. This is Lowell. 16 

### I'm confused on the assumption of why the 17 

### manufacturer has to hit a solar heat gain target 18 

### to begin with, here at the moment. 19 

### MR. LEVY: Mark, this is Emanuel. 20 

### Are we talking about for modular homes? 21 

### MR. EZZO: Oh, excuse me, for modular 22190

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### homes. Yeah, for modular homes where we're right 1 

### now complying with mostly the '09 energy code, 2 

### there are specific requirements for heat gain 3 

### coefficient we have to hit, not for HUD. 4 

### MR. UNGER: Thanks. So you're saying for 5 

### some modular homes, in order to meet the IECC, or 6 

### whatever the relevant code in the state, that 7 

### you're limited in your type of window choice in 8 

### order to meet that? 9 

### MR. EZZO: Exactly. 10 

### MR. UNGER: Thanks. 11 

### MR. LACEY: This is Eric -- 12 

### MR. LUBLINER: This is Mike Lubliner. 13 

### MR. RAMIREZ: Go ahead, Michael. 14 

### MR. LUBLINER: I was just going to say I 15 

### think this highlights the reason I asked to see 16 

### the specific window schedule for the two 17 

### prototypes that are being modeled, or create one, 18 

### so that we have an idea. 19 

### And I would recommend that the 20 

### manufacturers suggest what's fairly typical in 21 

### that floor plan, no special windows, and then the 22191

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### operator type, whether it has grids or not. Then 1 

### we can assess that window schedule and see if we 2 

### have a problem, typically. 3 

### I think that's an important step. Thank 4


### you. 5 

### MR. RAMIREZ: All right. Let's get Eric, 6 

### and then Mark. 7 

### MR. LACEY: This is Eric. 8 

### Just one more question to qualify. I'm 9 

### kind of as puzzled as Lowell was on this issue of 10 

### being forced to put in grids. 11 

### Is the issue that the window that was 12 

### stocked, you may not have had a window in stock 13 

### that met the SHGC requirements other than one 14 

### that had grids? Or is the issue that the 15 

### manufacturers can't achieve that low of an SHGC 16 

### without grids? 17 

### Because I thought I had heard earlier 18 

### that the enhanced products are available. There 19 

### are several levels of enhanced products that meet 20 

### SHGC's, probably in the low 3s or high 2 range. 21 

### I'm still trying to wrap my brain around 22192

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### this instance you brought up and would 1 

### appreciate, you know, maybe some more specifics 2 

### on the whole grid issue. Maybe we can follow up 3 

### after this call. 4 

### MR. EZZO: I can give you -- this is 5 

### Mark. I can tell you, Eric, real quick. 6 

### One of the suppliers we buy windows from, 7 

### okay, they don't have on the shelf an enhanced 8 

### low-E glass. So in the '09 IECC, when I have to 9 

### hit 0.30, I have to buy their gridded product to 10 

### hit that number. Because their non-gridded 11 

### product has a 0.32, I think the number is -- 12 

### don't quote me on that. 13 

### It's not to say they can't go and buy 14 

### enhanced glass and do that. But that's not 15 

### something that they do today. 16 

### MR. RAMIREZ: Okay. Thank you. 17 

### Mark? 18 

### MR. EZZO: Or that's not something they 19 

### offer today, I guess I should say. 20 

### MR. RAMIREZ: Yeah. Mark? 21 

### MR. WEISS: If that discussion is played 22193

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### out? 1 

### MR. RAMIREZ: I think so. 2 

### MR. WEISS: Okay. Going back to Joe's 3 

### original statement, the point -- analysis point 4 

### 28, the 33, whatever. 5 

### Anyway, your comments also pertain to the 6 

### HUD baseline calculation, correct? When you say 7 

### you've got to go back and look at it? 8 

### Okay. Thanks. 9 

### MR. HAGERMAN: Yeah. We've provided the 10 

### HUD baseline. So we can add that to the table, 11 

### too. It's like 0.60 or 0.80. It's way away. 12 

### MR. RAMIREZ: Okay. All right. 13 

### Anything additional before we have 14 

### Emanuel continue? 15 

### [Pause.] 16 

### MR. RAMIREZ: All right. Okay, Emanuel, 17 

### you're back on. 18 

### MR. LEVY: I'm glad we got past the easy 19



### one. 20 

### [Laughter.] 21 

### MR. LEVY: Let's move along to ducts. So 22194

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### the issue here is actually two related, two 1 

### issues, both that deal with ducts. One is the -- 2 

### and I brought them together on this table. We 3 

### can take them in pieces. 4 

### The first at the installation level at 5 

### the exterior ducts, the amount of insulation 6 

### that's wrapped around those ducts. And the 7 

### second issue is the amount of leakage from the 8 

### duct system itself. 9 

### So, again, following the same format, you 10 

### can see that at the top I've listed out here the 11 

### survey of the current requirements. 12 

### There's a typo. And, Mark, I know you 13 

### and I talked about this. Just to confirm, the 14 

### HUD code current requirement is R-8 for supply 15 

### and return ducts? Mark Ezzo? 16 

### MR. EZZO: That's correct. 17 

### MR. LEVY: So if you would type an 8 in 18 

### there and correct your sheets. 19 

### MR. RAMIREZ: Yeah, that's a PDF form, so 20 

### we can't change it. 21 

### MR. LEVY: Okay. But for everybody's 22195

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### benefit, that should be an 8 instead of a 4. 1 

### [Pause.] 2 

### MR. LEVY: Okay. So, let's talk about 3 

### the installation piece -- 4 

### MR. LUBLINER: Emanuel? 5 

### MR. LEVY: Yes, go ahead. 6 

### MR. LUBLINER: Mark Lubliner. 7 

### I just want to -- just background for 8 

### some of the folks. The reason that the HUD code 9 

### started with R-4 in 1994 and changed to R-8 was 10 

### the result of work that the NFPA 501 originally 11 

### did on a proposal I had made and also then 12 

### adoption by the consensus committee of HUD. And 13 

### then, promulgation of that by HUD. 14 

### So just a little background that we've 15 

### made some progress even without the DOE efforts 16 

### here on that one. 17 

### Thank you. 18 

### MR. LEVY: Thanks for that, Mike. 19 

### Okay. So if we look down a little bit on 20 

### the sheet, I think this is a pretty easy one for 21 

### us to wrap up. What we're suggesting is under 22196

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### section A-1 there, that ducts be insulated to R1 

### 8, which is basically maintaining the requirement 2 

### that we have today. 3 

### And as you can see from the table above, 4 

### that that is consistent with what's in the IECC. 5 

### Actually, it's a little bit better than the IECC 6 

### 15. And this is both for -- this is for exterior 7 

### ducts now. This is ducts that run outside of the 8 

### thermal envelope of the home, that it's 9 

### consistent with what's in the IECC, or even 10 

### superior. 11 

### So that's the proposal there, no change. 12 

### Any comments? 13 

### MR. RAMIREZ: Yeah. Let me ask the 14 

### group. What do you think of that? 15 

### [Pause.] 16 

### MR. WEISS: This is for Rick. The R-8, 17 

### is that the prescriptive? 18 

### MR. MENDLEN: It's prescriptive, and it's 19 

### put into effect. 20 

### MR. WEISS: Okay. 21 

### MR. RAMIREZ: So, does this look okay to 22197

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### everybody? 1 

### [Pause.] 2 

### MR. RAMIREZ: Let me ask the question and 3 

### clarify that I'd like to see some thumbs. 4 

### Is R-8 for exterior insulation for the 5 

### ventilation okay with everybody, for the duct 6 

### systems? Let me see a show of thumbs. 7 

### [Pause.] 8 

### MR. RAMIREZ: Okay. Going once -- 9 

### MR. HAGERMAN: Let's get the -- since he 10 

### put his placard up, I'd assume he has a question 11 

### or a comment before we take a vote, right? 12 

### [Cross-talk.] 13 

### MR. RAMIREZ: Yeah. You know what? 14 

### MR. LACEY: Rather than giving a thumbs15 

### down. 16 

### MR. RAMIREZ: And that's okay. If you 17 

### remember, thumbs-down could be just that you have 18 

### a question or -- yeah. That's fine. Because, 19 

### remember, there's going to be some onus on you. 20 

### Either ask a question or explain why your thumb 21 

### is down, and offer alternatives if need be. 22198

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### Okay. So go ahead and ask the question. 1 

### MR. LACEY: All right. Eric Lacey from 2


### RECA. 3 

### This looks fine, except the one question 4 

### I had is this clause, "and exposed to outside 5 

### air." I'm wondering, and I'm not as familiar 6 

### with the construction of manufactured homes as I 7 

### am with site-built homes. But outside the 8 

### building thermal envelope, you know, a stick9 

### built home might be the attic. It might be 10 

### someplace other than completely outside the 11 

### building. 12 

### So what I'm wondering is, are there areas 13 

### within the manufactured home that aren't 14 

### completely exposed to outside air that would 15 

### still be considered outside the building thermal 16 

### envelope? And how much of the duct is going to 17 

### be in that area? 18 

### I think that's important, because if 19 

### you're not required to insulate, but it's in an 20 

### area that's semi-conditioned or unconditioned, 21 

### then you're going to lose a lot of duct 22199

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### efficiency. That's the only reason I ask. 1 

### But honestly, I don't know how they're 2 

### constructed like that. 3 

### MR. RAMIREZ: Emanuel, do you have an 4 

### answer for that? 5 

### MR. LUBLINER: Mike Lubliner. 6 

### MR. LEVY: I would defer to the 7 

### manufacturers to explain that. 8 

### MR. SANTANA: This is Manny with 9 

### CAVCO, and I think that I can field that one. 10 

### I think the only part of a manufactured 11 

### home that would be in question is going to be the 12 

### un-insulated duct that is in the belly. You 13 

### know, and this might be something that we want to 14 

### talk about. 15 

### You know, the definitions in Chapter 2 of 16 

### the IECC, the one for conditioned space would 17 

### still count the ducts in the belly as being in 18 

### conditioned space. So it's the belly being the 19 

### area in between the two main rails that has a 20 

### bottom board with insulation. 21 

### So since that is typically insulated 22200

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### outside of the duct, that would fall into a 1 

### conditioned space area, even though we don't have 2 

### conditioned air going into that area. 3 

### [Pause.] 4 

### MR. RAMIREZ: So then, if I understand 5 

### correctly, then that would not be required to be 6 

### insulated. 7 

### MR. SANTANA: Right. That's the way that 8 

### I see it. 9 

### MR. RAMIREZ: Okay. Lowell, do you have 10 

### a question? 11 

### MR. UNGER: Yeah. I'm still not sure I 12 

### understand. You're saying under either IECC or 13 

### this straw man, the duct in the belly would not 14 

### be -- 15 

### MR. RAMIREZ: I'm sorry, Lowell. 16 

### [Inaudible interjections.] 17 

### MR. RAMIREZ: Rick. Rick. Rick. Rick! 18 

### Okay. I'm sorry. Lowell? 19 

### MR. UNGER: Did I understand that you're 20 

### saying that a duct in the belly would not be 21 

### required to be insulated under either the IECC or 22201

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### this straw man? 1 

### MR. SANTANA: Right. 2 

### MR. UNGER: So, I'll leave it to the 3 

### building experts whether that's a problem. But I 4 

### did have a question. So I think the original 5 

### question was, this says, "outside the building 6 

### thermal envelope," which is, I think, a normal 7 

### description for codes as to what you're talking 8 

### about, "and exposed to outside air." 9 

### The question is, why does it say, "and 10 

### exposed to outside air," and what difference does 11 

### that phrase make? 12 

### [Pause.] 13 

### MR. LUBLINER: This is Mike Lubliner. 14 

### You know, I don't see that we need to 15 

### have the "and exposed to outside air" in there. 16 

### My read of that is that, as long as the attic is 17 

### vented or the crawl space is vented, it's exposed 18 

### to outside air. And those are going to need to 19 

### have the RA crossover. 20 

### If the duct is in the attic and it's 21 

### above the insulation, it's exposed to outside air 22202

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### and needs to be RA. If the duct is in the belly 1 

### and there's at least RA insulation of the belly, 2 

### then it wouldn't be. That's kind of my read of 3 

### what this is, where this is. 4 

### MR. RAMIREZ: And does that work? 5 

### MR. LUBLINER: Does it work to take the 6 

### "and exposed to outside air" out? Is that the 7 

### question? 8 

### MR. RAMIREZ: Either that, or is it okay 9 

### if it's underneath the insulation of the belly? 10 

### Right? If it's between the insulation and the 11 

### frame, and not covered, right? That's how it 12 

### would state there. 13 

### So is it okay as is, or do we need to 14 

### strike "and exposed to outside air"? 15 

### MR. HAGERMAN: This is Joe Hagerman. I 16 

### have a question for the manufacturers about that. 17 

### Is the phrase "outside the building 18 

### thermal envelope and exposed to outside air" an 19 

### artifact of the HUD code and-or an artifact of 20 

### the IECC code? Or vice-versa? 21 

### [Pause.] 22203

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### MR. EZZO: Hey, this is Mark Ezzo. 1 

### Does anybody there have the IECC handy 2 

### that we can look at? 3 

### MALE VOICE: Yeah. I'm looking at it 4 

### right now. 5 

### MR. RAMIREZ: We have quite a few people. 6 

### MALE VOICE: We all do. 7 

### MR. EZZO: It's 403.3.1. Supply and 8 

### return ducts in attics shall be insulated to 9 

### minimum R-8 where three-inch in diameter or 10 

### greater, in R-6 where less than three inches in 11 

### diameter. Supply and return ducts in other 12 

### portions of the building shall be insulated to 13 

### minimum R-6. 14 

### MR. RAMIREZ: Mark, could you repeat that 15 

### reference? 16 

### MR. EZZO: 403.3.1. It's on page R-35 of 17 

### the IECC. 18 

### And then the exception says, "Ducts or 19 

### portions thereof located completely inside the 20 

### building thermal envelope." So that's IECC 21 

### version. 22204

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### [Pause.] 1 

### MR. LACEY: This is Eric. 2 

### Then, just to clarify, "building thermal 3 

### envelope" is a defined term. So you can look in 4 

### Chapter 2, and it's the basement walls, exterior 5 

### walls, roof, floor roof, and any other building 6 

### elements that enclose conditioned space or 7 

### provide a boundary. 8 

### And so, I don't have a dog in the fight 9 

### here. I just wanted to make sure we were being 10 

### consistent and find out how much of the ducts 11 

### might be in this space in between being 12 

### completely exposed and being inside the thermal 13 

### envelope. That was all. 14 

### MR. LUBLINER: This is Mike Lubliner 15 

### again. 16 

### And in the definition of sub-part F of 17 

### the HUD code, there's both a definition for 18 

### "thermal envelope area," which gets into the 19 

### definition of "thermal envelope," but a separate 20 

### definition for "pressure envelope." 21 

### And that's going to come up later. So 22205

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### I'm just putting that on the radar screen. 1 

### That's going to come up later as we talk about, 2 

### are we trying to limit the pressure? Or is it 3 

### the thermal envelope? 4 

### I think that Mark Ezzo has pretty much, 5 

### if I understand, confirmed what I was saying, is 6 

### that if it's in the attic and the attic is vented 7 

### and it's above the insulation, it needs to be 8 

### insulated to a minimum of R-8. 9 

### If it's within the conditioned space, or 10 

### the pressure envelope, meaning it's within the 11 

### insulation in the drywall like a chase within the 12 

### drywall of a house, which is rarely done at this 13 

### point, except for some test homes that I know 14 

### that the manufacturers have built, that would be 15 

### totally in the conditioned space. 16 

### I think that the other issue is in the 17 

### crawl space. Are we talking about the crossover 18 

### duct, period? If there's a through-the-rim 19 

### system, then I wouldn't expect this provision 20 

### would apply because the rim joist is within that 21 

### space and has full insulation because of the 22206

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### floor insulation. 1 

### So I'm thinking this really applies. The 2 

### R-8 would apply to the crossover, or when the 3 

### ducts are in the attic above the insulation. 4 

### MR. EZZO: This is Mark Ezzo. I agree 5 

### with that as well. I think that's the intent. 6 

### And I think that's consistent with what's in the 7 

### HUD code. 8 

### MR. RAMIREZ: Would that intent be more 9 

### clear if that was deleted then and exposed to 10 

### outside air? 11 

### MR. LEVY: Yeah. Let's take that out, 12 

### and then we're completely consistent with IECC. 13 

### And I think it's the simplest way to say that. 14 

### MR. RAMIREZ: Okay. So, with that 15 

### understanding, what I'm trying to do is to see if 16 

### we get agreement on this so that can be plugged 17 

### into any future models so we don't have to keep 18 

### on going back and forth on this. 19 

### Yeah, Mark? 20 

### MR. WEISS: Okay. That raises two 21 

### questions that I was actually going to save till 22207

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### the end. But I think we'll need to bring them up 1



### now. 2 

### These three documents we have, these are 3 

### being proposed as substitutes for presumably 4 

### parallel provisions of the IECC; is that correct? 5 

### MR. LEVY: That's correct. 6 

### MR. WEISS: Okay. So, based on that, to 7 

### me these should go into the same chart that we 8 

### did for the stuff that Manny had earlier, subject 9 

### to what's in that chart. 10 

### MR. RAMIREZ: Okay. 11 

### MR. WEISS: As proposed parallel 12 

### replacements for specified IECC provisions. 13 

### MR. RAMIREZ: Right. And then, Manny, I 14 

### would ask you -- not Emanuel, I got it right this 15 

### time. Manny, is that something that then you 16 

### would incorporate with your subcommittee as 17 

### you're outlining the 2015 IECC stuff? 18 

### MR. SANTANA: Can I use the "I spaced 19 

### out" card, and can you repeat that? 20 

### [Laughter.] 21 

### MR. RAMIREZ: Exactly. Thank you. 22208

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### So, that was a thumbs-down, and that was 1 

### exactly why you would choose it, right, to ask 2 

### that question? 3 

### So, as we're sitting here, if the group 4 

### is saying, "Yeah, we're okay with this component 5 

### here to insulate to R-8 when you have the ducts 6 

### that are outside the envelope," then what you 7 

### would do is, when you're going through the 2015 8 

### IECC stuff and you're looking for where to make 9 

### the changes, this would be one that you'd 10 

### incorporate in there because the group has agreed 11 

### to go along with this. 12 

### MR. SANTANA: Yeah, right. That is 13


### correct. 14 

### MR. RAMIREZ: Okay. Okay, great. 15 

### So then, we'll -- 16 

### MR. HAGERMAN: But on that note, I mean, 17 

### this is one that's already in the manufactured 18 

### housing code, correct? And so this would not be 19 

### a cost increase. Right? 20 

### [Inaudible interjections and laughter.] 21 

### MR. SANTANA: You know, that is correct 22209

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### as well. And, you know, in all fairness, I think 1 

### this is one of the prescriptive portions of it. 2 

### So, you know, with so much to go through on the 3 

### mandatory side, I don't know that we have time to 4 

### get to it. 5 

### But if we were to, it might be one of the 6 

### ones that we just kind of gloss over because it's 7 

### already in the HUD code. And I'm not exactly 8 

### sure how we would address it. We might take the 9 

### position that there are more important things to 10 

### worry about. This is almost done. 11 

### MR. RAMIREZ: Okay. Then we'll update 12 

### that then and get that out. Okay? 13 

### MR. WEISS: Just for clarification, the 14 

### parallel provisions we're talking about for this 15 

### one, the ducts. 403.3.1 and 403.3.3, that's the 16 

### stuff we haven't discussed yet on the testing, 17 

### correct? It looks that way to me. 18


### MR. SANTANA: Correct. 19 

### MR. WEISS: It looks that way to me. 20 

### On the SHGC, which you've already 21 

### discussed, it looks like the parallel provision 22210

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### is 402.1.2 in the corresponding table. 1 

### MR. RAMIREZ: 402. -- 2 

### MR. WEISS: 402.1.2 in the corresponding 3 

### table, which I don't have the number of. Where 4 

### is that one? 402.1.2. Yeah, same. Table is the 5 

### same reference. 6 

### MR. RAMIREZ: Okay. So, for 7 

### clarification, everyone is okay with that, to 8 

### plug that in for future references, correct? 9 

### Show of thumbs? 10 

### [Pause.] 11 

### MR. RAMIREZ: All right. I sparked up 12 

### that steamroller and went over a couple of people 13 

### because I didn't see any thumbs. So we're moving 14



### on. 15 

### All right. Great. So what else do you 16 

### have on your document there, Emanuel? 17 

### MR. LEVY: Well, first I want to 18 

### congratulate the committee. It took us only 45 19 

### minutes to agree on something that's already in 20 

### the standard. So we're in good shape. 21 

### [Laughter.] 22211

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### MR. LEVY: Okay. So, under duct leakage, 1 

### and this is a much more substantive part, because 2 

### it has to do not only with what the requirement 3 

### is, but how -- and it gets into the verification 4 

### of that requirement. 5 

### And if you look above -- Javier, if you 6 

### can go back up to the table above? You'll see 7 

### that maximum duct leakage, there's not currently 8 

### a requirement -- I believe that's correct -- in 9 

### the HUD code. 10 

### And the 2009, there was a requirement set 11 

### that the duct system couldn't leak more than 8 12 

### cubic feet per minute per 100 square feet of 13 

### conditioned floor area. This is kind of a 14 

### universal metric for measuring air leakage from 15 

### duct systems. 16 

### That was reduced to four, a level of 17 

### four, for both the 2012 and 2015 IECC. 18 

### The proposal on the table is recognizing 19 

### that the leakage will be -- can only be measured 20 

### under the statute in the plant. I've suggested 21 

### in two parts. One is to maintain the four when 22212

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### the measurement is done without the air handler 1 

### in place, and a target of six cubic feet when the 2 

### air handler is in place. 3 

### There's a section, before I turn this 4 

### back to comments, there's two sections below this 5 

### that I'll touch on in a minute. One of them has 6 

### to do with sealing instructions, which is more of 7 

### a prescriptive direction on how you get to those 8 

### lower leakage levels. 9 

### And then in section B, right there, is a 10 

### description of how the leakage is actually 11 

### measured. It's a protocol for measuring leakage. 12 

### This is a fairly standard protocol. 13 

### So that's the proposal on the table, is 14 

### four CFM for leakage, maximum leakage, without 15 

### the air handler, and six with the air handler in 16 

### place. Let me stop there. 17 

### MR. LUBLINER: Emanuel, Mike Lubliner. 18 

### I think this is real good. I do have one 19 

### constructive suggestion based on communications 20 

### on this with some of the folks I work on at the 21 

### ASHRAE that developed these testing standards, 22213

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### ASTM, and manufacturer of the testing systems. 1 

### It seems like that the six cubic foot per 2 

### minute per 100 square foot varies with the size 3 

### of the house. And I'm just wondering. You know, 4 

### a furnace is a furnace. It leaks. Whether it's 5 

### a 16 KW electric furnace or something else, it 6 

### tends to have a leakage value. 7 

### And I'm just wondering -- and if it 8 

### doesn't vary with the size of the house, I'm just 9 

### wondering whether it would be more appropriate, 10 

### as I think we do in the Northwest in our ENERGY 11 

### STAR program when we test the house with the 12 

### furnace in place, is to consider something that's 13 

### a fixed number, not variable with, per square 14 

### foot. 15 

### I'm just wondering if that's a friendly 16 

### amendment or something that we could put in as 17 

### technical leads, but agree to look into something 18 

### equivalent to the six feet per minute that's more 19 

### reflecting of the physics of the furnace being a 20 

### fixed leakage. 21 

### MR. SANTANA: You mean a percentage lost 22214

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### or percentage of the leakage type? 1 

### MR. LUBLINER: Well, like what we do, I 2 

### think -- and I have to double-check with the guys 3 

### that run the program in the Northwest. But I 4 

### think they just subtract 40 CFM for the furnace, 5 

### period. They don't have a variable of that 6 

### that's based on the house size, because a furnace 7 

### is a furnace. 8 

### So anyway, I'm just wondering where that 9 

### six came from. And maybe suggesting that, from a 10 

### physics standpoint, since it's a fixed leakage, 11 

### it shouldn't vary with the home. It should be a 12 

### fixed number. What that number is I'm open for 13 

### suggestion. 14 

### Emanuel, do you understand where I'm 15 

### going with that? 16 

### MR. LEVY: Yeah. Absolutely. 17 

### MR. LUBLINER: Okay. Thank you. 18 

### MR. LEVY: I mean, there's one furnace. 19 

### There's one place for leakage to occur. Sure. 20 

### MR. LUBLINER: The other thing is, there 21 

### is a standard, 193, an ASHRAE standard, which is 22215

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### a method of test to determine the air leakage 1 

### rate of an HVAC box. And that's standard 193. I 2 

### chaired that committee. 3 

### And that standard is referenced in the I4 

### codes in the State of California as the method of 5 

### test to determine what those codes are prescribed 6 

### for as a, quote, "tight box," just an FYI. I 7 

### don't know that we need to get into those weeds 8



### now. 9 

### But I would suggest that we just look at 10 

### whether or not we could substitute CFM in there 11 

### and then get back on what that appropriate CFM 12 

### would be from some discussions we can have 13 

### offline. 14 

### Anyway, I don't want to hold things up 15 

### with that weeds, technical weeds discussion, but 16 

### I think it's important. Thank you. 17 

### MR. RAMIREZ: So then, where do we go 18 

### with this? Manny has this up here. If we're 19 

### going to look at just one number -- I'm sorry, 20 

### Emanuel. 21 

### Emanuel, is that something that you would 22216

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### dig up? Or Luby, is that on you to get Emanuel a 1 

### number? 2 

### MR. LUBLINER: I will get the information 3 

### on what the number is we use from the Northwest 4 

### program and share it with Emanuel. And then we 5 

### can decide whether or not it's appropriate. 6 

### MR. RAMIREZ: Okay. 7 

### MR. LEVY: Yeah, I think that's 8 

### appropriate. I understand, Michael, what you're 9 

### saying. And I'm just trying to think about what 10 

### that number might be to be representative of the 11 

### range of cases that we would be -- that would 12 

### actually be encountered. But I'd certainly be 13 

### open to that. 14 

### MR. LUBLINER: Thank you. 15 

### MR. RAMIREZ: Okay. What do you have 16


### next? 17 

### I'm sorry. Eric, then Lowell, and then 18 

### Mark. 19 

### MR. LACEY: This is Eric. Just for 20 

### Emanuel, one clarifying question. 21 

### In the IECC, there's an exception to the 22217

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### duct testing requirement if all ducts and air 1 

### handlers are located inside conditioned space. 2 

### And I'm wondering if you intended to include that 3 

### exception, or if the intent here is to have the 4 

### ducts tested in every manufactured home. 5 

### MR. LEVY: You know, that's a very good 6 

### point. Eric, I'm glad you brought that up 7 

### because that is something that should be in here, 8 

### and it's not. So I will add that after this 9 

### call. 10 

### Does everybody understand what Eric has 11 

### just suggested? 12 

### MR. LACEY: I mean, personally, I'd 13 

### prefer that every system be tested. I think it's 14 

### better. But that is something that I know a lot 15 

### of builders take advantage of. And it's -- you 16 

### know, locating inside conditioned space is by far 17 

### the most efficient way to do it. 18 

### MR. LEVY: And that encourages 19 

### manufacturers to do that. So I think that would 20 

### be a good thing to include. 21 

### MR. RAMIREZ: Okay. And again, Emanuel, 22218

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### will you dig that up and throw it in there? 1


### MR. LEVY: Yes. 2 

### MR. RAMIREZ: Okay. 3 

### MR. LEVY: Yes. I'll add that into the 4 

### language here. 5 

### [Pause.] 6 

### MR. LUBLINER: This is Mike Lubliner. 7 

### I had mentioned ducts and the conditions 8 

### based on one of our first meetings. I totally 9 

### support where both you guys are going. 10 

### MR. RAMIREZ: Mike, hold off for a 11 

### second. We've got Lowell and then you, okay? 12 

### MR. LUBLINER: Sorry. 13 

### MR. EZZO: This is Mark. 14 

### I think he were just supporting what was 15 

### just said. 16 

### I had a couple of questions that were 17 

### different. One is, at the beginning of 2, it 18 

### says, "the prescriptive and-or performance 19 

### targets." And I'm wondering whether you meant 20 

### "and" or "or." I don't see how it can be both 21 

### "and" and "or." 22219

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### [Pause.] 1 

### MR. LEVY: Yeah. I think that's an 2 

### artifact. I had an earlier version. Let me just 3 

### see if I'm looking at that. There's one more 4 

### section to this. Maybe we can come back to this, 5 

### because there's one more section I want to talk 6 

### about, which is the sampling procedure. 7 

### MR. EZZO: So, leave that for the moment. 8 

### So the second question is, you have the 9 

### detailed duct leakage test procedures. 10


### MR. LEVY: Yes. 11 

### MR. EZZO: And I wasn't sure where those 12 

### -- since I'm certainly not qualified to judge the 13 

### details of them, I'm wondering where they came 14 

### from. 15 

### MR. LEVY: Yeah. This is a fairly 16 

### standard protocol for doing testing. You know, 17 

### this is how the tests are actually done. And I 18 

### don't know. Michael, does this -- I've used this 19 

### in so many different places, I can't tell you 20 

### exactly what the origin of it is. It is 21 

### referenced from a number of different standards. 22220

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### Mike Lubliner, do you know? 1 

### MR. LUBLINER: Yeah, I'm here. You're 2 

### talking about the protocol, the section B, 3 

### basically, the duct procedure? 4 

### MR. LEVY: Right. Um-hm. 5 

### MR. LUBLINER: Yeah. I mean, I think 6 

### it's -- there's different references there. But 7 

### it seems to be what I see is out there. There is 8 

### a requirement that only test method B in the STM 9 

### standard be used. There are other approaches, 10 

### but not ones that I want to raise at this point. 11 

### So I'm pretty good with that. 12 

### My question on this one really gets back 13 

### to the question of where HUD is at. At one 14 

### point, the consensus committee went ahead and 15 

### approved the requirement for duct leakage and 16 

### actually had promulgated some wording that I 17 

### thought was awaiting HUD to decide if they were 18 

### going to promulgate it as a standard. 19 

### So I didn't want to put Rick on the spot. 20 

### But if Rick felt comfortable talking about what 21 

### status of that, maybe it would be good for some 22221

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### background to let people know that, like the RA 1 

### crossover, the consensus committee work with HUD 2 

### to adopt. We're in the process of something on 3 

### the duct leakage. And we might be able to learn 4 

### from that. That's the one point. 5 

### And the other point is that I do think 6 

### that when you move the ducts totally in the 7 

### conditioned space, and I think this would be 8 

### applicable in a single-section home if you could 9 

### drop a chase for the duct trunk, that there's 10 

### really large energy savings potential there that 11 

### could possibly be traded off against other 12



### measures. 13 

### It's not just the air leakage. It's the 14 

### conduction of the ducts. The ducts are no longer 15 

### in a 160-degree attic running air-conditioning 16 

### air with R-8. They're inside the building at 78 17 

### degrees. 18 

### So that's an area that I would encourage 19 

### DOE to look at from the analysis standpoint 20 

### issue. What's the energy savings associated with 21 

### moving those ducts that are R-8 out of the attic 22222

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### and into the house? And it may be beyond the 1 

### scope, because as I understand, all the modeling 2 

### looked at the ducts being in the floor, not in 3 

### the attic at all. 4 

### So, but getting back to your question, 5 

### Emanuel -- I took the liberty of rambling on here 6 

### -- yeah, I think it's adequate. 7 

### MR. WEISS: Just getting to the good 8 

### part. 9 

### [Laughter.] 10 

### MR. RAMIREZ: You faded out there. 11 

### MR. UNGER: I had two additional, besides 12 

### the response to my question, I saw a couple more. 13 

### I heard two additional questions that were added 14 

### there. So if you want to deal with those first? 15 

### MR. RAMIREZ: Yeah. Go ahead, Mark. 16 

### MR. WEISS: I'll wait. I have a much 17 

### less-technical question. 18 

### MR. UNGER: I also had a couple more 19 

### things. 20 

### MR. RAMIREZ: Go ahead. 21 

### MR. LEVY: Let me just answer that 22223

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### earlier question about the performance and 1 

### prescriptive. 2 

### MR. UNGER: Yeah. 3 

### MR. LEVY: This is just a wording change. 4 

### The duct leakage 82 is a performance standard. 5 

### The additional requirements for sealing, which 6 

### are prescriptive in nature, they're prescriptive, 7 

### so it's "and," prescriptive and performance 8 

### targets. You have to go both of those things. 9 

### MR. UNGER: Thanks. 10 

### MR. LEVY: What we're suggesting is that 11 

### there's a series of sealing measures that ought 12 

### to be undertaken consistently, regardless of what 13 

### the performance target is. 14 

### MR. UNGER: Emanuel, if I understand, the 15 

### prescriptive happens on every house. The testing 16 

### happens on a sampling basis. 17 

### MR. LEVY: That's correct. 18 

### MR. RAMIREZ: Okay. 19 

### MR. LEVY: And that we'll get to in a 20 

### moment. That's a piece we'll get to in a minute. 21 

### That's in section C. 22224

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### MR. UNGER: So, I also was just looking 1 

### at IECC. And if I understand, post-construction 2 

### they don't refer to air handlers. But pre3 

### construction, it's actually four cubic feet per 4 

### minute with an air handler, or three if there's 5 

### not an air handler. Is that correct? 6 

### So in some -- so if I understand it, the 7 

### equivalent for IECC would be four and three, 8 

### where this proposal is six and four. 9 

### [Pause.] 10 

### MR. UNGER: And so I guess my question 11 

### there would be, my follow-up question is why does 12 

### this need to be -- you know, if we're starting 13 

### from IECC, is there a reason why manufactured 14 

### homes can't meet the same standard? Or is this a 15 

### case where argument is it's not cost effective or 16 

### something? 17 

### MR. LUBLINER: This is Mike Lubliner. I 18 

### could try to answer that. 19 

### I think that, you know, in the assumption 20 

### the IECC is that the air handler may be in the 21 

### unconditioned space. I don't know that that's 22225

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### the case for this industry. It's always within 1 

### the building. 2 

### There may be some Southern climates, 3 

### Miami, where they used to have some air handler 4 

### that was outside the building. But I don't know 5 

### if that's even around anymore. I could go to 6 

### manufacturers. But I think that that's kind of 7 

### an apples-and-oranges. The IECC was broad or it 8 

### was looking at homes where the air handler may 9 

### not be in the conditioned space. 10 

### But I'm not really clear. I wasn't 11 

### involved in that with the I-codes. 12 

### MR. RAMIREZ: Okay. Now, you had a 13 

### question for Rick? Michael? 14 

### MR. LUBLINER: Yeah. I was just 15 

### wondering if Rick was in a position to update us 16 

### on this status of the duct leakage testing 17 

### proposal that the consensus committee approved in 18 

### 2009. It's been awaiting HUD action, I believe. 19 

### Clarify for me if I'm wrong, Rick. 20 

### MR. RAMIREZ: Okay. Okay. Rick, hold on 21 

### a second because -- 22226

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### MR. HAGERMAN: Let me interject. You 1 

### know, Mike, I think just so that we can move this 2 

### committee along, I think if you need to ask him 3 

### that question, you should do -- I don't think 4 

### that's really necessarily germane. I mean, this 5 

### is the consensus committee for DOE's standard, 6 

### not the MHCC. 7 

### MR. LUBLINER: Yeah, I totally respect 8 

### that. If it's not appropriate, I'll withdraw the 9 

### question. I was thinking one of the comments 10 

### made the other day by Mark Weiss was better 11 

### communications with HUD. When Mr. Mendlen has 12 

### come over, I thought that information would be 13 

### useful for the group. 14 

### But I respect that totally. Thank you. 15 

### MR. RAMIREZ: All right. Thank you. 16 

### Mark? 17 

### MR. LEVY: This is Emanuel. 18 

### Lowell, I wanted to take a shot at 19 

### answering your question. 20 

### MR. RAMIREZ: Go ahead, Emanuel. 21 

### MR. LEVY: Okay. In the IECC, I'm 22227

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### looking at the '09. I'm not sure if the '12 is 1 

### worded exactly the same way. You have two 2 

### options for verifying duct tightness. The first 3 

### is a post-construction test. And I'm assuming, 4 

### because of when the homes would be tested, that 5 

### that would be more relevant to our case. 6 

### In that case, it says, "Total leakage 7 

### shall be less than or equal to four CFM of 8 

### conditioned floor area when tested at a pressure 9 

### differential," et cetera. "All register boots 10 

### shall be taped or otherwise sealed under this 11 

### test." 12 

### So that's an option -- that's option one 13 

### that would be available to builders. 14 

### There's a second test, as you said, 15 

### during rough-in, which I didn't bother to consult 16 

### because I thought the point at which they would 17 

### be tested in the plant would be more analogous to 18 

### post-construction testing. 19 

### MR. RAMIREZ: Okay. 20 

### MR. UNGER: I'm not sure that answers. I 21 

### assume that would typically be with an air 22228

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### handler. And so, that you're recommending that 1 

### in that case -- and I don't know which is more 2 

### difficult for manufactured homes. But in 3 

### essence, you're recommending six rather than four 4 

### CFM. And I wasn't sure why what you were 5 

### recommending would not follow IECC in this case. 6 

### [Pause.] 7 

### MR. LEVY: Yeah. That's right. To be 8 

### consistent with IECC, would be four at the upper 9 

### limit. 10 

### MR. ROY: This is Robin. Do we have a 11 

### sense of what the energy implications of six 12 

### versus four are? 13 

### [Pause.] 14 

### MR. WEISS: Well, that kind of verges 15 

### into my question. The first one is, just to 16 

### clarify, I mean, the testing would be a new 17 

### requirement. Is that right? Is that correct, 18 

### Emanuel? 19 

### MR. LEVY: Yes. I think many of the 20 

### manufacturers already do testing. 21 

### MR. WEISS: Okay. 22229

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### MR. LEVY: I don't think it's mandatory, 1 

### but I would defer to the manufacturers on that. 2 

### MR. WEISS: Okay. So it would be a new 3 

### mandatory requirement. 4 

### And the next question is to the meat of 5 

### it. Why four? Why not two, three, one, six, 6 

### ten? Is this four just to be consistent with 7 

### IECC, or is there some other rationale behind 8 

### that number? And have the cost implications of 9 

### four versus some other number been considered 10 

### already, or is that something that's pending? 11 

### MR. LEVY: My take on that is that four 12 

### is one of those things that has come out of 13 

### practice as to what is possible on a routine 14 

### basis to achieve, with good sealing measures. 15 

### It's probably not easily cost 16 

### quantifiable or cost-benefit quantifiable because 17 

### it's difficult to put your finger on what the 18 

### cost would be for any one building to achieve one 19 

### number versus another. 20 

### So I think this is one of those more 21 

### professional judgmental issues than anything 22230

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### else. 1 

### MR. WEISS: Okay. And I mean, you can 2 

### understand my concern. Just because something is 3 

### possible doesn't mean it's cost effective. It 4 

### could involve significant costs. It's not 5 

### necessarily worth it. 6 

### MR. LEVY: It could. And just to answer 7 

### your question, I don't think we will really know 8 

### how difficult this is on a routine basis until 9 

### it's administered in the plans and required for 10 

### compliance. 11 

### MR. WEISS: That sounds like you don't 12 

### know what's in it till you read it, I don't know, 13 

### till we pass it, rather. 14 

### MR. LEVY: Well, perhaps some of the 15 

### manufacturers can speak to it, who have done this 16 

### testing, can speak to that as an issue. But -- 17 

### MR. WEISS: That's fine. I appreciate 18 

### your answer. Thanks. 19 

### MR. LEVY: Yep. 20 

### MR. SANTANA: Can we scroll up a little 21 

### bit to the comparison of the duct leakage from 22231

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### the HUD? This is Manny, by the way. From the 1 

### HUD to the -- you know, so when you look at this 2 

### chart, in table 1, you see that the IECC kind of 3 

### went through a progression. They went from 4 

### nothing to eight to four to four. 5 

### And I think that reinforces what Emanuel 6 

### said, that it was, kind of learn what you can do 7 

### as you go along. 8 

### You know, as far as what we've been able 9 

### to achieve with testing, I haven't been able to 10 

### gather up enough evidence to have anything 11 

### concrete to show, that illustrates a trend. But 12 

### I'd be a proponent to also have a kind of a 13 

### tiered approach, similar to what the IECC did. 14 

### You know, what do you guys think about starting 15 

### with eight and then seeing how that goes before 16 

### we just jump right into four? 17 

### MR. LUBLINER: This is Mike Lubliner. I 18 

### could comment on my feeling on that. 19 

### I'm not real keen on that. My 20 

### understanding -- and I'd like the manufacturers 21 

### to provide feedback, if they would -- is that the 22232

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### reason that the manufacturers, part of the reason 1 

### the manufacturers are testing voluntarily their 2 

### ductwork, particularly in the hot, humid 3 

### climates, is to avoid callbacks and potential 4 

### moisture litigation due to a number of things. 5 

### And so that there's some economic benefit 6 

### of doing this, to them, regardless of energy 7 

### savings. And this is in response to Mark's 8 

### comment about hidden costs. There's also hidden 9 

### savings. 10 

### I'd like the manufacturers, if they're 11 

### willing, to explain why they are currently 12 

### testing for ducts and whether or not it's 13 

### benefiting them on the moisture and callback 14 

### issue, as well as their experience testing ducts, 15 

### which I understand is a requirement for ENERGY 16


### STAR. 17 

### There's been thousands and thousands of 18 

### ENERGY STAR homes built by this industry. So I'm 19 

### assuming that there is some experiencing testing 20 

### these ducts in the factory. 21 

### Emanuel, I'd love to get your perspective 22233

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### as well, because I know you've looked at the 1 

### implications of moisture issues in supply duct 2 

### leakage in hot, humid climates. Thank you. 3 

### MR. SANTANA: Yeah, this is Manny again. 4 

### And I could answer, I guess, to a degree 5 

### just -- and this is just on the personal basis 6 

### with the knowledge that I have. It doesn't speak 7 

### to the industry as a whole. 8 

### But the answer to that is that it really 9 

### does depend on the region. You know, certain 10 

### parts of the country where it's hot and wet, you 11 

### know, hot and humid are really susceptible to 12 

### having moisture issues in the house. And those 13 

### plans, in order to -- you know, exactly what Mike 14 

### said. 15 

### In order to combat service calls and 16 

### those kinds of issues, you know, they found that 17 

### even in their ducts and having tight ducts helps 18 

### to mitigate that. You know, we have some other 19 

### plants in areas where it's dry that don't have to 20 

### worry about that. 21 

### So I really -- you know, it comes back 22234

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### to, you know, building what's required for your 1 

### area. It isn't an issue throughout the entire 2 

### country. So some plants do it, and some plants 3 

### don't. You know, it's a good idea to have a 4 

### tight duct. That goes without saying. But just 5 

### the level of which is what I'm talking about. 6 

### MR. RAMIREZ: Okay. 7 

### MR. EZZO: It's Mark at Clayton Homes. 8 

### I agree with what Manny said. We do the 9 

### same thing. We have a lot of plants that do an 10 

### awful lot of duct testing. And, Mike, to your 11 

### question, it's primarily to fix some of the 12 

### problems that we've had mainly in the hot, humid 13 

### climates. But we have carried that to a lot of 14 

### facilities that are in other parts of the country 15 

### as well. 16 

### But I do agree with what Manny suggested 17 

### about a tier approach. Just starting off and 18 

### going all the way down to four right out of the 19 

### gate for an industry that's never required this, 20 

### I think that's a pretty big leap. 21 

### I'm not saying it can't be done, and I'm 22235

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### not saying that it's impossible to do. But I 1 

### think our proposal, which is to start at six -- 2 

### is it six, Emanuel? 3 

### MR. LEVY: Well, it's four without the 4 

### air handler, and six with air handler. 5 

### MR. EZZO: Six with air handler? 6 

### MR. LEVY: Yep. 7 

### MR. EZZO: I think that's a pretty fair 8 

### compromise. 9 

### MR. ROY: It's Robin. 10 

### Mark, that sounds sensible to me, too. 11 

### But I'm curious. I am curious what we're giving 12 

### up in terms of energy. I like the idea of 13 

### staging down, but I'd also like to know what 14 

### we're giving up and how important it is to ever 15 

### get to four, in fact, if it's even worth leaving 16 

### it at six. 17 

### MR. LEVY: Robin, I can't answer that 18 

### because I have no idea. 19 

### MR. ROY: No, I'm looking over at Joe 20 

### still to see if they've done that analysis. 21 

### MR. LEVY: Oh, okay. 22236

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### MR. ROY: Have you done that energy 1 

### analysis? 2 

### MR. HAGERMAN: We just pulled up the 3 

### numbers and we looked through it. It looked like 4 

### there's max, depending on the climate zone and 5 

### everything, two KBTU's per square foot per year. 6 

### So in my opinion, it's not widely significant. 7 

### But you'd have to come up with your own 8 

### conclusions. 9 

### MR. ROY: Thanks for that. 10 

### MR. HAGERMAN: Going from eight to four. 11 

### MR. LUBLINER: And what is two KBTU 12 

### relative to the total per square foot? 13 

### [Pause.] 14 

### MR. BARBOUR: This is Ed Barbour. Yeah, 15 

### anywhere from 10 percent in the Southern climate 16


### zones to -- 17 

### MR. LUBLINER: Two percent? 18 

### MR. BARBOUR: Two percent in the Northern 19 

### climate zones. 20 

### MR. UNGER: This is Lowell. Ten percent 21 

### for one measure sounds like a lot to me. 22237

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### MR. BARBOUR: That's of the total annual. 1 

### I mean, approximately if you do two -- ballpark. 2 

### Keeping in mind that there's multiple measures 3 

### still called in there. So we're just kind of 4 

### trying to eyeball what it is. 5 

### MR. UNGER: Yeah, the total is 28. 6 

### MR. BARBOUR: Yeah, I understand. So two 7 

### would be -- if it's 24, about 10 percent. 8 

### MR. LUBLINER: So, not so significant in 9 

### the North, but fairly -- quite significant in the 10 

### South is what your eyeball is telling you? 11 

### MR. BARBOUR: Based on the eyeball test, 12 

### yeah. 13 

### MR. LUBLINER: Right. 14 

### [Cross-talk.] 15 

### MR. RAMIREZ: Let me get Eric, then Mark. 16 

### MR. LACEY: All right. Thanks. This is 17 

### Eric. 18 

### One of the questions that I was thinking 19 

### about for so long that I totally forgot what it 20 

### was. Can you come back to me? 21 

### [Laughter.] 22238

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### MR. RAMIREZ: No problem. 1 

### Mark? 2 

### MR. WEISS: Yeah, Eric, I've been there, 3


### too. 4 

### [Laughter.] 5 

### MR. WEISS: And it gets worse as you get 6 

### older, believe me. Mark Weiss, MHARR. 7 

### Just a point. I mean, if some folks are 8 

### doing this already, it would seem to me that 9 

### there must be some way to get some relative cost 10 

### information related to this rather than just 11 

### relying on, you know, luck and hope and, you 12 

### know, see what we find out in the future. 13 

### MR. RAMIREZ: Okay. Eric, are you ready? 14 

### MR. LACEY: Yeah, it came back. Thanks. 15 

### MR. RAMIREZ: Okay. 16 

### MR. LACEY: Sorry. I wasn't planning on 17 

### talking this much. 18 

### One other question. And I'm not sure if 19 

### folks realize this. But the duct testing 20 

### requirement actually, in some way it's got a 21 

### little less efficient or a little less stringent 22239

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### in 2015 in the IECC. And it's not really 1 

### reflected up there. 2 

### Even though the tested leakage level is 3 

### the same at four CFM, it was turned from a 4 

### mandatory level to a prescriptive level. 5 

### What that means is, if you don't think 6 

### you can routinely hit four, or if when you test 7 

### it, it doesn't hit four, you can trade that off. 8 

### So if you're concerned about whether you can hit 9 

### whatever level this group sets, you know, I don't 10 

### know where you'll end up on that. 11 

### But if it's just, you know, a little bit 12 

### too tight or something, you can make up for that 13 

### energy savings in another way, in the thermal 14 

### envelope or somewhere else. 15 

### You know, in the 2012 IECC, you 16 

### absolutely had to hit that level and there was no 17 

### exception to it unless you had all the ducts 18 

### inside conditioned space. In 2015, that 19 

### mandatory designation was removed so that you 20 

### could trade off. Even though the standard level 21 

### was set at four, you could make up for that 22240

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### somewhere else if you failed. 1 

### I just wanted to clarify. 2 

### MR. LEVY: Eric, yeah, the danger of 3 

### that, of course, is that you don't know what 4 

### you're going to hit until you build a home. 5 

### And if you want to do what you're 6 

### suggesting, which is to be ultra-conservative and 7 

### say, "All right, I assume I'll get to a six or an 8 

### eight because I'm pretty sure I can do that 9 

### routinely," then you're basically having to over10 

### insulate the rest of your building because you 11 

### have this fear that you won't make the target for 12 

### duct leakage. 13 

### MR. LACEY: I think you're in a much more 14 

### controlled environment in a manufacturing 15 

### facility than you are in the stick-built onsite 16 

### where every home is built, you know, from the 17 

### ground up and it may be by different contractors 18 

### and so on. 19 

### I tend to think that the ducts would be 20 

### more easily controlled and the quality control 21 

### would be much better in a manufacturer. But I 22241

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### can't comment on what the appropriate level of 1 

### leakage should be. That's for you all. 2 

### MR. HAGERMAN: Let me clarify something I 3 

### said -- Joe Hagerman. 4 

### We re-eyeballed the data here just for 5 

### better measures. And it looks like in Houston, 6 

### it's two KBTU's per square foot per year, which 7 

### is about 7 percent. Now, it's sort of hard to 8 

### disaggregate specifically the number that you're 9 

### talking about. So I would range it by saying 5 10 

### to 7 percent. 11 

### But that's going from eight to four. The 12 

### proposal that Emanuel is talking about is six. 13 

### So you're not quite all the way at eight, right? 14 

### And what the code says is four, so you're not -- 15 

### so you have to take that into account. So I'd 16 

### say you're anywhere from 2.5 to 5 percent, in 17 

### Houston, which would be worst-case. Use your own 18 

### eyeballs. 19 

### MR. LUBLINER: This is Mike Lubliner. 20 

### MR. RAMIREZ: Yeah, Mike. 21 

### MR. LUBLINER: Yeah. I think one of the 22242

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### points to make when we're comparing it to the 1 

### IECC is that the home that we're testing in final 2 

### is complete when it's a site-built home. But we 3 

### still have the cross-over duct or the rim joist 4 

### leakage associated with a through-the-rim system. 5 

### So when we're talking about this, we're 6 

### really not talking about the final leakage of the 7 

### home. We're just talking about the component 8 

### that the manufacturer is building. And our 9 

### experience is that a significant amount of 10 

### leakage happens after the fact. So I think it's 11 

### important that we remember that as we're 12 

### comparing the site-built. 13 

### Our program standards for ENERGY STAR 14 

### NEEM program in the Northwest are 5 percent, I 15 

### believe. And maybe that's an appropriate number. 16 

### If we go ahead and come up with a factor for the 17 

### furnace testing, you know, I think we can work in 18 

### this. 19 

### But the bottom line is that if you use 20 

### mastic and you have a good prescriptive 21 

### procedure, you're going to find it is what it is. 22243

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### And you're going to be periodically testing. 1 

### And I think what you find if you were to 2 

### do testing over and over and over is, the 3 

### variability is going to be there for -- it could 4 

### be between three and six on any given day on any 5 

### given house. So we need to be a little clear on 6 

### understanding this. 7 

### I'm very comfortable, if there was a 8 

### commitment from DOE that they're going to do some 9 

### evaluation if this code gets adopted of what the 10 

### leakage is in the factory and adjust it 11 

### accordingly, based on what we find. So I'd 12 

### rather start with a conservative number like 4 or 13 

### 5 percent. And then if they find that we can't 14 

### get there, we can make some provisions down the 15 

### road. 16 

### But I guess I would like to get a better 17 

### handle. If the manufacturers say 5 or 4 percent 18 

### isn't going to cut it, 5 percent without the 19 

### furnace, then we're going to have to work through 20 

### our differences here. 21 

### Sorry for the ramble. Thank you. 22244

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### MR. RAMIREZ: Mark? 1 

### MR. WEISS: Yeah, a few questions. 2 

### Joe, you said Houston was worst-case. 3 

### Why is Houston worst-case? Because of the 4 

### humidity? So in different climates, the impact 5 

### is going to be different, correct? 6 

### Okay. So my question, first to Emanuel, 7 

### is the four figure for the IECC, that's across 8 

### all zones; is that correct? 9 

### MR. LEVY: That's correct. 10 

### MR. WEISS: Okay. Is this something that 11 

### perhaps -- and I'm just putting this out there, 12 

### as a nontechnical person. Is this something that 13 

### perhaps we should be looking at in terms of 14 

### different zones in that ultimate discussion? 15 

### Should it be different for different zones, or is 16 

### that just too much of a hassle to -- okay. 17 

### MR. LEVY: Well, and it probably is 18 

### easier for plants to develop standard protocol 19 

### for installation of duct systems to achieve a 20 

### certain target and not have to worry about where 21 

### the home is going. 22245

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### MR. WEISS: All right. I understand. 1 

### MR. LUBLINER: This is Mike Lubliner. 2 

### One minor comment I'd like to make. 3 

### And that's a question to Joe. Joe, when 4 

### this modeling was done, this all assumes all the 5 

### ductwork is in the belly. None of it, in other 6 

### words, there's no modeling that I saw where it 7 

### assumed ducts in the attic. 8 

### And that's really the area, when there's 9 

### duct leakage in the attic, that you really get 10 

### into significant higher energy savings by sealing 11 

### the ducts, relative. 12 

### So I think the modeling -- the numbers 13 

### you're coming up with are reflective and probably 14 

### accurate for that scenario where the ducts are in 15 

### the floor. I'm trying to get a sense of if 16 

### that's going to give us a story when the ducts 17 

### are in the attic. Maybe there's not a lot of 18 

### homes out here with ducts in the attic, and maybe 19 

### I should just not worry about it. 20 

### I'd like to get some input from you on 21 

### the analysis, and the manufacturers on the 22246

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### prevalence of ducts in attics versus floors, and 1 

### the adequacy of modeling it only as a floor 2 

### system. 3 

### MR. RAMIREZ: So, it looks like we need 4 

### to -- sorry, Emanuel. You did some great work 5 

### here. But it looks like you're probably going to 6 

### have to do a little bit of cleanup based on some 7 

### of the discussion that we had here, and also that 8 

### the working group needs to look at the test 9 

### procedures to see if they're okay with that as 10 

### well. There's quite a bit there. 11 

### And then, Lowell, you have a comment? Go 12 

### ahead. 13 

### MR. UNGER: Just one more. I mean, so 14 

### what I've understood, I think, from this 15 

### discussion is that the IECC four is actually 16 

### including an air handler. And so the equivalent 17 

### number for your typical manufactured house would 18 

### actually be more like three without the air 19 

### handler, in terms of what would be comparable to 20 

### IECC 2015. 21 

### I also haven't heard any reason why 22247

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### that's not achievable. What I heard was that, 1 

### for manufacturers that haven't been doing this, 2 

### there may be a learning period to get there, 3 

### which suggests to me that, you know, if that's 4 

### the issue, that one should set a low standard, 5 

### but then either ratchet it in, a little higher 6 

### standard the first year or an exception the first 7 

### year or something, something which allows for a 8 

### period of learning, but with still the lower 9 

### ultimate standard. Thanks. 10 

### MS. HOFFMAN: We've got a request from 11 

### some of our folks on line for a one function 12 

### break. So let's come back in 10 minutes. Thank 13 

### you. So it's three o'clock. Come back at three. 14 

### Thank you. 15 

### [Recess taken from 2:42 to 3:01 p.m.] 16 

### MR. RAMIREZ: All right. Let's go ahead 17 

### and get started. 18 

### And we left off with trying to do a quick 19 

### little summary of where we're at on some of the 20 

### items here under the duct leakage. And I think 21 

### Lowell, trying to summarize it for us, basically 22248

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### we're looking at the possibility of a step-in to 1 

### allow for a learning curve for the manufacturers. 2 

### Those numbers or time hasn't been 3 

### tightened up. But either way, based on some of 4 

### the discussion that we had, it looks like, 5 

### Emanuel, I really appreciate all your hard work. 6 

### If I could impose on you a little bit more just 7 

### to help clean up some of the areas that the group 8 

### spoke of, that would be greatly appreciated. 9 

### Are you okay with that, Emanuel? 10 

### MR. LEVY: Yeah, of course. 11 

### MR. RAMIREZ: Okay. Thank you. 12 

### And then, on the other two pieces, on the 13 

### duct leakage and test procedures, as well as the 14 

### compliance piece, those two areas, although those 15 

### could be, you know, recommendations that go to 16 

### ASRAC, fall outside of the scope of this working 17 

### group. And so at this time, is everyone okay 18 

### with setting those aside? 19 

### Hopefully, we show them how functional we 20 

### are and we end up with a great term sheet, and 21 

### they say, "You know what? Keep going at it, and 22249

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### deal with the compliance piece." But if we do, 1 

### then that's the time when we'll discuss those 2 

### items in greater detail. 3 

### MR. HAGERMAN: This is Joe Hagerman, DOE. 4 

### I've always made the point to say when we 5 

### put that final term sheet together, I think that 6 

### it's going to include also a -- I would 7 

### hypothesize it would include a memo that this 8 

### committee writes that says, "This committee also, 9 

### you know, wants to make some other 10 

### recommendations to ASRAC, as DOE has to put forth 11 

### an enforcement and compliance rule as well," 12 

### right. 13 

### But just to be clear, the enforcement and 14 

### compliance is outside the scope of the current 15 

### charter. So I say we don't discuss that, just in 16 

### time's sake. We don't discuss it. And if the 17 

### group wants to add this to the memo, then you 18 

### approach it that way. 19 

### MR. RAMIREZ: Is everyone okay with that? 20 

### [Pause.] 21 

### MR. RAMIREZ: Okay. Hearing no 22250

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### objections -- sorry. 1 

### MR. LEVY: Javier, it's Emanuel. 2 

### Just let me add that the duct leakage 3 

### procedures and the compliance and the 4 

### requirements are kind of all of a piece. You 5 

### know, the requirements make sense if you do this 6 

### kind of -- if you run this kind of test, and this 7 

### is the way you would evaluate that number. 8 

### And the compliance piece is a part of 9 

### that because it has to do with how the industry 10 

### itself conforms to meeting that requirement. 11 

### So I really hear what you're saying about 12 

### it has to be handled a particular way from a 13 

### bookkeeping standpoint, or a presentation 14 

### standpoint. But I'd hate to see this go out and 15 

### not include all those pieces of it in some 16 

### fashion. 17 

### MR. HAGERMAN: This is Joe Hagerman. 18 

### I agree. I mean, the test procedure and 19 

### the enforcement, you know, are essential to 20 

### getting a good standard, right? The standard is 21 

### only as good as the test procedure and 22251

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### enforcement. 1 

### That's why I don't think we lose it. We 2 

### just add it to the memo and then let ASRAC 3 

### decide. It's my hope that ASRAC would extend 4 

### this working group if the members, you know, feel 5 

### interest in that. So this group could start 6 

### dealing with enforcement and compliance after we 7 

### deal with the standards. 8 

### MR. LEVY: So, are you saying, Joe, that 9 

### we should not talk any more about those pieces at 10 

### this point? 11 

### MR. RAMIREZ: Yeah. We'll set those 12 

### aside, and those go into the recommendation, 13 

### along with what we ultimately agree upon for the 14 

### duct leakage requirements that you've set up 15 

### here. 16 

### MR. LEVY: Okay. Yeah. 17 

### MR. RAMIREZ: Sound all right? 18 

### MR. LEVY: Good. 19 

### MS. HOFFMAN: Eileen Hoffman. 20 

### They're not lost. They'll be appended, 21 

### perhaps, to a recommendation, but they'll be 22252

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### there, but not formally discussed at this moment. 1 

### MR. RAMIREZ: Okay. So then, move on to 2 

### whole-house leakage? 3 

### MR. LEVY: Yep. 4 

### MR. RAMIREZ: Okay, Emanuel. You're on 5 

### again. 6 

### MR. LEVY: All right. So we know the 7 

### routine already. We're just talking about how 8 

### much leakage is allowed from the entire house 9 

### when tested with something like a blower door. 10 

### And here you can see, from this survey of 11 

### current requirements, what the history has been 12 

### in terms of HUD code. There is no specific 13 

### requirements in the IECC, which in the '09 14 

### version started out with a target of 7/8th ACH 15 

### added pressure difference of 50 Pascals and has 16 

### now been modified for the '12 and '15 versions to 17 

### five and three, respectively, for zones 1, 2, and 18 

### 3 through 8. 19 

### So that's the starting point. And again, 20 

### we can just actually go right down to -- we can 21 

### stop here at any point you want. But I was just 22253

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### going to say here, for the testing -- and this is 1 

### the essence of what the proposal is -- is kind of 2 

### in the same vein as our discussion about the duct 3 

### leakage. 4 

### It's kind of a phase-in, for a couple of 5 

### reasons. For the manufacturers, to seven and 6 

### five, seven being for zone 1 and five for zones 2 7 

### and 3, these are obviously above where the 8


### current IECC. 9 

### And the idea would be that this would, 10 

### again, give the industry a chance to figure out 11 

### how they are going to meet these standards and 12 

### give them some insight into how they're going to 13 

### meet more stringent standards in the future. 14 

### The rough part about this one, maybe even 15 

### harder than the ducts, is that single sections 16 

### are one challenge to do that. Because this is 17 

### being done in the plant. It's not being done in 18 

### the field. 19 

### But multi-sections are even a bit more of 20 

### a challenge because it means that the plant would 21 

### have to do something they don't typically do, 22254

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### which is to put both halves, if there are only 1 

### two halves, there are all the pieces together of 2 

### a home on a temporary basis to test it. 3 

### And that means they have to seal it up 4 

### analogous to how it would be sealed up on the 5 

### site. That could be a very time-consuming 6 

### process. And we don't know exactly how that will 7


### turn out. 8 

### There's been some limited testing in 9 

### plants, but it's not nearly enough to know what 10 

### the track record would be here. So we're kind of 11 

### tiptoeing into this one a little bit. And I 12 

### think we need some experience before we're 13 

### confident that these levels or something lower 14 

### than these levels are practical. 15 

### Again, there are other pieces associated 16 

### with this, a visual inspection, which would be 17 

### additional prescriptive things that we know that 18 

### are routine areas of potential leakage that would 19 

### be addressed. So all these would be prescriptive 20 

### requirements. 21 

### And then, of course, as with the ducts, 22255

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### there would be a testing procedure and a 1 

### compliance sampling procedure. But it sounds 2 

### like we're just confining our comments for the 3 

### moment to section A at the top. 4 

### Let me stop there. 5 

### MR. ROY: This is Robin. A quick 6 

### question for Joe, again. 7 

### Do you have a rough sense of what the 8 

### energy implications of different home leakage 9 

### are, just the same eyeball test? 10 

### MR. HAGERMAN: We'll put our eyeballs to 11 

### it. 12 

### [Laughter.] 13 

### MR. RAMIREZ: They're coming up with the 14 

### SWAG number? Scientific wild-ass guess. 15 

### Mark? 16 

### MR. WEISS: Just real quick, what's the 17 

### parallel IECC provision? I see something -- I'm 18 

### sorry. I turned the page. 403.6 about 19 

### mechanical ventilation, but where are you getting 20 

### the five and the three from? 21 

### MR. LEVY: It's the -- and I'm looking 22256

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### right at it, Mark. It comes out of the IECC. 1 

### [Cross-talk.] 2 

### MR. EZZO: Mark, it's 402.4, Air Leakage, 3 

### on page R-33. 4 

### MR. WEISS: Okay, thanks. 5 

### MR. LUBLINER: This is Mike Lubliner. 6 

### Question for Emanuel. 7 

### Why is it that it's harder to, or you 8 

### have more concern about, building to five ACH 50 9 

### in climate zones 2 and 3 than 1? 10 

### MR. LEVY: Is that a question for the 11


### IECC? 12 

### MR. LUBLINER: Well, I'm just -- well, 13 

### you were talking about -- you know, the IECC, I 14 

### think, has five and three in it. And I had 15 

### proposed five for everywhere, and I think just 16 

### kind of as a compromise. And what I was seeing 17 

### here was seven and five. 18 

### And I'm just wondering, you know, from a 19 

### physics standpoint, you build a house. You build 20 

### it so tight. Is there a reason that it won't be 21 

### as tight if you build it in climate zone 1? What 22257

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### was driving the distinction? 1 

### I was kind of hoping we could just leave 2 

### it at five everywhere, and maybe a provision that 3 

### if we find that's too -- not achievable, that 4 

### those could be addressed in the future by DOE. 5 

### I would think that, in the first couple 6 

### of years -- and this will, obviously, get 7 

### synergy, of course, by the compliance side, that 8 

### DOE will be looking at this as a learning 9 

### experience and not being vindictive in the way 10 

### that they enforce this if it's a good-faith 11 

### effort to meet the prescriptive path and you just 12 

### happen don't get to the five. 13 

### What we do in the site build codes in 14 

### Washington State is we required the blower test, 15 

### but we don't red-tag them if they don't pass. We 16 

### explore the root cause and fix it. Thank you. 17 

### MR. LEVY: Well, I'm sure, in part, the 18 

### root cause is one of energy. I mean, seven is 19 

### the ENERGY STAR standard right now. And in the 20 

### South, you know, you pay less of a penalty 21 

### energy-wise for a little more air leakage. 22258

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### So the seven is right now for what's 1 

### being built a step up. But the five reflects the 2 

### fact that those air changes are a little more 3 

### precious from an energy standpoint in the North. 4 

### MR. RAMIREZ: Emanuel, what do you think 5 

### of that? 6 

### [Pause.] 7 

### MR. LEVY: Javier, was that question 8 

### directed at me? 9 

### MR. RAMIREZ: Yeah. 10 

### MR. LEVY: Did you hear my answer? 11 

### MS. HOFFMAN: That was his answer. That 12 

### was Emanuel. 13 

### MR. LUBLINER: I think she was directing 14 

### that at me, Emanuel, and see if I was satisfied. 15 

### Yeah, I appreciate that. So it's really being 16 

### driven by your assumption of this energy savings, 17 

### not the technical feasibility of building to a 18 

### tightness level. 19 

### There shouldn't be any distinction 20 

### whether you're building in zone 1 or zone 3 in 21 

### terms of its technical feasibility of getting 22259

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### there. It more was driven by your assumption 1 

### that you don't save as much from going to the 2 

### tighter level in the warmer climate. Is that 3 

### right? 4 

### MR. LEVY: Well, in effect, that's 5 

### correct. We're in effect asking plants to go 6 

### through more gymnastics or more careful procedure 7 

### of sealing, recognizing that we're doing that 8 

### mainly for an energy benefit. 9 

### And that it's going to be a bit of a 10 

### challenge to do that anywhere because, as you 11 

### recognized doing that in the Northwest, because 12 

### you're, you know, artificially putting together a 13 

### home just for the purposes of testing. So you 14 

### already have quite a hump to get over, you know, 15 

### to reach that level within the plant. 16 

### So it's kind of what is reasonable, given 17 

### all the factors involved. And ultimately, this 18 

### is a judgment call as much as a cost-benefit 19 

### call. 20 

### MR. LUBLINER: Thank you. I think that 21 

### answered my question. I think that the criteria 22260

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### in the Northwest is less than five for our ENERGY 1 

### STAR homes program, and I can provide that 2 

### information back. Thank you. 3 

### MR. LACEY: This is Eric. Just some 4 

### clarifying questions, Emanuel. 5 

### I want to make sure I understand this 6 

### correctly. You're saying that you either test or 7 

### get a visual inspection. There's two options. 8 

### You're not necessarily requiring that every home 9 

### be tested. And even if you take the testing 10 

### option, there's some kind of sampling protocol. 11 

### Is that the intent here? 12 

### MR. LEVY: That's the intent, yep. 13 

### MR. LACEY: Okay. So the intent is that 14 

### if you wanted to avoid the test entirely, you 15 

### could just do a visual inspection. 16 

### And then I guess my follow-up question 17 

### is, I know that our prescriptive requirements or 18 

### mandatory requirements subgroup has been working 19 

### on the thermal envelope requirements and the 20 

### specific list of insulation and installation 21



### measures. 22261

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### And I'm wondering if there's some 1 

### duplication here with your visual inspection, and 2 

### if we could combine the two. I mean, I guess 3 

### maybe that's something that we can work out 4 

### later. But I just wanted to make sure. 5 

### What you're showing here is an approach 6 

### more like the 2009 IECC, where you or a code 7 

### official or somebody would inspect them. In this 8 

### case, it would be one of the manufacturer's 9 

### internal folks doing just a visual inspection, 10 

### looking at specific spots, rather than testing 11 

### every home. 12 

### MR. LEVY: Yes, I agree. And I think we 13 

### ought to put those pieces together to make sure 14 

### they're not in two places. 15 

### MR. SANTANA: You know, I will add, if I 16 

### can -- this is Manny -- that there's going to be 17 

### a lot more than just the plant personnel with 18 

### their own quality control. You know, you've got 19 

### third parties, as well as government third 20 

### parties, that go and conduct these kinds of 21 

### inspections. 22262

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### So it's quite a bit when you talk about 1 

### the inspections that are going to be done. And I 2 

### think it's a good approach to have. 3 

### MR. RAMIREZ: Okay. Let me get Lowell. 4 

### But for the folks that are on line, we need for 5 

### you to identify yourself for the Court Reporter 6 

### before you speak. 7 

### Lowell? 8 

### MR. UNGER: Thanks. So, if this is an 9 

### either-or, that the visual can be instead of 10 

### testing, let me ask again. Where did this list 11 

### of visual prescriptive measures come from? 12 

### MR. LEVY: This has been, Lowell, kind of 13 

### the result of -- it's partly the result of years 14 

### of having worked with the industry on identifying 15 

### techniques that are effective at keeping leakage 16 

### at the lowest possible levels. So it partly 17 

### comes from our experience; it partly comes from 18 

### ENERGY STAR. It's sort of a conglomeration of 19 

### different sources here. 20 

### But we thought this was a pretty good 21 

### list of the items that are essential to make sure 22263

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### that the home is tight. And there are a couple 1 

### of others. 2 

### MR. UNGER: And is there testing 3 

### experienced with people trying to implement a 4 

### list similar to this? I understand it may not be 5 

### exactly the same as to what kind of leakage one 6 

### typically can achieve through the prescriptive 7


### measures? 8 

### MR. LEVY: Yeah. We have tested homes 9 

### under ENERGY STAR. We have 500 or so homes out 10 

### in the field which we've tested. And we have had 11 

### good results from those homes. And that's part 12 

### of what this is predicated on. 13 

### Again, those are out in the field; 14 

### they're not in the plant. But it should be 15 

### harder to reach these goals in the field. 16 

### So, this information is borrowed from a 17 

### number of different studies and efforts that 18 

### we've done. It wouldn't be a bad thing to build 19 

### a bunch of homes in the plant, using these 20 

### prescriptions, and test them, you know, 21 

### specifically for this effort if we have the 22264

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### luxury of doing that. 1 

### So, again, what this represents is our 2 

### best experience thus far as to how best to seal 3 

### homes for leakage. 4 

### MR. UNGER: So you're saying that your 5 

### experience is that you can get, I think you said 6 

### ENERGY STAR is seven, and that you can achieve 7 

### that in the field through these measures? 8 

### MR. LEVY: That's right. And, you know, 9 

### with the testing we have done in the plant, and 10 

### Michael maybe have some experience here, too, has 11 

### been pretty compelling in terms of the homes 12 

### being very tight. In fact, I think one of the 13 

### issues often is that homes are so tight that we 14 

### really need to start looking at some ventilation 15 

### strategies that provide for more air change. 16 

### But you know, because of the materials 17 

### and the products that are used in the plant 18 

### today, the homes tend to be extremely tight to 19 

### begin with. And these are the areas that could 20 

### more readily not be routine or slip through the 21 

### cracks. 22265

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### MR. LUBLINER: This is Mike Lubliner. 1 

### My experience -- 2 

### MR. POTTS: This is Richard Potts, 3 

### Emanuel. 4 

### MR. RAMIREZ: I'm sorry. Go ahead, 5 

### Michael. 6 

### MR. LUBLINER: I was going to say our 7 

### experience in the Northwest is that five in the 8 

### field is achievable if you stick to a 9 

### prescriptive option and the plants are engaged in 10 

### implementing a quality assurance plan, 11 

### specifically, what things need to be caulked, 12 

### when, with what material, and who inspects. 13 

### You can get to five readily. I think 14 

### that's something that we should really be 15 

### thinking about, that because our ENERGY STAR 16 

### experience is suggesting that you're able to 17 

### achieve that, on average, out in the field, from 18 

### random testing of homes. 19 

### So it may be a little tougher with 20 

### single-section homes because it's an air change 21 

### metric, which means that the volume is a little 22266

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### tougher. We might be exploring flexibility. 1 

### Maybe we shouldn't be looking at air change at 50 2 

### Pascals. Maybe we should be looking at the 3 

### leakage area per foot or something. 4 

### But I do think that we really need to 5 

### consider that five is achievable. That's what 6 

### we're seeing, not in the factory, but actually in 7 

### the field, from random testing. And our 8 

### specifications have ramped down over the years 9 

### from seven down to five. And actually, in our 10 

### test homes without ductwork, we're down as low as 11 

### three. 12 

### I do agree that the homes need mechanical 13 

### ventilation, and I believe that there's a HUD 14 

### requirement for that mechanical ventilation 15 

### attempted. And it's been in the HUD code since 16 

### '94. So I think that we're on our way to 17 

### ventilating right. And I'm just trying to define 18 

### what "build tight" is. 19 

### Our motto is, "Build tight, ventilate 20 

### right." And we need to define what "tight" is 21 

### here. 22267

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### MR. LEVY: This is Emanuel. 1 

### Mike, I just want to say that your 2 

### experience, you know, having had experience over 3 

### the years of doing this, is the kind of thing 4 

### that we're talking about emulating here. Where 5 

### in other parts of the country hasn't had the 6 

### benefit of those years of experience, this would 7 

### be an opportunity to move the industry towards 8 

### the kinds of things you're doing in the 9 

### Northwest. 10 

### MR. LUBLINER: I agree. Thank you. 11 

### MR. RAMIREZ: Was there somebody else on 12 

### line that wanted to chime in? Richard? 13 

### MR. POTTS: Yeah, this is Richard Potts. 14 

### Can you hear me? 15 

### MR. RAMIREZ: Yeah. 16 

### MR. POTTS: Okay. So have we -- maybe 17 

### I'm jumping ahead. You know, we were talking a 18 

### little bit about mechanical ventilation. Is this 19 

### section correlating with the mechanical 20 

### ventilation requirements of, you know, requiring 21 

### either whole house or some sort of mechanical 22268

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### ventilation? I believe it's under five air 1 

### changes. And if not, definitely something that 2 

### we're going to have to deal with. 3 

### And earlier in the meeting, we had 4 

### mentioned cross references. And in the IECC, the 5 

### residential code is referenced for mechanical 6 

### ventilation. So it's another thing that we'll 7 

### have to make sure that we're, I guess, cross 8 

### referencing and making sure that we get the 9 

### correct information and not miss anything that's 10 

### required. 11 

### Another part of my question is, 12 

### basically, you know, what is involved with 13 

### testing multiple sections time-wise? I mean, are 14 

### we talking about -- you know, it seems like a 15 

### daunting undertaking. So I'd just like to get an 16 

### idea. 17 

### I'm trying to imagine. I've done factory 18 

### audits for the states. And I know how the 19 

### assembly is set up. I'm just trying to visualize 20 

### the testing procedure if anybody can help me out 21 

### with that. 22269

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### [Pause.] 1 

### MR. LEVY: Richard, let me take the first 2 

### part of your question, and maybe one of the 3 

### manufacturers who have done some testing will 4 

### weigh in on the second part. 5 

### I think the ventilation piece is part and 6 

### parcel of leakage, related to leakage, as Mike 7 

### Lubliner mentioned earlier. As far as I 8 

### understand, it's on our PBD list to come up with 9 

### a straw man for ventilation. So that will be a 10 

### subject of probably the next meeting. We'll have 11 

### something for the committee to look at. 12 

### Do any of the manufacturers want to talk 13 

### about, speak to the testing of homes in the plant 14 

### for leakage? 15 

### MR. RAMIREZ: Let me chime in right 16 

### there. Because it sounds like that probably a 17 

### little bit more education, where we could try and 18 

### do some of that stuff off line. But I want to 19 

### try and see if what we need to do on here to try 20 

### to bring this to a conclusion or see if there's 21 

### some more detailed questions on that. 22270

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### Is everyone okay with -- 1 

### MR. POTTS: This is Richard. There's a 2 

### little bit behind that. You know, it's kind of 3 

### maybe deciding whether some more so a visual 4 

### inspection approach might be, I don't know, more 5 

### cost effective. I mean, I know we're talking 6 

### about testing a class of homes or sampling, and 7 

### that's probably a good balanced approach. 8 

### But I wouldn't consider it just 9 

### educational. It might be good for the whole 10 

### group if we're really trying to decide long-term 11 

### strategies for testing. But it's up to you guys. 12 

### MR. RAMIREZ: Are you trying to find out 13 

### if it's labor intensive or costly? 14 

### MR. POTTS: Exactly. You know, is it 15 

### like a half-a-day to really set these things up 16 

### and run your blower, go over testing? Or is it 17 

### simple? They're right there, you know, you make 18 

### the units together. They might get in the groove 19 

### of things and it might only take an hour. I 20 

### don't know. 21 

### MR. RAMIREZ: Is there anybody that can 22271

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### give an elevator response on that? 1 

### MR. EZZO: This is Mark Ezzo, Clayton 2


### Homes. 3 

### I don't have any experience with it. I 4 

### mean, on the surface, it sounds -- and I would 5 

### suspect it's a pretty labor-some and cumbersome 6 

### process to take multi-section homes, take them 7 

### out into the yard somewhere. I suppose there are 8 

### some facilities that could do it in-plant. 9 

### But putting them together, sealing them 10 

### properly at all the connection points -- 11 

### underneath, at the ends, at the top, at the ridge 12 

### line -- and then performing, you know, the 13 

### corresponding tests, we're talking about 14 

### something that's pretty labor intensive. 15 

### I'm not going to say I know how long it 16 

### would take to do one or to do, you know, three a 17 

### day or one a day or one a week. But I think it 18 

### would be something that would be a fairly big 19 

### burden on manufacturers to try to accomplish in 20 

### the plant. 21 

### MR. RAMIREZ: Let me go to Lois. I think 22272

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### she probably wants to add something here. 1 

### MS. STARKEY: Yeah. And also, it doesn't 2 

### really achieve the objective. Because really, 3 

### you're talking about ultimately siting the home 4 

### and a consumer living in it. And that's when all 5 

### the -- that's when you're concerned about how the 6 

### house is performing. 7 

### So the idea of doing it in the factory is 8 

### just -- it just seems so infeasible and really 9 

### not -- doesn't really meet the objective that 10 

### you're trying to meet. 11 

### MS. HOFFMAN: Quick question -- Eileen 12 

### Hoffman. 13 

### Is testing -- maybe just help me. 14 

### Sampling, testing, inspection, is that part of 15 

### compliance and enforcement? Or is that part of 16 

### the charter of this committee for standards? 17 

### Just so I know. 18 

### MR. HAGERMAN: I mean, DOE's official 19 

### position is it's not within the scope here of 20 

### this working group. This working group can make 21 

### recommendations to ASRAC. But that's a separate 22273

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### rule. 1 

### MS. HOFFMAN: I just meant discussing 2 

### testing and sampling. That's out of the scope. 3 

### MR. HAGERMAN: That's our understanding. 4 

### MS. HOFFMAN: Okay. Okay. 5 

### MR. HAGERMAN: That's our position. 6 

### MS. HOFFMAN: So then, although it's very 7 

### important, in the interest of time, perhaps it 8 

### would be good to move on then. I see we have a 9 

### number of folks commenting, though. 10 

### MR. HAGERMAN: Just let me offer this up. 11 

### So we've been eyeballing all this data. And it's 12 

### a little bit hard to specifically pull out some 13 

### of the impacts of these individual measures with 14 

### the runs that we currently have, given that, you 15 

### know, they just are what they are. 16 

### So what I'm going to offer is, and I've 17 

### been communicating with PNNL -- they can get us 18 

### the results, we hope, by Friday -- to do some 19 

### additional runs first on the solar heat gain 20 

### issue. So I've already issued that to them. And 21 

### then I'm going to ask them specifically to do 22274

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### some models of this whole-house air leakage, and 1 

### then also the duct leakage. 2 

### So the duct leakage would be a six, four, 3 

### and three; and the whole house would be seven, 4 

### five, and three. So then by Friday we can see 5 

### the annual results. And then you'll know the 6 

### impacts. And then we'll just have to get the 7 

### costs. So is that good enough for everybody? 8 

### I hate to -- you know, today I've tried 9 

### to say, let's try to make some decisions and not 10 

### just kick the can down the road. But this is the 11 

### one that I think we're going to have to kick it 12 

### down a little bit to get you the analysis that 13 

### you need to see. Because my eyeballs are getting 14 

### tired. 15 

### [Laughter.] 16 

### MR. RAMIREZ: All right. Lowell, then 17 

### Eric? 18 

### MR. UNGAR: Take Eric, because his is an 19 

### immediate response. 20 

### MR. RAMIREZ: Okay. 21 

### Go ahead, Eric. 22275

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### MR. LACEY: Immediate, positive response? 1 

### No, I guess just a general question about this. 2 

### I'm really struggling to see what 3 

### incentive a manufacturer would have to test any 4 

### home for air leakage. Because if there's a 5 

### visual inspection option that includes a handful 6 

### of measures that are already probably going to be 7 

### included in the air barrier and insulation 8 

### installation table, which we're kind of working 9 

### on right now, I'm still not seeing why you would 10 

### ever test a home. 11 

### I mean, regardless of what the air 12 

### leakage number is, I think it's a good thing to 13 

### know how much air leakage the home is getting, 14 

### not only for energy efficiency, but also for 15 

### sick-building issues and whether you need 16 

### mechanical ventilation. 17 

### And in the 2009 era of the IECC when you 18 

### had a visual inspection, there was a bit of an 19 

### incentive to still test, because you didn't want 20 

### to wait on a code official to have to come in and 21 

### do the visual inspection for you. You might as 22276

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### well just get it tested, check the box, and move 1 

### forward with production. 2 

### I don't see that as being the same 3 

### incentive-disincentive for a manufacturer, where 4 

### you're probably just doing the testing or the 5 

### visual inspection yourself. 6 

### Does anybody have a sense, or Emanuel, is 7 

### there any incentive here to actually do the test? 8 

### Or is this intended to not be an incentive to do 9 

### the test and push people towards just doing a 10 

### visual inspection? 11 

### MR. LEVY: Yeah, I can tell you my take 12 

### on it, which would be the latter. If companies 13 

### were routinely doing a whole list of things, 14 

### which we know from experience results in a tight 15 

### home, why would we want to make them test, and 16 

### the cost and expenses associated with that? 17 

### I do think there's a difference here 18 

### between site-built and manufactured homes, where 19 

### site-built runs the gamut, routinely, of 20 

### different designs and level of quality 21 

### construction. And it's done outside, and all 22277

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### those other things that mean that there's high 1 

### variability in how tight the homes are going to 2 

### likely be. 3 

### With the factory-built home, you know, 4 

### from our experience, it's -- the band of 5 

### tightness is much tighter. It's much more 6 

### limited. And if companies routinely do certain 7 

### things, and it's in their DAPI [phonetic] package 8 

### and it's part of their routine construction, you 9 

### can test them all day, yeah. But you're going to 10 

### hit those marks very consistently. 11 

### And if that's the case, and we can 12 

### demonstrate that that's the case, why require 13 

### testing that is just going to be costly? And 14 

### frankly, in the case of whole-house testing, not 15 

### entirely informative, because the home is going 16 

### to be taken apart and shipped and set up again a 17 

### second time. 18 

### MR. LUBLINER: This is Mike Lubliner. 19 

### I do think that there's value in testing 20 

### from a feedback-loop standpoint, regardless of 21 

### what level you're presently achieving. 22278

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### To be clarified, there is a requirement 1 

### for whole-house mechanical ventilation, installed 2 

### capacity, in the HUD code since 1994, of 0.35 CFM 3 

### per square foot. So we have a requirement 4 

### already in the base case that these mechanical 5 

### ventilation is in there regardless of how tight 6 

### the home is. 7 

### But what we find is that the benefit of 8 

### testing is providing feedback periodically to the 9 

### manufacturers to, "Oh, we have a QA issue with 10 

### our P-trap." Or, "Oh, we're not doing this door. 11 

### We're seeing daylight through the front-door 12 

### weather stripping." It's that kind of feedback 13 

### that you can get from the testing. 14 

### And I think if you did a quarterly test 15 

### of a cross section of homes, I don't know, 16 

### single-wide homes do not have the problems that 17 

### Mark Ezzo articulated, so I suggest we focus on 18 

### constructive feedback from single-wides. 19 

### But at a minimum, four times a year to do 20 

### a blower test in the factory and pull a double21 

### wide together, if that's what you're building, I 22279

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### don't think is that burdensome, and I think it 1 

### provides an amazing amount of feedback to improve 2 

### your quality assurance plan and ensure that 3 

### you're meeting the metrics. 4 

### That's my feeling on this. 5 

### MR. LEVY: And Mike -- this is Emanuel -- 6 

### I agree with you. And that was the intent of the 7 

### compliance sampling procedure, section C. 8 

### MR. RAMIREZ: Lowell? 9 

### MR. UNGER: Yeah, first thing is, I think 10 

### the last exchange has been very illuminating and 11 

### helpful. 12 

### It strikes me, one thing in Emanuel's 13 

### argument, is that manufactured homes are 14 

### different, is very interesting. I had understood 15 

### from the discussion, I guess it was on the duct 16 

### leakage, that there was a huge range and that 17 

### there was no consistency. And if you did three, 18 

### tested three homes, they're all going to be 19 

### different. 20 

### Is the whole-house leakage different? I 21 

### mean, is the whole-house leakage very consistent, 22280

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### but the duct leakage very inconsistent? 1 

### MR. LEVY: You know, I would say the same 2 

### thing goes for ducts, too. I think once -- and 3 

### this is again why we had to be heavily biased 4 

### toward the prescriptive measures. 5 

### Once you do that and you check that, just 6 

### like Mike has just described, on a routine basis, 7 

### you know, once you set up those protocols and you 8 

### have people doing things the same way every time 9 

### at every home coming down the line, you're going 10 

### to get fairly consistent results. 11 

### And I know some of the manufacturers here 12 

### have done some testing. I mean, it would be 13 

### interesting to hear what their experience is. 14 

### But I think the same can be said for ducts and 15 

### whole-house. 16 

### MR. LUBLINER: Mike Lubliner. I was just 17 

### going to try to reply. 18 

### We look at -- when we go out in the field 19 

### to look at duct leakage and envelope leakage, we 20 

### do a random sample from thousands of homes built 21 

### under the program. And we get, you know, 30 to 22281

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### 100 homes. And we go out and we test them. So 1 

### we get an average. We get a distribution and max 2 

### them in. And we get a standard deviation. 3 

### The standard deviation for the duct 4 

### variability and the envelope variability are 5 

### comparable. But I think exactly what Emanuel 6 

### says is right, that if you do the periodic 7 

### testing in the factory -- and we can argue how 8 

### periodic that is or how that varies with your 9 

### compliance -- you do learn from that. 10 

### And if there are criteria in the quality 11 

### assurance plan that allow you to go back to and 12 

### say, "We're missing this criteria in the quality 13 

### assurance plan," I'm comfortable with that. 14 

### How about if we were able to come up -- I 15 

### mean, I think we're arguing about five to seven 16 

### here in zone 1. How about if we were able to 17 

### come up with something that we provide a maximum 18 

### range, and we say, you know, "Our goal is five, 19 

### but we want a couple of years of evaluation. And 20 

### if we go above seven, we're bad. But if we go 21 

### above five and we're within seven, we're okay." 22282

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### And again, this is more of a technical 1 

### assistance technology transfer effort, 2 

### educational effort. It's not meant to be red3 

### tagging people for trying their best to implement 4 

### a quality assurance program. Thank you. 5 

### MR. RAMIREZ: All right. So then -- 6 

### MR. UNGER: Sorry. So I guess on that, I 7 

### would just note, as I said before, if there's a 8 

### transitional issue, it seems to me that to set a 9 

### temporary standard or temporary exception, and 10 

### then a final, more stringent standard, makes 11



### sense. 12 

### The other thing is, from the descriptions 13 

### I've heard, it sounds to me that universal visual 14 

### -- universal prescription measures or visual 15 

### inspection, combined with testing of a sample, 16 

### and here I recognize that that sample is a 17 

### question, and whether that means only testing 18 

### single-wide homes or testing a small sample in 19 

### the field, or I don't know what the solution is. 20 

### And sounds like perhaps we can't get into 21 

### that here. But it seems to me that a combination 22283

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### of a testing of a sample with the prescriptive 1 

### measures makes logical sense to me, rather than, 2 

### or -- and that's what I understood the proposal 3 

### was on the ducts. And I would wonder whether we 4 

### could do the same kind of approach here as well. 5 

### MR. RAMIREZ: So then, similar to ducts, 6 

### we're looking at the possibility of a step-in 7 

### phase, although it's a little bit different. 8 

### We're talking about a goal of a five with a max 9 

### of a seven, but aligned for some type of step-in. 10 

### Nothing concrete on that one yet, but at 11 

### least that's what's being thrown out there. 12 

### Anything additional that we need to cover 13 

### on this one, or should we move on to next steps? 14 

### MR. HAGERMAN: Let me just reiterate that 15 

### I just issued the orders to PNNL to run those 16 

### additional simulations with the HUD code 17 

### baseline. So that was a good add. So you should 18 

### hopefully get those by Friday. It might take 19 

### them a little bit longer if they run into 20 

### problems. But we'll see. I mean, we're trying 21 

### to be as fast as possible. 22284

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### MR. RAMIREZ: Great. Thank you. 1 

### MR. LUBLINER: Thanks, Joe. 2 

### MR. RAMIREZ: Okay. Then, as far as next 3 

### step goes, it seems like Emanuel and Lois are 4 

### going to get getting those cost figures in pretty 5 

### quick. And then we're going to get that 6 

### information out. 7 

### What's your comfort level with doing 8 

### something similar that we did last time, as far 9 

### as, let's see what actual data we get, what 10 

### information is disseminated to the group, and 11 

### build the agenda a few days before to see if 12 

### there's any modifications that you all come up 13 

### with? Everyone okay with that approach? 14 

### MR. HAGERMAN: This is Joe Hagerman, DOE. 15 

### I think we have to be comfortable with 16 

### that, given that we're still outstanding so many 17 

### items. 18 

### MR. RAMIREZ: Um-hm. 19 

### MR. HAGERMAN: Let me just conjure up 20 

### John Caskey and say, you know, we hope everybody 21 

### comes next time ready to make the hard decisions, 22285

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### right? Because we will have gotten all that 1 

### data. So hopefully, we can move down the field a 2 

### little bit farther. 3 

### MR. RAMIREZ: And I'll piggyback on that, 4 

### right, that again, you all are the subject matter 5 

### experts on this. And so we're going to have 6 

### quite a bit of data. And I'm going to be pushing 7 

### you a little bit more to, "Look. Based on what 8 

### we have, what do you think? What's your 9 

### recommendation, what's your suggestion?" 10 

### MS. HOFFMAN: Eileen Hoffman. We'll be 11 

### looking at costs and energy efficiencies, and 12 

### using your expertise to work on these standards. 13 

### MR. RAMIREZ: And if I understand 14 

### correctly, Eileen's a little squeamish with 15 

### blood. So she won't be here at the next meeting. 16 

### [Laughter.] 17 

### MS. HOFFMAN: I will tell you, Ted 18 

### Bantle, who you've seen behind me, is going to be 19 

### a very welcome substitute. So. Duty calls. 20 

### MR. RAMIREZ: Go ahead, Mike. 21 

### MR. LUBLINER: This is Mike Lubliner. 22286

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### Yeah, I just want to make one suggestion 1 

### as we look for consensus that I would be 2 

### comfortable with, is if we were able to change 3 

### under A requirements from "or" to say "either," 4 

### where it says, "by periodic testing and visual 5 

### inspection of each house," I think that addresses 6 

### the concern that Lowell and I had. 7 

### And then down under testing for climate 8 

### zone 1, I would put five to seven air changes per 9 

### hour and leave that range, and leave it up to DOE 10 

### to decide how to enforce that, or discussion in 11 

### the spinoff group. 12 

### I think that would be adequate to making 13 

### this comfortable to my likings. Thank you. 14 

### MR. RAMIREZ: Mark? 15 

### MR. EZZO: Mark Ezzo. Could you say the 16 

### first part of that again, please? 17 

### MR. LUBLINER: Sure. It would be, for 18 

### compliance with the leakage targets that can be 19 

### demonstrated by VI, get rid of the word "either" 20 

### and say, "periodic testing and visual inspection 21 

### of each home by prescriptive air sealing." 22287

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### MR. EZZO: Okay. I got it. Thank you. 1 

### MR. LUBLINER: And then under one, it 2 

### would just say -- 3 

### MR. RAMIREZ: I'm sorry. Hold on a 4 

### second, Michael. 5 

### Look on the screen here. Ted's doing a 6 

### great job of trying to write with the mouse. 7 

### Right? 8 

### [Laughter.] 9 

### MR. RAMIREZ: You see that where the 10 

### cross-out is, and there's a plus there? That's 11 

### "and." And then under testing, number one would 12 

### be a range of five to seven. 13 

### [Pause.] 14 

### MR. RAMIREZ: Yeah, that's it. That's 15 

### PDF shorthand. 16 

### [Pause.] 17 

### MR. WEISS: Yeah, just to respond to 18 

### that. Mark Weiss, MHARR. 19 

### I guess it goes under the heading of, 20 

### "Burn me once, burn me twice." And I'm not 21 

### suggesting that DOE is going to act or interpret 22288

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### things the same way as HUD. 1 

### But we recently had a recommendation for 2 

### HUD for periodic something, and that became 3 

### monthly inspections versus periodic inspections. 4 

### So having been alerted thusly, I am very 5 

### concerned, not inclined to use the term 6 

### "periodic" if I can avoid it. No offense, Rick. 7 

### MR. EZZO: How about "random"? 8 

### MR. RAMIREZ: "Random" versus "periodic"? 9 

### MR. WEISS: That might be even worse. 10 

### [Laughter.] 11 

### MR. RAMIREZ: All right. So we're not 12 

### going to be getting consensus on this right at 13 

### this moment, right? There's going to be a little 14 

### bit of cleanup. But just to kind of give you a 15 

### heads-up, though. That's the type of holding16 

### your-feet-to-the-fire that I'm going to be doing 17 

### with you next. 18 

### I would ask you, Mark, "What would you 19 

### put there instead?" Right? 20 

### Not right now. But there's an example of 21 

### how we're going to be doing that so that we can 22289

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### try to bring things to closure. Okay? 1 

### All right. So, thank you for those 2 

### recommendations, Michael. 3 

### Now, just looking at the map here, we had 4 

### started off yesterday with trying to identify, 5 

### what roadmap do we need? What do we need to do 6 

### in order to reach an agreement by -- and just as 7 

### we're discussing today, I put 10/2 on there. But 8 

### it sounds like we might have a little bit more 9 

### time. But I don't want to push it all the way to 10 

### the end of November. 11 

### So what if we're saying like that the 12 

### 10th of November, right? What do we need to have 13 

### something done by the 10th of November, as a term 14 

### sheet, regardless of that actual -- 15 

### MS. HOFFMAN: So, you don't mean 16 

### November; you mean October? 17 

### MR. RAMIREZ: I'm sorry. October, the 18 

### end of October. Right. So, say October 10th. 19 

### Again, regardless of that specific 20 

### timeline there, what else do we need to put on 21 

### here in order to try to reach that goal? 22290

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### [Pause.] 1 

### MR. RAMIREZ: So, we have on there the 2 

### cost data that's going to be provided. And once 3 

### that cost data is provided, which is going to be 4 

### by the end of this week, when we do some 5 

### additional runs, that might help clarify the 6 

### climate zones. 7 

### So I'm hoping that when we get together 8 

### on 9/22, also going on climate zones is something 9 

### that we could walk out of here with on that day, 10 

### right, maybe even some of the actual performance 11 

### levels. 12 

### And Manny and your subgroup, I'm hoping 13 

### that you're going to be able to bring in some 14 

### fairly tight recommendations of what we could do 15 

### for either the low-hanging fruit or even maybe 16 

### the ones that we need a little step-stool for, 17 

### right? 18 

### MR. SANTANA: This is Manny again. You 19 

### know, regarding that, can we assume -- you know, 20 

### I'm not there, so I couldn't gauge what was going 21 

### on. But did we obtain tacit approval for the 22291

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### Emanuel proposal? 1 

### You know, because a lot of that stuff, 2 

### you know, it incorporates duct sealing, you know, 3 

### tightness value, stuff like that that's in the 4 

### IECC. Can we assume that there was approval for 5 

### that so then we won't have to worry about those 6 

### sections? 7 

### MR. RAMIREZ: Yeah. I think what we're 8 

### talking about was to use that one to plug in 9 

### those values, those numbers. And then we'll see 10 

### how that looks. We haven't approved it, right? 11 

### But we're saying, "Yeah, use that as the starting 12 

### point." 13 

### MR. HAGERMAN: I think he's specifically 14 

### asking if his working group can skip over those 15 

### sections, because we're going to use -- 16 

### MR. RAMIREZ: Plug in those numbers. 17 

### MR. HAGERMAN: -- Emanuel's proposal in 18 

### replacement. 19


### MR. RAMIREZ: Yes. 20 

### MR. HAGERMAN: And I think that, largely, 21 

### the group would probably be comfortable with 22292

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### that. I just would recommend that committee to 1 

### at least skim those provisions again and just to 2 

### see that, you know, you didn't leave out 3 

### something in there. 4 

### MS. HOFFMAN: Right. And I would also 5 

### suggest that you relook at it in the two weeks 6 

### and see what it looks like, and write it up. 7 

### Now, who will do that? Just to write up 8 

### Emanuel's -- maybe he will -- and put it in a 9 

### format so they can look at it, as well as the 10


### IECC? 11 

### MR. RAMIREZ: Manny's subcommittee is 12 

### going to be tackling that. 13 

### MS. HOFFMAN: Manny's subcommittee, all 14 

### right. 15 

### The other thing is the definitions. You 16 

### may want to decide what kinds of definitions 17 

### you'll need in this rule. You don't have to make 18 

### up new definitions. But you may want to locate 19 

### where they are. 20 

### MR. RAMIREZ: Yeah, Mark. 21 

### MR. WEISS: Mark Weiss, just a follow-on 22293

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### to that. 1 

### Yeah, I mean, if folks have term-of-art 2 

### definitions or definitions from other codes or 3 

### things that they want to reference, it would be 4 

### good to get those out on the table and know where 5 

### they're coming from and exactly what folks are 6 

### putting forward, if there are. 7 

### MR. HAGERMAN: I think definitions are 8 

### critical, too -- 9 

### MR. WEISS: I'm sorry. I mean aside from 10 

### what's sitting in the book here, other stuff. 11 

### MR. HAGERMAN: Joe Hagerman, DOE. 12 

### I think definitions are critical, too, if 13 

### the group decides to go the Robin Roy route of 14 

### this type LO, type full option, right? We're 15 

### going to have to, as a group, define what those 16 

### two things are, right? 17 

### MR. RAMIREZ: Um-hm. 18 

### MR. HAGERMAN: So I think definitions 19 

### here are critical. 20 

### MR. RAMIREZ: And as far as that approach 21 

### of the two products, how are we going to try to 22294

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### capture that so that we have some structure that 1 

### we could really look at versus something 2 

### conceptual and having the group trying to come up 3 

### with detail? 4 

### MS. HOFFMAN: Eileen Hoffman. Maybe 5 

### Robin's committee could come up with some 6 

### language beyond what you had done already, but 7 

### some language -- 8 

### MR. RAMIREZ: Developing a straw man? 9 

### MS. HOFFMAN: With a proposal. 10 

### MR. ROY: That was the intent. And we 11 

### tried to lay out a general framework of what 12 

### would be the targets for the LO and FO. 13 

### MR. RAMIREZ: Okay. 14 

### MR. ROY: Product types. And we'll have 15 

### conversations about whether those definitions are 16 

### suitable and the analysis, which is being done, 17 

### you know, fits. You know, it was designed to fit 18 

### into the analysis, or to take what comes from the 19 

### analysis. We'll have conversations about whether 20 

### that still seems suitable. I mean, that's the 21 

### intent. 22295

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### MR. RAMIREZ: Okay. And as any of these 1 

### things, documents are made available, if you 2 

### could forward them on to us so that we could send 3 

### them out to the entire work group so that that 4 

### way they have a chance to chew on it before we 5 

### get together on the 22nd, that would be great. 6 

### What about on the other discussions? 7 

### What needs to be done there? How do we handle 8 

### labeling the space water heating piece? Well, 9 

### window types, we discussed a little bit of that 10 

### today. 11 

### MR. LEVY: Javier? Emanuel. 12 

### MR. RAMIREZ: Yeah. 13 

### MR. LEVY: Can I ask a question before we 14 

### move on to that? Just a clarification on the two 15 

### items that seem like the big-ticket items to me 16 

### on the 9-22 list. Climate zones and actual 17 

### performance levels, I assume that's the 18 

### prescriptive packages of U values we're 19 

### describing them as. Some were requirements. 20 

### My understanding is that you need our 21 

### costs to start getting clarification of what 22296

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### those things are. 1 

### MR. RAMIREZ: Right. 2 

### MR. LEVY: And I'm just asking whether it 3 

### would be useful, if the laboratory expects to 4 

### have results sooner rather than later, to have a 5 

### call with the group -- and maybe there's a 6 

### committee looking at this already -- to look at 7 

### those interim results and maybe iterate through 8 

### that before the next meeting to try to accelerate 9 

### things a bit, rather than wait until the 9-22 10 

### meeting to start talking about this. 11 

### MR. RAMIREZ: So a subcommittee on 12 

### climate zones and compliance paths? 13 

### MR. LEVY: Well, yes. Well -- 14 

### MS. HOFFMAN: You're thinking the whole 15 

### committee, through a GoToMeeting, some kind of 16 

### system to discuss it for maybe an hour or so? Is 17 

### that what I'm hearing? Before the -- 18 

### MR. LEVY: Just to get an understanding. 19 

### Yes. At minimum to get an understanding of what 20 

### kinds of results are coming out. And at best, to 21 

### be able to provide feedback that -- so maybe 22297

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### there's an iteration cycle that goes on before 1 

### the meeting, and some additional information can 2 

### be generated to anticipate questions that will 3 

### come up in the meeting. 4 

### I just think that that is going to be the 5 

### most difficult piece to deal with, the most 6 

### controversial, require the most input and 7 

### analysis. 8 

### MR. ROY: This is Robin. I tend to 9 

### concur. I mean, part of this affordability to 10 

### product types is driven by a presumption that the 11 

### different cost effectiveness perspective that 12 

### you're looking at, that you're doing analysis on, 13 

### will end up with reasonably different performance 14 

### levels. 15 

### We're going to continue on that 16 

### presumption for awhile until we see otherwise. 17 

### But as soon as we get some of those results, the 18 

### sooner we can talk more concretely within our 19 

### little group. 20 

### MR. UNGER: This is Lowell. It seems to 21 

### me that the climate zones and perhaps the 22298

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### compliance paths are structural issues. It's 1 

### actually not even clear to me how useful more 2 

### data will be in order to decide those. So we do 3 

### have, at least, energy data. 4 

### But I think it would be useful to the 5 

### extent that we could get at least a preliminary 6 

### revolution on what those are, that would then 7 

### help deal with all the other issues, because we 8 

### would at least know more about what the structure 9 

### is that we're trying to fill in. 10 

### The performance levels is much more 11 

### substantive. And, you know, it would be great to 12 

### make progress on that, too. But that's kind of 13 

### at a different level I certainly don't think 14 

### we're going to be able to resolve in between 15 

### meetings. 16 

### But I wonder for the climate zones in 17 

### particular, and potentially past the compliance, 18 

### if there would be a way of wrapping those up or 19 

### at least getting people's views on the table or 20 

### something, to see if we can resolve those in 21 

### order just to make it easier to deal with the 22299

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### other questions. 1 

### MR. RAMIREZ: Joe, did you have 2 

### something? 3 

### MR. HAGERMAN: So, Joe Hagerman, DOE. 4 

### What I did, what -- if you just remember 5 

### things here. The KISS Luby proposal that was run 6 

### was specified in the three HUD climate zones. So 7 

### then, PNNL modeled that in the eight climate 8 

### zones with the IECC, right? 9 

### If you look at those results, there's, in 10 

### my opinion, wild swings going from the three 11 

### climate zones to the eight climate zones that I 12 

### think you should look at the results. I think 13 

### everybody should look at the results. But I 14 

### think you should look at the results in 15 

### particular, right? 16 

### Because in one location of the IECC 17 

### climate zones, the HUD climate zones are kind of 18 

### wacky, right, and may not be cost effective. Or, 19 

### you know, they're not as aggressively cost 20 

### effective, however you want to say that, right? 21 

### So what I did for the new analysis that 22300

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### the group just requested, which is actually a lot 1 

### of runs, but I think we simplified it here, I 2 

### took the KISS Luby proposal as the basis. And 3 

### then I'm changing the solar heat gain 4 

### coefficient, all right, and going back to the 5 

### original proposal, changing the duct leakage, all 6 

### right, going back to the original proposal, and 7 

### changing the air leakage, right? 8 

### So you'll see everything baselined off of 9 

### that in terms of insulation values and all that, 10 

### right? That's my base. That's my new interim 11 

### baseline. Okay? Does that sound fair? 12 

### And then you'll also see the duct leakage 13 

### if it was at the HUD minimum, or if the windows 14 

### are at the HUD minimum. But the insulation 15 

### levels are pegged to that last proposal, which I 16 

### think is the only reasonable way to do this right 17 

### now. But I just want full understanding of that 18 

### from everybody, that ya'll agree to that, so. 19 

### MR. RAMIREZ: I think that the thinking 20 

### of the group was that if we could just plug in 21 

### some of the cost numbers on there, that that 22301

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### might actually bring out which of the climate 1 

### zones, IECC or HUD, would make sense. 2 

### And I think that that was going to become 3 

### a little bit more clear once the cost numbers 4 

### were put in. 5 

### MR. HAGERMAN: This is Joe Hagerman, DOE, 6 

### again. 7 

### And remember, Matthew is going to be 8 

### plugging in the cost numbers for that KISS Luby 9 

### proposal, right? So again, you'll have the cost 10 

### numbers for that baseline proposal as well. 11 

### MR. LUBLINER: Rob Luter with Lippert? 12 

### MR. RAMIREZ: Yeah. 13 

### MR. LUBLINER: Pardon me for the 14 

### timeliness issues. I've been trying to get 15 

### unmuted for a little while. 16 

### Regarding the two-tiered compliance that 17 

### was discussed here a few minutes ago, the LO and 18 

### the FO, is anyone else troubled by that? Trying 19 

### to come up with two different standards? I mean, 20 

### right now the industry has to deal with the I21 

### code modulars and the HUD code homes to break the 22302

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### HUD down into two tiers, if you will. 1 

### I know from my perspective, it will be 2 

### more complex than I think it really needs to be, 3 

### especially in light of the fact we're supposed to 4 

### be developing, as I understood, a standard, not a 5 

### sliding scale based on some set of criteria. 6 

### MR. SANTANA: This is Manny with CAVCO. 7 

### It would also seem to me that Robin's 8 

### proposal and Emanuel's proposal were kind of 9 

### competing proposals. Is there any way we can try 10 

### to -- you know, we're not going to end up with 11 

### two. Given the short, you know, the imminent 12 

### deadline that we have, is there any way we can 13 

### maybe parry that down to one and focus our 14 

### attention? 15 

### MR. RAMIREZ: Okay, if I remember 16 

### correctly, the reason for the whole idea of the 17 

### two different products was to deal with the 18 

### affordability issue, you know, which Mark has 19 

### been stating all along, is that increased costs 20 

### is going to impact the affordability point. Are 21 

### we going to be excluding folks from the market? 22303

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### And I think the idea there was to say, 1 

### "Okay, fine. Let's come up with this low 2 

### option," is that low option that would allow for 3 

### those folks that are at the entry level to still 4 

### be able to afford one of these units. 5 

### But folks that are not quite at that 6 

### level, then they could absorb the initial up7 

### front costs, knowing that they're going to save 8 

### it on the back end with the efficiencies. 9 

### So we're trying to -- I think the idea 10 

### there was to try to capture both the 11 

### affordability as well as the energy efficiencies 12 

### over the long run. 13 

### MR. WEISS: Yeah, Mark Weiss, MHARR. 14 

### Without prejudging anything, we're not, 15 

### obviously, committing to anything, I would like 16 

### to see more information on that and see it 17 

### further developed. So. 18 

### MR. RAMIREZ: Okay. 19 

### MR. HAGERMAN: Joe Hagerman, DOE. 20 

### It's not two different standards. It's 21 

### just a product type, right? Just like side-by- 22304

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### side refrigerator is different than a top-mount 1 

### freezer-refrigerator, right, which is still 2 

### covered by one standard. We call it, you know -- 3 

### we call it product types, or product classes. 4 

### MR. RAMIREZ: Okay. So, as far as 5 

### continuing on with the next step, so it sounds 6 

### like we need to get some of this data out. And 7 

### then we can try and arrange a conference call 8 

### somewhere before, or GoToMeeting with the entire 9 

### group to discuss the zones and the compliance 10 

### paths. 11 

### And then we'll have to schedule that, 12 

### because we don't know exactly when the data is 13 

### going to be coming out in the runs. 14 

### Mark, you had something on that? 15 

### MR. WEISS: Just a heads-up. I became 16 

### aware of earlier that probably a number of us are 17 

### going to be on another conference call on 18 

### September 16th in the afternoon that HUD is 19 

### running. So if we could avoid that, it would be 20 

### helpful. 21 

### MR. RAMIREZ: Okay. 22305

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### [Pause.] 1 

### MR. RAMIREZ: Okay. What else needs to 2 

### go up here to make sure that it's either on our 3 

### minds or that we need to gather information or 4 

### prepare for for the next meeting? 5 

### [Pause.] 6 

### MR. HAGERMAN: This is Joe Hagerman, DOE. 7 

### We were going to circulate this outline 8 

### of the term sheet. But I was talking to Ed 9 

### Barbour of Navigant, and he suggested that, you 10 

### know, we go back after we've heard from everybody 11 

### for the last two days and tweak the outline that 12 

### he's presented to more reflect the current 13 

### conversation. 14 

### MR. RAMIREZ: Okay. 15 

### MR. HAGERMAN: So I suggest we do that, 16 

### and then we can circulate it by email to 17 

### everybody. 18 

### MR. RAMIREZ: Okay. 19 

### MR. HAGERMAN: It should not shock you. 20 

### I mean, there's nothing -- it's just an outline, 21 

### right? 22306

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### MS. HOFFMAN: Excuse me. Eileen Hoffman. 1 

### But it gives you an idea of what the term 2 

### sheet might look like. It doesn't have the 3 

### numbers, but it does have the words. So at least 4 

### it gives you an idea of the template that might 5 

### be followed. 6 

### MR. RAMIREZ: Okay. Is there anything 7 

### else then before we open up the floor for public 8


### comment? 9 

### I'm sorry, Mark. 10 

### MR. WEISS: Mark Weiss, MHARR. 11 

### And since Eileen won't be here for the 12 

### next meeting, I just wanted to thank all of you 13 

### for your efforts in facilitation. I think 14 

### they've been excellent. 15 

### MR. RAMIREZ: Thank you. And she will be 16 

### back, though. 17 

### [Laughter.] 18 

### MS. HOFFMAN: How much did I pay him? 19 

### No, no. 20 

### [Laughter.] 21 

### MR. LUBLINER: This is Mike Lubliner. I 22307

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### want to echo that as well. 1 

### And I want to make an observation, if 2 

### it's appropriate here. Back in the '90s after 3 

### Hurricane Andrew, there was a significant amount 4 

### of property loss due to the windstorm, wind 5 

### damage. And the manufactured housing industry 6 

### took a big hit and some really bad PR. 7 

### And as a result of that, they were 8 

### forced, in a way, dragging and kicking, by HUD to 9 

### update higher structural efficiency in the homes. 10 

### And as a result of that, my understanding is, 11 

### after Hurricane Charlie, that we had much, much 12 

### better success of getting through these disasters 13 

### without structural damage. 14 

### The argument that was being made at the 15 

### time when that was being proposed was that this 16 

### was going to price us out of the market, and it 17 

### was going to address affordability, and it was 18 

### going to hurt our buyers. 19 

### And I just think we need to reflect on 20 

### experiences that we've had in this industry, 21 

### because my understanding is that wasn't the case 22308

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### at all, that it made it a better product, a 1 

### better industry, and cost society less when we 2 

### have these catastrophic events, which seem to be 3 

### happening more and more. 4 

### Just a thought so that we can reflect on 5 

### what we've learned from the past. And I 6 

### appreciate you guys taking that with a grain of 7 

### salt, based on my value system. So, thank you. 8 

### MR. RAMIREZ: Okay. Thank you for those 9 

### comments. All right. 10 

### MR. LUTER: I have one item as well, 11 

### please. 12 

### MR. RAMIREZ: Okay. Go ahead, Rob. 13 

### MR. LUTER: For those of us doing the 14 

### GoToMeeting, I know that there in the conference 15 

### room there have been copies of the 2015 IECC made 16 

### available. So those present can follow along. 17 

### Are those available for those of us that 18 

### joined the call remotely? Like can I get a copy 19 

### of whatever you have copies of mailed to me? 20 

### MR. RAMIREZ: We have books here. And I 21 

### was assuming these were on loan. So I was going 22309

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### to give them back here. But, Joe? 1 

### MR. HAGERMAN: The books are on loan. So 2 

### we'd appreciate them back. I mean, we're not 3 

### going to hunt you down if you don't -- I guess I 4 

### shouldn't say that. 5 

### [Laughter.] 6


### MR. HAGERMAN: But -- 7 

### MR. RAMIREZ: I'll gladly turn mine back 8 

### in. 9 

### MR. HAGERMAN: We can -- I guess if 10 

### there's a member that needs a copy, we can 11 

### possibly mail you a copy. 12 

### MR. LUTER: Well, that, or if there's an 13 

### electronic resource, I'm more than happy if you 14 

### just have a view-only copy on a screen. I just 15 

### like to follow along and keep up with 16 

### developments. 17 

### MS. HOFFMAN: Eric, did you have copies 18 

### we could unofficially have? 19 

### MR. LACEY: I am working on that. I just 20 

### had a voice mail this morning that I wasn't able 21 

### to return from the guy at IECC I'm trying to work 22310

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### with. I think there is an online view-only 1 

### version. But I haven't been able to find it, and 2 

### I haven't been able to connect with the right 3 

### person there. So. 4 

### MS. HOFFMAN: But can we ask you to come 5 

### up with it? 6 

### MR. LUBLINER: A couple of months ago, 7 

### there was one. 8 

### MS. HOFFMAN: Yeah. 9 

### MR. LUTER: I'm cognizant of copyright 10 

### issues and all that. I respect those. 11 

### MR. RAMIREZ: Yeah. That's what we're 12 

### dealing with. But I think that Eric is trying to 13 

### get approval for this working group so that we 14 

### could get some copies there. 15 

### MR. LUTER: It's not without precedent 16 

### for that to happen. That's for sure. 17 

### MR. LUBLINER: Rob, Mike Lubliner. I had 18 

### to spend 50 bucks to buy the electronic version 19 

### last week in preparation for Manny's meeting. 20 

### MR. LUTER: Well, you got a deal. 21 

### [Laughter.] 22311

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### MR. RAMIREZ: Mark? 1 

### Go ahead, Isabel. 2 

### MS. DICKENS: Can you all hear me? I'm 3 

### sorry. I've been trying to get in a little bit. 4 

### I am just -- I can't afford to come out 5 

### to all these meetings. I had to reserve a flight 6 

### for the 22nd and 23rd of September meeting. But 7 

### I'm wondering if we can set dates today for the 8 

### future meetings that we're going to have into 9 

### October. 10 

### And I may end up having to just change a 11 

### flight, because I'm not sure I can come out more 12 

### than one more time and whether coming on the 22nd 13 

### makes more sense or coming in mid-October makes 14 

### better sense. 15 

### So, can we set those dates right now? 16 

### MR. RAMIREZ: Before we get there, Mark, 17 

### you had a comment? 18 

### MR. WEISS: Yeah, just before we move on. 19 

### Turn back the booklets in at the end of the 20 

### proceeding. 21 

### MR. HAGERMAN: Yeah, at the end. We're 22312

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### at the honor system here. At the end of the 1 

### proceeding, turn back your books. 2 

### MR. WEISS: Right. Right. 3 

### MR. HAGERMAN: Or you fail the class. 4 

### And yes, I agree. We should talk about 5 

### the future dates and locations. The offer is on 6 

### the table that we could meet at another DOE 7 

### facility. We have a facility in Chicago at the 8 

### Argon National Lab. It's pretty easy. And then 9 

### there's also a facility, a very nice facility, 10 

### brand-new facility in Golden, Colorado, at the 11 

### National Renewable Lab. 12 

### MS. DICKENS: I would vote for Colorado. 13 

### MR. HAGERMAN: Colorado is very easy for 14 

### a lot of us to get to. So. 15 

### MR. RAMIREZ: All right. Well, I'll tell 16 

### you what. Let's look at dates, and then we could 17 

### determine location. 18 

### MR. HAGERMAN: I think the next meeting 19 

### we set last time to be here. So the future, the 20 

### next future meeting that we haven't set yet is 21 

### October 1st or October 2nd, something like that. 22313

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### MS. HOFFMAN: Yeah. Eileen Hoffman. 1 

### We have it in the registrar as being 2 

### here, but that doesn't mean that couldn't change. 3 

### But we do have both for September 22nd and 23rd 4 

### in a ground-floor address here, and October 1 and 5 

### 2 here. 6 

### MR. RAMIREZ: Right. So, let's look at 7 

### the next dates beyond October 1st and 2nd. What 8 

### other dates do you all want to -- 9 

### MR. HAGERMAN: October 1 and 2 are on the 10 

### table for being at a different location. If the 11 

### committee -- if the working group tells me ahead 12 

### of time, I could work with our contractors to get 13 

### us a discounted room rate at some of the local 14 

### hotels there. So. 15 

### MR. RAMIREZ: So, is everyone okay with 16 

### changing the location? It sounds like Denver is 17 

### the preferred spot? Is there any objection to 18 

### holding the October 1st and 2nd meetings in 19


### Denver? 20 

### [Cross-talk.] 21 

### MS. DICKENS: Although I said Colorado, 22314

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### if I come out to D.C. in September, I wouldn't be 1 

### able to get to Colorado in October. So it 2 

### doesn't really matter. You should decide. 3 

### MR. RAMIREZ: Okay. Anyone else? 4 

### MR. LUBLINER: Mike Lubliner here. 5 

### I have already made my plans, my travel 6 

### plans, for D.C. on October 1st and 2nd. And 7 

### because I'm not being reimbursed by DOE for this, 8 

### I've tried to use that time back in D.C. to meet 9 

### with other clients, which I've already scheduled 10 

### meetings for on the 3rd. 11 

### So it would be a real disruption to me to 12 

### have to change that end route for Golden, 13 

### Colorado. But I would be very willing, if we 14 

### have future meetings beyond that, to consider 15 

### doing the next one in Golden, Colorado, say the 16 

### third week in October. 17 

### MR. RAMIREZ: Okay. So is everyone okay, 18 

### then, keeping the October 1st and 2nd here in 19


### D.C.? 20 

### MR. SANTANA: Well, did we already set 21 

### the date for October 1st and 2nd? 22315

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### MS. HOFFMAN: Yes, we did. 1 

### MR. SANTANA: Was that already 2 

### established? 3 

### MS. HOFFMAN: Well, we had it down, yes. 4 

### And it wasn't affirmed, but it was pretty close. 5 

### MR. RAMIREZ: Yeah. So I think that we 6 

### did have that one down. 7 

### MR. SANTANA: Well, you know, that's only 8 

### a week-and-a-half after the 22nd meeting. So I 9 

### can make it to the 22nd and probably not to the 10 

### 1st. 11 

### MR. LUBLINER: It's actually five 12 

### business days later. I just wonder whether 13 

### something can be accomplished in that period. 14 

### [Pause.] 15 

### MR. RAMIREZ: Yeah, because I think part 16 

### of the reason that we were scheduling with these 17 

### two-week increments was because of the concern 18 

### that we were going to be requesting quite a bit 19 

### of analysis. By then, I'm hoping that we have 20 

### the numbers that we need in order to start making 21 

### decisions. 22316

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### So, as a facilitator, I don't see why we 1 

### couldn't have it that tight unless someone else 2 

### -- and I guess I'd have to defer more to Joe and 3 

### some of the other folks that, if that's not going 4 

### to be productive, then, yeah, let's give it a 5 

### little bit more space. But if we can, let's move 6 

### forward. 7 

### [Pause.] 8 

### MR. RAMIREZ: So, let's keep the 1st and 9 

### 2nd then. All right. 10 

### So, beyond the 1st and 2nd, when do you 11 

### want to look again? What other date? 12 

### [Pause.] 13 

### MS. DICKENS: Do you think it would be 14 

### one more being after the 1st and 2nd? Do you 15 

### think we can do it? I mean, that would be our 16 

### third meeting from today, right? 17 

### MR. RAMIREZ: Yeah. When you talk about 18 

### sets, yeah. 19 

### MS. DICKENS: Yeah. So maybe we -- do we 20 

### want to go into the third week of October, the 21 

### week starting October the 20th? 22317

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### MR. LUBLINER: This is Mike Lubliner. 1 

### That's the soonest that I could -- my 2 

### October is full. I had to defer everything that 3 

### I was going to do in September to October for my 4 

### clients, my paying clients. 5 

### [Laughter.] 6 

### MR. LUBLINER: So, yeah, I'd like to -- 7 

### I'd certainly like to go to the third week. That 8 

### will give me a couple of weeks to catch up on my 9 

### back order from that meeting on the 1st. And I 10 

### think that gives us a good amount of time to 11 

### really get some of the subcommittee wheelings and 12 

### dealings done so that I'm -- 13 

### MS. HOFFMAN: Are we talking then -- 14 

### Michael, are we talking about the week of October 15 

### 20th? That's a Monday. 16 

### MR. LUBLINER: Yeah. That would be my 17 

### preference. Yeah, thank you. 18 

### MR. LUTER: I'd echo that preference. 19 

### This is Rob. 20 

### MR. EZZO: Mark Ezzo. That week works 21 

### for me, too. 22318

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### MR. RAMIREZ: All right. So which days 1 

### do you want to look at on there? 2 

### MALE VOICE: Not Monday. 3 

### MR. WEISS: Not Friday. 4 

### MR. LUTER: The 21st, 22nd. 5 

### MR. RAMIREZ: Yes. We're looking at 6 

### Tuesday, Wednesday, Thursday. Of those three 7 

### days, which ones work best for everybody? 8 

### MS. DICKENS: I'd like Wednesday and 9 

### Thursday. But I can be flexible. 10 

### MR. RAMIREZ: Stacey? 11 

### MALE VOICE: Tuesday, Wednesday, or 12 

### Thursday are fine. 13 

### MS. EPPERSON: Wednesday, I'm out. But I 14 

### could possibly do an alternate. But I imagine 15 

### this is our final vote, too, isn't it? Okay. 16 

### MR. RAMIREZ: That's the hope. 17 

### MS. EPPERSON: Um-hm. 18 

### MS. DICKENS: Would Thursday-Friday work 19 

### for people, the 23rd and 24th? 20


### MS. EPPERSON: Yes. 21 

### MR. RAMIREZ: I heard somebody say not 22319

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### Friday. 1 

### MR. WEISS: That was a preference. 2 

### MR. RAMIREZ: Yeah. Let me beat you up 3 

### on that one, Mark, then, right? If it's a 4 

### preference -- 5 

### MR. WEISS: I'm flexible. 6 

### MR. RAMIREZ: Because Stacey does have a 7 

### conflict on Wednesday. 8 

### So how does the 23rd and the 24th look? 9 

### MR. HAGERMAN: Would it help if we 10 

### proposed, just as an option, you fly in the 22nd, 11 

### the meeting starts at 1:00, and you fly out the 12 

### 24th? 13 

### MALE VOICE: Are we flying into Golden? 14 

### MS. HOFFMAN: Or is this going to be -- 15


### MR. HAGERMAN: In Denver. 16 

### MR. RAMIREZ: So a half-day on Wednesday, 17 

### full day on Thursday, half-day on Friday? 18


### MR. HAGERMAN: Sure. 19 

### MS. EPPERSON: I'm out on the 22nd, all 20 

### day. I could fly that night. 21 

### MR. LEVY: I want to suggest Chicago as 22320

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### an option. I'm more interested in whether other 1 

### people who haven't been able to make the meetings 2 

### could come to that meeting if it was closer to 3 

### them. 4 

### MR. ROY: I'm getting tired of flying 5 

### from the West Coast, but there you go. 6 

### MR. LUTER: I'd vote for Chicago 7 

### wholeheartedly, but I'm selfish. I can drive. 8 

### MR. EZZO: This is Mark. I could do 9 

### either Denver or Chicago. 10 

### MR. SANTANA: Manny here. I can do 11 

### either as well. And I think in late October, I'm 12 

### pretty much open. So whatever you guys decide, 13 

### I'll be pretty good. 14 

### MR. LUBLINER: This is Mike Lubliner. 15 

### My preference would be Denver. But I 16 

### would say either flip a coin or come to 17 

### consensus. I would attend Chicago as well if the 18 

### group feels it's appropriate. 19 

### MS. DICKENS: This is Isabel. I'm more 20 

### likely to attend in person in Denver. I'm more 21 

### likely to attend by telephone if it's Chicago, 22321

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### just because of other issues in the cities, where 1 

### I can do more work or not. 2 

### MR. RAMIREZ: And Michael Wade chimed in 3 

### that Golden was a preference. 4 

### [Cross-talk.] 5 

### MR. RAMIREZ: And Dave Tompos was for 6 

### Chicago. 7 

### MS. HOFFMAN: It's about half and half. 8 

### MR. RAMIREZ: Yeah. It sounds like it's 9 

### a fairly even split. 10 

### Now, the folks that are saying Chicago, 11 

### is it a preference thing where it's just easier 12 

### to fly in and out of? Because I'm hearing some 13 

### folks say that Chicago would be very similar to 14 

### D.C. as far as ability to attend or not attend, 15 

### meaning that Denver would be a better location. 16 

### Selfishly, Argon, I could walk there if 17 

### we had it there. That's how close it is to my 18 

### house. But it sounds like the majority of the 19 

### folks, we'd probably get the greatest attendance 20 

### with Denver. 21 

### MR. LUBLINER: Javier, Mike Lubliner 22322

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### here. 1 

### My preference is Denver because of the 2 

### shorter plane flight. But also, it's much less 3 

### expensive for me, both in terms of flight and, 4 

### you know, accommodations and logistics and 5 

### everything, and time change. 6 

### MS. DICKENS: Ditto for Isabel. 7 

### MS. HOFFMAN: Well, why don't we make an 8 

### executive decision? 9 

### MR. RAMIREZ: Yeah. So let's pull the 10 

### trigger on Denver unless somebody really wants to 11 

### rip my head off for that. 12 

### MR. LUTER: Can I throw out something a 13 

### little unorthodox? Could we have a conference 14 

### room at both locations and hook up, do a 15 

### videoconference? We have the technology. 16 

### MR. RAMIREZ: I have no idea. I don't 17 

### know. 18 

### MR. LUTER: Let the West Coast folks go 19 

### to Denver and the East Coast folks go to Chicago? 20 

### MS. HOFFMAN: I hear you. There's a 21 

### synergy, I think, in having everyone, if 22323

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### possible, in the same room so we can actually 1 

### craft this final, you know, our final meeting. 2 

### MR. LUTER: I don't disagree. What I 3 

### seem to be hearing, though, is that for at least 4 

### a contingent, either place means GoToMeeting. 5 

### But if it could be both places, we could have 6 

### more people actually sitting in rooms next to one 7 

### another. 8 

### MR. RAMIREZ: Yeah. Let me hear the 9 

### folks that, if it was in Denver, that you would 10 

### absolutely have to do a GoToMeeting. And I don't 11 

### want to hear from you if regardless of where 12 

### we're having the meeting, it would be GoToMeeting 13 

### anyway. In fact, there's a number of you that 14 

### are doing that anyways. 15 

### But if it was Denver versus Chicago, how 16 

### many of you would then have to say, "I can't do 17 

### that. I'd have to do a GoToMeeting"? 18 

### MR. LUTER: It would probably be 19 

### GoToMeeting for me, Rob Luter, in Denver. 20 

### [Pause.] 21 

### [Inaudible interjection.] 22324

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### MR. RAMIREZ: And the other way, it 1 

### sounded like there was at least two that if it 2 

### was Chicago versus Denver, that it would have to 3 

### be a GoToMeeting, which was Isabel and Michael. 4 

### Was there anyone else that if it was in 5 

### Chicago, then you would have to do a GoToMeeting 6 

### then? 7 

### [Inaudible interjection.] 8 

### MR. RAMIREZ: No, no. Rob would go to 9 

### Chicago. 10 

### MR. TOMPOS: Dave Tompos. I favor 11 

### Chicago as well. 12 

### MR. RAMIREZ: What do you think, Eileen? 13 

### Well, let me ask Joe. All right. So 14 

### we're looking at the 23rd and 24th. But, Joe, 15 

### which has better facilities? 16 

### MR. HAGERMAN: Colorado. 17 

### MR. RAMIREZ: Let's do Colorado then. 18 

### All right? 19 

### MS. HOFFMAN: Joe, you'll be in charge of 20 

### getting the facilities. And you're also 21 

### recommending where to stay. 22325

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### MR. RAMIREZ: Joe is saying that they 1 

### have better facilities over in Colorado. 2 

### MS. HOFFMAN: Can you fly in that 3 

### morning? You can get -- no. You have to go the 4 

### night before. Okay. 5 

### MR. HAGERMAN: Well, it depends on the 6 

### start time, right? 7 

### MR. LUTER: Yeah. It's a little bit of a 8 

### hike from the airport over to Golden. 9 

### MR. RAMIREZ: It is? 10 

### MR. LUTER: Not as convenient as D.C. in 11 

### that regard. The meeting would be at NREL? 12 

### MR. HAGERMAN: The meeting would be at 13


### NREL. 14 

### MR. LUTER: Yeah, it's about 50 minutes 15 

### from the airport, 50 minutes to an hour from the 16 

### airport. 17 

### MR. RAMIREZ: You could take longer than 18 

### that in traffic in Chicago. 19 

### [Laughter.] 20 

### MR. RAMIREZ: Isabel, you had something? 21 

### MS. DICKENS: Yeah, I just thought we 22326

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### could meet at the airport and carpool. 1 

### MR. LUBLINER: I really think it would be 2 

### -- since we're talking about energy efficiency, I 3 

### think it would be a really good learning exposure 4 

### for a lot of people to tour the National 5 

### Renewable Energy Lab there. It's quite 6 

### impressive and might kind of sensitize us to some 7 

### of the discussions we're having about energy and 8 

### the opportunities here. 9 

### So that's my plug on a value system 10 

### basis. 11 

### MR. RAMIREZ: Okay. I think that will 12 

### have to be an optional field trip at the end of 13 

### our meetings, right? But I would sign up for it 14 

### if we did. 15 

### Okay. So then we're looking at Thursday16 

### Friday in Denver. We'll get out those details, 17 

### the 23rd and the 24th. 18 

### [Pause.] 19 

### MR. RAMIREZ: Yeah. Okay. So then -- 20 

### MS. HOFFMAN: Are we going to 21 

### tentatively, for tickets purposes, say it's nine 22327

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376

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### to five or nine to three? Nine to five the first 1 

### day, nine to three on a Friday? I don't know. I 2 

### just think we might want to -- 3 

### MR. HAGERMAN: I think for flights out, 4 

### back to D.C., we'd have to leave the facility 5 

### around noon or one to make the direct back. 6 

### MR. RAMIREZ: Yeah. That's going to make 7 

### for a pretty short meeting that day. 8 

### MS. DICKENS: We could start early. 9 

### MR. EZZO: We could start at eight. 10 

### MS. DICKENS: We could start an hour 11 

### earlier on Friday, since West Coast people 12 

### wouldn't be as impacted by an 8:00 a.m. start as 13 

### we would be if we had an 8:00 a.m. start in D.C. 14 

### and they were on the phone. An 8:00 a.m. start 15 

### in Denver would be okay, I think, for anyone who 16 

### is on the phone, as well as who was there in 17


### person. 18 

### MR. EZZO: How about starting early on 19 

### both days and ending early on Friday? 20 

### MR. RAMIREZ: So, a marathon session on 21 

### Thursday, the 23rd. 22328

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376

Toll Free: 888-445-3376 

### MALE VOICE: Eight to six. 1 

### MR. EZZO: Yeah, that's helpful for 2 

### people flying out on Friday. 3 

### MR. RAMIREZ: And then eight to noon on 4 

### Friday. So eight to six on the 23rd, eight to 5 

### noon on Friday. 6 

### MR. WEISS: So is there a shuttle? 7 

### [Cross-talk.] 8 

### MR. RAMIREZ: Okay. All right. Anything 9 

### else before we open the floor for public comment? 10 

### [Pause.] 11 

### MR. RAMIREZ: All right. Any public 12


### comment? 13 

### All right, Rick. Rick you could just use 14 

### the mic there. Just turn that one on. 15 

### MS. HOFFMAN: Just identify yourself. 16 

### MR. MENDLEN: Rick Mendlen. I'm just 17 

### going to sit. 18 

### I've been listening very attentively for 19 

### the last couple of days. And the one thing 20 

### that's on our front page in the HUD code is 21 

### affordability. 22329

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376

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### I got to say -- and unfortunately, Rob 1 

### left before I could get this out. I really do 2 

### appreciate his efforts and his thoughts about 3 

### having this sort of a two-tier product type. But 4 

### I am extremely concerned, as is my manager, about 5 

### some kind of a dual -- enforcing a dual set of 6 

### requirements. 7 

### Call them product types, call them 8 

### whatever you are. We're going to have enough 9 

### trouble integrating between the two agencies on 10 

### one enforcement mechanism or a dual-enforced 11 

### mechanism that's going to work effectively. 12 

### And complicating it with yet another set 13 

### of requirements that have to be evaluated by this 14 

### system I think is asking for more trouble than 15 

### our agency wants to deal with, I can tell you. 16 

### Thank you. 17 

### MR. RAMIREZ: Okay. All right. 18 

### MR. MENDLEN: Also, I can't make the 19 

### meeting because I'm committed to see my 20 

### grandchildren on the 23rd. 21 

### MS. HOFFMAN: What about the other day? 22330

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Toll Free: 888-445-3376 

### Will you be on phone? 1 

### MR. MENDLEN: I think I'll be on a plane. 2 

### MS. HOFFMAN: Oh, okay. 3 

### MR. RAMIREZ: Okay. Then, that's it, and 4 

### we'll have our communications back and forth. As 5 

### soon as we get data, as we have been, we'll send 6 

### it out as soon as possible. And as soon as you 7 

### can get something to Joe, the better. So that 8 

### way we could -- 9 

### MS. HOFFMAN: And if we want to do that 10 

### conference call, we'll get back to you about that 11 

### as well. We understand not the 16th. But it 12 

### might be later that week. 13 

### MR. HAGERMAN: And I would just like to 14 

### say for DOE, we really appreciate your time and 15 

### your commitment and your hard work at helping us 16 

### all come up to this consensus standard. So we 17 

### appreciate everything you're doing for us. 18 

### MS. HOFFMAN: Want to thank you all. 19 

### Thank you. 20 

### [Whereupon, at 4:22 p.m., the conference 21 

### concluded.] 22331

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

10 

### for, related to, nor employed by any of the

11 

### parties to the action in which this testimony is

12 

### taken; and, further, that I am not a relative or

13 

### employee of any of the parties hereto, nor

14 

### financially or otherwise

1s 

### outcome of the action.

16

17

18

19

20

21 

### Commission Expires: ,; 

### Notary Public in and for
The District of Columbia
10.14.2019

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. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445

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