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 U.S. DEPARTMENT OF ENERGY

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 MANUFACTURED HOUSING WORKING GROUP

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 PUBLIC MEETING

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 FRIDAY

 AUGUST 22, 2014

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The Public Meeting was held in Room 8E-089,

1000 Independence Avenue, S.W., Washington,

D.C., at 9:00 a.m., Eileen Hoffman, Meeting

Facilitator, presiding.

PRESENT:

EILEEN HOFFMAN, Meeting Facilitator, Federal 

 Mediation and Conciliation Service

TED BANTLE, Meeting Facilitator, Federal 

 Mediation and Conciliation Service

JOHN CASKEY, National Electric Manufacturers 

 Association*

KEITH DENNIS, National Rural Electric 

 Cooperative Association*

ISHBEL DICKENS, National Manufactured Home 

 Owners Association*

SCOTT DRAKE, East Kentucky Power Cooperative* 

STACY EPPERSON, Next Step Network

MARK EZZO, Clayton Homes, Inc.*

RICHARD HANGER, Housing Technology and 

 Standards*

BERT KESSLER, Palm Harbor Homes, Inc.*

ERIC LACEY, Responsible Energy Codes 

 Alliance
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EMANUEL LEVY, Systems Building Research 

 Alliance

MICHAEL LUBLINER, Washington State University

 Extension Energy Program

ROBERT LUTER, Lippert Components, Inc.*

RICHARD POTTS, Virginia Department of Housing

 and Community Development*

JAVIER RAMIREZ, Meeting Facilitator, Federal 

 Mediation and Conciliation Service

ROBIN ROY, Natural Resources Defense Council

MANUEL SANTANA, Cavco Industries

PETER SCHNEIDER, Efficiency Vermont*

DAVID TOMPOS, NTA, Inc.

MICHAEL WADE, Cavalier Home Builders*

MARK WEISS, Manufactured Housing Association 

 for Regulatory Reform

*Present via teleconference

ALSO PRESENT:

ED BARBOUR, Navigant Consulting

JOSEPH HAGERMAN, Energy Efficiency and

 Renewable Energy Office, U.S. Department

 of Energy

PAM PONTILLO, Office of Conflict Prevention 

 and Resolution, U.S. Department of

 Energy

DON SURRENA, National Association of 

 Homebuilders 

KANITA VAIDYANATHAN, Office of the General 

 Counsel, U.S. Department of Energy

MATTHEW WALKER, Navigant Consulting
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 TABLE OF CONTENTS

Introductions. . . . . . . . . . . . . . . . . 4

Continuing Discussion on . . . . . . . . . . . 8

Proposed Strawman by Emanuel Levy

Working Group Comments . . . . . . . . . . . 109

GC Questions and Comments. . . . . . . . . . 131

Discussion of Strawman by. . . . . . . . . . 193

Michael Lubliner

Next Steps . . . . . . . . . . . . . . . . . 295

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

2 (9:07 a.m.)

3 MS. HOFFMAN: Good morning. This

4 is the second day of our meeting, the ASRAC

5 Manufactured Housing Working Group. And just

6 to get started, let's just introduce who is in

7 the room and then we'll hear who is on the

8 phone. Why don't we start with you, Luby.

9 MEMBER LUBLINER: Mike Lubliner,

10 Washington State University Extension Energy

11 Program.

12 MEMBER EPPERSON: Stacy Epperson,

13 Next Step Network.

14 MEMBER WEISS: Mark Weiss,

15 Manufactured Housing Association for

16 Regulatory Reform.

17 MEMBER TOMPOS: David Tompos, NTA.

18 MEMBER ROY: Robin Roy, Natural

19 Resources Defense Council.

20 MEMBER LEVY: Emanuel Levy,

21 Systems Building Research Alliance.

22 MEMBER LACEY: Eric Lacey,
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1 Responsible Energy Codes Alliance.

2 MR. HAGERMAN: Joe Hagerman, DOE. 

3 And I know that we have Manny Santana here. 

4 He is getting Dunkin Donuts, let the record

5 show. And then let me go grab the list from

6 who is online.

7 MS. HOFFMAN: Okay. And while

8 he's doing that, let's hear from the folks on

9 the -- back there.

10 MS. VAIDYANATHAN: Kavita

11 Vaidyanathan from DOE, General Counsel's

12 Office.

13 MR. WALKER: Matthew Walker from

14 Navigant.

15 MR. BARBOUR: Ed Barbour, Navigant

16 Consulting.

17 MS. HOFFMAN: Pam, just tell us

18 who you are again.

19 MS. PONTILLO: Okay. This is Pam

20 Pontillo, and I'm DOE, Office of Conflict

21 Prevention and Resolution. 

22 MS. HOFFMAN: And I'm Eileen
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1 Barkas Hoffman from FMCS, one of your co2 facilitators.

3 MR. RAMIREZ: Javier Ramirez from

4 FMCS as well, facilitator.

5 MR. BANTLE: Ted Bantle from FMCS.

6 MS. HOFFMAN: Okay. Joe, so do

7 you have the list?

8 MR. HAGERMAN: And then we have

9 the following people online, and then I guess

10 they can introduce themselves after I get done

11 reading this list -- Ishbel Dickens, Mark

12 Ezzo, Richard Hanger, Bert Kessler, Robert

13 Luter, Richard Potts, Peter Schneider, and

14 Michael Wade.

15 MEMBER LUTER: Good morning. Rob

16 Luter with Lippert Components.

17 MS. HOFFMAN: Okay. Good morning.

18 MEMBER EZZO: Mark Ezzo, Clayton

19 Homes. Good morning.

20 MS. HOFFMAN: Good morning.

21 MEMBER DICKENS: Ishbel Dickens. 

22 Good morning.
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1 MS. HOFFMAN: Good morning. We

2 can hear you loud and clear.

3 MEMBER DICKENS: Great. Thank

4 you.

5 MS. HOFFMAN: Scott Drake, are you

6 on?

7 MEMBER HANGER: Rick Hanger, State

8 of Colorado.

9 MS. HOFFMAN: Excuse me?

10 MEMBER HANGER: Rick Hanger, State

11 of Colorado.

12 MS. HOFFMAN: Oh. Thank you.

13 MEMBER DRAKE: Scott Drake, East

14 Kentucky Power.

15 MS. HOFFMAN: Do we have Peter

16 Schneider?

17 MEMBER WADE: Michael Wade,

18 Cavalier Homes.

19 MS. HOFFMAN: Okay. 

20 MEMBER POTTS: Richard Potts,

21 Virginia Department of Housing and Community

22 Development.
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1 MS. HOFFMAN: Okay. Do we have

2 Bert Kessler? Oh, but he can't unmute. Okay. 

3 And Peter Schneider? He's on. Okay. 

4 Okay. Well, let's start.

5 MR. RAMIREZ: Eileen, I'm sorry. 

6 Before -- just one technical thing.

7 MS. HOFFMAN: Yes.

8 MR. RAMIREZ: Folks that are

9 online, if you could just mute your phones

10 unless you're going to comment. That way we

11 don't get any feedback or background noise. 

12 We appreciate that. Thank you.

13 MS. HOFFMAN: All right. Thank

14 you.

15 Okay. Javier is -- we put up a

16 revised agenda for today. We just want to go

17 over it with you.

18 MR. RAMIREZ: All right. So we're

19 planning on continuing the discussion with

20 Emanuel Levy on his proposed strawman. 

21 Hopefully, we can wrap that up in about an

22 hour or so. I mean, if we go long on any of
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1 this stuff, we'll find time to deal with it. 

2 Working group comments after that, and then --

3 oh, I'm the feedback. GC questions and

4 comments, and then Michael Lubliner had

5 presented a -- or emailed a strawman, and he

6 is going to review that with us as well. And

7 then we'll do lunch.

8 Eric is going to go over some

9 multiple compliance items that we had

10 discussed yesterday briefly. Lubliner will

11 lead the discussion on sources of data,

12 revisiting the Mind Map. And what we want to

13 do with the Mind Map is just look at that and

14 see if we can clean it up a little bit,

15 because I think after we've been discussing

16 this for a while we could probably agree that

17 there are some items on there that aren't

18 relevant to this working group and just see if

19 we could tighten it up a bit. Public comment,

20 and then agree on what we are going to do for

21 the next meeting as far as reviewing the

22 schedule and any wrap-up comments that we
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1 would need to do.

2 MS. HOFFMAN: So I think we should

3 just get started now with Emanuel.

4 (Pause)

5 MEMBER LEVY: This is more of kind

6 of a freeform discussion I think about some

7 issues that will impact the discussion of

8 affordability and what is affordable, and

9 there have been already a number of comments

10 in this vein. And I wanted to maybe take a

11 few minutes to see if we can capture the ideas

12 that have been discussed about how you put a

13 limit on what the requirements are predicated

14 on, issues of affordability.

15 So this is, again, a strawman, a

16 series of ideas. These are other economic

17 considerations that would enter into the

18 decisionmaking about setting standard levels. 

19 And the first one here is a list of

20 affordability metrics. I have been trying to

21 keep pace with what everybody has been saying

22 as to what other factors ought to be
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1 considered when we look at affordability. 

2 The ones I have captured so far

3 are price elasticity of demand, added cost of

4 energy measures, that in regard to what impact

5 might be on affordability, the ability of

6 homeowners to purchase a home, added costs

7 associated with the measures, basically in the

8 same vein. And other factors that tie

9 allowable cost increase to the cost of the

10 home.

11 So I wanted to use this

12 opportunity to open this up for discussion and

13 see if we can't discuss some of these

14 specifics in ways that are meaningful that

15 could help in the standard-setting process. 

16 So let me just kind of throw that open, see

17 whether anybody has any comments about how we

18 use affordability metrics to impact the

19 requirements. Any comments? Thoughts? Mark?

20 MEMBER WEISS: I'd like to see --

21 and perhaps we should have some more specific

22 reference to some of these related cost
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1 issues, for example, issues relating to air

2 exchange, moisture, condensation, and what is

3 needed to overcome those collateral impacts in

4 terms of both the cost of direct measures and

5 related energy costs. 

6 I'll give you an example. You

7 know, given air exchange, if you need to have

8 a more powerful -- and, again, I'm not a

9 technical person, but a more powerful pumping

10 system for getting air through the house, the

11 cost of that and then the energy-related cost

12 of that, cost for electricity and so forth, I

13 think those are legitimate issues. I don't

14 know what remedial measures would be needed

15 with respect to condensation and moisture, but

16 those should be considered as well.

17 MEMBER EZZO: This is Mark Ezzo at

18 Clayton Homes. I agree with what Mark is

19 saying. So far we have just really talked

20 about envelope costs, but there is a lot of

21 other things in the energy code that are going

22 to attribute to cost. And there is extra
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1 testing that has to be done that we're not

2 doing today, and there are lots of air sealing

3 measures, sealants, and prescriptive tables

4 that we're not doing today. So I think it's

5 important that we capture the costs of all of

6 those things in any kind of analysis we are

7 doing. 

8 There is something else in the

9 code, and it's in regards to inspection

10 processes. And I know that the regulatory

11 side of how things are going to be regulated

12 and controlled are not part of our scope, but

13 there are items in the code, in the energy

14 code, that address at what point in the

15 construction things have to be inspected. And

16 if that ends up being a lot more burdensome

17 than what we do today, that's going to add

18 cost as well to the process.

19 MR. HAGERMAN: So this is Joe

20 Hagerman. Mark, those are all great comments.

21 Emanuel, you have -- the next

22 section, Section 3, talks about establishing
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1 energy measure properties for different items,

2 some of those items that Mark just talked

3 about. So how did you -- when you put this,

4 you know, this framework originally together,

5 how were you dealing with these issues?

6 MEMBER LEVY: Well, of course,

7 they are place markers for later on coming up

8 with some suggested ways that those things be

9 verified. And those sections are intended to

10 be fleshed out before the Committee actually

11 gets to them with some ideas about how those

12 would be looked at in the field and verified

13 in the field and compliance verified.

14 And I think what Mark is talking

15 about is let's make sure we capture the costs

16 of all of this --

17 MR. HAGERMAN: The costs here, but

18 the terms of the measure in Section 3.

19 MEMBER LEVY: That's right.

20 Did I characterize that correctly,

21 Mark?

22 MEMBER EZZO: Yes. That's right.
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1 MEMBER LEVY: Anything else about

2 other -- capturing other -- other costs? Yes,

3 Michael.

4 MEMBER LUBLINER: Yes. I'm

5 wondering if you want to separate out the cost

6 of inspections and compliance from the other

7 things there that -- in that they are

8 amortized over a bunch of houses as opposed to

9 individual measures for individual houses. I

10 agree with Mark's comments that we need to --

11 both Marks' comments that we need to look at

12 all of the costs. But I think we will have a

13 different methodology for -- and so I want to

14 separate them out.

15 MEMBER LEVY: Okay. Any other

16 comments here?

17 There was also discussion

18 yesterday about price elasticity of demand. 

19 I don't recall who brought that up, but -- was

20 that Eric? Do you want to expand on what you

21 meant there, Eric?

22 MEMBER LACEY: Yes. I think what
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1 I was looking for is maybe some information or

2 some studies on where the step changes happen

3 and how big they are. And, you know, for

4 example, is it true that one dollar of

5 increased cost would knock out, you know, 300

6 people? Or is it that there is some

7 flexibility within the market? For example,

8 someone could buy an existing home or someone

9 could buy from a competitor.

10 And in some of these things, it

11 may not be the case, and I actually think it's

12 not the case, that the demand for homes is

13 effected on a straight line sort of basis. 

14 I'm not an economist, but, you know, I tend to

15 think that it's maybe a little bit more fluid

16 and flexible than that.

17 So I'd be interested if there are

18 studies on that or -- or, you know, if there

19 is kind of, you know, a sensitivity analysis

20 on that.

21 MEMBER WEISS: Yes. Eric, we do

22 have the study that was done recently by NAHB
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1 that was mentioned at the last meeting. I

2 don't know how fine or detailed that gets, but

3 one of the things that I think we are doing

4 for a subgroup is to try to get in touch with

5 them and try to ascertain how refined that

6 analysis is.

7 MR. RAMIREZ: So, then, the

8 Finance Committee would work on trying to get

9 stuff together on that?

10 MEMBER EPPERSON: Stacy, Next

11 Step. Yes. And we've gotten the information

12 of the economist who completed the study, and

13 we plan to schedule her for a discussion.

14 MR. RAMIREZ: Great. Okay. Thank

15 you. Eric?

16 MEMBER LACEY: I was just going to

17 follow up on what Mark suggested, the NAHB

18 study. I think the NAHB study is actually a

19 poor example of looking -- I think it doesn't

20 consider the price elasticity of demand. So,

21 I mean, that's fine to put that in there as

22 one possibility, but I think we need to look
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1 at some that do consider a real -- you know,

2 some real demand issues. But that's -- you

3 know, it's certainly a good idea to include

4 that.

5 MEMBER EPPERSON: This is Stacy. 

6 Do you have any examples, Eric, of some that

7 we might look at?

8 MEMBER LACEY: I don't.

9 MEMBER EPPERSON: Okay.

10 MEMBER LUBLINER: I do. I

11 referenced these on the first call, and I

12 think Joe has a copy of them now. One is

13 Marshall, and that one was looking

14 specifically at the manufactured housing

15 industry and not the entire public, like I

16 believe the NAHB report was. It's Marshall

17 and Marks, and I think it was done in 2006.

18 There is another study I shared

19 with Joe that Tom Eckman did that looked at

20 the other side of the market, whether or not

21 as you increase the price of a home and the

22 energy efficiency whether you grow your market
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1 at the upper end. I have that study as well

2 for you.

3 And then I would recommend that

4 you look at the study that MHI did, Dr. Carol

5 Meeks. I believe that was -- I don't know,

6 when was that, like in the early 90s I think? 

7 Yes, as well. But those are the three studies

8 that I am aware of that might add value to the

9 group's effort.

10 Thanks.

11 MR. HAGERMAN: So let me also say

12 it's -- Michael, thank you for sending

13 everything you sent. He sent me maybe five or

14 six emails last night around 11:00, so he

15 bombed my in box. I have not yet had a chance

16 to circulate that to the group, but I intend

17 to do that as soon as possible today.

18 MEMBER LUBLINER: I want to make

19 sure I send it to Joe, so he can look at it,

20 see if it kind of met the target of what we

21 wanted to do. So thanks.

22 MR. HAGERMAN: I think usually if
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1 you send me anything, if anybody sends me

2 anything, we send it out pretty promptly. 

3 Sometimes if it's, you know, a little bit

4 obtuse we might ask you a question about how

5 you intend, you know, the working group to

6 consider it. So I know, like, Robin asked a

7 question about the -- can we get an ENERGY

8 STAR manufactured home model, which we are

9 going to send those results, but, you know,

10 we're not going to send his request out to the

11 group. We're going to send you the results

12 once we get them.

13 MS. HOFFMAN: I just wanted to --

14 it's Eileen. I wanted just to ask, is this

15 the appropriate time to see if there is a

16 consensus on this is what we need to do for

17 affordability metrics, or is it -- is it still

18 in fluid state? Any comments?

19 MEMBER ROY: I think it's in the

20 fluid state. I think we are getting a good

21 list of lots of different types of data, but

22 the headings aren't quite meshing with the
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1 content everywhere. It's a bunch of good

2 stuff that needs a little bit more innovation.

3 MS. HOFFMAN: Okay.

4 MEMBER ROY: I'm not sure it needs

5 to be done with a huge group. I suspect

6 Emanuel will go and take it and mesh it around

7 and throw it back at us with some --

8 MS. HOFFMAN: Okay. I just wanted

9 to make sure we got feedback.

10 MEMBER WEISS: Also, I think the

11 further we get into this, I think other things

12 are going to arise that need to be addressed,

13 so --

14 MS. HOFFMAN: Okay. Fine. Just

15 taking the temperature.

16 MR. HAGERMAN: I think we have a

17 consensus that we are going to kind of march

18 down this framework and use this framework to

19 ground the conversation direction, right? I

20 mean, thus far, absent some other proposal?

21 MEMBER WEISS: Other than those

22 goals that I mentioned yesterday, I mean,
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1 everything after the goals I'm fine with.

2 MR. HAGERMAN: Okay. Great.

3 MS. HOFFMAN: Okay.

4 MR. HAGERMAN: We agree.

5 MS. HOFFMAN: Okay. Sorry,

6 Emanuel. Keep going.

7 MEMBER LEVY: Okay. Manny, did

8 you want to say something?

9 MEMBER SANTANA: No. I'm good.

10 MS. HOFFMAN: Oh, okay. We should

11 summarize, besides those guiding principles,

12 the framework itself is one we are working

13 with. Okay.

14 MEMBER LEVY: So have we captured

15 everything as of the moment in terms of other

16 metrics that we want to use? Costs of the

17 measures, other measures other than the ones

18 that we're looking at through life cycle cost,

19 costs of inspections and compliance, and price

20 elasticity -- those seem to be the three areas

21 that we are concerned about, right?

22 The next -- Section 2 is intended
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1 to capture those specific conditions that have

2 been brought up by various members of the

3 Committee that might pose particular problems

4 because of the cost of those kinds of -- in

5 this case homes meeting whatever standards are

6 developed. 

7 So I have listed three here that I

8 think were points that were made as to the

9 kinds of homes that could pose problems for --

10 in meeting these standards. I wanted to see

11 whether we have captured the right -- all of

12 the right items and whether there should be

13 other ones added here. And these would be

14 sent -- these would be the subject of

15 sensitivity studies as part of the life cycle

16 cost analysis.

17 And we can add more specificity

18 here, if that's appropriate. What other

19 things should we be looking at to make sure

20 they are not unduly burdened by whatever comes

21 out of the standards process?

22 MR. HAGERMAN: I was just going to
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1 -- one thing that I think David Tompos said

2 yesterday isn't on that list, that there are

3 some state-specific shipping limitations,

4 right?

5 MR. RAMIREZ: Stacy? Michael?

6 MS. HOFFMAN: Robin?

7 MR. RAMIREZ: Michael?

8 MEMBER LUBLINER: I'm interested

9 in learning a little bit more about these --

10 you know, kind of what the technical -- the

11 problem was.

12 MEMBER LEVY: What the specifics

13 are?

14 MEMBER LUBLINER: Yes. And is it

15 associated with the Uo? Or, in other words,

16 if we used a prescriptive approach, which is

17 available to us. So I've just got to get a

18 sense of what the challenges are here at some

19 point and I'll feel more comfortable about

20 what I can -- yes.

21 MEMBER TOMPOS: Dave Tompos. I

22 guess I can talk about a couple of them. 
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1 Cathedral ceilings I think is a big concern. 

2 You know, we talk about getting an R38 in a

3 cathedral. Prescriptively, you can say that

4 you're getting an R38, but with the trust

5 configurations that I have seen it is going to

6 get compressed down. You're going to get

7 about -- I think the maximum that I think that

8 we can get is about a 32, somewhere in that

9 range.

10 So you just have a physical

11 constraint that you can't do much more than

12 that. I know there are some manufacturers

13 that are doing almost nothing but cathedral

14 homes. So, and I don't think too many of them

15 are represented on this Committee, so that's

16 one of my -- one of my big concerns.

17 The seven-foot sidewalls, some of

18 that is the U of O being able to meet -- it's

19 just very difficult to meet that when you

20 shrink down the wall sizes. And typically

21 when you do that you are going to have more

22 glazing area. And then the state-specific
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1 shipping limitations, I still would love to

2 see the example of an R60 roof in Vermont,

3 because that could solve all our problems if

4 we have an example of how to do that.

5 MEMBER ROY: Dave, with the

6 exception of the shipping, would all of those

7 be addressed by taking a UA approach as

8 opposed to a Uo approach? The sidewalls

9 would, right, because it's just for the

10 structure. And that wouldn't be a problem. 

11 The cathedral ceilings? I'm not sure.

12 MEMBER TOMPOS: Potentially. I

13 mean, you know, if you can take the tradeoffs,

14 that's great. It's just a matter of if you

15 take the tradeoff in the roof cavity and say,

16 okay, now we can only get an R -- let's say,

17 R30 in the roof cavity, now I'm going to have

18 to put a lot more either in the floors or in

19 the sidewalls, we maybe have more opportunity

20 in the sidewalls than we do in the floor

21 cavity. 

22 And it's not a -- it's not like we
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1 can't do it. I know some people suggested,

2 okay, we go to a two by eight, two by ten. 

3 Again, we may run into some of those height

4 limitations, but I think you're going to find

5 out that when you go from a two by six to a

6 two by eight or two by ten that the -- it's

7 not going to be affordable considering the

8 amount of additional R value you get, because

9 you're not going to get a whole lot more for

10 those couple of inches as opposed to the --

11 you know, you're probably looking at a 30

12 percent cost increase to go from some of those

13 different numbers for an entire building. 

14 So --

15 MR. RAMIREZ: Eric?

16 MEMBER TOMPOS: -- it is possible. 

17 I just -- it's a matter of whether or not it's

18 affordable.

19 MR. RAMIREZ: Right. Eric?

20 MEMBER LACEY: I just want to

21 throw something in here, and I know we'll talk

22 about this later. Several of us have been
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1 talking about, you know, multiple compliance

2 options and how that might solve some of these

3 issues. I totally support this idea of

4 finding kind of the optimal, you know,

5 efficiency and cost effectiveness number, you

6 know, that Emanuel is going after. I think

7 that's a good cause.

8 But I also think that in the name

9 of getting to a compromise some of these

10 issues might be solved if we had a few

11 different options. You know, maybe you have

12 a prescriptive table and it has a set path

13 that you can meet and it's simple, but it

14 might not account for cathedral ceilings, so

15 in that case you go to a different option, you

16 go to a UA that is based on that but allow

17 more tradeoffs. 

18 The U of O obviously would be, you

19 know, something that industry is familiar

20 with, and if that's all you've been doing and

21 you're comfortable with those calculations,

22 you can continue down that path. But, I mean,
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1 this is a good discussion to have, and I don't

2 mean to, like -- to get off the rails here. 

3 But I want folks to keep that in

4 mind, that I don't think we have to solve for

5 every specific construction type and come up

6 with one standard that would satisfy all of

7 them, and all designs, but that maybe there

8 might be some flexibility built into this to

9 address those things.

10 But, anyway, this is good

11 information to get on the table at least.

12 MEMBER SCHNEIDER: This is Peter

13 Schneider.

14 MR. RAMIREZ: Go ahead, Peter.

15 MEMBER SCHNEIDER: Okay. I was

16 just wondering, what is the roof pitch that

17 the manufactured housing industry needs to

18 achieve? Like, what is the minimum, you know,

19 where the shingles warranty is not voided and

20 we can get away -- because it sounds like we

21 are talking about a cosmetic issue here and

22 not actually, you know, a structural issue.
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1 That is, you're trying to achieve

2 a certain roof pitch for a home to be

3 delivered down the road turn-key, so you don't

4 have to flip up, you know, your roof and do

5 any work onsite. So I'm just wondering, you

6 know, if you didn't have such a steep pitch

7 roof, doesn't that accommodate a better truss

8 that could accommodate those R values? And

9 even a floor system that would accommodate

10 higher R values?

11 MEMBER SANTANA: This is Manny

12 with Cavco. As far as the minimum roof pitch,

13 to comply with the shingles manufacturers'

14 requirements, that would be a two/twelve. 

15 And, you are right, if you have a two/twelve

16 pitch on the roof, that takes away some of the

17 overall height. Problem is, there is a trend

18 towards folks wanting to buy steeper pitched

19 roofs.

20 And I don't know how we -- I don't

21 know how you -- you can't ignore that trend

22 and that demand, you know, only if -- if we
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1 build two/twelve pitches, you know, I'm not a

2 dealer, but I'm sure that would have a big

3 effect on sales, overall look and aesthetics. 

4 You know, it's a factor.

5 MEMBER SCHNEIDER: I think that

6 that needs to be looked at in more detail. 

7 You know, the homes in Vermont that we are

8 delivering have a two and a half/twelve pitch,

9 and that's how we're achieving all of the R

10 values we are achieving. 

11 And I haven't had a homeowner to

12 date mention the roof pitch as being

13 aesthetically displeasing and any different

14 than the typical manufactured home that is

15 sitting on a dealer lot. So, you know, that

16 concern may be alleviated with the market

17 consumer research.

18 MEMBER SANTANA: You know, in

19 response to that, I would like to point out

20 that we are talking about a region -- you

21 know, I don't know exactly what the percentage

22 of total manufactured housing sales to Vermont
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1 is, but I know that the top 10 or 12 states

2 are in the southeast, with the exception of

3 California.

4 So although I believe the evidence

5 that you present, I don't see that it is

6 representative of the manufactured housing

7 industry as a whole.

8 MEMBER SCHNEIDER: No. And that's

9 the reason that there needs to be consumer

10 research. But I will tell you in Vermont we

11 are far more used to steeper pitched roofs

12 than anybody else in the country with our snow

13 loading.

14 MR. RAMIREZ: All right. So let's

15 go to Stacy and then Michael.

16 MEMBER EPPERSON: Stacy. So I'm

17 going to put my lender hat on. I think roof

18 pitch, what I'd like to point out here, that

19 from a market-based solution and how you

20 finance it and how you give it value, one of

21 the ways you get more value is curb appeal and

22 blending with the site built world. 
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1 And roof pitch at Next Step is one

2 of those strategies to help get better

3 financing into the marketplace. If we have

4 these two/twelves, it affects it. So I just

5 want to point that out from an overall market

6 perspective.

7 MEMBER SCHNEIDER: Stacy, do you

8 have data that prove that?

9 MEMBER EPPERSON: Well, we could

10 look into this, because we could look at the

11 pitch that sells regionally, and what those --

12 I don't have a study of values, but I know how

13 they appraise and there is a difference with

14 a small amount of data, but I don't know if

15 there are national studies.

16 (Pause)

17 MEMBER SCHNEIDER: This is Peter,

18 just with one more comment, which is let's

19 take a look at a section of achieving the R

20 values of IECC 2015 of a home in, let's just

21 say, the three HUD climate zones and just see

22 what that section looks like, you know, and
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1 what the maximum roof pitch it that we can

2 achieve while achieving the R values and the

3 cavity depths that we need in each of those,

4 in the roof truss and in the floor system,

5 instead of, you know, anecdotally determining

6 that a two/twelve, you know, isn't going to

7 meet the market's demand for a steeper roof

8 pitch.

9 MEMBER LUBLINER: This is Mike

10 Lubliner. I totally agree with what Peter

11 says. We need to do the engineering here and

12 tell us -- and then once we have that, once we

13 know which are the roof pitches -- and as I

14 understand, this is in the -- this has to do

15 with cathedral ceilings as well. 

16 You know, this is a tall roof

17 pitch with a cathedral ceiling. I wasn't

18 sure, Stacy, if that was what you were -- when

19 you talked about roof pitch, is this in the

20 context of also a cathedral ceiling in the

21 house or a flat -- so we need to be clear on

22 what it is we're talking about, is my point. 
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1 And I totally agree with Peter. 

2 We need to identify, what are the typical roof

3 trusses with cathedral, without cathedral, and

4 what percentage of the market they represent. 

5 I don't want to be chasing for two days here

6 a discussion that has to do with one percent

7 of the market, which is a cathedral high

8 pitch.

9 My experience in the northwest

10 where we built an upper end home is that --

11 significantly upper end, there is more triple

12 wides than there are singles, but we --

13 two/twelve is accepted. We -- very rarely do

14 we see a lot that -- where we are going to get

15 into a problem situation. And when we do,

16 they do a tilt up and those customers can

17 generally afford that.

18 But I think that the methodology

19 we need to approach here is first to establish

20 the engineering. Where is the problem with

21 the pitch relative to its cathedral or flat

22 ceiling? And then go in and look at how --
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1 what percentage of the time you typically get

2 a home built that way. When we have that

3 information, then we can decide whether we

4 want to just exempt that as, okay, these cases

5 don't need -- they are allowed to have more

6 compression.

7 On the floors, I am not here to

8 tell you you need to start building two by

9 eight floor joists if you're building two by

10 six to meet an energy code. That's

11 ridiculous. I think we can sit down, again,

12 with the engineering and identify how much of

13 what I called the "pooch" yesterday, how long

14 the belly blanket needs to be to get an

15 acceptable amount of dip to accommodate the

16 belly board, and then look at what that

17 compression is and allow that based on the

18 physical limitations that you discuss.

19 So I think we should really be

20 thinking about, what are the -- where can we

21 make exceptions to these rules and not -- and

22 identify where there is a problem and how
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1 extensive the problem is in terms of the

2 population of homes that we are going to be

3 regulating here. 

4 Thank you.

5 MR. RAMIREZ: Stacy, did you have

6 something? Okay. David?

7 MEMBER TOMPOS: I agree. I think

8 we need to get some of these numbers before we

9 can determine if we have any problem at all. 

10 We are just trying to get them out there.

11 Emanuel, if you go back to your

12 list -- I don't know where we went -- I just

13 want to add, because I also have a concern

14 about some of the FEMA product that our

15 industry builds. I want to make sure that at

16 the end of the day once we figure out where

17 everything falls that we can still build a --

18 the unit that I'm concerned about is the

19 northern handicap-accessible unit, because we

20 have -- we already have space limitations the

21 way it is.

22 MEMBER LUBLINER: This is Mike
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1 Lubliner again. There was also discussion

2 about which of these issues are really driven

3 by the Uo calculation approach, and whether or

4 not these issues go away if you provide a

5 prescriptive approach or a UA tradeoff. So I

6 want to make sure that, as we do this, I'd

7 like to get a sense -- it seems like if you

8 had a prescriptive path that worked, one size

9 fits all, that Item A might not be an issue

10 because you're just going to build to the same

11 thing.

12 The same thing with Item C. If

13 you had used the prescriptive path, that's not

14 an issue. Therefore, D isn't an issue, and

15 I'd like to understand the FEMA part, and also

16 work with FEMA. I've had FEMA call me, asking

17 me what kind of ventilation standards to put

18 in manufactured homes. And when I made my

19 recommendation, they said, "HUD won't let us

20 do that."

21 So I think that we need to be

22 thinking proactively with FEMA about, you
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1 know, what are the challenges, so that their

2 procurement gets the win-win, gets the designs

3 they need and ensures the efficiency, that

4 they are not having to make an exception for

5 FEMA homes in the energy code.

6 But, again, let's delve into the

7 engineering and figure that one out, what it

8 costs and what the issue is.

9 And, finally, I want to bring my

10 little box to the table and show you a system

11 that we have been working on with a couple of

12 the manufacturers like Dow and Owens Corning. 

13 And this is not a commercial because this

14 isn't commercially available. I'm not

15 plugging it, but this is -- the idea was that

16 we have two trusses in the industry that are

17 typical. One is a five and a half inch truss,

18 or the other one is a two and a half inch

19 truss. You were saying yesterday -- somebody

20 was saying yesterday that industry has been

21 moving towards more five and a half inch on

22 the heel.
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1 So this is the minimum depth that

2 -- over the exterior wall. And so what we

3 were trying to figure out is, how can we get

4 more R per inch at that point? My experience

5 in northern climates is that this is not just

6 an issue of energy efficiency. I can shoot

7 the house with an infrared camera and see that

8 heat loss significant at that bridging point.

9 But it also causes moisture

10 issues, like ice damming. I don't know how

11 prevalent that is in your experience, your

12 SAA. That's the -- SAA, for people who don't

13 know, that's the HUD consumer complaint

14 office. So they may have data on ice dams. 

15 But I know that manufacturers deal with that

16 in cold climates.

17 So as you improve the R value at

18 the eave, you reduce the potential for ice

19 damming and moisture problems. So when we

20 were talking about this wedge, everybody was

21 saying, heck, this thing might be more

22 beneficial to the industry in terms of
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1 callbacks in cold climates, as valuable as the

2 energy savings could do.

3 So basically what this is is just

4 a series of pieces of foam block, two-inch

5 foam block. I made it pink, and then I

6 covered it in blue, so Dow nor Owens Corning

7 would be upset about it. So the flash thing,

8 this is just to keep it -- hold it in place.

9 But basically what it would do is,

10 you know, you could have this extend out, and

11 so air comes up here and you have -- this ends

12 up being the baffle, so you're replacing the

13 labor associated with stapling up a baffle or

14 putting in a baffle for your insulation, your

15 loose fill, and it also provides you

16 significantly higher R per inch.

17 So I guess this gets back to new

18 technologies and solutions, and I'm not

19 suggesting this is on the shelf now and is

20 something that you can buy tomorrow. But as

21 we sat down and talked about solving the

22 problem with these manufacturers, they came up
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1 with some even lower cost spray foam

2 applications using a mold like this that you

3 could build in your factory yourself.

4 So I guess where I'm coming from

5 is I think that if we look a little bit

6 outside the box in problem-solving some of

7 these compression things, we might be able to

8 solve multiple problems and minimize both the

9 operating costs and the maintenance issues in

10 some of the colder climates.

11 So, anyway, if anybody is

12 interested, this is available to engage you in

13 discussions and figure out what kind of cost

14 point this would be and whether or not it's

15 realistic to expect it in the industry. I

16 like coming up with ideas, and I like the

17 industry to tell me to go jump in a lake if

18 they think it's something that isn't really

19 appropriate, because I respect you guys, and

20 I think you guys are very innovative in the

21 factory. And if there is a way to solve the

22 compression problem at the pooch or at the
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1 eave, you've got to -- I've got to come up

2 with a better word for that. What's the best

3 --

4 MEMBER TOMPOS: Belly.

5 MEMBER LUBLINER: At the belly,

6 from the I-joist to the rim. 

7 Anyway, that's the kind of things

8 -- there are products out there that are

9 higher R per inch that could be used to help

10 solve the problem, and that's what I meant,

11 really.

12 MEMBER LEVY: Okay. So did we

13 miss anything? And I added above -- Michael,

14 I tried to capture your comment about looking

15 also at the cathedrals in terms of what would

16 actually be built for those. So, and made

17 that our responsibility, to come up with a

18 series of solutions there.

19 So the INEL -- I don't think we

20 need to get into this, but the reason we're

21 identifying these is we would ask DOE to do

22 sensitivity analyses of these cases. I
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1 suspect we will have to dig deeper to specify

2 in what locations and what kind of building

3 configurations, but that would be the idea.

4 And then we'd look at the life

5 cycle cost impacts of these kinds of measures. 

6 Is everybody in agreement with that? Yes. 

7 good.

8 Okay. Other economic

9 considerations, did we miss anything? 

10 Excellent.

11 MR. RAMIREZ: Eric, do you want to

12 back up on that?

13 MEMBER LACEY: I just wanted to

14 add something and throw something in there. 

15 When you're talking about the economic

16 measures, there was an issue raised yesterday

17 about the expected lifetime of measures. And

18 I had mentioned that the National Association

19 of Home Builders put out a study of those

20 things, and I checked in with Don Surrena of

21 NAHB to make sure it was okay to circulate

22 this report and to see if we have the most
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1 recent version.

2 And would it be okay to give him

3 just a couple of minutes to talk about the

4 source of that study and how it can be used,

5 and so on?

6 MR. RAMIREZ: Don?

7 MR. SURRENA: Good morning. I'm

8 Don Surrena, National Association of Home

9 Builders. What we have is a study of life

10 expectancy of home components. It was done in

11 2007. The report was issued then. The

12 information came from 2006, 2005, so it is

13 slightly dated. Products have changed. 

14 Materials have changed. But the study was

15 done exclusively for stick-built housing. So

16 as you look at the products in here,

17 understand that they were anticipated to be in

18 a stick-built house. 

19 Additionally, you'll look at some

20 of the life spans, and they will be quite

21 long. Roofing materials, for example, 50 to

22 70 years. That's if you're using a slate roof
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1 or a tile roof. We differentiate asphalt

2 shingles and the different types of roofing

3 that there are, and the same with countertops

4 and other equipment.

5 So I have told Eric he would -- he

6 has the PDF, and I told him feel free to

7 distribute it. But I wanted you to understand

8 what the source of the report was for and that

9 it is rather dated. You know, we are looking

10 at revise it, but this is something that was

11 a major undertaking in these days, and our

12 staff has diminished by at least one-third

13 since then. It is time-consuming and

14 resource-engulfing.

15 So feel free to look at it. Take

16 it for what -- I don't want to say what it's

17 worth. It's worth quite a bit, and it is

18 helpful to get an understanding of how things,

19 in their most optimal condition, will perform. 

20 A lot of it has to do with maintenance and

21 what it is put on and what it is put into and

22 the clientele who have bought it. 
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1 So enjoy. Thank you for the time.

2 MR. RAMIREZ: Thank you, Don.

3 MEMBER LACEY: And I can circulate

4 that around.

5 MR. RAMIREZ: Yes. Thank you. If

6 you get it to me, I could send it out.

7 MR. SURRENA: And, excuse me,

8 there is a hard copy available if you'd like

9 to look at it.

10 MR. RAMIREZ: Okay. Thank you.

11 MEMBER LEVY: Anything else before

12 we move on? We have about 10 minutes left. 

13 I thought the time might be well spent if we

14 just talked about the other energy measures

15 that would be -- might be addressed included

16 in the standard and get to some agreement

17 about this. 

18 There is no -- I have put up four

19 items that might be subject to discussion. We

20 can add or subtract from this list. So these

21 are things that are not covered by the life

22 cycle cost analysis that could be included in
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1 the requirements.

2 MR. HAGERMAN: This is John

3 Hagerman, DOE. I think if you look at the

4 PNNL analysis, some of these additional energy

5 measures impact the annual energy use

6 considerably, like lighting is 10 to 20

7 percent or 10 to 15 percent. So I think not

8 including them would be a huge mistake.

9 MEMBER TOMPOS: Dave Tompos. 

10 Emanuel, why don't -- I'm sorry.

11 MR. BARBOUR: I just wanted to

12 clarify -- this is Ed Barbour, Navigant. 

13 Actually, all four of those are currently in

14 the PNNL result, if you look at them, both

15 whiting, hot water pipe insulation, SHGC, as

16 well as duct insulation.

17 MEMBER TOMPOS: Dave Tompos. Why

18 wouldn't we -- or is there a reason why we

19 can't include them in the life cycle cost

20 analysis? I mean, there is obviously a cost

21 associated with better glazing or the

22 insulation on the pipes. I mean, is that --
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1 MEMBER ROY: (Off-mic comment.)

2 MEMBER TOMPOS: Yes. That's my

3 concern is why --

4 MEMBER ROY: (Off-mic comment.)

5 THE COURT REPORTER: Sir, can you

6 turn on your microphone, please?

7 MR. RAMIREZ: That was Robin.

8 MEMBER ROY: I suggest we just

9 delete those last five words in the scope. 

10 This is Robin.

11 MR. RAMIREZ: Well, you know, if

12 you deleted one of the words, which completely

13 changes the meaning --

14 (Laughter)

15 So I'm guessing you're okay with

16 that, Robin, right?

17 MEMBER ROY: I'm going off the

18 distributed hard copy, not the thing which is

19 in process and changing on the screen.

20 MR. RAMIREZ: Yes. Okay. Eric,

21 you had something?

22 MEMBER LACEY: Yes. So the IECC
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1 has a number of mandatory provisions, and I'm

2 trying to put together a complete list of

3 everything that, you know, if you were

4 complying with the IECC, there is a list of,

5 you know, eight or ten things that you'd be

6 specifically required to do. And these are

7 some of them, and then I'm going to suggest

8 that maybe we take a look at that list, and if

9 there is anything that just doesn't apply, we

10 knock it out or -- but everything else, you

11 know, you include. 

12 And it sounds like they have

13 included it in the analysis, and that can be,

14 you know, a point of discussion. But, you

15 know, I am compiling that list right now, and

16 I think I've got most of them.

17 MR. RAMIREZ: Okay. Can you share

18 that with us once you do? Okay. Great. 

19 Thank you.

20 Michael?

21 MEMBER LUBLINER: Mike Lubliner. 

22 These may or may not be what the group wants
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1 to talk about, but I wanted to kind of -- the

2 kind of technologies that we are working with

3 in the industry, and haven't really gained a

4 lot of market perspective yet, but we are

5 moving in that direction.

6 But before I do, I want to make

7 sure that something I said yesterday about

8 proposals that I made to the Manufactured

9 Housing Consensus Committee five years ago

10 that were rejected because they believed that

11 this group was going to address them, and

12 those have to do with a requirement that gas

13 furnaces have -- be ENERGY STAR, and so a

14 condensing furnace.

15 Water heaters would have to be

16 ENERGY STAR, which might require heat pump

17 water heaters in warm climates. One inch or

18 foam sheathing on exterior walls, which is

19 something I know Emanuel is doing research for

20 Building America on, and so have we.

21 Heat recovery ventilation, ENERGY

22 STAR appliances, which was another one that
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1 was rejected, and specifically that would be

2 when a washer and dryer is offered that it be

3 ENERGY STAR, a dishwasher, which is typically

4 installed, and a refrigerator which is

5 typically sold, and exhaust fans, which are

6 also listed.

7 So assessing the ENERGY STAR

8 appliances would be another one that's good. 

9 And I think another one is some sort of a

10 credit or some sort of a benefit to

11 manufacturers who are taking steps to reduce

12 the heat loss associated with their thermal

13 distribution systems, their ductwork, or heat

14 gain.

15 So taking air conditioning ducts

16 out of a 140-degree attic with one inch of

17 insulation on them and moving them inside the

18 house would be I think a very cost effective

19 measure to look at. 

20 Now, we can talk about technical

21 feasibility and issues like that, but that

22 would be something. The other one that is
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1 typically done all the time is the elimination

2 of the crossover duct in the belly by using a

3 through-the-rim system.

4 It seems to me that manufacturers

5 that are employing different innovative

6 systems that reduce the thermal distribution

7 losses should be getting some sort of

8 acknowledgment in the code for those, and

9 there should be an incentive for them to look

10 at that.

11 Thank you.

12 MEMBER LEVY: Michael, I think I

13 might have missed one or two of your points.

14 MEMBER LUBLINER: Yes. Gas or

15 condensing gas furnace. I don't know if

16 that's -- oh, you've got that, required ENERGY

17 STAR. Yes. And these are only for products

18 that are shipped with the home. Oh, and last

19 but not least, there was one I didn't put in

20 there and that's -- but it could be under

21 this, and that would be mini-split heat pumps

22 and air conditioners, which we are now
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1 shipping with the homes right out of the

2 factory.

3 Thank you.

4 MR. RAMIREZ: Robin?

5 MEMBER ROY: I generally agree

6 with those additions. I would suggest making

7 it a bit more generic and having the ENERGY

8 STAR as examples, particularly on the heating

9 and cooling appliances. I mean, higher

10 efficiency heating equipment -- for example,

11 ENERGY STAR, condensing furnaces, ducted and

12 ductless heat pumps, just so it's not tied to

13 ENERGY STAR solely. 

14 Not to say we necessarily want to

15 do that, but it's worth understanding what we

16 are getting from a heat pump. I have heard

17 from Peter quite a bit the -- and others the

18 attraction of it. I'd love to see some

19 analysis of it and get some sense what the

20 cost is and how this might fit in the overall.

21 One thing that might be worth

22 adding also is flow management on hot water
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1 using devices. I don't know the extent to

2 which, for example, water sense fixtures are

3 used, you know, lower heating. I don't know

4 if that's -- is that something that we're

5 considering? Is that something that is

6 standard or used anywhere? If not, then it's

7 something we should think about -- lower water

8 use.

9 MR. RAMIREZ: Eric?

10 MEMBER LACEY: This is an issue

11 that probably deserves a little more

12 discussion. I think it would be great if we

13 could require more efficiency furnaces and air

14 conditioners and things like that. I'm not

15 sure if we can in this group, and I'm not sure

16 if we want to go down that path. I think

17 we'll hear from DOE General Counsel later, you

18 know, on whether that's a possibility.

19 I guess the issue I have is the,

20 you know, the term "credit," that's a

21 dangerous term because currently, you know, in

22 the 2009, 2012, 2015 IECC there was -- there
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1 is no credit, you know, against thermal

2 envelope components for these things.

3 Now, you know, in above code

4 programs you get extra points for these things

5 and credit, because they are not subject to

6 the same NAECA limitations that they mandatory

7 building codes are of the states. So, you

8 know, that is -- I think there is going to be

9 some discussion on that later, but that's the

10 one caution I would throw in here is if you

11 end up with a standard that awards a bunch of

12 credit for appliances that are already going

13 in, you may not come anywhere near the IECC in

14 terms of the efficiency of the unit. That's

15 my other caution there.

16 MEMBER LUBLINER: I agree. I

17 might have misspoke or -- the way it was

18 characterized here. When I was talking about

19 -- some incentive, whether that's a carrot or

20 a stick, to get ducts more efficient, and

21 that's the only one I was talking about, not

22 mini-splits or -- but mini-splits would be a
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1 separate thing.

2 And then, and I --

3 MR. RAMIREZ: So we need to change

4 number 8 from "credit" to "incentive"?

5 MEMBER LEVY: Yes. 

6 MEMBER ROY: This is Robin. I

7 think five and eight -- I think the rest --

8 all of them we're just talking about

9 evaluating and additional measures. We don't

10 have to say what form that evaluation or

11 recommendation comes.

12 MEMBER LUBLINER: Yes, exactly. 

13 This -- and then the mini-split would be under

14 HVAC, and it would be separate from the -- and

15 then the heat pump water heaters. I don't

16 know, is that up there? I just missed that. 

17 But that's an 800-pound gorilla.

18 And I totally agree that we should

19 wait for legal counsel to decide whether this

20 is applicable before we even waste our time on

21 it. this would lower priority to the bulk of

22 the effort, which is the envelope stuff we
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1 have been talking about. I wanted to put this

2 all in context. I don't want to sidestep us

3 into the nuances here of these emerging

4 technologies relative to the mission.

5 Thank you.

6 MEMBER ROY: Robin here. I just

7 wouldn't say that heat pump space heating is

8 an emerging technology so much. It's

9 demonstrated. And whether it's covered by the

10 Act and could be regulated by DOE here, it

11 would be good to get a sense sooner rather

12 than later. We can see that there's a problem

13 with it. I'm not sure we want to -- we want

14 to do it, but --

15 MR. HAGERMAN: Right. This is Joe

16 Hagerman, DOE. We know this is an important

17 topic. Kavita is going to come back at 10:30,

18 and we are going to talk about it or start the

19 discussion. And not to preempt what she is

20 going to say, but we are -- we'd very much

21 like to take receipt of any more material you

22 can provide us on the kind of arguments that
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1 you've made and your legal counsel has made.

2 MEMBER SCHNEIDER: Peter from

3 Efficiency Vermont.

4 MR. RAMIREZ: Go ahead, Peter.

5 MEMBER SCHNEIDER: I just -- yes. 

6 I just think that we -- I just don't want to

7 lose the concept of looking at this house and

8 what we're doing as a whole system. So to

9 eliminate any of these that we're talking

10 about, I appreciate that, you know, they may

11 -- it turns that they are not within our

12 scope. But when we talk about the thermal

13 envelope, just as an example, eliminating

14 ductwork, not only just bringing it inside the

15 envelope, which we can have discussions about

16 and I'm sure we will, but eliminating the

17 ductwork and taking advantage of new

18 technologies that eliminate ductwork, you

19 know, allows us to achieve the goals that we

20 are looking for with regards to R value,

21 improved air barrier durability, and so forth.

22 So, you know, each one of those, I
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1 could go down that list, and, you know, it's

2 part of the comprehensive system. And while

3 it may be defined here as an additional energy

4 measure, it certainly has an impact on all of

5 the other components that we are discussing

6 that are, you know, ultimately within our

7 scope clearly.

8 MR. RAMIREZ: Okay. Thank you.

9 MEMBER LEVY: I want some

10 recognition for finishing exactly at 10:00.

11 (Laughter.)

12 Just to make one other comment,

13 you know, this is fine to have a list. I

14 think we need to start fleshing out what we

15 mean by these things, so we have something to

16 talk about when we get back together again. 

17 I'm not sure what the process, Javier, would

18 be for moving that forward, for assigning

19 responsibilities, other than the things we

20 have already assigned out, but --

21 MR. RAMIREZ: Maybe you don't take

22 a seat yet, right? We could scroll back up to
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1 the top and make sure that we have either the

2 information or the proper assignments for the

3 items that are on there, then.

4 MS. HOFFMAN: And just one other

5 question. What about all of the other items

6 on the back of the term --

7 MEMBER LEVY: Yes. I think -- I

8 mean, just in consideration of timing, that --

9 and my plan was to come forward with more

10 detail on that, so we would have the same kind

11 of discussion in the subsequent meeting about

12 the other topic areas. I think we have a lot

13 to digest already.

14 MS. HOFFMAN: All right.

15 MR. HAGERMAN: Can I also make the

16 recommendation maybe that you go to the top of

17 the document, since this has been a document

18 that we have generated in real time or edited

19 in real time, and make sure it reflects

20 everybody's understanding? And make sure, in

21 particular, that the guiding principles I

22 think are taken out of this?
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1 MS. HOFFMAN: They can be put in

2 the parking lot? Or there was a discussion

3 about applying the law, the actual charter

4 that was given to the Committee. The other

5 thing is getting copies of this change for the

6 --

7 MR. RAMIREZ: Yes. We can do that

8 during the break.

9 MS. HOFFMAN: -- maybe during the

10 break, so you have the copy here. But perhaps

11 going over it now wouldn't be a bad idea, so

12 that the copies reflect what you have talked

13 about.

14 MR. RAMIREZ: Okay. Yes.

15 MEMBER WEISS: I think we all

16 recognize that that's a matter that we need to

17 deal with, the purchase versus life cycle. I

18 don't have a problem with parking lot that

19 stuff, you know, it's generic form.

20 MEMBER LEVY: So do we want to go

21 down through these specific items?

22 MR. RAMIREZ: Yes. On the top
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1 over there, Emanuel, if you wouldn't mind,

2 maybe just putting a strike through --

3 MEMBER LEVY: Why don't we change

4 places? Because you have --

5 (Pause.)

6 MR. RAMIREZ: Okay. So on the --

7 thank you, Emanuel. On the top there, guiding

8 principles, if we could just put a strike-thru

9 on the bullets there, and then right below it

10 we'll put a parking lot, right? Or a hold.

11 Okay. So starting off with the

12 thermal requirements, then, Emanuel, I'm going

13 to -- if it's all right, I'll defer to you to

14 walk us through it again just to make sure

15 that we have, you know, the information or the

16 proper assignments and then we'll note it on

17 here, what we need to do. Is that all right?

18 MEMBER LEVY: Yes. I think number

19 one here we already have. For the analysis

20 that the laboratory has already done, we have

21 a comprehensive list. That is our jump off

22 point for doing subsequent analysis.
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1 MR. RAMIREZ: Okay. Perfect.

2 MEMBER LEVY: Item number 2, we

3 have committed to do that. SPRA has committed

4 to provide that information. We provided a

5 sample table of what that might look like. 

6 That will be fleshed out -- specifically for

7 all of the thermal measures that are in one,

8 we will provide industry average costs,

9 including max/min values, and also some of the

10 unique construction variations on those, like

11 cathedral ceilings and the other items that

12 are captured below.

13 MR. RAMIREZ: So then you are

14 working on that right now?

15 MEMBER LEVY: We'll be working on

16 that over the next week or two.

17 MR. RAMIREZ: Okay.

18 MEMBER LEVY: And we'll provide

19 that back to the Committee, obviously, for

20 discussion and comment.

21 MR. RAMIREZ: Okay. 

22 MR. BANTLE: Just one thing. It
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1 says identify cases where reaching -- oops,

2 sorry. This is Ted Bantle. Reaching R values

3 create a -- was there supposed to be something

4 that was lost at the end of that sentence?

5 MEMBER LEVY: Might create a

6 barrier to the use. Yes, that's fine. I

7 think we have consensus that -- to use this

8 set of features. This is I believe what the

9 laboratory used as a typical set of baseline

10 features for the analysis. Obviously, we can

11 look at -- we will be looking at variations on

12 this, small homes, larger homes, those kinds

13 of things.

14 MR. RAMIREZ: Okay. So I want to

15 stress baseline, right? So -- because I think

16 the group always gets hung up that we are

17 talking about something that is inclusive,

18 right? That's all inclusive. 

19 So as a baseline, do we have

20 consensus on these characteristics as a

21 baseline? Michael?

22 MEMBER LUBLINER: Yes. I just had
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1 a question on the efficiencies on the

2 equipment. And I think -- I just want to get

3 a sense of how PNNL handled the thermal

4 distribution system, in other words, the heat

5 gain or loss from ductwork, either the

6 ductwork in the belly or the ductwork

7 underneath the home or the ductwork in the

8 attic. I need to understand what the

9 assumptions were there if we're going to do

10 assessments.

11 MEMBER LEVY: So there is two

12 additions here to the list. One is -- should

13 be under heating equipment -- or under the

14 equipment should be the ducts, the length of

15 the ducts and the insulation value in the

16 ducts, for exterior ducts.

17 MR. RAMIREZ: Length of duct? 

18 Length of --

19 MEMBER LEVY: Length and

20 insulation level of the exterior ducts.

21 MEMBER LUBLINER: It may be useful

22 to get just kind of the duct layout of the --
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1 you know, what is the duct system or a series

2 of them, so we know the surface area, and not

3 just the crossover but all the ducts.

4 The reason I think that might be

5 appropriate is, you know, if you've got a

6 bunch of -- most of your ductwork is the trunk

7 duct, say, in the belly, and you've got an R11

8 belly blanket down there. And then all of a

9 sudden you make an R33 and now those ducts are

10 in an R33. While those ducts are in the

11 buffered space, there is still a heat loss

12 implication benefit by further coupling that

13 ductwork to the house.

14 So my data need would be is to try

15 to have the duct system where -- you know, not

16 just the length but the -- just the system

17 design specified, or maybe we do three, maybe

18 we do one in the floor, one in the attic --

19 that is more typical -- and/or just those two

20 scenarios. But whatever you think is

21 representative of what the industry is doing.

22 MEMBER LEVY: Well, I think we are
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1 talking about these in the vein of, do they

2 affect -- do the values we are putting on this

3 table affect the result of the life cycle cost

4 analysis? And everything we have on the table

5 thus far does. 

6 The amount of insulation in the

7 floor vis-à-vis the internal ducts has no

8 impact on the LCC analysis. I mean, it's

9 interesting in terms of total energy use, but

10 it wouldn't be -- it wouldn't change anything

11 I guess is the point.

12 MEMBER LUBLINER: Yes. And I

13 guess I need to understand what PNNL did on

14 the modeling, so we can do that at a separate

15 --

16 MR. HAGERMAN: Let me just call a

17 timeout here real quick. So when this came up 

18 last -- yesterday I guess in our discussion,

19 I emailed PNNL to ask them to quickly compile

20 a document that explained all of their

21 assumptions, because some of the assumptions

22 were sort of buried in here or people had
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1 asked questions about it.

2 So they gave me a document late

3 last night to -- it was about 10 to 15 pages. 

4 I'm going through just to make sure, you know,

5 that it -- they explain things right. I'll

6 try to turn that around, you know, by the

7 weekend, end of the weekend for the whole

8 group. And that should answer a lot of these

9 questions, right? Or, you know, you can flag

10 other things that need to be changed.

11 MR. RAMIREZ: So then at the

12 bottom of this one we'll just put on here PNNL

13 is to provide assumptions.

14 MEMBER SCHNEIDER: This is Peter. 

15 I was just going to add, I mean, just like you

16 have efficiency ratings on the furnace, you

17 know, I like to think of, you know, the duct

18 leakage assumption as an efficiency rating on

19 the duct system. So I would have a line item

20 there just so it's out in the open that we're

21 talking about duct leakage level, you know, on

22 a CSM for 100 square feet. That would go the
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1 same for the air infiltration assumption.

2 MR. RAMIREZ: Okay. Peter, you're

3 going to have to help us out here. How do we

4 capture that?

5 MEMBER LEVY: Well, I think

6 there's a bigger issue here, and I think that

7 will be addressed by what Joe just said,

8 because it's not just assumptions and

9 leakages; it's assumptions about internal

10 loads. There's a whole variety of things that

11 go into the analysis that may or may not make

12 a difference, by the way, in terms of what we

13 are looking at but are important to

14 understand.

15 MR. RAMIREZ: Peter, so are you

16 okay with that? Let's get that assumptions

17 document and then see if you need further

18 information.

19 MEMBER SCHNEIDER: Yes, that's

20 fine.

21 MEMBER LEVY: Missing from this

22 list is, however, the heat pump efficiency
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1 assumptions.

2 MEMBER SCHNEIDER: Right. And I

3 didn't see in the modeling -- and maybe that

4 was noted -- but where the heat pumps -- I'm

5 assuming those were ducted heat pumps in the

6 modeling assumption, and, you know, could we

7 go ductless. And I hate to beat that horse,

8 but I just wanted to get clarification on

9 that.

10 MR. RAMIREZ: All right. So,

11 then, does number 3 look okay like that? Let

12 me see a show of thumbs I guess if we're okay

13 with number -- with the table here.

14 MS. HOFFMAN: By the way, Manny,

15 am I blocking your --

16 MEMBER SANTANA: Not at all.

17 MS. HOFFMAN: Okay.

18 MR. RAMIREZ: Yes. So show of

19 thumbs? Good. All right. So we're good on

20 number 3.

21 Number 4. What do we need here? 

22 This is one of the elephants?
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1 MEMBER LEVY: This is the one that

2 didn't want to go away.

3 MR. RAMIREZ: Yes. So where do we

4 go? Life cycle cost.

5 MEMBER WEISS: Didn't Eric make a

6 suggestion, motion, whatever, that we consider

7 both periods, seven years and the 30?

8 MR. RAMIREZ: Okay. So let me ask

9 the group -- oh, Michael?

10 MEMBER LUBLINER: If we're going

11 to consider the seven-year period -- and I

12 don't want to beat this one to death -- I'd

13 like to get the reference research, the peer

14 review research that justifies why we are

15 using seven years for the factory built

16 housing industry. It seems like -- you know,

17 so if that's available and referenceable, or

18 if somebody can inform me of this reference,

19 thank you.

20 MR. RAMIREZ: Okay.

21 MEMBER LEVY: There might be a

22 reference, and I believe there is, but by the
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1 same token we have to put the same burden on

2 the 30 year. I mean, if you pick a number,

3 you've got to defend it.

4 MEMBER LUBLINER: I could provide

5 references for the 30 year, and I think

6 they're yours. You guys did studies that

7 looked at the life of manufactured homes. 

8 When you compared them to site built homes, I

9 was thinking that would be a good reference

10 for the 30. But my discussion is having to do

11 with the seven, my concerns on the seven. We

12 can talk about the 30, it's totally legitimate

13 we need to have. If people are uncomfortable

14 with the 30, then we need to document that

15 that's acceptable as well.

16 MR. RAMIREZ: Okay. So then the

17 reference documentation for both seven and 30,

18 who is going to get those?

19 MEMBER EPPERSON: Stay, Next Step. 

20 So this may be a clarification question. How

21 the seven was originally picked -- I know that

22 is also the average time the buyer is in the
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1 home, first time buyer. Is that where that

2 seven came from? Okay. And we do have

3 document -- we can get documentation to that

4 at the Committee level. 

5 (Off mic comment.)

6 MEMBER EPPERSON: Well it's a lone

7 data study, as -- it would be, you know, the

8 cycle for the buyer being in the home before

9 it's sold, but that's where we would be --

10 just HUD code, yes.

11 MR. RAMIREZ: Okay. So for the

12 seven year we'll put the Finance Committee --

13 we'll get that. How about the 30 year? Luby,

14 is that something that you could provide?

15 MEMBER LUBLINER: This is Mike

16 Lubliner. It might be easier -- because I

17 think it was work that MHI did that looked at

18 the -- compared a site built home to a HUD

19 code manufactured home, and it looked at life

20 expectancy and stuff. And I think that's

21 where I -- and I thought it was actually

22 longer than 30.
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1 MEMBER LEVY: This is Emanuel. 

2 The Meeks study suggested that the lifetime in

3 the home on average is something like 57

4 years. But we shouldn't conflate lifetime of

5 home with the period for doing the life cycle

6 cost analysis. They are really two different

7 items in my mind.

8 And we are -- and I think the

9 reason we are grappling with this is this is

10 as much a philosophical issue as anything

11 else. And as I tried to characterize

12 yesterday, it is the difference between

13 thinking about the perspective of the first

14 time home buyer and the person who is actually

15 making an investment versus the -- all of the

16 homeowners that -- over some period of time.

17 And so it's not as easy as just

18 providing documentation. I think there is a

19 philosophical discussion that needs to be a

20 matter of principal consensus here.

21 MR. RAMIREZ: Right. And I think

22 at some point we're going to have to nail it
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1 down, right? But as far as just to -- both

2 sides are asking for reference documents for

3 the seven and the 30. Seven, the Finance

4 Committee is going to be assembling that, but

5 we need to find out who is going to get at

6 least the initial documentation, right, for

7 the 30-year cycle.

8 MEMBER LEVY: So I would -- if it

9 isn't the life of the home, let's not call it

10 the life of the home here in the table. Right

11 now it says life of the home. It shouldn't be

12 called that if what you said is true.

13 So I think it's important that we

14 talk about the period of the analysis. As I

15 said, the 50-something years doesn't really

16 matter. When you do the life cycle cost

17 analysis, if you use any kind of reasonable

18 discount rate, you're going to find that

19 anything that happens after the 30th year is

20 in the rounding error. So it's really not

21 going to matter.

22 So I'm fine with the 30, and I
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1 think the documentation that we discussed

2 supports that. 

3 MEMBER ROY: This is Robin. I

4 have a slightly different take. Instead of

5 saying either the seven or 30 as the concrete

6 bids, which I think we can come to an answer

7 on, we should say that the periods of

8 analysis, both of which are interesting and

9 relevant to our consideration, are the tenure

10 of the initial buyer, and then parenthetically

11 seven with a question mark, because we want to

12 get some more thoughts on that. But what

13 we're interested in there is the tenure of

14 that first buyer. 

15 And the second one is the life of

16 the home, and parenthetically 30 years, don't

17 know. That's what we're actually interested

18 in. These are the two different perspectives. 

19 Well, how is this product going to perform

20 over its existence, and how is that first

21 buyer going to come out? Those are very

22 interesting facts.
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1 And then it changes everything,

2 and I think it's actually worth saying under

3 A, two cases, both of which are relevant to

4 our considerations, or our deliberations.

5 MS. HOFFMAN: And that this

6 Committee would like analysis on both, is what

7 I heard. Is that correct?

8 MR. RAMIREZ: Yes. And the only

9 -- what we're trying to do here now is assign

10 who is -- we are asking for information. We

11 don't want to just leave it floating out

12 there, right? We want to nail it down as far

13 as who is going to be getting it. So we still

14 need who is going to get that 30-year

15 information analysis. Is it something that

16 you could provide?

17 MEMBER LEVY: Emanuel. I think we

18 are talking about the Meeks study, and I -- I

19 believe DOE might have that already. If they

20 don't, we can get that.

21 MR. RAMIREZ: Meeks, M-E-E-K-S?

22 MEMBER LEVY: That's correct. Dr.
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1 Carol Meeks.

2 MR. RAMIREZ: Go ahead, Manny.

3 MEMBER SANTANA: Manny with Cavco. 

4 You know, if -- my understanding was that the

5 importance of this was how it affected

6 purchase price, operating costs. So, then,

7 why are we considering the life of the home

8 over a 30-year span at all? You know, why not

9 just consider the tenure of the initial buyer?

10 You know, we can see the reasoning

11 for why that's important, right? Because that

12 affects somebody getting into the house and

13 operating the house and not, you know, going

14 upside down in the house or defaulting on the

15 loan because they can't handle the energy

16 costs. I mean, I don't see how the tenure of

17 the life of the home is as relevant.

18 MR. RAMIREZ: Eric?

19 MEMBER LACEY: Yes. This is Eric

20 Lacey. I just want to maybe try to clarify

21 that, why this number might be important. The

22 seven-year number or whatever that number is
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1 for how long the first purchaser is going to

2 be in there might be relevant to the purchase

3 price impact, because that is -- you know, you

4 need to look at the way it's financed and the

5 impact that might have that on first number,

6 you know, when there is a closing. 

7 But the house isn't -- I'm

8 guessing the house probably isn't paid off in

9 seven years completely, and so the benefits of

10 an energy efficiency improvement don't go away

11 after seven years. They are actually -- they

12 actually come every month, you know, you have

13 energy efficiency benefits in terms of a lower

14 energy bill, and you may have a higher

15 mortgage payment because of those upgrades.

16 And so the balance is you want to

17 make sure that you are money ahead, really,

18 that you are getting more -- you are getting

19 some benefits from energy efficiency and that

20 it's, you know, outweighing the mortgage

21 costs. And I think the life cycle analysis

22 will do a better job of that because it
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1 understands that you won't pay it all off, the

2 first buyer won't just pay it off in seven

3 years and get all of the energy efficiency

4 benefits. 

5 They are getting a month to month

6 benefit, along with a month to month kind of

7 charge. And the only way to really

8 effectively address that is through an

9 analysis that looks at, you know, some period. 

10 And it's typically 30 years, and maybe it's

11 different for that -- for manufactured

12 housing, but it's -- you know, most houses are

13 going to be around for longer than 30 years,

14 and a lot of those benefits, the insulation,

15 for example, is going to give you a benefit

16 for 70 or 100 years. But I think that's why

17 maybe two numbers are different for two

18 different --

19 MEMBER SANTANA: So in response to

20 that, I understand everything that Eric said,

21 and so I'm thinking that the 30 years --

22 there's a reason why 30 years is such a widely
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1 used metric, and because that's the typical

2 life of a conventional loan, you know, and so

3 I -- I think Eric brings up a good point, that

4 -- so not only should we consider the tenure

5 of the initial buyer, but the tenure of the

6 life of the home should be more akin to the

7 tenure of the life of the loan, of a typical

8 manufactured housing loan.

9 You know, if the 30 years is

10 typically used because it's associated with a

11 conventional loan, then we should use a span

12 that is typical of a manufactured housing

13 loan.

14 MR. RAMIREZ: So then what -- if I

15 understand you correctly, what you're saying,

16 then, is that we would have to add a third one

17 up there somewhere, because the conventional

18 --

19 MEMBER SANTANA: Because if

20 conventional loans aren't typical for

21 manufactured housing, then that's a metric

22 that is not suitable for manufactured housing. 
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1 I think we use the terms that are typical for

2 manufactured housing. I don't know what those

3 are. It could be 20 years. It could be 30

4 years. I'm not sure, but I doubt it.

5 MR. RAMIREZ: And correct me if

6 I'm wrong, I don't know if this group is

7 prepared to ultimately decide on what that

8 life cycle year is, right? And so right now

9 we are just trying to gather information. We

10 will figure out the periods that we need to

11 analyze for the savings.

12 And so we had the seven and the 30

13 year. So if I heard you correctly, what

14 you're saying, but let's just do a -- what is

15 a life cycle cost? We have to see what that

16 -- or, I'm sorry, what the average mortgage

17 is, but we don't know -- I think we have an

18 idea, but we haven't seen any data on that, of

19 what that average is.

20 So, for these purposes, to gather

21 data, do we need to add a middle one in there

22 for the average loan?
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1 MEMBER SANTANA: Right. I don't

2 think we have to add an extra one. I think we

3 are talking about the same one, which would

4 replace the tenure of the life of the home. 

5 The tenure of the life of the home should be

6 a span of time, right, which is past the

7 initial buyer, right, but it shouldn't be past

8 what the loan is or the terms of the original

9 loan is.

10 MEMBER ROY: This is Robin. 

11 Actually, I think it needs to go for the life

12 of the home. I'm interested in seeing what

13 the benefits of the energy measures that we

14 are contemplating there are for all the folks

15 who are going to have the benefit of living in

16 that home for the time that it's standing and

17 working. That's what is really interesting to

18 me.

19 I mean, I take your point that

20 it's something also interesting about a

21 mortgage. I'm not really sure what's

22 interesting about that mortgage, but --
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1 MEMBER SANTANA: You know, one

2 thing that's interesting, I don't think it's

3 as relevant to the discussions as they pertain

4 to how energy increases affect the cost of the

5 home. I mean, it's interesting. We want to

6 see how it performs, and the better that it

7 performs over the course of its entire life,

8 the structure is standing, we want that to be

9 as best as they can. But as it applies to the

10 consumer, and us taking measures that are

11 going to increase costs to the consumer, it

12 has to be tied back to that. So --

13 MR. RAMIREZ: Let's go to Mark,

14 Stacy, then Michael.

15 MEMBER WEISS: Yes. I agree with

16 Manny's reasoning. At a minimum, I think we

17 should put the average life span of a loan as

18 one of the parameters to be looked at and to

19 gather data for. So, at a minimum, I would

20 include that. Whether or not we strike off 30

21 years is another matter.

22 One other point -- and, again, I
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1 step outside of my field with trepidation, but

2 if you're going to look at a 30-year span,

3 shouldn't those numbers also -- and I don't

4 know to formulate this correctly maybe, but

5 shouldn't that span be discounted in some

6 fashion based on the number of people you are

7 potentially excluding from the market and the

8 contraction of the overall utilization of

9 manufactured housing as a result of purchase

10 price increases? Isn't there some discount

11 factor that should be applied to that?

12 MR. RAMIREZ: Michael?

13 MEMBER LUBLINER: So to answer

14 Mark's question, from my understanding is we

15 are talking about two separate analyses. This

16 is what Robin was trying to explain to Manny,

17 and we keep jumping back. We keep having this

18 cycle thing over and over. You guys keep

19 saying it's -- yes, we'll address that, but

20 that can't be addressed in the life cycle cost

21 analysis. We'll address that -- once we

22 figure out what the bar is, how many people
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1 can no longer afford that, but we have to do

2 these independent. I don't know of a way you

3 can do what you want.

4 Also, I want to get back to the

5 issue. If you talk to an economics professor,

6 or anybody, this thing is going to get public. 

7 It is going to go public. People are going to

8 see it. You're going to have to justify that

9 your economics approach is correct. In other

10 words, it accounts for all of the benefits of

11 the energy savings package over the life of

12 the home.

13 Life cycle costing does that, and

14 it's typically based on the life of the home,

15 not the life of the mortgage. So you're going

16 to have to be able to justify to the

17 economists that are going to be reviewing this

18 that. Now, I don't know. I'm not an

19 economist, but I do think that there will be

20 a lot of criticism if we try to integrate

21 these two processes of the people that can't

22 afford it any longer from setting the bar, and
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1 I also think there would be a significant

2 amount of back-push if we get into a situation

3 where we are trying to justify doing a period

4 of analysis that doesn't consider all of the

5 energy benefits that are being purchased by

6 the consumer.

7 MR. RAMIREZ: Let me jump in, just

8 because I -- again, we're not going to resolve

9 this number today. And I understand the

10 importance, right? This is one of the bigger

11 issues that we are going to have to deal with.

12 I don't want to take up a bunch of

13 time discussing the merits of it today, just

14 because I don't think we have the information

15 that we need in order to truly do that, right? 

16 But as far as to move forward, what do you

17 think of not eliminating anything, but adding

18 that middle one in there? And I guess before

19 I fully commit, Joe, is that going to be -- is

20 that -- am I throwing out a bunch of

21 additional work here by adding a middle one in

22 there?
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1 MS. HOFFMAN: And I guess I would

2 ask, Stacy, is that a number that is

3 verifiable and useable?

4 MEMBER EPPERSON: Yes. That's a

5 number that's verifiable. You know, you're

6 going to have two different loan types,

7 though, so are we asking an average of the

8 two. Very different loan products -- chattel

9 and real estate.

10 (Off mic comment.)

11 MEMBER EPPERSON: Except it's a

12 much shorter term. So there is a little bit

13 of complexity with it, but I'm sure our

14 Committee can do it.

15 MR. RAMIREZ: Yes. And we'll just

16 need some rationale for how you came up with

17 that average, right? 

18 Emanuel?

19 MEMBER LEVY: Yes. There's one

20 piece of information we're missing here that

21 falls into lap I think, Stacy, and which makes

22 the seven year and the tenure of the home --
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1 the tenure of the home buyer and the tenure of

2 the home much different, and that is the

3 assumption about what is recaptured in terms

4 of -- at the end of the power of ownership of

5 the cost of the measures.

6 So if the additional measures that

7 we are talking about cost $5,000 more, and the

8 homeowner is not able to get some residual

9 value from those, and loses that entire value,

10 they face a significant economic impact of

11 that. So whether you determine -- whether

12 they get zero value back, 50 percent, or 100

13 percent, it makes a huge difference in terms

14 of what the difference will be between the

15 number 1 there and number 3. So that's also

16 in your wheelhouse.

17 MEMBER EPPERSON: May I?

18 MR. RAMIREZ: Yes.

19 MEMBER EPPERSON: Just so I'm

20 clear, you know, the tenure of the initial

21 buyer, that loan ends there, right, in terms

22 of that first loan. So that's how we get to
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1 seven years, okay? That loan paid off. Now

2 you're asking us for tenure of the average

3 loan. I'm not sure that tells us anything, so

4 I'm asking -- I want to be enlightened here,

5 because, you know, the tenure of the average

6 loan length, isn't that seven years, what I

7 just said, if that loan pays off? Or do you

8 want the initial loan that doesn't really, in

9 my mind, tell us anything because it's

10 probably an average, I'll guess -- appease me

11 here -- of 12 years. Okay?

12 Well, that's when you go into the

13 deal with a 12-year loan. You may not stay

14 there, so just clarification on what you're

15 after.

16 MR. RAMIREZ: Okay. Robin?

17 MEMBER ROY: Hi. Robin. I'm

18 after a couple of things. But, first, to

19 reinforce what Emanuel just said, I think it

20 is very interesting. If there is no recovery

21 of some of the additional cost upon sale,

22 that's worth noting. And then, all of that
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1 additional cost that we were concerned about

2 making something less affordable is making --

3 is really not being mitigated by anything. 

4 But to the extent it is being mitigated by a

5 higher resale value, that's interesting. 

6 We are kind of assuming it's about

7 a zero, so it would be interesting to see if

8 it's a non-zero number, because that's a

9 different way to recapture some of that

10 savings, for those that haven't been excluded

11 from being able to buy in the first place. 

12 So that's a very interesting one. 

13 I think that's a tremendously important point. 

14 Is there any recapture of higher cost upon

15 sale from that first buyer?

16 On the second point, I'm not

17 really looking for the average loan length. 

18 I appreciate Manny's interest in it. I don't

19 feel that same interest. I'm very interested

20 in what that first buyer is going to have to

21 face, and I'm very interested in what, very

22 broadly, society, all the folks that will own
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1 that house will be facing, what they will be

2 paying and what they will be receiving back

3 from it. 

4 So I like the "too" on the end. 

5 It's very informative.

6 MEMBER EPPERSON: I concur with

7 you, Robin, exactly where you are, and

8 Emanuel, too.

9 MR. RAMIREZ: Okay. Did you have

10 anything else, Emanuel?

11 MS. HOFFMAN: So just so I know,

12 are we back to the two measures at this point? 

13 No. Okay. We're still looking at a potential

14 middle third. Okay. Just want to check. All

15 right.

16 MR. BANTLE: Just process stuff. 

17 We still haven't answered I think clearly. We

18 have the Meeks study for the 30-year period. 

19 Who will be providing that?

20 MR. RAMIREZ: Oh. Emanuel.

21 MR. BANTLE: Okay.

22 MS. HOFFMAN: I wanted to just
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1 raise something that was handed to me from

2 Scott Drake, one of our members. He said --

3 this is on this topic -- "We use 20 years for

4 stick-built homes when determining the rebates

5 we pay. Thirty years gets too long for good

6 assumptions. Seven leaves too much energy

7 savings out of the calculation." So he has

8 now put 20 years into the mix, so we have it. 

9 Is Scott available to elaborate? 

10 Scott? Oh, he's -- okay. So we know there

11 are other numbers here.

12 MR. RAMIREZ: Michael?

13 MEMBER LUBLINER: Yes. I just

14 want to seek clarification from Scott that the

15 use of the 20 years is for looking at consumer

16 cost effectiveness or for the utility cost

17 effectiveness of their incentives. I don't

18 want to --

19 MS. HOFFMAN: Okay.

20 MEMBER LUBLINER: -- because they

21 are two separate economic analyses, and I

22 wasn't clear from that wording which one it
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1 was.

2 MR. RAMIREZ: Well, we'll see if

3 he gives a response to that. In the meantime,

4 Robin?

5 MEMBER ROY: Different topic. 

6 Explain up at the top under the scope, item 1

7 -- sorry I didn't bring it up a while ago. I

8 stepped out. Is it too late to bring that up?

9 MR. RAMIREZ: Well, under scope,

10 we just tabled -- we just --

11 MEMBER ROY: No, not the guiding

12 principles.

13 MR. RAMIREZ: Oh.

14 MS. HOFFMAN: Excuse me just one

15 sec. Scott said "both." The answer to your

16 question was both, for both purposes. Okay. 

17 Sorry.

18 MEMBER ROY: Because their

19 consumers are their owners, co-ops, very

20 interesting structures. I just want to make

21 sure that we are not with any of this language

22 inadvertently foreclosing the expression of
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1 our interest in looking at the U factor and UA

2 approaches to setting up a standard by only

3 mentioning Uo in this document. I think the

4 -- well, it just is such a fundamental

5 statement at the beginning. I just don't want

6 to have it missed, if we really do think that

7 this might be a useful thing for the industry

8 to go with.

9 MR. HAGERMAN: Do you want to put

10 in there more explicitly multiple compliance

11 paths?

12 MEMBER ROY: Well, I'm also -- I

13 just want to have some language. I'm not sure

14 what the language is. I don't want to

15 complicate what you're doing. I understand

16 why the Uo is a very interesting thing to have

17 here, but just -- I'm not sure what the

18 language is, but something has to be there. 

19 I would be specifically referencing the UA and

20 U factor -- I would specifically reference the

21 UA and U factor approaches in the IECC 2015.

22 MR. RAMIREZ: The Uo and --
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1 MEMBER ROY: UA.

2 MR. RAMIREZ: -- UA --

3 MEMBER ROY: And U factor.

4 MEMBER TOMPOS: Dave Tompos. I

5 don't know if we want to limit it to those,

6 just those. I like leaving it open to any,

7 you know, performance path or whatever we

8 decide is -- I want to make sure the

9 manufacturers have all the options.

10 MEMBER ROY: I agree. I'm happy

11 with that, too. As long as it's --

12 MEMBER TOMPOS: So I don't know if

13 we just go back to what -- do we just cross

14 that out and put allowable thermal

15 requirements, is that --

16 MR. HAGERMAN: Right. With

17 multiple -- with potentially multiple

18 compliance paths.

19 MEMBER TOMPOS: There you go. I

20 think that sounds great.

21 MR. BANTLE: Allow thermal

22 requirements, and then add that language? 
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1 MR. RAMIREZ: Does that look

2 better to everyone? Okay.

3 MR. BANTLE: Just one question. 

4 This is Ted. We had done kind of a mini

5 consensus check, I believe on this Section 1,

6 and on the chart. Is that correct? I believe

7 we did that today?

8 MR. RAMIREZ: Yes.

9 MR. BANTLE: Is it all right if I

10 put consensus and then today's date in the

11 red, just so we have that? Because I saw we

12 have consensus in other parts of this

13 document.

14 MR. RAMIREZ: Yes. I think

15 Emanuel was putting it in there just to --

16 just as a reminder to check to make sure that

17 we have consensus.

18 MR. HAGERMAN: Just another

19 reminder, you're going to get a Word document

20 that has all of those assumptions detailed

21 out, so I would wait before you agree to that,

22 until you read this document.
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1 MR. BANTLE: Okay.

2 MR. RAMIREZ: Yes. And so I guess

3 the consensus that we're talking about right

4 now is just that, yes, this is okay, to gather

5 that information and move forward in this

6 format. Right.

7 MR. BANTLE: So should I leave the

8 red consensus in there that we had -- that

9 we've had in since the beginning? Or is that

10 somewhat confusing?

11 MR. RAMIREZ: Yes. I think those

12 are just markers that Emanuel put in there

13 just to make sure that we do get it

14 eventually.

15 MR. BANTLE: Okay. And one last

16 note, I added -- on our second bullet point I

17 added -- I believe the Finance Committee was

18 going to get that length as well, on average

19 length of loan, so I added that in.

20 MR. RAMIREZ: Okay. Perfect. 

21 Thank you.

22 Yes, Eric?
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1 MEMBER LACEY: This is Eric. One

2 more issue that I just wanted to mention

3 before we left the thermal requirements. I'm

4 assuming that thermal requirements includes

5 not just the U factors but also the SHGC. I

6 just don't want that -- I don't want that to

7 get dropped off unintentionally. And since

8 you took out Uo value, maybe that's, you know,

9 not a big deal.

10 MR. RAMIREZ: So allowing multiple

11 compliance paths, would that cover that?

12 MEMBER LACEY: Yes. It's the

13 term, you know, maximum allowable thermal

14 requirements. I guess for the sake of -- you

15 know, so that the analysts don't leave this

16 out, but I want to make sure that it's not

17 just the U factors, but also the SHGC.

18 MR. RAMIREZ: Want to put in

19 parentheses right there "including SHGC"?

20 MEMBER LACEY: Sure. Including

21 SHGC, I think would -- does that work for --

22 MEMBER SANTANA: You know, I think
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1 it's all inclusive. I think that's all

2 inclusive. We would have SHGC under

3 Section 3.

4 MR. RAMIREZ: Okay with that? 

5 Okay. Robin, did you have anything

6 additional? Okay.

7 Okay. B?

8 MEMBER EZZO: This is Mark Ezzo. 

9 Can I make a comment about the scope back up

10 there under thermal requirements? Just for

11 clarification. The numbers that are in the

12 PNNL tables, the U value numbers and the

13 insulation numbers, and all of the thermal

14 criteria, we are going to use those for this

15 analysis. Is that correct?

16 MR. RAMIREZ: Yes.

17 MEMBER EZZO: Okay. So you might

18 want to say up there in scope that, you know,

19 it is going to be based on the IECC 2015. 

20 Maybe you put slash PNNL just so we're clear

21 that we're not going out of the raw data that

22 is in the actual code. Am I saying that
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1 right? 

2 I mean, there are things in the

3 PNNL tables that are different than what is in

4 the prescriptive IECC.

5 MR. RAMIREZ: Is under covered

6 under number 1?

7 MEMBER EZZO: Yes. As long as --

8 yes, okay, I see it now. So, okay.

9 MR. RAMIREZ: Okay. Great. Thank

10 you.

11 MR. HAGERMAN: As long as it's

12 explicit, I think is his point.

13 MR. RAMIREZ: Does that capture

14 it, under number 1, though? Is that explicit

15 enough?

16 MR. HAGERMAN: The members will

17 have to decide. It is for me, but --

18 MR. RAMIREZ: Yes, but --

19 MS. HOFFMAN: We should ask, is it

20 explicit enough for the members of the

21 Committee?

22 MR. RAMIREZ: Show of thumbs here.
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1 MS. HOFFMAN: Okay.

2 MR. RAMIREZ: All right. I didn't

3 see any thumbs down, so we're -- we're moving.

4 Okay. B, C, D, E, and F, is that

5 accurate, will be from the Finance Committee? 

6 All right. Is there anything that's needed on

7 G?

8 MEMBER ROY: This is Robin. I

9 think the Finance Committee has another brief

10 now also, and that's to take an estimate of

11 the recapture or the higher value upon resale. 

12 Is that up there somewhere?

13 MR. RAMIREZ: Let's add a --

14 MS. HOFFMAN: And on the discount

15 rate, John Caskey -- oh. On the discount rate

16 -- this is Eileen Hoffman -- John Caskey

17 mentioned yesterday about an OMB Circular with

18 seven percent discount. So maybe you want to

19 include John on your committee.

20 MR. BANTLE: Are we okay adding

21 this as --

22 MR. RAMIREZ: And, Robin, could
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1 you restate it, so it's a recapture of --

2 MEMBER ROY: Impact on resale

3 price of energy efficiency measures -- of

4 energy efficiency characteristics.

5 MEMBER WEISS: Question for

6 Emanuel. Is that too narrow? Should it be --

7 should it be resale/recap? Something like

8 resale/recapture, phrased that way?

9 MEMBER LEVY: Yes. As a practical

10 matter, we need a percentage of the cost

11 that's recaptured at sale.

12 MR. RAMIREZ: Yes. Stacy?

13 MEMBER EPPERSON: So I just asked

14 Mike if he's got data. He does. Emanuel, do

15 you also have any -- do you have data around

16 this issue at all? Is there research you know

17 of?

18 MEMBER LEVY: It's -- what we know

19 is very anecdotal.

20 MEMBER EPPERSON: That's what I

21 thought. Okay.

22 MEMBER LUTER: This is Rob. Are
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1 we not trying to recapture the investment as

2 opposed to the characteristics, investment in

3 energy efficiency characteristics?

4 MEMBER LEVY: Yes. The investment

5 will come out of the analysis. That will be

6 determined by what is shown to be cost

7 effective. That -- the cost difference

8 between that and the HUD code or whatever our

9 baseline is, that cost difference is what

10 we're looking at recapturing the value of at

11 resale.

12 MEMBER LUTER: Understood. I was

13 just addressing the grammatical issues of the

14 sentence here.

15 MR. RAMIREZ: How would you like

16 to see it changed?

17 MEMBER LUTER: It has been

18 changed. It looks fine now.

19 MR. RAMIREZ: Okay. 

20 MEMBER LEVY: Just as a point of

21 clarification, I think what Robin mentioned

22 earlier was the idea that we -- our starting
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1 position on this is that it's a zero

2 recapture, and we might do a sensitivity study

3 to other recapture rates, just as a point of

4 information. But I don't see any reason not

5 to start with a zero assumption. Robin?

6 MEMBER ROY: If we don't have a

7 basis for a non-zero number, then let's use a

8 non-zero number. If you have some good ideas

9 on a different number, that's fine, too.

10 MEMBER LUBLINER: I don't want to

11 be committed to -- I want you guys to take the

12 NADA software and put in the energy efficiency

13 improvements for a chattel loan and figure out

14 what the recovery is. That's the only data we

15 have, and that's not zero. It's not even

16 close to zero. 

17 MEMBER ROY: This is Robin. I'm

18 happy to run that up.

19 MEMBER LUBLINER: What's that?

20 MEMBER ROY: That sounds fine.

21 MEMBER LUBLINER: Yes. So what I

22 -- instead of putting Lubliner there, could
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1 you put NADA, and you guys can buy the

2 software and do the analysis. I think it's

3 $200, and you probably have that software

4 already. If you're in the industry, I imagine

5 you have it, so -- anyway, if you don't, I

6 could certainly directly you to it.

7 I can't do it -- the work with my

8 personal license copy of the software, nor do

9 I want to commit to do that, because I have

10 other things that I'll be doing on the

11 committee. So I -- but if -- this is a

12 slippery slope, and this is why I have some

13 concern about why we're doing a seven-year

14 analysis. But if you are, it's GIGO, garbage

15 in equals garbage out. 

16 And the garbage that I'm worried

17 about going in is an assumption that you buy

18 a home for a thousand, say, dollars more, and

19 in seven years there is no value, and you take

20 a homeowner and go out to the lot and this

21 home has ENERGY STAR windows and this home

22 doesn't, this home has two by six walls, this
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1 home doesn't, with -- this home has R38, and

2 you're going to tell me that the value of that

3 is zero to the next buyer? I mean, that just

4 doesn't jibe with any economic model I know

5 of.

6 So if you have data to support

7 that, that's great. But my preference is not

8 to go down that path. But if we're going to

9 go down that path, we should at least attempt

10 to use what is out there in your industry,

11 which is the NADA stuff.

12 MS. HOFFMAN: What I'm hearing --

13 this is Eileen -- is, Robin, are you

14 volunteering to do that analysis?

15 MEMBER ROY: I'm volunteering to

16 go down that path and see what we can acquire

17 from the reasonable cost.

18 MS. HOFFMAN: Okay. So why don't

19 we put Robin down and move on, if that's all

20 right with the group.

21 MEMBER EPPERSON: I would like to

22 make one comment, though. NADA is not the
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1 only way value is determined in the

2 marketplace. In fact, Next Step does not use

3 NADA. We use an appraisal process working

4 trying to get the value for energy. So I do

5 not have access to this model to run it. It

6 is not something at Next Step we have embraced

7 as one solution, so that's for us to figure

8 out.

9 MS. HOFFMAN: Can you work with

10 Robin, then?

11 MEMBER EPPERSON: Do we have it,

12 Robin?

13 MEMBER ROY: I am working with you

14 on your subcommittee already.

15 MEMBER EPPERSON: Do you have

16 access to it?

17 MEMBER ROY: We can buy access to

18 it.

19 MEMBER EPPERSON: Okay.

20 MS. HOFFMAN: Okay. So you'll

21 both work on it, and the Finance Committee

22 will. Thank you.
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1 MR. RAMIREZ: Michael?

2 MEMBER LUBLINER: Yes. Don't get

3 me wrong, I think that if we have estimates

4 from other sources than NADA, we should

5 absolutely use them. And to the extent that

6 I'm hearing, though, that the chattel mortgage

7 is a big component of the industry, we can't

8 ignore that. We can't take all of the

9 benefits that one side takes from making that

10 case and not recognize the value that that

11 process adds.

12 So I thought that if we agree that

13 NADA's resale value is representative of

14 chattel mortgage, then maybe that's the best

15 available data we have for that. For the

16 others, I would use the experience you have.

17 And I have a letter from the

18 Director of NADA, and this is -- I'm going to

19 submit this for you guys, so you can follow up

20 with her. "It was a pleasure speaking with

21 you yesterday. We have recognized Super Good

22 Sense and ENERGY STAR home cost options in the
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1 printed Manufactured Housing Cost Guide for a

2 number of years." Over 20, I believe.

3 "While the printed guide is no

4 longer in production, additional features and

5 costs for both home energy option types

6 continues to be a selection for our users of

7 our electronic products, NADA guides,

8 manufactured housing connect, which replaces

9 this printed guide.

10 "I have received the updated NEME

11 and ECO-ADELS and will be adding them as

12 images for reference in the NADA Manufactured

13 Housing Guide."

14 And I think your product is also

15 recognized there. So I guess I have a concern

16 when you say that there is zero value, but

17 your product is recognized here as having --

18 and I'd just leave it at that.

19 MEMBER LEVY: Let me just clarify,

20 Mike.

21 MEMBER LUBLINER: Okay.

22 MEMBER LEVY: A couple of things. 
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1 One is, yes, we also have a page in the NADA

2 guide, and I offered to provide that page to

3 the committee. Our experience has been that

4 we were happy to have that information

5 included. Our experience has been in talking

6 to the NADA people and to people who sell

7 homes, because we are quite interested in

8 this. Your label is for the northwest; our

9 label covers the rest of the country. And so

10 we are interested to know what kind of

11 traction it is getting.

12 And when I said earlier our

13 experience is anecdotal, it comes from talking

14 to people in the resale business. And I ask,

15 "To what extent are you using our material?" 

16 And they're saying, "What material?" And so

17 they are not -- yes, they might meet ENERGY

18 STAR, but they are using that as a point of

19 sale and/or they are not recognizing the

20 higher value as a result of the fact that

21 those measures are in the homes.

22 And it could be simply because the
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1 salespeople are not qualified to deliver that

2 message. Whatever the reason, it is -- the

3 effective result is a zero net value for those

4 features.

5 MS. HOFFMAN: I just want to do a

6 process check. We want to have a break. We

7 also want to hear from the GC with some

8 questions that you had asked her. And we want

9 to continue this, and we'll be hearing from

10 Eric about multiple compliance approaches.

11 So I'll yield to the group, but

12 what about a 15-minute break now? Okay. 

13 Fine. Okay. So what about 15 minutes, come

14 back, and then we'll talk about if we hear

15 from the GC first or just continue with this. 

16 Okay? But we will get both done.

17 Thank you.

18 (Whereupon, the above-entitled

19 matter went off the record at 10:51 a.m. and

20 resumed at 11:13 a.m.)

21 MS. HOFFMAN: Okay, everybody,

22 we're back on for the continuation of the
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1 Working Group's meeting. And we were still

2 going over the straw man proposed framework

3 for developing a term sheet. So let's go back

4 to where we were and see if we can pick up the

5 pace and also assign some job duties.

6 MR. RAMIREZ: I'm thinking that

7 realistically the other item probably should

8 -- I don't know there's a lot of assignments

9 that need to be doled out on some of the other

10 stuff, but we'll take a look at it and see if

11 there's anything that we need to fill in.

12 So I think, if I'm not mistaken,

13 we are done with the -- can you scroll up to

14 that economics stuff? I think we're done with

15 all that stuff. So let's go down to the next

16 point then, the analysis. 

17 MS. HOFFMAN: Put your thing on,

18 yes.

19 MEMBER LEVY: Sorry, Emanuel. I

20 don't think this is relevant any more. I

21 think this has kind of been superseded by

22 subsequent conversation, and this is really
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1 what the Laboratory and Navigant will be

2 doing.

3 MR. RAMIREZ: So that's all

4 analysis or just one?

5 MEMBER LEVY: Right, this is kind

6 of a description of what would be done with

7 the data that's above.

8 MR. RAMIREZ: All right, then

9 let's go down to -- you can leave it on there. 

10 That's encompassed in some of the data that

11 the folks have already been assigned. They're

12 working on that, so I think we'll be okay with

13 just leaving it there.

14 MS. HOFFMAN: What did you have in

15 mind, Emanuel?

16 MEMBER LEVY: I think that's

17 right. I think this was intended to be the

18 directive to the contractor, what to do next.

19 MR. RAMIREZ: Yes.

20 MEMBER LEVY: This needs to be

21 probably wordsmithed a bit.

22 MS. HOFFMAN: So put on wordsmith
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1 and rework it.

2 MR. RAMIREZ: And so is that

3 something that you're going to take a shot at?

4 MEMBER LEVY: We can do that,

5 sure.

6 MR. RAMIREZ: Okay, great. 

7 MS. HOFFMAN: Now what about the

8 results? That also -- results?

9 MEMBER LEVY: We're now talking

10 about a lot of other kinds of results and

11 sensitivity studies. I don't think we need to

12 capture -- take the time right now to capture

13 those.

14 MR. RAMIREZ: That's something

15 you're working on. As the stuff comes in and

16 you see little tweaks that you're going to be

17 asking for as far as the data goes, is that

18 accurate?

19 MEMBER LEVY: Sorry, Emanuel. Are

20 you talking about the results?

21 MR. RAMIREZ: Yes.

22 MEMBER LEVY: This is basically
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1 what our expectation is of what's going to

2 come out of the analysis, what we're going to

3 end up with. And it just needs to now reflect

4 better, all the changes we'd need to -- what

5 the data collection is, what will be the

6 analysis.

7 MS. HOFFMAN: So add it to his

8 wordsmithing. We're adding it to your

9 wordsmithing duties, okay?

10 Okay, other economic

11 considerations. Any comments? There seems to

12 be a need for data or stories for number two,

13 the additional cases with economic burdens. 

14 And I wondered if Dave would like to, David

15 Tompos, would like to take that on and maybe

16 chat with his colleagues.

17 MR. TOMPOS: I can do that. I'm

18 currently working on some diagrams so we can

19 at least put them in picture form so everybody

20 can understand them.

21 MS. HOFFMAN: Great. I've been

22 given good instructions to make you in charge,
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1 but please feel free to talk to other folks as

2 well.

3 MR. TOMPOS: I'm extremely excited

4 to take that on.

5 MS. HOFFMAN: Thank you. Or as we

6 say you've been "voluntold."

7 MR. RAMIREZ: Going up to number

8 one, is there anything to be done on that?

9 MS. HOFFMAN: This is what we

10 brainstormed this morning.

11 MR. RAMIREZ: Yes, I see that

12 there's some studies that are going to be done

13 on C. But what about A and B? Do we need

14 anything on those? And if so, who is taking

15 care of those?

16 MEMBER LEVY: Emanuel. I think

17 that those items were place markers for when

18 we start to describe what we have in mind in

19 terms of inspections and compliance, that we

20 make sure we capture those costs, but I think

21 it's early to start thinking about what those

22 might be.
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1 MR. RAMIREZ: So no action right

2 now. And then C, there were some studies that

3 were in there. Did somebody assemble those or

4 is that part of what you said?

5 MS. HOFFMAN: That's what David

6 was going to work on. 

7 MR. RAMIREZ: Yes. I see on C

8 that the NAHB study that Eric sent that to me,

9 correct? And I just brought it on to the

10 entire work group during the break. But

11 there's some other components in there. Who

12 is going to get those?

13 MEMBER LEVY: The Meeks study I'm

14 going to put in Lois' hands because that's an

15 MHI study.

16 MR. RAMIREZ: Okay, so Lois will

17 take care of that?

18 MEMBER LEVY: If you would note

19 that so she knows.

20 MR. RAMIREZ: Yes. The March and

21 Meeks study.

22 MEMBER LEVY: Just the Meeks
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1 study.

2 MR. RAMIREZ: Oh, the Meeks.

3 MS. HOFFMAN: We'll make sure she

4 knows then. Okay.

5 MR. RAMIREZ: What about Marsh,

6 Marks and Eckman?

7 MS. HOFFMAN: That's Luby.

8 MR. RAMIREZ: We just volunteered

9 you to do some stuff.

10 MEMBER LUBLINER: So Joe has both

11 those studies? Sorry, last night I sent

12 those, both those studies to Joe.

13 MR. RAMIREZ: Can you forward

14 those to me and I'll forward them to the work

15 group?

16 MEMBER LUBLINER: Absolutely. But

17 Joe, are you all right, forwarding?

18 MR. RAMIREZ: Marsh, Marks and

19 Eckman.

20 MR. HAGERMAN: I was going to

21 forward everything you sent probably after

22 this meeting when I get some breathing time.
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1 MR. RAMIREZ: You don't have to do

2 it right this moment, but okay, as long as

3 you'll forward that.

4 MS. HOFFMAN: Yes, Eric?

5 MEMBER LACEY: This is Eric. The

6 NAHB study probably doesn't belong in the

7 price elasticity of demand. It's a life

8 expectancy of measures. And so that probably

9 goes up in the discussion of life-cycle cost

10 analysis, not in the price elasticity. Small

11 detail.

12 MEMBER WEISS: Mark Weiss. I

13 wasn't talking about the one that was

14 distributed today. I was talking about the

15 one that came out a few days ago or a couple

16 of weeks ago on the cost impacts, exclusion

17 and cost impacts.

18 MR. RAMIREZ: Do you have a copy

19 of that?

20 MEMBER WEISS: The one that Mr.

21 Surrena was talking about at our last meeting

22 and I believe that's available on line. So I
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1 guess we can --

2 MS. HOFFMAN: You can send us the

3 link.

4 MR. SURRENA: I'm sorry, I zoomed

5 out for a second.

6 MEMBER WEISS: The NAHB study on

7 cost impacts, on exclusion impacts that you

8 addressed at our last meeting.

9 MR. SURRENA: Yes.

10 MEMBER WEISS: That is available

11 online in its entirety.

12 MR. SURRENA: Yes.

13 MEMBER WEISS: Okay.

14 MS. HOFFMAN: And you can send us

15 the link.

16 MEMBER WEISS: That's what I was

17 referring to and we can get that.

18 MR. SURRENA: I will send the link

19 to whomever.

20 MS. HOFFMAN: Joe and Javier, the

21 committee, yes.

22 MR. RAMIREZ: Thank you, Don. Is
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1 that good, Mark? Exclusionary cost impact? 

2 Okay. And that will be forwarded to the

3 working group.

4 MS. HOFFMAN: By the way, do we

5 need anyone besides David on number two or can

6 you deal with all of those, A, B, C, D?

7 MR. TOMPOS: I think I can put

8 something together for all those.

9 MS. HOFFMAN: Okay.

10 MR. TOMPOS: Again, not knowing

11 what U values we're talking about kind of

12 makes it difficult to decide if we have a

13 problem or not. We may be getting a little

14 bit ahead of ourselves.

15 MS. HOFFMAN: Okay, keep moving. 

16 I think we ended with the additional energy

17 measure properties with Eric providing some

18 resources. Is that right? And we put Eric

19 down there. Were you going to --

20 MEMBER LACEY: Yes, this is Eric. 

21 I think I was going to provide a list of other

22 measures that are required by the IECC that
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1 may not be reflected in the typical use of Uo

2 calculation.

3 MS. HOFFMAN: And you're going to

4 send it to all of us?

5 MEMBER LACEY: Yes.

6 MS. HOFFMAN: Great. Anything

7 else on that? Okay, I think that's a good

8 start. We'll have copies of this for

9 everyone. Does everybody have a -- yes?

10 MEMBER LUBLINER: Can we go back

11 to that list again?

12 MS. HOFFMAN: Yes. I think you

13 had some stricter standards, too.

14 MEMBER LUBLINER: Is a heat pump

15 water heater on there? Heat pump water

16 heater. So I would move that because it's not

17 -- I think you want to separate where the

18 heating from domestic hot water so you're not

19 overlapping things. So maybe you could just

20 make DHW systems its own bullet and then put

21 heat pump water heaters and tankless water

22 heaters. Thank you.
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1 MS. HOFFMAN: Mark?

2 MEMBER WEISS: I guess under data

3 needs and I would just appreciate this as a

4 reminder to me. I want to provide some

5 information related to what Manny was talking

6 about earlier. We've been hearing a lot about

7 Vermont and the Northwest and that's fine, but

8 that's not where the bulk of manufactured home

9 shipments go. I'd like to provide the working

10 group with some data dealing with that, with

11 the distribution of those shipments around the

12 country. It should be valuable for looking at

13 zones and that sort of thing?

14 MS. HOFFMAN: Great. Where would

15 it go in here or just in general?

16 MEMBER WEISS: Basically, it's

17 just a reminder for me to provide it to you so

18 --

19 MS. HOFFMAN: Yes, because once

20 you're on this list, you're on the list.

21 MEMBER WEISS: Right.

22 MR. RAMIREZ: So Mark, is there a
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1 name for that?

2 MEMBER WEISS: I would just call

3 it shipment distribution, should be by state

4 distribution.

5 MS. HOFFMAN: Good. Any other

6 comments on this at this point? Okay. What

7 we'd like to do now is hear from the general

8 counsel. Oh, sorry.

9 MEMBER LEVY: There was one data

10 need that came up. I'm not sure it's been

11 assigned. Robin, I think, mentioned it, which

12 is the distribution of heating equipment type

13 by location which is something we're going to

14 need at some point, particularly for the cost

15 benefit analysis.

16 MR. RAMIREZ: Heating equipment

17 type by location? Who would have that data?

18 MEMBER LEVY: Million dollar

19 question. The American Housing Survey.

20 MS. HOFFMAN: Robin, put your

21 thing -- yes.

22 MR. HAGERMAN: I can answer that,
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1 too. So the American Housing Survey is where

2 we pulled it from the last list that we used

3 and I've already asked the PNNL team per

4 Mark's suggestion to update that with the 2011

5 data. So that version of the analysis you're

6 going to see updated.

7 MEMBER LUBLINER: Just to clarify. 

8 It was the micro data or something that was

9 referenced. Is that just the manufactured

10 housing component of the survey or does that

11 represent all of the --

12 MR. HAGERMAN: I don't know the

13 answer to that, but I can find out.

14 MEMBER LUBLINER: Thank you. 

15 That's really, really important.

16 MR. RAMIREZ: So Emanuel, does

17 that capture what you need?

18 MEMBER LEVY: What we'll need,

19 yes, I personally don't think the housing

20 survey is very good, very accurate, because it

21 looks at all the historic data and what is

22 being built today may not be what has been
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1 built historically, particularly when it comes

2 to heat pumps. So there may be other sources

3 for this. For example, there are only a

4 handful of manufacturers of equipment for the

5 industry. They know where they're selling

6 equipment. So they may be a source of sales. 

7 Their sales data may be a source of

8 information.

9 MR. RAMIREZ: How do we get that?

10 MEMBER ROY: I think it's a fine

11 test to call the small number of manufacturers

12 and solicit that information. It's almost

13 their task or DOE, somebody.

14 MR. HAGERMAN: And we might have

15 some shipment data from previous rules for

16 water heaters?

17 MEMBER ROY: We almost certainly

18 do.

19 MR. RAMIREZ: Right.

20 MEMBER LUBLINER: I'd also suggest

21 that you maybe talk to HUD and IBTS and the

22 SAAs and get feedback from them as to what
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1 they're seeing out there in the way of fuel

2 mix and how many homes are converted to heat

3 pumps or how many homes go out with propane

4 and just get -- because you're going to get

5 anecdotal data from everyone and it gets a

6 broader group.

7 MR. HAGERMAN: Just to make sure I

8 heard everybody right. We're going to update

9 the analysis with the 2011 micro data for

10 manufactured housing from the American Housing

11 Survey and then I'm going to supplement that

12 with any data that I can get about heat pump

13 water heater usage. Is that right?

14 MEMBER ROY: Heat pumps. And if

15 you can find something that addresses

16 Emanuel's sensible concern about the

17 difference between the overall stock of mobile

18 and manufactured homes and the difference

19 between that which is what American Housing

20 Survey probably is heading to and new sales. 

21 That would be great.

22 MEMBER LUBLINER: And also, I will
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1 volunteer. I've been working the Northwest

2 Energy Efficiency Alliance, the Northeast

3 Energy Efficiency Alliance, the Midwest Energy

4 Efficiency Alliance, and the Southeast Energy

5 Efficiency Alliance. We've had conversations

6 about the need for this data. They run

7 utility programs, in many cases, incentivizing

8 heat pumps and they're going to provide some

9 data as well.

10 MR. RAMIREZ: How soon is that?

11 MEMBER LUBLINER: It's going to be

12 anecdotal data and I'm pursuing it right now.

13 We have data from the Northwest program to

14 provide for everyone. 

15 The suggestion that Emanuel made

16 is a good one on the heating system by

17 location. I want to make sure that we also

18 get water heating distribution. My

19 understanding is that about 90 percent of all

20 HUD code homes regardless of if they have gas

21 heat, have electric water heaters. I'd like

22 to try to get some data to look at that
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1 because if that's the case, this is a

2 significant energy use of the whole sector and

3 so it would behoove us not to -- if we're

4 going to get water heating as part of the

5 mission and we're still waiting for counsel on

6 that one, that would be important to have.

7 MR. RAMIREZ: I'm leaving it up to

8 you all to self-monitor in the sense of we

9 want to make sure that we don't have paralysis

10 by over analysis, right? And so I don't know

11 what's relevant. So you guys are going to

12 have to self-monitor that. Is that fair

13 enough? Okay.

14 MS. HOFFMAN: Are we finished with

15 this?

16 MR. BANTLE: Are we putting water

17 heater on?

18 MR. RAMIREZ: Can you give us the

19 headline version of that?

20 MEMBER LUBLINER: Water heating

21 equipment --

22 MS. HOFFMAN: Microphone.
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1 MEMBER LUBLINER: Water heating

2 equipment by location and fuel type. Does

3 that work?

4 MR. RAMIREZ: And you said that

5 you are working on some initial data on that?

6 MEMBER LUBLINER: No, I have data

7 on the distribution of the space heating

8 stuff. I don't know. The industry knows

9 better than I do if that 90 percent was

10 correct or even in the reasonable ballpark.

11 MR. RAMIREZ: So your last request

12 there who has --

13 MEMBER LUBLINER: I'm asking the

14 industry right now is 90 percent a reasonable

15 number to use or do we want to wait on that

16 and do that later? I don't have source of

17 that data other than what people in the

18 industry have told me. We've got the industry

19 here. They can decide to respond or not to

20 that.

21 MR. RAMIREZ: Manny?

22 MR. SANTANA: Yes, Manny with
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1 Cavco. Without having any hard numbers, just

2 the floor plans that I've seen across our

3 plants which are spread across the country, I

4 would say 90 percent is not reasonable or not

5 accurate without -- I haven't seen anything to

6 indicate that. I see a lot of gas water

7 heaters. I don't know what percentage. I

8 can't even give you a ballpark. But 90, I

9 don't think is correct.

10 MR. RAMIREZ: Is Mark Ezzo on the

11 phone?

12 MR. EZZO: Yes, I'm here. So the

13 question is what percent of homes are built

14 with gas versus electric water heaters?

15 MEMBER LUBLINER: Yes. I guess my

16 question is what percentage of overall homes

17 are built with electrical water heaters

18 regardless if they have gas space heating or

19 not?

20 MR. EZZO: I don't know that

21 number. It's very regional, as you guys know. 

22 I mean out West, gas is a lot more prevalent
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1 than it is in the South and the East. But

2 it's kind of hard to grab a number on that

3 unless we were to go and look at all our

4 plants and ask some questions.

5 MR. TOMPOS: Dave Tompos --

6 MR. EZZO: Basically, the gas

7 water heaters, as you guys know, are more

8 expensive than electric, so lower end markets

9 see a lot more electric and in the higher-end

10 markets, we see more gas. So Mike, like in

11 your area, Northwest, there's a higher

12 percentage of gas water heaters than there is

13 in the Southeast.

14 MEMBER LUBLINER: Yes, that's

15 scary because our data suggests that 90

16 percent are electric even if there's a gas

17 furnace in the house, 90 percent of the water

18 heaters in -- even in the gas -- overall, is

19 electric. If you don't want to use the

20 Northwest as an example, if -- but again, I

21 can just provide what we have from the

22 Northwest, if you guys want to survey your
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1 manufacturers or you want to talk to HUD or

2 SAA or IBTS, maybe they can provide some

3 concurrence or significant concern like Manny

4 raised about the number I threw out there.

5 MR. TOMPOS: I just want to -- I

6 don't think 90 is probably the number we

7 should use. And I don't have the numbers, but

8 we do a lot of on-site inspections on gas

9 water heaters. However, that's only when

10 they're going through the hinge portion of the

11 roof we're required to do an on-site

12 inspection. And I know we do a lot of them. 

13 So I'm just throwing that out there. I can't

14 give you any hard numbers, but 90 doesn't feel

15 like a proper number for the entire country.

16 MR. RAMIREZ: Mark, did you have

17 something?

18 No, okay.

19 MS. HOFFMAN: Eileen Hoffman,

20 here. I think for this point, we'll put this

21 aside and hear from our -- we're not done with

22 it, but we're done with that portion and hear
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1 from our general counsel who is answering a

2 specific question.

3 MR. BANTLE: Eileen, this is Ted. 

4 Just one last thing. I believe that Eric had

5 a comment on the NAHB in a different set of

6 data from there that he wanted at the life

7 cycle?

8 MR. RAMIREZ: We don't have that

9 to put up because it's already been

10 distributed. It's an assignment that's been

11 done already.

12 MR. BANTLE: Okay, so we're good.

13 MR. RAMIREZ: Right?

14 MR. BANTLE: Sounds good.

15 MR. RAMIREZ: We just wanted to

16 make sure we captured that, but that one was

17 -- he sent it this morning and I sent it out.

18 MR. BANTLE: Okay.

19 MS. HOFFMAN: Okay, Ted, so now

20 we're going to hear from general counsel's

21 office. Will you introduce yourself?

22 MS. VAIDYANATHAN: Yes, this is
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1 just a point of clarification. I'm not the

2 General Counsel of DOE. I would love to be,

3 but I work in the Office of the General

4 Counsel. I'm just one of the attorneys,

5 Kavita Vaidyanathan, and I am Program Counsel

6 for Building Codes and for the Office of

7 Building Programs. 

8 So the question came up whether

9 the National Appliance Efficiency and

10 Conservation Act preempted DOE from setting

11 efficiency standards for covered products

12 within manufactured homes. So in my

13 preliminary research and talking to some

14 folks, I haven't been able to connect with

15 everyone. I understand that the Act has been

16 applied to preempt authority to set higher

17 efficiency standards from the federal minimum

18 for states. And preemption is a specific

19 legal concept where the Federal Government

20 takes authority away from the states. So

21 preemption is not what we're talking about

22 here. 
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1 From what I understand, we're

2 talking about setting efficiency standards for

3 a covered product different from what DOE sets

4 under the Energy Policy and Conservation Act,

5 based on the site of the product. The product

6 would be in a manufactured home versus other

7 applications that we set. For example, DOE is

8 currently doing a rulemaking on mobile homes

9 for furnaces.

10 MR. HAGERMAN: Furnaces for

11 manufactured housing.

12 MS. VAIDYANATHAN: Oh, for

13 manufactured housing. Okay, so if this group

14 were interested in setting different standards

15 than the one we're setting for that

16 rulemaking, that might be a problem because

17 that covered product is specifically set forth

18 in the Energy Policy and Conservation Act. It

19 seems counter productive. It doesn't seem

20 correct to do something different from another

21 rulemaking that we already are pursuing in a

22 different aspect.
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1 But if we're talking about other

2 covered products as well, the question I guess

3 the General Counsel's Office has is what's the

4 rationale for having a different standard for

5 a covered product under a manufactured home? 

6 Is it somehow -- is a covered product somehow

7 installed differently? Is it used differently

8 than it would be in other homes? Why we would

9 set a different standard than we do in other

10 rulemakings for a national standard that we

11 already set for those covered products? I

12 don't know. I mean this is a question for the

13 group. 

14 We just want more information on

15 what the rationale DOE would give to set a

16 standard under the Energy Policy and

17 Conservation Act for covered products and then

18 say but, for manufactured homes, we have a

19 different standard that we're going to set. 

20 And is it because -- I guess this is a

21 question for the manufacturers, do you -- for

22 the equipment and the appliances that you may
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1 want to set, do you ship all that together

2 with the manufactured home or is it installed

3 later? I don't know the process. So is a

4 water heater shipped with the manufactured

5 home? Or is an ENERGY STAR appliance shipped

6 with the manufactured home and that's why you

7 would want to set those standards? And is it

8 installed differently in a manufactured home

9 than it would be in other settings? Because

10 in looking at our covered products under EPCA,

11 we don't look at, I guess, the site use of the

12 product. We set those standards without

13 looking at the site use of the product. We

14 don't see different standards for a 4,000

15 square foot home versus a 2,000 square foot

16 home. So these are questions for the group,

17 for us, to make a determination on whether

18 it's rationale to set those standards.

19 MEMBER WEISS: Mark Weiss. I did

20 have a question on your reference to the

21 furnaces for manufactured homes. What stage

22 is that rulemaking in? Is that conventional
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1 or negotiated? Is that under ASRAC requests?

2 MR. HAGERMAN: I think I can

3 answer that, but I can look up for the

4 specifics, but I believe it just started and

5 it's usually about a two-year process. It's

6 not going through ASRAC as far as I know. 

7 I've not heard that. It's a traditional

8 rulemaking.

9 MEMBER WEISS: Conventional.

10 MR. HAGERMAN: Yes. And I can get

11 you the docket and I'm sure somebody here can

12 point you to the docket where it would be

13 found. But it is an update. There's already

14 a standard for manufactured housing furnaces. 

15 It's an update to that standard.

16 MEMBER ROY: This is Robin. It's

17 only gas furnaces, I believe. It's from a

18 remanded efficiency standard. It was

19 something which was contested from a

20 rulemaking a few years ago. It only applies

21 to gas furnaces.

22 MEMBER LACEY: I can attempt to
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1 maybe clarify what some questions would be or

2 narrow it down, at least the questions I would

3 have related to this. The preemption issue is

4 something that's come up many times in the

5 states and I think I have a general sense of

6 how that works. Two questions or maybe

7 subquestions here. 

8 One is we know that states are

9 preempted from setting a higher efficiency

10 level than what's been established for a

11 covered product by the Federal Government. Is

12 this committee -- I wouldn't be preempted, but

13 would this committee be allowed to specify

14 something higher as a baseline requirement for

15 all manufactured homes. I think I'm hearing

16 from you the answer is no, but that's kind of

17 the first part of the question.

18 The second part of the question is

19 if the efficiency of a covered product is

20 going to be used in a compliance baseline or

21 in a set of building code requirements, are

22 there specific rules that apply? For example,
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1 in NAECA, there's a whole set, I think there

2 are seven restrictions placed on states. If

3 they do include equipment efficiency in their

4 calculation of the overall efficiency of the

5 home, it was to meet seven criteria. It has

6 to be at the federal minimum or there has to

7 be at least one option that references the

8 federal minimum and so on. And I don't have

9 the reference in front of me, but I can get

10 that.

11 And so there's the whole set of

12 rules that apply to states that are using

13 equipment efficiencies in their calculations. 

14 So I'd be interested to hear whether that set

15 of rules applies to DOE and HUD and more

16 specifically to this group. My personal

17 opinion is I don't think we want to go down

18 that path because I think it would make us

19 inconsistent with the IECC, but I think that's

20 the general -- I think those are the questions

21 that we were asking. I think that's maybe a

22 finer point on the questions. I hope that
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1 makes sense.

2 MS. VAIDYANATHAN: I think it

3 does. On your first point, we're not saying

4 that you can't. I just think that we need

5 more information before we make that

6 determination. Preemption is not an issue

7 here, so it's not a question of NAECA stopping

8 us. It's looking at the Energy Policy

9 Conservation Act where we do set standards for

10 covered products and then determining what the

11 rationale would be under EPCA and the

12 rationale for the manufactured housing energy

13 efficiency standards we're setting, why we

14 would set different standards.

15 So it could be a possibility if we

16 can come up with the rationale. And I am

17 sorry, I'm not familiar with NAECA standards,

18 so I would have to look into whether those

19 standards would apply or if there are other

20 standards in setting, if the group is thinking

21 about setting standards what restrictions

22 would be. 
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1 But I think the overall question

2 is if we are going to set them, what's the

3 rationale for setting a different standard

4 first. And then if there is such a rationale,

5 are there are restrictions in setting those

6 standards? So I can do some research and

7 looking at if there are restrictions and if

8 the committee can give me some information on

9 why you would want to set a different standard

10 from what's already in the covered products. 

11 If you can give me that information, because

12 I'm not quite sure on a technical basis what

13 the difference would be.

14 MR. HAGERMAN: This is Joe

15 Hagerman. Let's just remember the context

16 here. So this was brought up yesterday

17 afternoon. The committee has gone back to

18 General Counsel to kind of discuss this and

19 really came back to the group to ask. You

20 know, we need more information to be honest

21 with you and this is a very tricky question,

22 right? We need more information from you guys
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1 to help us be able to answer what it is this

2 group could do or not do in its scope.

3 MR. RAMIREZ: Let's get Michael

4 and Mark.

5 MEMBER LUBLINER: So I want to

6 thank you for jumping right on this one. And

7 I totally understand this is a process that

8 needs information from a number of sources. 

9 So to answer one of your

10 questions, I think the fundamental one is the

11 homes are shipped with water heaters by law. 

12 I believe you can probably get a home to ship

13 without a water heater if you have a special

14 alteration, what is it an AC letter or

15 something. So it happens. Say I wanted to. 

16 I'm a consumer. I go in and I want to buy a

17 tankless water heater instead of a tank water

18 heater. And I go to the retailer and they say

19 well, we don't necessarily offer that or yes,

20 we offer it, but it's very expensive because

21 we don't stock it. We don't have the buying

22 power. So I don't have a choice in many
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1 cases.

2 One of the arguments is consumer

3 choice. The consumer should be able to buy a

4 manufactured home and be able to afford the

5 buying power that the industry has in

6 procuring energy efficient products that may

7 be in the consumer's best economic interest. 

8 If I understand what drove the preemption to

9 begin with, my understanding and again, I'm

10 not a lawyer, was that it was looking at the

11 burden to the manufacturer of the product like

12 the refrigerator manufacturer and not having

13 states with different regulations in every

14 state so that they were being driven crazy. 

15 Well, I don't think that that applies here at

16 all. This isn't going to have an impact on --

17 all it's going to mean for G.E. would be if it

18 was a refrigerator criteria, it would mean

19 they're going to stock more ENERGY STAR

20 refrigerators when they do a national sales

21 contract with any of these manufacturers.

22 My own personal experience was
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1 when I bought my home. I ended up -- it was

2 cheaper for me to go to Home Depot and get my

3 own refrigerator than it was to have the

4 manufacturer special order it and then mark it

5 up and then the retailer mark it up. So I

6 went back to the Consensus Committee and I

7 said this doesn't, as a consumer, represent

8 any consumers in saying the consumer is not

9 getting a choice because of the decisions in

10 the factory not to offer it.

11 So I look at the economics to the

12 consumer of purchasing an ENERGY STAR

13 refrigerator, given the cost at Home Depot, I

14 say God, this is a good economic choice. I

15 wish the manufacturer could get me a price

16 like that. And so that's kind of some

17 background on where we're going.

18 The heat pump water heaters is a

19 very important one. Let's just take the

20 example, heat pump water heater which G.E.

21 will sell right now for $500 wholesale to this

22 industry. And you can confirm that if you
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1 want from the suppliers, but if you would mark

2 that up to reasonable retail rates that could

3 be like a $1,500, $1,200 to $1,500 product to

4 the consumer. But that consumer, if you

5 believe the DOE and the G.E. advertising, is

6 going to save roughly $150 to $200 a year. So

7 he's going to realize that investment back,

8 but he can't get that product right now. And

9 it may be cost effective.

10 So what I'm asking is that we

11 analyze these to make sure we know where

12 they're at and we engage the manufacturers in

13 a discussion of what the costs would be if

14 they were procuring these products at the

15 volumes that they're procuring the non-ENERGY

16 STAR products. And so the specific ones that

17 I think are really most important would be the

18 appliances, the dryer and the laundry if it's

19 shipped with the home. It's typically not, so

20 maybe that's not a big issue. The

21 refrigerator which is often most always

22 shipped with the home and the dishwasher and
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1 the exhaust fans in the homes.

2 And for the water heater, it would

3 be either -- if it was gas a tankless water

4 heater or a condensing water heater and if it

5 was electric it might be a heat pump water

6 heater or even a solar water heater, but

7 that's a little bit out. That's out on DOE's

8 2050 goals.

9 I apologize for that lengthy

10 background. I just thought it was appropriate

11 to kind of understand my perspective of what

12 was driving this to begin with.

13 MEMBER WEISS: A few questions and

14 I apologize for my lack of background, but

15 this NAECA law, when was it enacted, if you

16 know?

17 MS. VAIDYANATHAN: I actually

18 don't know and I apologize. I just started

19 researching this.

20 MEMBER WEISS: My question would

21 be assuming maybe it was before 2007, was it

22 before EISA or after? That's one question. 
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1 Yes.

2 MR. HAGERMAN: We're going to

3 Google it, but I'm pretty sure it was like 30

4 years ago.

5 MEMBER WEISS: Like I said, this

6 is the first I've ever heard of this. When

7 did the NAECA standards go into effect? Now

8 I assume that's over a period of time. What

9 was that period of time? And again, was it

10 before 2007? I assume at least a portion of

11 them were before 2007 if the law went into

12 effect 30 years ago, but you never know. Then

13 third, what's the definition of a quote

14 unquote covered product? 

15 MR. HAGERMAN: Mark, this is Joe

16 Hagerman. So it all went into effect with the

17 National Appliance Energy Conservation Act and

18 that Act, I think, details a lot of the

19 questions that you're asking right here, so

20 maybe we could circulate that.

21 MEMBER WEISS: That would be

22 terrific, yes. I'm specifically looking for
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1 that information.

2 MR. HAGERMAN: There's a great

3 Wikipedia article on it, too.

4 MEMBER WEISS: And then just one

5 further comment in response to what Mike said

6 and Mike and I have known each other a long

7 time. So I say this with all affection in my

8 heart, and that is that you live in a

9 manufactured home and I commend you for that. 

10 You're to be commended. Our chairman at

11 MHARR, Chief Executive of one of the producers

12 lives in a manufactured home, John Bostick. 

13 But the fact of the matter is that we're not

14 analyzing all this stuff or setting these

15 standards for you or for John because you're

16 not typical and I hate to use that word

17 because it might have a pejorative

18 connotation, but neither one of you is a

19 typical manufactured home owner. I mean we're

20 talking about folks with a median family

21 income of $27,000 plus. And as I said

22 yesterday, we can never lose sight of that
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1 fact.

2 So I appreciate your experience

3 and your input, but it's -- that's the fact of

4 the matter. You're not on the same level as

5 these other people and West things are much

6 different than I imagine them to be.

7 MS. HOFFMAN: Okay, Mark, thank

8 you. Any more questions for -- okay.

9 MR. TOMPOS: I just wanted to

10 respond to Mike on the on-demand water

11 heaters. We have several manufacturers that

12 are offering that and do that without any

13 problems at all. So it comes down to a demand

14 thing, I think, with a lot of these

15 appliances. I know a lot of manufacturers

16 offer an ENERGY STAR package on the appliance. 

17 I think I'm a proponent of giving the consumer

18 a choice. I don't think we should require

19 them to do it. 

20 I also think if there's already

21 federal requirements or standards, why would

22 we -- we have way too much to do here. We
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1 shouldn't waste our time trying to up a

2 standard that's already set. So just my

3 opinion. Maybe we can come back around to it

4 if we get everything done by the end of

5 September, but just my two cents.

6 MR. RAMIREZ: That was one of the

7 questions that I have for the group is that if

8 -- Kavita said that if the group is planning

9 on doing this, what's the rationale for the

10 change? So I guess that's the first question. 

11 Is it something that the group is seriously

12 considering because that goes back to my --

13 perhaps my over analysis. You need to be

14 selective on which roads we're going to go

15 down, okay?

16 Let me get Robin and then Eric.

17 MEMBER ROY: Robin. I tend to

18 agree, but I think we'll provide, NRDC's

19 counsel will provide a short memo to you why

20 we see no problem with DOE promulgating a

21 standard that includes treatment of water

22 heaters and space heaters. I don't think
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1 we'll address the other appliances because

2 those are required to be shipped with the

3 product. We'll provide that to you.

4 I do see some reason for our

5 continued interest in it and you can see that

6 from the first cut of PNNL's spreadsheet where

7 they have both electric resistance and heat

8 pump, energy of facts. It's a large number. 

9 The consumption in an electric resistance,

10 well, for space and water both. It's not all

11 there. The difference is very, very large. 

12 I think it may be -- well, at the very least,

13 it may be something that we want to consider

14 when we think about grinding out some

15 additional costs on the shell measures. Is

16 there a lower cost, more attractive way to get

17 the same, more savings, out of some of these

18 heating measures? Just for consideration, not

19 that we would do it.

20 MR. RAMIREZ: Eric and then Mark.

21 MEMBER LACEY: So I just wanted to

22 be clear. I don't think we have to resolve
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1 the issue for our purposes here for trying to

2 create a standard that we can recommend to DOE

3 that's going to give us -- that's going to

4 look something like the IECC. The IECC

5 doesn't include those trade-offs right now and

6 so it may be a non-issue. 

7 I'd be happy to follow up with

8 Kavita and give some citations and maybe try

9 to further refine what the question is. But

10 I think for this group's purposes, this might

11 be one of those kind of parking lots issues

12 where in theory it would be great to be able

13 to acquire the right cost effective piece of

14 equipment for every circumstance. I think

15 Robin is speaking to it. There are ways we

16 can give incentives for that. 

17 I think it's great to have

18 incentives. I don't think it's a good idea to

19 have incentives that would result in less

20 efficient buildings, the thermal envelopes,

21 for example. But I think some of these

22 issues, maybe we'll put it in the parking lot. 
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1 They might be better captured in an above code

2 or ENERGY STAR or green program where you

3 don't have some of those same restrictions

4 that you have in a mandatory standard. That's

5 what I'm suggesting. Maybe put that into

6 another category altogether.

7 MR. RAMIREZ: Mark?

8 MEMBER WEISS: Yes, Mark Weiss. 

9 Even aside from the straight legal issue

10 though is the question of the advisability of

11 requiring a different standard specifically

12 for manufactured homes. There is additional

13 costs entailed in that no matter how you go,

14 even if the standard were lower, since you're

15 departing from what is by now the national

16 norm for the original equipment manufacturers,

17 their stuff. So even if you set the energy

18 criteria lower, you're still potentially

19 looking at a higher cost. So that would be my

20 problem with this, one of them.

21 MS. HOFFMAN: So what I'm hearing

22 is putting it in the parking lot as a
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1 possibility. We will get to it, but trying to

2 do some other things first. Is that -- but

3 also that Joe and Eric and Robin will all be

4 in touch with Kavita in terms of the

5 application of the law and some background as

6 well. Is that fair to say? And we will all

7 get copies of the Act, as well, reference

8 Mark's suggestion that he wanted to see the

9 relevant portions as well.

10 I think you have a question or

11 comment?

12 MEMBER LUBLINER: Yes, I just

13 wanted to wrap it up with a final observation.

14 MS. HOFFMAN: Okay.

15 MEMBER LUBLINER: And since I was

16 a catalyst for this discussion, I went and

17 I've been on a federal advisory committee for

18 many years, a consensus committee, and I

19 represent the consumer. I made

20 recommendations to that committee many years

21 ago to require higher efficiencies for these

22 equipment. The committee decided that they
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1 didn't want to address it because they thought

2 this group was going to address it. So my

3 goal was really just to clarify whether this

4 group is going to address it or not. My

5 personal preference is that this committee not

6 address it because we have other fish to fry. 

7 We have more important things to do. But I

8 wanted clarification so now if it's that we're

9 going to parking lot it, it would be ideal for

10 HUD since I will now bring it back to the

11 Consensus Committee and say no, they didn't

12 address it. But it would be nice if DOE has

13 the resources to do the analysis of it because

14 HUD doesn't. So that's just a plug for the

15 parking lot. And I support the parking lot

16 with analysis. And maybe that's not a

17 priority for this ASRAC group.

18 MS. HOFFMAN: Manny.

19 MR. SANTANA: Manny with Cavco. 

20 Yes, I'd just like to make the comment, you

21 know, references to what has happened at the

22 MACC have come up and I think we have enough
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1 to do in this group to not push other agendas. 

2 And I would like to keep that in mind.

3 MS. HOFFMAN: Okay, Kavita. 

4 MR. RAMIREZ: Robin has been

5 patient.

6 MS. HOFFMAN: Okay, Robin, then

7 Kavita.

8 MEMBER ROY: I have to say I think

9 this is right in the agenda and we'll have to

10 explain. Part of what I want to do is explain

11 why if we don't address it, why we're not

12 addressing it. I mean space heating in many

13 parts of the country represents half of the

14 energy used in a manufactured home, if you use

15 electric resistance. And if you used a heat

16 pump, you'd be using only half or less of

17 that. Now that's a large fraction and we

18 will need to be coherent and clear as to why

19 we're not addressing it because it is not

20 precluded from our consideration under the

21 law, at least the understanding of our

22 counsel, but that's for you to determine.
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1 So we'll have to explain why we

2 did not address a measure or a series of

3 measures that could have reduced the energy by

4 something like 30, 35 percent total for

5 electric resistance, water and space heated

6 homes. Not to say that we should do it. I

7 take the point. There are all kinds of issues

8 with it, but we have to clear as to why we're

9 not doing it and understand what we are not

10 doing.

11 MR. HAGERMAN: This is Joe

12 Hagerman, DOE. I sort of appreciate that

13 sentiment and I anticipate that the Secretary,

14 before he signed off on a final rule, would

15 want us to be able to articulate that either

16 way. I think the group has to address it.

17 MS. HOFFMAN: Right, and just --

18 MR. HAGERMAN: I don't want to

19 necessarily think it's in a parking lot. We

20 have a lot to do as Manny keeps on pointing

21 out to get this term sheet written. Please

22 give us whatever information you can about
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1 this. We'll circulate the NAECA statute and

2 give us your comments. Whatever we can do,

3 but that should be kind of a little bit side

4 project for us.

5 MS. VAIDYANATHAN: Yes, and I just

6 want to say because I'm not a member of the

7 committee, I'm happy to do the work that you

8 don't have time to do. So I can look into the

9 issue. I'm happy to get the information that

10 you all have and look into it and see what we

11 can do from a DOE perspective and come back to

12 you with the information.

13 MS. HOFFMAN: Great, thank you. 

14 Before we end, before our lunch break, Keith

15 Dennis, who has been on the phone wanted me to

16 read his comments and they're somewhat close

17 to this discussion. 

18 He says, "From NRECA, we estimate

19 that more than half the people served by

20 cooperatives have no access to natural gas and

21 suspect that is why electric is so prevalent

22 for water heating." That's his point.
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1 And I think if he wanted to make

2 any more comments, he could be unmuted for a

3 moment.

4 MR. DENNIS: That's good. That

5 captures my point. We just find that a lot of

6 our -- don't have access to that.

7 MS. HOFFMAN: Okay, thank you. 

8 Now it's close to noon. What I'd like to do

9 if my co-facilitators agree, you noticed our

10 choreography is seamless. We had no

11 rehearsals either. We'd like to have a one12 hour break. Come back at one o'clock and

13 we've got a number of things to deal with

14 including a presentation from Eric Lacey on

15 compliance and from Michael Lubliner as well. 

16 And all of you, thank you.

17 (Whereupon, the above-entitled

18 matter went off the record at 12:03 p.m. and

19 resumed at 1:13 p.m.)

20 MS. HOFFMAN: I hope you had a

21 good lunch break. We're back on the record

22 and back ready to work. And in terms of our
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1 agenda, we're now going to ask Eric Lacey to

2 talk about multiple compliance options for us

3 to consider.

4 Thank you, Eric.

5 MEMBER LACEY: All right.

6 MR. HAGERMAN: This is Joe

7 Hagerman. Before you start, I think this has

8 come up before in the previous discussion

9 multiple times. And so the previous

10 conversation is going to advance the

11 discussion a little bit, but Eric, before the

12 start of the day, wanted to present some ideas

13 on multiple compliant options and he's come up

14 with this brief document for us to kind of

15 discuss.

16 MEMBER LACEY: And my idea here is

17 not right now to set the specific R-values or

18 U-factors or SHGC, but to think about a

19 possible framework for what some options might

20 look like.

21 Right now there's basically one

22 option in the HUD code for a meeting, and
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1 then, you know, the Uo, and we may continue

2 and have that as one of the options.

3 But based on what I've heard about

4 the use of REScheck for modular homes and, you

5 know, looking at the prescriptive path and

6 having conversations internally here, I

7 thought, well, starting with the different

8 options there are currently in the 2015 IECC,

9 would it make sense to adopt some of those

10 into the manufactured housing standard, and if

11 so, which of the options? All of them or a

12 couple of them that might be useful or well

13 understood already.

14 So I put together kind of a

15 strawman proposal with three options in here,

16 and I'm interested in your feedback as to

17 whether you think these things would be

18 feasible.

19 And, you know, I think Michael's

20 going to suggest what some possible values

21 might be for the first option. I'm not going

22 to get into that yet. There will be a good
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1 discussion on that later.

2 But this is to kind of outline

3 where I would see this, you know, where I

4 think we could go back to DOE with something

5 that looks like the 2015 IECC in many

6 respects, but that would allow a lot of

7 flexibility and maybe, you know, incorporate

8 some new ideas.

9 So three compliance options. The

10 first might be a prescriptive path. Now the

11 prescriptive path wouldn't have to be perfect

12 for every scenario. It wouldn't have to be,

13 the lowest common denominator is something

14 that any design could meet, but maybe a

15 sensible list of requirements that a

16 reasonably efficient manufactured home could

17 meet.

18 You know, it may not consider the

19 case of a cathedral ceiling or, you know, any

20 other conditions that you might come up with,

21 but it would be just kind of an average,

22 relatively efficient unit.
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1 And so it would have, I'm assuming

2 it would have like an R-value table or a U3 factor table or both just so that you have a

4 set list of requirements that you could

5 follow, and similar to what the IECC has for

6 its prescriptive options.

7 Now the IECC has a number of other

8 specific requirements beyond just a U-factor

9 requirement, and so I've tried to list the key

10 requirements up here. We wouldn't have to

11 keep all of these.

12 I would suggest keeping as many as

13 you can to make this, again, more like the

14 IECC and because some of these are pretty

15 important backstops when you start trading

16 things off.

17 But beyond just having an R-value

18 or a U-factor table or both, you'd have some

19 specific requirements and some exceptions that

20 are built into these for the thermal envelope

21 requirements, the systems and lighting, unless

22 the group here decides, look, this just
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1 doesn't apply.

2 There's a provision for pool

3 covers in the 2015 IECC. Maybe assuming pool

4 covers is not something that's really

5 necessary in here. It's a mandatory

6 provision. You know, maybe we drop that out

7 because it just doesn't even apply, I would

8 assume, in most cases.

9 Snow melt systems for the

10 driveway. That's another one that's, you

11 know, it would be nice to have but it's hard

12 to require that in every case in a

13 manufactured home.

14 And so that's the sort of

15 analysis, and we don't need to go through all

16 those things right now, but I tried to list

17 what I think and under the mandatory sections

18 what I think are the things that are currently

19 mandatory under all the compliance options of

20 the IECC that I think would still apply in

21 some form or another for manufactured housing. 

22 You might change some of those. 
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1 You might tweak them a little bit. But, you

2 know, in order to go back to DOE with

3 something that's roughly equivalent or within

4 range of the 2015 IECC, these seem to be the

5 sections I think you'd want to include. So

6 that would be the prescriptive path.

7 (Off the record comments)

8 MEMBER LACEY: That's Option 1. 

9 And I'd be interested to hear, maybe after I

10 go through these, how useful you think any of

11 these things would be. If you think you would

12 never use a prescriptive path maybe we don't

13 have one in there.

14 One reason why you might have one

15 on there, I'll give you two reasons to have a

16 prescriptive baseline in there. One is to set

17 the baseline for the other options.

18 That's the way the IECC is set up,

19 is you have kind of a prescriptive baseline

20 and the performance path and the UA and

21 everything is built on top of that single

22 baseline. So you kind of know what the base
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1 characteristics are and when you start doing

2 tradeoffs everybody understands the rules. 

3 Another reason to do this is to

4 allow product manufacturers to have a target

5 to try to aim for. If they understand that

6 the baseline home is supposed to be insulated

7 at about this level or have windows that are

8 about this efficient, it helps them kind of

9 fine-tune their offerings, their product

10 offerings.

11 And it would help, you know, I

12 think it would help spur innovation. You

13 know, if everybody saw that this is the attic

14 insulation requirement you might have more

15 suppliers out there saying well, look, we can

16 offer that too.

17 We can offer something that meets

18 that requirement, or better than that

19 requirement, and you can trade it off, you

20 know, elsewhere in the house. So that would

21 be another good reason to have just a base set

22 of requirements even if you aren't building a
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1 lot of homes to that base.

2 The next one would be a total UA,

3 or I'm calling it a REScheck option. And

4 we've talked about this before. Basically you

5 would have a baseline home that would be based

6 on the R-value/U-factor tables and then you

7 would have your proposed home.

8 And you would perform a

9 calculation to make sure you're getting

10 roughly the same level of efficiency in your

11 proposed home. It's a very simplified version

12 of a performance path and it's the same thing

13 that REScheck uses.

14 Now I'd point out that REScheck to

15 my knowledge doesn't currently have a

16 manufactured housing setting. It has a number

17 of different codes, and when I go into

18 REScheck and plug in a home I can key it to

19 the 2006, 2009, 2012 version of the IECC, and

20 I'd presume sometime soon the 2015 version. 

21 It also has some state-specific

22 versions of the code. North Carolina version,
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1 a Washington, a Utah version, for a handful of

2 states that have changes.

3 And so, you know, as part of this

4 recommendation, if we decided to go down this

5 path maybe we'd recommend to DOE that we're

6 adopting a UA path and we recommend creating

7 a manufactured home-specific version of

8 REScheck so that you could use it.

9 And I would appreciate your

10 feedback. If you think the current REScheck

11 works, great. We don't need to be concerned

12 about this. But if we change the baseline,

13 you know, and want to keep it consistent with

14 our baseline, whatever that baseline is, maybe

15 we include that as one of our recommendations. 

16 And I'd point out that even in the

17 UA approach in the IECC, you're still required

18 to meet certain mandatory sections and there

19 are still some exceptions and exclusions that

20 apply.

21 And I've tried to list the key

22 sections in here and I'm not promising to hit
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1 all of them, but again it's just a strawman

2 and as we go forward. If you wanted to go

3 down this path, we could take a very careful

4 look at them and decide which of the sections

5 did or didn't apply.

6 So that's the second path. And

7 then the third path is the one that I think

8 we've been talking about the most.

9 MR. RAMIREZ: Eric, could I just

10 ask you a question?

11 MEMBER LACEY: Yes.

12 MR. RAMIREZ: So you're saying

13 that it's not a guarantee that you'd hit all

14 the sections, but did you expect to do a

15 pretty thorough combing in here? I mean is it

16 more of hey, I just did a broad overview or I

17 went through it but I might have missed

18 something? In other words is it an attempt to

19 be all-inclusive, an attempt?

20 MEMBER LACEY: Okay, so here's how

21 I'd answer that. I have two bullet points

22 under each of these. The first bullet point,
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1 these are the other sections that apply.

2 You have Section 402 deals with

3 the thermal envelope. 403 is the systems, the

4 duct systems and heating and cooling systems. 

5 404 is lighting. Those are the requirements. 

6 I mean there are some that are in other

7 chapters of the code, but those are kind of

8 the core requirements.

9 And built, you know, inside each

10 of these sections there are a lot of

11 subsections, you know, how to properly install

12 insulation and, you know, what the air barrier

13 should look like and so on. And we would have

14 to go through each of those in finer detail.

15 The mandatory sections, this is

16 not a complete list of all mandatory sections. 

17 These are the mandatory sections that I

18 thought probably applied to manufactured

19 homes.

20 I tried to be a little more

21 specific here. There were a couple, like I

22 mentioned snow melt systems, I don't think
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1 really applies so I just eliminated that one. 

2 As far as I could, you know, come up with this

3 morning, this was kind of the key list of

4 mandatory sections. And this is negotiable,

5 you know, if you think that something is not

6 feasible or not sensible then one could be

7 knocked out or changed.

8 MR. RAMIREZ: Okay, thank you.

9 MEMBER LACEY: Is that a -- all

10 right.

11 MEMBER TOMPOS: I'm sorry. Dave

12 Tompos. Were the mandatory sections under

13 your prescriptive the same as under the UA?

14 MEMBER LACEY: Yes, they are. Oh,

15 go ahead.

16 MEMBER TOMPOS: No, no, no. And I

17 guess I'm getting ahead of you, but are they

18 the same in the other options as well?

19 MEMBER LACEY: Yes. In the IECC

20 the mandatory provisions apply across all the

21 paths.

22 MEMBER TOMPOS: Okay.
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1 MEMBER LACEY: And, you know, they

2 decided that there were certain things,

3 certain backstops that just had to apply. And

4 I'm going to recommend applying them to the Uo

5 path as well just in the name of consistency

6 with IECC approach.

7 So again the Uo we've been talking

8 about is trying to find that optimal, cost

9 effective, you know, reasonable approach to

10 getting that magic number. And I think that's

11 useful, and largely because it's, I think, the

12 path that most people in here are familiar

13 with for achieving compliance with the energy

14 standard.

15 You know, there are other

16 requirements that would apply. I added SHGC

17 in there because I don't think it's in the

18 current standard, and then there's the other

19 list of, you know, specific requirements and

20 mandatory sections.

21 In the IECC, the mandatory

22 provisions apply whether you're using
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1 performance, UA or prescriptive or even in the

2 ERI path, the new path. And so I would

3 recommend that we carry that forward into

4 whatever we come up with here, but that's an

5 issue we can discuss later.

6 If you think there's something in

7 the mandatory provisions that you just cannot

8 do in a Uo of a performance path then, you

9 know, we can talk about that. But I tried to

10 list them here just for the sake of being

11 complete.

12 There are a couple of other, there

13 are questions specific to the Uo? Okay. A

14 couple of other considerations that I jotted

15 down here, and this is again not a complete

16 list but things that I kind of thought of this

17 morning.

18 One is, and I mentioned that, you

19 know, if we decide to go down a UA or REScheck

20 approach maybe part of our recommendation is

21 DOE would like you to take a look at creating

22 a specific REScheck option for this.
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1 The other one is the ERI option,

2 the energy rating index. I mentioned in my

3 presentation yesterday that the 2015 IECC

4 incorporates basically a HERS alternative to

5 the code, a home energy rating score

6 alternative.

7 And just in informal discussions

8 here, I gathered that HERS is not something

9 that's often used for manufactured housing and

10 I'm not sure it's even appropriate. I like

11 the idea of having another option out there,

12 but it might take another iteration of HERS or

13 some communication with them to come up with

14 something that did work. I left it off the

15 options for now.

16 You know, I put three forward that

17 based on what I've heard are kind of common

18 approaches that I thought would be useful. If

19 you want to discuss the ERI option further we

20 can.

21 One thought I had is, you know,

22 maybe we set three options for the standard
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1 that comes out of this group. We could

2 suggest to DOE or later to Energy Star that,

3 you know, maybe there can be an energy rating

4 index option for Energy Star or for green

5 building programs or things that go beyond

6 this, where you capture some of the things

7 like improved equipment efficiency and

8 improved appliances and other things that you

9 really can't capture in the base code but that

10 you might capture in an above code program

11 without running afoul of any potential, you

12 know, federal minimum standard issues.

13 So anyway those are a couple of

14 thoughts I had about this. But again the idea

15 that I have is, you know, I think if we try to

16 focus on getting to a single right answer for

17 all units we could get bogged down in the

18 details and the discussion over the cost

19 effectiveness of various specific measures. 

20 But if we want to get to some kind

21 of consensus that people could live with,

22 having a couple more options in there that are
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1 roughly equivalent, I think, would be a thing

2 to do. At least that's how we can get through

3 things in the ICC process.

4 You know, if you're not happy with

5 something that goes into base code or in the

6 prescriptive path you have a performance

7 option too. If I want to have a cathedral

8 ceiling for all the attic space, I can't do

9 the prescriptive but I can do the UA or I can

10 do a performance path.

11 But anyway this is the strawman,

12 these three options. So I'd appreciate any

13 feedback or any thoughts.

14 MR. RAMIREZ: Manny? I'm sorry,

15 Emanuel.

16 MEMBER LEVY: Well, I can't see

17 the argument against keeping all these on the

18 table, particularly since we don't know where

19 we're going to get with what's in the standard

20 and some of these formats may be more

21 appropriate than others.

22 I want to pick up on couple of
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1 things. You said a little bit about

2 performance path but it's not really up here,

3 and there's a part of this which is kind of

4 coming at this with a site-built hat on as

5 opposed to thinking about it from what the

6 opportunities might be from a factory-built

7 standpoint.

8 And what I mean by that is you

9 have 160 or 140-some builders in this country

10 who build all the homes. It's a very small

11 group, fairly sophisticated companies who are

12 capable of doing things that site-builders

13 can't simply because there are thousands, tens

14 of thousands of site-builders.

15 So what might be appropriate for

16 the factory-building arena, which we're not

17 even talking about now, may be different than

18 what's appropriate for manufactured housing. 

19 And you've kind of touched on

20 this, Eric, about some of the opportunities

21 that might be out there if we went down a

22 different path. And what I'm thinking about
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1 here specifically, and we've talked about this

2 within the Research Alliance about the

3 opportunities here. A real performance path

4 that's simulation based which might pull into

5 it a lot of other things that provide value,

6 like you use this tool to comply but you also

7 use it to demonstrate your compliance with

8 Energy Star and do other things that might be

9 valuable to your business.

10 So there might be another path

11 here which, just call it, for lack of a better

12 term, a simulation based performance

13 compliance that might be a more robust and

14 provide even other opportunities beyond those

15 described in the options you have here but

16 might be consistent with this.

17 So I just wanted to throw that on

18 the table because I'm sure we're going to come

19 back to this.

20 MEMBER LACEY: Yes. And I'd

21 certainly be open to that. I think the reason

22 why I started with these three is because
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1 they're kind of known quantities, and people

2 tended, as I heard, people were familiar with

3 the UA calculation and with REScheck, and so

4 it seemed like it would be a pretty seamless

5 thing even if you had to change the baseline

6 to continue using that sort of approach or

7 that program.

8 Did you have a specific

9 performance path in mind? Are you talking

10 about the performance path that's built into

11 the IECC? Are you talking about HERS? Or do

12 you have a specific model that we could look

13 at to, you know, kind of evaluate?

14 MEMBER LEVY: Well, conceptually,

15 we went to an IECC, and what's called a

16 performance path is a number of rules about

17 how to do performance but it's not an actual

18 tool. REScheck is an actual tool and it's

19 closer to what I'm trying to get at here. 

20 REScheck is not quite as robust as

21 what it could be, but that's the kind of

22 thinking that I think is the direction we
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1 ought to be and are heading in or at least

2 talking about.

3 So IECC has a bunch of rules if

4 you want to do a performance path. I think we

5 could be much more defined about what the

6 performance path is. It may be even created,

7 as a result of this activity create a piece of

8 software that all the companies use and do

9 these things and more.

10 MEMBER LACEY: Okay. All right,

11 are there other thoughts? Questions about

12 this?

13 Manny?

14 MEMBER SANTANA: Manny with Cavco. 

15 I like the framework. I'm okay with doing the

16 prescriptive path and then the other two

17 performance paths. I don't have a problem

18 with that at all.

19 I just think as we continue we

20 want to focus more on what parts of the

21 mandatory sections, not just what sections

22 apply and which ones obviously don't apply,
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1 but also what parts of the mandatory sections

2 are useful and apply to manufactured housing.

3 MEMBER LACEY: Yes, absolutely.

4 MR. HAGERMAN: And so this is Joe

5 Hagerman. I totally agree with you. It would

6 be nice to have like a subcommittee to start

7 going through those sections and say this one

8 does apply and this one doesn't, right, and

9 here's why. Else we're going to be kind of

10 spinning our wheels.

11 MS. HOFFMAN: And Manny, I have a

12 feeling you haven't headed up a subcommittee.

13 MEMBER SANTANA: I knew I was

14 getting baited.

15 MEMBER LACEY: Does anyone else

16 want to speak?

17 MS. HOFFMAN: Is that something

18 you could tackle?

19 MEMBER SANTANA: Yes. Yes, I

20 think so.

21 MS. HOFFMAN: Thank you.

22 MEMBER EZZO: This is Mark Ezzo. 
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1 Manny, I'll help you with that.

2 MS. HOFFMAN: Who's speaking? Oh,

3 Mark Ezzo, thank you.

4 MR. HAGERMAN: I mean if the

5 manufacturers could do that and then wherever

6 possible if you said, I mean you have, you

7 know, you're a smart guy. If you axe out a

8 section that you don't think applies but you

9 know somebody else in the room, I'm not

10 calling out names, but like Luby might

11 disagree with you, right, you might want to

12 write that down why it does or doesn't apply,

13 right.

14 MR. RAMIREZ: Well, so would it

15 make sense to put someone like Luby on that

16 committee?

17 MS. HOFFMAN: Yes, but we'll give

18 a deadline.

19 MEMBER LACEY: And I could

20 volunteer as well. I mean I'm familiar with

21 how the IECC works but not so familiar with

22 how manufactured design works.
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1 MS. HOFFMAN: So Manny, Mark Ezzo,

2 Luby and Eric. Okay. If anyone else wants to

3 join --

4 MEMBER KESSLER: This is Bert.

5 MS. HOFFMAN: Bert?

6 MEMBER KESSLER: Bert at Palm

7 Harbor. Count me in.

8 MS. HOFFMAN: Okay, Bert.

9 MEMBER KESSLER: And Eric, can I

10 ask you a quick question here?

11 MEMBER LACEY: Sure.

12 MEMBER KESSLER: When we're

13 talking about prescriptive path, aren't we

14 assuming that whatever we're putting in a

15 cavity will actually work? For instance, if

16 I put in R-19 in a wall, in a 2x6 wall, I

17 don't think REScheck right now considers that

18 as it relates to compression.

19 MEMBER LACEY: Yes, you raise a

20 good point. And I'm sorry, I think you raised

21 this yesterday and I never circled back with

22 an answer.
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1 The prescriptive table in the

2 IECC, I think it's footnote A of the

3 prescriptive table, actually says that if you

4 are compressing the insulation you have to use

5 the compressed value not the nominal value of

6 the insulation.

7 And that's one of these things,

8 there are two bullet points under each of

9 these paths. The first bullet point says you

10 need to meet these other requirements, these

11 specifics, and I think that's the sort of

12 thing that would be in there.

13 It's not just meeting a nominal

14 R-value. There are specific insulation and

15 installation requirements that are in there. 

16 And again we could go through these and decide

17 what applies and what doesn't.

18 But that might be a good one, you

19 know, to say that if you're installing

20 insulation that it's not just the nominal R21 value but the, you know, if it is compressed

22 then you have to use the actual compressed
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1 value. Does that answer your question?

2 MEMBER KESSLER: Yes. I just

3 wanted to point out if that's the case then

4 for a floor assembly, as an example, we really

5 couldn't use a prescriptive path like it was

6 suggested, I think Luby did, because we're not

7 going to be anywhere near what that U would be

8 if we had actual R-values that could be

9 installed.

10 MEMBER LACEY: Yes, and I'm not

11 proposing any specific values here. You know,

12 I think I say starting with the 2015 IECC

13 specifications, but if it's going to be

14 impossible in the floor it's going to be

15 impossible. Or if it's going to be cost

16 prohibitive we need to consider that.

17 And so I think Luby, later, is

18 going to walk us through one possibility and,

19 you know, it may be that it matches most

20 construction types. But if it doesn't then,

21 you know, we need to find one that does. But

22 yes, that's a point well taken.
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1 MS. HOFFMAN: Mark?

2 MEMBER WEISS: Yes, Eileen, if you

3 would just add me to Manny's group.

4 MS. HOFFMAN: Okay.

5 (Off microphone comments)

6 MR. RAMIREZ: Membership closed.

7 MEMBER WEISS: I don't want them

8 to feel lonely.

9 MS. HOFFMAN: I think we've got a

10 good group, thank you.

11 MEMBER EZZO: This is Mark Ezzo. 

12 I just want to go back to what Eric was

13 offering up on those different performance

14 paths. And I fully support having

15 prescriptive, a REScheck manufactured housing

16 version and the Uo path. I think it's great

17 to have all three of those options.

18 I really am intrigued by the

19 prescriptive approach because I think it will

20 really simplify things for manufacturers,

21 retailers, everybody else involved. So I'm

22 really interested in hearing what Mike
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1 Lubliner has to say in terms of a

2 recommendation for a prescriptive approach.

3 MR. RAMIREZ: Is that our

4 transition? Is this all that we need to

5 discuss on this and then we go to Lubliner's

6 strawman?

7 MEMBER SCHNEIDER: This is Peter

8 Schneider. Just one other note with regards

9 to, you know, a HERS index. You know, as our

10 appraisal industry is moving to recognizing

11 energy efficiency upgrades, they are going to

12 be utilizing the HERS index which is already

13 included in a number of states' MLS listings. 

14 And so I think it would behoove

15 the manufactured housing industry to begin

16 moving in that direction so their houses can

17 be evaluated in an apples to apples comparison

18 with stick-built housing that has HERS

19 indexes.

20 MEMBER LACEY: I can maybe speak

21 to that. This is Eric. I agree that, you

22 know, in the future I think that might be a
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1 good target.

2 There are some challenges with the

3 current HERS method. For example, there are

4 penalties for having a smaller sized building

5 and you get a break for getting a larger sized

6 building.

7 There are a number of reasons why

8 and I'm not sure I agree with all of them, but

9 that seems like there are some unintended

10 consequences there that might apply to a

11 smaller building like a manufactured home. 

12 I'd very much like for the HERS

13 index or an energy rating index to work. I'm

14 not sure we're quite there yet. And that's

15 why I suggested that you tee it up as a

16 potential issue for either the next iteration

17 here or possibly for Energy Star or above code

18 sorts of programs. That it may take a little

19 more work, you know, with RESNET or with BPI

20 or somebody else to come up with the right

21 index standard for manufactured housing, but

22 I'm not sure that we're there yet.
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1 If there's anyone in here or a

2 manufacturer that's using this, I'd love to

3 hear from you because I'm interested in how

4 this is applied to manufactured housing.

5 MR. RAMIREZ: Sounds like no

6 takers on that.

7 MEMBER LUBLINER: So I could speak

8 a little bit to the RESNET. I'm on the RESNET

9 technical committee and the guy who works for

10 me is the vice president of the board.

11 And we've talked with Steve Baden

12 and the RESNET board about this initiative

13 going on right now in the ASRAC, and I think

14 that down the road they would be very

15 interested in addressing the needs of labeling

16 for consumers and for even contractors and

17 looking at the HUD certificate and trying to

18 come up with a system that it would be

19 legitimately recognized by the lenders that

20 are recognizing the existing rating for site21 built.

22 But I do agree that that's farther
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1 down the road and we have a lot of other more

2 important fish to fry right here with the

3 minimum.

4 And I like Emanuel's idea of

5 trying to not have two separate systems for

6 the voluntary program and the mandatory, if

7 you could allow that to be one tool. And if

8 that's a simulation tool REScheck would have

9 we can talk about that.

10 I had one comment on if you scroll

11 up where you reference the ASHRAE handbook, I

12 believe. Anyway I just wanted to point out

13 that we should probably include the ASHRAE,

14 and we should probably include the work that

15 PNNL's done that's published by HUD on how to

16 do the U-value calculations in accordance to

17 the procedures you guys use and include that

18 as a reference there as well.

19 MEMBER LACEY: Okay, yes. Just

20 for clarity, I just pulled this language out

21 of the IECC, and so yes, that's something we

22 could certainly tweak and make it very
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1 specific.

2 I just put that up there as,

3 because I did such a poor job of explaining

4 the UA yesterday, I just took their language.

5 MS. HOFFMAN: Now do we have

6 copies of this?

7 MR. RAMIREZ: Yes. I will send it

8 out.

9 MEMBER LACEY: Okay.

10 MS. HOFFMAN: And do you want to

11 incorporate Luby's suggestion to include the 

12 PNNL there?

13 MEMBER LACEY: Yes, we can. I'm

14 not sure how to word that but --

15 MEMBER LUBLINER: Just put in

16 right after Handbook of Fundamentals and/or

17 PNNL. What's the title of that? U-values for

18 manufactured housing. We'll get you the right

19 --

20 MEMBER LACEY: Yes, we can work

21 that out later. Okay.

22 MEMBER LUBLINER: Anyway.
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1 MEMBER LACEY: Understood.

2 MEMBER LUBLINER: Just put a PNNL

3 play soldier there right now.

4 MEMBER LACEY: Okay.

5 MEMBER LUBLINER: It's Conner, I

6 believe, is the author. Conner and Lucas.

7 MEMBER LACEY: All right. Any

8 more questions?

9 MR. RAMIREZ: So any other

10 questions for Eric? Thank you.

11 MS. HOFFMAN: Thank you very much.

12 MR. RAMIREZ: Okay, I want to get

13 Michael set up, up here.

14 (Off the record comments)

15 MEMBER LUBLINER: So thanks

16 everyone. I don't know that we'll need the

17 full hour, but I'm going to try to go through

18 just this kind of concept, and don't shoot the

19 messenger.

20 It all revolves around something a

21 guy named Milt Miner from Fleetwood Homes told

22 me when I first started working in this
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1 industry, and that's Murphy shows up on

2 special orders, and that standardization has

3 made this industry what it is.

4 And we learned a lot from that as

5 we developed our $100 million partnership

6 between the utilities that wanted to do energy

7 conservation and an industry that needed

8 resources to help the buyers.

9 So I'm approaching this with a

10 keep it simple approach here. And what I've

11 tried to do is think, after having a few years

12 in this industry and dealing with issues is

13 what's kind of, what are the measures that

14 make sense throughout the country in terms of

15 lost opportunities?

16 So we just spent about, the

17 utilities in the Northwest were spending and

18 the Department of Energy weatherization

19 programs are spending about $8,000 to $12,000

20 a house, a HUD code home, to weatherize them

21 after the fact. And it just seems like if we

22 had some of that money to put in up front we
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1 would avoid the lost opportunities.

2 And so where are those lost

3 opportunities? Well, one of the things that's

4 been real expensive is adding insulation to

5 the belly. And again what I'm hoping to do

6 here is just throw out this.

7 I'm not claiming this is, quote,

8 cost effective to everybody in every sale and

9 every fuel type and everything, but just

10 throwing out the concept here.

11 So I've broken it out and this

12 gets back to Mark Ezzo's comment and Bert's

13 comment. When I say nominal R-value it's kind

14 of the way we do it in the Northwest. We say

15 nominal R-value, it is what it is.

16 If it's compressed it still has a

17 nominal R-value and we'll accommodate the

18 compression one way or another. We'll either

19 make an exemption of it or consider it in the

20 overall calculation. So that's a really

21 important point.

22 So what I was thinking is, is
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1 that, really, the belly, the insulation in the

2 floor is something that's really hard to add

3 after the fact down the road.

4 And warm floors are nice. There's

5 a lot of thermal distributions systems in the

6 floor. There's probably some energy savings

7 from adding insulation there to the thermal

8 distribution system that's icing on the cake

9 and isn't counted in the modeling.

10 So what I'm suggesting is that we

11 stay with the R-30 in the belly and just add

12 a high density R-21 to the joist space. And

13 that's across the board in any climate zone. 

14 My feeling is is that we're

15 probably talking in terms of cost, the

16 additional material and labor cost,

17 associated, let's say, in zone 1 with adding

18 the R-21, and that's the rules of thumbs that

19 I've been using for over the years are a penny

20 per R per square foot.

21 And we should probably go to see

22 if that rule of thumb is something you and I
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1 jive on or how far off we are if that's an

2 acceptable metric. But anyway so that's the

3 floor. So regardless of the climate zone, you

4 put a blanket in and you add 21 in the joists. 

5 And the 21 can be added in any 2x6

6 joist without any compression. There will be

7 some compression of the R-11 in the belly, but

8 that's really a function of how much you allow

9 the belly insulation to sag.

10 And so this is an area that we

11 could get into more technical discussion but

12 not right now. But that's what I'm talking

13 about. I'm saying, okay, it is what it is. 

14 It's compressed. There's some compression but

15 it's a nominal R-21 with a nominal R-11 in the

16 belly.

17 Okay, so the walls. What I

18 learned from the codes in site-built was we

19 had R-11 in many of the walls in this country

20 and they upped it to R-13 which required a

21 higher density fiberglass and was more

22 expensive. It was about a 1.2 cents per R per
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1 square foot wholesale.

2 And over time as the manufacturers

3 of the insulation started making more

4 insulation that was high density the price

5 came down. So that's something to explore. 

6 Is a high density R-21 or a high

7 density R-15 bat something that if it was

8 procured in the volumes here would represent

9 something about a 1.2 cents or less per square

10 foot?

11 But I think it's appropriate that

12 in zone 1 that we don't need to change the

13 framing from 2x4. We can stay with 2x4 but

14 let's max out the insulation level with high

15 density bat.

16 The same philosophy would hold

17 true in zones 2 and 3 except now we have a 2x6

18 wall. In all cases, assuming 16 inch on

19 center. Some manufacturers might make more

20 efficient framing but that's the assumption. 

21 And then if you look under my

22 footnote there, we're talking about insulated
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1 headers. So there's an expense associated

2 with solid headers that are a thermal bridge

3 in the framing. But the details of the

4 framing factors can be discussed.

5 I just want to throw this out as a

6 nominal. Is R-15 in a 2x4 something to

7 explore, and is R-21 in a 2x6 with the current

8 practice walls that you're building? All

9 right, so then we get down to the ceilings. 

10 This is another area where

11 weatherization is kind of a lost opportunity. 

12 If you don't blow it in right, there's no

13 attic you can go up into and do it later. So

14 this is one where I would argue, you know,

15 let's skip the blow right and let's get the

16 insulation in the floors, the walls, the

17 ceilings. These are areas that you're not

18 going to be able to change out.

19 So I'm suggesting again it is what

20 it is. The U is what it is when you taper. 

21 So if you have a certain truss and it tapers

22 down, I think typically to about a 5-1/2 inch
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1 minimum heel height is where the industry is

2 going but not always, that that's what you

3 get. So what I'm talking about is a nominal

4 R-value of R-38 at the kingpost, I think,

5 that's the highest point, and tapering down to

6 whatever the heel height is paralleling the

7 roof slope.

8 And we have details of this in our

9 quality assurance manuals. So it would be R10 38 in zones 1 and 2 and again a nominal R-49. 

11 So there we might be talking about 14 to 16

12 inches of blown as opposed to 11 to 13 inches

13 of blown at the kingpost, again tapering down. 

14 So we address the compression by

15 adjusting the U-factor, but we base everything

16 off this standard.

17 The next one would be the windows. 

18 So the windows is one I'm having a little

19 issues with because the industry's used

20 historically these interior storm windows and

21 things.

22 So I'm making the paradigm shift
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1 away from interior storms or storm windows at

2 all in new homes, going to a prime window. 

3 And I'm suggesting that we investigate whether

4 it's appropriate in HUD zone 1 that we have a

5 double paned vinyl window. And with a Low E

6 coating on it, which once you get to the

7 double pane jump in cost is not that expensive

8 and will get you the solar heat gain

9 coefficient options that Eric was talking out. 

10 So a 0.35 window, and then going

11 to add argon to the window in zones 2 and 3

12 would give it a 0.30. These are windows that

13 our manufacturers, 60 percent of our

14 manufacturers in the Northwest have been

15 installing for over ten years.

16 Duct tests. I think it's

17 appropriate that -- oh, excuse me. Before we

18 go into that I wanted to point out that the

19 NFRC is the U-factor that I would recommend

20 that we use for designating a window's U-value

21 and also its solar heat gain coefficient.

22 So back to the windows. I have
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1 the 0.35 as the U-value/0.25 is the heat gain

2 coefficient. So there would be a requirement

3 of 0.25 for solar heat gain coefficient in

4 climate zones 1 and 2 and no requirement in

5 zone 3.

6 Duct leakage. Oh, excuse me. One

7 other thing. I am interested in getting

8 feedback on awnings, exterior awnings. I did

9 a net zero energy home with KIT Homes a few

10 years ago with the Bonneville Power

11 Administration, the Nez Perce Tribe, and KIT

12 offered these exterior awnings that could be

13 adjusted and provided shading and would

14 significantly reduce the air conditioning load

15 to the house.

16 There might be some tradeoffs

17 there with that and other ways of minimizing

18 solar gains. And as I pointed out, I think in

19 one of the MHI sizing guides is that if you do

20 put some sort of a Low-E that has a reasonable

21 solar heat gain coefficient on windows in air

22 conditioning climates you can reduce the size
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1 of the air conditioner by half a ton.

2 That doesn't impact the cost of

3 the price to the retailer because that's

4 something the manufacturer, it's out of the

5 manufacturer's realm, but it's something that

6 I think is pretty important that we look at

7 other options for solar heat gain control.

8 But regardless of which option you

9 use, one could argue that there's some cost

10 savings on the HVAC system even though it's

11 not in the sales price of the home to the

12 dealer.

13 Anyway that's a nuance. Let's get

14 into the duct leakage. So what I'd like to do

15 is we worked quite hard on the Manufactured

16 Housing Consensus Committee for years to get

17 a requirement for duct testing that was

18 approved by the committee and is awaiting HUD

19 to promulgate.

20 I think that was four percent of

21 floor area. I go back to my notes, but

22 whatever it was I think it was a good
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1 agreement. We should stick to it and

2 prescribe that as the duct leakage testing. 

3 I know from talking with some of

4 the folks in the industry that many

5 manufacturers were willing to go into testing

6 duct work because it was a good quality

7 assurance thing that made business sense to

8 them and avoiding moisture issues and

9 particularly in the hot, humid climates.

10 So under duct testing I would say

11 let's use whatever that's in the Manufactured

12 Housing Consensus Committee came up with in

13 terms of the leakage rate tested at floors. 

14 Real simple. We do that in the Northwest. 

15 And I threw out one floor per week

16 or one per 40 floors, but whatever we came up

17 with in the consensus group we should look at

18 that as the frequency. 

19 And I think if this stuff was in

20 the QA plan of the HUD manual it would really

21 allow us to adjust that based on the

22 performance in the factory. In other words,
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1 if homes were failing to meet whatever that

2 percent, four percent of floor area leakage

3 value they would have to test more frequently. 

4 And that's kind of the process I believe the

5 industry's using now for all of their quality

6 assurance.

7 But let's stick to something we

8 already agreed to years ago and I've been

9 waiting for HUD to do. On the envelopes

10 leakage there was some concern, and I think

11 well placed concern by the industry that, you

12 know, getting down to like 3ACH50 like the I13 codes have is pretty tough to do.

14 Our random studies that we do of

15 the 100,000 homes we've built over the years,

16 we go out and select every four or five years

17 a random selection of them and go out and test

18 them. And we would be hard pressed even in

19 our program to achieve 3 in all cases.

20 Maybe 3-1/2 is an average that

21 you're 20 years of working. I think it's not

22 really the number you achieve, it's whether or
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1 not you're achieving a good quality assurance

2 process in the factory that tells you what to

3 seal, when to seal it with, what material and

4 who checks.

5 And this gets back to my reference

6 in the quality assurance plan and the proposal

7 I made to the Consensus Committee that they

8 punted to us, which is if we have explicit

9 details that can be enforced about this gets

10 caulked, this is how you caulk the P-trap,

11 this is when you caulk the ceiling fan

12 penetration, and a good checklist like

13 something that's used in Energy Star, then it

14 doesn't really matter what the number is,

15 we're going to have good practice.

16 There was also some discussions

17 going on about the cost burden of testing

18 multi-section homes in the factory

19 periodically because they have to be set up. 

20 And I think that we can learn everything we

21 need to learn.

22 Really, this testing thing is more
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1 for a feedback to the plant so that they

2 understand that their quality assurance

3 procedures are being achieved. So when you

4 test a single section home you're going to get

5 that feedback which can be applied to all the

6 homes whether they're multi-section or not. 

7 So one thing as a possible

8 compromise to consider would be just pulling

9 single section homes out and testing them and

10 then we can sit down and work out, is there a

11 viable way of cost effectively testing the

12 multi-section homes in their own individual

13 sections?

14 Emanuel and I have had a little

15 few discussions. It's more, that's research

16 based, that's down the road. Can you,

17 basically, with the closure up, the plastic

18 over the section, depressurize it and get a

19 relatively good number and account for the

20 leakage associated with the temporary close21 up?

22 But again I don't even think we
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1 need to go there. I think we can learn

2 everything we need to learn from testing the

3 single wides and applying the quality

4 assurance. So that's a compromise, I think,

5 trying to leave it at five-year changes now,

6 which I think is much more reasonable and a

7 good QA program.

8 Pipe insulation on the hot water

9 pipe, like in the I-codes, I think it's, is it

10 R-4? I did this like midnight. But whatever

11 the proposed insulation value that has some

12 real benefits too.

13 When I wake up in the morning, I

14 have a 66-foot home and about 60 feet from my

15 water heater is my shower. So the good news

16 is I get about a minute of pushups before the

17 hot water is warm enough to get in the shower. 

18 The bad news is I've wasted a minute's worth

19 of hot water down the drain.

20 So there's some energy saving and

21 some benefits in terms of water savings, I

22 believe, in looking at that insulation option. 
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1 And then on the crossover ducts, I think we

2 came to some agreement and it's in the HUD

3 rule that R-8 seemed to work everywhere in the

4 country.

5 So that's what I was going to

6 propose. That's pretty much what I was

7 thinking about. I want to open it up because

8 I know, again I'm not saying that this is cost

9 effective in all cases and all climates or

10 anything, but it's a simple approach.

11 It really doesn't vary much. It's

12 almost a one-size-fits-all approach. You do

13 this and when you could get a house and we

14 account for the compression that's already in

15 the houses that happen to have more

16 compression while they use this path, they

17 maybe aren't going to perform exactly the same

18 but we've addressed the issue of buildability

19 there and come up with a simple approach.

20 So anyway that's kind of the idea. 

21 Again we can horse trade on the numbers and

22 the zones and stuff, but that was kind of what
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1 I was thinking about.

2 MR. RAMIREZ: Questions?

3 MEMBER LUTER: This is Rob Luter. 

4 I'd like to chime in on the window performance

5 if I can?

6 MEMBER LUBLINER: Thank you, Rob,

7 I would appreciate that.

8 MEMBER LUTER: Just a couple

9 adjustments. The, and pardon me if I sound a

10 little broken up. I'm hearing an echo and

11 it's really kind of disturbing to me.

12 MR. RAMIREZ: You're fine on this

13 side.

14 MEMBER LUTER: In any case, HUD

15 zone 1, I think your assumption that a vinyl

16 Low-E dual glazed window will make a 3.5

17 U-value is correct. The solar heat gain will

18 be closer to 0.28 with standard Low-E. What

19 I'll call commodity Low-E.

20 HUD zone 2 Low-E with argon will

21 get you down to about a 3.1 U-value. To get

22 down to a 0.30 you're also going to need an
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1 enhanced glass spacer system which adds

2 significant cost. Again, the solar heat gain

3 about 0.28 with regular Low-E.

4 And could you scroll over to HUD

5 zone 3 for me please? I'm not seeing that on

6 the screen. Okay, again --

7 MEMBER LUBLINER: Same as two.

8 MEMBER LUTER: Again, 0.31 would

9 be more accurate on the U-value with that

10 building materials there.

11 I think the industry will agree

12 with me back when the tax credits were issued

13 for the 0.30, 0.30. There was a lot of

14 scrambling going on to get from 0.31 onto

15 0.30.

16 Now I'll add that on the solar

17 heat gain for zone 1 and zone 2, 0.25 is

18 achievable it just takes an enhanced Low-E

19 product that adds additional cost.

20 MEMBER LUBLINER: Thanks, Robert. 

21 I made those changes and we should probably

22 look at what that additional cost to the 0.28
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1 and the 0.25 is and what the savings, but I

2 suspect that it's minimal. And I certainly

3 think that this, what you just told me, is

4 helping to refine and update this to reflect

5 reality at least of the E-values.

6 Eric, maybe I should draw on you

7 on that one, on the 0.28.

8 MEMBER LACEY: Yes, this is Eric. 

9 I just wanted to put out, I do have, I have

10 some information.

11 Energy Star, when we're working on

12 Version 3, again, this is for, you know,

13 stick-built homes, but the windows, the

14 insulated glass unit should be the same from

15 one, you know, build to the next.

16 They have some costs data in here

17 that I think is interesting and useful. I

18 mean I think getting from a 0.28 SHGC down to

19 like a 0.25 or a 0.22 is, I think, just

20 another coating. Another layer of coating

21 which is pretty inexpensive.

22 But I think that's something we
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1 should talk about, you know. What the right

2 level is and, you know, if it's a very minimal

3 cost.

4 But if it reduces the size of the

5 air conditions or something, you know, this

6 stuff all balances out pretty nicely, so. 

7 Anyway, that's something we should probably

8 continue to discuss.

9 MEMBER LUBLINER: Yes. Perhaps

10 what we can do is get PNNL to do a sensitivity

11 stay. Looks at 0.28 versus 0.25 and get Rob's

12 cost differential with the manufacturers input

13 and we can do that.

14 But again, I suspect it's not

15 going to make a lot of difference. It was

16 certainly to get Low-E in the house and with

17 people.

18 The things that really happen if

19 people use awnings and shades and things that

20 probably will result in adequate solar heat

21 gain savings.

22 MEMBER TOMPOS: Dave Tompos. 
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1 Michael, I think this is a good start for

2 prescriptive method. You know, I mean we'll

3 have to get into some of the specifics on

4 whether or not some of this is cost-effective

5 or not.

6 MEMBER LUBLINER: Yes.

7 MEMBER TOMPOS: One of my concerns

8 is, you know, to be able to say, hey, we're

9 putting in R49 in the roof and we're not

10 worried about the taper or how that, what that

11 actual value is.

12 We need somebody to look at the

13 FTC requirements on what these manufacturers

14 are going to report when they're done building

15 this home because they can't put, I'm putting

16 in R49 in the roof if it's not an actual R49

17 roof. So I just want to make sure we're

18 addressing that issue.

19 MEMBER LUBLINER: Do you want me

20 to feedback and then, I know you have some

21 others there? So let's start on that one.

22 So I totally agree. You and I
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1 have talked about, what does the FTC really

2 have. And I think that's an important liaison

3 discussion with DOE and FTC.

4 Explain the context, get them in

5 here and, I mean right now what's going on is

6 the tapering is happening and our nominal

7 R-values are being put out. I think, you

8 know, we need to be careful how we approach

9 that because we don't want to get ourselves in

10 trouble for what we're doing now.

11 But I think it's, disclosure is

12 good. I think that the intent, we're not

13 trying to misrepresent to the consumer, which

14 is really what the FTC is really worried about

15 in some cases. In all cases.

16 So I think it would be a healthy

17 discussion to say, hey, what can we do so that

18 we can advertise this as a nominal R-value

19 with whatever the footnote is that says

20 accounting for compression associated with the

21 construction.

22 But those are clearly issues, I
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1 don't want to propose a prescriptive path that

2 gets us in trouble with the Federal Trade

3 Commission. So you had some more concerns.

4 MEMBER TOMPOS: Just to comment on

5 what you just said. To say it's happening now

6 --

7 MEMBER LUBLINER: I don't know if

8 --

9 MEMBER TOMPOS: I don't think it

10 is.

11 MEMBER LUBLINER: Okay.

12 MEMBER TOMPOS: We're very

13 critical, even though it's not a requirement

14 of the HUD standards, we're in business to

15 protect the manufacturers from getting sued. 

16 So we have been very critical on making sure

17 they're reporting proper values.

18 I think it maybe happening outside

19 of the manufactured housing industry, but --

20 MEMBER LUBLINER: Yes.

21 MEMBER TOMPOS: -- that's a

22 compliance issue for somebody else.
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1 MEMBER LUBLINER: I apologize, I

2 didn't mean to misconstrue that. What I was

3 thinking is, is sometimes I'll see like a

4 literature advertisement of the insulation

5 package in some sales literature and it will

6 say, R19 walls or R38 in the roof. And

7 clearly that's the nominal value.

8 And there is compression going on. 

9 So I think nipping this in the butt and having

10 a good discussion with FTC so that there's no

11 question whatsoever what we mean and that is

12 a healthy thing, so.

13 MR. RAMIREZ: Yes, I don't think

14 they were too concerned about that right now.

15 MEMBER LUBLINER: Okay.

16 MR. RAMIREZ: Did you have a

17 follow-up question?

18 MEMBER TOMPOS: No, no. Again, I

19 just think --

20 MEMBER LUBLINER: Thanks, Dave, I

21 really --

22 MEMBER TOMPOS: -- this is a great
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1 start.

2 MEMBER LUBLINER: I very much

3 appreciate your input and support to the

4 concept.

5 MEMBER SANTANA: Yes Manny, Cavco. 

6 I agree that I think this is a great starting

7 point. You know, I'd like to commend Luby for

8 putting this together.

9 This gets to elements that are

10 important, and to HUD construction and that

11 HUD construction can control. You know, these

12 are part of the elements that we need to be

13 thinking about. You know, there's no fluff or

14 anything like that.

15 So I, like I said, I think this

16 sets the stage for what we need to discuss. 

17 I have questions and, on some of the values,

18 you know, but that's a great place to start.

19 MR. RAMIREZ: Well, and you guys

20 are on the same subcommittee so maybe you

21 could --

22 MR. HAGERMAN: No and, Manny, if
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1 you have some quick, you know, edits to this

2 we could run that in addition to running this. 

3 It's very easy to do these runs the way we've

4 gotten it setup.

5 MEMBER SANTANA: Yes. I can think

6 of some that maybe, you know, right off the

7 top. I see Note Number 2.

8 From manufacturers that are using

9 tested headers it might be tough to get

10 insulation in there, you know and safe to say

11 an R5. What's an R5 in a rigid board, is that

12 half inch or is that three-quarters of an

13 inch?

14 MEMBER LUBLINER: Yes, one inch of

15 --

16 MEMBER SANTANA: One inch.

17 MEMBER LUBLINER: -- pink board --

18 MEMBER SANTANA: Right.

19 MEMBER LUBLINER: -- or

20 three-quarters of an inch of foil faced

21 isocyanurate.

22 MEMBER SANTANA: Right, so if you
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1 have, so say if you have a 2x6 wall you have

2 two half inch ends. So it wouldn't be a

3 problem there, right. But of you got 2x4

4 walls you only have a half inch end.

5 MEMBER LUBLINER: I try.

6 MEMBER SANTANA: So that may have

7 to be adjusted. And then little things like

8 that then we have to see, you know, the R38,

9 the kingpost, tapered to the truss heel, that

10 seems very doable, you know. It won't be an

11 effective R38 that you have, that you get in

12 the roof, as Dave said.

13 But I mean as far as how this

14 thing can work, the R15 as a standard in the

15 walls I think might be a little much for zone

16 1. But, you know, stuff like that is what we

17 have to discuss. But overall I think it's a

18 great start.

19 MEMBER LUBLINER: Thank you.

20 MR. RAMIREZ: So a couple

21 follow-ups then. It sounds like we need to

22 run the KISS straw man, right? That's what
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1 you're calling it, Luby?

2 MR. HAGERMAN: It's the KISS-Luby

3 Proposal.

4 MR. RAMIREZ: The KISS-Luby

5 Proposal.

6 MEMBER TOMPOS: Dave Tompos. Why

7 did you use R4 on the waterlines when IECC

8 uses three? I just want to make sure we're

9 not using any --

10 MEMBER LUBLINER: Because it was

11 midnight last night, I couldn't remember what

12 it was.

13 MEMBER TOMPOS: Oh, okay.

14 MR. HAGERMAN: Which is R3.

15 MEMBER TOMPOS: It should be R3

16 and --

17 MEMBER LUBLINER: My bad. I heard

18 a real interesting presentation by Gary Klein,

19 who is the water guru on this stuff, and he

20 said for the commercial buildings what they

21 say is, whatever the diameter of the pipe is,

22 that's the thickness of the insulation that
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1 you should use. We don't need to be that

2 complicated, R3 works for me.

3 MR. RAMIREZ: So you could change

4 it on here so we can print it out?

5 MEMBER LUBLINER: Yes, absolutely.

6 MR. RAMIREZ: Okay.

7 MEMBER LUBLINER: I can do that

8 right now.

9 MR. RAMIREZ: So the question I

10 have is for the KISS-Luby study, we're going

11 to be doing the, a PNNL study on those?

12 MR. HAGERMAN: I'm sorry, say it

13 again?

14 MR. RAMIREZ: Did you said it was

15 -- MR. HAGERMAN: Yes. No, PNNL can

16 run this. Let me just be clear. I think Rob

17 Luter said that the windows should be changed

18 to 0.35, 0.28, 0.31, 0.28 and 0.31.

19 MR. RAMIREZ: Got it.

20 MR. HAGERMAN: All right. And

21 then --

22 MEMBER LUTER: This is Rob, let me
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1 offer clarification there. That is the

2 performance that would be reflective of the

3 construction attributes he has listed.

4 MR. HAGERMAN: All right. And

5 then you mentioned something about the HUD

6 zone 2 windows being extremely expensive, do

7 you have alternate that you'd also like to

8 run?

9 MEMBER LUTER: I'm not sure I said

10 that.

11 MR. HAGERMAN: Okay, sorry.

12 MEMBER LUTER: The point I was

13 making was that with respect to the solar heat

14 gain that was previously shown, that is

15 achievable with a Low-E product different than

16 I assumed he was considering. It's an

17 enhanced product.

18 As Eric put it, it has an extra

19 layer on it. There's extra cost, there's less

20 economies of scale that comes in.

21 MR. RAMIREZ: Yes, Eric.

22 MEMBER LACEY: This is Eric. I'd
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1 really like to see how the 2.5 SHGC comes out

2 for zone 1 and zone 2 because that's what's

3 required in the 2015 IECC and the 2012 as

4 well.

5 And I think it's going to come out

6 pretty cost-effective, especially when you

7 consider the cooling load issue and potential

8 resizing.

9 So anyway, it's a very common

10 technology that all the manufacturers offer,

11 it's just another coating and it's pretty

12 inexpensive. So if we could have, you know,

13 the numbers back on what a 2.5 SHGC would be

14 I think we'd benefit from that.

15 MEMBER LUTER: My point was to

16 dispute that it was achievable.

17 MEMBER LACEY: Got it.

18 MEMBER LUTER: My point was that

19 the, just plain Jane Low-E won't get you

20 there. It takes a more expensive product. 

21 And maybe that's cost-effective.

22 MEMBER LACEY: Understood.
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1 MEMBER LUBLINER: I think what I'm

2 hearing is we need to get the costs and do the

3 simulation for the savings and see whether

4 there's a justifiable bang for the buck to go

5 down 0.25 from 0.28. And yes, I totally, I

6 think that's appropriate.

7 So I bolded the ones that are

8 questions that we want to --

9 MR. HAGERMAN: So we'll add that

10 --

11 MEMBER LUBLINER: -- kind of

12 refine.

13 MR. HAGERMAN: We'll add that as

14 the Eric-KISS-Luby Proposal.

15 MEMBER LUBLINER: Thank you.

16 MR. HAGERMAN: All right.

17 MEMBER LUBLINER: Thank you. And

18 also, Rob, just to, some of the people that

19 I've been talking to, Cardinal, you probably

20 have the cost data, but they said they'd be

21 much, very welcome to talk with you all about

22 the Low-E since that's, they manufacture the
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1 Low-E.

2 I don't know if you're using them

3 or other manufacturer, but they were engaged

4 in this discussion and offered their

5 assistance if needed. Thank you everyone.

6 MR. RAMIREZ: Hold one yet.

7 MEMBER LUBLINER: Oh, we got more?

8 MEMBER EPPERSON: It's not a

9 question, just comment. I think it's a great

10 place to start, it's close to our

11 specifications. Amy and I are looking at

12 this.

13 It's simplistic that it's just,

14 you know, the HUD zones in a way I think the

15 industry looks at it, so I think it's a good

16 start.

17 MEMBER LUTER: Thank you.

18 MEMBER EPPERSON: I still want to

19 nail down the subject just because --

20 MEMBER KESSLER: Hey, Luby, this

21 is Bert.

22 MEMBER LUBLINER: Hey, Bert.
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1 MEMBER KESSLER: I have known you

2 for a long time and I just can't believe that

3 you actually put in writing, U is what it is.

4 MEMBER LUBLINER: So long as the

5 FTC lets us do it, it's okay with me.

6 You know, I think that really, if

7 we were able to implement a good quality

8 assurance procedure on terms of how we put the

9 insulation in the walls and the ceiling and

10 you have that, whether it's bat counts or

11 depth charts or a QA plan that says no voids,

12 you know, or minimize voids, I think really

13 that's what we're trying to get to is, and

14 recognizing that we do want you to have to go

15 to 2x8's if you're building 2x6, that doesn't

16 make any sense if we can just degrade the

17 U-value assumption and stay with something

18 that may work and is simpler.

19 But yes, I, a lot of this stuff

20 came from working with you over the years too,

21 Bert, so thank you.

22 MR. RAMIREZ: We have a --
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1 MEMBER EZZO: Hey, Mike, this is

2 Mark Ezzo at Clayton.

3 MR. RAMIREZ: Go ahead Mark.

4 MEMBER LUBLINER: Hey, Mark.

5 MEMBER EZZO: I think this is a

6 great start, really good work on your part. 

7 I really like the nominal R that you're

8 talking about there and, you know, the U

9 whatever it is is what it is. I think that's

10 perfect.

11 It prevents all of us

12 manufacturers from having to run thousands of

13 U-value component counts and figuring out how

14 to address compression and other things. So

15 I really like the simplicity of this.

16 Only question I have is on the

17 floor insulation where you're saying 11 belly

18 blanket plus 21. Is the 21 bat, is that going

19 just from the rim to the main rail or is that

20 going all the way across the floor?

21 MEMBER LUBLINER: That would be

22 the entire floor.
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1 MEMBER EZZO: Okay, not just the

2 outrigger area?

3 MEMBER LUBLINER: Yes, yes.

4 MEMBER EZZO: Got you, okay.

5 MEMBER LUBLINER: And I want to

6 say that --

7 MEMBER EZZO: And then --

8 MEMBER LUBLINER: I'm sorry, keep

9 going.

10 MEMBER EZZO: And then --

11 MEMBER KESSLER: As far as HUD --

12 MEMBER EZZO: Oh, I'm sorry, go

13 ahead.

14 MR. RAMIREZ: Go ahead Michael.

15 MEMBER KESSLER: Well my point

16 there was that we really have to look at how

17 that is to be installed. I guess my point too

18 is, and maybe that's too technical for this

19 audience, but if that bat goes below the edge

20 of the floor joist, then it essentially become

21 ineffective.

22 MEMBER LUBLINER: Absolutely. I
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1 think that, what we're trying to get to is

2 something that we've been trying to build in

3 the Northwest for many years with your

4 factories and make sure we minimize any

5 leakage paths that could reduce the

6 effectiveness of the floor insulation. So

7 yes.

8 MR. RAMIREZ: Joe?

9 MR. HAGERMAN: I've got a quick

10 question for David Tompos since he brought it

11 up. In those states that have the shipping

12 issues, are you going to have a problem

13 building this unit and shipping this unit? 

14 Does this unit solve that shipping problem

15 that you were talking about earlier?

16 MEMBER TOMPOS: Maybe. How about

17 that answer?

18 MR. HAGERMAN: That is not an

19 answer.

20 MEMBER TOMPOS: R49 still, I think

21 we're going to be a little shy of that in some

22 of the, I'm trying to draw up a diagram so
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1 that we can show where are limits are and how

2 much I can get in a single wide for that

3 specific region. So I'll have more

4 information next time.

5 MR. RAMIREZ: Okay, Stacy?

6 MEMBER EZZO: Hey, Dave, this is

7 Mark Ezzo, maybe this might help. You can get

8 49 at the kingpost like Mike's suggesting.

9 The challenge is because of the

10 taper of, or the geometry of, the single wide

11 trusses of the vaulted ceilings, the

12 manufacturers of the insulation that we buy

13 tell us how many bags of insulation we have to

14 blow in a ceiling to get R49. And they're

15 just physically isn't enough room in certain

16 trusses to put that many bags in.

17 So there maybe cases where if we

18 need to hit 49 that a truss geometry might

19 have to change.

20 And one of the reasons I like the

21 PNNL document where they limited the roof to

22 38, I thought that was a good concession. 
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1 And, Mike, I don't know if you're willing to

2 put your zone 3 down at R38 or not but that

3 might solve that problem of having to change

4 truss geometry.

5 MEMBER LUBLINER: I certainly

6 think we should look at the cost and the

7 benefit and if, see where it falls. But yes,

8 I understand what you're talking about.

9 Because the bat count becomes

10 problematic as you get, you're moving

11 insulation from one area to another and you

12 need to maintain a one inch air space. So

13 yes, I think that should be open for our

14 discussion.

15 MR. HAGERMAN: So is that a

16 recommendation that I run that --

17 MEMBER LUBLINER: Yes, please.

18 MR. HAGERMAN: -- as well? 38

19 there?

20 MEMBER LUBLINER: 49 in zone 3, 49

21 versus 38. And I, the ones that we decided we

22 were going to investigate more I've just
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1 bolded. I bolded them here so that's kind of

2 my code for we need to think about these

3 things.

4 MEMBER SANTANA: Manny with Cavco. 

5 You know, Joe, when DOE runs these analysis

6 they might want to keep in mind that they're

7 not going to do it with R49 in the roof. It's

8 R49 at the kingpost, but it might start to

9 slope immediately depending on the

10 configuration of the truss.

11 So, you know, R49, and then that's

12 why I think, you know, that's one of the

13 reasons why I liked it because, you know, one,

14 it's prescriptive so it's not supposed to

15 apply to everything that's out there.

16 So if you're in zone 3 and you

17 have, you know, 17 inches at the kingpost,

18 then you can comply. You could use the

19 prescriptive path.

20 But if you're not in, well if

21 you're in R3 and you don't have the 17 inches

22 at the kingpost, you might have to take
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1 another compliance path because this one won't

2 work. It won't be applicable to every house.

3 But if you have your 17 inches at

4 the kingpost for zone 3, then you can put your

5 R49 at that point. But it might start to

6 slope immediately and you don't have to really

7 take that into account as much because it's

8 part of the descriptive path.

9 You know, that's how we get the

10 benefit out this thing. And I think, well I

11 think that's good.

12 MR. RAMIREZ: Okay, thank you. 

13 Robin?

14 MEMBER ROY: That all sounds

15 sensible. Joe in PNNL, you guys know what to

16 put in for U is what it is based on these real

17 considerations because I'm going to have to

18 calculate that?

19 Will that pose any problems? I

20 thought there was some consideration, there's

21 some question about how the calculations are

22 done before, right?
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1 MEMBER TOMPOS: No, the problem,

2 Dave Tompos, the problem is going to be

3 depending on your unit width or if it's a

4 single wide, double wide, you're going to

5 have, you know, if you just say R49, that's

6 great.

7 But yes, depending on your unit

8 width, the U-value for that R-value, you know,

9 there's not a, it's not a direct relationship. 

10 It's going to change.

11 MEMBER ROY: That's what I was

12 wondering. So how, what are they going to

13 model? So this would be an interesting little

14 challenge. We have one of these --

15 MEMBER TOMPOS: I'd like them to

16 figure that out.

17 MEMBER ROY: Well we had these

18 conversations yesterday, right, with some

19 concern that you weren't actually getting the

20 U-values that were shown up in the Uo

21 calculation.

22 MR. HAGERMAN: So how they model
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1 it is they build a model, not a, I want to say

2 a physical model but it's not a physical,

3 virtue model of all those components, right,

4 in, you know, the geometries in the 3

5 dimensional. And then they run the software

6 on it.

7 So they actually start with all

8 the components and then they had to generate

9 the U-values in the way that you all express

10 those. I don't believe it's necessarily hard

11 for them to do what you're asking them to do. 

12 It's actually, I think, easier.

13 MEMBER TOMPOS: So they are, I

14 mean they're modeling the actual --

15 MR. HAGERMAN: That's right.

16 MEMBER TOMPOS: -- geometry of --

17 MR. HAGERMAN: Right.

18 MEMBER TOMPOS: -- the truss and

19 --

20 MR. HAGERMAN: Of the component,

21 yes.

22 MEMBER SANTANA: For multiple
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1 widths, you know, so say if you have a 12 wide

2 --

3 MR. HAGERMAN: No, no. So go back

4 to the assumption sheet, you know, with the

5 single wide and the double section in those

6 geometries.

7 MEMBER TOMPOS: Oh, they're doing

8 it based on, okay.

9 MR. HAGERMAN: Yes. That's how

10 this all ties together, right? And you'll see

11 that in the modeling document that I sent out.

12 So I don't want you to think that

13 they're modeling the truss because they're

14 not. They're just modeling the insulation,

15 right?

16 MEMBER SANTANA: Well when they do

17 that, do they use an R-value of 49, is that

18 their starting point?

19 MR. HAGERMAN: Yes, that's what

20 they would use. I mean --

21 MEMBER SANTANA: Would that be an

22 accurate, you know, because you won't get R49
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1 for the roof.

2 MR. HAGERMAN: That's exactly

3 right, that's why I need to know if you can't

4 get a 49 in the roof I need to know what you

5 can get in the roof.

6 MEMBER SANTANA: Well you get 49

7 at the peak.

8 MR. HAGERMAN: Right.

9 MEMBER SANTANA: You know. But

10 then that's it. After that it might start

11 sloping, you know, along with the truss --

12 MR. HAGERMAN: Sure.

13 MEMBER SANTANA: -- and whatever,

14 however tight that is. So, you know, for

15 instance to give you an extreme for instance,

16 if you have a unit that's 12 feet wide and

17 it's a single wide and it has a peak and you

18 have 17 inches at the peak and five and a half

19 at the heel, so you have six feet to go from

20 17 to five and a half. That's not going to be

21 an R49 for the whole roof.

22 MR. BARBOUR: Yes, what I heard
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1 yesterday, just a point, this is Ed Barbour,

2 Navigant Consultant. Just a point of

3 clarification.

4 If you would look in the Uo

5 calculation, the sheets that Emanuel

6 highlighted yesterday that were hidden, if you

7 unhide them you'll actually see how PNNL has

8 calculated it between the truss, with the

9 truss, how much is partial. It's the exact

10 same way.

11 It's follows methodology that the

12 manufacturers are supposed to use when they

13 calculate Uo for the components.

14 MEMBER ROY: This is Robin. 

15 That's what I recall too. And, but what I

16 also recall is some conversation about, it

17 looked like the numbers may not have lined up

18 with the understanding of some of the

19 manufacturers.

20 MR. BARBOUR: I heard that

21 yesterday as well.

22 MEMBER ROY: So, and I'm hoping
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1 they're, the manufacturer will take a look at

2 that. Either your Uo sheet or you can look at

3 their Uo sheets to figure out where that

4 disparity comes about. Discrepancy.

5 MEMBER LUBLINER: Yes, I think

6 again it gets back to when we say, it is what,

7 U is what it is but U is going to vary

8 depending on the truss configurations. And we

9 want to take a typical one and model it.

10 We also want to look at a worst

11 case scenario that you can identify where

12 you're going to be most challenged that it is

13 what it is but it's a big difference of a

14 nominal R than a true R49 or an R38.

15 Just a final points, comments. 

16 I'm not in any position wanting to propose

17 water heating, lighting, space heating, all

18 the other things we talked about, in terms of

19 legal, in the discussion of what authority. 

20 That's not part of this package. That's, I'm

21 not going there with this group.

22 So I just want to let you know in
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1 good faith, as much as I would like to get

2 into that with this group, but it's something

3 that I'm not proposing as part of this

4 package. And I would like to see a discussion

5 on the durability of weather resistant

6 barriers and flashing. But that's again, a

7 separate discussion from the energy

8 discussion.

9 But I do think that, that that, if

10 we do these packages and we had a good weather

11 resistant barrier system for the home, I would

12 feel very comfortable talking to anyone. New

13 York Times or a home owner saying or a banker,

14 and tell Jamie Dimon that this is a same, if

15 not better, than a site-build home.

16 And I'd like to see the preamble

17 of this group come out with that message. 

18 That we should get the same afforded financing

19 as site-build homes and start to explore the

20 realistic reasons as to why the banks are

21 concerned about that.

22 Now that might be incredible
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1 naive, but it's a lofty goal that I think that

2 if we can get collaboration here on good value

3 and energy, I'm very happy to support the

4 industry in terms of making that case. I

5 think there's others that might as well. So

6 thanks.

7 MR. RAMIREZ: Okay. Then, there

8 was a far more technical discussion here than

9 I could wrap my hands around. So, Joe, I'm

10 assuming that when Manny, throughout his

11 revisions and things like that, you were able

12 to catch them so you could do whatever studies

13 are appropriate there? Okay.

14 And then there was one comment

15 from Michael Wade that I want to read, make

16 sure that he's being represented as well.

17 Mr. Lubliner stated that the cost

18 of insulation per R is around one cent per

19 square foot. Reality is that by the time it

20 gets to the consumer, an upgrade is around

21 0.075 per R per square foot. Noted.

22 MEMBER LUBLINER: Yes, I totally
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1 agree with Michael that what I was talking

2 about is the wholesale price to the

3 manufacturer that then would have to get

4 marked up to reflect their additional labor,

5 their expenses, their profit as well as the

6 retailers margin.

7 MR. RAMIREZ: Okay, anything else

8 on this before we move on? All right, great

9 discussion there.

10 Michael, do you want to have a

11 discussion on sources of data and that's where

12 we're going to go next. But before we do, do

13 we need a break or do you want to keep

14 rolling?

15 MR. HAGERMAN: Should we ask to,

16 if we still need that discussion since we had

17 it earlier?

18 MEMBER LUBLINER: This is Mike

19 Lubliner. I think we flushed a lot of that

20 stuff --

21 MR. RAMIREZ: Okay.

22 MEMBER LUBLINER: -- out already. 
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1 You know, on the comments that I've made and

2 other people have provided data sources. I

3 don't know how everybody else feels, I don't

4 necessarily need to have that discussion.

5 MR. HAGERMAN: Let's have a vote

6 to remove it from the agenda.

7 MR. RAMIREZ: All right. I didn't

8 see any thumbs down.

9 (Off microphone comments)

10 MEMBER LUBLINER: My associates

11 call me Minute Lube so I've busted them all

12 here.

13 MR. RAMIREZ: All right, well end

14 that one there. I tell you what, we'll go on

15 break before that one goes any further.

16 All right, so ten minutes, we'll

17 call a quick break, and actually I think you

18 still have a little bit of time to get a cup

19 of coffee or something before they close up

20 over there.

21 (Whereupon, the above-entitled

22 matter went off the record at 2:28 p.m. and
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1 resumed at 2:46 p.m.)

2 MS. HOFFMAN: We're back on the

3 clock and --

4 MR. HAGERMAN: Can I start by

5 saying yes --

6 MS. HOFFMAN: Of course.

7 MR. HAGERMAN: -- so that was a

8 really good discussion that we had and I'm

9 glad. This is Joe Hagerman, DOE. That was a

10 really good discussion.

11 Luby, thank you so much for

12 Proposal Number 1 and then Proposal Number 2

13 was going back to the original view values and

14 the solar heat getting coefficients and then

15 Proposal 3 was that R32 of the kingpost.

16 And I first of all, I've got to

17 apologize for PNL that they hid some of those

18 tabs in there and the terms, I think they were

19 just trying to keep it simple but in actuality

20 I think we need to see all that so I will tell

21 them not to do that anymore.

22 I look forward to giving you all
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1 of this data that you're asking for right now

2 hopefully by Wednesday of next week if not

3 sooner.

4 MR. RAMIREZ: Just for one

5 clarification, yes, I guess they are three

6 different proposals but they're for each of

7 the HUD zones.

8 MR. HAGERMAN: That's right.

9 MR. RAMIREZ: Okay. Yes?

10 MR. HAGERMAN: Oh, good, so

11 timeout before I go any further, let me go

12 first. It's three proposals for all of the

13 HUD zones but they're going to go, they're

14 going to model it in all the climate zones,

15 the IECC climate zones still, so there will be

16 11 climate zones that we'll map to the three

17 climate zones in HUD.

18 And in addition to that they will

19 model it with the various appliance and

20 equipment that they modeled before and the

21 different field types they modeled before.

22 So you'll see basically the same
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1 type of analysis that we already presented but

2 with these variables.

3 MR. RAMIREZ: Excellent, great,

4 thank you. David?

5 MEMBER TOMPOS: Just one change to

6 Luby's proposal here. On the, I don't know

7 how much difference this really makes but I

8 thought we should be consistent with the IECC.

9 So we already changed it to an R3,

10 but it doesn't require it everywhere as I

11 think this proposal says that it does, it's

12 only on 3/4-inch or larger nominal pipe size,

13 which typically in manufactured housing I

14 think it's just going to be the main run.

15 MR. HAGERMAN: So that's an R3 on

16 the main run?

17 MEMBER LUBLINER: Yes, a 3/4-inch

18 size, I think. That's right, Eric, is the

19 current discussion? I mean that handles a

20 large portion of the pushup problem that I was

21 talking about, you know, waiting a long time

22 is the main trunk.
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1 We could talk about the other

2 stuff offline, but that was, my intent was to

3 mimic what was in the I Code, sir.

4 MEMBER LACEY: Yes, this is Eric. 

5 I would just add that the requirement changed

6 between 2012 and 2015 and I think it's

7 required in fewer places now, but it's more

8 than just 3/4-inch pipe.

9 There are a few more places, but

10 that's something that, yes, that could be

11 easily fixed and I can look that up while

12 we're talking.

13 MEMBER SANTANA: Anytime the

14 mandatory requirements to the IECC --

15 MEMBER LUBLINER: Well I can tell

16 you what they are.

17 MEMBER LACEY: I can get someone

18 to look at it, yes.

19 MEMBER LUBLINER: I can tell you

20 what they are real quick, I mean the ones that

21 pertain. I mean there's some in here that,

22 serving more than one dwelling unit obviously
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1 don't pertain.

2 Piping located outside the

3 condition space, that would be something that

4 we'd want to include. Piping from the water

5 heater to distribution manifold, piping

6 located under a floor slab doesn't pertain.

7 Buried piping doesn't pertain. 

8 Supply and return piping in recirculation

9 systems, other than demand recirculation

10 systems, so I mean if we want to include all

11 that.

12 Some of those don't happen very

13 often. I mean I don't know if -- Has anybody

14 ever done a recirculation system in a --

15 I was thinking just in the small

16 percentage of homes like the ones that were

17 advertised in the Wall Street Journal the

18 other day, but I think you're right.

19 MEMBER TOMPOS: I mean if we want

20 to --

21 MEMBER LUBLINER: It's in the

22 noise. It's in the noise, yes.
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1 MEMBER TOMPOS: -- include it to

2 be consistent with the IECC I don't think

3 anybody has a problem with that.

4 MEMBER LUBLINER: No. No.

5 MEMBER TOMPOS: But it's pretty

6 limited.

7 MR. RAMIREZ: Okay. All right,

8 Robin?

9 MEMBER ROY: I'm just curious and

10 following up. Do we also have the KISS Energy

11 Star proposal that you guys are looking at? 

12 Do you need any more information for that or

13 do you have anything you need?

14 MR. HAGERMAN: I believe I have

15 everything I need until you see the results

16 and you tell me that I didn't do it right. 

17 But we got the information from Emanuel on the

18 Energy Star Program and that is what they

19 modeled, but I have not seen the results.

20 I think I'm supposed to get the

21 results by today, which I assume close of

22 business today, so you'll see it next week as
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1 well.

2 MEMBER ROY: I'm not racing for

3 it, I was just hoping it hadn't fallen away as

4 one of the kissable items.

5 MR. RAMIREZ: All right, next step

6 is we want to take a look at the Mind Map and

7 this was something that was sent out to you

8 all. If you have a hard copy you could look

9 at it, if not we'll blow this up section-by10 section as we go through.

11 But I wanted to, I didn't want to

12 take a lot of time on it, right. I wanted to

13 be able to just do a quick review and see is

14 there any cleanup that we need to do on this

15 as far as we've had some of this discussion

16 are there items on here that are not within

17 purview that we need to strike out for now.

18 Did we miss any glaring items that

19 we need to add it? So let's look at Number 1

20 and we'll isolate that one, if we could go to,

21 if you click on "Envelope of Building." 

22 Perfect.
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1 Is there anything on here that we

2 should eliminate based on our discussions or

3 is there anything that we need to make sure

4 that we add on here?

5 MS. HOFFMAN: Or is it still

6 useful after you have your terms of reference?

7 MEMBER SANTANA: Manny with Cavco. 

8 I think a lot of this, well I think most of

9 this has been discussed or it will be

10 discussed, you know, for example, well I don't

11 know that insulation installation grading is

12 currently in the IECC.

13 It has requirements for

14 installation, but I don't think it has any

15 grading in there, so I don't if that's

16 pertinent.

17 MR. RAMIREZ: Yes, if I remember

18 some of the discussion on that was that the

19 values on that were fairly insignificant,

20 between one and two in the savings and so we

21 didn't really have to focus a lot of attention

22 on that if I remember correctly.
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1 MEMBER SANTANA: That has more to

2 do I think with execution that Government of

3 Code.

4 MR. RAMIREZ: Okay.

5 MEMBER SANTANA: And then the

6 items under 1.5, those are probably going to

7 be, except for 1.51, the other ones are

8 probably going to be part of what's in the

9 mandatory requirements that we're going to

10 discuss at a subcommittee.

11 MR. RAMIREZ: So let's put a

12 strike through on 1.4. I'm sorry, not 1.54,

13 just 1.4.

14 MR. RAMIREZ: And then on those,

15 so on the durability -- I'm sorry, you said

16 1.52, 1.53, and 1.54?

17 MEMBER SANTANA: Will probably be,

18 all of those would be part of the mandatory

19 measures. I think so.

20 MR. RAMIREZ: Yes, let's instead

21 put in parentheses after them put it has to do

22 with mandatory components, or, those are
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1 mandatory components?

2 MEMBER TOMPOS: Is the window

3 flashing, Eric? I don't think it is.

4 MEMBER LACEY: Can we defer it to

5 the Mandatory Committee, or I don't know what

6 we're calling it.

7 MR. RAMIREZ: Okay.

8 MEMBER LACEY: And I'll go through

9 and I can provide a list of what some of these

10 requirements are and whether they're mandatory

11 or prescriptive, does that help?

12 MEMBER SANTANA: And then 1.51, I

13 can't remember exactly why we put that up

14 there.

15 MR. RAMIREZ: Well that's kind of

16 an example of is that something that this

17 committee is charged with and if it's not do

18 we put a strike through? David?

19 MEMBER TOMPOS: My opinion is it's

20 not in our scope.

21 MR. RAMIREZ: Okay.

22 MEMBER TOMPOS: Even though it's
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1 important I think we delete it for now.

2 MR. RAMIREZ: So show of thumbs if

3 you're okay with striking 1.51.

4 MR. RAMIREZ: Okay, put a strike

5 through on that. All right, so is that all

6 the cleanup that we need for now for this

7 first issue? And if you could do a fit to

8 window for me when it, I know it's a lot.

9 Bottom right, there you go. Go

10 ahead and do the, yes, the single view of

11 that.

12 So is that all we need to do for a

13 cleanup on Number 1? Is air leakage relevant? 

14 Okay. Next point, all right, so let's go

15 ahead and move to equipment. How's that

16 looking?

17 If I remember that was the noise

18 that the furnaces would create, so --

19 MEMBER KESSLER: This is Bert,

20 Palm Harbor.

21 MR. RAMIREZ: Yes?

22 MEMBER KESSLER: I think based on
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1 the discussions we've had earlier today and

2 yesterday, 2.4 should be stricken. I think

3 that's definitely a decision that should be

4 made by the homeowner and not be part of any

5 code.

6 MR. RAMIREZ: I believe that's

7 that issue that, it's part of the issue that's

8 in the parking lot right now. So why don't we

9 put parking lot and then that way it's there

10 but we'll see if we have time to get to that. 

11 Does that sound all right?

12 MEMBER SANTANA: Can I make a

13 suggestion to that, Javier?

14 MR. RAMIREZ: Yes, Manny.

15 MEMBER SANTANA: In addition to

16 saying parking lot can we say, somehow state

17 that these are the appliances that ship with

18 the home, mandatory appliances?

19 MR. RAMIREZ: Okay. So, yes, we

20 could --

21 MR. HAGERMAN: Joe Hagerman. Like

22 equipment that ships with -- Microphones.
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1 MEMBER ROY: The mandatory ones

2 are 2.1 and 2.3, right?

3 MEMBER SANTANA: The item in the

4 parking lot, it's appliances, equipment as,

5 and then we added water heater to it because

6 it, I think the discussion went towards more

7 what's mandatory that the homeowner actually

8 has to control.

9 MR. HAGERMAN: So the parking lot

10 I believe is the NAECA issue, right? And then

11 a sub-component of that parking lot item is

12 the equipment that ships with the unit.

13 MEMBER ROY: This is Robin. What

14 I heard, I think it was Bert just saying he

15 was thinking the non-required to be shipped

16 with appliances, like a fridge, which isn't

17 required to be shipped with, right? It should

18 be stricken if it is removed.

19 MEMBER WEISS: That's right. I

20 thought he was saying strike the whole

21 category.

22 MR. RAMIREZ: Yes, well we could,
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1 I mean we could clean it up right now if we

2 need to.

3 MEMBER WEISS: Mark Weiss, MHARR. 

4 I agree with Bert. I think based on the

5 discussion today, the workload we already

6 have, I think that should be stricken period

7 and park as well.

8 MEMBER SCHNEIDER: This is Peter.

9 MR. RAMIREZ: Yes, Peter?

10 MEMBER SCHNEIDER: Peter from

11 Efficiency Vermont. I would include it

12 because it is part of the home package and to

13 be honest it's not really a homeowner's

14 decision.

15 You know, the water heater shows

16 up, the refrigerator shows up with the home as

17 it is whether it's on the dealer lot or it's

18 a special order, so I would keep it there and

19 wait for the NAECA decision.

20 MR. RAMIREZ: All right, so a

21 cleanup there that we can put is that it's

22 referencing NAECA, and that's the issue that's
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1 in the parking lot.

2 MEMBER SCHNEIDER: And this is

3 just Peter again from Efficiency Vermont. 

4 Just on that same track, I was muted so I

5 wasn't able to contribute to the last section

6 so I'll revisit that.

7 But after, with regards to

8 acoustics, I know there was a question about

9 that, you know, this is just like appliances

10 coming with a manufactured home which is very

11 different than a stick-built home or even a

12 modular home and that's why I think that it

13 should be included.

14 It's the same with acoustics. 

15 Time and time again it leads where we are. 

16 Homeowners complain about how loud the

17 furnaces are in their living space.

18 They're sitting in the hallway

19 behind a vented panel and they can't even hear

20 the T.V. or the radio or each other, talk to

21 each other.

22 So, you know, it's a very unique
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1 situation with manufactured housing. It's a

2 problem that I hear about over and over again,

3 so I feel like that may not be a common

4 situation in typical stick-builts or modular

5 homes where you have a basement or a crawl

6 space with mechanical equipment, but in a

7 manufactured home it's typically in the living

8 space and should be dealt with differently.

9 MR. RAMIREZ: Peter, and maybe

10 it's just me, so you all need to tell me if

11 I'm failing to connect the dots here, but what

12 does that do with efficiency?

13 MEMBER SCHNEIDER: Well I think

14 it's associated with fan efficiency to be

15 perfectly honest, you know. These are very

16 inefficient fans and the noise associated with

17 those, but I just think that it's, you know,

18 it could be related to the code that we're

19 developing here.

20 It's something specific that's

21 never been dealt with but is a big problem so

22 I just want to have it on the table.
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1 MEMBER LUTER: This is Rob Luter. 

2 I'd like to comment on that if I could,

3 please?

4 MR. RAMIREZ: Yes, please.

5 MEMBER LUTER: I know the subject

6 of the noise from air move or specifically

7 whole house ventilation has been a problem for

8 awhile.

9 The least expensive way to move

10 air is usually not the quietest and if fans

11 are noisy people won't run them. There's been

12 a number of products developed that will move

13 air nearly silently but they're very

14 expensive.

15 I think the noise issue,

16 specifically sone levels, have been either

17 mandated or attempted to be mandated to

18 encourage the homeowners to run the fans more

19 often and so they can hear their T.V.

20 MR. RAMIREZ: Okay, let me set

21 that aside for just a second. How is

22 everything else looking on here as far as
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1 Number 2 goes?

2 MEMBER SANTANA: Manny with Cavco. 

3 Well, you know, I'm not trying to minimize or

4 belittle the importance of acoustics, but

5 trying to stay inline with our mandate as a

6 working group, I don't know that the acoustics

7 or even indoor air quality is within our

8 scope.

9 MEMBER LUTER: Well I think

10 mechanical ventilation is certainly within our

11 scope as it's called out in IECC 2015 and I

12 would also note that, you know, in 403.61, you

13 know, it notes that ultimately you need to

14 meet the fan efficacy noted in that table or

15 install a BTM fan which would resolve this

16 issue.

17 MEMBER SANTANA: Are those part of

18 the mandatory requirements? Can we group this

19 in with that subcommittee?

20 MR. RAMIREZ: It probably will be

21 anyways, right, because that's some of the

22 stuff they're going to be viewing.
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1 MEMBER SANTANA: All right, very

2 good.

3 MR. RAMIREZ: All right, so we'll

4 leave it on there. We'll revisit this map

5 again, you know, in the future based on some

6 of the research and the work of the

7 subcommittees we'll see how we deal with it.

8 Does that sound okay to everyone? 

9 Okay. All right, so then let's look at Number

10 3.

11 MEMBER SCHNEIDER: And can I just

12 -- It's just Peter again. I apologize, but

13 just in regards to the insulation installation

14 grading, that was just scratched, I didn't

15 have a chance to comment nor did I understand

16 why grading wasn't just removed from that but

17 the line item kept?

18 MR. RAMIREZ: You're asking why

19 that was removed, is that the question? Okay. 

20 I'll let the group jump in on this. I think

21 some of the response to that was that as far

22 as the installation of it, from the way I
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1 recall it there were three steps, one, two,

2 and three levels of the grading and the

3 efficiency, the savings on them were fairly

4 small in between one and two and for the most

5 part very few actually saw a Level 3 grading.

6 Level 1 is the highest efficiency

7 and most of them were within that one and two

8 and the saving differences were fairly minimal

9 and so I think that was part of the reason

10 that the group was saying that it's not

11 something that we need to spend our time with,

12 if that's accurate.

13 MEMBER LUBLINER: This is Mike

14 Lubliner. Perhaps, and my concern isn't

15 necessarily the focus on the grading as it is

16 do we have an installation procedure in the

17 Quality Assurance Plan or the DAPE approved

18 manual that does the specifics of installing

19 the installation correctly.

20 That could be using a grading

21 scale or just specificity in the QA Plan. So

22 perhaps what we want to do is leave it in, but
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1 just call it Insulation Installation QA and

2 that would allow us to discuss grading and

3 other approaches that --

4 MEMBER SANTANA: Manny with Cavco. 

5 You know, again, I think insulation

6 installation is in the IECC. Grading is not

7 in the IECC, so that's a reason why it was

8 struck, not because we're not going to focus

9 on insulation installation, that's one of the

10 mandatory grades.

11 Now as, you know, and again going

12 into the execution of it, you know, in the

13 plant, that is probably outside of the scope

14 of this group at this time.

15 MR. RAMIREZ: Okay, so if QA --

16 MEMBER SCHNEIDER: This is Peter.

17 MR. RAMIREZ: Go ahead, Peter.

18 MEMBER SCHNEIDER: I was just

19 going to note I mean if you read air barrier

20 and insulation installation under Table

21 402.411, I mean it basically defines Grade 1.

22 They're just not using RESNET's
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1 grading system, so, you know, to achieve that

2 is going to require definition and if we're

3 just following the language in that table

4 that's fine, but I certainly think it needs to

5 be included.

6 MR. RAMIREZ: All right, so is

7 everyone okay with the modification of

8 Insulation Installation QA? Okay. Manny?

9 MEMBER SANTANA: Yes, the QA is

10 where I think we're getting a little bit off

11 the rails, you know, because and that, you

12 know, although that's very concerning to me as

13 well is how this is going to be implemented in

14 the plant, but if we start getting into that

15 I think it could just help to convolute the

16 issues.

17 MR. RAMIREZ: Okay. David?

18 MEMBER TOMPOS: Can I just make

19 the suggestion just to, just insulation

20 installation I think is all we need, so we can

21 talk about how we need to do that and I think

22 that will clear up everything and we can move
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1 on.

2 MR. RAMIREZ: All right, let me

3 see thumbs on that.

4 MEMBER SANTANA: Parentheses

5 mandatory on that?

6 MR. RAMIREZ: Oh, yes, okay, yes. 

7 All right we'll clean up the strike through,

8 but okay. Everyone good with that? Okay. 

9 All right so then let's go back to Number 3,

10 Finance.

11 All right, so what is within our

12 scope here, either things that could be

13 cleaned up or things that need to be cleared

14 up?

15 MEMBER ROY: It's Robin. We need

16 to add resale, what was it, resale recapture

17 from first buyer.

18 MR. RAMIREZ: Okay. So we could

19 make it a child of that you said?

20 MR. BANTLE: Oh, I thought we just

21 had -- Are they two different things?

22 MEMBER EPPERSON: Stacy, here. I
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1 think they're two different things.

2 MS. HOFFMAN: As its own number

3 not a subpart?

4 MEMBER EPPERSON: I believe it's

5 more appropriate.

6 MS. HOFFMAN: Okay.

7 MR. RAMIREZ: That's the nice

8 thing about this, right, we could see what it

9 looks like, if it doesn't work we'll move it

10 back right. Okay, any other cleanups here?

11 MEMBER EPPERSON: I'm struggling

12 with 3.2. Looking back at it, maybe hearing

13 from the group, I don't, I think it's outside

14 our scope to be looking at HUD grants and

15 other financing and something that says et

16 cetera and other.

17 MR. RAMIREZ: All right, so you're

18 just saying that that whole 3.2 was probably

19 out of our scope?

20 MEMBER EPPERSON: That's my --

21 MS. HOFFMAN: 3.23.

22 MEMBER EPPERSON: No, the other --
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1 MR. BANTLE: 3.23, these three?

2 MEMBER EPPERSON: Yes.

3 MR. RAMIREZ: Okay. So let's put

4 a strike through on that and see if everyone's

5 okay with that. Yes, go ahead and put on the

6 other as well.

7 MEMBER EPPERSON: I think you can

8 take other if others agree.

9 MS. HOFFMAN: Was that cash? Was

10 other meaning cash?

11 MEMBER EPPERSON: We could look to

12 get an estimate as the percentage of the

13 marketplace in cash. We understand

14 anecdotally it's significant these days.

15 MR. RAMIREZ: All right, so like

16 that?

17 MEMBER SCHNEIDER: This is Peter.

18 MR. RAMIREZ: Yes, Peter?

19 MEMBER SCHNEIDER: Sorry, I was

20 just trying to get unmuted. You know, this is

21 very unique and I'll admit that, but Vermont,

22 as a result of Tropical Storm Irene, we had 15
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1 percent of our housing stock qualify for FEMA

2 assistance.

3 Excuse me, let me rephrase that. 

4 That 15 percent of the housing stock that did

5 qualify for FEMA in Tropical Storm Irene were

6 mobile homes or manufactured housing, which is

7 only 7 percent of our housing stock.

8 So one of our Senators passed

9 through legislation and a mobile home tax

10 credit, replacement tax credit, and $35,000

11 for homes in parks.

12 So just the idea that, you know,

13 that's something that we see as critical in

14 moving better manufactured housing forward as

15 an up front subsidy and in this case this

16 mobile home replacement tax credit has been

17 really valuable in getting better homes out

18 there to replace, in particular, our pre-HUD

19 homes.

20 MR. RAMIREZ: Wait, what's this

21 committee going to do with that?

22 MEMBER SCHNEIDER: That's a really
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1 good question, but I just wanted to, with the

2 idea that, you know, we're looking at

3 conventional mortgages as being a possibility,

4 finding out what percent are actually using

5 conventional mortgages, I would be interested

6 in finding out what other opportunities are

7 out there, grants for instance, or tax credits

8 that are offsetting the incremental cost

9 currently so we can factor that in.

10 MR. RAMIREZ: Yes, Mark?

11 MEMBER WEISS: Mark Weiss, MHARR. 

12 It's interesting and anecdotally it would be

13 good to know, but I just don't see where that

14 impacts what we're doing here in terms of what

15 --

16 COURT REPORTER: Do you have your

17 microphone on? I can get you a little bit.

18 MEMBER WEISS: Yes. Okay, I just

19 don't see where that impacts what we're doing

20 in terms of putting together a recommendation

21 for a standard that goes indefinitely into

22 time when you're dealing with these targeted
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1 types of programs that might also be time

2 limited.

3 I just don't see where that has

4 enough of an impact to really factor into

5 this.

6 MR. RAMIREZ: Michael?

7 MEMBER LUBLINER: Mike Lubliner. 

8 I think that what I was thinking about when I

9 was saying financing was innovative financing. 

10 It's stuff that Peter's done, things that our

11 utilities have done, and I don't see that we

12 would include those in the cost effectiveness

13 analysis.

14 I want to be clear, you know,

15 we're not going to make the case that, you

16 know, we're going to buy down the incremental

17 cost because these things exist in certain

18 areas of the country.

19 But I do think it's interesting,

20 particularly if we're going to have some

21 preamble that comes with this recommendation,

22 that we explore and identify where the
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1 innovative financing opportunities either that

2 exist now or could exist or come back like tax

3 credits or utility and such.

4 I think it would be important to

5 have a group that could kind of brainstorm if

6 time permits. It wouldn't be clearly a

7 priority of the mission here, which is really

8 looking at the economic analysis and stuff.

9 But I do think there's value, so

10 possibly I would throw out innovative

11 financing as either a parking lot or something

12 that if there was a willingness.

13 I do think there's an opportunity

14 here for industry, environmental stakeholders,

15 consumer stakeholders, to come together and

16 make the case in this preamble that HUD and

17 other affordable housing, governmental

18 entities need to address the important issues

19 that we've been grappling with over the

20 affordability index.

21 So I wouldn't want to discard it,

22 but at the same time I wouldn't want to make
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1 you guys think we'd want to use it in the

2 analysis.

3 MEMBER DICKENS: Yes, this is

4 Ishbel. I agree with that. I've been unmuted

5 so I wanted to support what Peter and Michael

6 have both been saying.

7 I think it is important that we

8 look at that because I think that could be a

9 potential way of balancing out some of the

10 potential increased costs with the incentives

11 that we've talked about earlier that might

12 apply directly to the manufacturer for

13 providing a more energy efficient home.

14 So I don't think it should even

15 necessarily be in the parking lot, I think I

16 would just still include it as part of the

17 financing that we look at, because Peter's

18 obviously got some examples of that and I

19 think Scott from Kentucky, it's an approach

20 that they're beginning to look at that I think

21 is very creative and I'd like to explore that

22 more.
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1 MR. RAMIREZ: So let me ask,

2 Ishbel and Peter, is that information that you

3 all can send to the Finance Committee so when

4 they do their final report they could include

5 some of that? I won't say final report, but

6 when they report out.

7 MEMBER SCHNEIDER: Yes, and I have

8 a short summary on all different financing

9 options, many of which we're implementing in

10 Vermont right now.

11 And I would just add to what I

12 said earlier, you know, you could say the same

13 thing, you know, we're talking about, you

14 know, developing a code that's going to be in

15 place for a very long time and why should we

16 be talking about innovative financing

17 approaches that may be, you know, not as

18 extensively available right now or may or may

19 not be available in the future, but that's

20 going to be the case with, you know, the

21 financing rates associated with chattel loans

22 and with conventional mortgages, those are
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1 going to change as well.

2 Who knows what happens there. I

3 mean we've already seen the volatility in that

4 financial market, so my suggestion is

5 absolutely keep it in and with the idea that,

6 you know -- The other thing that I was going

7 to mention and I apologize, my mind is kind of

8 racing, but, you know, there was a comment

9 yesterday, I think it came from Mark that 73

10 percent of manufactured housing financing are

11 chattel loans and, you know, my experience, at

12 least in the Northeast, is only those homes on

13 leased land are carrying private property

14 chattel loans and the rest have conventional

15 mortgages.

16 So if only 30 percent of our

17 manufactured homes are on leased land I'm just

18 wondering if we could really nail down that

19 number and I was wondering is that the

20 Financing Committee that's working on that and

21 I'm not sure if somebody took that on?

22 MEMBER EPPERSON: This is Stacy,
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1 Next Step. Yes, I think that's within our

2 committee and we have access to that data.

3 MR. RAMIREZ: Okay, great.

4 MEMBER DICKENS: And this is

5 Ishbel, and I think I've also seen the same

6 statistics that Mark Weiss was commenting. I

7 was going to say, had I been unmuted

8 yesterday, that it's my understanding that 70

9 percent of manufactured homes are purchased

10 through chattel loans rather than mortgages.

11 And I don't know if Scott's on the

12 line and can talk more to the innovative

13 program in Kentucky that they're doing as a

14 way to help support energy savings there, but

15 I think it's something, at least now it's

16 information that we can get from him for the

17 committee.

18 MR. RAMIREZ: Yes, and I don't

19 think I want to get too deep into this right

20 now. What I'm looking for is just to see what

21 we need to cleanup and in this case if we're

22 leaving innovative financing on the board I
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1 want to see, Ishbel, if you and Peter wouldn't

2 mind getting whatever information you can on

3 that to, I'll say Stacy, so that she could

4 include that in whenever they report out from

5 the Financial Subcommittee.

6 MEMBER DICKENS: Yes, and I'm on

7 that Subcommittee, too, Javier.

8 MR. RAMIREZ: Okay, great.

9 MEMBER SCHNEIDER: I'll email

10 Stacy.

11 MR. RAMIREZ: Perfect. Eric?

12 MEMBER LACEY: I'm not on the

13 Financial Subcommittee, but I'd also like to

14 see the breakdown between new purchases and

15 existing, because I hear all these loan

16 numbers and figures being thrown around there

17 and I keep wondering is this for purchases of

18 new units or is this the whole universe of

19 units and so on.

20 And I'm not asking for an answer

21 right now, but I'm just, I think our focus

22 here has been on the manufacturing of the
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1 units and if the concern is going to be about

2 the initial purchase price then I don't think

3 you can include some of those other, some of

4 the other populations that are already in

5 existing units or purchasing units and so on.

6 Anyway, I just want to make sure

7 that's one of the factors you are going to

8 consider.

9 MEMBER WEISS: Yes, I'm Mark

10 Weiss. The number that I remember is 76

11 percent and that is a Census Bureau number for

12 new placements based on the last run that they

13 did.

14 I don't remember off the top of my

15 head that was, but it was fairly recent, but

16 that's what we will be looking at is new

17 homes, new placements.

18 MEMBER SCHNEIDER: Yes, and this

19 is Peter, and I see that as a huge problem if

20 that is indeed the case and that's the

21 financing that these homeowners are getting

22 and that, boy, if we could change that and
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1 flip that percentage so 76 percent are

2 traditional mortgages that should be a goal

3 because that's certainly providing better

4 access to good financing to make a huge

5 difference.

6 MEMBER WEISS: We invite you to

7 support us in our efforts with FHA, FHFA, GNMA

8 and a bunch of other organizations. Thanks,

9 Peter.

10 MR. RAMIREZ: It sounds like

11 something that the whole group may be

12 interested in.

13 MS. HOFFMAN: Yes. Just wondered

14 are we finished then with financial or is

15 there anything more to discuss?

16 MEMBER SCHNEIDER: Just

17 "manufacturer" is misspelled in 3.10.

18 MR. RAMIREZ: All right. So

19 everything else stays on the list?

20 Okay, great. Then let's move on

21 to Number 4.

22 MS. HOFFMAN: By the way is
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1 everyone unmuted? Our members in the remote

2 if you want to be unmuted so be it.

3 MR. RAMIREZ: I believe they also

4 have the ability to send a message if they

5 need to --

6 MS. HOFFMAN: Yes, okay.

7 MR. RAMIREZ: And so far I'm

8 getting a nod that we're good to go.

9 MS. HOFFMAN: Good.

10 MR. RAMIREZ: All right, so

11 building performance, is there anything that

12 needs to be deleted from here or revised?

13 MS. HOFFMAN: Yes.

14 MR. RAMIREZ: Yes, I believe it

15 was like that.

16 MEMBER SANTANA: Same thing for

17 4.7.

18 MR. RAMIREZ: Yes, if I remember

19 correctly there was some debate as to where

20 that should've gone and so to expedite it we

21 just copied and pasted it in both so that way

22 we made sure that we covered it.
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1 Yes. Yes, I think, I mean if

2 we're going to leave it on Number 2 I think

3 it's okay to leave it on four, once it's dealt

4 with it dealt with regardless of which place

5 it is right now.

6 MEMBER SANTANA: I think we can

7 scratch 4.3 because that's what 4.7 is.

8 MR. RAMIREZ: Okay. Everyone good

9 with that?

10 MEMBER SCHNEIDER: And 4.4 for

11 that matter. 

12 MEMBER SANTANA: 4.4 as well.

13 MR. RAMIREZ: Great, okay. What

14 else? Yes?

15 MEMBER LUBLINER: Mike Lubliner. 

16 I just, a scope and question on acoustics

17 because I heard we were talking about fan

18 mechanical noise, but on the other side of the

19 spectrum one of the things that we hear a lot

20 from people who purchased high performance

21 manufactured homes is that they're quieter,

22 they don't hear the street noise.
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1 The choice of windows, single

2 pane, the nice insulated windows, air ceiling,

3 so I'm wondering when we talk about acoustics

4 do we want to talk about the negatives and the

5 positives at all and I don't know how you

6 quantify that obviously, but it's a non7 tangible economic benefit, anecdotal economic

8 benefit.

9 MR. RAMIREZ: And I would ask is

10 that our scope?

11 MEMBER LUBLINER: To the extent

12 that acoustics is up there I would want to

13 make sure that that's included in the

14 discussion, but whether it's our scope or not

15 I'll leave to the group.

16 MR. RAMIREZ: I think that might

17 be --

18 MEMBER ROY: It's sort of our

19 scope in the same way that we appreciate the

20 higher amenity value that comes with a vaulted

21 ceiling, you know, if it's something which

22 consumers value then I guess it is, you know,
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1 what's the cost impact and the slight offset

2 on the cost of a window perhaps if you

3 quantify it.

4 MR. RAMIREZ: Yes, it seems like

5 that would be a by-product, right, that if you

6 get the higher grade windows you're probably

7 going to hit two birds with one stone there,

8 correct?

9 All right. Manny?

10 MEMBER ROY: I don't know to the

11 extent the manufacturers and the retailers are

12 using that as a selling point now, so it's

13 hard to see the extent to which it is a highly

14 valued consumer attribute.

15 MEMBER WEISS: Mark Weiss. It

16 seems like kind of potentially a long alley of

17 only tangential relevance at best.

18 MR. RAMIREZ: All right,

19 suggestion, leave it on for now, we'll see how

20 deep we need to go if at all. Is everyone

21 okay with that. Okay. Any other cleanup?

22 MEMBER SANTANA: This is Manny.
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1 MR. RAMIREZ: Yes?

2 MEMBER SANTANA: 4.8 is, that was,

3 I think that was Kevin's suggestion, he's not

4 here, or Keith's suggestion. I don't know

5 that this was in our scope either. I mean if

6 it isn't in the IECC now, you know, I think to

7 striking that.

8 MR. RAMIREZ: Is everyone good

9 with striking --

10 MEMBER SCHNEIDER: This is Peter.

11 MR. RAMIREZ: Yes, Peter?

12 MEMBER SCHNEIDER: Well I just

13 think that for instance not having the full R

14 value of your slope ceiling assembly over the

15 exterior wall, which leads to significant ice

16 damming in the Northeast and then compromised

17 shingles, leakage, and all sorts of things.

18 I mean I've seen windows broken

19 because of poor overhang detail, so certainly

20 durability is associated with the thermal

21 envelope that we're discussing.

22 So if it is just left there to
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1 help support the argument for better thermal

2 envelopes I'm in support of leaving it.

3 MEMBER SANTANA: I don't know if,

4 I guess I don't see the benefit to having

5 items that describe fringe benefits in there,

6 but, you know, we have acoustics, it wouldn't

7 hurt to leave it in there for another round.

8 MR. RAMIREZ: Is that something

9 also that the Mandatory Committee would be

10 exploring?

11 Okay.

12 MEMBER LUBLINER: Yes, I think

13 that there are different issues associated

14 with durability. There's a lot of them and

15 they vary by climate zone and the approach

16 materials that manufacturers take in the

17 assistance integration of the systems.

18 I think it's important that we

19 discuss what the ramifications on the energy

20 code change have on durability. So having a

21 dialogue is useful, but it really won't play

22 in too much to the financial analysis.
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1 It'll be, again, an economic

2 intangible, either a negative or a positive.

3 MR. RAMIREZ: Okay. Manny?

4 MEMBER SANTANA: Like one of those

5 items where you get peripheral benefit, just

6 the same as you get better acoustics when you

7 have better, you know, windows, but it isn't

8 anything we're going to specifically look at

9 because it isn't anything that's specifically

10 in the IECC.

11 MR. RAMIREZ: Let's do this then,

12 let's take acoustics and durability and let's

13 just move them towards the bottom of the list.

14 MEMBER SCHNEIDER: And comfort.

15 MR. RAMIREZ: Okay. All right, so

16 is that it for Number 4?

17 MEMBER SANTANA: Energy

18 consumption is a little general. I mean isn't

19 that the point of this entire exercise?

20 MR. RAMIREZ: Yes, so a bit

21 redundant there.

22 MEMBER SANTANA: A little bit.
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1 MR. RAMIREZ: Okay. Everyone okay

2 with striking that? Just for the sake of

3 redundancy that's our mission right?

4 MEMBER SCHNEIDER: Forgive me,

5 this may be somewhere else, this is Peter, but

6 duct tightness right alongside whole house

7 tightness as building performance?

8 MR. RAMIREZ: Yes, okay, what

9 about it?

10 MEMBER SCHNEIDER: Oh, I'm sorry. 

11 I had just said that is duct tightness missing

12 or is that called out under equipment? Should

13 it be somewhere and it's not? I see ducts

14 there, but --

15 MR. RAMIREZ: Yes, if you look

16 under --

17 MEMBER SCHNEIDER: -- performance

18 certainly --

19 MR. RAMIREZ: Do you see 1.2?

20 MEMBER SCHNEIDER: Yes.

21 MR. RAMIREZ: Is that okay there?

22 MEMBER SCHNEIDER: That's fine as
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1 long as it's focused on, it's just as

2 important as whole house tightness.

3 MR. RAMIREZ: Yes, I don't think

4 we've put any value on any these. We're just

5 trying to identify what are the issues. All

6 right, and then Number 5. I'm sorry, was that

7 it for four? Okay to move to five?

8 I think this is sort of something

9 we've been --

10 MEMBER KESSLER: This is Bert. I

11 --

12 MR. RAMIREZ: I'm sorry, go ahead.

13 MEMBER KESSLER: I've got a

14 question to Joe and DOE. Is it the intent to

15 replace all of the current thermal

16 requirements in the HUD code with whatever we

17 come up with?

18 MR. HAGERMAN: Yes, I think that

19 would be the case. That's the --

20 MEMBER KESSLER: Okay, good. 

21 Because I was a little bit concerned about our

22 discussion about the prescriptive requirements
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1 and, you know, we had comments like Uos,

2 whatever it is. And we don't have to worry

3 about compression. All of those things are

4 now covered in the HUD code.

5 MEMBER SANTANA: You know, I think

6 this is a, Manny again, that's another one of

7 those gorillas that are in the room as well,

8 you know, that we discuss but we don't know

9 how this thing's going to be enforced and

10 whether HUD is going to have to adopt whatever

11 DOE comes out with or whether DOE's going to

12 have a parallel enforcement arm that inspects

13 just energy.

14 I think that was, we were told in

15 the first meeting that we can't worry about

16 it. Because we don't know how it's going to

17 play out.

18 MR. HAGERMAN: That's right, the

19 scope of this --

20 MEMBER SANTANA: Now, that's very

21 important to us. Because how that plays in,

22 you know, that's how we're regulating, and
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1 it's going to have an impact on cost.

2 It'll have an impact on execution,

3 it's going to have an impact on everything. 

4 I mean, but if you don't know what it is, I

5 don't know if it would help to speculate.

6 MR. HAGERMAN: Right. So the

7 ASRAC charter is just the standard setting,

8 right? That's what they've asked this group

9 for. But as we said at the first meeting,

10 ASRAC would consider any recommendation you

11 have for continuing this, to look at the other

12 items to implement this, this standard.

13 So I would recommend, you know,

14 and I think this was said the first day, that

15 this committee would recommend to ASRAC

16 continuing this past the deadline to work on

17 issues like enforcement or other items that

18 they come up with.

19 Because there may be some need

20 that, you know, you need training, help

21 training, you know, people on how to install

22 things better because of this or education
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1 comes out of this. And that's another thing

2 this group can work on and make

3 recommendations to ASRAC for.

4 I mean, in Eric's prescriptive or

5 description of the paths, he had the one path

6 that said REScheck would have to be revised to

7 look at manufactured housing. So that would

8 be a recommendation that this group would make

9 to ASRAC, right?

10 MR. RAMIREZ: So then as far as

11 going forward on Number 5, is this a next step

12 that is taken out of the scope of this

13 committee, but it's a next step issue? And if

14 so, do we strike it?

15 MS. HOFFMAN: I wanted to ask

16 Emanuel, isn't it one of the considerations in

17 your term sheet?

18 MEMBER LEVY: I think this,

19 actually I'm just thinking about whether this

20 is the right way to orient the section. But

21 obviously it's part of what we're talking

22 about.
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1 I think actually this section's

2 about compliance. And maybe a subsection of

3 compliance would be method. And those would

4 be the methods that Eric laid out as the

5 methods of compliance.

6 And then there would be

7 verification, which would be field or factory

8 testing. So I would rethink this section a

9 little bit being entirely about the method of

10 compliance, demonstrating compliance, and

11 conform it that way.

12 MR. RAMIREZ: Okay. So, then what

13 you're saying is off of compliance we'd move

14 field versus factory performance testing off

15 of 5.1?

16 MEMBER LEVY: Performance and

17 prescriptive are types of compliance. So

18 compliance would be five. And --

19 MR. RAMIREZ: And we can move that

20 numbering, so --

21 MEMBER LEVY: Right. See, I would

22 have suggested 8.1 be method. And then the
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1 subsections to that would be Uo, UA,

2 performance, whatever those are, the various

3 methods of compliance, just kind of conforming

4 now the discussion to what we talked about

5 earlier. The method is the technique, so the

6 other part of, so I would take out the word

7 field there.

8 MR. RAMIREZ: You know, do you see

9 that little squiggly that you just had? Go

10 back over the dots, you know, hit that. Oh,

11 wait a second, then undo.

12 MR. BANTLE: It just deletes

13 everything to the right of it.

14 MEMBER LEVY: And the other,

15 again, I'm not sure this is totally making

16 sense, but 8.2 would be verification. And

17 that's where you would talk about field or

18 site --

19 MR. RAMIREZ: Field or site?

20 MEMBER LEVY: Testing. Field or

21 plant, field or, yes, plant or field.

22 MR. RAMIREZ: Okay, so with that
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1 up there, how do we clean up five then?

2 MEMBER LEVY: Delete it.

3 MR. RAMIREZ: Delete it?

4 MEMBER SANTANA: Well, not

5 exactly, because, you know, part of it applies

6 to both, you know, when we first started it

7 was suggested that we have a performance

8 approach. But now we have performance and

9 prescriptive. So we have performance dash --

10 MR. RAMIREZ: No, go back up. Go

11 back to eight.

12 MEMBER SANTANA: That's the third

13 case, yes.

14 MR. RAMIREZ: Yes, Okay. So with

15 those components captured in our 8.1 that

16 Manny was talking about, so now then do we

17 delete five? Waiting, Dave.

18 MEMBER TOMPOS: Well, I can't

19 believe Michael hasn't spoken up on energy

20 labeling yet, not wanting to delete that.

21 I hate to see it being deleted. I

22 don't know if we can make it a requirement?
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1 But I think there's some benefit to maybe

2 keeping it in the conversation.

3 MR. RAMIREZ: All right. So like

4 make that appear off by itself?

5 MEMBER SANTANA: I think it's

6 included in eight. Manny, I think it's

7 included in eight, because you're going to

8 have to have some kind of label.

9 And the label's going to have to

10 reflect what method was used. And so the

11 method is going to dictate how you verify. 

12 So, you know, it's harder --

13 MEMBER LUBLINER: Yes, it's Mike

14 Lubliner. I mean, to address your comment,

15 yes, I don't really care where we put it as

16 long as it's in there.

17 And specifically, when we talk

18 about energy labeling, we're thinking labeling

19 that's providing the consumer with information

20 and also labeling to reinvent the heating

21 certificate that's there now that would

22 provide the after-market heating contractor
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1 with the right information to size the air

2 conditioner.

3 So, you know, you'd have energy

4 labeling, and then a sub-section might be

5 consumer education and HVAC as two areas where

6 there's distinct goals that I have, at least,

7 for wanting labeling to address.

8 MEMBER SANTANA: Well, you know,

9 there's going to be quite a few, you know. 

10 Because there's, you know, along with this

11 you're going to have the label that goes with

12 the house, that describes how the house is

13 built.

14 You're going to have the one that,

15 you know, explains how the whole house 

16 ventilation works. You're going to have the

17 one that explains what kind of insulation was

18 installed. You know, so I think just saying

19 energy labeling, that should include them all.

20 MEMBER LUBLINER: Yes. This is

21 Mike Lubliner.

22 MEMBER SCHNEIDER: And this is
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1 Peter.

2 MR. RAMIREZ: Go ahead, Peter, and

3 then we'll get Michael. Go ahead.

4 MEMBER SCHNEIDER: Just further,

5 with regards to energy labeling and the

6 importance of this is, having just sat through

7 an appraisal education class on the green and

8 energy efficient addendum for any home built

9 beyond typical code, is that the appraiser's

10 looking in the electrical panel to identify

11 any energy features in the home that they

12 would utilize to fill out that form which

13 would then turn into additional value on that

14 appraisal, which obviously is going to help

15 with financing and, of course, resale down the

16 road.

17 So energy labeling and then making

18 sure that that's incorporated into the

19 standard, I think, is critical moving forward

20 for a number of reasons.

21 MR. RAMIREZ: Michael?

22 MEMBER LUBLINER: I'd support
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1 that. We have probably over 100,000 homes with

2 labels that give the nominal R-value and that

3 the home complies with our program, Energy

4 Star, or the other programs we've had over the

5 years.

6 And it says explicitly this home

7 may qualify for an energy efficient mortgage. 

8 That's had value in all those homes over the

9 years.

10 We see in the Nickel One ads and

11 different sales of homes in the newspaper,

12 they'll advertise Energy Star manufactured

13 home. That's one of the things they'll

14 feature in the ad. And they have like eight

15 words. And one of them says Energy Star.

16 So I would think that it's

17 important for us to come up with a label that

18 provides consumer education, provides HVAC

19 precedent education, and then it provides, you

20 know, the education here for the lender or the

21 appraiser, and I'll shut up --

22 MR. RAMIREZ: Joe?
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1 MR. HAGERMAN: Just let me step in

2 here real quick -- this is Joe Hagerman, DOE

3 -- and just say, you know, everybody knows

4 there's a lot of red tape in DC, so I'm going

5 to preface what I say with that.

6 Now traditionally, DOE doesn't

7 have the authority to issue labels, right, is

8 my understanding. Kavita and I are going to

9 run to ground with this issue. I think it

10 should stay up here for now.

11 Typically, the FDC labels the

12 appliances that are sold. We provide data to

13 the FDC, and that's how they generate the

14 labels. But there is some division where we

15 can't label, I do believe. But we're going to

16 run this to the ground.

17 So my advice is let us take this

18 on to see what we can and can't do. And, you

19 know, if we need to pull in FDC, let's pull in

20 FDC. Let us do our homework before we go any

21 farther with this. And let's just keep it on

22 there.
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1 MR. RAMIREZ: Thanks. We'll add a

2 note under energy labeling that OGC will

3 review. Okay.

4 MEMBER LEVY: Could you add this

5 to 4.1 prescriptive?

6 MEMBER SCHNEIDER: And this is

7 Peter. When we're ready to change course, I

8 have one other comment and potential line

9 item.

10 MR. RAMIREZ: All right. So let

11 me go back then. With the cleanup that we had

12 under what's now four, do we delete the

13 previous one that we're looking at, which is

14 now six?

15 Everyone good with that? Let me

16 see a show of thumbs. All right, let's strike

17 that one. Okay, Peter, what did you have? 

18 I'm sorry, Peter, is there something in

19 regards to the map, or was there a different

20 issue?

21 MEMBER SCHNEIDER: Yes, it's the

22 map. And just actually looking at the
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1 Research Alliance website previously, looking

2 at Frost Free Foundation details and then

3 actually looking at the regions in the U.S.

4 for, you know, where Frost Free Foundation

5 should be incorporated, I know at least in my

6 climate region, having un-frost protected

7 connections to the ground leads to all sorts

8 of energy efficiency, durability, and

9 performance issues with doors no longer

10 opening and closing, windows no longer opening

11 and closing and certainly additional air

12 leakage.

13 And of course, this is very

14 specific to manufactured housing, how it's

15 delivered. And I was just wondering if we

16 felt as though that should be explored.

17 Because, you know, there are some

18 simple strategies to improve the way these

19 homes are set, particularly if, you know, the

20 areas are similar to Vermont where these homes

21 are rarely ever moved. So putting them on

22 permanent frost-protected foundations would be
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1 a big benefit.

2 MR. RAMIREZ: David?

3 MEMBER TOMPOS: I want to ask DOE,

4 does our scope include just the home? Or does

5 it include the installation?

6 MR. HAGERMAN: It's just the home.

7 MEMBER TOMPOS: So does that mean

8 that, not that I don't agree that Peter's

9 point is important, but I just want to make

10 sure that it's inside our scope.

11 MR. HAGERMAN: It's just the home 

12 that's shipped from the manufacturers.

13 MEMBER SCHNEIDER: So who would

14 deal with that then? 

15 MR. RAMIREZ: Do you know, does

16 anyone know? 

17 MEMBER TOMPOS: Well, I think that

18 would be something the MHCC would deal with

19 and local jurisdiction. But specifically, I'd

20 start with MHCC.

21 MR. RAMIREZ: Okay. So then let's

22 look at Number 7. I think that's kind of as
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1 we go along, right? I don't think there's

2 anything that really needs to be modified

3 here, unless you all see something. It's

4 something we're going to be discussing, right,

5 I think all throughout.

6 Okay. Number 8? And we're doing

7 that as we go along as well, correct? Okay. 

8 I think that's it. Yes, Mark?

9 MEMBER WEISS: Mark Weiss. As

10 much as I really hate to do this, can we just

11 go back to three for a second, financial?

12 MR. RAMIREZ: Okay.

13 MEMBER WEISS: And I raise this

14 more, I guess, as a question. Looking at the

15 statute, it refers specifically to, it says

16 total life cycle construction and operating

17 costs.

18 And we've been doing most of our

19 talking about life cycle operating costs. But

20 I'm wondering if somewhere up there we should

21 specifically reference construction cost.

22 I know we have competitiveness
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1 which addresses, to some extent, the

2 disparities that will happen between larger

3 and smaller manufacturers. But I think this

4 more concretely addresses some of those issues

5 and others.

6 MR. RAMIREZ: Do you want to put

7 that as an offshoot, as a child of

8 competitiveness construction costs?

9 MEMBER WEISS: No. I think it's

10 in the statute. We should at least reflect it

11 somewhere in here. I'd just say construction

12 cost is a separate item.

13 MR. RAMIREZ: Okay. Yes, Eric?

14 MEMBER LACEY: I mean, I agree

15 that we should repeat all the language in the

16 statute. But I thought total cost of

17 ownership was intended to cover that.

18 Is this something, I mean, that

19 includes construction costs, replacement

20 costs, operating costs and everything. Does

21 that not cover what you're talking about

22 there?
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1 It's 3.8.2. It's under the

2 affordability discussion. I thought we'd kind

3 of incorporated the construction, replacement

4 costs, operating costs, everything in that one

5 thing.

6 And construction costs, calling it

7 out separately, I'm not sure that it's quite

8 as useful as including it up in the

9 affordability analysis. But I'm interested.

10 MR. RAMIREZ: I guess the

11 clarification is how does that vary from

12 purchase price?

13 MEMBER WEISS: Purchase price is

14 the end price to the consumer. Construction

15 cost goes to the compliance costs on the part

16 of the manufacturer and potential disparities.

17 You know, again, I'm simply

18 suggesting that, because it's terminology used

19 in the statute. And I just want to make sure

20 that we address that as an issue.

21 MR. RAMIREZ: And so do we put it

22 under affordability or still keep it separate?
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1 MEMBER ROY: How about we put it

2 under 3.8.3. And then we'd have operation,

3 maintenance and purchase, including

4 construction and other installation costs,

5 construction, installation and other purchase

6 costs.

7 MEMBER WEISS: No. It's not that. 

8 You can say and/or, I wouldn't say and/or

9 purchase, I would --

10 MEMBER ROY: No, no. And --

11 MEMBER WEISS: Operation --

12 MEMBER ROY: Why don't we run it

13 together with operation, maintenance,

14 construction cost. No, I'm not sure about

15 that.

16 MEMBER WEISS: I would separate

17 each one of them out.

18 MEMBER ROY: It should go

19 somewhere up there.

20 MEMBER WEISS: I would separate

21 each one of them out, operation, maintenance

22 --
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1 MEMBER ROY: Operation, comma --

2 MEMBER WEISS: Operation/

3 maintenance, purchase price, and construction

4 costs, three separate ones?

5 MEMBER ROY: That sounds fine. 

6 That's a good place.

7 MEMBER SCHNEIDER: I'm still not

8 sure how construction costs would be separate

9 from total cost of ownership unless the

10 manufacturer was going to absorb the

11 incremental costs and not pass it along to the

12 buyer. It seems redundant.

13 MR. RAMIREZ: This is, just a

14 reminder to everyone, this is just a map,

15 right, to help us make sure that we don't miss

16 anything, that we could use this to hopefully

17 review and construct the term sheet. So

18 whether we cover it in either one of those

19 locations, I guess as long as it's being

20 considered and discussed --

21 MEMBER ROY: This is Robin. I

22 support what Mark's suggesting here, if only
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1 because it is in the legislation. It's nice

2 to be firm and have that reminder that we

3 should try to speak to the language of the

4 legislation.

5 MR. RAMIREZ: Yes.

6 MEMBER ROY: Including other

7 places. So it's just a reminder up there. 

8 I'd like to see it somehow.

9 MEMBER WEISS: And it might meld

10 into something else. But since it's in the

11 statute, I think we should at least kind of --

12 MR. RAMIREZ: I didn't want to

13 argue whether it should be as part of 3.8.2 or

14 3.8.3, as long as it's up there, right, and we

15 can address it. Michael?

16 MEMBER LUBLINER: I was just going

17 to make a suggestion of the 3.8.4 which would

18 be construction costs. And what I was

19 understanding that is, it's the implications

20 on sales is what you were, is that what, the

21 sales implication that having a higher

22 construction cost is an implication.
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1 It's reducing your sales, you

2 know, it's the price elasticity step. So if

3 we just had it as construction costs, and then

4 one of the things would be price elasticity. 

5 But I think we talk about it somewhere else in

6 there. So as long as it gets discussed --

7 MEMBER WEISS: I don't want to

8 overdo this. I just wonder if there's a

9 placeholder so that we address that part of

10 the statute.

11 MEMBER LUBLINER: So maybe --

12 MEMBER WEISS: -- somehow. Just

13 put them in there. Okay.

14 MR. RAMIREZ: Okay. All right. I

15 want to, I know that Manny you have to leave

16 at 4:00.

17 And I'd like for, well, while we

18 have him and some of the other committee

19 members, especially the folks on the phone as

20 well, what are our next steps? I mean, what

21 are we going to be doing here. Do we have

22 enough information to have two full days of
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1 meetings?

2 As this was progressing, some of

3 the ideas that we were throwing around as

4 facilitators would be to still keep the ninth

5 and the tenth blocked off for us to use but

6 just use them a little different.

7 Where on the ninth, hopefully the

8 subcommittees are doing work apart from that,

9 but the subcommittees could use the ninth to

10 really nail down some of the information that

11 we're going to need.

12 And then on the tenth, we'll still

13 be here. So the local folks could come here

14 if they would like to. And we still have the

15 Webinar offerings.

16 And additionally, what we could do

17 then is as we get closer, you know, a couple

18 of days out, depending on what information's

19 been sent out, some of the feedback that we're

20 getting from the folks, we'll tighten up the

21 agenda for the 10th. And we'll send it out a

22 couple of days in advance, depending on how
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1 much progress you make between now and then.

2 MS. HOFFMAN: And not just local

3 folks, but if other people do want to come in,

4 we will be here on the tenth. We'll be here,

5 so you're welcome to be here. But we also do

6 have a GoToMeeting, so we'll have that as

7 well. And on the ninth, we intend to also do

8 some work.

9 MEMBER ROY: This is Robin. I

10 find GoToMeeting, I don't know how you feel,

11 it's out there, Ishbel, and Peter and Bert,

12 but I don't think it's remotely as good trying

13 to have a conversation about so many of these

14 things.

15 And, Mark, as you've seen from

16 both sides now, I can't believe it's remotely

17 as good to have these conversations on the

18 phone and having to have somebody read off an

19 email or something. It seems silly.

20 I also recall, just a day ago,

21 folks saying there was not much to do today

22 and that we should postpone Friday. And until
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1 Luby said that he's going to miss his

2 daughter's graduation anyway, we were going to

3 go ahead and postpone Friday until some other

4 year.

5 I think today was a phenomenally

6 productive day. We pushed through so many

7 things that we had to deal with at some point. 

8 We actually filled out a lot of documents.

9 I think between now and the ninth,

10 we might come to the right answers. But with

11 the genius work, and I keep using that word

12 for you guys, PNNL, and Navigant and DOE, you

13 will fill out a lot of these documents which

14 we may or may not agree with in detail. But

15 you will have a lot of structure and a lot of

16 numbers in there that we will then be

17 reporting back, and we will be done.

18 Stacy, and Mark, and I, and the

19 others and Ishbel will not be done coming up

20 with all those finance bits to throw in. But

21 we'll have a lot to talk about in a meaningful

22 way on the ninth.
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1 I don't see a benefit in pushing

2 this stuff off. All it does is it slows us

3 down from doing what turned out to be

4 incredibly productive, not necessarily that

5 much fun. Although I've got to say, I like

6 you guys so much, I'm going to miss you in

7 October.

8 MS. HOFFMAN: Well, what I'm

9 hearing is you want to have two full meetings

10 both on the ninth and the tenth. So as I

11 said, we've allocated them. Let's get a sense

12 of the group.

13 MEMBER DICKENS: Yes, this is

14 Ishbel. I was going to be doing it by phone

15 again. It's not ideal, obviously. But I

16 think there is a lot of material there.

17 And even if, when we meet on the

18 ninth, if we need to break into subcommittees

19 to do some work independently of the whole

20 group, perhaps that's an option as well.

21 But I do think we did set a time. 

22 I know I'm planning to come out the 22nd and
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1 23rd. I'll be booking a flight soon, so I

2 want to make sure that we're --

3 MS. HOFFMAN: That's a definite,

4 yes, the 22nd and 23rd.

5 MEMBER DICKENS: Okay.

6 MS. HOFFMAN: But I'm sorry, go on

7 please.

8 MEMBER DICKENS: No, no. That's

9 all I was going to say, Eileen, just that we

10 did commit to these times. And I think we've

11 all set them aside. And I think we're using

12 them very effectively and very efficiently.

13 MS. HOFFMAN: Any other thoughts?

14 MEMBER LUBLINER: This is Mike

15 Lubliner. Yes, just on a logistical

16 suggestion, having been here now and done the

17 phone penance, we've got to figure out this

18 feedback thing, if there's any way you can

19 deal with the technical glitch there.

20 Because it's really, there's two

21 issues as I recall. One is as you're talking

22 you're getting an echo and then the, yes. So
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1 that's a logistical thing. If you can look

2 into it.

3 Also on the logistical side, if we

4 are going to break down into task groups, we

5 need to make sure that we have multiple

6 conversations on the technical capability of

7 doing that. I don't know how you --

8 MR. RAMIREZ: Yes, space.

9 MS. HOFFMAN: There might be space

10 for a conference call.

11 MEMBER LUBLINER: Space for a

12 conference call, yes.

13 MS. HOFFMAN: Because we do have -

14 -

15 MEMBER LUBLINER: So there's more

16 than one conference call going on

17 simultaneously.

18 MS. HOFFMAN: Yes. Because we

19 have a room next door. Excuse me?

20 (Off the record comments)

21 MEMBER LUBLINER: So those are the

22 only --
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1 MS. HOFFMAN: I'll check, we're

2 going to check and see if we can use our

3 offices. We have a variety of rooms. So I

4 will check on those dates.

5 MEMBER LUBLINER: So that's

6 excellent. I will not be able to attend,

7 physically, the next one. but I will be at

8 the final September and the first meeting in

9 October. But I want to just thank you guys.

10 If I graded you guys against the HUD Consensus

11 Committee, it'd be A+.

12 (Laughter)

13 MEMBER LUBLINER: And I wish the

14 credit scores of our clients were that good. 

15 But no, really, you guys have got it, it's a

16 great group to work with. I think we're going

17 to get into some more nitty-gritty stuff. 

18 Thank you.

19 MR. RAMIREZ: Well, as a

20 facilitator question then, just logistically,

21 so we could explore what options we have for

22 you all, most computers nowadays have the
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1 built in cameras.

2 If we were to do something that

3 involved cameras, would everyone be able to

4 access an iPad, a laptop with a camera, a

5 computer with a camera if we needed to?

6 And I'm thinking not so much for

7 the folks that can make it, but the folks

8 looking at the feedback issue and some of the

9 technology issues that we're experiencing, if

10 you have cameras, we might be able to explore

11 some additional options.

12 MEMBER ROY: This is Robin. I'd

13 like to --

14 (Simultaneous speaking)

15 MEMBER LUTER: Oh, go ahead,

16 Peter.

17 MS. HOFFMAN: Rob, go on please.

18 MEMBER SCHNEIDER: Just about the

19 camera.

20 MS. HOFFMAN: Excuse me? Rob,

21 what did you say. We didn't hear you?

22 MEMBER LUTER: I suggested Peter
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1 go ahead. And I'll follow Peter.

2 MS. HOFFMAN: Oh, okay. Peter?

3 MEMBER SCHNEIDER: Well I was just

4 saying that I have a camera and I've joined a

5 number of meetings where we video conference

6 and that works even better than the

7 GoToMeeting just listening and sharing

8 documents via the Webinar. So I --

9 MR. RAMIREZ: Okay.

10 MEMBER LUTER: My comment was that

11 I use GoToMeeting and GoToWebinar quite

12 frequently, two or three times a week at

13 least. And I find it very effective.

14 I've not felt left out in these

15 last two days. I've felt like I could comment

16 freely. The feedback issue is very

17 problematic though. This is the only time

18 I've ever experienced this. And I'm really

19 not sure why.

20 MS. HOFFMAN: Another suggestion

21 I heard was --

22 MEMBER SCHNEIDER: This is Peter. 
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1 In the past --

2 MS. HOFFMAN: Oh, sorry. Go on,

3 Peter.

4 MEMBER SCHNEIDER: Oh, I was just

5 going to, yes, I was just going to say that

6 historically when I've had the feedback issue

7 it's been associated with folks not wearing

8 headsets and not muting when they're not

9 talking.

10 And maybe if we just try that

11 right now, that might be a solution. If

12 everybody has a headset they can plug in and

13 then mute themselves and that may resolve it

14 right now.

15 MEMBER LUTER: That's been my

16 practice for the last two days, I have the

17 headset in and mute when I'm not talking. And

18 it's, for example, right now I'm hearing an

19 echo of myself that's totally distracting.

20 MR. RAMIREZ: All right. So we're

21 going to try something here. Everyone that's

22 in the room -- I guess, Eileen, you and I are
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1 the only ones, do you have your mike on? 

2 Okay. I'm going to mute my mike. And then,

3 Peter, go ahead and say something. Peter, go

4 ahead and see if you still have the echo.

5 MEMBER SCHNEIDER: -- testing. I

6 am not hearing an echo. I'm not sure.

7 MEMBER LUTER: I'm hearing an echo

8 from Peter.

9 MEMBER SCHNEIDER: You are?

10 MEMBER LUTER: And I'm hearing my

11 own voice as well echoing.

12 MEMBER SCHNEIDER: Yeah, I hear you

13 echoing.

14 MR. HAGERMAN: Rob, are you logged

15 into the Webinar on your computer with your

16 computer speakers and also dialing in with a

17 telephone or a cell phone?

18 MEMBER LUTER: No. I'm just

19 logged in on my laptop and using voice over

20 IP.

21 MEMBER DRAKE: This is Scott

22 Drake. I'm logged in on an iPad.
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1 MS. HOFFMAN: And is it okay?

2 MEMBER LUTER: I heard an echo

3 there.

4 MEMBER DRAKE: There's an echo.

5 MS. HOFFMAN: Okay. So one other

6 thing while we're still looking at echos, for

7 people who have to fly out, one thought is,

8 for the next meeting, have it start on the

9 ninth at 9:00 and end at 5:00. But the one on

10 Wednesday, maybe start at 8:00 and end at 4:00

11 or 3:00. So you can get out, or you can't do

12 it?

13 MEMBER DICKENS: Well, that would

14 mean I'd be starting at 5:00 in the morning.

15 MEMBER SANTANA: Is there any way

16 that we can meet somewhere else that's not so

17 far on the East Coast?

18 MR. RAMIREZ: Chicago's a great

19 location.

20 MEMBER SANTANA: Chicago? Chicago

21 or St. Louis?

22 MR. RAMIREZ: Well, that was a
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1 little selfish.

2 MEMBER SANTANA: Dallas?

3 MEMBER LUTER: Chicago works for

4 me.

5 MS. HOFFMAN: Well, DOE says it

6 can meet wherever. But I don't know. We'll

7 --

8 (Off the record comments)

9 MEMBER DICKENS: How many of us

10 are from the West Coast?

11 MEMBER TOMPOS: I can do the West

12 Coast. Phoenix, beautiful this time of year.

13 MR. HAGERMAN: We have the

14 National Renewable Energy Lab in Golden,

15 Colorado, which is right at Denver. It's very

16 easy to fly into. It's kind of halfway for

17 everybody. But that's up to the group to

18 decide.

19 MS. HOFFMAN: Well, we lose some

20 of our local people.

21 MR. RAMIREZ: Yes, so, you know

22 what, I don't know. Probably for the next
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1 meeting, that would probably be a little to

2 tight to change locations. But for future

3 ones, after that, so that's something that

4 we'll discuss.

5 The facilitators, along with Joe,

6 will have some discussions on that and see

7 what other options there really are. I think

8 we need to take Maui off the table.

9 MEMBER ROY: Could we commit to

10 the 21st, 22nd, whatever that was, to one of

11 these, to Chicago or to Denver? That would be

12 great if you could do that, sooner rather than

13 later.

14 MS. HOFFMAN: Okay. Well, --

15 MEMBER DICKENS: This is Ishbel. 

16 I actually want to come to DC on those

17 September dates.

18 MEMBER LUBLINER: I'm Mike

19 Lubliner. And I already planned those dates

20 to come to DC. I'm actually bringing my wife

21 to build marital bliss from the challenge that

22 we had on the last meeting.
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1 MR. RAMIREZ: Well, we're all good 

2 for today, right.

3 (Laughter)

4 MR. HAGERMAN: We can look into

5 October 1st and 2nd in Colorado or some place

6 else?

7 MEMBER LUBLINER: I would like to

8 have the last meeting in Colorado in October.

9 MR. RAMIREZ: Listen to that, the

10 last meeting, right? I mean, we're going to

11 get the, we're going to have the term sheet

12 wrapped up on the --

13 MEMBER ROY: Was that not an

14 optional meeting that we had not committed to

15 yet? Because we're going to be done in --

16 MS. HOFFMAN: We may not need it. 

17 But if we do need it, we could look into

18 October 1st and 2nd in Chicago, or Boulder or

19 whatever. Let me get a sense of the group. 

20 I mean, just --

21 MR. RAMIREZ: So the group is

22 saying that for the last meeting that we have
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1 on the schedule, October 1st and 2nd, to find

2 a more centrally located facility.

3 MEMBER SANTANA: You know,

4 everything's a factor here, airfare, hotels,

5 you know, even Louisville, you know, it's very

6 cost effective, Texas.

7 MS. HOFFMAN: Also our DOE staff,

8 can they fly everywhere? Are there, okay. 

9 Just wanted to check on that score.

10 MR. HAGERMAN: We already checked

11 it. This is Joe Hagerman. We already checked

12 into this some time ago. Everybody over there

13 did raise the flag that October 1st and 2nd

14 meeting is a contingency meeting.

15 MS. HOFFMAN: Right.

16 MR. HAGERMAN: We'd have to get

17 approval for ASRAC to extend into the October

18 date anyway. So just keep that in mind.

19 MS. HOFFMAN: Right.

20 MR. HAGERMAN: So we can start

21 that process, but let's get some more forward

22 momentum.
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1 (Off the record comments)

2 MS. HOFFMAN: It isn't. It's on.

3 MR. HAGERMAN: We were still

4 meeting the night that in D.C.

5 MS. HOFFMAN: We're meeting -- Oh,

6 for location. Let me ask. Is it too soon to,

7 well, somebody already bought tickets for the

8 8th and 9th --

9 MR. RAMIREZ: I have them on the

10 10th.

11 MR. HAGERMAN: The problem is

12 people haven't bought tickets.

13 MS. HOFFMAN: They haven't bought

14 tickets?

15 MR. HAGERMAN: Yes.

16 (Off the record comments)

17 MEMBER SANTANA: And even if we

18 don't meet, he's still going to be here.

19 MS. HOFFMAN: Okay. Well, we are

20 scheduled for the 9th and 10th here. And we

21 are going to do it here. We might, depending

22 on the room, we may switch around for those. 
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1 We're going to work on the agenda. 

2 And so we might have an hour or two for

3 working groups to get together. And if so,

4 we'll have the appropriate rooms for them to

5 talk.

6 But we are going to go ahead with

7 the 9th and 10th. So you can make your ticket

8 reservations on that score. Let me ask you

9 before Manny heads out. This has been going

10 all right so far?

11 We haven't cracked the whip yet,

12 but we're going to have to move at a, you

13 know, a quicker pace. But that means also

14 getting the data and getting the analysis.

15 We want to thank everybody. And

16 if you have anymore legal questions, we

17 appreciate General Counsel's office, I can

18 understand that office as well. So any other

19 comments does anyone have? Yes, Mark?

20 MEMBER WEISS: Question, this is

21 for Joe. The statute talks about consultation

22 with HUD. What is going on with that or the
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1 plan going forward?

2 MR. HAGERMAN: I'm glad you asked

3 that. So Kavita can update you with our

4 General Counsel's office's discussion with

5 their General Counsel's office.

6 MS. VAIDYANATHAN: This is Kavita

7 Vaidyanathan. We did have a conversation with

8 the General Counsel's office. And we still

9 have not defined what consultation is.

10 We're still discussing it, because

11 we don't have, we can't consult until we have

12 something to consult with. And we won't have

13 that until a term sheet is given to ASRAC, and

14 ASRAC actually gives a term sheet to the

15 Secretary.

16 So once the Secretary is given a

17 term sheet, then DOE has something to consult

18 on at that point. So if this committee does

19 come up with a term sheet, then it will go to

20 ASRAC. And if ASRAC does pass it along to

21 DOE, then at that point we'll discuss what

22 consultation is.
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1 MEMBER WEISS: Could you provide

2 the committee with the substance of that

3 discussion, not now, but I mean going

4 forward? In other words, is there something

5 in writing you could provide to us that would

6 be relevant to that?

7 MR. HAGERMAN: I think she can

8 give updates like this. And everything she

9 says is on the record. So that's kind of a

10 written update.

11 MS. VAIDYANATHAN: Yes. I'm happy

12 to provide, these are all conversations that

13 we've had with the HUD Counsel. So there is

14 no written documents we've passed back and

15 forth. We've just had telephone

16 conversations.

17 MR. HAGERMAN: Okay. I can say

18 we've been, you know, when we get the

19 transcript back, we review it just really

20 quickly. And then we push to post as quickly

21 as possible, seeing that the meetings are just

22 back-to-back, back-to-back. So there's going
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1 to be typos in that and everything. So just

2 bear with us.

3 MS. HOFFMAN: I also want to ask

4 about communication between meetings. Anyone,

5 would it be fair to say, Joe, if you write,

6 we're going to work on an FAQ sheet. And

7 anyone who writes something to us will be

8 getting it back. We can get it back to

9 everyone or to just that person, I guess,

10 depending on what they ask.

11 Usually what we've done is, if

12 somebody's asked for something, we actually

13 send the answer to everybody, thinking that it

14 might be something of interest to more than

15 just one person. But if you say I just want

16 you to respond to me, then we'll just do that.

17 Joe has said he'll try to get out

18 the analysis and I guess the Star, the Energy

19 Star analysis as well. And you'll get a lot

20 of figures. And I've asked Joe to put it in

21 layman's terms as well for those of us who may

22 not be as engineering or proficient as others. 
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1 So we should have that too. Any other

2 comments from, yes, Michael?

3 MEMBER LUBLINER: Well, it's back

4 to a discussion that Mark had. I had a couple

5 of questions. One, I've been communicating

6 with some people that work in the factory7 built housing with EPA. They are interested

8 in what's going on.

9 So if there's a possibility I

10 would encourage you, if you haven't, to keep

11 them in the loop. And the Government

12 Accountability Office which has just recently,

13 make sure they're, if possible and

14 appropriate, keep them in the loop as well.

15 And then finally, last week I was

16 made aware of an interpretation on federal

17 preemption that HUD legal Counsel made. And

18 I wasn't sure if you were aware of that or

19 were planning on commenting on it.

20 But it has to do with the State of

21 Minnesota asking, the IPIA there asking

22 clarification as to whether the state could
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1 require blower door testing of manufactured

2 homes when they're set up in the State of

3 Minnesota. This is because all other homes in

4 the State of Minnesota are required to be

5 blower door tested when they're built.

6 And there was a legal

7 interpretation that was shared with everyone

8 from the HUD Council on that. And I would

9 encourage you to look at that legal

10 interpretation and make a call as to whether

11 you concur. Because it does overlap in

12 responsibilities, I believe. Thank you.

13 MEMBER WEISS: It's just Mark

14 Weiss. For me, I don't think that's

15 appropriate. Because there was a

16 determination by HUD OGC as to the statute

17 they're operating under which is the

18 Manufactured Housing Construction and Safety

19 Standards Act which is not a statute that DOE

20 is enforcing.

21 MS. VAIDYANATHAN: We'd be happy

22 to look at different sources of information. 
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1 But we would not comment on another agency's

2 actions taken for interpreting their own

3 statutes.

4 So if HUD interpreted its own

5 statute on this issue, we wouldn't provide any

6 comments. But if it gives us some more

7 information on the issue overall, we're happy

8 to look at any information.

9 MEMBER LUBLINER: Yes. If it's

10 not appropriate, I don't want to ask you to do

11 something that's legally inappropriate but at

12 least put it on your radar screen to look and

13 review. Thank you.

14 MR. HAGERMAN: Thank you, Michael.

15 MS. HOFFMAN: When Emanuel

16 presented his proposed framework for

17 developing a term sheet, there were a number

18 of other topics on the back that we don't want

19 to get, we'll need to deal with them as well,

20 whole house tightness, ventilation

21 requirements, duct system tightness,

22 performance paths, option, and compliance and
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1 verification.

2 Now to some extant, that's

3 subsumed in some of the other things that have

4 been discussed. But let's not lose sight of

5 it, because we'll be dealing with that as well

6 when we come back. Any comments from Joe,

7 please?

8 MR. HAGERMAN: No. I just want to

9 say thank you all for your time and hard work. 

10 I mean, I have a very long list of to-dos and

11 action items out of this. So I feel like

12 we've made good progress. And I look forward

13 to getting you all that information,

14 hopefully, by Wednesday of next week. That's

15 what I'm trying to target for. So appreciate

16 your support and I'm excited about us reaching

17 a consensus. We did forget to ask if there's

18 any public comment --

19 MS. HOFFMAN: Right.

20 MR. HAGERMAN: -- from the general

21 public.

22 MR. RAMIREZ: Well, I looked. And
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1 unless somebody's sleeping --

2 MS. HOFFMAN: Is there anybody

3 remotely on the line, our public remotely that

4 wants to ask a question or make a short

5 comment?

6 (No audible response)

7 MS. HOFFMAN: Okay. Hearing

8 nothing, just remember, for everyone's

9 benefit, we are holding the meetings here on

10 the 9th and 10th from 9:00 to 5:00. If the

11 room changes, we will let you know. We will

12 also, when you see the agenda in advance, we

13 may have an hour or two for subcommittees to

14 meet. But we'll talk to you about that. And

15 thank you all.

16 MR. HAGERMAN: Yes, thank you all.

17 (Whereupon, the above-entitled

18 matter went off the record at 4:10 p.m.)

19

20

21

22
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blower 336:1,5

blown 203:12,13

blue 41:6

board 36:16 193:10

193:12 199:13

222:11,17 280:22

bogged 179:17

bolded 228:7 236:1

236:1

bombed 19:15

Bonneville 205:10

booking 318:1

Bostick 152:12

bottom 69:12 258:9

290:13

bought 46:22 148:1

330:7,12,13

Boulder 328:18

box 19:15 39:10

42:6

boy 282:22

BPI 192:19

brainstorm 276:5

brainstormed

118:10

break 62:8,10

113:6,12 119:10

162:14 163:12,21

192:5 246:13

247:15,17 317:18

319:4

breakdown 281:14

breathing 120:22

bridge 202:2

bridging 40:8

brief 103:9 164:14

briefly 9:10

bring 39:9 95:7,8

159:10

bringing 59:14

327:20

brings 82:3

broad 173:16

broader 129:6

broadly 92:22

broken 198:11

213:10 288:18

brought 15:19 23:2

119:9 145:16

233:10

BTM 265:15

buck 228:4

buffered 67:11

build 31:1 37:17

38:10 42:3 181:10

215:15 233:2

239:1 327:21

buildability 212:18

builders 2:7 44:19

45:9 181:9

building 2:1 4:21

27:13 36:8,9 44:2

51:20 56:7 137:6

137:7 142:21

170:22 179:5

192:4,6,11 202:8

214:10 217:14

230:15 233:13

254:21 284:11

291:7

buildings 156:20

224:20

builds 37:15

built 29:8 32:22

35:10 36:2 43:16

72:15 73:8 74:18

127:22 128:1

133:13,17 167:20

169:21 174:9

183:10 193:21

208:15 300:13

301:8 321:1 335:7

336:5

bulk 57:21 125:8

bullet 99:16 124:20

173:21,22 188:8,9

bullets 63:9

bunch 15:8 21:1

56:11 67:6 88:12

88:20 184:3 283:8

burden 73:1

147:11 209:17

burdened 23:20

burdens 117:13

burdensome 13:16

Bureau 282:11

buried 68:22 252:7

business 112:14

182:9 207:7

219:14 253:22

busted 247:11

butt 220:9

buy 16:8,9 30:18

41:20 92:11 107:1

107:17 109:17

146:16 147:3

234:12 275:16

buyer 73:22 74:1,8

75:14 77:10,14,21

79:9 81:2 82:5

84:7 90:1,21

92:15,20 108:3

270:17 311:12

buyers 197:8

buying 146:21

147:5

by-product 287:5

C

C 38:12 103:4

118:13 119:2,7

123:6

cake 199:8

calculate 237:18

242:13

calculated 242:8

calculation 38:3

94:7 124:2 143:4

171:9 183:3

198:20 238:21

242:5

calculations 28:21

143:13 194:16

237:21

California 32:3

call 18:11 38:16

68:16 76:9 126:2

128:11 182:11

213:19 247:11,17

268:1 319:10,12

319:16 336:10

callbacks 41:1

called 36:13 76:12

183:15 265:11

291:12

calling 171:3

186:10 224:1

257:6 309:6

camera 40:7 321:4

321:5,19 322:4

cameras 321:1,3,10

capability 319:6

capable 181:12

capture 10:11 13:5

14:15 23:1 43:14

70:4 102:13

116:12,12 118:20

127:17 179:6,9,10

captured 11:2

22:14 23:11 64:12

136:16 157:1

298:15

captures 163:5

capturing 15:2

Cardinal 228:19

care 118:15 119:17

299:15

careful 173:3 218:8

Carol 19:4 79:1

Carolina 171:22

carrot 56:19

carry 177:3

carrying 279:13

case 16:11,12 23:5

28:15 110:10

131:1 166:19

168:12 189:3

213:14 243:11

245:4 273:15

275:15 276:16

278:20 280:21

282:20 292:19

298:13

cases 36:4 43:22

65:1 78:3 117:13

130:7 147:1 168:8

201:18 208:19

212:9 218:15,15

234:17

cash 272:9,10,13

Caskey 1:16

103:15,16

catalyst 158:16

catch 245:12

category 157:6

260:21

cathedral 25:1,3,13

26:11 28:14 34:15

34:17,20 35:3,3,7

35:21 64:11

166:19 180:7

cathedrals 43:15

caulk 209:10,11

caulked 209:10

cause 28:7

causes 40:9

caution 56:10,15

Cavalier 2:7 7:18

Cavco 2:6 30:12
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Census 282:11

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certificate 193:17

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cetera 271:16

chairman 152:10

challenge 234:9

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chance 19:15

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change 57:3 62:5

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234:19 235:3

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changed 45:13,14

69:10 105:16,18

175:7 225:17

250:9 251:5

changes 16:2 49:13

78:1 117:4 172:2

211:5 214:21

339:11

changing 49:19

chapters 174:7

characteristics

65:20 104:4 105:2

105:3 170:1

characterize 14:20

75:11

characterized

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charge 81:7 117:22

charged 257:17

chart 98:6

charter 62:3 294:7

charts 230:11

chasing 35:5

chat 117:16

chattel 89:8 106:13

110:6,14 278:21

279:11,14 280:10

cheaper 148:2

check 93:14 98:5

98:16 113:6 320:1

320:2,4 329:9

checked 44:20

329:10,11

checklist 209:12

checks 209:4

Chicago 325:20,20

326:3 327:11

328:18

Chicago's 325:18

Chief 152:11

child 270:19 308:7

chime 213:4

choice 146:22

147:3 148:9,14

153:18 286:1

choreography

163:10

circled 187:21

Circular 103:17

circulate 19:16

44:21 47:3 151:20

162:1

circumstance

156:14

citations 156:8

claiming 198:7

clarification 71:8

73:20 91:14 94:14

101:11 105:21

137:1 159:8 226:1

242:3 249:5

309:11 335:22

clarify 48:12 79:20

111:19 127:7

142:1 159:3

clarity 194:20

class 301:7

Clayton 1:20 6:18

12:18 231:2

clean 9:14 261:1

270:7 298:1

cleaned 270:13

cleanup 254:14

258:6,13 261:21

280:21 287:21

304:11

cleanups 271:10

clear 7:2 34:21

90:20 94:22

101:20 155:22

160:18 161:8

225:16 269:22

275:14

cleared 270:13

clearly 60:7 93:17

218:22 220:7

276:6

click 254:21

clientele 46:22

clients 320:14

climate 33:21

199:13 200:3

205:4 249:14,15

249:16,17 289:15

305:6

climates 40:5,16

41:1 42:10 51:17

205:22 207:9

212:9

clock 248:3

close 106:16 162:16

163:8 210:20

229:10 247:19

253:21

closed 190:6

closer 183:19

213:18 314:17

closing 80:6 305:10

305:11

closure 210:17

co-facilitators

163:9

co-ops 95:19

Coast 325:17

326:10,12

coating 204:6

215:20,20 227:11

code 12:21 13:9,13

13:14 36:10 39:5

53:8 56:3 74:10

74:19 101:22

105:8 130:20

142:21 157:1

164:22 171:22

174:7 178:5 179:9

179:10 180:5

192:17 197:20

236:2 251:3 256:3

259:5 263:18

278:14 289:20

292:16 293:4

301:9

codes 1:22 5:1 56:7

137:6 171:17

200:18 208:13

coefficient 204:9

204:21 205:2,3,21

coefficients 248:14

coffee 247:19

coherent 160:18

cold 40:16 41:1

colder 42:10

collaboration

245:2

collateral 12:3

colleagues 117:16

collection 117:5

Colorado 7:8,11

326:15 328:5,8

combing 173:15

come 29:5 43:1,17

56:13 58:17 61:9

77:6,21 80:12

105:5 113:13

117:2 142:4

144:16 154:3

159:22 162:11

163:12 164:8,13

166:20 175:2

177:4 178:13

182:18 192:20

193:18 212:19

227:5 244:17

276:2,15 292:17

294:18 302:17

314:13 315:3

316:10 317:22

327:16,20 332:19

338:6

comes 23:20 41:11

57:11 112:13

116:15 128:1

153:13 179:1

226:20 227:1

243:4 275:21

286:20 293:11

295:1

comfort 290:14

comfortable 24:19

28:21 244:12

coming 14:7 42:4

42:16 181:4
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commercially

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Commission 219:3

commit 88:19

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committed 64:3,3

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committee 14:10

17:8 23:3 25:15

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107:11 109:21

112:3 122:21

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145:17 148:6

158:17,18,20,22

159:5,11 162:7

186:16 193:9

206:16,18 207:12

209:7 257:5,17

273:21 278:3

279:20 280:2,17

289:9 294:15

295:13 313:18

320:11 332:18

333:2

commodity 213:19

common 166:13

178:17 227:9

263:3

communicating

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communication

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Community 2:4

7:21

companies 181:11

184:8

compared 73:8

74:18

comparison 191:17

competitiveness

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competitor 16:9

compile 68:19

compiling 50:15

complain 262:16

complaint 40:13

complete 50:2

174:16 177:11,15

completed 17:12

completely 49:12

80:9

complexity 89:13

compliance 9:9

14:13 15:6 22:19

28:1 96:10 97:18

100:11 113:10

118:19 142:20

163:15 164:2

166:9 168:19

176:13 182:7,13

219:22 237:1

296:2,3,5,10,10

296:13,17,18

297:3 309:15

337:22

compliant 164:13

complicate 96:15

complicated 225:2

complies 302:3

comply 30:13

182:6 236:18

complying 50:4

component 110:7

127:10 231:13

239:20

components 2:3

6:16 45:10 56:2

60:5 119:11 239:3

239:8 242:13

256:22 257:1

298:15

comprehensive

60:2 63:21

compressed 25:6

188:5,21,22

198:16 200:14

compressing 188:4

compression 36:6

36:17 42:7,22

187:18 198:18

200:6,7,14 203:14

212:14,16 218:20

220:8 231:14

293:3

compromise 28:9

210:8 211:4

compromised

288:16

computer 321:5

324:15,16

computers 320:22

concept 59:7

137:19 196:18

198:10 221:4

conceptually

183:14

concern 25:1 31:16

37:13 49:3 107:13

111:15 129:16

135:3 208:10,11

238:19 267:14

282:1

concerned 22:21

37:18 92:1 172:11

220:14 244:21

292:21

concerning 269:12

concerns 25:16

73:11 217:7 219:3

concession 234:22

Conciliation 1:14

1:15 2:5

concrete 77:5

concretely 308:4

concur 93:6 336:11

concurrence 135:3

condensation 12:2

12:15

condensing 51:14

53:15 54:11 150:4

condition 46:19

252:3

conditioner 206:1

300:2

conditioners 53:22

55:14

conditioning 52:15

205:14,22

conditions 23:1

166:20 216:5

conference 319:10

319:12,16 322:5

configuration

236:10

configurations

25:5 44:3 243:8

confirm 148:22

conflate 75:4

Conflict 2:14 5:20

conform 296:11

conforming 297:3

confusing 99:10

connect 111:8

137:14 263:11

connections 305:7

Conner 196:5,6

connotation 152:18

consensus 20:16

21:17 51:9 65:7

65:20 75:20 98:5

98:10,12,17 99:3

99:8 148:6 158:18

159:11 179:21

206:16 207:12,17

209:7 320:10

338:17

consequences

192:10

conservation

137:10 138:4,18

139:17 144:9

151:17 197:7

consider 17:20

18:1 20:6 72:6,11

79:9 82:4 88:4

155:13 164:3

166:18 189:16

198:19 210:8

227:7 282:8

294:10

considerably 48:6

consideration 61:8

77:9 155:18

160:20 237:20

considerations

10:17 44:9 78:4

117:11 177:14

237:17 295:16

considered 11:1

12:16 311:20

considering 27:7

55:5 79:7 154:12

226:16

considers 187:17
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consult 332:11,12

332:17

Consultant 242:2

consultation

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Consulting 2:12,17

5:16

consumer 31:17

32:9 40:13 85:10

85:11 88:6 94:15

146:16 147:2,3

148:7,8,12 149:4

149:4 153:17

158:19 218:13

245:20 276:15

287:14 299:19

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309:14

consumer's 147:7

consumers 95:19

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consumption 155:9

290:18

contemplating

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content 21:1

CONTENTS 3:5

contested 141:19

context 34:20 58:2

145:15 218:4

contingency 329:14

continuation

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continue 28:22

113:9,15 165:1

183:6 184:19

216:8

continued 155:5

continues 111:6

continuing 3:10

8:19 294:11,16

contract 147:21

contraction 86:8

contractor 115:18

299:22

contractors 193:16

contribute 262:5

control 206:7

221:11 260:8

controlled 13:12

conventional 82:2

82:11,17,20

140:22 141:9

274:3,5 278:22

279:14

conversation 21:19

114:22 164:10

242:16 299:2

315:13 332:7

conversations

130:5 165:6

238:18 315:17

319:6 333:12,16

converted 129:2

convolute 269:15

cooling 54:9 174:4

227:7

Cooperative 1:17

1:19

cooperatives

162:20

copied 284:21

copies 62:5,12

124:8 158:7 195:6

copy 18:12 47:8

49:18 62:10 107:8

121:18 254:8

core 174:8

Corning 39:12 41:6

correct 78:7,22

83:5 87:9 98:6

101:15 119:9

132:10 133:9

138:20 213:17

287:8 307:7

correctly 14:20

82:15 83:13 86:4

255:22 267:19

284:19

cosmetic 29:21

cost 11:3,9,9,22

12:4,11,11,12,22

13:18 15:5 16:5

22:18 23:4,16

27:12 28:5 42:1

42:13 44:5 47:22

48:19,20 52:18

54:20 68:3 72:4

75:6 76:16 83:15

85:4 86:20 90:5,7

91:21 92:1,14

94:16,16 104:10

105:6,7,9 108:17

110:22 111:1

121:9,16,17 122:7

123:1 126:14

148:13 149:9

155:16 156:13

157:19 176:8

179:18 189:15

198:8 199:15,16

204:7 206:2,9

209:17 210:11

212:8 214:2,19,22

216:3,12 226:19

228:20 235:6

245:17 274:8

275:12,17 287:1,2

294:1 307:21

308:12,16 309:15

310:14 311:9

312:22 329:6

cost-effective 217:4

227:6,21

costing 87:13

costs 11:6 12:5,20

13:5 14:15,17

15:2,12 22:16,19

39:8 42:9 64:8

79:6,16 80:21

85:11 111:5

118:20 149:13

155:15 157:13

215:16 228:2

277:10 307:17,19

308:8,19,20,20

309:4,4,6,15

310:4,6 311:4,8

311:11 312:18

313:3

Council 2:5 4:19

336:8

counsel 2:17 55:17

57:19 59:1 126:8

131:5 136:1 137:2

137:4,5 145:18

154:19 160:22

333:13 335:17

counsel's 5:11

136:20 139:3

331:17 332:4,5,8

count 187:7 235:9

counted 199:9

counter 138:19

countertops 46:3

country 32:12

112:9 125:12

133:3 135:15

160:13 181:9

197:14 200:19

212:4 275:18

counts 230:10

231:13

couple 24:22 27:10

39:11 45:3 91:18

111:22 121:15

165:12 174:21

177:12,14 179:13

179:22 180:22

213:8 223:20

314:17,22 335:4

coupling 67:12

course 14:6 85:7

248:6 301:15

304:7 305:13

COURT 49:5

274:16

cover 100:11

308:17,21 311:18

covered 41:6 47:21

58:9 102:5 137:11

138:3,17 139:2,5

139:6,11,17

140:10 142:11,19

144:10 145:10

151:14 284:22

293:4

covers 112:9 168:3

168:4

cracked 331:11

crawl 263:5

crazy 147:14

create 65:3,5 156:2

184:7 258:18

created 184:6

creating 172:6

177:21

creative 277:21

credit 52:10 55:20

56:1,5,12 57:4

273:10,10,16

320:14

credits 214:12

274:7 276:3

criteria 101:14

143:5 147:18

157:18

critical 219:13,16

273:13 301:19

criticism 87:20

cross 97:13

crossover 53:2 67:3

212:1

CSM 69:22

cup 247:18

curb 32:21

curious 253:9

current 172:10

176:18 192:3
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123:6

D.C 1:11 330:4

Dallas 326:2

damming 40:10,19

288:16

dams 40:14

dangerous 55:21

DAPE 267:17

dash 298:9

data 9:11 20:21

33:8,14 40:14

67:14 74:7 83:18

83:21 85:19

101:21 104:14,15

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136:6 215:16

228:20 246:11

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date 31:12 98:10

329:18

dated 45:13 46:9

dates 320:4 327:17

327:19

daughter's 316:2

Dave 24:21 26:5

48:9,17 97:4

117:14 134:5

175:11 216:22

220:20 223:12

224:6 234:6 238:2

298:17

David 2:7 4:17 24:1

37:6 117:14 119:5

123:5 233:10

250:4 257:18

269:17 306:2

day 4:4 37:16

164:12 252:18

294:14 315:20

316:6

days 35:5 46:11

121:15 272:14

313:22 314:18,22

322:15 323:16

DC 303:4 327:16

327:20

deadline 186:18

294:16

deal 9:1 40:15

62:17 88:11 91:13

100:9 123:6

163:13 266:7

306:14,18 316:7

318:19 337:19

dealer 31:2,15

206:12 261:17

dealing 14:5

125:10 197:12

274:22 338:5

deals 174:2

dealt 263:8,21

285:3,4

death 72:12

debate 284:19

decide 36:3 57:19

83:7 97:8 102:17

123:12 132:19

173:4 177:19

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282:16 301:10

304:13,22 305:1,3

307:14 321:8

325:6

looks 33:22 81:9

105:18 127:21

166:5 216:11

229:15 271:9

loop 335:11,14

loose 41:15

lose 59:7 152:22

326:19 338:4

loses 90:9

loss 40:8 52:12 66:5

67:11

losses 53:7

lost 65:4 197:15

198:1,2 202:11

lot 12:20 13:16

26:18 27:9 31:15

35:14 46:20 51:4

61:12 62:2,18

63:10 69:8 81:14

87:20 107:20

114:8 116:10

125:6 133:6,22

134:9 135:8,12

151:18 153:14,15

156:22 157:22

159:9,15,15

161:19,20 163:5

166:6 171:1

174:10 182:5

194:1 197:4 199:5

214:13 216:15

230:19 246:19

254:12 255:8,21

258:8 259:8,9,16

260:4,9,11 261:17

262:1 276:11

277:15 285:19

289:14 303:4

316:8,13,15,15,21

317:16 334:19

lots 13:2 20:21

156:11

loud 7:2 262:16

Louis 325:21

Louisville 329:5

love 26:1 54:18

137:2 193:2

Low 204:5

Low-E 205:20

213:16,18,19,20

214:3,18 216:16

226:15 227:19

228:22 229:1

lower 42:1 55:3,7

57:21 80:13 134:8

155:16 157:14,18

lowest 166:13

Lube 247:11

Lubliner 2:2 3:18

4:9,9 9:4,10 15:4

18:10 19:18 24:8

24:14 34:9,10

37:22 38:1 43:5

50:21,21 53:14

56:16 57:12 65:22

66:21 68:12 72:10

73:4 74:15,16

86:13 94:13,20

106:10,19,21,22

110:2 111:21

120:10,16 124:10

124:14 127:7,14

128:20 129:22

130:11 131:20

132:1,6,13 133:15

134:14 146:5

158:12,15 163:15

191:1 193:7

195:15,22 196:2,5

196:15 213:6

214:7,20 216:9

217:6,19 219:7,11

219:20 220:1,15

220:20 221:2

222:14,17,19

223:5,19 224:10

224:17 225:5,7

228:1,11,15,17

229:7,22 230:4

231:4,21 232:3,5

232:8,22 235:5,17

235:20 243:5

245:17,22 246:18

246:19,22 247:10

250:17 251:15,19

252:21 253:4

267:13,14 275:7,7

285:15,15 286:11

289:12 299:13,14

300:20,21 301:22

312:16 313:11

318:14,15 319:11

319:15,21 320:5

320:13 327:18,19

328:7 335:3 337:9

Lubliner's 191:5

Luby 4:8 74:13

120:7 186:10,15

187:2 189:6,17

221:7 224:1

229:20 248:11

316:1

Luby's 195:11

250:6

Lucas 196:6

lunch 9:7 162:14

163:21

Luter 2:3 6:13,15

6:16 104:22
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322:10 323:15

324:7,10,18 325:2

326:3

M

M-E-E-K-S 78:21

MACC 159:22

magic 176:10

main 231:19

250:14,16,22

maintain 235:12

maintenance 42:9

46:20 310:3,13,21

311:3

major 46:11

making 54:6 75:15

92:2,2 110:9

201:3 203:22

219:16 226:13

245:4 297:15

301:17

man 114:2 223:22

management 54:22

mandate 265:5

mandated 264:17

264:17

mandatory 50:1

56:6 157:4 168:5

168:17,19 172:18

174:15,16,17

175:4,12,20

176:20,21 177:7

184:21 185:1

194:6 251:14

256:9,18,22 257:1

257:5,10 259:18

260:1,7 265:18

268:10 270:5

289:9

manifold 252:5

Manny 5:3 22:7

30:11 71:14 79:2

79:3 86:16 125:5

132:21,22 135:3

159:18,19 161:20

180:14 184:13,14

185:11 186:1

187:1 221:5,22

236:4 245:10

255:7 259:14

265:2 268:4 269:8

287:9,22 290:3

293:6 298:16

299:6 313:15

331:9

Manny's 85:16

92:18 190:3

manual 207:20

267:18

manuals 203:9

MANUEL 2:6

manufacture

228:22

manufactured 1:3

1:18 2:8 4:5,15

18:14 20:8 29:17

31:14,22 32:6

38:18 51:8 73:7

74:19 81:11 82:8

82:12,21,22 83:2

86:9 111:1,8,12

125:8 127:9

129:10,18 137:12

138:6,11,13 139:5

139:18 140:2,4,6

140:8,21 141:14

142:15 144:12

147:4 152:9,12,19

157:12 160:14

165:10 166:16

168:13,21 171:16

172:7 174:18

178:9 181:18

185:2 186:22

190:15 191:15

192:11,21 193:4

195:18 206:15

207:11 219:19

250:13 262:10

263:1,7 273:6,14

279:10,17 280:9

285:21 295:7

302:12 305:14

336:1,18

manufacturer

147:11,12 148:4

148:15 193:2

206:4 229:3 243:1

246:3 277:12

283:17 309:16

311:10

manufacturer's

206:5

manufacturers

1:16 25:12 30:13

39:12 40:15 41:22

52:11 53:4 97:9

128:4,11 135:1

139:21 147:21

149:12 153:11,15

157:16 170:4

186:5 190:20

201:2,19 204:13

204:14 207:5

216:12 217:13

219:15 222:8

227:10 231:12

234:12 242:12,19

287:11 289:16

306:12 308:3

manufacturing

281:22

map 9:12,13

249:16 254:6

266:4 304:19,22

311:14

march 21:17

119:20

margin 246:6

marital 327:21

mark 1:20 2:8 4:14

6:11,18 11:19

12:17,18 13:20

14:2,14,21 17:17

77:11 85:13 101:8

121:12 123:1

125:1,22 133:10

135:16 140:19

146:4 148:4,5

149:1 151:15

153:7 155:20

157:7,8 185:22

186:3 187:1 190:1

190:11 198:12

231:2,3,4 234:7

261:3 274:10,11

279:9 280:6 282:9

287:15 307:8,9

315:15 316:18

331:19 335:4

336:13

Mark's 15:10

86:14 127:4 158:8

311:22

marked 246:4

markers 14:7

99:12 118:17

market 16:7 18:20

18:22 31:16 33:5

35:4,7 51:4 86:7

279:4

market's 34:7

market-based

32:19

marketplace 33:3

109:2 272:13

markets 134:8,10

Marks 15:11 18:17

120:6,18

Marsh 120:5,18

Marshall 18:13,16

matches 189:19

material 58:21

112:15,16 199:16

209:3 317:16

materials 45:14,21

214:10 289:16

matter 26:14 27:17

62:16 75:20 76:16

76:21 85:21

104:10 113:19

152:13 153:4

157:13 163:18

209:14 247:22

285:11 339:18

Matthew 2:17 5:13

Maui 327:8

max 201:14

max/min 64:9

maximum 25:7

34:1 100:13

mean 8:22 17:21

21:20,22 26:13

28:22 29:2 48:20

48:22 54:9 60:15

61:8 68:8 69:15

73:2 79:16 84:19

85:5 102:2 108:3

133:22 139:12

147:17,18 152:19

160:12 173:15

174:6 181:8 186:4

186:6,20 215:18

217:2 218:5 220:2

220:11 223:13

239:14 240:20

250:19 251:20,21

252:10,13,19

261:1 268:19,21

279:3 285:1 288:5

288:18 290:18

294:4 295:4

299:14 306:7

308:14,18 313:20

325:14 328:10,20

333:3 338:10

meaning 49:13

272:10

meaningful 11:14

316:21

means 331:13

meant 15:21 43:10

measure 14:1,18

52:19 60:4 123:17

161:2

measures 11:4,7

12:4,14 13:3 15:9

22:17,17 44:5,16

44:17 47:14 48:5

57:9 64:7 84:13
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mechanical 263:6

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median 152:20

Mediation 1:14,15

2:5

Meeks 19:5 75:2

78:18,21 79:1

93:18 119:13,21

119:22 120:2

meet 25:18,19

28:13 34:7 36:10

112:17 143:5

166:14,17 172:18

188:10 208:1

265:14 317:17

325:16 326:6

330:18 339:14

meeting 1:5,10,11

1:14,15 2:4 4:4

9:21 17:1 23:5,10

61:11 114:1

120:22 121:21

122:8 164:22

188:13 293:15

294:9 320:8 325:8

327:1,22 328:8,10

328:14,22 329:14

329:14 330:4,5

meetings 314:1

317:9 322:5

333:21 334:4

339:9

meets 170:17

meld 312:9

melt 168:9 174:22

member 4:9,12,14

4:17,18,20,22

6:15,18,21 7:3,7

7:10,13,17,20

10:5 11:20 12:17

14:6,19,22 15:1,4

15:15,22 16:21

17:10,16 18:5,8,9

18:10 19:18 20:19

21:4,10,21 22:7,9

22:14 24:8,12,14

24:21 26:5,12

27:16,20 29:12,15

30:11 31:5,18

32:8,16 33:7,9,17

34:9 37:7,22 43:4

43:5,12 44:13

47:3,11 48:9,17

49:1,2,4,8,17,22

50:21 53:12,14

54:5 55:10 56:16

57:5,6,12 58:6

59:2,5 60:9 61:7

62:15,20 63:3,18

64:2,15,18 65:5

65:22 66:11,19,21

67:22 68:12 69:14

70:5,19,21 71:2

71:16 72:1,5,10

72:21 73:4,19

74:6,15 75:1 76:8

77:3 78:17,22

79:3,19 81:19

82:19 84:1,10

85:1,15 86:13

89:4,11,19 90:17

90:19 91:17 93:6

94:13,20 95:5,11

95:18 96:12 97:1

97:3,4,10,12,19

100:1,12,20,22

101:8,17 102:7

103:8 104:2,5,9

104:13,18,20,22

105:4,12,17,20

106:6,10,17,19,20

106:21 108:15,21

109:11,13,15,17

109:19 110:2

111:19,21,22

114:19 115:5,16

115:20 116:4,9,19

116:22 118:16

119:13,18,22

120:10,16 121:5

121:12,20 122:6

122:10,13,16

123:20 124:5,10

124:14 125:2,16

125:21 126:2,9,18

127:7,14,18

128:10,17,20

129:14,22 130:11

131:20 132:1,6,13

133:15 134:14

140:19 141:9,16

141:22 146:5

150:13,20 151:5

151:21 152:4

154:17 155:21

157:8 158:12,15

160:8 162:6 164:5

164:16 169:8

173:11,20 175:9

175:11,14,16,19

175:22 176:1

180:16 182:20

183:14 184:10,14

185:3,13,15,19,22

186:19 187:4,6,9

187:11,12,19

189:2,10 190:2,7

190:11 191:7,20

193:7 194:19

195:9,13,15,20,22

196:1,2,4,5,7,15

213:3,6,8,14

214:7,8,20 215:8

216:9,22 217:6,7

217:19 219:4,7,9

219:11,12,20,21

220:1,15,18,20,22

221:2,5 222:5,14

222:16,17,18,19

222:22 223:5,6,19

224:6,10,13,15,17

225:5,7,22 226:9

226:12,22 227:15

227:17,18,22

228:1,11,15,17

229:7,8,17,18,20

229:22 230:1,4

231:1,4,5,21

232:1,3,4,5,7,8,10

232:11,12,15,22

233:16,20 234:6

235:5,17,20 236:4

237:14 238:1,11

238:15,17 239:13

239:16,18,22

240:7,16,21 241:6

241:9,13 242:14

242:22 243:5

245:22 246:18,22

247:10 250:5,17

251:4,13,15,17,19

252:19,21 253:1,4

253:5,9 254:2

255:7 256:1,5,17

257:2,4,8,12,19

257:22 258:19,22

259:12,15 260:1,3

260:13,19 261:3,8

261:10 262:2

263:13 264:1,5

265:2,9,17 266:1

266:11 267:13

268:4,16,18 269:9

269:18 270:4,15

270:22 271:4,11

271:20,22 272:2,7

272:11,17,19

273:22 274:11,18

275:7 277:3 278:7

279:22 280:4

281:6,9,12 282:9

282:18 283:6,16

284:16 285:6,10

285:12,15 286:11

286:18 287:10,15

287:22 288:2,10

288:12 289:3,12

290:4,14,17,22

291:4,10,17,20,22

292:10,13,20

293:5,20 295:18

296:16,21 297:14

297:20 298:2,4,12

298:18 299:5,13

300:8,20,22 301:4

301:22 304:4,6,21

306:3,7,13,17

307:9,13 308:9,14

309:13 310:1,7,10

310:11,12,16,18

310:20 311:1,2,5

311:7,21 312:6,9

312:16 313:7,11

313:12 315:9

317:13 318:5,8,14

319:11,15,21

320:5,13 321:12

321:15,18,22

322:3,10,22 323:4

323:15 324:5,7,9

324:10,12,18,21

325:2,4,13,15,20

326:2,3,9,11

327:9,15,18 328:7

328:13 329:3

330:17 331:20

333:1 335:3

336:13 337:9

members 23:2 94:2

102:16,20 284:1

313:19

Membership 190:6

memo 154:19

mention 31:12

100:2 279:7

mentioned 17:1

21:22 44:18

103:17 105:21

126:11 174:22

177:18 178:2

226:5

mentioning 96:3

merits 88:13

mesh 21:6

meshing 20:22

message 113:2

244:17 284:4

messenger 196:19

met 19:20
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metrics 10:20

11:18 20:17 22:16

MHARR 152:11

261:3 274:11

MHCC 306:18,20

MHI 19:4 74:17

119:15 205:19

mic 74:5 89:10

Michael 2:2,7 3:18

6:14 7:17 9:4

15:3 19:12 24:5,7

32:15 43:13 50:20

53:12 65:21 72:9

85:14 86:12 94:12

110:1 146:3

163:15 196:13

217:1 232:14

245:15 246:1,10

275:6 277:5

298:19 301:3,21

312:15 335:2

337:14

Michael's 165:19

micro 127:8 129:9

microphone 49:6

131:22 190:5

247:9 274:17

Microphones

259:22

middle 83:21 88:18

88:21 93:14

midnight 211:10

224:11

Midwest 130:3

mike 4:9 34:9

37:22 50:21 74:15

104:14 111:20

134:10 152:5,6

153:10 190:22

231:1 235:1

246:18 267:13

275:7 285:15

299:13 300:21

318:14 324:1,2

327:18

Mike's 234:8

million 126:18

197:5

Milt 196:21

mimic 251:3

mind 9:12,13 29:4

63:1 75:7 91:9

115:15 118:18

160:2 183:9 236:6

254:6 279:7 281:2

329:18

Miner 196:21

mini 98:4

mini-split 53:21

57:13

mini-splits 56:22

56:22

minimal 215:2

216:2 267:8

minimize 42:8

230:12 233:4

265:3

minimizing 205:17

minimum 29:18

30:12 40:1 85:16

85:19 137:17

143:6,8 179:12

194:3 203:1

Minnesota 335:21

336:3,4

minute 211:16

247:11

minute's 211:18

minutes 10:11 45:3

47:12 113:13

247:16

misconstrue 220:2

misrepresent

218:13

missed 53:13 57:16

96:6 173:17

missing 70:21

89:20 291:11

mission 58:4 131:5

276:7 291:3

misspelled 283:17

misspoke 56:17

mistake 48:8

mistaken 114:12

mitigated 92:3,4

mix 94:8 129:2

MLS 191:13

mobile 129:17

138:8 273:6,9,16

model 20:8 108:4

109:5 183:12

238:13,22 239:1,2

239:3 243:9

249:14,19

modeled 249:20,21

253:19

modeling 68:14

71:3,6 199:9

239:14 240:11,13

240:14

modification 269:7

modified 307:2

modular 165:4

262:12 263:4

moisture 12:2,15

40:9,19 207:8

mold 42:2

moment 22:15

121:2 163:3

momentum 329:22

money 80:17

197:22

month 80:12 81:5,5

81:6,6

morning 4:3 6:15

6:17,19,20,22 7:1

45:7 118:10

136:17 175:3

177:17 211:13

325:14

mortgage 80:15,20

83:16 84:21,22

87:15 110:6,14

302:7

mortgages 274:3,5

278:22 279:15

280:10 283:2

motion 72:6

move 47:12 88:16

99:5 108:19

124:16 246:8

258:15 264:6,9,12

269:22 271:9

283:20 290:13

292:7 296:13,19

331:12

moved 305:21

moving 39:21 51:5

52:17 60:18 103:3

123:15 191:10,16

235:10 273:14

301:19

multi-section

209:18 210:6,12

multiple 9:9 28:1

42:8 96:10 97:17

97:17 100:10

113:10 164:2,9,13

239:22 319:5

Murphy 197:1

mute 8:9 323:13,17

324:2

muted 262:4

muting 323:8

N

NADA 106:12

107:1 108:11,22

109:3 110:4,18

111:7,12 112:1,6

NADA's 110:13

NAECA 56:6 143:1

144:7,17 150:15

151:7 162:1

260:10 261:19,22

NAHB 16:22 17:17

17:18 18:16 44:21

119:8 121:6 122:6

136:5

nail 75:22 78:12

229:19 279:18

314:10

naive 245:1

name 28:8 126:1

176:5

named 196:21

names 186:10

narrow 104:6

142:2

national 1:16,17,18

2:15 33:15 44:18

45:8 137:9 139:10

147:20 151:17

157:15 326:14

natural 2:5 4:18

162:20

Navigant 2:12,17

5:14,15 48:12

115:1 242:2

316:12

near 56:13 189:7

nearly 264:13

necessarily 54:14

146:19 161:19

239:10 247:4

267:15 277:15

317:4

necessary 168:5

need 10:1 12:7

15:10,11 17:22

20:16 21:12 34:3

34:11,21 35:2,19

36:5,8 37:8 38:21

39:3 43:20 57:3

60:14 62:16 63:17

66:8 67:14 68:13

69:10 70:17 71:21

73:13,14 76:5

78:14 80:4 83:10

83:21 88:15 89:16

104:10 114:9,11

116:11 117:4,12

118:13 123:5

126:10,14 127:17

127:18 130:6

144:4 145:20,22

154:13 160:18
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negative 290:2

negatives 286:4

negotiable 175:4

negotiated 141:1

neither 152:18

NEME 111:10

net 113:3 205:9

Network 1:19 4:13

never 151:12

152:22 169:12

187:21 263:21

new 41:17 59:17

129:20 166:8

177:2 204:2

244:12 281:14,18

282:12,16,17

news 211:15,18

newspaper 302:11

Nez 205:11

NFRC 204:19

nice 159:12 168:11

185:6 199:4 271:7

286:2 312:1

nicely 216:6

Nickel 302:10

night 19:14 69:3

120:11 224:11

330:4

ninth 314:4,7,9

315:7 316:9,22

317:10,18 325:9

nipping 220:9

nitty-gritty 320:17

nod 284:8

noise 8:11 252:22

252:22 258:17

263:16 264:6,15

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nominal 188:5,13

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198:17 200:15,15

202:6 203:3,10

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North 171:22

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64:2 71:11,13,20

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136:21 137:3,6

139:3 331:17,18

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120:2 126:8

138:12 175:14

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129:17 133:16

134:18 143:4

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313:13 334:20

337:12

putting 41:14 63:2

68:2 98:15 106:22

131:16 157:22

187:14 217:9,15

221:8 274:20

305:21

Q

QA 207:20 211:7

230:11 267:21

268:1,15 269:8,9

qualified 113:1

qualify 273:1,5

302:7

quality 203:9 207:6

208:5 209:1,6

210:2 211:3 230:7

265:7 267:17

quantify 286:6

287:3

quantities 183:1

question 20:4,7

61:5 66:1 73:20

77:11 86:14 95:16

98:3 104:5 126:19

133:13,16 136:2

137:8 139:2,12,21

140:20 142:17,18

144:7 145:1,21

150:20,22 154:10

156:9 157:10

158:10 173:10

187:10 189:1

220:11,17 225:9

229:9 231:16

233:10 237:21

262:8 266:19

274:1 285:16

292:14 307:14

320:20 331:20

339:4

questions 3:15 9:3

69:1,9 113:8

134:4 140:16

142:1,2,6 143:20

143:22 146:10

150:13 151:19

153:8 154:7

177:13 184:11

196:8,10 213:2

221:17 228:8

331:16 335:5

quick 68:17 187:10

222:1 233:9

247:17 251:20

254:13 303:2

quicker 331:13

quickly 68:19

333:20,20

quieter 285:21

quietest 264:10

quite 20:22 45:20

46:17 54:17 112:7

145:12 183:20

192:14 206:15

300:9 309:7

322:11

quote 151:13 198:7

R

R 26:16 27:8 30:8

30:10 31:9 33:19

34:2 40:4,17

41:16 43:9 59:20

65:2 188:20

199:20 200:22

203:9 231:7

243:14 245:18,21

288:13

R-11 200:7,15,19

R-13 200:20

R-15 201:7 202:6

R-19 187:16

R-21 199:12,18

200:15 201:6

202:7

R-30 199:11

R-38 203:4

R-4 211:10

R-49 203:10

R-8 212:3

R-value 167:2,17

188:14 198:13,15

198:17 203:4

218:18 238:8

240:17 302:2

R-value/U-factor

171:6

R-values 164:17

189:8 218:7

R11 67:7

R15 223:14

R19 220:6

R3 224:14,15 225:2

236:21 250:9,15

R30 26:17

R32 248:15

R33 67:9,10

R38 25:2,4 108:1

220:6 223:8,11

235:2 243:14

R4 224:7

R49 217:9,16,16

233:20 234:14

236:7,8,11 237:5

238:5 240:22

241:21 243:14

R5 222:11,11

R60 26:2

racing 254:2 279:8

radar 337:12

radio 262:20

rail 231:19

rails 29:2 269:11

raise 94:1 187:19

307:13 329:13

raised 44:16 135:4

187:20

ramifications

289:19

Ramirez 2:4 6:3,3

8:5,8,18 17:7,14

24:5,7 27:15,19

29:14 32:14 37:5

44:11 45:6 47:2,5

47:10 49:7,11,20

50:17 54:4 55:9
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213:2,12 220:13

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223:20 224:4

225:3,6,9,14,19

226:21 229:6

230:22 231:3

232:14 233:8

234:5 237:12

245:7 246:7,21

247:7,13 249:4,9

250:3 253:7 254:5

255:17 256:4,11

256:14,20 257:7

257:15,21 258:2,4

258:21 259:6,14

259:19 260:22

261:9,20 263:9

264:4,20 265:20

266:3,18 268:15

268:17 269:6,17

270:2,6,18 271:7

271:17 272:3,15

272:18 273:20

274:10 275:6

278:1 280:3,18

281:8,11 283:10

283:18 284:3,7,10

284:14,18 285:8

285:13 286:9,16

287:4,18 288:1,8

288:11 289:8

290:3,11,15,20

291:1,8,15,19,21

292:3,12 295:10

296:12,19 297:8

297:19,22 298:3

298:10,14 299:3

301:2,21 302:22

304:1,10 306:2,15

306:21 307:12

308:6,13 309:10

309:21 311:13

312:5,12 313:14

319:8 320:19

322:9 323:20

325:18,22 326:21

328:1,9,21 330:9

338:22

random 208:14,17

range 25:9 169:4

rarely 35:13

305:21

rate 76:18 103:15

103:15 207:13

rates 106:3 149:2

278:21

rating 69:18 178:2

178:5 179:3

192:13 193:20

ratings 69:16

rationale 89:16

139:4,15 140:18

144:11,12,16

145:3,4 154:9

raw 101:21

reaching 65:1,2

338:16

read 98:22 162:16

245:15 268:19

315:18

reading 6:11

ready 163:22 304:7

real 18:1,2 61:18

61:19 68:17 89:9

182:3 198:4

207:14 211:12

224:18 237:16

251:20 303:2

realistic 42:15

244:20

realistically 114:7

reality 215:5

245:19

realize 149:7

really 12:19 36:19

38:2 42:18 43:11

51:3 75:6 76:15

76:20 80:17 81:7

84:17,21 91:8

92:3,17 96:6

114:22 127:15,15

145:19 149:17

159:3 168:4 175:1

179:9 181:2 189:4

190:18,20,22

198:20 199:1,2

200:8 207:20

208:22 209:14,22

212:11 213:11

216:18 218:1,14

218:14 220:21

227:1 230:6,12

231:6,7,15 232:16

237:6 248:8,10

250:7 255:21

261:13 273:17,22

275:4 276:7

279:18 289:21

299:15 307:2,10

314:10 318:20

320:15 322:18

327:7 333:19

realm 206:5

reason 32:9 43:20

48:18 67:4 75:9

81:22 106:4 113:2

155:4 169:14

170:3,21 182:21

267:9 268:7

reasonable 76:17

108:17 132:10,14

133:4 149:2 176:9

205:20 211:6

reasonably 166:16

reasoning 79:10

85:16

reasons 169:15

192:7 234:20

236:13 244:20

301:20

rebates 94:4

recall 15:19 242:15

242:16 267:1

315:20 318:21

recapture 92:9,14

103:11 104:1

105:1 106:2,3

270:16

recaptured 90:3

104:11

recapturing 105:10

receipt 58:21

received 111:10

receiving 93:2

recirculation 252:8

252:9,14

recognition 60:10

recognize 62:16

110:10

recognized 110:21

111:15,17 193:19

recognizing 112:19

191:10 193:20

230:14

recommend 19:3

156:2 172:5,6

176:4 177:3

204:19 294:13,15

recommendation

38:19 57:11 61:16

172:4 177:20

191:2 235:16

274:20 275:21

294:10 295:8

recommendations

158:20 172:15

295:3

record 5:4 113:19

163:18,21 169:7

196:14 247:22

319:20 326:8

330:1,16 333:9

339:18

recovery 51:21

91:20 106:14

red 98:11 99:8

303:4

reduce 40:18 52:11

53:6 205:14,22

233:5

reduced 161:3

reduces 216:4

reducing 313:1

redundancy 291:3

redundant 290:21

311:12

reference 11:22

72:13,18,22 73:9

73:17 76:2 96:20

111:12 140:20

143:9 158:7

194:11,18 209:5

255:6 307:21

referenceable

72:17

referenced 18:11

127:9
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referencing 96:19

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referring 122:17

refers 307:15

refine 156:9 215:4

228:12

refined 17:5

reflect 62:12 117:3

215:4 246:4

299:10 308:10

reflected 124:1

reflective 226:2

reflects 61:19

Reform 2:8 4:16

refrigerator 52:4

147:12,18 148:3

148:13 149:21

261:16

refrigerators

147:20

regard 11:4

regardless 130:20

133:18 200:3

206:8 285:4

regards 13:9 59:20

191:8 262:7

266:13 301:5

304:19

region 31:20 234:3

305:6

regional 133:21

regionally 33:11

regions 305:3

regular 214:3

regulated 13:11

58:10

regulating 37:3

293:22

regulations 147:13

regulatory 2:8 4:16

13:10

rehearsals 163:11

reinforce 91:19

reinvent 299:20

rejected 51:10 52:1

related 11:22 12:5

125:5 142:3

263:18

relates 187:18

relating 12:1

relationship 238:9

relative 35:21 58:4

relatively 166:22

210:19

relevance 287:17

relevant 9:18 77:9

78:3 79:17 80:2

85:3 114:20

131:11 158:9

258:13 333:6

remanded 141:18

remedial 12:14

remember 145:15

224:11 255:17,22

257:13 258:17

282:10,14 284:18

339:8

reminder 98:16,19

125:4,17 311:14

312:2,7

remote 284:1

remotely 315:12,16

339:3,3

remove 247:6

removed 260:18

266:16,19

Renewable 2:13

326:14

repeat 308:15

rephrase 273:3

replace 84:4

273:18 292:15

replacement

273:10,16 308:19

309:3

replaces 111:8

replacing 41:12

report 18:16 44:22

45:11 46:8 217:14

278:4,5,6 281:4

REPORTER 49:5

274:16

reporting 219:17

316:17

represent 35:4

127:11 148:7

158:19 201:8

representative 32:6

67:21 110:13

represented 25:15

245:16

represents 160:13

request 20:10

132:11

requests 141:1

require 51:16

55:13 153:18

158:21 168:12

250:10 269:2

336:1

required 50:6

53:16 123:22

135:11 155:2

172:17 200:20

227:3 251:7

260:17 336:4

requirement 51:12

142:14 167:9

170:14,18,19

205:2,4 206:17

219:13 251:5

298:22

requirements

10:13 11:19 30:14

48:1 63:12 97:15

97:22 100:3,4,14

101:10 142:21

153:21 166:15

167:4,8,10,19,21

170:22 174:5,8

176:16,19 188:10

188:15 217:13

251:14 255:13

256:9 257:10

265:18 292:16,22

337:21

requiring 157:11

resale 92:5 103:11

104:2 105:11

110:13 112:14

270:16,16 301:15

resale/recap 104:7

resale/recapture

104:8

REScheck 165:4

171:3,13,14,18

172:8,10 177:19

177:22 183:3,18

183:20 187:17

190:15 194:8

295:6

research 2:1 4:21

31:17 32:10 51:19

72:13,14 104:16

137:13 145:6

182:2 210:15

266:6 305:1

researching 150:19

reservations 331:8

residual 90:8

resistance 155:7,9

160:15 161:5

resistant 244:5,11

resizing 227:8

RESNET 192:19

193:8,8,12

RESNET's 268:22

Resolution 2:14

5:21

resolve 88:8 155:22

265:15 323:13

resource-engulfing

46:14

resources 2:5 4:19

123:18 159:13

197:8

respect 12:15 42:19

226:13

respects 166:6

respond 132:19

153:10 334:16

response 31:19

81:19 95:3 152:5

266:21 339:6

responsibilities

60:19 336:12

responsibility

43:17

Responsible 1:22

5:1

rest 57:7 112:9

279:14

restate 104:1

restrictions 143:2

144:21 145:5,7

157:3

result 48:14 68:3

86:9 112:20 113:3

156:19 184:7

216:20 272:22

results 20:9,11

116:8,8,10,20

253:15,19,21

resumed 113:20

163:19 248:1

retail 149:2

retailer 146:18

148:5 206:3

retailers 190:21

246:6 287:11

rethink 296:8

return 252:8

review 9:6 72:14

254:13 304:3

311:17 333:19

337:13

reviewing 9:21

87:17

revise 46:10

revised 8:16 284:12

295:6

revisions 245:11

revisit 262:6 266:4

revisiting 9:12

revolves 196:20

rework 116:1

Richard 1:20 2:3

6:12,13 7:20

Rick 7:7,10

ridiculous 36:11

right 8:13,18 14:19

14:22 21:19 22:21

23:11,12 24:4
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272:15 278:10,18

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313:14 316:10

323:11,14,18,20

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rigid 222:11

rim 43:6 231:19

road 30:3 193:14

194:1 199:3

210:16 301:16

roads 154:14

Rob 6:15 104:22

213:3,6 225:16,22

228:18 264:1

321:17,20 324:14

Rob's 216:11

Robert 2:3 6:12

214:20

Robin 2:5 4:18

20:6 24:6 49:7,10

49:16 54:4 57:6

58:6 77:3 84:10

86:16 91:16,17

93:7 95:4 101:5

103:8,22 105:21

106:5,17 108:13

108:19 109:10,12

126:11,20 141:16

154:16,17 156:15

158:3 160:4,6

237:13 242:14

253:8 260:13

270:15 311:21

315:9 321:12

robust 182:13

183:20

rolling 246:14

roof 26:2,15,17

29:16 30:2,4,7,12

30:16 31:12 32:17

33:1 34:1,4,7,13

34:16,19 35:2

45:22 46:1 135:11

203:7 217:9,16,17

220:6 223:12

234:21 236:7

241:1,4,5,21

roofing 45:21 46:2

roofs 30:19 32:11

room 1:10 4:7

186:9 234:15

293:7 319:19

323:22 330:22

339:11

rooms 320:3 331:4

roughly 149:6

169:3 171:10

180:1

round 289:7

rounding 76:20

Roy 2:5 4:18,18

20:19 21:4 26:5

49:1,4,8,17 54:5

57:6 58:6 77:3

84:10 91:17 95:5

95:11,18 96:12

97:1,3,10 103:8

104:2 106:6,17,20

108:15 109:13,17

128:10,17 129:14

141:16 154:17

160:8 237:14

238:11,17 242:14

242:22 253:9

254:2 260:1,13

270:15 286:18

287:10 310:1,10

310:12,18 311:1,5

311:21 312:6

315:9 321:12

327:9 328:13

rule 161:14 199:22

212:3

rulemaking 138:8

138:16,21 140:22

141:8,20

rulemakings

139:10

rules 36:21 128:15

142:22 143:12,15

170:2 183:16

184:3 199:18

run 27:3 106:18

109:5 130:6 222:2

223:22 225:16

226:8 231:12

235:16 239:5

250:14,16 264:11

264:18 282:12

303:9,16 310:12

running 179:11

222:2

runs 222:3 236:5

Rural 1:17

S

S.W 1:10

SAA 40:12,12

135:2

SAAs 128:22

safe 222:10

Safety 336:18

sag 200:9

sake 100:14 177:10

291:2

sale 91:21 92:15

104:11 112:19

198:8

sales 31:3,22 128:6

128:7 129:20

147:20 206:11

220:5 302:11

312:20,21 313:1

salespeople 113:1

sample 64:5

Santana 2:6 5:3

22:9 30:11 31:18

71:16 79:3 81:19

82:19 84:1 85:1

100:22 132:22

159:19 184:14

185:13,19 221:5

222:5,16,18,22

223:6 236:4

239:22 240:16,21

241:6,9,13 251:13

255:7 256:1,5,17

257:12 259:12,15

260:3 265:2,17

266:1 268:4 269:9

270:4 284:16

285:6,12 287:22

288:2 289:3 290:4

290:17,22 293:5

293:20 298:4,12

299:5 300:8

325:15,20 326:2

329:3 330:17

sat 41:21 301:6

satisfy 29:6

save 149:6

saving 211:20

267:8

savings 41:2 83:11

87:11 92:10 94:7

155:17 199:6

206:10 211:21

215:1 216:21

228:3 255:20

267:3 280:14

saw 98:11 170:13

267:5

saying 10:21 12:19

39:19,20 40:21

77:5 78:2 82:15

83:14 86:19

101:22 112:16

144:3 148:8

170:15 173:12

200:13 212:8

231:17 244:13

248:5 259:16

260:14,20 267:10

271:18 275:9

277:6 296:13
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307:15 326:5

333:9

scale 226:20 267:21

scary 134:15

scenario 166:12

243:11

scenarios 67:20

schedule 9:22

17:13 329:1

scheduled 330:20

Schneider 2:6 6:13

7:16 8:3 29:12,13

29:15 31:5 32:8

33:7,17 59:2,5

69:14 70:19 71:2

191:7,8 261:8,10

262:2 263:13

266:11 268:16,18

272:17,19 273:22

278:7 281:9

282:18 283:16

285:10 288:10,12

290:14 291:4,10

291:17,20,22

300:22 301:4

304:6,21 306:13

311:7 321:18

322:3,22 323:4

324:5,9,12

scope 13:12 49:9

59:12 60:7 95:6,9

101:9,18 146:2

257:20 265:8,11

268:13 270:12

271:14,19 285:16

286:10,14,19

288:5 293:19

295:12 306:4,10

score 178:5 329:9

331:8

scores 320:14

Scott 1:19 7:5,13

94:2,9,10,14

95:15 277:19

324:21

Scott's 280:11

scrambling 214:14

scratch 285:7

scratched 266:14

screen 49:19 214:6

337:12

scroll 60:22 114:13

194:10 214:4

seal 209:3,3

sealants 13:3

sealing 13:2

seamless 163:10

183:4

seat 60:22

sec 95:15

second 4:4 77:15

92:16 99:16 122:5

142:18 173:6

264:21 297:11

307:11

Secretary 161:13

332:15,16

section 13:22,22

14:18 22:22 33:19

33:22 98:5 101:3

174:2 186:8 210:4

210:9,18 240:5

254:10 262:5

295:20 296:8

section's 296:1

section-by 254:9

sections 14:9

168:17 169:5

172:18,22 173:4

173:14 174:1,10

174:15,16,17

175:4,12 176:20

184:21,21 185:1,7

210:13

sector 131:2

see 9:14,18 10:11

11:13,16,20 19:20

20:15 23:10 26:2

32:5 33:21 35:14

40:7 44:22 54:18

58:12 70:17 71:3

71:12 79:10,16

83:15 85:6 87:8

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334:11 338:12

wearing 323:7

weather 244:5,10

weatherization

197:18 202:11

weatherize 197:20

Webinar 314:15

322:8 324:15

website 305:1

wedge 40:20

Wednesday 249:2

325:10 338:14

week 64:16 207:15

249:2 253:22

322:12 335:15

338:14

weekend 69:7,7

weeks 121:16

Weiss 2:8 4:14,14

11:20 16:21 21:10

21:21 62:15 72:5

85:15 104:5

121:12,12,20

122:6,10,13,16

125:2,16,21 126:2

140:19,19 141:9

150:13,20 151:5

151:21 152:4

157:8,8 190:2,7

260:19 261:3,3

274:11,11,18

280:6 282:9,10

283:6 287:15,15

307:9,9,13 308:9

309:13 310:7,11

310:16,20 311:2

312:9 313:7,12

331:20 333:1

336:13,14

welcome 228:21

315:5

went 37:12 113:19

148:6 151:11,16

158:16 163:18

173:17 181:21

183:15 247:22

260:6 339:18

weren't 238:19

West 133:22 153:5

326:10,11

whatsoever 220:11

wheelhouse 90:16

wheels 185:10

whip 331:11

whiting 48:15

wholesale 148:21

201:1 246:2

wide 234:2,10

238:4,4 240:1,5

241:16,17

widely 81:22

wides 35:12 211:3

width 238:3,8

widths 240:1

wife 327:20

Wikipedia 152:3

willing 207:5 235:1

willingness 276:12

win-win 39:2

window 204:2,5,10

204:11 213:4,16

257:2 258:8 287:2

window's 204:20

windows 107:21

170:7 203:17,18

203:20 204:1,12

204:22 205:21

215:13 225:17

226:6 286:1,2

287:6 288:18

290:7 305:10

wish 148:15 320:13

wonder 313:8

wondered 117:14

283:13

wondering 15:5

29:16 30:5 238:12

279:18,19 281:17

286:3 305:15

307:20

word 43:2 98:19

152:16 195:14

297:6 316:11

wording 94:22

words 24:15 49:9

49:12 66:4 87:10

173:18 207:22

302:15 333:4

wordsmith 115:22

wordsmithed

115:21

wordsmithing

117:8,9

work 17:8 30:5

38:16 74:17 88:21

100:21 107:7

109:9,21 119:6,10

120:14 132:3

137:3 162:7

163:22 178:14

187:15 192:13,19

194:14 195:20

207:6 210:10

212:3 223:14

230:18 231:6

237:2 266:6 271:9

294:16 295:2

314:8 315:8

316:11 317:19

320:16 331:1

334:6 335:6 338:9

worked 38:8

206:15

working 1:3 3:13

4:5 9:2,18 20:5
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worry 293:2,15

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worth 46:17,17

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wouldn't 26:10

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wrap-up 9:22

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write 186:12 334:5

writes 334:7

writing 230:3

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X

Y

Yeah 324:12

year 73:2,5 74:12

74:13 76:19 83:8

83:13 89:22 149:6

316:4 326:12

years 45:22 51:9

72:7,15 75:4

76:15 77:16 80:9

80:11 81:3,10,13

81:16,21,22 82:9

83:3,4 85:21 91:1

91:6,11 94:3,5,8

94:15 107:19

111:2 141:20

151:4,12 158:18

158:20 197:11

199:19 204:15

205:10 206:16

208:8,15,16,21

230:20 233:3

302:5,9

yesterday 9:10

15:18 21:22 24:2

36:13 39:19,20

44:16 51:7 68:18

75:12 103:17

110:21 145:16

152:22 178:3

187:21 195:4

238:18 242:1,6,21

259:2 279:9 280:8

yield 113:11

York 244:13

Z

zero 90:12 92:7

106:1,5,15,16

108:3 111:16

113:3 205:9

zone 199:13,17

200:3 201:12

204:4 205:5

213:15,20 214:5

214:17,17 223:15

226:6 227:2,2

235:2,20 236:16

237:4 289:15

zones 33:21 125:13

201:17 203:10

204:11 205:4

212:22 229:14

249:7,13,14,15,16

249:17

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0

0.075 245:21

0.22 215:19

0.25 205:3 214:17

215:1,19 216:11

228:5

0.28 213:18 214:3

214:22 215:7,18

216:11 225:18,18

228:5

0.30 204:12 213:22

214:13,13,15

0.31 214:8,14

225:18,18

0.35 204:10 205:1

225:18

1

1 90:15 95:6 98:5

102:6,14 169:8

199:17 201:12

203:10 204:4

205:4 213:15

214:17 223:16

227:2 248:12

254:19 258:13

267:6 268:21

1.2 200:22 201:9

291:19

1.4 256:12,13

1.5 256:6

1.51 256:7 257:12

258:3

1.52 256:16

1.53 256:16

1.54 256:12,16

1:13 163:19

10 32:1 47:12 48:6

48:7 69:3

10:00 60:10

10:30 58:17

10:51 113:19

100 69:22 81:16

90:12

100,000 208:15

302:1

1000 1:10

109 3:13

10th 314:21 330:10

330:20 331:7

339:10

11 203:12 231:17

249:16

11:00 19:14

11:13 113:20

12 32:1 91:11 240:1

241:16

12-year 91:13

12:03 163:18

13 203:12

131 3:15

14 203:11

140-degree 52:16

140-some 181:9

15 48:7 69:3 113:13

272:22 273:4

15-minute 113:12

16 201:18 203:11

160 181:9

17 236:17,21 237:3

241:18,20

193 3:17

1st 328:5,18 329:1

329:13

2

2 22:22 64:2 201:17

203:10 204:11

205:4 213:20

214:17 222:7

226:6 227:2

248:12 265:1

285:2

2,000 140:15

2.1 260:2

2.3 260:2

2.4 259:2

2.5 227:1,13

2:28 247:22

2:46 248:1

20 48:6 83:3 94:3,8

94:15 111:2

208:21

2005 45:12

2006 18:17 45:12

171:19

2007 45:11 150:21

151:10,11

2009 55:22 171:19

2011 127:4 129:9

2012 55:22 171:19

227:3 251:6

2014 1:7

2015 33:20 55:22

96:21 101:19

165:8 166:5 168:3

169:4 171:20

178:3 189:12

227:3 251:6

265:11

2050 150:8

21 200:4,5 231:18

231:18

21st 327:10

22 1:7

22nd 317:22 318:4

327:10

23rd 318:1,4

295 3:20

2nd 328:5,18 329:1

329:13

2x4 201:13,13

202:6 223:3

2x6 187:16 200:5

201:17 202:7

223:1 230:15

2x8's 230:15

3

3 13:22 14:18 71:11

71:20 90:15 101:3

201:17 204:11

205:5 208:19

214:5 215:12

235:2,20 236:16

237:4 239:4

248:15 266:10

267:5 270:9

3-1/2 208:20
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3/4-inch 250:12,17

251:8

3:00 325:11

30 27:11 72:7 73:2

73:5,10,12,14,17

74:13,22 76:3,22

77:5,16 81:10,13

81:21,22 82:9

83:3,12 85:20

151:3,12 161:4

279:16

30-year 76:7 78:14

79:8 86:2 93:18

300 16:5

30th 76:19

32 25:8

35 161:4

38 203:10 234:22

235:18,21

3ACH50 208:12

4

4 3:8 71:21 283:21

290:16

4,000 140:14

4.1 304:5

4.3 285:7

4.4 285:10,12

4.7 284:17 285:7

4.8 288:2

4:00 313:16 325:10

4:10 339:18

40 207:16

402 174:2

402.411 268:21

403 174:3

403.61 265:12

404 174:5

49 234:8,18 235:20

235:20 240:17

241:4,6

5

5 292:6 295:11

5-1/2 202:22

5.1 296:15

5:00 325:9,14

339:10

50 45:21 90:12

50-something

76:15

57 75:3

6

60 204:13 211:14

66-foot 211:14

7

7 273:7 306:22

70 45:22 81:16

280:8

73 279:9

76 282:10 283:1

8

8 3:10 57:4 307:6

8.1 296:22 298:15

8.2 297:16

8:00 325:10

800-pound 57:17

8E-089 1:10

8th 330:8

9
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

382

Manufactured Housing Working Group

US DOE

08-22-14

Washington, DC