Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

1

1 

2 U.S. DEPARTMENT OF ENERGY

3 

4 MANUFACTURED HOUSING WORKING GROUP

5 

6 GOLDEN, COLORADO

7 

8 OCTOBER 23, 2014

9 (9:00 a.m. to 6:00 p.m.)

10 

11

12

13

14

15

16

17

18

19

20

21

22
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

2

1 APPEARANCES:

2 Eileen Hoffman - Moderator

3 Javier Ramirez - Moderator

4 Lois Starkey - Manufactured Housing Institute

5 Mark Ezzo - Clayton Homes

6 Rob Luter - Lippert

7 Kavita Vaidyanatham - DOE

8 Joe Hagerman - DOE

9 Ed Barbour - Navigant

10 Matthew Muller 

11 Robin Roy - Natural Resources Defense Council

12 Manuel Santana - CAVCO Industries

13 Eric Lacey - Responsible Energy Codes Alliance

14 Michael Lubliner - State University

15 Ishbel Dickens - NMHOA

16 Stacey Epperson - Next Step Network

17 Mark Weiss - Manufactured Housing Association

18 Lowell Ungar - American Council for an Energy Efficient

19 Economy

20 Emanuel Levy - Systems Building & Research Alliance

21

22
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

3

1 APPEARANCES CONTINED:

2 John Caskey - National Electrical Manufacturer's Association

3 David Tompos - NTA, Inc.

4 Michael Wade - Cavalier Home Builders

5 Pete Schneider - Efficiency Vermont

6 Richard Potts - Virginia Department of Housing and Community

7 Development

8 Bert Kessler - Palm Harbor Homes

9 Keith Dennis - National Rural Electric Cooperative Association

10 Rick Hanger - Housing Technology and Standards

11 Tom Eckman

12 Matthew Walker - Navigant

13 Keith Dennis

14 

15 

16 

17 

18 

19 

20 

21 

22
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

4

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

2 MS. HOFFMAN: First things first, can the folks remotely

3 hear us? This is Eileen Barcus (phonetical) Hoffman. 

4 MALE VOICE: I'm unmuting them right now. You're being

5 unmuted. 

6 MS. HOFFMAN: You're being unmuted. Hello? So first we

7 want to make sure that folks from remote can hear us, and then

8 we'll go around the room to see who's here.

9 And we'll hear from our host for any kind of procedural

10 logistical issues and then get started. So let's hear from our

11 remote people first. Who is on the line so we know who's here? 

12 You are unmuted. Do we hear anyone?

13 MALE VOICE: No. 

14 MS. HOFFMAN: Bert Kessler, David Tompos, Keith Dennis,

15 Michael Wade, Pete Snyder, Richard Potts. Okay, those are all

16 the members. If we've missed someone, let us know.

17 Okay, let's go around the room now to hear who's here,

18 starting with John.

19 MR. CASKEY: I'm John Caskey with National Electrical

20 Manufacturers representing the National Manufacturers

21 Association and I'm representing ASRAC.

22 MR. LEVY: Emanuel Levy and I'm representing Systems
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

5

1 Building Research Alliance.

2 MR. UNGAR: Lowell Ungar, American Council for an

3 Energy-Efficient Economy.

4 MR. WEISS: Manufactured Housing Association for

5 Regulatory Reform.

6 MS. EPPERSON: Stacey Epperson, Next Step Network. 

7 MS. DICKENS: Ishbel Dickens, National Manufactured Home

8 Owners Association.

9 MR. LUBLINER: Michael Lubliner, Washington State

10 University Extension Energy Program. 

11 MR. LACEY: Eric Lacey, Responsible Energy Codes Alliance.

12 MR. SANTANA: Manuel Santana, Cavco Industries.

13 MR. ROY: Robin Roy, Natural Resources Defense Council.

14 MR. WALKER: Matthew Walker, an advocate.

15 MR. HAGERMAN: Joe Hagerman -- 

16 (Whereupon, there was static on the recording.)

17 MALE VOICE: -- first cavity, second is continuous

18 throughout. Some of these things are helpful, but they're

19 probably not worth the time of this committee to discuss.

20 MALE VOICE: One question is footnote G is the one that

21 has an asterisk next to lower "R" values. And it gives you the

22 option of where it says a prescriptive lower "R" value being R30
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

6

1 or 38.

2 It says in lieu of that you can fill aa 56 cavity to R19

3 minimum in lieu of hitting that number. Is that one of the

4 footnotes that we're considering hanging on to?

5 MALE VOICE: Maybe I can answer this one way and you can

6 answer another. There are a couple of exceptions and exclusions

7 built into the IECC prescriptive path. We felt that there had

8 already been quite a few concessions and exceptions and other

9 things built into this system, and to take some of these

10 exceptions.

11 Like there's a glazing area exemption for decorative glass

12 or, you know, an exemption for a certain number of square of

13 door and some of those other things -- 

14 (Whereupon, there are dial tones coming across the

15 microphone and an automated announcement.)

16 MALE VOICE: I didn't know if we'd have time after the "U"

17 discussion, zone discussion to get into the prescriptive table.

18 MR. HAGERMAN: Is it safe to say that, just to try to

19 recap I think what the discussion here is the difference in

20 background is my understanding. Please correct me if I'm wrong.

21

22 But some of the footnotes that are in the prescriptive
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

7

1 table are there to explain the prescriptive table that in the

2 IECC. Coming up with our own prescriptive table.

3 MALE VOICE: Right. 

4 MR. HAGERMAN: So it's not so useful for us to consider

5 the footnotes necessarily of somebody else's prescriptive table,

6 but we need to come up with our own footnotes for our

7 prescriptive table, right? 

8 MALE VOICE: Right. 

9 MR. HAGERMAN: And of course there may be some lessons

10 learned in their prescriptive footnotes that apply to ours, or

11 we can just easily adopt them.

12 There are some issues just -- it sounds like this floor

13 insulation footnote that we probably need further discussion as

14 we finalize our prescriptive data; is that safe to say?

15 MALE VOICE: Yes. 

16 MR. HAGERMAN: I was saying that your subcommittee doesn't

17 have necessarily your complete -- like we sufficiently reviewed

18 the IECC and you've -- the previous discussion kind of reflects

19 what needs to be in the term sheet in terms of what applies from

20 that IECC?

21 MALE VOICE: That's correct. Under the time allotted you

22 completed the work.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

8

1 MS. HOFFMAN: I've been told the court reporter needs a

2 break. About ten minutes; is that correct? And also would like

3 everyone to mention their names. So let's take a ten-minute --

4 is that correct? 

5 COURT REPORTER: I don't necessarily need a break, I just

6 need for whoever is speaking to express their names and spell

7 them. 

8 MS. HOFFMAN: Oh, okay. 

9 COURT REPORTER: You have multiple people talking, and

10 with the phone I can't hear anything. 

11 MS. HOFFMAN: Okay. 

12 COURT REPORTER: So we don't necessarily have to take a

13 break. I just wanted to -- 

14 MS. HOFFMAN: Oh, okay. All right, thank you. So whoever

15 speaks, say your name and spell it. I guess we can also give

16 you a list of the spelling. And we can keep going then.

17 But, Joe, you recapped. Thank you. So we have Manny's

18 report. Do we have everyone online now? No. 

19 MALE VOICE: Do we have folks online? 

20 MS. HOFFMAN: Okay. We'll going to take ten minutes just

21 to make sure that the technology is working because we've got a

22 lot to do.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

9

1 (Whereupon, there was a brief recess.) 

2 MS. HOFFMAN: It's Eileen Hoffman. Thanks for your

3 patients. The wonders of technology and the challenges of

4 technology. 

5 We just heard from Manny and Eric about their committee

6 report and the footnotes with a discussion from Mark Ezzo, and

7 now we're moving on to the next submitted, Stacey Epperson.

8 MS. EPPERSON: I'm Stacey Epperson, Next Step Network. 

9 The finance committee did not meet since the last meeting, so we

10 have we believe concluded our work. 

11 MS. HOFFMAN: Okay, thank you, Stacey and your committee.

12 Okay, moving right along, the next committee -- let me

13 just get that. Sorry. I've got too many papers -- the next

14 committee report, David Tompos, Indoor Air Quality. We have to

15 unmute.

16 MR. TOMPOS: Dave Tompos from NTA. Can you hear me okay? 

17 MS. HOFFMAN: Yes. Yeah, thank you. 

18 MR. TOMPOS: Okay. Our committee was on the mechanical

19 ventilation section of the IECC. You should have two documents.

20 One was a Word file that has some proposed language, the other

21 one is an Excel sheet -- I can bring it up here -- that had some

22 cost method calculations.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

10

1 MR. RAMIREZ: David, can you identify the document so that

2 we can pull it up? The title of it? 

3 MR. TOMPOS: The title is mechanicalventilation.doc. The

4 Excel sheet is -- I maybe should have changed the name of it. 

5 Lubbybasecasefan.xls. 

6 MS. HOFFMAN: You're immortal. 

7 MR. TOMPOS: I didn't give away who put it together, did

8 I? 

9 MALE VOICE: I resemble that. 

10 MR. TOMPOS: Okay. So you can leave the Excel sheet up. 

11 I guess if you have both of them there, that's fine. 

12 We can talk about the Excel sheet a little bit. First of

13 all what we were comparing here is the current full-house

14 ventilation fan that's in -- currently required by the

15 Manufacturing Housing Code.

16 And typically they're looking at fans that are 50 watts,

17 and if we would accept the proposal that requires the efficacies

18 on the whole house, and that would bring us down to typically

19 the Energy Star fan of 22 watts.

20 So the first line here shows if the fan was being used two

21 hours a day, we'd have kickback of something along the order of

22 over 175 years of payback.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

11

1 So then go down to the next line it shows if that fan in

2 the manufactured home as is currently being put in is used on

3 100 percent, now you come down to a 14.5 year payback.

4 And the last line is if the homeowner or the house is set

5 up with the exhaust fan utilizing the HVAC fan for the

6 whole-house ventilation, that typically being a 400 watt fan,

7 and comparing that to the -- according to this new standard.

8 Now it does make the assumption that that whole-house fan

9 is being run 24 hours a day. In not sure that that's the

10 reality. I think the reality is closer to the first line.

11 This also makes the assumption that the cost to the owner

12 is around $350. The financials of it (inaudible) the language,

13 we can look at that and see what it says in the IRC and proposed

14 language for how we believe it should read.

15 Potentially we're leaving exactly what it says in the

16 IECC; however, instead of referencing the IRC for the mechanical

17 ventilation, we're referencing what's required by the

18 Manufactured Housing Construction Safety Standard.

19 And then what we are saying is that the whole-house

20 mechanical ventilation fan efficacy from the efficiency

21 requirements of Table 403.6.1, which is what's in the IECC. So

22 that would require better efficiency or efficacy for those fans
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

12

1 when used. 

2 There's also an exception in here for when the mechanical

3 fan is used in conjunction with the HVAC equipment. 

4 Essentially, that's the proposal that was put together by the

5 subcommittee. Any questions? 

6 MS. HOFFMAN: Yes, Lubby.

7 MR. DUBLINER: Can you go back to that Lubby spreadsheet

8 for a second because I know we had talked trying to get some

9 narrow in on the costs of the Energy Star fan relative to the

10 base case fan.

11

12 There was a comment about those being a little high. So I

13 was just wondering if that happened. I know, Mark, you were

14 going to try get some feedback for us on that, but I wasn't sure

15 if you were able to do that.

16 MR. HAGERMAN: What now, Mike? 

17 MR. DUBLINER: Oh, when you had your guy price the Energy

18 Star fan and Dave said he thought that was a little high. And I

19 was wondering if we got new numbers to plug in there that could

20 -- I'm sorry, Joe. 

21 MR. HAGERMAN: I just have just a general question. 

22 MS. HOFFMAN: Sure, Joe. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

13

1 MR. HAGERMAN: It seems like maybe I just don't understand

2 how to read this spreadsheet, but if you look at row 4 where it

3 says 50 CFM back bed, I assume that to be the base case of

4 whatever is doing right now. 

5 So then the next row, row 5 should be labeled Energy Star

6 fan?

7 MR. LUBLINER: Row 4 is a bath fan being used as an

8 intermittent bath fan; in other words, it's just being used when

9 people are bathing. That's a spot ventilation fan.

10 And then row 5 is that same fan or a separate fan that's

11 running 24 hours a day to meet the whole-house ventilation. 

12 MR. HAGERMAN: It's the same fan. You're just running it

13 at different times. 

14 MR. LUBLINER: The only difference there is the run time. 

15 MR. HAGERMAN: I got it. 

16 MR. LUBLINER: And what my question had to do was when we

17 looked at the cost of the manufacturer's current 50 CFM fan,

18 whether it's the whole-house fan in the hallway, which some of

19 them use or that same fan in the bathroom.

20 What it's going to cost the consumer for the Energy Star

21 far at 172 for an incremental of 162, when we talk about

22 tweaking that one a little bit. So that was my only comment
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

14

1 because it seemed a little high. 

2 MALE VOICE: I don't have a problem with that. 

3 MR. LUTER: This illustrates that while the more efficient

4 bath fan might be a nice thing, if it's off 22 hours a day, it's

5 just as efficient those 22 hours as anything. 

6 MALE VOICE: It's run time. 

7 MS. DICKENS: This is Ishbel. I just want to remind

8 people to say their names because I think aren't we supposed to

9 give our names for the court reporter? 

10 MS. HOFFMAN: Thank you. Thank you, Ishbel. Manny?

11 MR. SANTANA: Manny with Cavco. So the 400-watt fan, is

12 that supposed to be the range hood fan? 

13 MR. LUBLINER: No, that's the furnace blower. When you do

14 a blend air or a ventile air system for whole-house mechanical

15 ventilation, it relies on the energy of the furnace blower to

16 deliver the 30- or 50 CFM air around the house.

17 So you're using a 400-watt fan to deliver 30 or 60 CFM,

18 which I believe is why there's an exemption in the -- well,

19 there's an exemption for that kind of a system that says you

20 need to use an ECM motor if you're going to go that way and it

21 doesn't have a watt per CFM. 

22 MS. HOFFMAN: Rob Luter and then Manny.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

15

1 MR. LUTER: Rob Luter with Lipper Components. Just a

2 point of clarification. This is specific to mechanical

3 whole-house ventilation, and if we can go back to the code

4 excerpt, what is from the mechanicalventilation.doc, please?

5 You can see that in this table there are air movers that

6 are not traditionally use for whole-house ventilation. This

7 language, though, is specific to air movers used for continuous

8 whole-house ventilation.

9 So while there are efficacy numbers here for a bath fan or

10 a range hood, those are not applicable in the context of this;

11 in other words, we're not mandating that the range hood have 2.8

12 CFM per watt efficacy unless it's being used as a continuous

13 whole-house ventilation fan, which as a rule they're not. 

14 MS. HOFFMAN: Thank you. Manny?

15 MR. SANTANA: Manny with Cavco. The way that I read this

16 is that it applies to all mechanical ventilation. Is it just

17 for whole-house ventilation? 

18 MS. HOFFMAN: Okay. So I'm just going to recap for our

19 court reporter. Mark Ezzo says and Lubby it's whole-house

20 ventilation, yes. 

21 MR. SANTANA: And if we can go back? Manny still. If we

22 can go back to the Excel file. I just have a couple questions. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

16

1 So what we're seeing is that the current fan costs $10 and

2 that Energy Star fan is $172. So the difference is 162, and the

3 cost to the consumer is 356. That's all correct? 

4 MR. LUBLINER: That's what we're talking about tweaking a

5 little bit. 

6 MS. HOFFMAN: That's Lubby, Michael Dubliner. 

7 MR. LUBLINER: And we're only talking about the

8 whole-house ventilation fan, then that's going to be the only

9 fan. You only need to buy one fan, right?

10 So I'm looking confused because I thought that the section

11 of the IECC applied to fan efficacy for all the ventilation

12 fans; is that not the case? 

13 MR. LUBLINER: I think if a ventilation fan is being used

14 as both the spot ventilation, say, in the bathroom and also

15 being used as the whole-house fan, then it would need to meet

16 that efficacy. But if it was only being used as a spot, it

17 doesn't have to. 

18 MR. SANTANA: It doesn't have to. 

19 MR. HOFFMAN: Mark Weiss and then Rob Luter. Mark Weiss

20 had a -- did you have a comment, Mark? 

21 MR. WEISS: Yeah, thanks. Manny clarified this part of

22 it. So we're talking about $356 cost increase at the retail
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

17

1 level to go from what we have to what we're talking about.

2 If you could flip to the other slide please, I have a

3 question. Dave, can you hear me? 

4 MR. TOMPOS: Yes, I can hear you. 

5 MR. WEISS: Okay, thanks. So I read this, you're saying

6 that the ventilation is going to continue to meet the requires

7 of the HUD code. Then you say whole-house ventilation will meet

8 the efficacy requirements of 403.61..

9 How does meeting the fan efficacy requirements of that

10 table relate to those cost figures? I guess what I'm asking you

11 is, is there no change in cost because you're still complying

12 with the HUD code, or is there a change in cost? And if so, is

13 it the 356 or something else? 

14 MR. TOMPOS: Dave Tompos from NTA. We would still be able

15 to meet the ventilation requirements. I mean, the amount of air

16 changes would have to be required, so we are saying that that

17 should be set by HUD.

18 What we're saying is that the efficacy of those fans, the

19 whole-house fan, needed to meet this table. So price would

20 change.

21 Now, there was talk about, you know, the price of

22 $170-some probably is a little high based on some additional
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

18

1 research. It's probably closer I would say to 140, $150 cost to

2 manufacture. There is going to be additional costs of, you

3 know, around $300 to the consumer. 

4 MR. WEISS: Okay, thank you. Thanks for answering. 

5 MS. HOFFMAN: Okay, thank you. 

6 Mark Ezzo.

7 MR. EZZO: Mark Ezzo. Dave, can you here me? 

8 MS. HOFFMAN: Can you hear him? 

9 MR. TOMPOS: Yes, yes. 

10 MS. HOFFMAN: Oh, yes. 

11 MR. EZZO: So the say I see this proposal, to determine

12 that the CFM requirement for the whole-house fan we're going to

13 follow what's in the HUD code, right? 

14 MR. TOMPOS: Correct. 

15 MR. EZZO: Okay. And the HUD code today says 035 CFM per

16 square foot. No less than 50 and no more than 90. And

17 everybody knows we have a problem that 90 upper limit only

18 covers a home up to 2500 square feet.

19 So my is, can we have our proposal address the problem

20 that's in the HUD code currently that says you can't go above

21 90?

22 Because what we're doing today as manufacturers, we're
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

19

1 have to submit alternate construction requests for any home over

2 2571 square feet or whatever the number is, which is crazy.

3 So what I'm thinking is, we could fix that when we put

4 this proposal in place. 

5 MS. HOFFMAN: Are you waiting for Dave's comment/response

6 or -- 

7 MR. EZZO: Are you onboard with that, Dave? Do you hear

8 what I'm saying? 

9 MS. HOFFMAN: And then we have Lois. 

10 MR. TOMPOS: Yeah. I think we could do that. I mean, I'd

11 like to -- I think there was a proposal already in the MHCC that

12 made that recommendation. Somebody else that's on the committee

13 may need to correct me if I'm wrong, because it's going back a

14 few years. 

15 My preference would be that HUD handle that because I

16 think it's outside of the energy requirements.

17 And I know that there's a subcommittee meeting, you know,

18 within the next few weeks before we have our meeting the first

19 week in December to discuss some of the concerns with

20 whole-house ventilation. And it's just my preference that the

21 MHCC handle that. 

22 If this committee feels that we want to address it in this
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

20

1 proposal, you know, that's up to the committee. 

2 MS. HOFFMAN: Okay. 

3 MR. TOMPOS: I think there's still some technical issue

4 that maybe DOE has to address on whether or not they have

5 authority over that part of 3280. 

6 MS. HOFFMAN: Okay, thank you. We're going to hear from

7 Joe first. Oh, I'm sorry, please. 

8 MR. EZZO: I'm fine with that. One suggestion, though, is

9 where we have it saying mechanical ventilation mandatory, can we

10 change that to say whole-house mechanical ventilation to remove

11 the confusion about spot vent, range hoods, and bath fans, and

12 those kinds of things? 

13 MS. HOFFMAN: Okay. We have a proposal. We'll keep that

14 on target. We'll hear from other people, but to change it to

15 whole-house mechanical.

16 Joe, you were trying to -- 

17 MR. HAGERMAN: Manny's first. 

18 MS. HOFFMAN: Oh, Manny. Thank you. 

19 MR. SANTANA: Well, first, Mark brought up my second point

20 was to be clear on what kind of a ventilation applies to -- you

21 know, I think conceptually I agree with what this is trying to

22 do is provide efficacy limits on a whole-house ventilation fan.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

21

1 I think the part about meeting the requirements of the

2 3280, that alludes to a relationship between the new DOE

3 standard and the current HUD standard that hasn't been

4 established yet. 

5 And I think that can be confusing, so I think that the

6 most we can do with this is accept the principle, and then we

7 won't know how the final language is going to look until it's

8 determined how DOE is going to deal with the HUD code on

9 sections that have overlap. 

10 MR. HAGERMAN: Mike, Let me try to answer that. So I

11 believe 3280 -- so you can correct me if I'm wrong. But 24

12 C.F.R. part 3280 that's been published for a long time, right? 

13 So it's out there, right?

14 And I see it that we're just -- that this one little line

15 is just referencing a public standard, right? It's not trying

16 to rewrite that standard. I mean, this sentence right here

17 doesn't try to rewrite that standard, does it? 

18 MR. SANTANA: No. Manny again. No, but you almost have

19 to because the current HUD code has more than just require

20 whole-house mechanical ventilation. 

21 As a CFM rate, you have to follow. It has max caps on the

22 max CFM, and so then that puts a limit on the maximum size of
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

22

1 house the you can have.

2 And so this, you know, the current HUD code doesn't allow

3 you to have a fan rated at more than 90, you know. And so here

4 one of those is a minimum of 90, and so it has parts that are

5 going to conflict with the HUD code, so you're going to have to

6 rewrite parts of it. And that is what I meant when I said that.

7

8 MR. HAGERMAN: Again, I agree with that. I appreciate

9 those comments. So if we -- like, can you explain why we even

10 have that?

11 Even though I know it's a legacy of IECC, but wouldn't you

12 recommend then that we just remove that last line that says

13 bathroom utility room 90 CFM 2.8 centimeters -- I mean, cubic

14 feet per watt? I mean, you've done that in other IECC tables

15 where it's not applicable. Why don't we just remove that line

16 and then you don't have that disconnect, right? 

17 MR. SANTANA: Manny again. And you really can't do that

18 because, you know, the HUD code has a built in contradiction

19 where they have a maximum cap on the CFM, then they have a CFM

20 rate per square footage, that you need to maintain.

21 So when your house gets over a certain size, you know, you

22 can't do it. So for some homes over a certain square footage
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

23

1 you need to have more than 90 CFM. And if you can handle it

2 with one-as opposed to a two-year you're better off. 

3 MS. HOFFMAN: Joe, after you we'll hear from Lubby and

4 then from Lois. Okay. 

5 MR. HAGERMAN: My comment had more to do with your

6 spreadsheet. Can you tab back over to the spreadsheet, please? 

7 So I'm not trying to derail everybody here by any means,

8 but when you Google, and I know we're not allowed to Google Home

9 Depot for costs.

10 So when you do that, right, you get an Energy Star fan at

11 50 CFMs to a consumer for $35, and you're coming up with $356,

12 right, which is like, you know, it's clearly a factor of ten

13 more, right? 

14 So what's the disconnect there? Why, you know, are these

15 not the same fans that you're buying at Home Depot that are

16 Energy Star rated at 50 CFMs? These are different fans than

17 what you're talking about here? 

18 MR. EZZO: There are different classes of Energy Star fans

19 based on the amount of air being moved. 

20 MR. LUBLINER: So if you look at the fan that we're

21 talking about -- 

22 MS. HOFFMAN: Michael Dubliner. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

24

1 MR. LUBLINER: If you're looking at the fan we're talking

2 about here, it's more like 100 bucks on those sites. 

3 MR. HAGERMAN: Okay. 

4 MR. LUBLINER: And we talked about this a little bit, and

5 we got a distributer price that was a little bit high, and we

6 could bring that down. I heard 140. You know, we can argue in

7 a different way. But my observation --

8 MR. HAGERMAN: 356 seems almost laughable.

9 MR. LUBLINER: So we have 100,000 homes with these fans in

10 them in the northwest with 20 manufacturers, HUD code

11 manufacturers for over 15 years. You could check with them, but

12 my feeling is this is, just like you said, it's a little high.

13 But, you know, if you tweak it down to 140, the scenario

14 that we're really talking about here is going to bring the

15 payback down into what it's comparable with, the other measures

16 that we're been looking at and accepting here.

17 And I think, you know, so I would argue that those two,

18 clearly it's not cost effective if we're using it as just a bath

19 fan.

20 But if it's being used as a whole-house fan, which if HUD

21 adopts, what the consensus committee already approved in the

22 last meeting, which is to allow 62.2 to be used as an option
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

25

1 that an manufacturer once HUD had offset. 

2 Manny's correct when he says the current requirements

3 because this hasn't been -- 62.2 hasn't been adopted as an

4 alternate.

5 But if it was adopted, what you could do is those

6 manufacturers that are using a separate fan in the hallway,

7 that's a loud fan, but it's a $10 fan.

8 And then having them put another fan, that same fan on the

9 other side of the door to the bathroom, the 62.2 would allow you

10 to get rid of the fan in the hallway, put a better fan in the

11 bathroom and do double duty.

12 And we haven't included the savings associated with that

13 in here because now you're eliminated wiring, a roof

14 penetration, roof flashing, everything else.

15 So if we define the current practice ventilation including

16 what the consensus committee approved, and a manufacturer was to

17 select to use 62.2, which doesn't also have the 90 CFM

18 limitation in it, then we would be able to do this at much, much

19 lower cost.

20 And we've decided, well, let's not get into those details

21 too much because this looked like it was pretty possible. 

22 MS. HOFFMAN: Okay. Lois had the comment.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

26

1 MS. STARKEY: Lois from MHI. I just wanted to confirm

2 that not only did we add a voluntary ASRAC option in the 3280. 

3 We also -- the consensus committee also addressed the

4 contradiction regarding the 90 CFM. And so just for the record,

5 there is a proposal that's pending at HUD to update that

6 provision. 

7 MS. HOFFMAN: So what do we do here in terms of this

8 committee? Michael? 

9 MR. LUBLINER: I think this is a really good thing for our

10 scope because what it's suggesting is that things related to the

11 ventilation, once HUD adopts 62.2 as an option, the

12 manufacturers will have a lot more flexibility about how they

13 meet the whole-house ventilation criteria.

14 So if we were to go ahead and approve some of the

15 efficiency efficacy things here, then we don't need to deal with

16 all the other things in this committee.

17 They could be discussed within the consensus committee,

18 and I'm happy to be chairing that portion of the consensus

19 committee on air quality, and I'd invite Mark or others to join

20 us. We've got Manny and Dave on that. 

21 And we've made a lot of -- a real lot of good positive

22 motions in the area of indoor air quality with the consensus
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

27

1 committee and HUD.

2 We've gotten clarification on ventilation, we've got duct

3 testing going through. We've got 62.2, and we've got CO2

4 alarms. All these -- CO alarms, excuse me. 

5 We've done a lot to improve indoor air quality standards,

6 and I think that we can continue to use that committee. But I

7 really would love to see a liaison between DOE on this and HUD

8 as it moves forward.

9 MR. SCHNEIDER: Peter Schneider, Efficiency Vermont. 

10 MS. HOFFMAN: Okay. Hi, Peter. 

11 MR. SCHNEIDER: I just wanted to echo what Joe said. You

12 know, it doesn't take a comprehensive surge to identify that

13 that manufactured for an Energy Star can more than double what

14 it should be.

15 I'd also like what Michael said. I think 62.2 is the most

16 cost-effective approach here, and more importantly you have to

17 accept your ventilation strategy as well and would certainly

18 make the cost analysis look at lot better for an Energy Start

19 fan. 

20 MS. HOFFMAN: Okay. So, Joe, I just want to -- where are

21 we heading on this discussion? First I want to thank David and

22 for the committee report. And we've got a lot to discuss, but
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

28

1 you sort of help me with this, because I heard a couple of

2 different things.

3 You know, there's perhaps some overlap here that Lubby has

4 said had a liaison with HUD committee. We've also heard

5 reliable it as whole-house ventilation from Mark Ezzo.

6 So what suggestions do you have to close this at this

7 moment? Yeah, Mark Weiss. 

8 MR. WEISS: I have a question for Mike. I think I know

9 the answer to this, but I want to be sure. 

10 Does that table trump the option that you're talking about

11 on 62.2? In other words, does that -- 

12 MR. LUBLINER: No, it'd be a complement. When you say

13 trump, I'm not sure what you mean. 

14 MR. WEISS: Just does it obviate the object? In other

15 words, this is prescribed to -- 

16 MR. RAMIREZ: 62.2 is clearly looking at what type of

17 systems can you put in to meet the ventilation rates, either

18 whole-house or size. And then it tells you how the flow rates. 

19 It doesn't get into the energy efficiency. 

20 MS. HOFFMAN: All right. So as far as this document here,

21 is this good enough with the suggestion that Mark had to change

22 the whole house? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

29

1 MR. RAMIREZ: Is that good enough to gauge consensus on to

2 add to the term sheet? 

3 MR. SANTANA: Manny with Cavco. I've got one suggestion. 

4 If we can highlight the sentence after that where it says "meets

5 the requirements of, you know, 24 C.F.R. part 3280."

6 If we could highlight that section and add an asterisk to

7 be determined or once established by the future relationship," I

8 think we can vote on the rest. 

9 You know, I think the rest, there's not a whole lot of

10 questions on the rest. That part's the only part that, you

11 know, I think it hasn't been established yet. 

12 MR. RAMIREZ: So what's the verbiage? I think maybe you

13 could down underneath the table and have the verbiage there,

14 right? 

15 MR. HAGERMAN: He's suggesting you put a footnote after

16 where that period is or after that period, however you want to

17 deal with that. 

18 MS. HOFFMAN: It is a footnote, yeah. 

19 MR. HAGERMAN: It is a footnote in what he just said. 

20 MS. HOFFMAN: Please repeat, Manny. 

21 MR. SANTANA: All right. To be determined once the

22 relationship between the HUD standard and the DOE standard is
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

30

1 established.

2 Because, you know, only because the HUD code is addressing

3 an option to remove the CFM max, and only because the HUD code

4 is considering an option to allow 62.2. We don't know how

5 they're going to work yet. 

6 MR. HAGERMAN: Joe Hagerman. Is it safe to say "to be

7 determined as the HUD standard is being updated"? Does that say

8 the same thing you want to say, or do you want to specifically

9 call it the HUD DOE relationship? 

10 MR. LUBLINER: I think the HUD DOE relationship between,

11 you know, you haven't said how this is going to be implemented,

12 how it's going to be enforced. That's unknown. 

13 MS. HOFFMAN: Lubby. No? So would it be appropriate now

14 for a consensus vote to see where we are on this? 

15 MR. RAMIREZ: To include it in the term sheet? 

16 MS. HOFFMAN: Let's gauge the level of consensus here. 

17 MR. RAMIREZ: All right. Anybody online with your thumbs

18 down? Okay, so it's

19 unanimous? 

20 MS. HOFFMAN: No, it's not. 

21 MR. RAMIREZ: Mark, and I'm assuming it's the same

22 objection as far as any cost components? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

31

1 MR. WEISS: Well, it's that and it's something else I

2 mentioned at the last meeting. It's the cost, and it's also the

3 question of authority.

4 As I've said, IECC is a variation of HUD's general

5 authority over manufactured housing construction and safety, and

6 I'm uncomfortable with DOE in areas that HUD already regulates. 

7 MS. HOFFMAN: Okay, so noted. 

8 MR. HAGERMAN: Joe Hagerman. Just to be clear, just so

9 maybe I'm reading this wrong, but it specifically points to -- 

10 MR. WEISS: I know it goes beyond providing a table. 

11 MR. HAGERMAN: Okay, I got you. 

12 MS. HOFFMAN: But under our definition of consensus --

13 sorry, Eileen Hoffman. Under our definition of consensus, it

14 holds. And I want to thank David Tompos and the whole committee

15 and this discussion. 

16 We're going to move on to the affordability report from

17 Robin Roy. 

18 MR. ROY: Robin Roy. We had one more meeting since our

19 last meeting. We did not propose or refine any of the previous

20 two product-type straw men.

21 Rather, we recognized that that is a fall back deal we

22 might consider, but there's a broad preference among the group
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

32

1 to find a consensus.

2 If for some reason there isn't a separation between the

3 two cost effectiveness perspectives that were laid out in the

4 legislation, we're hopeful that either there's not such a large

5 deviation between those two cost effective perspectives and the

6 deficiencies associate with that, or that we come to a

7 consensus.

8 There's a preference to come into a consensus. And we

9 don't have, other than that, anything more to report. 

10 MS. HOFFMAN: Thank you. I want to thank Rob and his

11 whole committee. And I note that you had some comments. This

12 is Javier Ramirez

13 MR. RAMIREZ: We had -- those are the committee reports,

14 and that wraps up the committee reports that were outstanding,

15 which gives you all the data I believe that is necessary.

16 There's some information based on some straw voice or

17 straw man that they may be looking at to finalize the term

18 sheet.

19 And I believe that you're at a point right now where I

20 guess it's the wedding day, right?

21 MR. SCHNEIDER: Can I interrupt you? Can you speak into a

22 microphone? I can't hear you or Eileen at all throughout this
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

33

1 whole conversation. Every once in a while you come in, so

2 something's wrong. 

3 MS. HOFFMAN: Okay, then. And you are? 

4 MR. SCHNEIDER: Peter Schneider. 

5 MR. RAMIREZ: Is this any better? Peter, is this any

6 better?

7 MR. SCHNEIDER: Much better, Javier. 

8 MR. RAMIREZ: So what I was getting at is that -- 

9 MS. HOFFMAN: Why do we need to review the vote? 

10 MR. RAMIREZ: Yeah. As far as the votes go, it was one no

11 vote. Everyone else online I believe was okay, correct? Did

12 you hear that, Peter?

13 We have taken a consensus vote on the whole-house

14 mechanical ventilation that was put together by David Tompos and

15 that committee, and the level of consensus was everyone was okay

16 with it, with the exception of Mark Weiss.

17 So if anyone online disagrees with that chime in,

18 otherwise we'll move on.

19 MR. SCHNEIDER: This is Peter. Javier, you sound great,

20 and I -- 

21 MS. HOFFMAN: And we haven't heard -- okay. So we're

22 going to continue then. Javier, you have some comments. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

34

1 MR. RAMIREZ: Yeah. The comments were that with the

2 committee reports wrapped up there, that's all the data I

3 believe that's necessary.

4 Obviously we need some discussion to either reach some

5 agreements on some point, but that's where we're going to be

6 going next. And we need to have the group start working towards

7 those final commitments, right? 

8 We have a pretty aggressive agenda here, and although we

9 started off a little later with the technical issues that we

10 had, we're really not that far off track right now. As a matter

11 of fact, I think we're right about where we're supposed to be at

12 at this moment. 

13 So I know that there's quite a few engineers in the room,

14 and sometimes we see a paralysis over analysis. You want more

15 and more data, but at some point we do have to make those

16 decisions, and I think we're at that point right now. 

17 So there's a couple things as far as process goes where I

18 want to make sure we time box some of these items here. So if

19 we're butting up across on a time limit, we're going to have to

20 make sure that we keep the conversation focused so that we could

21 take a consensus vote at that time.

22 I'm going to rely a little bit on you all as well to enact
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

35

1 those ELMOS right because there's times where Eileen and I may

2 not know that you're beating the dead horse. Right, there's

3 time when we get the idea, right, but you all control that. 

4 So let's keep it focused on what we need to discuss in

5 order to reach those final agreements. Okay? I saw Lowell and

6 then Joe. 

7 MR. UNGAR: I just want to check. Last time Lois and I

8 were asked to look at labels. Do you want to talk about that? 

9 MR. RAMIREZ: Yeah. That's some of the data that we're

10 going to have to be confirming to make sure that we're okay with

11 all that. We'll definitely get to that. Thank you. 

12 MS. HOFFMAN: And I think is labeling 445, labeling? Is

13 that -- yeah, we haven't forgotten that. Thank you. 

14 MR. HAGERMAN: Joe Hagerman. So just to reiterate because

15 we had some technical difficulties. I sent around a PowerPoint

16 to everyone, or Matthew did.

17 A very brief PowerPoint. It's only three little slides. 

18 I don't know if you can pull it up. We need to go over this.

19 The second slide, if you go to the next slide, just is a

20 graphical reminder of all the meetings we've had.

21 The next slide to me really reflects sort of the

22 outstanding items that we need to discuss, right, that we've
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

36

1 been discussing that I don't think we've been taking notes or

2 reviewing things that we kind of had resolution on, right? The

3 big items, right? 

4 So to me in my mind this sheet is really kind of today's

5 and tomorrow's score card of what we need to wrap up and resolve

6 to get to that final term sheet. 

7 So, you know, I think it's a pretty useful tool up here,

8 so. So I don't know if maybe you want to start crossing out on

9 this what we've gone over or not, the stuff that we've gone over

10 just so we can always refer back to this to see where we are. 

11 MR. RAMIREZ: Okay. So as we do, just we'll come back and

12 do that. 

13 MR. HAGERMAN: And the second thing I want to add is if

14 you go back to your agenda, the next kind of big thing on the

15 agenda is for Navigant to review the life cycle revisions.

16 And my recommendation is to skip that and go to Emanuel's

17 discussion because all of Emanuel's previous work rely on the

18 results and where we need to ask Emanuel for clarification on

19 the results, we could have Matthew just pull up his spreadsheet

20 and go through that.

21 But you think that's a wise decision, and then does

22 everybody agree?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

37

1 MR. LEVY: That's fine. Robin just walked out. I know

2 Robin looked at the cost results as I have. I mean, they've

3 looked at that piece so we probably should keep that in mind. 

4 MR. HAGERMAN: Absolutely. So we should keep that into

5 mind because that's a good comment. And let me just say, too,

6 that Robin saw us just in the lobby of the Marriott and asked

7 for some clarification on one of the column titles.

8 I think there was some confusion about one column. And

9 that column title was incremental home costs. It's the far last

10 column, correct? And just for clarity, it's there right on the

11 same page.

12 That column represents the total costs, incremental home

13 costs over the years of analysis. Meaning, all the, you know,

14 tax payments, all the sales, all the property taxes, incremental

15 property taxes you pay, all the interest payments, that's all

16 the costs.

17 It's not the sticker price. So it's on the up-front costs

18 to the consumer, it's the all-in cost, right? So to derive the

19 sticker cost is actually very easy. There's only about the nine

20 percent difference.

21 And so if you want to know what the up-front sticker cost

22 is to the homeowner on the lot, it's that number. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

38

1 And so what I asked Matthew to do is to revise the tables

2 that he sent out with a sticker price column. So now that I've

3 explained that, I'm going to ask him to circulate that, too. 

4 But just for a, you know, rule of thumb, just take off

5 nine percent and that gives you the sticker price. And that's

6 because, you know, that we've discounted the interest rate and

7 all that.

8 That should I think clarifies some of the confusion that I

9 overheard just as people talked the other day. It should be

10 helpful. 

11 MS. HOFFMAN: Well, Emanuel, I got the impression we can

12 start, but you'd like Robin to be in audience. 

13 MR. LEVY: I would like Robin to be in the audience, but I

14 think we can start. 

15 MR. RAMIREZ: Well, let me ask you this, are you all good

16 to roll on or do you want to do a quick one-function break? 

17 Take five minutes and then come back and start, or do you want

18 to roll? 

19 MR. LEVY: One function I think. 

20 MR. RAMIREZ: Okay. 

21 MR. HAGERMAN: Yeah. Robin took the one-function break

22 before we all did, right? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

39

1 MS. HOFFMAN: And so why don't we come back at what is it

2 -- just five minutes. 

3 MR. HAGERMAN: So just a reminder, everybody -- Joe

4 Hagerman -- there's two restrooms here right down this hall, or

5 you can go left down that way. 

6 MR. RAMIREZ: Yeah. So according to my watch its right at

7 10:30, 10:31. 

8 MS. HOFFMAN: Okay. 

9 (Whereupon, there was a brief recess.) 

10 MS. HOFFMAN: So, Manny, are you going to do it from here?

11

12 MR. SANTANA: No. 

13 MS. HOFFMAN: And it's billed as climate's own discussion;

14 is that correct? 

15 MR. SANTANA: Yes. 

16 MS. HOFFMAN: And can everyone hear him? That's

17 important. 

18 MR. SANTANA: Can everyone hear me? 

19 MS. HOFFMAN: Robin Roy is in the audience, okay. 

20 MR. ROY: I will be for a little bit definitely. 

21 MS. HOFFMAN: Okay, we're ready. 

22 MR. LEVY: So this is what I'll be talked about briefly is
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

40

1 kind of a continuation of the discussion we started a couple

2 meetings back in which we are trying to look at a combination of

3 things, both of a map of the U.S. divided into thermal zones and

4 Uo-values associated with those zones.

5 And since we didn't have the luxury of doing a really

6 robust cost benefit of every measure, we did over the past

7 couple months just a month or so is to look at selective

8 measures that appear to be on the surface from prior analysis.

9 Might be on the cusp but being cost effectively report

10 clearly looked like it wouldn't be cost effective. And Matthew

11 and his team ran some numbers to look at what the energy savings

12 would be for some individual measures.

13 So instead of doing a much more robust analysis, we

14 focused our assessment on just the individual measures that we

15 thought might not be cost effective, and these are kind of a

16 summary of results that we've gotten so far, just to explain

17 what we're looking at. 

18 In select locations that corresponded to zones, and we'll

19 look at the map in a second, Matthew ran some cases for us.

20 For example, we look at ceiling R-value going down to 22

21 from 30 in Houston and Birmingham. Those are the southern

22 zones. And you could see that the savings, the annual savings
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

41

1 for electrical resistance or heat pump are displayed there for

2 both single-section and double-section homes.

3 So that in essence the change from 22 to 30 for a

4 single-section home, if you have electric resistant heat and

5 you're in Houston, it would save you $16 a year if you had made

6 that change. If you've got a heat pump, it would be $10.

7 And looking at the costs of that, the option under option

8 costs we just displayed what a simple payback was. And this is

9 a fairly gross measure as opposed to lifestyle cost analysis.

10 We wanted to simply look at what the payback was

11 (inaudible) possibly a good idea or was cost effective. And we

12 used a simple definition that was up for debates that anything

13 with more than 50-year payback was not attractive. And the

14 higher you got obviously the less attractive it would be.

15 So we could subject any of these individual measures to

16 lifestyle cost analysis, but I guess the point is, if you get up

17 into 15, 20, 25, in some cases 30 or more, those things are

18 clearly not cost effective.

19 So we're looking at those kinds of gross conclusions to

20 make about these individual measures in these locations. 

21 The other one I just want to bring to your attention

22 because we've had a lot of internal discussion about what this
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

42

1 results means, and that's heat zone coefficient results from .33

2 down to .25; that's an improvement in the south.

3 And again, I wanted to caution you that the numbers, the

4 $90 and 150, those are our ballpark numbers where we think the

5 cost increase would be to get down to that (inaudible).

6 This gave us real pause because (inaudible) in the IECC

7 standard. And so when you see something so not cost effective,

8 it makes you wonder whether you're doing it correctly or what

9 IECC was thinking about.

10 So we've had some discussions about this. But our sense

11 is that these are marginal measures, and in particularly some

12 parts of the northern part of the southern zone, if you will.

13 And the reason for this, and we went back to Matthew and

14 his team and asked for a clarification. Why are the numbers so

15 low? Why are the savings $1, $5, $6?

16 And the reason is quite simple. If you have a better heat

17 zone coefficient, you get benefit on the cooling side, you

18 reduce your cooling because you have less solar heat coming

19 through your windows. 

20 But on the inside you're losing the benefit of the extra

21 side. So the tradeoff becomes a function of a number of

22 different factors: location, orientation of the windows, the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

43

1 relative cost of heating and cooling, and then those kinds of

2 considerations.

3 So you're actually dealing with a negative on the heating

4 side and canceling a lot of the benefit on the cooling side. 

5 And in some cases you can actually see some real dis-factor from

6 using solar heat gain coefficient windows.

7 So that in our mind raised an issue. I don't think we

8 feel like this is conclusive, even though the numbers,

9 particularly in Birmingham, Alabama, look fairly unfavorable. 

10 And even higher end increment from that from 4 down -- .4

11 to .33 and those locations don't look particular attractive. 

12 MR. HAGERMAN: Joe Hagerman. I have a comment. I think

13 when you see some of these results and you see some things that

14 look sort of counterintuitive, you start to wonder why, right? 

15 And in my mind the solar heat gain coefficients are

16 somewhat inconclusive to -- I write it as slightly different. 

17 I'm not completely understanding everything you said. I

18 appreciate those comments. Those are great comments.

19 I think that one of the problems is a little bit of an

20 artifact of one of our assumptions that is the design.

21 If you remember early on like the first PowerPoint I ever

22 gave, we showed you graphically the assumptions of what a signal
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

44

1 section and a double section look like for our analysis, right? 

2 And one of the largest section of the windows is, we have

3 equal windows on all sides.

4 Well, you know, just as you drove in or walked into the

5 entrance here, you passed the double section -- two or three

6 double sections, and they don't have that, right? They have all

7 the windows on one side, right? 

8 So I believe in the PNNL team has backed me up here on

9 this that some of the decisions on just the physical location of

10 the windows and the orientation don't favor a very clear method

11 to really comprehensively study solar heat gain coefficients.

12 We need to properly study heat in heat coefficient, we

13 need a new base model, right? And so that's why, you know,

14 that's why I think it would be best to -- my recommendation to

15 the group would be to consider punting the solar heat gain

16 coefficient to DOE and let us redo that baseline model because

17 obviously we don't have time to do that.

18 We didn't have time three weeks ago to do it, right? And

19 let us resolve solar heat gain coefficients. Because once you

20 make those model changes, I think this thing racks and stacks

21 like (inaudible).

22 So that's just an observation. We don't need to talk
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

45

1 through that and consider that. 

2 MR. LUBLINER: Mike Lubliner. I would like to see that

3 additional assessment get done. And if possible if you can do a

4 parametric evaluation of how the payback, or whatever the metric

5 you use varies when you consider the (inaudible). I think

6 that's important.

7 It's been ignored in all the analysis. It's gospel for

8 building America and other programs. (Inaudible.) 

9 I guess my question for Emanuel is, the 15-year, it seems

10 to me that putting insulation in a roof, putting insulation in a

11 floor, maybe even windows. I'll defer to Rob on useful life of

12 windows.

13 But it seems like -- and I've been saying this all along

14 -- working with weatherization programs and having to go out and

15 spend more out of federal dollars to fill cavities in attics and

16 floors that weren't filled to begin with, I've been using the

17 term "lost opportunity."

18 And I would argue that these homes are going to be there

19 for 60 years, and there's going to be a lost opportunity.

20 And that that few extra instances of insulation in there

21 is probably prudent, even though when you do these kind of

22 assessments and it isn't so --
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

46

1 I think that 15 years is probably low because a lot of

2 homes are going to be there for a long time, and this is a lost

3 opportunity. So those are my two kind of points for why I'm a

4 little uncomfortable with that. 

5 MR. UNGAR: No, that's a point well taken. But let me

6 just mention a couple of things about the 15 years.

7 First of all, I look at that as only a threshold, and you

8 said as a starting point is best case. And so you see that most

9 of the values that are highlighted are sell above 15.

10 The only thing about 15 as simple backpack, as everybody

11 in this room will tell you, it's not even the metric for looking

12 at the benefits. I just did it because I had it easily

13 available to me. 

14 But a 15-year payback is equivalent to in terms of a

15 lifestyle cost analysis, that's a different matter. And I think

16 that's really a better metric, and then you're really making a

17 decision about things.

18 And a 15-year payback doesn't mean it's only good for 15

19 years, and we don't know exactly what that's equivalent to in

20 terms of lifestyle cost (inaudible) or Matthew.

21 What a 15-year payback means in terms of what would be the

22 equivalent to get a lifestyle cost analysis to get a positive
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

47

1 benefit. You know, that 30 years with certain rate assumptions,

2 I don't have a feeling for that. 

3 But I wasn't looking at it in that vein. I was simply

4 looking at let's pick a starting point and know that anything

5 that's 15 years may be marginal. But everything that's -- but

6 as you get higher, it's clearly not that. 

7 MS. HOFFMAN: Eric.

8 MR. LACEY: Yeah. I guess fundamentally -- Eric from

9 Responsible Energy Codes Alliance -- I get concerned when we

10 start kind of picking out individual measures in very small

11 increments when the assumptions that are behind the analysis

12 could be huge in the sway -- the amount of area you cover, the

13 assumptions could be very big.

14 You know, taking for example the four cities that are

15 analyzed here in looking at SHGC, Birmingham, Atlanta, and

16 Houston have all adopted the 2009 IECC, which requires a .30

17 SHGC.

18 Orlando, they're adopting a 2012 IECC, which requires a

19 .25. Did they get it wrong? I mean are they all wrong? You

20 know, does it not make sense for them?

21 I think behind all this, though, while I appreciate that

22 the couple of manufacturers who provided cost data did so in
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

48

1 good faith.

2 That's all based on today's assumptions and what it would

3 cost to get a window right now in these two or three or however

4 many, you know, manufacturers provided information.

5 How much it would cost them to get the window there and

6 marked up and so on. Where I believe if we have more data, and

7 unfortunately we don't have more cost data from other

8 manufacturers, more looking ahead as some of these processes get

9 streamlined and there's some efficiencies of scale.

10 I think those cost numbers will come down substantially. 

11 I have a hard time believing for example that to get from a .4

12 SHGC to a .33 costs $90 because I don't think there's a .4 SHGC

13 window, you know, just based on what I've seen.

14 And so it's a $90 costing permit that I don't think

15 exists. And now you have to plug those things in for the

16 purposes of analysis, but I think we're reaching that level

17 where we have to start making some professional judgments on

18 this.

19 You know, we know what kind of windows are being sold and

20 installed in these four cities in particular, you know, an maybe

21 our analysis spits out some longer payback numbers, but I think

22 it should cause us to pause and say, "Would it really make sense
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

49

1 to go that much higher with the SHGC or the E factors or the R

2 values"?

3 Or should be we question some of those assumptions, take a

4 look at all the data and say, "Let's pick this level."

5 Even in spite of our own data sometimes recognizing, you

6 know, that we're not taking into account the orientation,

7 electricity costs, the equipment downsizing, you know,

8 additional efficiencies of scale for the costs, and so on.

9 We need to go a step back and say we're not completely

10 driven by the results of this analysis, which, you know, does

11 its best but it's also relying on the limited set of assumptions

12 that some of us probably don't agree with are on the tables. 

13 MR. LEVY: Let me just make a couple clarifying points. 

14 First about the .04 to 3.3, we didn't do anything with that. We

15 just looked at that.

16 MR. LACEY: Okay. 

17 MR. LEVY: And the .4 comes right out of the IECC. 

18 MR. LACEY: 2006 IECC.

19 MR. LEVY: Actually, I think it's in 15. And I was simply

20 interested in looking at it, but we didn't do it. But the one

21 point I wanted to make is sometimes everybody's wrong.

22 I mean, and I think that behind the IECC standard -- and I
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

50

1 haven't been personally involved in the process, but what I hear

2 about it is it's in a negotiation process.

3 It's a consensus building process. And sometimes it's not

4 -- decisions aren't made like we were trying to make here based

5 on economic and cost benefit data, based on professional

6 judgment. 

7 Sometimes those aren't cost effective. I'm not saying

8 that's the case with windows, but I wouldn't be surprised when

9 Joe goes back and does the sensitivity studies.

10 And the conclusion is that going from 3.3 to 2.5 is not

11 cost effective for part of the south. I wouldn't be surprised

12 for the reasons we mentioned. 

13 MS. HOFFMAN: Lowell. 

14 MR. UNGAR: No, that's okay. 

15 MS. HOFFMAN: Introduce yourself, Lowell. 

16 MR. UNGAR: Lowell Ungar. I just want to know when I look

17 at numbers, I was only looking at one the sensitivity analyses. 

18 I got different numbers, and we haven't had a chance to go back

19 and figure out what I did wrong or whether -- so I'm not quite

20 sure these numbers are right. We don't know yet. 

21 MR. HAGERMAN: When you say these numbers, you mean solar

22 heat gain coefficient numbers or -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

51

1 MR. UNGAR: No. I mean actually what I was looking at was

2 the wall sensitivity analysis. And I didn't do this complete

3 enough -- you know, a complete manipulation of the numbers that

4 Emanuel did to get there, but what I look at isn't consistent

5 with this.

6 And so we haven't gone back to compare and see, but there

7 could be errors here. Or it's quite possible I just made

8 mistakes. 

9 I guess if we're going to base it on this analysis, I'd

10 like to make sure these -- that we get the numbers right. 

11 MS. HOFFMAN: Let's get Manny then Mark. 

12 MR. SANTANA: Manny with Cavco. I'm afraid that we might

13 be -- it might be time for an ELMOS here because as DOE

14 suggested, they want to go back and take a look at solar heat

15 gain coefficient because they think the analysis -- the say that

16 we're doing the analysis here isn't as encompassing as they

17 would like it to be.

18 So, you know, with the agenda that we have, is it prudent

19 for us to continue on what may be a moot point? 

20 MR. HAGERMAN: Joe Hagerman. I made the recommendation

21 that for the solar heat gain coefficient topics that the

22 committee recommend that, you know, we don't let that bog down
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

52

1 and get to the term sheet.

2 We just say DOE needs to consider what the solar heat gain

3 coefficient do further analysis, right? 

4 MR. RAMIREZ: So let me ask the group then, because I'm go

5 to ask to see if everyone's okay with that idea to defer the

6 solar heat gain coefficient portions to DOE.

7 Obviously there's going to be a lot more that we need to

8 discuss here. But as far as that component itself, are you

9 already to gauge that or, Mark, did you want to comment on that

10 specifically? 

11 MR. WEISS: No, I wanted to ask a follow-up question to

12 Emanuel. 

13 MR. RAMIREZ: To Emanuel? 

14 MR. WEISS: To Emanuel. 

15 MR. RAMIREZ: Yeah. 

16 MR. WEISS: So is it correct that the IECC process is not

17 bound to cost versus life cycle cost; is that correct? 

18 MR. LEVY: Well, what I said is I'm on the expert on the

19 IECC process. What I understood or actually what I asked

20 Matthew was are there work papers that came out of the IECC

21 process that we can look at to understand this particular issue

22 -- this issue in particular?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

53

1 But that doesn't mean they don't exist. And, again, I

2 haven't been involved in that process. 

3 MR. HAGERMAN: Joe Hagerman. There's a DOE report that we

4 have to issue annually or every time a code comes out, an IECC

5 code comes out that (inaudible) cost effectiveness, so I think

6 it's always positive. 

7 MR. ROY: This is Robin. But that's for the package that

8 puts the individual measures in there. So we've taken a look at

9 that, and we've also taken a look at the proposal that was

10 adopted for the IECC, and it doesn't seem to have attached to it

11 the kind of analysis.

12 And for that reason, I quite like it. If you think, you

13 know, we can bring a bit more intelligent and focused analysis

14 on specifically this question, I like the idea of opining it to.

15 I'm not exactly sure what your decision process would be in

16 determining what SHGC and what cost performance tradeoff you

17 would deem appropriate. 

18 I mean, if you could speak to that a little bit more. 

19 MR. HAGERMAN: Yeah. Well, you can be assured that it's

20 going to go through that process where we'll do the analysis,

21 we'll publish the analysis, we'll ask for comment, write on that

22 analysis.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

54

1 And then we'll select a level very much like doing the

2 same type of tables and we can discuss it here consistent with

3 the kind of spirit of discussion.

4 And once that's selected, we'll select that and we'll get

5 another chance to comment before those finals. So there's

6 plenty of continuing engagement. It's just not in this, you

7 know, every two-week forum. 

8 MR. ROY: That comforts me. 

9 MS. HOFFMAN: So Lois. 

10 MS. STARKEY: The conversation here, what would be the

11 time frame for doing this, giving this time? 

12 MR. HAGERMAN: So just to be clear, once you develop a

13 term sheet, right, we would put that recommendation up to the

14 secretary. And if the secretary adopts it, we do right to rule,

15 right? 

16 In this particular case we couldn't write the complete

17 rule because there's still some issues unknown to us, right, or

18 undecided, right? 

19 So we would do the analysis and put that analysis out for

20 a comment. And I don't know if we do that all with the rule or

21 we would do that in current with us sitting on the rule. That's

22 just an administrative thing for us. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

55

1 But I mean, the intent here and just with any rule making

2 is you have plenty of chances to comment and look at the

3 analysis and provide us more analysis, challenge the analysis,

4 etcetera.

5 That's why, I mean, any of these issues that you feel like

6 need to be punted, that's how we do them. 

7 MS. HOFFMAN: Eric. 

8 MR. LACEY: Eric from RECA. I just want to clarify in

9 taking a step back. I think in our last meeting we looked at

10 the window U factors and SHGCs and we kind in the name of kind

11 of limiting the number of SKUs and kind of splitting up the

12 country.

13 I thought we had landed on some U factors and SHGCs based

14 on generally on the IECC, but a little more simplified. There

15 were fewer differences.

16 You know, there was like a 3.2 window, a 3.2 U factor in

17 part of the country and a 3.5 in the other part of the country,

18 and then the SHGCs were set based on the IECC.

19 What we're talking about here when we're talking about

20 punting is just the Gulf States when a U factor and SHGCs that

21 we're talking about. Because I kind of thought we'd put this to

22 rest, and then I say a day or two I saw these numbers up again
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

56

1 and I thought, I thought we'd already had this discussion. 

2 Are we just talking about the Gulf States or this little

3 section of the country here? 

4 MR. HAGERMAN: We're going to show maps, but we're talking

5 about the Gulf States. 

6 MR. LACEY: Okay. 

7 MR. HAGERMAN: That was my understanding. 

8 MR. LACEY: I just wanted to clarify that. 

9 MR. LUBLINER: Mike Dubliner. I had a question because I

10 was reviewing this Building America report that you guys know

11 about with advanced envelope research, and you have a number of

12 manufacturers involved.

13 And I was wondering. I was looking at the cost for the

14 R13 and R21 up there, and about 665. And I was noticing in here

15 it was about 398. And so I'm just trying to figure out, was

16 this -- is this an apples and apples? 

17 Because this says going from a 2 by 4 16 inch on center

18 R13 to a 2 by 6 16 inch on center R21 was 398 bucks, and I'm

19 going on just thinking why is that 398, but was it because some

20 manufacturers had such higher costs when you collected them that

21 the average was that? 

22 MR. LEVY: Michael Dubliner. I can't tell you, but I'll
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

57

1 look at a study with you later on. 

2 MR. LUBLINER: Okay. Because I'd love to take it offline.

3 Because the numbers when I look at this report seem more

4 indicative of what our experience was.

5 But I don't want to rehash the whole issue costs here. 

6 But that might be something that you'd be looking at with the

7 sensitivity on the costs. 

8 MR. HAGERMAN: Joe Hagerman. I'm not trying to get the

9 committee to punt everything to DOE. The solar heat gain

10 coefficient, you know, is not modeled correctly given some

11 underlying assumptions about the geometry that we all chose in

12 the very beginning, right?

13 So it's a little bit unfair to pull out solar heat gain

14 coefficient here. That's all I want to stress.

15 To just reiterate what Michael said, this is the first

16 time that we've ever seen, I believe, the incremental costs for

17 a single section measure to be more expensive than a double

18 section measure. That's the only flag that I would have -- 

19 MR. LEVY: On the walls. 

20 MR. HAGERMAN: -- on the walls. 

21 MR. LEVY: There's more wall area per single section. 

22 MR. HAGERMAN: There's more wall area in the single
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

58

1 section compared to the square footage. 

2 MR. LEVY: There's more windows in the double section than

3 is effected out here. 

4 MR. RAMIREZ: All right. So is everyone okay with the

5 idea of deferring the solar heat gain coefficient portion of

6 this to the DOE? 

7 MALE VOICE: Just one comment to echo what Eric mentioned.

8 When I saw this, I was surprised as well. It's

9 counterintuitive to what we think we believe.

10 I'm not in a position to say whether it's in error or not.

11 My understanding is the math got run several times. Whoever

12 ran the math said it was right.

13 Once could rationalize that in certain cases, yeah, the

14 solar gain you're not getting could contribute to higher heating

15 losses, I don't know.

16 I'm uncomfortable with the word "punt." Okay, I would

17 prefer to defer for additional analysis rather than punt with

18 fingers crossed. 

19 I don't think that this is necessarily a fluke and should

20 be dismissed. I think it deserves some scrutiny. 

21 MR. LEVY: I agree. The flip side of that argument is,

22 well, let's use this result and then if your analysis suggests
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

59

1 otherwise, we come back. 

2 MR. RAMIREZ: Michael and then Lowell. 

3 MR. LUBLINER: Yeah. I heard from Eric, and I guess I

4 have a question, Rob, for you on this. Is that on this $90

5 split both ways, you were pointing out that the .4, what is that

6 window and how do you cost that out?

7 MR. EZZO: I had the same question as to what the .4 was

8 as well. With the technology that's available, you make a jump

9 from clear glass to low "E," and there's an incremental change

10 into to get in the middle you have to either blend some windows

11 or use some technologies that aren't commonly used.

12 So I can't speak to that at this point. I can speak to

13 the difference between .33 and .25, and that's a pretty easy one

14 to explain. 

15 MR. LUBLINER: So if there's not a real .4 product out

16 there, is what I'm hearing -- maybe there is, but not generally

17 -- then shouldn't we just be looking at what it is to .33? I'm

18 not sure. I just got confused when I saw the .4. 

19 MR. HAGERMAN: When I said punt, it was move the topic so

20 we can go more analysis and treat it like a normal component or

21 a rule-making rule. Published analysis, common analysis, we'll

22 take a level and you can comment on what we picked on, and then
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

60

1 we close it out, so. 

2 MR. EZZO: It's not like we're a guy with a dart board. 

3 MR. RAMIREZ: Lowell. 

4 MR. UNGAR: Yes, on the point .4 to .33, I think so we're

5 not using it, so I would suggest we defer discussion on that.

6 On the punting, I mean, my understanding of the idea is we

7 hope when we would wrap up the term sheet before the DOE

8 analysis came back, so it would be opportunity to comment, but

9 it would on the necessarily be in the form of this committee. 

10 Just so that we're clear.

11 And third is, it was my understanding from the discussion

12 after Eric's question that we're only talking about punting, if

13 you will, the SHGC for this. I think what we'll be calling is

14 Zone 2, but these Gulf States.

15 I'm fine either way. But my understanding is whether we

16 were talking about was that we would continue with what -- to

17 put in the term sheet recommendation for other regions. There's

18 only this one region where there's -- where we would leave the

19 question. 

20 MR. HAGERMAN: Should we take a vote on punting? 

21 MR. ROY: Deferred. 

22 MR. HAGERMAN: Deferred. Let's use the word deferred. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

61

1 MR. ROY: Punting means that it could be ending. 

2 MR. HAGERMAN: Let's defer. Let's take a vote on that. 

3 MS. HOFFMAN: Let me just clarify. It's deferring the

4 solar heat gain coefficient for the southern states -- 

5 MR. RAMIREZ: For region two. 

6 MS. HOFFMAN: -- for region two for additional analysis;

7 is that fair to say? 

8 MR. RAMIREZ: Let's see a show of thumbs for that. Okay. 

9 I see two thumbs down. 

10 MS. HOFFMAN: Three. 

11 MR. RAMIREZ: No, Rob was sideways. 

12 MS. HOFFMAN: Emanuel. 

13 MR. RAMIREZ: So let's hear from Emanuel and Mark. 

14 MR. LEVY: I was just -- mine is just a minor point. I

15 just think we should make a decision now and see if it gets

16 refuted by your analysis so that we have a decision in place. 

17 And then we can decide later on if you come up with

18 something that indicates that the analysis was wrong or the

19 findings were wrong or there was some flaw in this, then we can

20 go back and revisit it. But we'll have a decision. 

21 MR. HAGERMAN: I'd be fine with that, but I would think

22 that we'd go back to the original decision that we started,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

62

1 which we already selected this. And then this analysis that

2 you're making arguments like take it away. 

3 MR. RAMIREZ: When you say the original, is that the one

4 that we had looked at before, I think? 

5 MR. HAGERMAN: Just as a reminder -- Joe Hagerman. Just

6 as a reminder, we had already sort of selected solar heat gain

7 coefficients in all the zones, right? And today we're talking

8 about rethinking that decision, right?

9 So I'm fine -- I would be the most comfortable with

10 sticking with our original decision unless the DOE analysis, you

11 know, says otherwise. 

12 MR. LEVY: Could I just ask for a deferral on this vote

13 until we look at the map? 

14 MR. RAMIREZ: That's fine. So we're just going to table

15 this for now until we see the map. 

16 MR. HAGERMAN: Let me also remind everybody that we can't

17 just table the thing. We've got to get done in the next, you

18 know, day and half here, right? 

19 MR. RAMIREZ: Yeah. And that's tabled until just the map.

20 We're going to get to that today. 

21 MR. ROY: And this is Robin. Just to be clear, does that

22 mean we have like consensus agreed to defer this to DOE but now
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

63

1 there's a proposal also to consider going back on that

2 consensus?

3 Because we had two down and the rest okay. I think we

4 have consensus on the matter that was brought. 

5 MR. RAMIREZ: Yeah. What I would suggest is -- and the

6 reason that we have the thumbs down, I want to have some

7 discussion on that that. 

8 We want to lock things in, but because Emanuel has -- he's

9 got something in his head here of what the map might do, right? 

10 So what I would suggest is that we'll vote again right after the

11 map.

12 More likely than not, unless there's something the

13 changed, you know, minds, we'll probably get a similar outcome

14 at that point. But let's give Emanuel to at least present that

15 before we do a final vote. 

16 MR. HAGERMAN: Joe Hagerman. Do you want to let Mark

17 explain the no vote? 

18 MR. RAMIREZ: Yes. 

19 MR. WEISS: So that's not going to change? 

20 MR. WEISS: No, but it's based on the facts that deferral

21 or punting or whatever you want to call it is consistent based

22 by the deadline on this committee, which as I've said before, is
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

64

1 fundamentally arbitrary to procedural issues. 

2 MR. RAMIREZ: Thank you. All right. So where do we go

3 from here then? All right, Ted. Could you move to the next

4 page? 

5 Ted had mentioned that there was a bit of a delay, but -- 

6 MR. LEVY: So this is just taking that information from

7 previous iterations on the zone analysis.

8 He's now looking at the IECC zones and just putting down

9 prescriptively where things now fall in terms when we look at

10 making changes based on the analysis that was done by the

11 laboratory, with those changes listed at the bottom. 

12 Now, you will notice that for -- I've divided Zone 3 into

13 two parts, and you'll see why that is on the map in a few

14 minutes.

15 But mainly it's because we wanted to note that one of the

16 changes we made that's between 3a and 3b, a couple -- two of

17 those changes actually, relate to only running an analysis for a

18 part of that Zone 3.

19 And also on the windows, there are no .4 windows. We put

20 in real windows here, so that drags down both the SHGC and the

21 U-value for the window, in effect creating another U-value for

22 the whole region.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

65

1 And so the results of that are shown under the single and

2 double columns for U-value.

3 Let's go to the next slide because I think we can see what

4 this looks like when it's mapped. 

5 These are the cost implications of that. We've looked at

6 this before. The cost come down a little bit because we made

7 some substitutions, but we can come back to this.

8 So this is what the IECC map would look like. U-values

9 from that table above. And you see what we've done. We've

10 taken region 3 and we've divided in two parts. We've only

11 broken out those five states in the brown area, which is the

12 Gulf Coast states with high use of Uo value because we only

13 dissent to the analyses in the states that were in that area. 

14 We didn't want to apply those results elsewhere to Zone 3. So

15 the rest of Zone 3 is .069 as an average between the single and

16 multi, and the 3a is now at .083.

17 And the north is -- is should start from the top. The

18 north has changed a little bit too, and you can see that for

19 almost half the geographical country. You have a very small

20 range or U-values from .059 to .055 suggesting that all those

21 areas need to be moved together if you're creating a zone. And

22 we'll see that on the next map. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

66

1 And also in the middle part, it's .069 to .069, so that is

2 a natural grouping too. The question becomes, what you do with

3 the south, which is now .083 to .090.

4 Next slide. I'm trying to get to the punch line here. 

5 All right. So there are two options that are being

6 proposed here. This is, again, you've seen this mapping at our

7 last meeting. And the only thing we've changed here is in that

8 zone, that Climate Zone 2 the numbers are wrong. It should be

9 .069 I believe instead of .076, which you'll see on the map. 

10 It's correct on the next one. So there's two options

11 shown here. Both are just variations on the Zone 1

12 configuration. So let's quickly go to the next one and we'll

13 come back to this one. 

14 Option one and option two have Zones 2 and 3, which are

15 identical. And you can see Zone 2 should be .069. And I kept

16 the solar heat gain coefficient at .4 because that's what in the

17 IECC. Again, we can change that to .33 by consensus, but that's

18 what it is right now. 

19 The weighted average in Climate Zone 3 is 058, and here

20 you see a variation on what to do with the Gulf States. And

21 this option number 2 where those states that are in IECC 1 and

22 2, which would be Miami Dade and the bottom of the Gulf Coast,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

67

1 would be grouped together into one Climate Zone we'd call 1A,

2 would could call it 1.

3 And the upper parts of those states in South Carolina

4 would be a separate zone. And this also reflects the fact that

5 we're trying to recognize the fact that these states in

6 particular have a lot of affordable housing in them. So we're

7 pushing up the use of Uo value in respect of that. 

8 So the difference between these two maps comes down to in

9 this case this map has two different solar heat gain

10 coefficients, one for the northern part and one for the southern

11 part, .25 and ,33, and other one only has one. And it treats

12 that whole area as one zone.

13 We can back up. 

14 MR. RAMIREZ: Yeah, if you can back up, Ted. 

15 MR. LEVY: So those are two options that came out of our

16 analysis. 

17 MR. RAMIREZ: So what you all have to do is decide which

18 one you want to go with, correct? So what questions do you have

19 for Emanuel so we could see if we could gauge the level of

20 consensus on one of these zone maps?

21 Let's start with Lowell. 

22 MR. UNGAR: Are you talking about the maps or the Uo
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

68

1 numbers? Those are two different -- one is where the regions

2 are, the second question is what the Uo numbers are in those

3 regions. I don't know what you're talking about. 

4 MR. LEVY: Let's handle those individually. 

5 MR. RAMIREZ: Okay, all right. Well, we could do that. I

6 was thinking both. 

7 MR. UNGAR: But I think we've got to talk about zones

8 first. 

9 MR. RAMIREZ: So carving out the numbers, just looking at

10 the lines, correct, those are lines, which one looks more

11 appealing, Eric? 

12 MR. LACEY: Just a clarification. Thanks for putting

13 these maps together. I would point out though that what you're

14 calling Climate Zone 2, the yellow section, it goes much further

15 south than Climate Zone 4. That includes a big chunk of Climate

16 Zone 3 of the IECC as well.

17 So take SHGC for example there, the SHGC would normally

18 not go that far south at a point .4 You'd be in the .25 range

19 for almost all of Texas, except for that little panhandle

20 section up there where you can kind of see a little jagged line.

21 And then it goes across, you know, all of those Gulf

22 States all the way to the top. So I would just point out that
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

69

1 it's never going to be perfect, but to apply a 4 over there is

2 captioning more than just Climate Zone 4. 

3 But I do agree with you, Climate Zone 4 would have the .4

4 in IECC. This just stretches that much further south. 

5 MR. LEVY: So the question is whether that zone should

6 have that integrity to it; and if so, what should solar heat

7 gain coefficient assigned to that zone be? 

8 MR. RAMIREZ: Yeah. California has a .25 statewide, so,

9 you know, if you took a weighted average or something of what

10 applies in that yellow region, I think it would be much lower

11 than .4. 

12 MR. HAGERMAN: Let's just refresh everybody where we were

13 last time. So last time you proposed a map like this, right? 

14 MR. LEVY: Right. 

15 MR. HAGERMAN: And my observation from hearing the two

16 maps, this map that you're showing here, the boundaries -- we're

17 not talking about the U-value right now, we're just talking

18 about the boundaries. 

19 MR. ROY: Joe, what map is that? I don't -- 

20 MR. HAGERMAN: This is the map he showed us last time, the

21 last meeting. Remember it had the Washington state problem up

22 here? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

70

1 MR. SANTANA: Yeah, we took care of that last map at the

2 last meeting. 

3 MR. HAGERMAN: Right. So here, this map right here looks

4 a lot like what we talked about at the last meeting. And then

5 your next map is this new proposal with carving out those other

6 states. 

7 MR. ROY: And this is rather to be clear that next map

8 looks a lot like a map we also discussed last time that we've

9 already done. 

10 MR. HAGERMAN: That's right. 

11 MR. RAMIREZ: So are you talking about this one here? 

12 MR. ROY: Would you put up the map I just sent you? 

13 MR. RAMIREZ: Ted, I just sent you another map from Robin.

14 Could you pull that one up? 

15 MR. HAGERMAN: Joe Hagerman. A lot of the discussion last

16 time revolved around I think Mark Ezzo talked about being

17 uncomfortable with, you know, dividing some states up, other

18 than Texas, right? 

19 MR. ROY: And the question then was put back to you to

20 come up with examples of those types of difficulties they had

21 experienced in breaking up of those Gulf states, hurricane.

22 Because they already have three zones that they're dealing
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

71

1 with. And I appreciate the interest in it, but we were waiting

2 to see if you had some specific examples of the cost or

3 impracticability of it. 

4 MR. HAGERMAN: It'd help me, Mark. This is Joe Hagerman. 

5 If you could weigh in because you projected to something like

6 this last time and you deserve the credit. I don't mean to put

7 you on the spot, I mean, I'd be interested to hear your thoughts

8 once again. 

9 MR. EZZO: I'm not sure what the question is. 

10 MR. HAGERMAN: So last time you were commenting that

11 dividing up the states would be very confusing, like in Alabama

12 or Georgia. Dividing up the state would be pretty confusing to

13 your dealers. And you thought that they wouldn't be able to

14 figure that out, right? 

15 And so you were trying to say that we should, wherever

16 possible, keep all the boundaries within the state lines, right?

17

18 MR. EZZO: Yeah. Mark Ezzo. Yeah. I think where I was

19 going with that was, like you said, Joe, simplicity for retail

20 folks who are in those areas of shipping intervals.

21 And I think the reason -- what I used to based that on was

22 by moving that boundary up to the top line of those states were
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

72

1 still increasing the energy efficiency way above where we're at

2 today.

3 That was kind of the negotiation point I was making. I

4 was trying to get support for moving that Zone 1 line up to the

5 top of those states. 

6 MR. ROY: We can appreciate that you want to keep the

7 cost down in that zone. I can imagine having the same

8 efficiency levels in that area in this brown, but leaving the

9 opportunity, although maybe different SHGCs.

10 So not entirely the same, even now we're talking about

11 that. But then in future rounds, rather than walking DOE and

12 all of the industry into a map forever more, it doesn't allow

13 that harmonization in those so critical states whether this

14 would pose a particular complication. 

15 MR. DENNIS: Can you hear me on the phone? 

16 MR. ROY: Yeah, Keith. 

17 MR. DENNIS: All right. This is Keith Dennis. I can make

18 an observation in the second map if we do punt the solar heat

19 gain that the U-values will be the same.

20 And, you know, we're one of the ones that have -- this is

21 Keith Dennis. I might have already said that, by the way. 

22 We're one of the ones that have a concern about the splitting up
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

73

1 of the states because of potential policy implications at the

2 state level. 

3 We have states that go to their commissioners and set

4 things for like attending 111-D but also for their renewal of

5 energy efficiency and energy deficiency standards where they

6 have baselines and then they have, you know, the actual home.

7 And if there's different energy values, it creates an

8 extra administrative burden, and it also -- I mean, there has to

9 be two different rebate levels and two different credit levels,

10 and it just gets more complicated.

11 We did talk offline about this, and I think a good

12 solution, I think what Robin mentioned, is, you know, having the

13 two zones set aside by having the same U level.

14 And I think that that meets, you know, certainly our short

15 term -- our issue in the short term and I think it meets Robin's

16 long-term issues.

17 So if we look at punting the solar heat gain, it might

18 make this even less of an issue. 

19 MR. EZZO: Mark Ezzo again. Back to that dialogue about

20 the boundary there in the Gulf states. What we're looking at

21 here on this map I think is very doable from what I was talking

22 about before because it maintains a constant Uo for both 1A and
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

74

1 1B.

2 Even though the heat gain coefficient for the windows

3 might be different, in terms of the thermal calculation for the

4 home, insulation levels, etcetera, they're going to be the same

5 for both those areas. And that's the bigger, I think the bigger

6 concern I think retailers would have. 

7 Whatever the heat gain coefficient numbers hit is where

8 they're going to hit. I don't think that's going to have an

9 impact on them. 

10 MR. RAMIREZ: Manny, did you have something? 

11 MR. SANTANA: No. I think it was -- I was going to just

12 -- Manny with Cavco. I was going to bring up the fact that when

13 Emanuel presented the option one last time, he stated all the

14 reasons for including those southern states in the same zone.

15 That was because of, you know, density of shipments, the

16 percentage of more economical units being shipped. You know,

17 the added sensitivity to initial price increases. 

18 All that were the reasons for including those states,

19 which was to ask for more analysis in some cities in those

20 northern parts of those states to justify, to see if there was a

21 cost justification for grouping them together.

22 And I think the analyses that we received shows that there
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

75

1 is substantiation for having those states in their entirety

2 grouped into Zone 1.

3 In terms of simplicity, I think it's easier to have one

4 zone. You know, I'm not in agreement that it's going to be hard

5 to add a zone in the future if facts mandate that.

6 What is going to be hard is to pull back and group two

7 zones back into one in the future. That's going to be next to

8 impossible. That's not going to happen. 

9 So, you know, again, I'm willing to err on the side of

10 being a little bit more conservative with respect to

11 implementing changes. You know, see what happens. There's a

12 whole lot that we just don't know. 

13 We don't know what the final costs are going to be. We

14 doing know how the market's going to receive the price increase.

15 We doing know what's going to happen.

16 You know, they could take to it like fish to water, you

17 know, or it could just, you know, put a whole bunch of folks out

18 of the home buyer category. You know, we don't know. 

19 I think that with DOE administrating this part of the

20 program, I think we have the added benefit to wait and see, and

21 then tweak things down the line. We're not going to 20 years

22 without updates. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

76

1 MR. UNGAR: May I ask a question on that? 

2 MR. RAMIREZ: Yeah, go ahead Lowell. 

3 MR. UNGAR: This is Lowell. You suggested that you think

4 in the future it would be much easier to split apart zones

5 instead of combine them, and I can't give any reason why that's

6 true. So I'm curious why you think that. 

7 MR. SANTANA: You don't understand how it would be easier

8 to split two zones? 

9 MR. HAGERMAN: We're sort of having that problem right

10 now. 

11 MR. UNGAR: It seems to be it would be easier -- my

12 thought is that you could potentially do either, but that it

13 would be easier -- if you had two zones, you can always set the

14 same standard for both of those zones. I don't see any problem

15 with that. 

16 Whereas splitting zones to the extent that people are used

17 to, the zones, etcetera, that it might be harder to split them. 

18 So my gut is, is exactly the opposite. It would be much easier

19 to combine them than to split them.

20 And you said -- so I'm curious why you think -- 

21 MR. RAMIREZ: Manny. 

22 MR. SANTANA: What I think? I think that it's going to be
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

77

1 difficult to split zones if there's no justification for it. I

2 think that it should -- it's going to be hard to split one zone

3 into two if you don't have U-values to justify it, justified, if

4 you don't have cost numbers to justify it. Then, yeah, it's

5 going to be very difficult to split. 

6 But if you have scientific backing behind it, costs

7 backing behind it, it'd be easier to just split. 

8 MR. UNGAR: So why would it be harder to combine it if it

9 would look like the same standard for two zones, why couldn't

10 you do that and effectively combine them? 

11 MR. SANTANA: I'd say because history. You know,

12 combining zones would go against what's in the IECC currently. 

13 You know, but if you look at thermal zones in the past life of

14 HUD, wind zones, breath of life, zones don't get combined. 

15 Zones get split.

16 This is what happened. This is what ASE does to wind

17 maps, that's what IECC did to climate zones. They're going to

18 get grouped, they're going to be split. 

19 MR. UNGAR: So I have one problem with that. I believe

20 actually IECC used to have 16 zones and combined 8. They didn't

21 combine them, they actually changed them.

22 But actually there's fewer zones in the IECC than there
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

78

1 used to be. So at least for the IECC I don't think history

2 supports that. 

3 MR. SANTANA: And that's the industry word. 

4 MR. UNGAR: You're saying for wind zones and others that

5 they were split. 

6 MR. RAMIREZ: Let's get Mark and then Michael. 

7 MR. WEISS: Well, whether it's easier to split or easier

8 to combine, the fundamental premise to what Manny said is

9 correct. Which is there's a whole lot of data we don't have.

10 We don't know how the market's going to react, we don't

11 have cost -- significant cost data, and we're doing this as a

12 shot in the dark that's based on computer modeling and limited

13 data from limited sources. 

14 So it's fundamentally a shot in the dark, but it's easier

15 to combine them or split them, and that's been the basis for my

16 opposition to any configuration of this all along. It's a shot

17 in the dark. 

18 MR. RAMIREZ: Michael. 

19 MR. LUBLINER: Yeah. I kind of follow Lowell's logic on

20 the zone thing. And in terms of the uncertainty, I know Manny,

21 I think I agree that there's uncertainty about what this impact

22 of this co-change is going to be on the price to the consumer
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

79

1 and also the impact on the market.

2 So I could just speak to examples in our area of the

3 country where we actually increased costs in the voluntary

4 partnership programs and stuff. And because of that, the price

5 of the home went down because the manufacturers started buying

6 more in bulk, and the price went down. 

7 So I would speculate, if I was a betting man that prices

8 will go down they won't go up on the first costs. 

9 MR. DENNIS: This is Keith on the phone. I have

10 experience in the other way where we expected market prices to

11 go down and products to be available and prices to go down. And

12 it hasn't happened. 

13 And I'll also echo what Manny said. I think that

14 everyone's getting on the right path here. But remember, this

15 is generally a one-way street with DOE.

16 They either get tighter or you allow them to go step wise,

17 but they don't get looser. There's an impact backsliding,

18 there's a lot of pressure.

19 So if we get it wrong, there's no undoing it. So I would

20 err on being conservative and then having them later. Because

21 if you go too far and there are adverse market reactions, it's

22 going to be virtually impossible to roll back at all. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

80

1 MR. RAMIREZ: Let me let Michael finish his comments and

2 then we'll get Lowell and Robin. 

3 MR. LUBLINER: So I'm just, again, I'm going off

4 experience with the manufactured housing industry where when we

5 built large percentage of the factory homes to a standard, a

6 higher standard, the costs to the manufacturer of the bulk

7 materials went down because they leveraged buying price.

8 That's what I'm saying, Keith. That's my hypothesis. 

9 There may be situations in programs where people mis-estimated

10 the costs, but my experience specifically from manufacture red

11 homes is that the reason this industry is so affordable is that

12 they buy -- they use their buying power. 

13 And I think that's something that we can argue either way.

14 We've tried our best with best-faith effort.

15 Emanuel has put together cost data. I would argue that

16 the cost will probably go down, but that's -- 

17 The other thing is, the market. That was the other

18 uncertainty, what it's going to do to the market. And I point

19 out two things.

20 There were wind standards that were adopted by HUD and

21 forced down the manufacturer's throats, and there was very

22 concern it was going to kill the market.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

81

1 My understanding is, is that those concerns were not

2 necessarily seen in the real world. It didn't kill the market. 

3 And I think that's important that we learn from large

4 charges in HUD codes and what it did to the market. 

5 My experience in the northwest, and I'll end with this

6 last point, is that the market is not just affordable housing. 

7 We've already been focused on affordable housing, and I think

8 it's important.

9 But what we learned and what we shared to committee, to

10 Tom Eckman, is that when you offer a product that's a higher

11 value product, it's got getter windows, better insulation, you

12 end up growing your market at the upper end against the

13 entry-level site builders.

14 So as an industry as a whole, if we're not just looking at

15 the affordable sector of the single-light guys in the southeast,

16 as a whole I think we could make a reasonably good hypothesis

17 based on our experience that your market will grow.

18 Although it may change, you may grow in the upper-end

19 product line, which may make you more profit perhaps, but I

20 won't speculate. 

21 MR. RAMIREZ: Let me get Lowell and the Robin and then

22 Manny. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

82

1 MR. UNGAR: Two things. I'll just note that the

2 anti-backsliding provision that was referred to as a provision

3 in appliance standards law, that is actually important there and

4 sometimes are useful, but as far as I know, it doesn't apply to

5 this.

6 In fact, in IECC in general we found that, you know, more

7 efficiency has worked and it has increased, but it's not always

8 the case. And there are cases where it's been weakened.

9 The main thing, though, is I wanted to ask Manny a

10 follow-up question. Going back to zones, rather the levels,

11 because I think we're talking about the zones at the moment.

12 And that's whether, if we adopted four zones but then set

13 a lessees either set Zones 1 and 2 with exactly the same

14 standard or have the same Uo everything, but only SHGC

15 differing, would that --

16 I mean, I don't feel strongly about this. I'm trying to

17 find a resolution, and I'm wondering if that would work. 

18 MR. SANTANA: Manny again with Cavco. I can say, option

19 one I give a thumbs up to. Option two I'd give a thumb sideway

20 to. You know, if you have the same Uo-value -- 

21 MR. UNGAR: What's option one? 

22 MR. SANTANA: The one with only one whole. Zone 1. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

83

1 MR. RAMIREZ: Can you go up, Ted? 

2 MR. SANTANA: So if we were voting now, I vote for -- no,

3 down one. 

4 MR. RAMIREZ: One more down. 

5 MR. SANTANA: If we had to vote right now, I'd vote for

6 that one. If we were voting on option two, which is the next

7 one, I wouldn't be opposed to it because the U-values are the

8 same. 

9 But having two zones with the same U value to me would be,

10 you know, understanding that the solar heat gain question has

11 yet to be answered.

12 You know, but having the same zone or two zones with the

13 same U-value would be -- would just add complexity when you

14 don't have to. It's the same U-value. You know, so I would

15 think that it wouldn't add any benefit. 

16 MR. UNGAR: If it had the same everything, same Uo-value

17 and same SHGC, would that make a difference? 

18 MR. SANTANA: Well, if you have the same U value and the

19 same SHGC in both zones, then you don't have two zones, you have

20 one zone. 

21 MR. UNGAR: Again, I'm trying to find a resolution here. 

22 If you label this two different zones, but then you just had
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

84

1 everything the same in the standard with the idea, noting that

2 in the future if there was --

3 If DOE found sufficient rationale and they might, in fact,

4 set different values with those two zones. 

5 MR. LEVY: What we're arguing about I think is whether we

6 have faith in the next group who's going to look at the

7 standard.

8 And we're arguing about whether we have less faith that

9 they will recognize that there are two applicable zones there by

10 climate and not whether that group, many of which --

11 Many of those people are probably sitting in this room

12 right now will be sitting here five years from now. So, Mike,

13 you won't have forgotten about this mapping discussion.

14 And it won't be difficult to add zones, and it won't be

15 difficult to track zones because we'll all understand how these

16 zones come to be.

17 So there's got to be a reason to put those two areas that

18 have essentially the same Uo -values. There's got to be a

19 reason to pull them apart that's more for now, for this group,

20 for us today. 

21 I was on the fence before I think when this discussion

22 started. Now I think I agree with Manny. This is where we are
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

85

1 today. This is what the map ought to look like. The next map,

2 add more zones, if that's what is appropriate. 

3 MS. HOFFMAN: So to summarize, you're saying you're in

4 favor of option one, the free zone? 

5 MR. LEVY: First thing, I'm in favor of option one. 

6 MS. HOFFMAN: Option one. 

7 MR. LEVY: The specific U-values, but in terms of mapping,

8 this is what I would prefer. 

9 MR. RAMIREZ: Robin. 

10 MR. ROY: I recall just a few minutes ago we were very

11 keen to get DOE's further view in appropriate SHGCs for what in

12 this picture is called climate Zone 1.

13 And it seemed to me the discussion we were having about

14 this zone, Climate Zone 1 SHGCs was very clearly about possibly

15 different SHGCs within it. 

16 If we adopt, as a group, that there is no difference in

17 this zone, then we're saying we actually don't want DOE to look

18 at that SHGC question about different SHGCs within the zone.

19 I find that bizarre. We just agreed we thought it would

20 be useful for them to come to a view, defer to their further

21 analysis about what would be useful SHGCs in this area, and that

22 there was a reasonable prospect that they may be different
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

86

1 within this area. 

2 MR. RAMIREZ: And maybe this is just an ignorant

3 layperson's perspective on this, right, but, Ted, could you go

4 to option two?

5 If it were -- if option two here were the one that was

6 adopted, and forgetting about the actual numbers that are in

7 there right now, just the lines, but then later on the SHGC

8 numbers end up being the same. What difference would that make

9 then? 

10 MR. HAGERMAN: Joe Hagerman. I think that's why this is

11 more -- as Manny called it earlier -- conservative.

12 Because once I go do the analysis on SHGC, get everybody's

13 comment, right, and decide whether or not the whole discussion

14 we were just having the last hour is really important, which I

15 think it is, right?

16 I think the solar heat gain coefficient are going to be

17 different, right? It's much easier to work within this map

18 because then I have to revisit the discussion on my own on where

19 that little line, 1A and 1B, would be, right? 

20 MS. HOFFMAN: So let me just ask, is a proposal that I'm

21 hearing Joe articulate is option two, subject with a deferral

22 based on DOE work on the solar heat component? I mean, that's
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

87

1 what I'm hearing, yeah. 

2 MR. DENNIS: That's the question. Can you hear me on the

3 phone? 

4 MS. HOFFMAN: Yeah, go ahead. Identify yourself, please. 

5 MR. DENNIS: This is Keith at NIJ. Is there like

6 additional paperwork that has to be done if they're in different

7 zones but have the same U-value? Or is it just literally a

8 line? I mean, is there added cost to this if it was all the

9 same U and SHGC value or not? 

10 MR. SANTANA: Manny here with Cavco. I don't believe

11 there are going to be any additional costs to anything because

12 you're going to have -- if you have the same U-value and the

13 same SHGC, then it's the same zone.

14 I think it's all the same zone. I think what I understand

15 the proposal to be is to have the line there, which is the same

16 line that's in the IECC, by the way as a place holder for future

17 -- to make it easier to change in the future.

18 But as far as any additional costs with identification of

19 labels, if you have the same Uo and the same SHGC, there

20 shouldn't be. 

21 MR. DENNIS: Does that change if the SHGC is different? 

22 MR. SANTANA: If the solar heat gain coefficient is
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

88

1 different, they you aren't going to have -- they're different. 

2 I don't know about costs again.

3 You could potentially have different windows, so that is a

4 cost item, but you will have a different label because it will,

5 in fact, be a different zone.

6 You know, you wouldn't be able to build a house for Zone

7 1B and ship it to Zone 1A. 

8 MS. HOFFMAN: Why not? 

9 MR. SANTANA: Because the solar heat gain coefficient will

10 be greater than what's in -- 

11 MR. RAMIREZ: We don't know that yet, so I -- 

12 MR. SANTANA: No. He asked if the solar heat gain

13 coefficient were different. 

14 MR. DENNIS: This is Keith. And I suggest that another

15 proposal is to lock the solar heat gain and go with the two

16 zones as a compromise. 

17 MR. RAMIREZ: Yeah. I think that's exactly what we're

18 discussing right now is the possibility of have the two zones,

19 but leaving that solar heat gain coefficient component for more

20 analysis from DOE. 

21 MR. DENNIS: Yeah, but I'm saying a different one would be

22 to lock it down and not punt it. Lock it down if they're the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

89

1 same and just have the different zones in name only. 

2 MR. RAMIREZ: Then that's option one, is the way I

3 understand it. 

4 MR. DENNIS: And one would be you still have the line in

5 the different zones. It's a little bit different from my

6 understanding. 

7 MR. SANTANA: I'd like to ask -- this is Manny -- if we

8 have Zone 1, which is one continuous zone, and has the same

9 U-knot value, has the same solar heat gain coefficient value and

10 just has the line through it which coincides with the line

11 that's in the IECC for the same, what is the benefit of that? 

12 MR. DENNIS: It makes Robin happy. 

13 MR. ROY: No, it doesn't make it happy. I really like the

14 idea of deferring to DOE's judgment, and also very much like the

15 idea of not, for example, forcing DOE to impose, if it comes to

16 this view, a .25 in an area where it's not effective in the

17 northern parts of these states.

18 Just as an arguing point, you'd have to see what their

19 analysis shows. The reason I first proposed this four-zone map

20 is slightly different because I didn't put those U-values in

21 there, which is because there was such an interest in the

22 manufacturers on trying to address this part of the country that
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

90

1 is so important to them.

2 We did not want to impose additional costs on folks. I am

3 very mindful of not imposing additional costs. But we're not

4 beneficial by mashing them together.

5 We're either going to lose -- we're going to foreclose the

6 possibility, depending what DOE finds on the SHGC, for example. 

7 We're going to foreclose the opportunity of cost effective SHGC

8 levels in one area, or we're going to impose expenses --

9 unnecessary costs on another area.

10 We're going to be kind of stuck with imposing costs we

11 don't want or giving away attractive efficiency.

12 I was being mindful of your industry concerns of this area

13 being of such importance to your businesses that you really want

14 to address first costs and you really didn't want to impose

15 things that were unnecessary.

16 Slamming them together really means walking away things

17 which are useful or imposing costs that are not. I find that

18 difficult. 

19 MR. HAGERMAN: Joe Hagerman. That's sort of hard. 

20 MS. HOFFMAN: Identify. 

21 MR. HAGERMAN: I said Joe Hagerman. 

22 MS. HOFFMAN: So, sorry. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

91

1 MR. HAGERMAN: Correct me where I'm wrong, but the number

2 of shipments in Climate Zone 1A probably equals the number of

3 shipments in Climate Zone 1B, right? 

4 MS. HOFFMAN: Yes. 

5 MR. HAGERMAN: So if we were sitting back -- so if DOE

6 only had one zone, the previous slide one zone, right, and we

7 found out that solar heat gain coefficient is a big deal between

8 those two lines, right, what would we do?

9 Which, you know, which group wins, which group loses,

10 right? Doesn't sound very equitable lumping it into one zone. 

11 It seems like the equitable thing to do is have two zones so we

12 can deal with it because it's, you know, equal number of

13 shipments, right? 

14 We get 20 percent of the market, and we can't address

15 affordability. 

16 MR. SANTANA: If DOE goes back and does the analysis and

17 finds out that that's cost justified, then there's no argument. 

18 You have a reason to split it. 

19 MR. HAGERMAN: Then let's vote on getting the next -- 

20 MR. DENNIS: This is Keith. I just have a comment. I

21 don't necessarily agree with that assessment.

22 Because you still are locking in -- you're leaving it up
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

92

1 to DOE to lock in a market risk that -- and I noticed I guess

2 there's no anti-backsliding provision. But if it messes us up,

3 it does have consequences.

4 Whereas if you were conservative, and you're talking about

5 a very small thing with this SHGC compared to a market

6 disruption, I think that you do end up potentially with locking

7 in some costs that way.

8 So, you know, I think that that argument skewed to one

9 point of view. I think that one of the conservative things to

10 do would allow for a higher SHGC, and if it's -- and give people

11 the option and not lock in that higher price.

12 So, you know, I hear what you're saying, but I also see a

13 different perspective on it. Because there are unknowns even

14 with DOE's further analysis. 

15 MS. HOFFMAN: John Caskey.

16 MR. CASKEY: John Caskey with NEMA. And this is a real

17 curiosity question, and I feel like it's a curve ball, but I'm

18 not sure.

19 There's certainly a lot of talk about climate change. Is

20 there any statistical information? I assume everything we're

21 looking at here is just historic data.

22 Is there any reasonable information out there that would
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

93

1 help us discern whether Climate Zone 1B and 1A will get more

2 similar as we go toward climate change? 

3 We know we're going to have flooding on the coast, and we

4 know a lot of other things are going to happen. We're already

5 seeing bird migrations and things like that.

6 Do with think those two things are going to get closer

7 together or might they get further apart, in which case that

8 would really put more pressure on choosing option two, in my

9 perspective.

10 And is there any analysis at DOE that they've sanctioned

11 it and look forward to what's going to happen with climate

12 change? 

13 MR. RAMIREZ: In some of the discussion that I'm hearing,

14 I think the idea here is to have probably -- this would be the

15 initial one and then three to five years having the group look

16 at this again.

17 As much as I think that there is climate change, I don't

18 think we're going to see that drastic in the next three to five

19 years that would impact these lines. 

20 MR. CASKEY: John Caskey at NEMA. That's not the three to

21 five years. Its homes that are being built and installed that

22 are going to hopefully last for 20, 30. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

94

1 MS. HOFFMAN: Lubby. 

2 MR. RAMIREZ: Michael. 

3 MS. HOFFMAN: Michael. 

4 MR. LUBLINER: So you brought the climate change issue. I

5 think that it's difficult, as Javier says, to look at that in

6 short increments like the next go-around. 

7 But my question for DOE is, is it important to DOE to look

8 at what these impacts have on the national grid and anything

9 else associated with the administration to objectives, stated

10 objectives and targets?

11 Because it seems to me that if this is a large population,

12 although it's small and the terabyte of energy the nation uses,

13 we're moving all in right direction. We're all trying to do our

14 thing.

15 So I would be interested in knowing not just how the

16 consumer benefits, but how all Americans benefit when you shift

17 to .25 in terms of carbon offsets. 

18 MR. HAGERMAN: Joe Hagerman. I guess I would say I'd go

19 back to what I said before. That I believe that there's 20

20 percent of the shipments in Climate Zone 1A, and I believe

21 there's 20 percent of the shipments in Climate Zone 1B.

22 If you lump those two together you get 40 percent of your
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

95

1 market. That's a large single percentage, right?

2 And there's a lot of factors, you know, that one could

3 consider to make the determination on what that needs to be,

4 right? And I think you highlighted some, I think a lot of

5 people highlighted others.

6 I mean, it worries me that there's 40 percent of the

7 market in Climate Zone 1 and there's evidence here -- there's

8 even evidence just if a person on the street just looked at the

9 IECC, you'll see that they treat what we're trying to treat as a

10 single zone very differently in the IECC document.

11 And knowing that it's 40 percent of the market, we're

12 sitting here trying to say, no, it's all the same. When, you

13 know, what Robin said before, you know, somebody's outfit in

14 Miami look different that people up in, you know, north Georgia.

15

16 MR. RAMIREZ: I'm seeing Eric, Manny, and then Mark. But

17 before we do, we have eight minutes before noon. Let me ask the

18 group, do you want to have a vote on this before the eight

19 minutes are up?

20 Okay, so let's get some discussion on this, but let's try

21 to take a vote right before lunch. 

22 MR. HAGERMAN: Joe Hagerman. Just could you test the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

96

1 waters like you sometimes do with the vote and see? 

2 MR. RAMIREZ: So let me see a show of thumbs for this

3 option two that's currently up on the screen. Anyone online

4 with your thumbs down? 

5 MR. DENNIS: Is this with the SHGC or -- 

6 MR. RAMIREZ: We're talking about the lines. We're just

7 talking about lines. We'll come back to the numbers. 

8 MR. DENNIS: I think I have my thumb down right now. 

9 MR. RAMIREZ: Okay, so just on that initial outlay there,

10 it looked like Keith with his thumb down and Mark. Everyone

11 else can live with this. So Manny? 

12 MR. SANTANA: Can you also gauge option one? 

13 MR. RAMIREZ: All right. Let's put option one back up

14 there. 

15 MR. TOMPOS: Dave Tompos from NTA. I have my thumb down. 

16 I don't think we should have two lines or two zones. 

17 MS. HOFFMAN: Who's that? 

18 MR. RAMIREZ: I'm sorry, who was that? David Tompos. 

19 Okay, so there was three on option two.

20 So let's look at option one. Let's see a show of thumbs

21 for option one. Option one I'm seeing one, two, three, four,

22 five, five thumbs down on option one. How about online, anyone
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

97

1 with your thumbs down on option one? 

2 MR. SCHNEIDER: Peter Schneider. 

3 MR. RAMIREZ: Okay, so six. So just as far as getting the

4 larger number, right, and I would tell you just for count wise,

5 let me just check real quick. 

6 MR. DENNIS: This is Keith. I could probably -- if we

7 clear up that SHGC thing, I guess I have a question more than a

8 vote, so I don't know if that matters. But we're supposed to

9 put our thumb down if we have a question, so. 

10 MR. RAMIREZ: And, again, we're talking about just the

11 lines. So out of 22 voting members, we would be technically

12 okay with either one, but we have a stronger consensus with

13 option two than we do for one.

14 Mark, you have a comment? 

15 MR. WEISS: Yes. As in the past, my new vote is based

16 just on the cost factors and issues that I've raised before. 

17 But I think the entire discussion here shows that we're missing

18 a key variable that factors into this. 

19 Without that being resolved, I think I go back to what

20 Manny said, whether you pick one or two, it's a shot in the dark

21 because you don't know how that variable is going to be resolved

22 sitting here now at this point. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

98

1 And I appreciate Robin's concern, and I agree with many of

2 the things that Keith has expressed. But I think it's a risky

3 affair at this point. 

4 MR. RAMIREZ: Yeah, and I actually think that that's one

5 of the reasons that we're talking about the possibility of going

6 to option two was to allow DOE to do some initial analysis on

7 that. 

8 And at least it will be easier to -- and if I understand

9 correctly, we're only talking about the one -- well, we haven't

10 gotten to the numbers yet. But it's leaning towards SHGC

11 numbers. 

12 MR. WEISS: We don't know how it's going to turn out. 

13 MR. HAGERMAN: But you're also saying that 40 percent of

14 your market is just the same. I don't think, you know, I think

15 that's just a little high.

16 I'm just saying that, when you know that they're so

17 geographically disbursed in that area and you know so much that

18 the IECC and all the other Climate Zone apps you've ever seen

19 have so many different divisions in those areas. 

20 MR. RAMIREZ: Well, what do you think of this? What do

21 you all think of going back, just to make sure, take your

22 consensus vote on option two, break for lunch, and then come
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

99

1 back and talk about the numbers? 

2 So I'm talking about just the lines for option two. 

3 Manny? 

4 MR. SANTANA: I've got a suggestion. How about option

5 one, having them both be the same zone but adding the line? 

6 MR. RAMIREZ: That is option two because we're not talking

7 about the numbers yet. 

8 MR. SANTANA: Well, you know, I think I would be a lot

9 stronger, if you identify the zone first, it's easier when you

10 come and vote for values to have different values between the

11 zones.

12 And if that was the case, I wouldn't vote -- I wouldn't be

13 sideways on the two zones. 

14 MR. DENNIS: Yeah, the question, it's hard to break the

15 two up with just a vote and no numbers. 

16 MR. TOMPOS: Dave Tompos from NTA. Are we punting on the

17 IECC number because we're questioning whether or not the new

18 analysis is correct from PNNL? We're showing that they're not

19 cost effective in most of these regions.

20 I'm confused, and I apologize because it's really hard to

21 follow a lot of this on the phone because it's hard to hear. 

22 But doesn't the kind of bring into question all PNNL analyses? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

100

1 MR. HAGERMAN: This Joe Hagerman. I know what they said. 

2 It's just the solar heat gain coefficients because the windows

3 are equally divided up or distributed around the unit, kind of

4 skews the impact of solar heat gain coefficient. And we may not

5 at best represented window placement within your industry on the

6 hard fact that they sell. 

7 MR. RAMIREZ: So it's just the solar heat gain

8 coefficient? 

9 MR. HAGERMAN: Yeah, it's only limited to solar heat gain

10 coefficient. 

11 MR. RAMIREZ: Let me get Michael and then Emanuel. 

12 MR. LUBLINER: Clarification. You would do the parametric

13 to see what the gap is in terms of downsizing equipment? I

14 suggested that, but I wasn't clear whether that would be --

15 MR. HAGERMAN: You know, the downsizing equipment

16 decision, you know, I think we ready talked about that. That we

17 have to consider that in the final. 

18 MR. LUBLINER: Okay, great. So it's not just for solar

19 heat, it's for the whole. 

20 MR. HAGERMAN: For the whole thing, yes. 

21 MR. LEVY: There's a model in the IECC where they break up

22 Climate Zone 4 into effectively two zones, two different thermal
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

101

1 climates for those zones, but they're still Zone 4.

2 So they're saying that those two -- those areas have some

3 integrity based on something. 

4 We could use the same model and say, Okay, we have Climate

5 Zone 1, but we have two subzones in same Climate Zone 1. One is

6 called the sunny and one is called the really sunny. 

7 MR. ROY: Hurricanes and snows, how about that? 

8 MR. LEVY: The problem is whether we're arguing over

9 semantics or not. Yes, that's the next slide.

10 MR. HAGERMAN: I'm more comfortable with this because it

11 seems like it allow us the possibility to consider the 20

12 percent of the market that's different from the 20 percent of

13 the other market that are in two different IECC climate zones. 

14 MR. RAMIREZ: Wait a second. So I think if I understand

15 where the disconnect here is, is it a labeling issue so that way

16 when something is labeled, can you ship it to a certain market?

17 And if that's the case, would this work if we could figure

18 out an appropriate labeling so you don't have to worry about

19 when it crosses lines? 

20 MR. HAGERMAN: Just to not to confuse Dave Tompos and

21 Keith on the phone, we're just talking about the dividing of the

22 states in the labeling of Climate Zone 1, 2, 3.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

102

1 We're not talking about the Uo-values or the SHGC,

2 because, you know, David or Keith said something they thought

3 they were voting -- 

4 MR. DENNIS: Just for clarification, is that assuming that

5 the U-values are going to be same in those different zones? 

6 MR. HAGERMAN: It's not assuming anything. 

7 MR. RAMIREZ: That's why I'm suggesting that we deal with

8 the numbers after lunch. 

9 MR. HAGERMAN: That's a separate discussion. 

10 MR. TOMPOS: Tompos from NTA. If PNNL was going to do a

11 more detailed analysis on solar heat gain coefficients, are they

12 going to take the project factors into account?

13 I mean, we don't even say that we have any, but, you know,

14 in a lot of cases you guys are going to make us do seven-foot

15 side walls, so our projection factor's going to be better. 

16 MR. HAGERMAN: We'd have to understand that more. I mean,

17 we're happy to do whatever analysis, you know, for the solar

18 heat gain coefficient in those four states. 

19 MR. DENNIS: I just want to point out, the IECC only

20 requires .25 when the projection factor's less than .2. So, I

21 mean, we're requiring manufactured homes to not have an option

22 to have less of an SGC.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

103

1 So, you know, this is one of those cases where I feel like

2 we're going above and beyond the IECC. And if we're going to

3 punt this thing, I want them to take everything into account. 

4 MR. HAGERMAN: Yeah, that's noted. 

5 MR. RAMIREZ: So let me get Lowell. 

6 MR. UNGAR: I just want to note that Eric who's I

7 think is our leading expert on window requirements in IECC isn't

8 in the room right now, so I would want to weigh his comments. 

9 On the regions, I just wanted to note that Emanuel

10 had referred to IECC in the northwest. My understanding is, the

11 regions in the IECC were developed by PNNL I believe based on

12 actual climate.

13 And then they chose -- the IECC has chosen in the

14 northwest essentially lump that piece in with a different

15 climate zone. What we're talking about is in some sense the

16 opposite, and we haven't done any climate analysis.

17 But from the little I've looked at, I suspect these

18 states, as the IECC has them, would, in fact, be with what here

19 is labeled Climate Zone 2. 

20 In terms of if we looked at the heating and cooling

21 degree days that the climate is going to be more similar to the

22 other climate zone because of other market factors, we're
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

104

1 talking about lumping it into with a different zone.

2 But that's not at all the same as IECC. In fact,

3 it's kind of the opposite. And in that sense, I would he most

4 comfortable labeling them, as I've been thinking of them

5 recently, as Climate Zones 1, 2, 3, and 4.

6 So we just don't take a position on where they go

7 because there's different reasons to one might include them in

8 each of the zones.

9 And I am not taking the position on Uo values there,

10 just in terms of the zones. 

11 MR. RAMIREZ: Manny. 

12 MR. SANTANA: Manny with Cavco. Similar to

13 paralysis by analysis, I think we've got paralysis by wanting

14 too much up front. You know, and I'd just like to remind the

15 membership that anything that we end up with is going to be a

16 huge improvement over what this zone period has the entire

17 country currently has. 

18 Currently in this zone, the U-value is .116 and

19 there are -- there is no value for solar heat gain, you know,

20 coefficient. So anything, .33 is going to be a huge improvement

21 over what we have, .25 even more. But, you know, so getting

22 bogged down on this level --
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

105

1 You know, another thing I'd like to remind everybody

2 is that, you know a statement was made earlier that we can get

3 market share from other state builders, and that we shouldn't

4 just concentrate on the affordable market. 

5 I think the affordable market is exactly what we're

6 concerned with. We're developing a minimum standard, minimum

7 additions. You could be more. 

8 You know, this is a minimum standard, and we still

9 have the mandate to try to keep these standards as affordable as

10 possible, so the affordable market is exactly what we're so

11 trying to -- we're trying to improve but not price anybody out. 

12 You know, another statement was made on trending. 

13 You know, and like I said, this is going to be a trending of

14 correct direction. There's a huge step forward. You know, I

15 think maybe we might want to try to move past it. 

16 MR. RAMIREZ: What was the last comment that you

17 want to what? 

18 MR. SANTANA: Move on. 

19 MR. RAMIREZ: Well, yeah, but I think the way to get

20 past it is by formalizing one of the consensus votes, right, and

21 just looking at it as far as the strength of the two votes.

22 Let's take a vote on option two, and let's see if we
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

106

1 can formalize what that consensus count is, right. And, again,

2 not the numbers, just the lines. 

3 MR. HAGERMAN: The lines and the lines or just the

4 lines and you have four zones? 

5 MR. SANTANA: Three zones and the line or four

6 zones; that's a good question. 

7 MR. RAMIREZ: Yeah. And my recommendation would be

8 to, let's chop off the labels. Let's just do lines. We could

9 figure out how the call it later, you know, because if there are

10 shipping concerns on how it's labeled, let's talk about that

11 after lunch. So just the lines. 

12 MS. DICKENS: So we're voting on -- is this Ishbel

13 -- four zones, no names, no numbers? 

14 MR. HAGERMAN: We're just actually voting on that

15 dash little line there. 

16 MR. RAMIREZ: That's really what it is. So with

17 that line, let me see a show of thumbs. Anyone online with your

18 thumbs down?

19 Okay, Mark? 

20 MR. WEISS: I don't see how you separate the lines

21 from the numbers, but I'll have to vote no again based on the

22 factors I previously laid out. But that's fine. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

107

1 MR. RAMIREZ: Noted. Anyone else online? 

2 MR. DENNIS: I just have a question -- well, I have

3 a comment. I think my vote would change if the U-values come

4 out to be different between the two zones. So I am no longer

5 locked into that vote, but just a comment. 

6 MR. RAMIREZ: Okay. 

7 MR. TOMPOS: Dave Tompos. I've got my thumb down

8 just for the same reason. I don't understand why we're putting

9 a random line there for no reason?

10 So it really depends on what the numbers are before

11 I can say, yeah, let's put an imaginary line there. 

12 MR. RAMIREZ: Right. And the issue is being that

13 whether that Uo-value is different in the two. If they're the

14 same, then you're okay. 

15 MR. TOMPOS: No, if they're the same, who gives a

16 crap? I mean, this is crazy to me. I don't understand why

17 we're going round and round about this. 

18 MR. RAMIREZ: I'm guessing that we may be going

19 there. So I'm going to say that you do have consensus. I

20 marked -- David I'll put you down as a no. Mark Weiss is a no. 

21 Keith, are you no or sideways? 

22 MR. DENNIS: I'm sideways. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

108

1 MR. RAMIREZ: Okay. So those are the two no votes. 

2 Let's break for lunch. When we come back we'll talk about

3 labeling and the numbers. 

4 MS. HOFFMAN: Okay. See you back at 1:00. 

5 MR. RAMIREZ: Yeah. No, we're not going to see you

6 back at 1:00. We're going to see you here, right? So let's

7 take a one function, use the restroom. I'm hoping that there's

8 some box lunches out there.

9 And then we'll going to be doing a working lunch

10 today. So anyone that's interested in hearing the presentation

11 that we're going to have at lunch, bring your lunches in here,

12 and let's hear what they've got to say. So let's get back here.

13

14 MR. HAGERMAN: DOE is going to sneak out real quick

15 because we're going to run around and try to get this term sheet

16 written up and finalized. 

17 MR. RAMIREZ: Okay, that's fine. This is an

18 optional presentation, so if you'd like to stay here, you're

19 more than welcome. And then so we'll start back up at 12:15. 

20 No, 12:15 of the presentation. 

21 MS. HOFFMAN: Oh, 12:15 for the presentation. 

22 MR. RAMIREZ: Yeah. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

109

1 MS. HOFFMAN: And 1:15 back for being back online. 

2 (Whereupon, there was a break for lunch.)

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19 MR. RAMIREZ: So let's go ahead and get started. 

20 And I left the map up here just too kind of refresh your memory

21 of where we are at and where we're going.

22 So prior tour lunch break we had talked about using
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

110

1 the lines here that are in option two, and then we said that we

2 would then talk about the actual Uo numbers and the SHGC

3 numbers.

4 And I had Matthew send me the chart that we had

5 talked about before regarding these numbers, so we'll go ahead

6 and put that chart number, the charts up here. Ted, would you

7 put those up for us? 

8 MR. HAGERMAN: Could you maybe ask if everybody on

9 the phone can hear us, just to make sure they're still alive? 

10 MR. RAMIREZ: Yeah. Folks, I'm hoping that you're

11 muted -- not muted rather. Can you hear us? 

12 MS. HOFFMAN: Is there anyone you can call to make

13 sure they're on? 

14 MR. RAMIREZ: All right. I just sent a note to see

15 if we could get the audio going online. 

16 MS. HOFFMAN: Can you unmute them? 

17 MR. RAMIREZ: Yeah. Well, we can't hear them. 

18 MS. HOFFMAN: Okay, we're back. 

19 MR. RAMIREZ: Okay. So, again, the folks that are

20 online. If you want to contribute, your mics are open. You can

21 speak at any time.

22 We would ask that while you're not speaking if you
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

111

1 could just keep your phones on mute. Sometimes that just helps

2 with any feedback. 

3 All right. So, again, we had the line up here and

4 we didn't put in the numbers, and once we're going to the

5 numbers, then forgot how we're going to label them.

6 And so when we were -- with these climate zone

7 numbers here we had already agreed to I think the majority of

8 them, if not all of them. And so I had Matthew send me the

9 chart of what numbers we had agreed to. So we'll take a look at

10 that and go from there. 

11 So if I could have Ted pull up the number with the

12 charts on it or the chart with the numbers on it. Okay.

13 Now, if you all remember -- 

14 MR. POTTS: Javier? 

15 MR. RAMIREZ: Yeah. 

16 MR. POTTS: This is Rick. I sent you an E-mail. 

17 You might want to read it to the group. 

18 MR. RAMIREZ: Is that still pretty hard to see? 

19 Let's focus on a single section. And, Ted, could you maybe make

20 it larger so that we could just see the single section?

21 How's that? Is that -- are you able to see that? 

22 Rick, and you see those now?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

112

1 Okay. So could someone walk us through these

2 numbers here again and exactly how this would apply to the math

3 that we were discussing? 

4 MR. HAGERMAN: This is Joe Hagerman. Sorry

5 everybody. We'll reiterate what this is. So this was from the

6 original packets, Emanuel Levy packets. I think it was page of

7 that packet.

8 This was also what we agreed to with some of the

9 solar group at the last meeting with just some changes to solar

10 heat gain coefficients. So, you know, not having those

11 corrections I asked Matthew to block out in blue the solar heat

12 gain coefficients there. 

13 And so the group asked us to go rerun the four

14 states and those four cities. And those four states and those

15 four cities are the U values and the prescriptive values are

16 contained within that box, the red box, red.

17 So that's what we reran. So is everybody clear

18 about that? I think it's pretty clear. 

19 MR. LEVY: This is the lifestyle costs? 

20 MR. HAGERMAN: Right. 

21 MR. UNGAR: You ran those two cases for cities? 

22 MR. HAGERMAN: That's right. And so we sent you
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

113

1 those results. So I think the discussion we wanted to have was,

2 you know, you asked -- I think everybody wanted to relook at the

3 U values for those four states, right.

4 And so that's what we wanted to highlight here in

5 this descriptive values for those four states, right?

6 And I don't think we're -- I hope we're not talking

7 about re-discussing like the 2015 IECC Zone 6 that gets mapped

8 into -- the map that we just decided on as an example. 

9 So I'm to limit the discussion to those U-values and

10 those prescriptive measures -- related prescriptive measures for

11 that that fall within the four states that we wanted to

12 reconsider. 

13 MR. TOMPOS: Dave Tompos from NTA. I just have a

14 question. I'm on the trying to make you redo anything. But why

15 do we use a .35 U value for glazing and a .40 for the doors? On

16 the IECC it is much, much higher than that.

17 Unless I'm looking at the wrong table in IECC, Table

18 T402.4, I mean even the worst case for operable fenestration,

19 which all windows in the manufactured housing that are all

20 operable is .37. That's for Zone 7. And in yours it's .77. We

21 used a .40 and a .35. Am I missing something? 

22 MR. RAMIREZ: Go ahead, Eric. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

114

1 MR. LACEY: This Eric from RECA. Are you looking at

2 the commercial table and not the residential? 

3 MR. TOMPOS: I'm sorry, I am. 

4 MR. LACEY: Yeah. I have a question about the

5 doors, too. It would be the door in the residential code, the

6 door U factors are the same as the window U factors because it's

7 all lumped into fenestration.

8 Here they're called out separately. And my question

9 is, is that because we're assuming this is an area weighted

10 average?

11 I was hearing at a previous meeting that maybe the

12 back door is an out-swinging door and it's harder to get that

13 same U factor.

14 And so this is kind of a rough average between

15 what's probably a good, you know, thermally insulated front door

16 and this less insulated back door.

17 I mean, I have no problem to be clear with them both

18 being the same U value as the other fenestration in the unit. 

19 But I'm guessing that that's why that number's different. Do

20 you want to clarify? 

21 MR. LEVY: It's hard to keep track. You look at the

22 most recent version, the one that we've looked at today, and
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

115

1 you'll notice that the U factors do change for the line, and to

2 correspond with what you're saying, Eric. So we made that

3 correction to the doors.

4 Earlier on I made a simplifying assumption then I

5 talked to Rob about it, and we agreed that they had to be

6 modified, and that's what's in the most recent version. 

7 MR. LUTER: Just a little more clarity. Rob with

8 Lippert. I don't particularly have too much heartburn with the

9 .4 over doors.

10 The reality is that to your point the out-swing back

11 doors do have poor thermal performance in general than a

12 comparably equipped in-swing front door. The construction is a

13 little different. 

14 However, when you start adding various door lights

15 to the front doors, you U value performance gets worse in a real

16 hurry. The solid door with nothing but a viewer in it is down

17 around .20. A door with a half-light or full light is closer to

18 .40.

19 And I'd hate to see a prescribed U value that would

20 disqualify a number of popular door options, especially

21 considering it's such a small square footage area of the whole,

22 so. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

116

1 MR. RAMIREZ: Eric. 

2 MR. LACEY: I mean, I thought I saw maybe earlier in

3 this meeting there was another table flashed up that had

4 different U values than what's here. Okay, that's what you're

5 talking about.

6 And I was going to raise a real concern about

7 cranking up U values that far. This seemed like a reasonable

8 level for an area weighted average given the limitations of that

9 back out-swinging door. 

10 MR. HAGERMAN: That's why I wanted to have a red

11 baseline just, you know, kind of re-kind of calibrate everybody.

12 This is what we voted on last time that we agreed on. 

13 MR. RAMIREZ: Yeah. That's kind of what I was

14 thinking was that the group had previously agreed on U values,

15 and what I wanted to see was looking at the lines, I don't even

16 want to call them the four zones or the three -- well, we'll get

17 to that labeling piece.

18 But to the group that was up on top was Climate Zone

19 3, what was the Uo value that needs to be plugged in there? 

20 MR. RAMIREZ: And we go by each group, right. So

21 we're starting off with that Climate Zone 3. Looking at the

22 numbers here, which of these numbers is it that we need to plug
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

117

1 in there? Yeah, Lowell. 

2 MR. UNGAR: Two things. One is, we have been

3 talking about having a prescriptive requirement and a Uo-value. 

4 MR. RAMIREZ: Right. 

5 MR. UNGAR: Even if we get the Uo value, then leaves

6 what is the prescriptive package that goes with that. 

7 The second is the PNNL's calculation of Uo-values

8 and Emanuel's calculation differ very -- it's only a little bit

9 like .002, but they are different.

10 And so if we are going to have both the prescriptive

11 package and a Uo, I don't know what Uo-value to use. I guess it

12 was on the agenda maybe for later on.

13 But I don't know which Uo-value we should use or if

14 we're trying to choose exact Uo-values to agree on right now. 

15 Because I don't know which set of Uo-values we should be looking

16 at. 

17 MR. RAMIREZ: Uh-huh. But given the numbers that we

18 had previously looked at, right. 

19 MR. UNGAR: But these are Emanuel's Uo numbers. But

20 when -- and we now have -- we didn't have PNNL Uo-values before,

21 but now with the recent runs they're giving us Uo-values and

22 they're not exactly the same. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

118

1 MR. RAMIREZ: How do we clarify that? 

2 MR. MULLER: Matthew Muller. The most recent so

3 those are run-on proposals. The October 17th proposal that was

4 not this set of prescriptive standards. It was a new proposal. 

5 MR. UNGAR: Some of them are the same.

6 MR. MULLER: Some of them are the same. 

7 MR. UNGAR: And when I looked at it, I didn't think

8 even where the prescriptive requirements are exactly the same. 

9 I didn't think the Uo-values were exactly the same. 

10 MR. LEVY: How are those calculated? How is the

11 Uo-value calculated? Is it internally to energy plus? 

12 MR. BARBOUR: PNNL uses the same methodology that was

13 historically 

14 MR. UNGAR: Three cases were different by as close as

15 2-1,000's of a U value. Two were higher and one was lower. So

16 there's something there and it's probably something small, but I

17 don't know how important it is to this discussion. 

18 MS. HOFFMAN: Lubby. 

19 MR. LUBLINER: And it's a question for the industry,

20 too. The Uo-value and what I read in the standard, I'm a little

21 confused. If there is a crossover duct, is that included in the

22 calculation Uo, and could this be where the discrepancy is? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

119

1 MR. EZZO: Mark Ezzo. Yeah. In today's HUD world,

2 we have to account for duct area and duct loss in Uo-values;

3 that's correct. And in IECC calculation methods you do not. 

4 You're right, Mike, it could be the reason. 

5 MR. LUBLINER: I know when Dave Tompos and I looked

6 at it, it wasn't a big deal. But I was just bringing it up

7 because it did may have some implications for this discussion. 

8 MR. HAGERMAN: When you said they differ, what are

9 you talking about in terms of real numbers? 

10 MR. EZZO: I'd say it was like .002 and it was not

11 big. But again, if we're agreeing on exact numbers, then I

12 don't know. 

13 MR. HAGERMAN: Just take it two decimal places. 

14 MR. RAMIREZ: Well, if there's that small and if I'm

15 hearing the group, it's fairly insignificant, which one do you

16 want to use? 

17 MR. UNGAR: I'm sure we can reconcile this online. 

18 MR. RAMIREZ: Okay. So you will reconcile the data,

19 okay. What does that do, though, with plugging in the numbers

20 for the result? How do we -- 

21 MR. LEVY: I think we just move forward, assuming

22 we're going to reconcile then it's not being go make a tangible
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

120

1 difference to the numbers. 

2 MR. RAMIREZ: Okay. Then that takes care -- that

3 would take care of then what those numbers would be for the use

4 of Uo numbers, right, and then what about the SHGC, that as

5 well? 

6 MR. UNGAR: No, that's a different. 

7 MR. HAGERMAN: We deferred that. 

8 MR. RAMIREZ: All right. Then going back to the map

9 then, okay, can we go back to the map, Ted? 

10 MR. HAGERMAN: Joe Hagerman. I think the

11 outstanding question was, you asked us to relook at the four or

12 five states, we got the numbers.

13 You want to stay with the U values and all the

14 prescriptive measures that we already voted on, or because now

15 that you've seen the data do you want to move them up or down? 

16 That's the fundamental question. 

17 MR. LEVY: Let me clarify something. 

18 MR. HAGERMAN: Then we're done, right? 

19 MR. RAMIREZ: No. 

20 MR. LEVY: We don't really have prescriptive

21 packages. We have seven prescriptive packages that correspond

22 with seven IECC zones. Now we're talking about having three or
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

121

1 potentially four Uo-values.

2 What we have to do to be correct is decide on the

3 Uo-values and then back out of that to the prescriptive packages

4 (inaudible).

5 MR. HAGERMAN: Joe Hagerman. So I don't disagree

6 with you, but I think if you go back to the table that you ready

7 generated, I think the packages -- these performance packages

8 generate the Uo-values, right? 

9 MR. LEVY: In combination. 

10 MR. HAGERMAN: In combination, how?

11 MR. LEVY: Well, you've got three -- you might have

12 new Zone 2 might have three zones in it. It might be a balance

13 of -- go back to the map for a second. 

14 MR. RAMIREZ: Can you go back to the map, Ted? 

15 Lowell, do you have something that you think might help clarify

16 it? Then Emanuel. 

17 MR. UNGAR: You need to go one after the other. 

18 MR. RAMIREZ: What do you mean? 

19 MR. UNGAR: I think I can help clarify some of this.

20

21 MR. RAMIREZ: Do you want to defer or do you want to

22 continue on? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

122

1 MR. UNGAR: Okay. 

2 MR. RAMIREZ: Emanuel. 

3 MR. LEVY: You know that we have a Uo value of 0.69,

4 0.58, and .090. Go back to the table you were just on. There's

5 really no 0.58 on that table. There's no 0.69, and there's no

6 .090.

7 Now, they may be one of those packages, but you

8 might be able to come up with a package that corresponds exactly

9 to those. 

10 MR. HAGERMAN: Right. And that's the only reason I

11 wanted to flag it was the previous map that had the Uo-values on

12 it are not the same Uo-values that we voted on. So I just want

13 to be crystal clear with this, right.

14 These are the Uo-values that we talked about last

15 time. So we want to change things just -- I don't want to

16 mistake anybody by saying the map that you saw up there reflects

17 what we decided on last time because there's a difference. 

18 MR. RAMIREZ: Lowell. 

19 MR. UNGAR: Yeah. So to be more concrete, I mean,

20 this table turns out to have the same width because of the

21 adjustments Emanuel made here, if you recall, IECC's Zones 1 and

22 2 are the same, IECC's Zones 3 and 4 are the same, 5 and 6 are
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

123

1 the same. 

2 And so if we -- I mean, and this gets us to the

3 October 17 run which you can also talk about.

4 But if you neglect -- ignore 7 and 8 for the moment

5 because they're a pretty small number of homes, the 5 and 6 is

6 very close to the Uo that Emanuel had for Zone 3. I recall Zone

7 4, but the most northern zone. 

8 The only real difference there is, like I said, this

9 is what we agreed on, which has a ceiling of 38. I think

10 Emanuel adjusted one at the ceiling in one of those zones but

11 not the other. But it came out. It was only like .001

12 difference I think in the Uo-value.

13 So I suggest what we put in the straw man on --

14 labeled October 17th is just these numbers that are applying in

15 5 and 6.

16 For the zone what I would call Zone 3, the middle

17 zone, what we used was, again, these numbers for I believe its

18 IECC 3 and 4.

19 And I believe in a modified version Emanuel had this

20 for a Zone 4 and so I think we're in agreement there. The Uo is

21 not exactly the same because the double-wide is different from

22 the single-wide.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

124

1 But I think the prescriptive package that we have

2 there is exactly the same. There was the issue and there we --

3 October 17th is a completely different package and we can talk

4 about it in those cases. But that's where the real question had

5 come.

6 MR. RAMIREZ: So help clarify. So, Ted, can you put

7 up the map? Looking at these numbers here, the ones that were

8 on the chat, how would these numbers have to be adjusted in

9 order to be more in line with the chart? 

10 MR. UNGAR: So my suggestion for what are here

11 labeled what I would call Zones 3 and 4 over here are label

12 Zones 2 and 3 is there are prescriptive packages there that we

13 had agreed to before. That would work for these. 

14 And then I don't know. The exact Uo lines are very

15 close, but the exact ones would depend on which set of Uo-values

16 we picked. 

17 MR. RAMIREZ: And when you say they're close, I

18 think it was .59 and .63 I think maybe. 

19 MR. HAGERMAN: Let me just say. Let me do a

20 friendly amendment to Lowell's explanation, if you could go back

21 to the table. 

22 MR. RAMIREZ: Okay. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

125

1 MR. HAGERMAN: He said that the IECC Zone 1 and 2

2 are the same. He means that literally the prescriptive and the

3 Uo-values are the same, right?

4 So effectively we don't have eight different rows

5 here, seven different rows here. You've got one, two, three,

6 four, right? And I think what we've been talking about is those

7 four rows, those four sets directly map onto this map that we

8 just voted on, right? 

9 MR. UNGAR: Well, no. 

10 MR. HAGERMAN: It should. 

11 MR. UNGAR: Because the zone -- when you're

12 referring to a Zone 4 where there's seven and IECC's zone 7 and

13 8 here that we basically discarded as being -- it wasn't worth

14 dealing with. 

15 MR. HAGERMAN: Right. That's absolutely correct. 

16 MR. UNGAR: And the new zone we carved out, what I

17 would call Zone 2 in the four southern states, it is in IECC 3,

18 but there was concern about using those values for that zone. 

19 And so that I think is an open question. 

20 So I think for the northern two -- what I call Zone

21 3 and 4, those we could use the prescriptive. Those I wasn't

22 hearing larger, and Emanuel had a very slight change to what we
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

126

1 had agreed to previously.

2 We could argue about it if you want, but I'm not

3 sure it's worth arguing about. 

4 MR. HAGERMAN: I agree with you. The upper northern

5 states that create their own new zone wouldn't necessarily just

6 disappear because it all represents two to three percent of the

7 shipment or three or four percent of the shipments.

8 I think we should take a vote whether or not, yes,

9 we want to consider them as a separate zone and separate

10 packages, or, no, we're fine with just lumping in Zone 3. 

11 MR. UNGAR: I thought we already agree to that when

12 we set the zones. 

13 MR. HAGERMAN: Perfect. I love it when we already

14 agreed on something. So did we also then by default agree that

15 those values were the same values in the Zone 3 values? 

16 MR. LEVY: Can you call it the zone blue value? 

17 It's just much easier to call it zone blue. 

18 MR. HAGERMAN: I'm sorry, zone blue.

19 MR. UNGAR: We had previously agreed on the

20 prescriptive packages and Uo-values, and I'm suggesting we just

21 ignore IECC 7 and 8 and take the others for these zones. 

22 MR. HAGERMAN: Okay. That's correct. Okay. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

127

1 MR. EZZO: This is Mark Ezzo. Can we take a -- I

2 mean, you have a way to edit what we're looking at here? 

3 MR. HAGERMAN: Ed is doing that right now. 

4 MR. EZZO: What I think would be really neat to have

5 is if we could have -- get each one of the zones. Have

6 somewhere written on there the R-values. Thanks, Mike.

7 And, you know, a prescriptive R-value for the wall,

8 ceiling, floor and the U value that goes along with that, those

9 components. Then we'd have everything on one map. 

10 MR. HAGERMAN: That's what Matthew is doing right

11 now. 

12 MR. RAMIREZ: So then do we want to table that until

13 that's done and then we can move onto some of other? Do we want

14 to wait for a few minutes?

15 How long will that take you, Matthew? 

16 MR. HAGERMAN: It's going to take Matthew ten

17 minutes. 

18 MS. HOFFMAN: So ten minutes to get one map with --

19 let me just summarize what I've heard -- with the blue zone, the

20 yellow zone. I don't know, is this a red and pick or whatever?

21 With the R-values for free areas and the U values,

22 and have it ready for us to look at, correct? All right. So
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

128

1 we'll be about ten minutes. 

2 MR. RAMIREZ: So a ten-minute break then? 

3 MS. HOFFMAN: I guess a ten-minute break, unless -- 

4 MR. UNGAR: If you want, we could talk about the

5 October 17th, which I said the north is the same, but in the

6 south it's actually different. 

7 MS. HOFFMAN: Okay. 

8 MR. ROY: I think we're in agreement, but I'd like

9 to take a temperature test on zones blue and yellow, the

10 prescriptive and the U that comes out. And I think we don't

11 have to spend as much time with yellow and blue. I think

12 there's a lot of agreement. 

13 MR. RAMIREZ: Yeah, I think it is. I think folks

14 just wanted to see exactly what it is before they do it, if I'm

15 on the mistaken. But, yeah, I think you're right, though,

16 Robin. 

17 MALE VOICE: You can see it on the table. Just put

18 up the table and we can do that one. 

19 MR. RAMIREZ: All right. Ted, can you pull up the

20 table? 

21 MR. UNGAR: So if you look at, say, IECC and IECC 5,

22 there's a lot of extra numbers in there, but they are R-values. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

129

1 Those were the two sets of, you know, that we were looking at. 

2 MR. RAMIREZ: So the blue is a five? So this is the

3 blue and this is the yellow. And so, Robin, that's what you're

4 saying that we could gauge the level of Texas on 5 and 4 that

5 take care of the yellow and the blue. 

6 MR. ROY: I think so. I thought we were pretty well

7 -- 

8 MR. RAMIREZ: All right. Let's wait for Emanuel and

9 then we'll gauge that one. 

10 MR. HAGERMAN: We voted that one on the last

11 prescriptive table. 

12 MR. SANTANA: So we're talking about .059 for Zone

13 3 and .070 for Zone 2. 

14 MR. UNGAR: It's not going to be exactly that, but

15 very close, within the .002 or so with that. 

16 MR. SANTANA: What we were talking about, I think

17 that's been established. 

18 MR. RAMIREZ: Yeah. And if that's the case, it's

19 just plugging into the term sheet. But then the discussion is

20 those four -- actually Zone 1. Right. Whether it be Zone 1. 

21 Just think in red. 

22 MR. HAGERMAN: I apologize if I confused everybody. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

130

1 I just realized that the map Emanuel showed has different U

2 values than what we already agreed to. 

3 MS. HOFFMAN: How different are they? 

4 MR. UNGAR: Well, in the north they're very similar.

5 It's from the south. 

6 MS. HOFFMAN: The south, okay. 

7 MR. HAGERMAN: Probably if we're going to start

8 doing that, then we need to re-talk about the prescriptive

9 measures because we previously agreed the use of Uo-value are

10 prescriptive measures were equal, right. 

11 MR. RAMIREZ: Okay, all right. So here's where

12 we're at then. Looking at 5 and 4 on this chart here, could you

13 go back to the map for me, Ted? 

14 Five takes care of the blue area, 4 takes care of

15 the yellow area, right? So we're not in dispute on that. What

16 do we do with the red and/or pink? 

17 MR. SANTANA: I'd like to invite Emanuel to explain

18 the U value for Zone 1, the new U value. 

19 MR. LEVY: What we're looking at on the screen. 

20 MR. RAMIREZ: You say Zone 1, you're talking about

21 both A and B? 

22 MR. SANTANA: Yeah, they're both Zone 1. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

131

1 MS. HOFFMAN: Zone 1, A and B, right. 

2 MR. LEVY: So the actual number, if you look at

3 (inaudible), that group of states is actually .083. 

4 MALE VOICE: Okay. 

5 MR. LEVY: It should be .083. If we just follow our

6 methodology. At the last meeting we -- and for the pink zone,

7 it's .090.

8 The recommendation that we raised last time was that

9 we would take those states -- the top of those states up to .090

10 and recognition of the fact that they are areas where affordable

11 housing is much duly important to that market, and that we

12 would, for the time being.

13 And I think take those out to the same levels as

14 what we have as Zone 1 now. So that's where that is.

15 I personally have no compunction about either

16 average those values and putting them in one zone or keeping

17 them separate and having separate Uo-values. You know, but I

18 think that's what the debate is about. But that's where the

19 .090 comes from. 

20 MR. RAMIREZ: So according to what we agreed to

21 before, that would be .83 in the red and .90 in the pink? 

22 MALE VOICE: No. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

132

1 MR. RAMIREZ: Okay, Lowell and then Manny. 

2 MR. UNGAR: Those are numbers that were in Emanuel's

3 when he presented today. But those actually changed before. 

4 They're not hugely different, but they are different. 

5 MS. HOFFMAN: Okay. What did we agree to before? 

6 Let's just -- 

7 MR. HAGERMAN: I have a record of what we agreed to

8 last time. 

9 MS. HOFFMAN: Okay. 

10 MR. HAGERMAN: We agreed to .087. This is what

11 you're about to see because Ed Barbour just sent it to Ted

12 Bantel (phonetical). 

13 MS. HOFFMAN: Okay, .087. 

14 MR. HAGERMAN: For a single section or single -- 

15 MR. HAGERMAN: Single section, okay. 

16 MR. BARBOUR: You'll see them both, actually. This

17 is Ed Barbour. You'll see both (inaudible). 

18 MR. HAGERMAN: So we agree to .087 -- 

19 MS. HOFFMAN: Yeah. 

20 MR. HAGERMAN: -- and 1A. We agree to .070 in Zone

21 1B and Zone 2, and then we agree to .059 in the next zone. And

22 then that little upper states that we just got rid of, we agree
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

133

1 to .051, but remember David Tompos said that'd be technically

2 impossible, so. 

3 MALE VOICE: .087. .070, .059? 

4 MR. HAGERMAN: That's correct. 

5 MR. SANTANA: The one we're discussing is .087. So

6 .087 is what we're discussing for the entire Zone 1. 

7 MALE VOICE: No. 

8 MR. TOMPOS: Nothing is impossible, and I don't

9 think I said it was impossible. I said it would be very

10 difficult one you get below .60 - .060. 

11 MR. HAGERMAN: That's right. I had to bite my

12 tongue when you said that. 

13 MR. HAGERMAN: Okay, sorry. I take that back. 

14 MR. HAGERMAN: Yes. So what we're kind of talking

15 about here is punting. You know, when we created the new 1b, we

16 previously had it at .070, right, and now it's gone to .09. You

17 know, the last thing we saw from the meeting was .9, so that's a

18 big jump, right? 

19 MR. SANTANA: I don't think that it was ever a .70,

20 or .070. 

21 MR. HAGERMAN: 1b would be. 

22 MR. LEVY: Maybe I can explain exactly what happened
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

134

1 here.

2 MR. HAGERMAN: Okay. 

3 MR. LEVY: .070 is that entire Zone 3. 

4 MR. HAGERMAN: That's right, that's right. 

5 MR. LEVY: And what we did is a sensitivity study

6 only for location in the four states part, those four southern

7 states part on one component, which was -- looked like it was

8 not cost effective and it was subtracted from the package. 

9 So just for that part of Zone 3 I suggested a change

10 to .083. And that's what most of the presentation was about. 

11 MR. RAMIREZ: Manny. 

12 MR. SANTANA: Right. So the handout that was

13 distributed right after lunch, -- 

14 MR. RAMIREZ: Yeah. 

15 MR. SANTANA: -- this showed the analysis of the

16 four southern cities in that area. That's the .087, correct?

17 And it shows -- and this is what we asked for during

18 the last meeting to see if it was cost justified to incorporate

19 those southern states and have them grouped in the same Zone 1,

20 correct? 

21 And the numbers reflect that it is beneficial. It

22 is justified to have those states in those parts -- or those
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

135

1 cities in those parts of the state be in Zone .087. Isn't that

2 what we're seeing that's reflected by the data? 

3 MR. UNGAR: Where are you looking at? 

4 MR. SANTANA: The handout. 

5 MR. ROY: Comparing the .070 and the .087 runs for

6 the four southern states. 

7 MR. SANTANA: So when you compare the runs, the .087

8 and the .087 (sic), you see that you get better savings with

9 .087 than you do with the .070. 

10 MR. UNGAR: Are you looking at the ten year? 

11 MS. HOFFMAN: This is blue. 

12 MR. SANTANA: But we've been talking about the ten

13 year pretty consistent. I didn't mean that the majority of the

14 committee had. 

15 MS. HOFFMAN: This is blue. That's brown, green,

16 and red. 

17 MR. ROY: This is kind of why I was so interested in

18 having -- well, now we have different colors. 

19 MS. HOFFMAN: I know. 

20 MR. ROY: Red's separated because the prescriptive

21 that we were looking on a while ago, which has IECC Zone 3 for

22 all of the green section here has .070 as the -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

136

1 MS. HOFFMAN: It's orange. It's brown orange. 

2 MR. ROY: And it seemed reasonably likely, in

3 listening to manufacturers' particular concerned about this

4 area, it seemed reasonably likely that Emanuel and others would

5 find a few measures which didn't look particularly economic in

6 the green area.

7 I agreed with that. It's one of the things I asked

8 him, too, a few weeks ago, and I asked is reduce in ceiling from

9 30 to 22 and to look at that. It looked suspicious as to its

10 cost effectiveness. 

11 But this an example of why I thought it was

12 important to break out these parts of those states.

13 It seemed like there was at least that one measure,

14 the ceiling measure that would be best stripped out and not have

15 those costs imposed in that area, either through some averaging

16 or other.

17 But what I think what Manny is saying, it resonates

18 with me, if you look at numbers and you believe the numbers, you

19 can qualify them as they are on these two, the .087 and .070

20 four southern cities, there's a slight improvement in total

21 life-cycle cost effectiveness from the more stringent standard.

22 But I appreciate the trade-off between those two
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

137

1 perspectives, the first -- the two cost effective perspectives,

2 the first cost and the cycle cost.

3 It was one that I thought was an interesting and

4 probably productive way to drop some of those more expensive

5 measures. I'm no giving up all that much in life-cycle cost

6 effective savings. 

7 And that's why the .087 looks like it's better than

8 the .070. What's not clear is whether a .083 is better than the

9 .087, but definitely just between the .070 and the .087, the

10 .087 looks like a sensible balance. 

11 MR. RAMIREZ: Lowell. 

12 MR. UNGAR: Have I raised now the October 17th run? 

13 Unfortunately we don't have a clean chart. I can try to find

14 it. If you want to pull it up, it's in the PNNL (inaudible). 

15 MALE VOICE: Let me see if I can find it. 

16 MR. UNGAR: So we tried in giving what we heard at

17 the last meeting the concerns for the green zone. Robin and I

18 tried to look at a set of measures that was in some sense in

19 between what are here, the red and the orange zones.

20 But with the real focus, we had a real concern about

21 costs, so we were trying to look at measures that were based on

22 the data that Emanuel had collected were particularly cheap from
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

138

1 a first-cost perspective. 

2 So let's talk about the very far south first because

3 when we changed the green zone it turned out that to make sense

4 you had to change the red zone as well. 

5 On the red zone and you were talking both about what

6 we agreed to before and compared to Emanuel's changes, which he

7 kind of concurrently was doing.

8 Emanuel looked at the ceiling value and said that

9 doesn't make sense, so he reduced the ceiling from I think R30

10 to R22. And we did the same thing.

11 However, we also took the floor with the R13 and

12 increased it to R19 in the floor. And we don't have the data as

13 to what the inner gain fact is that because nobody had run that

14 exact analysis.

15 But I would not that from the data Emanuel

16 collected, of a single light it's 76 of $74. For a double-wide

17 it's $125 roughly.

18 It's not a real expensive proposition from Lubby's

19 point of safer to do it than not. In the absence of data, I

20 suggested it may make sense. 

21 That combined package is cheaper than what we had

22 agreed to for the far south the last time, and it's -- I think
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

139

1 the life-cycle cost savings --

2 The energy savings are a little bit lower than what

3 we (inaudible) for life-cycle cost savings were pretty good

4 based on this analysis. The Uo-value is close to maybe slightly

5 lower, actually.

6 So then we looked at -- if you then look at the

7 green zone here, we then, in addition to the -- so we again

8 decrease the ceiling to R22, we then increase the floor, and

9 then we also -- to R19 -- we also increased the wall -- 

10 I'm sorry, this is a decrease. We kept the wall

11 where it was for that zone in the agreed numbers, but it's

12 higher rather than a south, which has a R13 in the wall, but

13 recommended putting R19 -- R21 in the wall. 

14 MR. RAMIREZ: Lowell, hold on one second. Ted,

15 could you bring up that chart? Let me see if this is what

16 you're talking about because there were like three of them that

17 were generated on that day. Is the one that you're referring

18 to? 

19 MR. UNGAR: That's the one that has it in the

20 October 17 proposal that includes the numbers. So I think if

21 you -- yeah. 

22 MR. RAMIREZ: This one right here, is this what
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

140

1 you're referring to? 

2 MR. UNGAR: Yes. 

3 MR. RAMIREZ: Okay. And so the question that we

4 had, though, was for -- I'm sorry. Could you go back to the map

5 that we were just looking at? 

6 MR. HAGERMAN: So would it be helpful if you wrote

7 up the values up here on the board or on this spreadsheet maybe

8 so we could -- 

9 MR. RAMIREZ: Yeah. How does that apply to this

10 right over here? Because if this is what we're talking about

11 potentially adopting. 

12 MR. HAGERMAN: Let me try this. Repeat what I

13 heard. So I think what he's saying is given the analysis that

14 of PNNL life-cycle, they specifically looked at the high costs,

15 little return measures and prescriptive components there in

16 proposing some modifications and prescriptive that make the

17 thing more cost effective, right? 

18 And so he was going through what had changed, right?

19 Now, as he was going through it verbally, it's kind of hard to

20 keep it all, yeah, so maybe if we can modify this chart with

21 what you're talking about, it'd help people understand. 

22 MS. HOFFMAN: Or you could write it up over there on
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

141

1 the chalkboard. 

2 MR. UNGAR: Yeah, I can write it up here. Get the

3 column and table that you had up. 

4 MR. RAMIREZ: Can you bring that table back up, Ted?

5 This one? 

6 MR. UNGAR: Between M and G. 

7 MR. RAMIREZ: Between M and H? 

8 MR. UNGAR: Between F and H. 

9 MR. RAMIREZ: F and H. 

10 MS. HOFFMAN: How do we know if it's a hidden

11 column? Oh, is that the hidden column? 

12 MALE VOICE: It's a secret column. 

13 MR. HAGERMAN: That's just the reference. 

14 MR. RAMIREZ: So what do we need to do here? 

15 MR. UNGAR: I think that may be confusing us and one

16 we haven't been talking about for a while. 

17 MR. RAMIREZ: Okay. Hit UNDO, Ted. 

18 MR. HAGERMAN: I think we're better off -- this is

19 Joe Hagerman. I think we're better off going back to your map. 

20 MS. HOFFMAN: Just putting in the other numbers. 

21 MR. HAGERMAN: You verbally telling -- 

22 MR. RAMIREZ: So, Ted, could you make changes to
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

142

1 this chart? 

2 MS. HOFFMAN: And just walk us through like red in

3 --

4 MALE VOICE: That ceiling would be -- 

5 MS. HOFFMAN: Twenty-two. 

6 MR. UNGAR: We reduced R-value to 22. 

7 MS. HOFFMAN: Okay. 

8 MR. UNGAR: And the floor we increased the R-value

9 to 19. 

10 MR. HAGERMAN: The red floor 19. It's a game of

11 Bingo. 

12 MR. UNGAR: So the green, those numbers are not -- I

13 mean, those numbers as the same as the red. Those are, in fact,

14 what was in the chart that we agreed to in terms of the -- 

15 MR. RAMIREZ: Okay. 

16 MS. HOFFMAN: Okay, so 22. 

17 MR. UNGAR: I don't know we really want to be

18 comparing there, but -- 

19 MS. HOFFMAN: Well, let's just see your proposal. 

20 MR. UNGAR: But I can put it in numbers. Again, for

21 green the ceiling would again be 22. 

22 MR. BARBOUR: Just for everybody's reference, what
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

143

1 was agreed to at the last meeting were the green, which is IECC

2 Zone 3. This was included as part of the discussion. 

3 MALE VOICE: And this was exactly a discussion we

4 had, right, was whether the green zone what be with the orange

5 and the red. 

6 MR. HAGERMAN: Exactly. 

7 MS. HOFFMAN: And your wall was 21, right? 

8 MR. UNGAR: And the wall was 21. 

9 MR. RAMIREZ: On the green? 

10 MS. HOFFMAN: On the green. 

11 MR. RAMIREZ: Green wall 21, Ted. 

12 MR. POTTS: I can't hear. Green wall is what? 

13 MR. RAMIREZ: Twenty-one. 

14 MR. POTTS: Twenty-one. 

15 MR. ROY: So essentially what that's doing, it's

16 walking back in the green zone, which is all in IECC 3. It's

17 walking back the ceiling from 30 to 22. 

18 MALE VOICE: And it's mandating 2 by 4 -- 2 by 6

19 walls. 

20 MR. ROY: That's in IECC 3. 

21 MR. UNGAR: And we agreed to discuss this. This is

22 the straw man. It would be, right. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

144

1 MR. ROY: So we were keen to ditch the ceiling. 

2 MR. UNGAR: So effectively we are trying to again

3 reduce the cost of recognizing and for those climates that would

4 make sense. 

5 MR. HAGERMAN: Joe Hagerman. Do you have any idea

6 what the resulting single section value would be or a double

7 section roughly? 

8 MR. UNGAR: For which zoning? 

9 MR. RAMIREZ: Let's do red first. 

10 MR. UNGAR: So for red zone -- 

11 MR. RAMIREZ: This is red zone single section. 

12 MR. UNGAR: Using Emanuel's method, not PNNL's

13 method, the single is .085, the double is .081.

14 Again, those are lower than the initial -- the cost

15 is actually lower than what we -- than the number -- than the

16 cost of what's black there, right. So it's a lower U value, but

17 it's also a lower cost. 

18 MR. ROY: The floor is more productive than the

19 ceiling. 

20 MR. UNGAR: In terms of U value. Whether it's for

21 energy, we don't quite know, but it's quite likely it was

22 probably. You know, it may not -- it's probably less energy
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

145

1 savings. But that's -- it is what it is, and so that's -- 

2 MR. RAMIREZ: Where are the numbers for the green? 

3 MR. UNGAR: And for green, using Emanuel's method, I

4 believe it's .075 for single, and .073. 

5 MS. HOFFMAN: Point oh 7.

6 MR. UNGAR: And the cost was -- it's in between the

7 old costs for red and orange, but it's closer to the red cost. 

8 MR. RAMIREZ: Ted, we're going to want that. If you

9 could put a .075 on the single for green. There you go. 

10 MR. LEVY: Actually, I've got a slightly different

11 number for the first one. Instead of .085 I actually got .087. 

12 MR. RAMIREZ: For red single? 

13 MR. LEVY: He switched those two things, but he

14 ended up with the same Uo-value. I do get the .081 for the

15 extension, but .087 is what I get for the single section. 

16 MS. HOFFMAN: So should he put .087? 

17 MR. LEVY: I have the doors at .050; that's the

18 difference. 

19 MR. RAMIREZ: On red? Could you put a .050 in

20 parentheses? Thank you. Oh five oh or point? 

21 MR. LEVY: Point 5. 

22 MR. RAMIREZ: Point five, Ted. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

146

1 MS. HOFFMAN: What about the green? 

2 MR. RAMIREZ: Lubby, you had something? 

3 MR. LUBLINER: Well, I can wait until you finish

4 this, but I have a comment about the 22 in the hot zones when

5 the duct work is up there, but I'll hold on that. 

6 MR. RAMIREZ: So how do these numbers look? 

7 I have a question of what the change was in the door

8 U value. It occurred to me when you go from one R-value to

9 another and when you're talking insulation, you're talking about

10 the thickness of the insulation.

11 Did you plug in a different door to get the .50? And

12 what door was that? I don't know why the door U value changed. 

13 MR. LEVY: That came out of IECC. 

14 MR. EZZO: Mark Ezzo. On the solar heat gain

15 coefficient for orange, should be questioned, Mark, as well? 

16 MR. HAGERMAN: Again, I believe everybody deferred

17 to DOE for this solar heat gain coefficient. 

18 MS. HOFFMAN: And did you want it for all zones? 

19 That was just for the southern ones. 

20 MR. RAMIREZ: Yeah. I thought it was originally

21 just for Zone 2. 

22 MR. LEVY: But .025 was the old number, and I don't
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

147

1 think anybody's opposing that. 

2 MR. UNGAR: Point oh 25 in Zone 3, the orange zone? 

3 MR. LEVY: I think we talked about .33. 

4 MR. RAMIREZ: Emanuel. 

5 MR. LEVY: Yeah. So my only comment about the green

6 zone changes that Lowell just mentioned is we specifically

7 looked at the wall of 2113. That change is not cost effective. 

8 So if you took that out, you have exactly the same

9 package between the red and the green zones, except for maybe

10 the door. 

11 MR. BARBOUR: Except for the SHGC, if you don't

12 know. 

13 MR. DENNIS: I have a question from the phone. It's

14 really hard to follow. Are you suggesting that the green zone

15 have a Uo-value of .75? 

16 MR. ROY: We asked DOE to model the numbers, which

17 result in a .075. I don't believe we put that as a proposal. 

18 We wanted to see the numbers and how they turned out,

19 recognizing that it would be a subject of discussion. 

20 MR. DENNIS: Like an analysis for another meeting or

21 have they been doing that? 

22 MR. ROY: They've done it. You did the analysis,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

148

1 didn't you? So you don't have the piece of paper? I sent an

2 E-mail to you, Keith. It wasn't in the document? 

3 MALE VOICE: IECC summary? 

4 MR. ROY: And the reason it was -- this is Robin. 

5 The reason we asked DOE to study it is we thought it was clearly

6 sensible to walk back the ceiling. We thought it might be

7 interesting to take a look at a better floor.

8 But the reason -- we thought it was useful to take a

9 look at. But otherwise short of a proposal was we recognized

10 that there is a first-cost implication with these items. 

11 MR. DENNIS: Is there a life-cycle analysis on this

12 one? 

13 MR. RAMIREZ: What we've just been talking about,

14 yes. 

15 MALE VOICE: Matthew said we forwarded it to you. 

16 MR. RAMIREZ: The working group has it. 

17 MR. DENNIS: I just got it, okay. 

18 MALE VOICE: October 17th. 

19 MR. RAMIREZ: Yeah, October 17 proposal, LLC summary

20 2014. 

21 MR. DENNIS: Okay, thank you. 

22 MR. RAMIREZ: So where do we go from here? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

149

1 MALE VOICE: What are we talking about exactly? 

2 MR. RAMIREZ: What I was looking at was to see if

3 the zone map was alright, and then we wanted to get in -- Mark

4 Ezzo suggested that we put in these numbers so that we could see

5 it all, and Matthew's been kind enough to do that for us real

6 quick.

7 But there are some suggested changes on here, so I

8 guess with them making the changes, and then if so, do we reach

9 consensus on the zone as well as the corresponding numbers? 

10 MS. HOFFMAN: Also, are there any changes in orange

11 and blue, or no, that's set? 

12 MR. RAMIREZ: Those are set already. Manny? 

13 MR. TOMPOS: Dave Tompos. Are we talking about

14 descriptive numbers here or are we trying to change the

15 Uo-values? 

16 MR. SANTANA: That's my point as well. I think

17 we're getting -- 

18 MR. TOMPOS: I really confused as far as what we're

19 doing here. 

20 MR. SANTANA: You know, we started off the

21 discussion after lunch talking about what values for the zones

22 that we just voted on. We've already established that we've
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

150

1 already come to consensus on Zone 4 and Zone 3.

2 So we were just going to discuss Zone 2 and Zone 1,

3 and that transition led to a prescriptive package that includes

4 U values, which would separate the green and the red zones into

5 two distinct zones, which is not what I voted for before lunch.

6 What I voted for before lunch was to include dash

7 lines as a place holder, not to have two separate zones. 

8 MR. ROY: I completely appreciate what you're

9 saying, Manny, and I appreciate what you said before lunch, and

10 I think you were very clear about it.

11 And, again, I'll say again, this is not the proposal

12 that we're making. This is just an analysis that we asked DOE

13 to do to help inform our discussion. 

14 I think it might be useful to just take a look at

15 the red line -- the red zone that we have there and not talk

16 about green for a moment. What we did was not set out to change

17 a Uo-value. What we did was to see if we could come up with a

18 more economic package. 

19 And the happy news is, according to Emanuel's

20 calculation, it ends up with the same U value, but it's much

21 less expensive than the prescriptive measures that we originally

22 agreed to. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

151

1 R30 ceiling, R13 fall, R13 floor. It turned out it

2 is a much lower cost prescriptively but getting to the same U

3 value, so that's kind of nice. And I would hope that we can

4 agree that that's a good outcome for the red zone. And maybe

5 take that one off the table. 

6 Now, to get you -- but before I ask you to do that,

7 your concern, Manny, on the green, whether it's actually green

8 or it's just a different shade of red, -- 

9 MR. SANTANA: Right. 

10 MR. ROY: -- and I understand you don't necessarily

11 want to have two different zones. 

12 One of the reasons it's not a proposal from us is we

13 recognize this is an area of great sensitivity. The first cost,

14 these particular states, and we're really inclined to listen to

15 what might be different. 

16 In fact, including exactly the same numbers, which

17 would in this case mean simply walking back from the -- what

18 looks to be cost effective, wall R21 in the green area.

19 I can imagine walking back from that R13 simply for

20 the purposes of addressing the first cost (inaudible) express. 

21 Then you end up with the same U values and with it, and the only

22 parts that left is the SHGC. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

152

1 MR. DENNIS: Another question because when he put in

2 this analysis for what we had talked about at the last meeting,

3 simply putting those states back in the other zone, which is

4 towards the middle of the country, or the southern zone.

5 The results came out that it was going to be $600

6 up-front cost and the life cycle was actually going to be less

7 savings. 

8 MR. RAMIREZ: All right. So what about the idea,

9 though, I'll lob a suggestion to see if we're okay with the red

10 numbers, and then just focusing on the green and see if the

11 green lined up to be similar to what the red is?

12 But what do you think of that, are those red numbers

13 okay? 

14 MR. ROY: Can I answer Keith's question? Because,

15 Keith, that's exactly what we were thinking about. Well, that's

16 an additional cost in that green part of this map we're not

17 inclined to see imposed on that area.

18 It didn't seem to make sense for the ceiling, for

19 sure. That's why we -- 

20 MR. DENNIS: Well, yeah, I mean, I understand what

21 you're saying. I think at this point it's a bit unfair to be

22 throwing out these new analysis with to life-cycle costs
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

153

1 assessment for different zones and completely really

2 complicating what --

3 I'm not very comfortable with all these numbers that

4 are kind of come up with on the side and put in there right now.

5 That we're just kind of talking about.

6 Okay. There's the same U value, but it's cheaper

7 this time. It just goes to show how bad the models are or how

8 much we're really guessing here. It doesn't show me any level

9 of confidence in what we're doing. 

10 I spent a lot of time with the numbers that were put

11 together based on what we talked about last time, and we're

12 sticking to those numbers for the other zones.

13 And now we're adding all this other stuff and we're

14 supposed to take, you know, kind of you guys' word on it. And

15 that's really concerning to me at this point. When we have, you

16 know, proposals out there that we've been looking at.

17 So I'm really nervous about opening up this window

18 looking at -- now we're just looking at this one zone even

19 though we just kind of voted on a line that would say we're

20 combining the two zones. I don't really know what path we're

21 going down. 

22 MR. RAMIREZ: I don't think that -- these numbers
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

154

1 have been projected. We're just trying to figure out and see if

2 we can agree on what I think it's the -- how you really of the

3 four in the green zone is probably what it's going to come down

4 to.

5 But these numbers have already been give out to

6 folks, and I don't think we're changing any of the costing data,

7 but I'm going to put it to Ishbel real quick and then I see some

8 other hands. We'll go around and get them. 

9 MALE VOICE: Can you speak up, Ishbel, so people can

10 hear you? 

11 MS. DICKENS: I'll point my voice right at the

12 microphone in the ceiling and hope for the best. 

13 I appreciate that everyone has been working on this

14 analysis from different perspectives. And there are a range of

15 numbers, but none of these are new numbers.

16 These are numbers that we've looked at in the past

17 and have data provided to us from several different people in

18 this room. And I like the fact that we're plugging them in now

19 and can do this comparison.

20 If we do lower R-values for ceilings and floors but

21 get to the same overall, you know, U value at the end of the

22 day, which gives us the energy efficiencies that we want with
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

155

1 the cost effectiveness, particularly for the first buyer, that

2 seems to me to be a win, win, win, win, win.

3 And I think it's okay to do it incrementally and

4 piecemeal, if you like, by color because there are some -- you

5 know, we haven't totally agreed on that line. If that line is

6 in there, not in there, how it's going to play out. 

7 But I'd be very comfortable voting on the red with

8 what we have, with the complete understanding that it's all, you

9 know, it's an organic process. We'll be working on it for a

10 long time.

11 It will probably evolve even further when it's

12 implemented, but at some point we've got to say enough is

13 enough. We've got to implement, and I'm kind of there. 

14 MR. RAMIREZ: Well, let me -- I saw some hands, so

15 let's see if we can do some brief comments from Eric, Lowell,

16 Michael, and then Manny. So Eric. 

17 MR. LACEY: Eric from RECA. Just one minor comment.

18 We it give any of you heartburn to make the door U value

19 consistent with all the other zones?

20 It seems kind of like an unnecessary giveaway to go

21 to a .5, and maybe it won't have a huge impact on the Uo. But

22 from a manufacturing standpoint, are you really going to use a
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

156

1 different set of doors in red climates or another?

2 But if you want to have a separate -- a different

3 set of U factors I'd say up in the northern part of the country,

4 crank that U factor down because it's a much bigger gap between

5 the, you know, window U factor and the door U factor.

6 But I think -- I mean, again, it's not a big thing,

7 but it seems silly to crank that up to a .5. I didn't hear that

8 you were -- 

9 MR. TOMPOS: We should make them all .05. 

10 MR. LACEY: Make them all .5? 

11 MR. RAMIREZ: Okay. Let's see, Lowell, Michael, and

12 then Manny. 

13 MR. UNGAR: On doors I would be fine, either with a

14 .4 or with a new set that Emanuel did of varying them by climate

15 zone. I don't know which is better. 

16 On the red zone, I would be okay with either zone or

17 numbers. We are trying to lower the costs, and if you want to

18 refer to the old ones, that's okay, too. 

19 I'm terms of the new numbers, again, Keith, there is

20 a life-cycle cost analysis. I'm not quite sure what you -- 

21 MR. DENNIS: I think it'd be helpful because it's so

22 hard over here on the phone. Is it possible to, like, put up
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

157

1 when we're doing this?

2 Is it also possible to have someone with a

3 spreadsheet that's putting in the same table we've been looking

4 with incremental home costs, energy cost savings, residual total

5 cost of ownership, and then total life-cycle savings like we've

6 been doing for the other options the Emanuel's been putting

7 together? 

8 MR. UNGAR: I think that's what you were just sent. 

9 Matthew just sent that to you. 

10 MR. DENNIS: Can we at least like line up which ones

11 we're talking about so we can figure out -- I can figure out

12 what part of the table we're talking about?

13 So we're talking about the -- what is it for

14 Charleston, for instance? What's the home cost in Charleston

15 for the proposal you're putting? 

16 MR. UNGAR: Are you looking at the life-cycle cost

17 table labeled October 17 proposal? The four added cities in the

18 south are at the bottom of that table. 

19 MR. DENNIS: I got those. 

20 MR. UNGAR: Charleston is, if you go -- if you look

21 below the black line where there are four cities, Charleston is

22 the second city. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

158

1 MR. DENNIS: Right. But how does that Uo-value that

2 you've got not add up to the Uo value you're putting in this

3 chart? 

4 MR. UNGAR: That's the green zone. 

5 MR. DENNIS: On that chart we're looking at, there's

6 two charts. There's one for .087. 

7 MR. RAMIREZ: Yeah. Ted, can you scroll down? 

8 MR. HAGERMAN: So I think he's asking, you're

9 looking at the .087 or the .070 for Charleston. 

10 MR. UNGAR: If we're talking about the new numbers

11 that we put in red on the other chart, that's not this -- it's

12 not these ones. Go up to the chart above it, so this is the

13 life-cycle cost analysis for that proposal.

14 If we're talking about the green zone, it's what's

15 labeled in 3a. It's all those cities at the bottom of the

16 chart. 

17 MR. DENNIS: So that up-front cost is 2855 as

18 opposed to with the .087 it was 2578. 

19 MR. UNGAR: Well, it's not -- that's actually not

20 the incremental cost. That's the ten-year cost. 

21 MALE VOICE: They're all ten-year costs. 

22 MR. UNGAR: The increment -- oh, you have a
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

159

1 different chart. The incremental is 2,657, if you include --

2 that's not the same incremental costs as in Emanuel's charts. 

3 Just to add confusion.

4 PNNL puts more stuff into the incremental costs, so

5 that's kind of the all-in incremental cost is for that zone is

6 2,657. 

7 MR. DENNIS: Now, in your chart, the chart above

8 Emanuel's .087 chart, you're saying you already took out the

9 nine percent? 

10 MR. UNGAR: I'm sorry. I don't understand at all. 

11 MR. DENNIS: Okay. I think I'm closer to

12 understanding what you're talking about. You're saying the

13 numbers that you're putting in red on the spreadsheet that

14 you're dealing with right now are the numbers from the third

15 line from the bottom in the bigger chart on the October 17th

16 sensitivity analysis. 

17 MR. UNGAR: I still don't understand. 

18 MR. HAGERMAN: I think what he's trying to say is,

19 not to -- the things in the sector right now, right, the results

20 are selected right now are derived from running the simulations

21 based on the components in the Uo's that we were just looking

22 at. Because he's particular worried about Charleston. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

160

1 MR. DENNIS: Yeah. You're looking at the October

2 16th, but I think that Lowell is talking about the October 17th,

3 right? 

4 MR. UNGAR: October 17th. 

5 MR. DENNIS: That's the one in the back. 

6 MR. HAGERMAN: Yeah. What's up there right now,

7 October 17th? 

8 MR. UNGAR: So if you're asking about the initial --

9 the total added initial cost, its still differs from Emanuel

10 because this includes sales tax. But in the far right-hand side

11 is the initial cost, including sales tax. 

12 MS. HOFFMAN: Manny, you had a question? 

13 MR. SANTANA: Yeah. You know, I understand what

14 Lowell and Robin are doing, and I understand where we're at. 

15 Oh, this is Manny again. 

16 MS. HOFFMAN: Manny. 

17 MR. SANTANA: I think, again, what we're trying to

18 do, we're working on the prescriptive package at the same time

19 that we're working on the performance value.

20 I think that we really need to try to focus on the

21 performance value. I think we have enough understanding to get

22 that through, and then we can back into the prescriptive table
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

161

1 and then talk about specific walls and floors and all that. 

2 You know, so we're talking about, you know, if we

3 look at the prescriptive package that was presented last

4 meeting, if we look at the values that Lowell and Rob just

5 presented and there, I guess, testimony provided.

6 And if we look at the results from the PNNL analysis

7 as, you know, I think we can -- I think we have enough to vote

8 on a U knot of .087 for both red and green together.

9 That's the last part of that map that we haven't

10 voted on. I think we have enough to -- you know, I guess I

11 think we have enough information. And then we could talk about

12 the prescriptive packages after that's done. 

13 MS. HOFFMAN: Lubby. 

14 MR. LUBLINER: I'm okay. I'm going to hold my nose

15 and say I'm okay with either proposal. But I do think, to get

16 back to where I was, this is a lost opportunity.

17 If you don't fill as much as you can in the attic or

18 the floor, you're never going to fill it again, unless you spent

19 ten times as much on low-income weatherization down the road. 

20 So I know we're trying to help out this first-time

21 affordable buyer, but also there's ramifications of that on the

22 other side.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

162

1 So I would ask, the utilities that do low-income

2 weatherization or DOE that spends hundreds of millions of

3 dollars of low-income weatherization.

4 When you're in one of those zones and you're using

5 DOE money to fill the attic insulation in (inaudible) home, how

6 much insulation do you put in? Do you stop at R22?

7 Keith, in your low-income weatherization programs in

8 your areas, when you blow the insulation into the attic to help

9 these low-income people meet their power bills, how much do you

10 blow in?

11 Do you blow in R22 in your climate or do you bill

12 it? And that's kind of where my concern is. 

13 MR. DENNIS: I completely understand that, Lubby,

14 and I really do sympathize with you. And, you know, if it was

15 up to me, I would say let's make an incremental approach and get

16 there.

17 I just don't trust these models in this system,

18 having seen how it's worked when I've been working on it. I

19 would rather take a bid approach, see how things work, and go

20 further.

21 You know, that's my main concern. Like I just don't

22 trust this process. I don't think it works.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

163

1 So I hear what you're saying. I think that it can

2 be very expensive to retrofit, but I want to be cautious about

3 all this and see how the market responds. I think that we're

4 going to have another chance in three years to go further.

5 I don't want to overdo it because I don't the front

6 page story in the "Washington Post" to say, "Hey, mobile homes

7 are going up by $2500, but over ten years they're going to save

8 on an average $2,000." 

9 Because that's what the proposals say right now, and

10 that's not a good story. I don't think that that's going to be

11 good for anyone.

12 So I see what you're saying, but, you know, I'm

13 cautious to take it all in one bite because I know these things,

14 once they go one way, they don't go back. And I think that we

15 can continue to move forward.

16 But I'd like to see one iteration and see how this

17 works before going. Let's push it all right now. Because when

18 we push it all right now and we push too hard and have

19 unintended consequences, you can't go back.

20 So I hear what you're saying, though. I completely

21 understand. But I feel like to me that doesn't stop me from

22 being cautious on putting raising the minimum standard on people
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

164

1 without, you know, at least testing the waters in some fashion,

2 so. 

3 MR. RAMIREZ: So let's go back to the map then that

4 had the numbers that were changed. Ted, could you do that? 

5 All right. So I think we still went on in a circle

6 here where even if the numbers that we had go into Keith's

7 point, the red numbers are basically what we've been looking at.

8 Is that -- Emanuel, is that accurate? 

9 MR. LEVY: I just want to make the exception being

10 in the green, going back to the 21 versus the 13. The 21 is not

11 cost effective. 

12 MR. RAMIREZ: No, I'm sorry. We're just talking

13 about the red zone. 

14 MR. LEVY: Not the red numbers. 

15 MR. RAMIREZ: No, the red zone. Yeah, the red zone,

16 this whole -- 

17 MR. LEVY: First line? 

18 MR. RAMIREZ: Well, is there any dispute with those

19 numbers? And go to the 22 and the 19. Lowell. 

20 MR. UNGAR: So I was (inaudible) and then whatever

21 the Uo-values, once we figure out exactly what Uo-values match,

22 we use whatever Uo values go with it. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

165

1 Manny was saying, you know, just pick Uo value and

2 then we'll find a prescriptive path to match. If we were going

3 to pick a Uo-value, and Manny's preference is certainly to

4 combine the red and the green zones and pick one -- I think one

5 Uo-value for red and green and single and multi, in which case

6 you're effectively averaging those four numbers.

7 If one took that approach, the difference we're

8 talking -- well, depends on which numbers were doing that.

9 But if you look at what we had agreed to before, by

10 coordinating the green zone along with the red, just using the

11 red values, you're looking at .085 or .086 for the combined

12 Uo-value.

13 With a new October 17 run if you combine them,

14 you're looking at .078, I would guess, eyeballing it as a

15 combined average. That's kind of a range where, you know, so I

16 guess my request is either we take whether we're talking about

17 the prescriptive path or about the Uo-value, and I can see going

18 either direction.

19 And whether we're just trying to do the red

20 separately and then the green zone or whether we're combining

21 them, because that's the only time the request from

22 manufacturers gets either one. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

166

1 MR. RAMIREZ: Well, they might be combined, but I

2 thought that we could possibly get agreement on red, and that's

3 why I was trying to see, you know, if we could do that.

4 And then let's see what green likes. It might be --

5 a lot of it may look the same, but we could take that next. 

6 MR. TOMPOS: Dave Tompos from NTA. We had a chart

7 up that had all the IECC values as U values -- Uo-values. I've

8 got it as a chart that has a version number 2.514. It's an IECC

9 map with revised U values revision C.

10 And it shows that red value we're at .090, and the

11 Zone 1 is a .091. Are we saying that this red, this new red

12 zone that we're talking about we're actually going to do Uo

13 values lower than what we originally had set up? 

14 We've got that .087 when we averaged Zone 1, 2, and

15 3 together. 

16 MR. RAMIREZ: Lowell. 

17 MR. UNGAR: So the revision C is Emanuel's most

18 recent numbers after -- so that's not what we had agreed to

19 before. That's after further -- after Emanuel did further

20 revisions that he talked about earlier this morning. 

21 MR. LEVY: Let me make one clarification to that. 

22 What I looked at was the 30 then at 22 and that was a change I
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

167

1 proposed. What I think Robin or Lowell are suggesting is now

2 increasing the 13 to the 19 in addition to that, because of the

3 relatively low cost of making that change.

4 Now, 13 is what's it IECC, so this is the first case

5 we're looking at an increase over the IECC for a zone.

6 First of all, I don't object to that because we

7 haven't looked specifically at that option to see if it's cost

8 effective or not, but we could.

9 And if it is, then I think there would be

10 justification for taking those numbers up to the, you know, the

11 .087 or the .085 or some other level. I don't know what exactly

12 it is, but just to be clear -- 

13 MR. TOMPOS: Well, I don't object to the 19 in the

14 floor as opposed to the 13, but I don't agree with lowering the

15 Uo-value. If you want to add the 19 for a prescriptive number,

16 that's fine, but I don't know. I think the Uo values are too

17 low the way it is. 

18 MR. HAGERMAN: So can I? 

19 MR. RAMIREZ: Joe. 

20 MR. HAGERMAN: It seems like the reason that Lowell

21 and Robin changed the prescriptive -- I'm just talking the red

22 line, the red zone line here -- numbers is because they realized
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

168

1 that, you know, they were sensitive to the cost problem, right,

2 or the cost opportunity here.

3 So they lowered the ceiling and they increased the

4 floor. Now, that had an impact on lowering the Uo-value of that

5 result, right. But you're really doing that, not really to

6 lower the value, you're really doing that just for the costs,

7 the supportability, right? 

8 So my recommendation or one could consideration a

9 recommendation such that we keep the prescriptive table for the

10 red zone at ceiling 22, wall 13, floor 19, and then you keep the

11 single section Uo-value as .087.

12 Because that's what our previous life-cycle analysis

13 already proved out as cost effective, and we all agreed on it,

14 right? And so that seems like that's the best of both worlds,

15 right?

16 I mean, the affordability group or concerns that are

17 worried about the up-front costs, go the prescriptive route,

18 right? We've seen this is more cost effective, right?

19 And then for the people that want to go the

20 Uo-value, they have assurance of that or the life cycle -- I'm

21 sorry, not the life cycle, but the ten year look is positive,

22 right? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

169

1 So it seems like, again, having different

2 prescriptive and different Uo-values addresses the -- it

3 addresses the affordability concern again. Just like having two

4 sets of values for multi sections and single sections.

5 But I think that's a nice compromise and it's in the

6 spirit of what John said earlier that, you know, it's like what

7 can we live with? I think we can all live with that and we're

8 actually pretty sensitive to affordability. 

9 MR. RAMIREZ: Let me caption to see what it looks

10 like. So you're saying that -- let me caption to we can see

11 what it looks like. 

12 So, Joe, you're saying ceiling at 22, floor 19. 

13 Could you go back to that chart, Ted? 

14 MR. HAGERMAN: It's pretty simple. I think it's --

15 all I'm saying is we would have maybe just strike out -- 

16 MR. RAMIREZ: Yeah, under single section oh in the

17 red. 

18 MR. HAGERMAN: You'd strike out the ceiling 30, so

19 you're left the ceiling 22, so strike out the 30. You're not

20 changing the wall. You're striking out 13 on the floor. 

21 MR. RAMIREZ: What about the door? 

22 MR. HAGERMAN: Well, the door is -- we skip the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

170

1 door. 

2 MR. RAMIREZ: Okay. Now we've really got into the

3 single section. 

4 MR. HAGERMAN: I agree I hadn't thought through the

5 door. So let's strike out the .085 and the .087 on the ceiling.

6

7 MR. RAMIREZ: The parenthesis part. 

8 MR. HAGERMAN: The red and the green under single

9 section, and strike out the red under the multi section. Then

10 I'm phoning a friend for the door, I guess. I need my lifeline

11 here. 

12 MR. LEVY: Well, if you make the door 5, .5 then

13 your Uo-value and your package line up. 

14 MALE VOICE: Well, making that 5 makes, you know,

15 orange and blue 35 and 32. 

16 MR. RAMIREZ: Right. 

17 MR. HAGERMAN: Joe Hagerman again. So I think just

18 out of principal about just doors in general. I have nothing

19 against the door people or doors in general. But I think just

20 for the nature here, if we strike out the .5, that's the most

21 equitable way to do the doors. 

22 Because if we start charging doors here, I think we
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

171

1 should revisit doors in all the zones, and I'm not ready to do

2 that. 

3 MR. RAMIREZ: Lowell. 

4 MR. UNGAR: I'm a little concerned about getting

5 into the details of the prescriptive packages, I guess, and

6 modifying them in total.

7 I still am hearing a strong sentiment to combining

8 the -- at least for the Uo to eventually end up with this same

9 number for red and green.

10 And I guess, you know, if we come up with

11 prescriptive packages that are different for red and green and

12 the combine them, we've gone to a lot of that work for now --

13 that we're going to actually change anyway. 

14 And I guess we can do that, but if we're really get

15 into in the end, if red and green are close enough that we want

16 to combine them, then I guess I would say perhaps we should

17 revisit the Mannyism again.

18 Use the O values in which case I would say we mash

19 them and compromise on the Uo-value and them I don't know what

20 the prescriptive package would be. 

21 MR. RAMIREZ: Michael. 

22 MR. LUBLINER: Just the thing about going from doing
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

172

1 without R30 for R22, I'm okay with.

2 But I am concerned that -- and may be the industry

3 can educate me -- that there are a lot of systems, particularly

4 in that part of the country that put the ducts up in the attic

5 not in the floor., and you only assume the modeling in the

6 floor. 

7 And that's been having huge energy savings that you

8 haven't modeled yet. So I have some concerns. And maybe one

9 suggestion would be is to make an exception. If ducts are in

10 the attic, it's R30. That would give the manufacturers on

11 single-section homes some opportunities to innovate and not have

12 to do R30 and move the ducts inside or rather the attic.

13 That's one that I think is kind of hurting me a

14 little bit because I really know those ducts, it's 160 degrees,

15 it's a peak load, summertime day, and you've got six inches of

16 insulation that isn't even covering the ducts. You put R30, at

17 least you've got some coverage.

18 The other thing is, radiant heating. You know,

19 nighttime cooling and things like that, we're not requiring any

20 kind of radiant variants or anything.

21 So I just think that going down to 22, it's below

22 general practice, and I don't know that our model is adequately
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

173

1 addressed for that scenario. So that's my only concern there. 

2 And the other question I have -- 

3 MR. TOMPOS: Didn't we decide that if the ducts go

4 in the floor, they don't have to be insulated. If they're in

5 the attic, they're going to have to be insulated. 

6 MR. LUBLINER: Yeah, but they're only going to be

7 insulated R38, and its 160 degrees. And my point, David, is

8 that that has not been modeled. We can argue over what the

9 modeling is.

10 But we're making an assumption here that we're going

11 from R30 to R22 in the ceiling, and I'm saying I'm okay with

12 that because the ducts are in the floor. But I'd like to see

13 what the ramifications are on energy if they're not.

14 And I also think it's an innovation if we do make it

15 harder -- a higher R-value for the ceiling when the ducts are in

16 the attic. It provides incentive to the manufacturers to move

17 the ducts out of the attic and get some stairs.

18 I would point out that our experience -- like, Wade,

19 I don't know if you're on the phone. But we do the single wide

20 with you guys at FSEC where we drop the duct down in the middle

21 for the single that was totally out of the attic.

22 The cost for doing that were comparable to the cost
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

174

1 of what has been proposed here to go from R30 to R38. I mean,

2 so you're talking about 600 bucks. You could move the ducts in

3 a single wide in the conditioned space, and we're talking about

4 saving 600 bucks.

5 So I guess I have some concern about just that

6 scenario, and I would suggest if it's possible, if you can, and

7 I understand you've got a lot of analysis to do.

8 But if the industry says we don't have a lot of

9 ducts in the attics in that part of the country, then I would

10 shut up. 

11 MR. RAMIREZ: All right. Ted's been doing a

12 fantastic job trying to keep up with all this on the chart here.

13 He has to take off, which means that it's going to switch over

14 to me. But all these documents are opened up on his computer. 

15 So we're going to take a little break so that he

16 could switch them over. But before we do, where are we at on

17 this? I mean, are we -- 

18 MR. HAGERMAN: Can we take a temperature vote? 

19 MR. RAMIREZ: Yeah. Are we close on at least the

20 red one, right? Because, again, orange and blue are done. Red

21 .219 it looks like door 40, and then .087 and .084. 

22 MS. STARKEY: Just a point of clarification. On
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

175

1 Zone 3 what did we decide on the SHGC? Because the IRC is a

2 .04, which I guess equals a .33, and we have it as .25. 

3 MR. RAMIREZ: Eric. 

4 MR. LACEY: Let me maybe add something here. It's

5 true that part of the orange zone is part of Zone 4 IECC, which

6 should be a .4. But a big chuck of it is Climate Zone 3, which

7 is a .25. And so there are couple of ways of cutting this up.

8 You know, either you could take the, you know, what

9 I would consider the safe, conservative route and go with the

10 .25 and kind of future proof it because of rising electricity

11 costs and so on.

12 You could take kind of the highest SHGC approach and

13 average it all to .4, or you could do some kind of a blend of

14 the two. 

15 I was going through and looking at the jurisdictions

16 that are wrapped up in that climate zone, and the lion's share

17 of them are enforcing something between a .25 and a .30, and

18 there are a few in there that aren't -- that don't have

19 residential energy codes.

20 Most of them are in the, you know, like all of

21 California is .25, a good chunk of Texas jurisdictions are in

22 the .25, a good chunk of Arizona are enforcing a .25.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

176

1 Then there are a number of -- including the Gulf

2 States -- a number of other states in there that are at .30. 

3 And the very, very top is either a .40 or they don't enforce

4 one.

5 So it's a challenge, you know, when you start

6 combining these to come up with, you know, what is the

7 appropriate SHGC? 

8 So, I mean, while I would prefer to see a .25, you

9 could put a .30 in there and it would be consistent with most of

10 the states in there and their energy codes, or some blend of the

11 different values. 

12 MR. HAGERMAN: And this problem is -- this is Joe

13 Hagerman. This problem is consistent with the problem that

14 we're going to be wrestling with in the zone -- the green zone

15 with the three question marks.

16 So, I mean, if you want to group the orange zone

17 solely being coefficient and replace the .25 there with three

18 question marks, I think that's the most -- the fairest way to do

19 it. 

20 Because everything Eric said -- 

21 MR. RAMIREZ: On the orange, Ted. 

22 MR. HAGERMAN: -- there's a lot of different
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

177

1 considerations you have to put up with, and we've got to get the

2 model right for solar heat gain coefficient, right, to know what

3 that value should be, right? 

4 MR. LACEY: Yeah, I'd be happy to share my lists. 

5 MR. HAGERMAN: I think if you want, you know, if we

6 move that three question marks there. 

7 MR. RAMIREZ: Orange, Ted.

8 MR. TOMPOS: Where are we putting the question

9 marks? 

10 MR. RAMIREZ: SHGC orange. 

11 MR. HAGERMAN: I mean, can we get a vote on that

12 real quick? That should be a pretty easy vote, right. 

13 MR. SANTANA: Remember we said that the SHGC was

14 going to be subject to further analysis? 

15 MR. RAMIREZ: Well, that's what we're saying, but we

16 were originally thinking there was just Climate Zone 2, which is

17 the green. But now we're saying because of this discussion that

18 we're having, also deferred for Climate Zone 3 to DOE.

19 Is everyone okay with that? Let me see a show of

20 thumbs if you're okay with SHGC Climate Zone 3 switching those

21 to question marks and let DOE to further analysis on that piece.

22
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

178

1 Okay, one thumb down with Mark. Anyone else online

2 with the thumb down? 

3 All right. Now, going back to the red, though. 

4 Let's see a show of thumbs for the red zone, and then if we get

5 this one done, then we'll move onto green after the break. 

6 MR. UNGAR: Lubby just made a proposal that I

7 thought was interesting that should defend where the duct is. 

8 MS. HOFFMAN: Yeah. He suggested an amendment of a

9 footnote. 

10 MR. RAMIREZ: A footnote for the ducts are in the

11 ceiling then there has to be a higher R-value in the ceiling? 

12 MS. HOFFMAN: If the ducts are in the attic. 

13 MR. LUBLINER: For R30 say exception to no ducts or

14 ducts in floor, and then for that you do R22. 

15 MS. HOFFMAN: You want to ask the manufacturers -- 

16 MR. EZZO: Mark Ezzo. 

17 MS. HOFFMAN: -- Mark Ezzo. 

18 MR. EZZO: This is Mark. 

19 MS. HOFFMAN: Just a second, Bert. 

20 MR. RAMIREZ: Go ahead, Mark. 

21 MR. EZZO: I agree with what you're saying because

22 you're right, in the south there are a lot of overhead ducts. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

179

1 But in lieu of what you're saying, instead of having the option,

2 having one more variable in this, my suggestion would be just go

3 back to the numbers in black. 

4 MALE VOICE: Very good. That solves it. 

5 MR. LEVY: How about if you have overhead ducts

6 you're required to use R30, if you don't, you're not. Then you

7 just need to use of or the red package. 

8 MR. HAGERMAN: So you would just be -- Joe Hagerman

9 here. You'd put the footnote under the red row ceiling where

10 22's listed, you'd put a footnote one there. That says where

11 the -- 

12 MR. LEVY: No. I'd just say for compliance in Zone

13 1, if the ducts are overhead, you're required to have on less

14 than R30 units of insulation. That's what Mike said. 

15 MR. HAGERMAN: That's what Mike says. That's what

16 the footnote says. 

17 MR. EZZO: And I said the opposite. I said my

18 preference would be go back to 30 and 13 in the floor. The way

19 it was originally. 

20 MR. LEVY: You and I are saying the same thing. I'm

21 just saying it would be a descriptive requirement. You could

22 still meet the requirement.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

180

1 You could still use Uo-value to get there, which

2 would get you to R13 in the floor. Or you could use it as a

3 package. You had two packages. 

4 MR. RAMIREZ: Manny. 

5 MR. SANTANA: Yeah, I think this -- Manny again. I

6 think this just highlights the need to talk about prescriptive

7 and performance separately, because we're going to have a lot of

8 footnotes that we need to qualify for the prescriptive package. 

9 FEMALE VOICE: I agree. 

10 MR. DENNIS: This is Keith on the phone. I agree

11 with Manny. I don't know why we're not voting on the numbers on

12 the map. Because it sounds to me like we have an analysis from

13 Emanuel that was dealing with what we talked about last time,

14 which was the .087/.084.

15 People are saying that there's an easier way to get

16 there, so we could use -- you know, Emanuel's is kind of a

17 floor. That's the one that I -- you know, I took that in good

18 faith is what we were talking about.

19 And it sounds like we might have an agreement from

20 both zones. If we did that, it seems to be it'd be easier to

21 get to. 

22 MR. RAMIREZ: Mark. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

181

1 MR. EZZO: Can we vote on the Uo numbers in black

2 for all the zones? 

3 MR. RAMIREZ: So are we talking about the two right

4 columns? I'm sorry, you said the prescriptive or the Uo? 

5 MS. HOFFMAN: No, not prescriptive. 

6 MR. EZZO: Uo. 

7 MR. RAMIREZ: Uo, so the two right columns. 

8 MR. EZZO: I'm was kind of going back to what Manny

9 said. Let's get that one done and then onto prescriptive. 

10 MR. RAMIREZ: So then are we talking about the Uo

11 numbers in black? 

12 MR. EZZO: Yes. 

13 MR. RAMIREZ: Okay, Lois. 

14 MS. STARKEY: Then I'd like to just -- I E-mailed

15 you a graph. I'd just like to show just for one last time on

16 affordability as we vote on these U values. 

17 MR. RAMIREZ: Pull that up, Ted. 

18 MS. STARKEY: Yeah, I just sent it. I think

19 everybody knows that this is a sensitive region of the country,

20 and so we looked at just 500 homes -- just under 500 homes

21 shipped to these states in the southern zones.

22 And we showed that if you look across the bottom,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

182

1 those are the prices of the homes, the price points of the homes

2 that were sold between January and June of 2014 in those

3 southern states.

4 And if you look at the line, the line there that

5 says 10 percent increase, 13 percent of homes.

6 So 13 percent of all those homes are going to see a

7 10 percent increase if we go, you know, depending on what we do.

8 Ninety-nine percent of the homes will see a five percent

9 increase.

10 And so I thought this was a pretty interesting chart

11 to see. It's only, you know, 500 homes, but I think it's a good

12 way visually to show, you know, that 13 percent of those homes

13 are going to see a, you know, minimum of a 10 percent increase

14 by virtue of what we do. 

15 MR. HAGERMAN: This is Joe Hagerman. Doesn't that

16 also show that 87 percent of the homes is going to have less

17 than a 10 percent increase? 

18 MS. STARKEY: Yeah, 99 percent are going to have a 5

19 percent, yeah. 

20 MR. RAMIREZ: Okay. So then with the Uo's on the

21 right side, I'll talk about the black numbers.

22 Ted, could you just scroll the map down a little
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

183

1 bit? And if you could lower the chart that is on the left side?

2 Okay, so -- yeah, I can't control that. 

3 So we're talking about .87 for the red zone on

4 single, .84 on the multi section. 

5 MS. HOFFMAN: Point 084.

6 MR. RAMIREZ: Point 084. Green, .087, multi section

7 .084, orange -- well, orange and blue are already done, right? 

8 So the .070 for the single, .068 for the multi, .059 for the

9 blue single, and .056 for the blue multi section. 

10 Let's see a show of thumbs for those Uo values for

11 the ones okay with those numbers. 

12 MR. HAGERMAN: Say again, sorry. 

13 MR. RAMIREZ: We're talking about the Uo-values for

14 the different zones, if those are okay. The black numbers. 

15 MR. TOMPOS: Dave Tompos. My thumb is down. 

16 MR. RAMIREZ: Okay. And Mark Weiss is down. Anyone

17 else? Mark, you want to make a comment? 

18 MR. WEISS: Yeah, just an addition to the cost

19 information issues that I've cited previously. This is probably

20 a good time to mention it. 

21 You know, we've got some input from our members. 

22 It's not as refined as the numbers that we've been getting
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

184

1 previously in terms of targeting the specific zones, specific

2 areas.

3 But the cost information we're getting is that the

4 cost impacts to the consumer are actually, from our folks,

5 roughly double the numbers that we're seeing here ranging from

6 4,000 for single wides up to 6,000-plus for double wides.

7 That spoke primarily on northern areas, but that's

8 some of the input is that the cost impact will be greater,

9 particularly with respect to smaller manufacturers that don't

10 necessarily get the volume supply rates, discounts that large

11 manufacturers do. 

12 MR. RAMIREZ: Okay. 

13 MR. DENNIS: This is Keith Dennis. And I have my

14 thumb sideways. And, you know, this is a really -- I mentioned

15 this to some other people. This is a really tough number for

16 us, and I would, you know, I'd be more comfortable with a --

17 And just adding to Lois's point, when we talk to our

18 members about this stuff, those people who have those ten

19 percent increases are some people who can't really even afford

20 their bills and go on the prepay and end up using less energy. 

21 And it makes this investment even less cost effective for them. 

22 And so this minimum standard is designed to protect
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

185

1 people and I guess help make decisions for them if they can't

2 make them themselves.

3 But I caution that, you know, this is really close

4 to making me uncomfortable that we're even making a good

5 decision for these people in terms of quality of life.

6 And, you know, this whole -- this makes me very

7 nervous. I think we're pushing the limits on what we should be

8 doing here. But I think in the spirit of consensus what can we

9 live with that we have to go with this because I think

10 everyone's put a lot of work in.

11 But I'm a very uncomfortable sideways vote on it,

12 given the feedback from my membership. 

13 MR. RAMIREZ: Lois. 

14 MS. STARKEY: Yes. I want clarifications. I

15 thought we were just talking about one number. Are we now

16 talking about two? One for single and one for double? Didn't

17 we agree to that last time or I thought we were just -- 

18 MR. TOMPOS: That's why my thumbs down. This is

19 Dave Tompos. And I don't think we've agreed on any of these

20 just for that reason. I don't think we need two numbers for

21 both sections.

22 In the single compared to the multi wide, you're
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

186

1 talking about a .003, and in my opinion we should use all the

2 single section U values. So the friendly amendment would be to

3 get rid of the last column. 

4 MR. RAMIREZ: Michael, you had something?

5 MR. LUBLINER: I don't see that as a friendly

6 amendment, but that wasn't my comment. 

7 MR. TOMPOS: My next friendly amendment is to make

8 it a point .090 because I agree with Keith, the numbers are not

9 affordable. I don't think looking at saving a home owner, you

10 know, 12,000 bucks over 30 years means it's affordable.

11 So take what you want. I either say we go to a .090

12 or you just take the single section number. 

13 MR. RAMIREZ: Michael. 

14 MR. LUBLINER: I thought I heard that the

15 affordability issue was really a single-section, predominately a

16 single-section issue, but maybe I'm wrong.

17 You know, I think that we've really tried our best

18 to compromise here and come to consensus. 

19 I'm a little concerned about issues being raised

20 about costs now at the last minute by Mark there claiming to be

21 twice. Because, you know, Mark, I could go the other way. I

22 could say, hey, we've got 150,000 homes built in the region to
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

187

1 these standards. 

2 MR. RAMIREZ: Let me jump in, though, because I

3 think Mark's record has been -- Mark's comments have been noted.

4 But I want to go more to the question of the single

5 versus the multi, right. Are we talking about one number? 

6 Because what you all approved, though, was a single and a multi.

7

8 MR. LEVY: Can we take a vote on just whether they

9 should be a single? 

10 MR. RAMIREZ: Let's look at that. I mean, well,

11 before we do, actually, what's the issue with it? I mean, is

12 there an issue if it was all single? Ishbel. 

13 MS. DICKENS: This is Ishbel with NMHOA. I just

14 want to ask sort of a process question. It seemed to be that we

15 had a vote and that only two people voted no, so therefore don't

16 we have an agreement on that? And therefore why are we going

17 back and discussing one or two numbers? 

18 MS. HOFFMAN: The only problem, Ishbel, it sounds

19 like -- is it working? 

20 MR. TOMPOS: I can't hear any over you. 

21 MS. HOFFMAN: Oh, okay. The only problem, and I

22 hear you, for process is it sounds like some of our members
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

188

1 weren't sure what they were exactly voting on.

2 Like, just, you know, we have to vote so that we

3 know that everyone, at least when they're voting, are agreeing

4 on what it was. So I think in that respect it's worth

5 revisiting to make sure. Is it a single number or is it both? 

6 MR. HAGERMAN: This is Joe Hagerman. We talked

7 about the single section and multi section before.

8 We left it at two columns because we thought giving

9 the single section, which you've all said is where affordability

10 problems lie, a less stringent U value helps, right? It makes

11 it more affordable, right? 

12 Now, we're saying, well, you know what, we have

13 affordability problems with the multi section, too. All right. 

14 We get to the prescriptive, we have affordability problems. 

15 It's like, listen. I mean, we're trying to be

16 accommodating for the affordability question, but it doesn't

17 need to affect everything that we do here, right? 

18 I mean, if that's the case, then, thanks. I've got

19 enough data here and I can talk to the secretary when the term

20 sheet gets made and say, "Listen, it's just watered down for

21 national efficiency."

22 Because it allows the people that can buy it to not
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

189

1 get the most energy efficient home they could possibly get,

2 right? So, I mean, -- 

3 MR. TOMPOS: No, I disagree with that, Joe. They

4 can buy whatever they want. 

5 MR. HAGERMAN: Hold on, hold on, hold on. So I just

6 want to be cautious after using the same affordability to kind

7 of like come back and re kind of decide things that we've kind

8 of already had consensus on. 

9 Like, if everything's back on the negotiation table,

10 I'm like, like what Lubby said a second ago, we're at the

11 second-to-last day here, right.

12 We're going to start the negotiation process all

13 from the start again, then, you know, thanks. I don't think

14 it's going to be productive, right? And I don't think that you

15 were in here in good faith to begin with, maybe, right? So

16 that's my concern here by kind of revisiting all these tables,

17 okay? 

18 MR. RAMIREZ: All right. So to Ishbel's point of,

19 you know, we did take a vote where it was the two of them. The

20 reason I wanted to look at the two was to see, first of all,

21 make sure that everyone understood.

22 But also to see if there's a way that we could also
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

190

1 any time strengthen a consensus vote, why not take a shot at

2 trying to strengthen it, right? 

3 And we had the two no votes. We had Mark and David

4 that voted no on that. 

5 MR. RAMIREZ: And Manny. 

6 MR. EZZO: Mark Ezzo. 

7 MR. RAMIREZ: Yeah, Mark. 

8 MR. EZZO: Then why can't we take, Manny, what you

9 think and what Dave thinks and what Mark thinks and put that on

10 the table and we vote on that?

11 I think what Dave suggested was, instead of having a

12 separate number for single and multi, use one number and based

13 it on the single section. So, Dave Tompos, it's my suggestion

14 to you is, call for a vote on that. 

15 MR. TOMPOS: And can I make one comment on that? 

16 The only reason I'm doing it is for simplicity. I'm going to

17 ask one question. It had to do more with compliance.

18 But what is the total section with a tag unit? 

19 Which column do I use? 

20 MALE VOICE: Use the multi section. It's got two

21 sections. 

22 MALE VOICE: We'll let Mandolin figure that one out.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

191

1

2 MR. TOMPOS: I'm just doing it for simplicity, and I

3 think it'd be easier to have one column. But I guess I'll vote

4 whatever way you guys want to. 

5 MR. RAMIREZ: Let's gauge the level of consensus for

6 just the single column of the black numbers, right, .087, and

7 .087. 

8 MR. UNGAR: The single home being the single

9 section? 

10 MR. RAMIREZ: Yeah, single, .087, .087, .070, and

11 .059. So just the single column to cover all sections. 

12 MR. UNGAR: At the single-section levels. 

13 MR. RAMIREZ: At the single-section levels. Let's

14 see a show of thumbs. 

15 MS. HOFFMAN: We'll get a 99 percent consensus here.

16

17 MALE VOICE: Good luck with that. 

18 MR. RAMIREZ: We've got one, two, three, four, five,

19 six, seven. Any other thumbs down online? 

20 MALE VOICE: We've got one more here. 

21 MR. RAMIREZ: Oh, Ishbel. So, again, it looks like

22 there's a stronger area of consensus here, the two sections with
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

192

1 black numbers. 

2 MR. LEVY: Can we just call for one more vote

3 because we had two things here. Can we just agree that we're

4 just going to have one value for both single and multi? 

5 MR. RAMIREZ: That's what we just -- 

6 MR. LEVY: No, we were voting on whether it would be

7 the single section. 

8 MS. HOFFMAN: Oh, I see. You want one. 

9 MR. RAMIREZ: We'll do the question again, but we're

10 talking about the single section and that we use one number for

11 all of them. 

12 MR. LEVY: I just want to make sure we'll all in

13 agreement that we're going to have one number regardless of

14 whether it's that column, that column, or some average between. 

15 MR. RAMIREZ: Okay, so that's a different one. 

16 MR. LEVY: We need to do that first, because then we

17 can decide whether it's the single, the multi, or the average. 

18 Those are the three options.

19 MR. LUTER: Rob with Lipper. What I believe is

20 being proposed is there be one column that simply be captioned

21 Uo. So reference to numbered sections, analyzed across the

22 board. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

193

1 MR. EZZO: And a space on single-section homes. 

2 MS. HOFFMAN: No. 

3 MR. RAMIREZ: Yeah, that's what we did vote on, and

4 there was eight no votes. And so now you're talking about an

5 average number. 

6 MR. LEVY: My motion is that every zone, however

7 many zones, have one number. 

8 MALE VOICE: But you're not saying which number? 

9 MR. LEVY: I'm not saying what number it is. Just

10 let's make sure we're in agreement on that. 

11 MALE VOICE: One column. 

12 MR. RAMIREZ: Lowell. 

13 MR. UNGAR: We did discuss this before, and I don't

14 remember whether we took a vote at that meeting. 

15 MS. HOFFMAN: We didn't. 

16 MR. UNGAR: We never took a vote on the question at

17 the last meeting. Okay, thanks. 

18 MR. SANTANA: We took a vote and we agreed on two

19 separate. We're okay. 

20 MR. RAMIREZ: Yeah, I thought we did also, and that

21 was the chart that was up there before, which had the two

22 numbers. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

194

1 So single -- we don't know what the number is. 

2 MR. BARBOUR: This is Ed Barbour now. I have the

3 vote that happened to do two, and it was done by the IECC

4 Climate Zones at the time recognizing that they were going to do

5 the climate, 19 yes, 1 no. 

6 MR. UNGAR: Was that the full chart or was that

7 specifically on the question of whether to have two? 

8 MR. BARBOUR: It was a vote on the full chart with

9 two in it. 

10 MR. UNGAR: But, like, essentially we're not

11 agreeing that we would have eight zones in the end. We were

12 agreeing to those, so that would be the basis -- 

13 MR. BARBOUR: What you voted on was the U values

14 associated with specifically four zones, even though it was not

15 that. That's what you voted on. 

16 MR. LEVY: I don't agree with that interpretation. 

17 And I think we should take another vote right now that

18 supersedes the last vote. 

19 MR. RAMIREZ: Michael. 

20 MR. LUBLINER: Before we vote, I want to get a

21 better understanding from the industry about how complicated and

22 what are the costs to industry when you have two Uo's, one for
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

195

1 single and double. Is it kind of a gauge cost engineering that

2 they've got to update things?

3 Is there a significant cost? And if there is, my

4 personal feeling is stay with the two, but acknowledge that

5 additional cost is transitional cost associated with the code

6 change. 

7 MR. RAMIREZ: Mark. 

8 MR. EZZO: Mark Ezzo.

9 MR. KESSLER: I'm Bert. 

10 MR. RAMIREZ: Go ahead, Bert. 

11 MR. KESSLER: Well, I, you know, I ran a couple

12 samples, and I don't know how you can control a .003 difference

13 in the Uo with anything.

14 I mean, you can out R11, R19, of R21 in the wall,

15 and that's it. You know, you can put a certain amount of

16 R-value in the floor, and that's it. 

17 About the only way I see you could even control that

18 is perhaps with varying R values in the ceiling because we're

19 using blowing. To that end, I think most manufacturers have a

20 standard insulation package that they apply across the board. 

21 And, you know, it's not model specific.

22 So I think having two sets of U values is a waste of
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

196

1 time and just adds to the confusion. 

2 MR. UNGAR: Can I ask a question on that? This is

3 Lowell Ungar. When we do the -- when we calculate the

4 Uo-values, the reason we have two values here is because we use

5 the same prescriptive packages.

6 And when we calculate the Uo-value for a single

7 section and for a multi section we get different numbers. So

8 what you're saying to me argues that if you have set

9 prescriptive packages that it should be easier for you to have

10 two different Uo-values.

11 Because then you can use the same prescriptive

12 package for a single section and as for a double section without

13 coming up with something different in order to meet exactly the

14 same Uo-value. 

15 And I just don't quite understand why you want the

16 same numbers (inaudible). 

17 MR. KESSLER: Well, my point about that is that if

18 we're talking about a prescriptive package then there shouldn't

19 be a need for a Uo-value.

20 If it's prescriptive, you can use it and whatever

21 prescriptive requirements we have for a particular zone makes

22 the home comply. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

197

1 MR. UNGAR: But if you're trying to hit the same

2 Uo-value for single and you have a single section and a multi

3 section designed very similar, don't you have to do something

4 different in order to hit the Uo-value? 

5 MR. KESSLER: Well, yeah. 

6 MR. TOMPOS: Dave Tompos. That doesn't make a

7 difference. 

8 MR. RAMIREZ: Let me get Eric and Manny. 

9 MR. LEVY: This is Eric from RECA. I guess I have

10 my thumbs down more in a philosophical way than anything. And

11 that's because, you know, what we're looking at here in fighting

12 over this .003, all of these assumptions are based on 12 percent

13 glazing area.

14 If you put 13 percent glazing area and using these

15 same prescriptive values, I imagine you're Uo would jump up to

16 where you would fail. If you put in 11 and a half percent you'd

17 probably meet both the single section and multi section, you

18 know, regardless of which number you use.

19 And so I tend to agree, you know, with the comments

20 that are made about, well, .003 isn't as big a deal. 

21 Philosophically where I come down on this is, the prescriptive

22 table has already been weakened considerably as compared to the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

198

1 IECC.

2 And then from that we derived a Uo. And now we're

3 looking at two different Uo's and picking the least efficient of

4 those two. I feel like we're kind of nickel and diming energy

5 efficiency.

6 And so I understand it would be a lot simpler to

7 have one set of numbers, but when we ran through this the last

8 time, we had some people that wanted the slightly more stringent

9 and some that wanted the slightly less stringent set of numbers.

10 In reality, you know, I think Bert's right. You

11 know, it's hard to hit exactly right on the Uo number down to

12 the third decimal point.

13 And so I'd be fine with some kind of average or some

14 single number, but I hate to just categorically take, you know,

15 the least efficient of a prescriptive path that's already been

16 watered down and so on.

17 And so that's why I have my thumbs down. Not

18 because I'm completely opposed to one specific number or the

19 other. 

20 MR. TOMPOS: Dave Tompos from NTA. I want to remind

21 everybody that we're still 30-some percent or better than what

22 we're doing today. That's less stringent of anything.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

199

1 We have Americans that can afford these homes

2 because that's who they're for. They're for the low-income

3 Americans. 

4 MR. RAMIREZ: Let me see a -- 

5 MR. TOMPOS: Buy whatever they want. They can buy

6 those houses. They can put solar on their houses. That's not

7 who these homes are for.

8 Michael Lubliner said that that's what's happening

9 up in the Pacific Northwest, but how much did the government

10 give the Pacific Northwest to make that happen? 

11 MR. RAMIREZ: Well, let me call a vote on this so

12 that way would could see exactly where we're at and hopefully

13 move on. 

14 The one number -- we're not saying which one or what

15 the number is. One number. Let's see a show of thumbs. 

16 MR. HAGERMAN: For Uo. 

17 MR. RAMIREZ: For Uo. One number for Uo. 

18 MR. HAGERMAN: So -- Joe Hagerman -- I'm voting yes,

19 but at the same time I'm going to tell you that I'm going to

20 make that number as aggressive as we can because I feel by going

21 with one number there means that we're going to deal with

22 affordability concerns in prescriptive side.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

200

1 And you're all happy with that. So I'm for one

2 number, but now you know how I'm going to vote as we go through

3 all the Uo selections. 

4 MR. RAMIREZ: All right. Let's see a show of

5 thumbs. All right, are there any thumbs down online?

6 MALE VOICE: You can't see me, but I've got two

7 thumbs up. 

8 MR. RAMIREZ: Okay, we'll count one of them. 

9 MR. WADE: If the number is going to be low, then

10 I've got a thumbs down. Michael Wade. 

11 MR. RAMIREZ: So, Mark, where is your thumb, Mark? 

12 MR. WEISS: Well, you know, if you're not using a

13 number, -- 

14 MR. RAMIREZ: Well, that's going to be the next

15 step. 

16 MR. WEISS: Just for consistency, I'll vote no. 

17 MR. RAMIREZ: Okay. Mark remains consistent. 

18 Mark's remaining consistent, okay. 

19 MS. HOFFMAN: Okay. So the thumbs win. Okay,

20 Manny. 

21 MR. SANTANA: I didn't get a change to answer Mike

22 on his previous statement. And only because I voted up for the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

201

1 one value, doesn't mean that I wouldn't have voted up for two

2 values. As I'm sure I remember, we voted up for two values

3 before. 

4 And to answer Mike's question as far as how much is

5 it going to cost, I don't know that it's going to cost anything

6 to have a single-wide section U value and a multi-wide section U

7 value because homes are going to have to get calculated anyway.

8 You know, so what you calculate for single -- I

9 don't see how. But first I'd say I don't know, right.

10 But I don't think it's going to have much of an

11 impact, if any, because you have to add the U values for the

12 home you're going to build, and those are inputted for the home

13 that you built. It doesn't matter if it's a single, you got

14 those. If you got a double, you got those.

15 And so we voted for a single number and that passed.

16 You know, I'd be interested to see how we vote for two values

17 because especially considering that if you have a single number,

18 it's going to be as aggressive as we can get. 

19 You know, we had the numbers all on the screen for

20 what two zones would be, so there would be less arguing there. 

21 So based off of that, I'd prefer to have two. 

22 MR. RAMIREZ: So let's take a break because Ted
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

202

1 needs to go, and I need a few minutes to try to transition all

2 the documents over. Okay, and then we'll start with Michael

3 when we get back. 

4 MS. HOFFMAN: So come back in ten minutes. 

5 MR. LUBLINER: Well, I'm not going to comment in ten

6 minutes. 

7 MR. RAMIREZ: Go ahead, go ahead. 

8 MS. HOFFMAN: All right. 

9 MR. LUBLINER: So I just want to tell Dave, since

10 you brought my name up, we need to talk about your issues over a

11 beer and just correct that the Pacific northwest utility gray

12 hairs pay for the conservation programs, not the federal

13 government.

14 We could talk about that over a beer. And our

15 program has resulted in less power plants, which keep the rates

16 down for everybody. Thank you. 

17 MR. RAMIREZ: Okay. David, Michael owes you a beer

18 to discuss this. Okay. Ten minutes. 

19 MR. TOMPOS: At least one. 

20 (Whereupon, there was a brief recess.)

21 MR. RAMIREZ: Folks online, can you hear me?

22 (No response.) 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

203

1 MR. RAMIREZ: Can anyone on line just give a quick comment

2 you can hear us?

3 PARTICIPANT: I can hear you.

4 MR. RAMIREZ: Okay. Great. Thank you. 

5 All right. So we left off agreeing to work with one Uo

6 number and now the question comes to, what is that number? 

7 Manny?

8 MR. SANTANA: I left off with this before break and I

9 would like to come back. It could save us a lot of time and

10 trouble. We voted on a single number without having any idea

11 what that number is and without having any analysis on what the

12 number is. We've got plenty of analysis on both of those

13 numbers there. So I would like to gauge what the membership

14 thinks of voting on the numbers in black for both columns and

15 then we can just put this thing away.

16 MS. DICKENS: That's what we did, and that's what I

17 thought we had consensus on and then we went back because

18 somebody said we should look at a single number. We already did

19 that vote.

20 (Simultaneous conversation.) 

21 MR. SANTANA: We did it last week; right?

22 (Simultaneous conversation.) 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

204

1 MS. DICKENS: Like a half an hour ago. MR.

2 SANTANA: Okay.

3 MR. RAMIREZ: We did and there was two no votes on that

4 and then we just slid all the way back.

5 (Simultaneous conversation.) 

6 PARTICIPANT: So then we didn't?

7 (Laughter.) 

8 MR. EZZO: We reached consensus.

9 MR. SANTANA: We have a lot on our plates, can we go back?

10 (Simultaneous conversation.) 

11 MR. RAMIREZ: Yeah, I'm sorry. Just a quick reminder, I

12 think I heard a couple heads explode, one of them mine. And I

13 don't want the court reporters to explode, either. So let's

14 make sure that we have one person talking and state you name.

15 MS. HOFFMAN: First Rob and then Ishbel.

16 MR. LUTER: Rob Luter, Luter Components. My suggestion

17 is, if we've already reached consensus on the black numbers with

18 two columns, we had two dissenting votes, I respect that. We

19 have consensus.

20 MS. HOFFMAN: We did.

21 MR. LUTER: Can we pretend we didn't backslide and rehash

22 it all and just agree we reached consensus, while not 100
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

205

1 percent, we reached a strong consensus to move on to the next

2 issue and make some progress here.

3 MS. HOFFMAN: Good point. We'll deal with that, but let's

4 hear from Ishbel, first.

5 MS. DICKENS: Ishbel's comment was exactly to second that

6 motion.

7 MS. HOFFMAN: Is there a vote to move on?

8 Mark Weiss?

9 MR. WEISS: Suddenly we have to unstrike and strike black

10 numbers.

11 MS. HOFFMAN: That is the least of my worries. 

12 (Laughter.) 

13 MS. HOFFMAN: You are right. Refreshing my recollection,

14 we did vote on this, we did have consensus. There were two

15 folks saying no. I think we've got two columns, we are ready to

16 go and we've got the Uo resolved; would that be fair to say?

17 MR. HAGERMAN: I don't think we resolved the green zone;

18 right. 

19 MS. HOFFMAN: The green zone.

20 MR. HAGERMAN: So I think we resolved all the Uo's for the

21 red, orange, and blue.

22 MS. HOFFMAN: But not the black.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

206

1 MR. HAGERMAN: --more analysis on the green zone and this

2 is what we -- this is not what we voted for the last time

3 because remember there's crossing zones and everything; right? 

4 And the affordability concerns came up; right? But I mean --

5 with DOE -- I'm happy with the Uo values for the red, orange and

6 the blue, but I think it's a toss-up -- I mean, I think we need

7 to have a further discussion on the green.

8 MR. RAMIREZ: Manny?

9 MS. HOFFMAN: Manny, yeah.

10 MR. SANTANA: Okay. So on that -- on the green, so we're

11 moving on; right? So we have red, orange and blue done?

12 MS. HOFFMAN: Done.

13 MR. RAMIREZ: Okay. So green. On the green what we

14 proposed last meeting was that the entire state, that green zone

15 be incorporated into the red zone with respect to you guys. 

16 MR. HAGERMAN: That was the Emanuel proposed -- 

17 MR. SANTANA: That was Emanuel's proposal. And so the

18 request to PNNL was to run those analyses, to run those sets, to

19 run those values. They did that and they distributed that. And

20 I don't know if you have that available to put up, but if we

21 could just go over that, I think that -- 

22 MS. HOFFMAN: Well, hold on a second, let's pull it up,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

207

1 and Matthew you could probably help me out here as far as

2 finding it quicker than I can. 

3 MR. HAGERMAN: The sheet that was passed out earlier that

4 has the three tables on it.

5 MS. HOFFMAN: Is that C?

6 MR. HAGERMAN: The October 17th proposal.

7 (Simultaneous conversation.) 

8 MR. MULLER: -- down low in your window. The second from

9 the bottom, maybe. 

10 MR. HAGERMAN: October 17th proposal, up three. Cursor up

11 three. Mouse up four, up, up, up.

12 MR. RAMIREZ: One more.

13 MR. HAGERMAN: Up, one more. That's it. You have the

14 hardest job here, Javier. 

15 MS. HOFFMAN: Javier is great.

16 MR. RAMIREZ: We're going to see I'm not as quick as Ted

17 was.

18 MR. SANTANA: Maybe just scroll down. 

19 MR. WEISS: What I'm holding here says October 23rd, that

20 says October 21st. 

21 MR. SANTANA: Yeah, that's the old version on the -- 

22 MS. HOFFMAN: This is October 17th.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

208

1 MR. SANTANA: This says October 17th on the top line.

2 MR. RAMIREZ: Okay. Yeah, the new one --

3 (Simultaneous conversation.) 

4 MR. SANTANA: That is around the same, but the new one has

5 an incremental sticker price over on the far right. 

6 (Simultaneous conversation.) 

7 MR. SANTANA: So the task or the question to PNNL or the

8 request to PNNL was to run analysis for four cities in the green

9 zone. In an effort to try to establish whether or not using the

10 same U value so the .087 that we just disapproved for

11 singlewide, then the .084 for multiwides was cost effective. 

12 And here are the results from PNNL that they can -- correct me

13 if I'm wrong, but looking at those four cities there, so the

14 ten-year look, your -- and so what this does, it compares the

15 .087 Uo to the .07 Uo and if you compared the two for the

16 ten-year look, it's more cost effective. So not only does it

17 have less of an upfront cost to the consumer in the way of 700

18 bucks or so, it also gives you more savings over ten years than

19 the .07 does. So I think this, and the results for the

20 multiwides are similar. 

21 So if this doesn't show that you have positive results by

22 going to Uo in the green zone that matches the red zone, I don't
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

209

1 see what does.

2 MS. HOFFMAN: Okay. We have some discussion, thank you. 

3 Lowell and then Robin.

4 MR. UNGAR: Can we go back to the chart, please?

5 So if you look at the top, down below the line -- why

6 don't you leave it where it was? Sorry. 

7 The bottom four on that top chart are the same cities, the

8 analysis of the straw man, the October 17th labeled straw man

9 that we talked about earlier. And if you will look at the total

10 trust ten-year analysis costs, the savings are actually greater

11 than for either of the two other options. And if you look at

12 for 30-year and then the old one under the 30-year analysis it

13 was reversed actually, the .07 was greater, but this is also

14 greater than at a 30-year analysis than either of the other two.

15

16 MR. SANTANA: Now what Uo is associated with the values

17 above and the table above?

18 MR. UNGAR: That's the Uo that were in red and I think

19 it's -- I closed my computer, I think its .075, .073. 

20 MR. ROY: I think to answer your question, Manny, what's

21 important is the way that those U values were represented. And

22 what we took out was the extensive, unproductive ceiling from
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

210

1 the 07 and we put in a much more productive, very low cost

2 floor. That's why we need to come up with better numbers all

3 around in the U070. It's just a wrong mix of things which got

4 to that particular 070. It's the wrong mix. It's an expensive

5 mix. 

6 MR. SANTANA: I think that the important thing to take

7 away from this is that increasing the Uo value didn't decrease

8 the return which is what Joe's concern was when we first got up

9 to suggestion. You know, so seeing the returns in the .087 in

10 the chart there shows that it's positive all the way around. 

11 MR. RAMIREZ: I think what it shows is that by using the

12 wrong mix of things to get to an 087 or an 070 you can spend too

13 much and get too little. That's actually what's underlying it. 

14 It's the wrong mix of things. That's what we tried to get rid

15 of when we did our -- 

16 (Simultaneous conversation.) 

17 MS. HOFFMAN: Let's got to Emanuel, Joe and then Lubby.

18 MR. LEVY: Can I go back to the map for the table? I

19 agree with what Robin is saying, getting to the right mix

20 ultimately is where we always wanted to be. But it was

21 difficult to get there, so we've been using going through the

22 gymnastics to try to get to the same place. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

211

1 My only point about the green group and red, the 22, 21,

2 19, is that group might look -- for the 19 in the floor in

3 particular might look attractive with reasons Javi mentioned. 

4 When we looked at the 21 versus 13, it did not. And so that's

5 the change I would make to this package to improve it even

6 further. 

7 And if you did that and you dropped back to 13 for the

8 wall, but left it at 19 on the floor, you would come up with not

9 values of 085 and 080 for the back.

10 MR. RAMIREZ: I suspect, Joe, my hunch tells me that's

11 right. That the wall is probably too strong a dip.

12 MR. HAGERMAN: When you make that change, what's the Uo

13 value that you get in that --? 

14 MR. LEVY: For the single section you get 085 and I just

15 ran this, and for the multi you get 080. That's where the 083

16 came from originally that is on some version.

17 MR. HAGERMAN: Just to address the value -- 

18 (Simultaneous conversation.) 

19 MR. HAGERMAN: -- I think what I said earlier was, you

20 know, .087 -- I'm sorry, a lower USFO value was modeled as

21 Lowell was talking about it in this USFO value 0.75, the last

22 four columns there, right, actually has -- those last four rows
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

212

1 there in the big column, I mean, sort of the big table has a

2 faster pay back than the .087. Right? 

3 It's a better investment. If you were going to invest

4 your money in one of these charts, that's the investment you'd

5 make. Right? Do you agree with that?

6 MR. SANTANA: Yeah, it's pay 300 bucks more. So from 2200

7 -- 

8 (Simultaneous conversation.) 

9 MR. HAGERMAN: You get your money back sooner and you make

10 more money over the course.

11 MR. SANTANA: I can see that, sure, but I guess I'm still

12 confused as to how that was developed. You know, and I think

13 going back to Keith's point that it seems to be a whole new --

14 well, what does that amount to? When we're talking about Uo,

15 does it amount that we're going to have four separate zones with

16 four separate Uo values?

17 (Simultaneous conversation.) 

18 MR. ROY: I think what it shows is there looks like --

19 you've got two questions. One, how is this developed? And two,

20 what does it mean in terms of what we would agree to as a

21 consensus?

22 First, how it was developed was by folks, Emanuel, Lowell,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

213

1 me, a bunch of folks thinking, what looks like its expensive

2 here that we should probably not be doing. What looks like its

3 cheap here that looks like it might be worth doing? And

4 continue to iterate through and asking DOE to do more and more

5 analysis during that last round, which in my view, probably

6 includes a wall prescription from the Ungar/Roy package that may

7 not be the right one. 

8 That's how we got there, sort of a continuing systematic

9 look at the next, the next, and the next package when we see

10 things that look expensive and probably up along there, print

11 them out.

12 But what this all means is it looks like there would be a

13 cost effectiveness and justification for a different value in

14 that other zone. But that doesn't mean that's what we should

15 adopt. Because we've all listened to the kinds of discussions

16 we've been having, particularly about this northern parts of

17 those southern states where there are a large number of

18 particularly poor people. It's of great concern to the

19 industry. I keep hearing that. 

20 In my mind that argues towards let's see what we can do to

21 give the industry time, for experience to give us all a bunch of

22 time to see how this thing works. We can revisit this in three
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

214

1 years and see if the comps are as they are. See how the

2 consumers respond, you know, what types of effects it has. And

3 for now simple to say it's conserve, I mean, you can serve on

4 one side, you can serve on the other. I do understand the

5 rationing challenge once you put an efficiency level in, it's

6 hard to walk back from it. So mindful of that, I would

7 necessarily argue for it. But I'd recognize it in three years. 

8 It's a question that can be asked again with more information to

9 see how consumers respond. 

10 So I would be willing to go with the same U values in

11 both. But much of the SHCG's really -- you say they have to be

12 all done, but the numbers look so different between those zones.

13 It is hard for me to think that you really want to have the

14 same things in there. Either you're going to pay too much in

15 the south or you're going to do the wrong thing in the north

16 part of this page.

17 MR. RAMIREZ: So what are we talking about then as far the

18 green zone numbers for single and multi?

19 MR. SANTANA: There's reasons to entertain the same values

20 as what we brought on for the red zone. The value is actually a

21 little bit lower.

22 MR. RAMIREZ: Are these the numbers then that we need to
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

215

1 gauge the level of consensus on?

2 MR. HAGERMAN: Could you just propose then a single

3 number, since there are so many numbers up there?

4 MR. SANTANA: I suggest we vote on the same .087 for

5 singlewides and .084 for multiwides and gauge that consensus.

6 MS. HOFFMAN: Okay. We have a proposal. Can you hear me?

7 I don't know if it's working. 

8 Let's have a showing of consensus -- see if there's a

9 consensus on that?

10 PARTICIPANT: Can you repeat it?

11 MS. HOFFMAN: Sure. Manny has proposed that for the green

12 zone that the U value for single sections be .087 and for multi

13 sections be .084.

14 MR. RAMIREZ: And that that would be the consistent with

15 what you see as the red numbers. So they're both --the U of O

16 numbers would be the same for both red and green.

17 MR. HAGERMAN: Before we vote, could I just get somebody

18 that's an industry representative, Mark, or Rob, or Manny, or,

19 you know, these are the manufacturers to comment as to whether

20 they feel like that adequately addresses this concern about

21 affordability and particularly that marketplace that you were

22 so concerned with? Does that resolve your previous concerns? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

216

1 Could you speak to that before we table it? So then I just feel

2 like absolute assurances is affordability on the topic is being

3 addressed and is resolved and everybody is comfortable with it. 

4 Is that fair?

5 MR. WEISS: Philosophically, I think there's benefit

6 having consistency with the Uo numbers. It doesn't change my

7 objections on to the cost data, but I think from a philosophical

8 perspective I think it makes sense -- do it that way. 

9 (Simultaneous conversation.) 

10 MR. HAGERMAN: Philosophically it addresses affordability?

11 MR. WEISS: I think our consistency of the uniformity are

12 beneficial or appropriate. Whether you address the affordability

13 as a function of the numbers as I've indicated, I have concerns

14 with those numbers. So I can't answer that question. But

15 philosophically it makes sense.

16 MR. EZZO: So let me, so 087 versus 084 helps. Like Bert

17 said on the phone though, it's hard to tell how much unless you

18 sit down and take a couple homes and run numbers. And, you

19 know, my question would be, how much different is it in glazing

20 area between those two numbers? I don't know. I don't know if

21 it's four square feet or four square inches. I know, you know,

22 3000ths doesn't make a difference, but when you're talking about
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

217

1 87 to 84 that's, you know, a little more than 3 percent

2 difference. So I think there's a little bit more significance

3 between those two numbers than we're giving a credit for.

4 Now, no question 087 is easier to get than 084. So does

5 it help affordability? Yeah. How much? I don't know. 

6 MR. SANTANA: Does having the green zone values match the

7 red zone values and how that addresses affordability? I think

8 it takes great leaps towards address affordability in that

9 region. 

10 And I'd echo what Robin said, that this affords us, you

11 know, a little leeway to see how the market reacts to this. The

12 numbers help to justify that and if reality has something

13 different, then we can always adjust it. But I think this goes

14 a long way towards addressing affordability in the region that

15 we have the most concern with. So I think that's -- 

16 MR. HAGERMAN: I appreciate that. The reason I asked was,

17 you know, we asked for more analysis, couldn't come to terms

18 with this the last meeting because of the affordability

19 concerns. So I just wanted to make sure that after we discuss

20 this it's like, yes, all regulation, that lingering and always

21 important concerns as getting back here, as we take a vote.

22 MS. HOFFMAN: Okay, Bert, did you want to add something? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

218

1 MR. KELLER: Well, during the break I ran a couple of

2 quick examples. So I actually used my current people's program

3 and modified it to incorporate the proposed Uo values. And to

4 get a change in a third digit, you have to remove two windows

5 with a SHGC of 33. Or increase or decrease the ceiling

6 insulation by an R3, just to give you an idea. 

7 MS. HOFFMAN: Rob?

8 MR. KELLER: And back to the point of I made earlier, you

9 know, I think most manufacturers will offer a standard package

10 that typically gets everything to pass across the board. So,

11 you know, I just think there are so many variables. 

12 MS. HOFFMAN: Keith has asked to be unmated. We're

13 working on it, Keith. So we haven't forgotten you. 

14 Yes, Lois.

15 MS. STARKEY: I do think it does go a long way to address

16 the affordability issue. I think because we know that the

17 distribution of homes is fairly even across those two zones that

18 that really does help. And it gives us a chance to see how the

19 market will respond going forward.

20 MR. HAGERMAN: Let's take a vote if we can.

21 MS. HOFFMAN: Does Keith have a comment?

22 MR. RAMIREZ: I'm going to ask, Keith, if you can hear us,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

219

1 maybe type in your comments here because I looked and I didn't

2 see you logged in. So I don't have any way of unmuting you.

3 MR. HAGERMAN: Did you unmute all the phone calls? Maybe

4 he was just calling in. Can you unmute the phone callers?

5 MR. RAMIREZ: Keith, do you want to try that?

6 Yeah, I don't see his name logged on there. 

7 MS. HOFFMAN: So, Keith, we're asking you to type in

8 something. 

9 MR. RAMIREZ: If you could send it to me, Keith.

10 MS. HOFFMAN: Yeah, send it to Javier, we'll read it out

11 and then we'll have a vote on this issue.

12 And I guess while we're waiting for Keith, is there any

13 other comments you have?

14 MR. HAGERMAN: Can we recap what the vote is?

15 MS. HOFFMAN: Excuse me? Oh, let me rephrase, it's on the

16 green zone U values for single section and multi section and the

17 proposal from Manny is .087 and .084, that's the proposal.

18 Now, I -- 

19 MR. HAGERMAN: If Keith is having problems, maybe he could

20 hang up and call back in.

21 MS. HOFFMAN: O, good.

22 MR. HAGERMAN: You will see him then, Javier.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

220

1 MR. RAMIREZ: Keith, you may have to log back in. 

2 MS. HOFFMAN: We're not talking about the prescriptive

3 part at this point. So keep it straight, keep it simple.

4 (Pause.) 

5 MR. RAMIREZ: I'm not sure how much time to give here. 

6 MR. HAGERMAN: Why don't you take a temperature vote?

7 MS. HOFFMAN: Yes, let's do that. Let's take a

8 temperature vote. Thank you. Put on our thermometer right now

9 and see who is in favor with your thumbs of this proposal for

10 the green zone, .087 and then for single and then .084 for

11 multi.

12 (Showing of thumbs.) 

13 MR. RAMIREZ: All right. I see only one thumb down. And

14 on line is there anyone that can speak that has their thumb

15 down?

16 (No response.)

17 MS. HOFFMAN: Okay. 

18 MR. RAMIREZ: I'm just going to do a quick check. David

19 Tompos, can you say something just to make sure that we can hear

20 everyone?

21 MR. TOMPOS: I'm here. Can you hear me?

22 MS. HOFFMAN: Yeah.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

221

1 MR. RAMIREZ: Okay. Fine, I just wanted to make sure that

2 there wasn't something else bigger going on here. 

3 Okay. Great. 

4 Yeah, I just got the report back also from the technical

5 folks in D.C., that he's not signed in.

6 MS. HOFFMAN: Well, we heard him earlier. I don't know.

7 MR. RAMIREZ: Yeah. 

8 MS. HOFFMAN: Okay. 

9 MR. RAMIREZ: So we have one no vote and then we'll let,

10 you know, if Keith has objection to it, we'll allow him to note

11 that when he gets back.

12 MS. HOFFMAN: Note that. And, Mark, you want to -- 

13 MR. WEISS: To be clear, I have no problem with having

14 consistent Uo values across both those zones. My objection is

15 purely related to cost.

16 MS. HOFFMAN: Cost.

17 MR. RAMIREZ: Thank you.

18 MS. HOFFMAN: Okay. Thank you. 

19 (Simultaneous conversation.) 

20 MR. RAMIREZ: Emanuel has a comment from Keith.

21 (Simultaneous conversation.) 

22 MR. RAMIREZ: .087 and .084 for both green and red work
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

222

1 sideways for me.

2 MS. HOFFMAN: Okay. I thought we had voted on that. 

3 Other numbers. Okay. Thank you, Keith. We are done. We voted

4 on -- we have all in black and we've got the numbers for the

5 four zones for the Uo. 

6 Yes, Lowell.

7 MR. UNGAR: Might I suggest in light of the previous

8 conversation that given that if we are going to use those Uo

9 values, let's go back to the black prescriptive -- 

10 MS. HOFFMAN: Oh, the prescriptive. Well, that's -- 

11 (Simultaneous conversation.) 

12 MR. RAMIREZ: Let me make it clear, we're not going to

13 touch those Uo numbers anymore.

14 MS. HOFFMAN: We're done.

15 MR. RAMIREZ: We're done.

16 (Simultaneous conversation.) 

17 MR. RAMIREZ: No, no, no.

18 MS. HOFFMAN: Not prescriptive Uo.

19 MR. RAMIREZ: So now we're going to be going to the

20 prescriptive, now let's figure out what those numbers need to be

21 a prescriptive which is where you're going next, and that's

22 where we need to go. But the way that you phrased it, I just
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

223

1 don't want to give the folks the impression that we can go back

2 and now tweak the Uo. We're done with the Uo. 

3 So knowing what the Uo numbers are on the prescriptive,

4 again, I don't think that the orange and the blue are at the --

5 you know, that we're hung up on that. Right? 

6 We need to be clear on what is red and green. So, with

7 that, Lowell, what numbers do you -- 

8 MR. UNGAR: My suggestion is to go -- the numbers in black

9 -- 

10 MR. RAMIREZ: The original numbers.

11 MR. UNGAR: -- the original numbers that we -- given the

12 discussion -- that we just go back to those which are consistent

13 with the -- and those were how we derived the Uo values that we

14 just voted on. 

15 MS. HOFFMAN: Is there any discussion? I know you worked

16 hard on that, though, Emanuel and Lowell. 

17 MR. UNGAR: The others were all right. But I was -- 

18 MS. HOFFMAN: Oh, okay.

19 MR. UNGAR: -- that was in order to address green and we

20 just didn't go that direction for green, so I'm suggesting we go

21 back.

22 MS. HOFFMAN: So go back to the original numbers in black?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

224

1 Any discussion?

2 (No response.) 

3 MS. HOFFMAN: Yes?

4 MR. LUBINER: I'm good with that and I'm glad we finally

5 came up with something. 

6 MS. HOFFMAN: Okay. That's Lubby. Okay. Mark?

7 MR. WEISS: For the technical, what impact will the

8 determination of the SHGC have on that, if any?

9 MS. HOFFMAN: Okay. A question because we've got -- 

10 MR. WEISS: Uo values. Okay. 

11 MS. HOFFMAN: The SHGC question marks for the green zone

12 and the orange zone, perhaps, Joe, you want to speak to that?

13 MR. HAGERMAN: I spaced out, I'm sorry. 

14 MS. HOFFMAN: Oh, okay. Sorry. Question before we voted

15 on the prescriptive, when it comes to the SHGC values and there

16 are question marks because they're being deferred for you to do

17 some research and see what they should be for the green zone and

18 the orange zone. What impact, let's see if I'm phrasing it

19 correctly.

20 MR. HAGERMAN: I can answer you. I think I understand

21 your question. When you pick a path, you either follow the

22 Uo's, the last two columns, or the other side of the columns;
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

225

1 right? They don't -- 

2 MS. HOFFMAN: Right. That's easy. He just wants to know

3 what the impact is thought of the question marks for the

4 prescriptive. 

5 (Simultaneous conversation.) 

6 MR. HAGERMAN: That's a great question. That's why we

7 need more time to answer the questions.

8 MS. DICKENS: I don't think that's the question.

9 MS. HOFFMAN: Oh, it's not the question?

10 PARTICIPANT: Whether they apply to the Uo.

11 MR. HAGERMAN: They don't.

12 MS. HOFFMAN: They don't.

13 (Simultaneous conversation.) 

14 MS. HOFFMAN: One at a time. Excuse me. One at a time. 

15 Since I've misunderstood him, why don't you start again? Mark,

16 what were you asking?

17 MR. WEISS: Since the prescriptive values--R values are

18 the same for red and green and the Uo values is the same for red

19 and green, the only variable missing is the question mark for

20 the SHGC. And my question was, would that have any impact on

21 the Uo values at the right-hand side of the -- and the answer

22 for that for these guys is no, which is fine.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

226

1 MS. HOFFMAN: Okay. There were some other comments or, if

2 that answered that question, then perhaps the best is that some

3 consensus then on all the others. Yes, Lois.

4 MS. STARKEY: Are we looking on the orange and blue zones

5 at 069 or 070 on the orange?

6 MS. HOFFMAN: I think it's on the black, right? Correct? 

7 The black 070 -- all the black. Not red.

8 MS. STARKEY: Take off the -- 

9 MS. HOFFMAN: Let's take off the red, if you don't mind.

10 Thank you. 

11 Okay. And this is a no requirement because there is no

12 requirement for SHGC for the blue zone. Okay. 

13 Now we're going to ask you for your indulgence and let us

14 know how you feel about all of the prescriptive numbers. 

15 They're all in black and it's -- I guess it's for the red,

16 green, and orange because we've changed it slightly because of a

17 question mark for -- if everyone is in favor, or whatever, let's

18 see by your thumbs, please, or can live with it.

19 (Showing of thumbs.) 

20 MS. HOFFMAN: Is there anyone besides Mark, anyone out in

21 the remote area?

22 MR. KELLER: Yes, this is -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

227

1 MS. HOFFMAN: Bert, yes.

2 MR. KELLER: I think I'm going to go sideways on that one.

3 MS. HOFFMAN: Sideways.

4 MR. KELLER: And let me explain that because we're

5 prescribing our third R13 in the floor. Typically blankets are

6 used, and that is not what's currently being done. It's like an

7 R11, but perhaps with the R30 in the ceiling, it may not be a

8 problem.

9 MS. HOFFMAN: Oh, any -- 

10 (Simultaneous conversation.)

11 MR. WEISS: Same comments.

12 MS. HOFFMAN: Same comments for you, Mark.

13 Let's assume then -- may we assume that this as discussed

14 has reached consensus for everyone?

15 So we can -- 

16 MR. TOMPOS: What are we voting on?

17 MS. HOFFMAN: Well, we've already voted, but let me

18 explain. 

19 MR. TOMPOS: Well, I couldn't hear half of it.

20 MS. HOFFMAN: Oh, okay. And who is this, please?

21 MR. TOMPOS: Dave Tompos.

22 MS. HOFFMAN: Oh, hi, Dave.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

228

1 We're voting on the red, green, and orange for the

2 prescriptive path, all that's in black.

3 MR. TOMPOS: Okay. My only concern would be -- I can't

4 remember who said it, but typically they are using an R11. You

5 know, in the orange zone they're going to do an R22 because

6 they're going to do two R11 blankets. So I'm not sure that

7 that's the best way to go. But I'm sideways, so I guess it

8 doesn't make a difference.

9 MR. RAMIREZ: Okay. Let's get Joe and then Michael.

10 MR. HAGERMAN: A technical procedural comment. Since

11 we're about to memorialize the totality of this table, and I

12 guess we'll re-memorialize the map above it, right? Were you

13 going to memorialize this?

14 MR. RAMIREZ: Yes.

15 MR. HAGERMAN: We need to take an official vote -- 

16 MS. HOFFMAN: On everything, the whole thing.

17 MR. HAGERMAN: -- and record that for the term sheet.

18 MS. HOFFMAN: Sure. The whole thing, yes.

19 MR. RAMIREZ: And the way that we are doing that is we're

20 identifying who those no votes are and then everyone else is

21 okay.

22 MS. HOFFMAN: Okay. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

229

1 MR. RAMIREZ: Sideways and up, that's consensus. So we

2 need to count the thumbs down.

3 MS. HOFFMAN: Thumbs down. No vote.

4 MR. RAMIREZ: We don't have too many of them.

5 MS. HOFFMAN: Michael, yes.

6 MR. LUBLINER: I mean, I was at a factory the other day

7 where they were using two R7s in the belly.

8 MS. HOFFMAN: And your point is?

9 PARTICIPANT: That would work. 

10 MR. LUBLINER: He said you couldn't get it.

11 MS. HOFFMAN: Oh, okay. Thank you. Thank you, Lubby. 

12 Okay. Given the time we've spent and worked very hard on this,

13 it's now the moment of truth. We want to hear for the whole

14 package, that's the map and the table covering both prescriptive

15 and Uo for manufactured housing. So can we hear from everyone

16 what your thumbs are, et cetera?

17 MR. SANTANA: That would be four zones.

18 MS. HOFFMAN: Four zones, yes. Four zones.

19 Okay. 

20 MR. RAMIREZ: I see one thumb down with Mark Weiss. 

21 Everyone on line that has their thumbs down?

22 MR. KELLER: Make that two. This is Bert.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

230

1 MS. HOFFMAN: Bert, your thumb is down or sideways?

2 MR. KELLER: Down.

3 MS. HOFFMAN: Okay. Do you want to tell us why?

4 MR. KELLER: Well, I still believe that the differences in

5 actual performance and small differences in what we're actually

6 doing with the minimum prescriptive requirements are not

7 significant enough to warrant a whole separate zone.

8 MS. HOFFMAN: Oh.

9 MR. KELLER: And, again, we're basing a lot of this on a

10 fixed, single section unit, and a fixed double section unit that

11 we're comparing across homes and I understand why we're doing

12 that. But, you know, we've got all kinds of variations and size

13 and window glazing percentages. I just don't think it's

14 necessary. 

15 MS. HOFFMAN: Okay. I appreciate that. Thank you.

16 MR. RAMIREZ: Mark, the costing issues. So then

17 congratulations. That was a big chunk that you got done there. 

18 MR. HAGERMAN: I have an ask for everybody. 

19 MS. HOFFMAN: Yes.

20 MR. HAGERMAN: You know, using your best professional

21 judgment, right. I know we have some outstanding questions

22 about the solar heat gain coefficients, but now that you've seen
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

231

1 the entire package and seen the consensus votes, the last time

2 we were sort of at the same place and then Mark Ezzo proposed

3 just the solar heat gain coefficient values and it seemed like

4 he nominated those and everybody was okay with them. I was just

5 wondering, you know, I don't mind going and doing homework, but

6 it would look a lot cleaner if we just had a complete term

7 sheet. Does somebody have some more thoughts on these question

8 marks now that the conversation has kind of moved along and we

9 maybe we could turn those question marks into values. Do you

10 follow the -- 

11 MS. HOFFMAN: Yes. 

12 (Simultaneous conversation.) 

13 MR. HAGERMAN: Since we're coming a long way here, can we

14 just close out the entire table?

15 MR. RAMIREZ: Let's start with Eric and then Emanuel. 

16 MS. HOFFMAN: And then Mark and then Mark.

17 MR. LACEY: This is Eric with RECA. I mean, I certainly

18 have an opinion on this and I can throw out a suggestion, a

19 straw man and see if anybody is okay with it. It's an attempt

20 to compromise. Again, you know, looking at some of the things

21 that are not captured in the PNNL analysis like, you know,

22 future proofing these homes, making sure that in any orientation
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

232

1 they're not going to be driving up the air conditioning costs. 

2 The potential downsizing, which I'm not sure if PNNL is going to

3 include that in any further analysis, but to date they haven't. 

4 And just the rising cost of electricity and especially peak

5 electricity and the associated increased pollution and increased

6 costs of having to meet the peak electricity loads. 

7 I think it's wise to keep the SHGC low, especially in all

8 those climate zones. And I think red is a clear winner for .25.

9 I mean, Florida and a good part of Texas down there, the

10 jurisdictions have already gone in the direction of the .25.

11 In the green zone, I would still recommend keeping that at

12 a 25. Three of the four states there are already at a 30 and

13 the 2012 and 2015 IECC would have you at a 25. I think Georgia

14 is going to go that way in the near future and so I think it

15 makes sense to keep it at 25 SHGC in zones one and two, you have

16 one product basically that would work with that whole zone. 

17 Then climate zone could take an amalgam of everything. 

18 Maybe that's like a 30 or a 33 for that whole climate zone. 

19 That captures parts of that zone that are in a 25 range, parts

20 that are in 30, parts that are in 40 and then a couple little

21 corners where there's not an SHGC. So I would say, you know,

22 starting down in climate zone marked red, so a 25, then green
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

233

1 25, and then the orange like a 30 or a 33. 

2 MR. HAGERMAN: Then I guess everybody should realize once

3 you do that there's no need for the red and green, they become

4 the same zone?

5 MR. LACEY: Right. That would be one simple factor.

6 MS. HOFFMAN: Okay. Wait, we did have an order. 

7 MR. KELLER: This is Bert.

8 MS. HOFFMAN: Yes, Bert, what's up?

9 MR. KELLER: Just for clarification, Texas state building

10 code is on 2012. Texas modular code is still on 2009. 

11 MR. RAMIREZ: Do you know what that number is?

12 MR. LACEY: Yeah, over half of the -- the state's base

13 code is the 2009 right now. Jurisdictions are allowed to go

14 beyond that and over 50 jurisdictions have already adopted the

15 2012 IECC. That's why there's a range of 25 to 35 depending on

16 where you are in the state.

17 MS. HOFFMAN: Who was next? It was Emanuel. And then

18 Manny, and then Mark, the two Marks.

19 Okay. Emanuel. 

20 MR. LEVY: I'd just go back to the analysis we've done

21 already. And on that basis I would make the green/orange zone

22 both .33. I agree with Eric that zone three is problematic
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

234

1 because it's so comprehensive in terms of this issue. But I

2 think the 33 is a better compromise and there are products out

3 there for that in the industry right now. And the 25 it seems

4 to be cost effective by the analysis that we've done, so I would

5 agree with the red zone result. But my proposal would be 33 for

6 green and orange.

7 MS. HOFFMAN: Okay. I'm losing it here. Manny and then

8 the two Marks and then Robert.

9 MR. SANTANA: I'm a little confused, which isn't a big

10 statement in and of itself. But, you know, earlier today we

11 voted that -- or Joe said that DOE needed to have more analysis

12 on it and we haven't provided any new information and we haven't

13 received any new information. So I don't see how we can bring

14 this back up again?

15 MR. HAGERMAN: No, I'm just asking you to tap into your

16 professional judgment so I don't have to go do anymore analysis.

17

18 (Simultaneous conversation.) 

19 MR. RAMIREZ: He's using all the rich resources of the

20 knowledge in this room to see if we can't -- 

21 MR. HAGERMAN: The last time we voted on this, we were in

22 the same place and Mark Ezzo put down a proposal. We asked for
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

235

1 more analysis, he put down a proposal, and you all didn't ask me

2 to do anything after we voted. So -- 

3 MS. HOFFMAN: Okay. Well, let's just hear what people

4 have to say and see. Mark Ezzo? Mark. Mark, you have the

5 floor. 

6 MR. HAGERMAN: Your finest moment too.

7 MR. EZZO: I agree with Emanuel on the 33 for green and

8 orange.

9 MS. HOFFMAN: 33 for green and orange.

10 All right. Mark Lubliner?

11 MR. LUBLINER: I'm going to pass.

12 MS. HOFFMAN: You're passing. Let's see. 

13 MR. RAMIREZ: I think it was Rob and then -- 

14 MS. HOFFMAN: Oh, Rob Luter, yeah. 

15 MR. LUTER: In terms of the solar heat unit for the orange

16 zone, I think 33 is probably a good fit. It's an imperfect

17 solution give the very areas you've got there. We're saying

18 that San Diego or Palm Springs is the same as St. Louis. I

19 don't know. But I would abdicate leaving zone two -- excuse me,

20 green zone, .33 subject to analysis by DOE. I think that if

21 there truly is a benefit to having a higher solar heat gain

22 because of the solar gain in the winter, we ought to be sure of
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

236

1 that. I wouldn't write that off just to some mathematical

2 anomaly and discount it because it doesn't follow convention. 

3 It should be easy enough to run the math and see if it makes

4 sense. 

5 MR. HAGERMAN: So just as you're gaming this out, what I

6 would go -- what DOE would go and study is, you know, I like the

7 fact that maybe I'm just doing analysis on the green now, or I

8 guess I've always been doing that, or we've been back and forth

9 on that. But we're going to study .25, I think we would have to

10 study .30 and then .33; right? 

11 MR. LUTER: I wouldn't bother with .30 because you're

12 going to get -- with a double silver and a triple silver, you're

13 going to go 33 right into 25.

14 MR. HAGERMAN: Okay. All right. 

15 MR. LUTER: And I'll say that if the math comes out that

16 .25 is really the number, I don't have a problem with that. But

17 I just want the number to be right, whatever it is. 

18 MR. HAGERMAN: We want all the numbers to be right. 

19 MS. HOFFMAN: Okay. Michael.

20 MR. RAMIREZ: I'm sorry, it was Robin and then Michael.

21 MR. LUBLINER: That's basically what we're talking about

22 is the incremental costs of the triple versus the double silver
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

237

1 coating.

2 MR. LUTER: As I just mentioned to Mark, if you used

3 particular window operator types that have low glass area like a

4 double hung with grids, and conventional double silver low E,

5 you might be able to get there. But you'll never get there with

6 a picture window or a patio door, or a single hub, and that's --

7 so that's why we established those ranges.

8 MR. LUBLINER: We get back to the discussion of a window

9 schedule and we do have the actual window schedule rather than

10 saying glazing. We're kind of limited there.

11 Anyway, that was just a question. I wanted to make sure I

12 was clear on what the real technology difference was here.

13 MR. LUTER: One other point of clarification, I believe I

14 understand this. These would be the maximum values for any

15 particular fenestration product, any window in the home. This

16 is value average. Is that -- is that a correct assumption?

17 MR. RAMIREZ: That's one of those footnotes that we could

18 discuss. I mean, if you're considering all the fenestration as

19 an area weighted average, then, yeah, that shouldn't be an issue

20 if you've got a patio door. Yeah, you're averaging that with

21 windows that are probably going to have a much lower SHGC than

22 what's up there. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

238

1 MR. LUTER: Or may have.

2 MR. RAMIREZ: Yeah. And 33, you know, maybe a 33 captures

3 every single window that you make right now. But maybe a 30

4 would capture the better half of those. You know, I don't think

5 you have to guarantee that every single product out there -- 

6 MR. LUTER: I don't disagree with the panels. I think

7 that although the windows that are primarily used are single

8 hung, the picture windows and the patio doors you don't see many

9 double hungs which that's the exception to the rule. That's

10 where the (inaudible) but it would be worth looking at. 

11 MR. HAGERMAN: So it would, so I should run .33, not .30.

12 MR. LUTER: Run a .30 as an average.

13 MR. HAGERMAN: As an average.

14 MR. LUTER: Just to see.

15 MS. HOFFMAN: Robin. 

16 MR. HAGERMAN: If you look at the chart right now, it

17 looks like, you know, there's a puzzle on the back of some

18 newspaper, .30 would be the number that falls there. Above it

19 is .25 and below is .33. 

20 MS. HOFFMAN: Robin, you had a comment?

21 MR. ROY: I think it's time to take a vote on whether we

22 go ahead with Joe's idea to take a number out of the air rather
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

239

1 than having him do the additional work. I'm really much more

2 inclined to do what we decided to do this morning.

3 MR. HAGERMAN: I don't think we can take a vote on it. 

4 (Simultaneous conversation.) 

5 MR. HAGERMAN: It was a bad suggestion by me.

6 MS. HOFFMAN: Well, I think you got a lot of good data

7 though.

8 (Simultaneous conversation.) 

9 MR. RAMIREZ: We could still tighten it up though; right? 

10 Because what I'm hearing is that for the SHGC for red it was

11 .25, orange is .33, and then the only question then would be for

12 DOE to run the data and pick the number that's appropriate

13 according to the data.

14 MR. HAGERMAN: DOE analysis we basically do the three runs

15 that you're talking about there with a new, you know, underlying

16 model that better captures (inaudible) coefficient effects. So

17 the discussion has limited how much work I have to do.

18 MS. HOFFMAN: But I think we need to know that everyone

19 agrees.

20 MR. RAMIREZ: Yeah.

21 MS. HOFFMAN: Yeah, we need to know that everyone agrees

22 with that. We had an ask from Joe and what we have here is the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

240

1 proposal to have for the SHGC rating .25 which was agreed to for

2 the red zone to study the appropriate amount for the green zone

3 and to put .33 in the orange zone. 

4 MR. RAMIREZ: Rob?

5 MR. LUTER: Question, regarding the updated analysis, if

6 we run the green zone with a different set of variables to be

7 the more accurate or differently capture the effects of solar

8 heat gain, are we saying that we should do that to red and

9 orange as well? Or just leave well enough alone and -- 

10 MR. RAMIREZ: What we're talking about is green.

11 MR. LUTER: Okay. 

12 MR. RAMIREZ: That would be .25, orange would be .33.

13 MR. LUTER: If we were to be entering into this on a blank

14 sheet of paper, would we ever suggest that one particular zone

15 be evaluated under a different set of variables than the rest of

16 them?

17 I already know the answer, but I'll let

18 -- 

19 (Simultaneous conversation.) 

20 MR. LUTER: I mean, seriously, I don't know if it's a show

21 stopper here, but -- 

22 MR. HAGERMAN: So just to be clear, you know, there's
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

241

1 other analysis that we have to do after we decide the term

2 sheet, like the national impacts and all this other kind of

3 analysis. In addition, since we've been doing this fast

4 turnaround stuff, we're going to have our teams rerun things

5 just to make sure we don't have any errors.

6 Like last time, and I apologize for this, I just got the

7 note today, this morning, and I should have made a note of

8 everybody, but last night or whatever, when we sent out the

9 energy stuff we miscataloged one of the runs. We confused, you

10 know, one city for the other. It didn't really make a big

11 effect, but we just didn't tell you that. So there's other

12 stuff that we're going to do, rerun the analysis and look at the

13 lifecycle tool to make sure that we're not making errors. 

14 MR. LUTER: I would hope that if there is a radical

15 difference in the changing this one variable is really

16 significant, that we at least gut check that against the others.

17 MR. HAGERMAN: Oh, absolutely. After we do this analysis

18 the rerunning and double-checking -- let's just call it

19 double-checking, right. We finish the package and we put it out

20 for full comment. So you're always going to have the

21 opportunity and we'll make it clear in the package, hey, we

22 reran the analysis and we saw an egregious error here and that
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

242

1 explains the difference of this and that, right? And we'll put

2 it out for a longer comment. Right? 

3 We're not trying to surprise you, we just also want to own

4 up to mistakes that we made mistakes; right. Because we want

5 the data to have some integrity. We want all this work to have

6 integrity; right? 

7 PARTICIPANT: Exactly. 

8 MR. HAGERMAN: I have my homework. I think you just out

9 of the technical -- again, another procedural thing is in this

10 discussion just right now, we did change the orange solar heat

11 gain coefficient on three question marks to the number -- 

12 MR. RAMIREZ: That's exactly what we -- 

13 (Simultaneous conversation.) 

14 MS. HOFFMAN: Yeah, we were just talking about that, we

15 want to make sure there is consensus to have orange as .33, and

16 for the referral to DOE to come up with the figure for the green

17 zone with the parameters of 2.5 and 3.3.

18 MR. RAMIREZ: One more comment from Eric and then we'll

19 get a consensus. 

20 MR. LACEY: This is Eric. Just to be clear, this is

21 reversing the vote we took at the last meeting -- 

22 MS. HOFFMAN: Yes.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

243

1 MR. LACEY: -- which would have had the whole green

2 section at 25 SHGC. Just so we acknowledge that. That's almost

3 all climate three of the IECC which have we not entered anything

4 here today, that would be 25 SHGC. So let's acknowledge that

5 going forward. As well as a big chunk of Texas as well.

6 On the orange zone, I would still prefer staying at about

7 30 because the whole say of California, their prescriptive

8 requirement is a 25 SHGC as is a good number of jurisdictions in

9 Texas and Arizona as well. And so, you know, I know it's an

10 average number and we're kind of picking numbers out of the air,

11 but a 30 at least is actually the code requirement in a lot of

12 those and a 25 is a code requirement in a couple of those

13 states. So, that's where I prefer to see it as a 30 there and

14 obviously a 25 in the red and green zones, but I realize that,

15 you know, I'm just one voice on this. It will be more

16 consistent with the IECC and -- 

17 (Simultaneous conversation.) 

18 MR. HAGERMAN: I'd be happy if you want to put down 30 -- 

19 MS. HOFFMAN: 30.

20 MR. HAGERMAN: -- new line, .33, new line, parentheses DOE

21 question mark. Because that helps me understand what, you know,

22 more specifically what it is that we're trying to make a
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

244

1 decision on.

2 MR. LUBLINER: You'll get comments from California, for

3 sure.

4 MS. HOFFMAN: Well, help me understand where we are now. 

5 Is there a discussion about the orange zone as having it as .30?

6 Is that what I'm hearing?

7 PARTICIPANT: Yeah.

8 MS. HOFFMAN: And then the green zone for you to look at

9 whether it will be .25 of .30 or point whatever?

10 MR. HAGERMAN: The discussion right now is it doesn't have

11 -- it doesn't really change the last vote. You just gave me

12 more definition.

13 MR. RAMIREZ: Yeah. We just gave him parameters. 

14 MR. HAGERMAN: Make a determination on those two sort of

15 -- 

16 MS. HOFFMAN: Yeah. Rob?

17 MR. LUTER: I would just like to comment on Eric's

18 comment. I understand where it's coming from and I think that

19 if we could use a weighted average and it didn't become too

20 complex a way to arrive at a solution, 30, you know, that could

21 be achievable without too much difficult. 

22 MR. RAMIREZ: Let's carve out -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

245

1 MS. HOFFMAN: I'm sorry, Emanuel, you had something?

2 MR. LEVY: I just wanted to clarify. When we talk about

3 .30, this isn't -- there's no .30 window. That means you're

4 going to have a mix of two fives and three threes, is that what

5 we're talking about?

6 MR. LUTER: It means there's going to need to be a mix of

7 things that are 30 or less with other things. And whether that

8 means triple silver low E or just a lot of double hungs in the

9 grids. It can be combined with the other ones. I think it's

10 capable if there are going to have to be some 25's there. Those

11 are the two -- 

12 (Simultaneous conversation.) 

13 MR. LUTER: And if 25's are not cost effective, then I'm

14 not sure why we're talking -- 

15 (Simultaneous conversation.) 

16 MR. LUBLINER: I just took a picture of a window at a

17 factory a couple weeks ago and it's a pretty typical window. 

18 This .30 is a solar EK coefficient there. But there were other

19 ones in the house a little higher, but the predominant windows

20 seemed to be that. 

21 Picture windows it's going to be tough, single hungs

22 you'll be able to do that. They'll all have grids. They'll all
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

246

1 have double silver OE. I can verify that.

2 MR. RAMIREZ: So we're at one of two points here. Both

3 we're done and DOE is going to do the analysis for the green and

4 the orange. And that's what we had agreed to before. The only

5 thing that this would do is give them -- 

6 MS. HOFFMAN: Some guidance.

7 MR. RAMIREZ: -- a little bit tighter parameters, right,

8 of what you need to run. Or, we lead DOE to run analysis on

9 green and we approved 30 average for orange. 

10 MR. LACEY: This is Eric from RECA. My assumption was

11 that you could area weight average the U factors or the SHGCs. 

12 That was one of the footnotes that we should probably tack on. 

13 And if that makes it a little easier to stomach the SHGC or the

14 U value of the window, I think that's totally reasonable. The

15 IECC allows you to do that. 

16 MR. LUTER: That was my request for clarification. I

17 still am not clear whether we can or can't do that.

18 MS. HOFFMAN: I see. We've got Michael, but also Ishbel

19 before. Did you have some comments? You had raised your hand.

20 MS. DICKENS: Yeah, no I just wanted to say, I just felt

21 like we had gone around in a whole circle and we were back with

22 DOE doing research on the orange and the green and could we just
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

247

1 please move on to the next -- 

2 MS. HOFFMAN: Right. I agree. But they have more

3 guidance now than they did before. So it's not for naught. 

4 MR. HAGERMAN: I think an opportunity to not do work, and

5 I tried.

6 (Simultaneous conversation.) 

7 MR. RAMIREZ: Well, that was about ten minutes, and I tell

8 you what though, it did tighten up the parameters, so it wasn't

9 all wasted.

10 All right. So we're not going to go to that -- 

11 MS. HOFFMAN: We're done.

12 MR. RAMIREZ: -- it's the same, it just has tighter

13 parameters.

14 MS. HOFFMAN: Okay. 

15 MR. RAMIREZ: The one thing I do want to -- and I hope

16 this isn't going down another rabbit hole here. But we had

17 talked about before as far as name the zones. You want to get

18 the numbers in there and the naming them. And now that we have

19 the chart on here, how are we naming these zones? Is it one,

20 two, three, four? Is it 1A, B, Manny?

21 MR. SANTANA: I think we should go back to Emanuel's

22 option two map which is what we took the initial vote on. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

248

1 MS. HOFFMAN: You mean 1A and B, and 2 and -- 

2 MR. SANTANA: And three. And that will be subject to what

3 SHGC comes back with. Because if the solar heat gain is the

4 same for the red and green, then there's no benefit to have -- I

5 mean, 1A and 1B. I mean, we keep the dashed line, but it should

6 still be zone 1.

7 MS. HOFFMAN: So we have a proposal, if I might say, from

8 Manny, of using the nomenclature, the manual proposed of zones

9 -- climate zones 1A and 1B, then zone two and zone three. Any

10 discussion? Yes, Lowell.

11 MR. UNGAR: With the caveat that regardless of what's

12 decided in SHGC, I'd like to make a recommendation to DOE that

13 in doing analysis for the next round of standards that they

14 analyze 1B separately from 1A. 

15 MR. HAGERMAN: Right.

16 MR. UNGAR: I mean, I don't know whether they should be

17 the same or different the next time, I just want to at least

18 have the analysis so we know what we're talking about. 

19 MS. HOFFMAN: Okay. So you would like analysis of every

20 zone, A and B.

21 (Simultaneous conversation.) 

22 MR. UNGAR: So that we have the data. At this point
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

249

1 we're just having the same discussion next time.

2 MS. HOFFMAN: Got it. Emanuel.

3 MR. LEVY: I just want to say, first of all I agree with

4 Lowell. 

5 MS. HOFFMAN: Uh-huh.

6 MR. LEVY: The next time this comes up, this stuff should

7 be revisited and the station made about whether those should be

8 separate zones or not.

9 MS. HOFFMAN: Right.

10 MR. LEVY: But for the time being if the solar heat gain

11 coefficient for both zones comes out the same, we've already

12 said the U values are going to be the same. By not collapsing

13 them to one zone, we have a real optic problem with trying to

14 explain why we have two zones with exactly the same

15 requirements. How do we explain that? How does the industry or

16 anybody else understand -- we're just talking concept of

17 something that might happen in the future that we want to add

18 another label to another set of parts of states. It doesn't

19 make any sense to me. 

20 MS. HOFFMAN: Ishbel?

21 MS. DICKENS: So does that mean that we should vote on

22 this map with the proviso that if DOE comes back with the same
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

250

1 heat coefficients that we then collapse it into one zone with a

2 footnote that next time around they be looked at, at least --

3 you go back to this original to do the analysis separately as a

4 baseline starting point next time around.

5 MS. HOFFMAN: Is that a proposal that we would like to

6 discuss; vote on? Yes?

7 MR. KELLER: Bert, Palm Harbor. Are we -- 

8 MS. HOFFMAN: Lois first.

9 Oh, Bert first. Yes, please speak.

10 MR. KELLER: Okay. Looking at the map we're still showing

11 a U of .090.

12 (Simultaneous conversation.) 

13 MR. KELLER: 1A and 1B, but those are now .87?

14 MS. HOFFMAN: Yes, they'll all be changed.

15 MR. KELLER: Or .83? Is that -- 

16 MS. HOFFMAN: Yes, Bert, they will be changing it for

17 tomorrow. 

18 MR. RAMIREZ: These are the numbers, these are the zones. 

19 I just wanted to go back because we had talked about how we name

20 them then once we agree on the numbers and the lines. And these

21 are the lines we agreed to. The only question I had was, what

22 are we calling them?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

251

1 MR. HAGERMAN: I think we should just move on. I mean,

2 it's sort of immaterial to the term sheet; right. I don't think

3 you're going to put it in the term sheet to the Secretary. If

4 this, then Secretary you need to do that; right? 

5 MS. DICKENS: Because your analysis won't be done until

6 after it's gone to the Secretary?

7 MR. HAGERMAN: Yeah, our analysis won't be done until

8 after the Secretary -- 

9 (Simultaneous conversation.) 

10 (Laughter.) 

11 MS. HOFFMAN: He's going to vote yes.

12 This is a major moment. 

13 Those of you in the remote places of the world, Mark Weiss

14 is voting yes. He's voting yes for dinner. No. Okay. So

15 we're moving ahead. But we can call them zones one and two, A

16 and B, zone two, and zone three. Okay. 

17 MR. HAGERMAN: So I think we have enough agenda. I'm just

18 looking over the agenda and looking over my PowerPoint that I

19 gave everybody which is sort of the scorecard; right? One of

20 the biggest outstanding things that we really need before we can

21 navigate folks and put together the term sheets when we get it

22 so I could either review it before it gets sent out tomorrow, is
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

252

1 the definitions. Right? The other stuff on the agenda today I

2 believe is more of external recommendations that are outside the

3 scope and the term sheet. Those are like the nice to have

4 things. Right. And we're happy to put, you know, we don't need

5 very much discussion on that; right? Because those are just

6 sort of outside the scope of the current term sheets. So if the

7 Secretary wanted to consider them, we can send them through the

8 rulemaking process or the working group has a recommendation to

9 extend this working group to deal with enforcement, we could

10 deal with it then; right? You know, change the kind of scope;

11 right? 

12 So that's why my recommendation is move the definitions. 

13 Let's spring through the definition and see if we can get

14 agreement with definitions, that pretty much concludes the term

15 sheet as I see it. And then we can just -- everybody, you know,

16 you can pull up that tool used to track all the ideas and start

17 making a mine map of all the other things that we can recommend

18 to the Secretary. And we don't really have to have that much

19 discussion on it in my opinion.

20 MR. RAMIREZ: Okay. So let's do this. Let's just take a

21 ten-minute break so I can pull up the documents that we need for

22 the definitions. And then we'll come back and we'll start -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

253

1 MS. HOFFMAN: Right and before we -- 

2 MR. KELLER: Could I ask one question first before we get

3 off this chart?

4 MR. RAMIREZ: Sure.

5 MR. KELLER: What is the door U values, and I'm not

6 suggesting we change them, but I need to ask a question. The

7 IECC doesn't have a requirement. Was that just for the

8 analysis? I mean, that's not a requirement, is it, a .40?

9 MS. HOFFMAN: Emanuel, do you want to answer?

10 MR. LEVY: Yep, you have the O value. You can use any

11 door you want. 

12 MR. KELLER: I just wanted to make sure. I don't know why

13 it's in the chart.

14 (Simultaneous conversation.) 

15 MR. LACEY: So it would be actually a lower U factor than

16 what's there.

17 PARTICIPANT: Do you want to speak up? Did you hear that?

18 MR. RAMIREZ: Go ahead, Eric.

19 MR. LACEY: This is Eric from RECA. In the IECC, doors

20 are part of fenestration. Doors and windows. And so the U

21 factor would be the same as for windows. So actually doors are

22 getting a break here. The IECC in every climate zone other than
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

254

1 the red, basically, your door U factor would have to be much

2 lower than what it is there. You'd have to be consistent with

3 the window.

4 MR. KELLER: Okay. That's fine. If we have the U value,

5 that's fine. I just didn't want to take that additional

6 requirement of some kind.

7 MS. HOFFMAN: Okay. Thank you. 

8 MR. LACEY: -- that approach and the area weighted

9 average, the windows and doors, and just have a single U factor

10 but this is the way -- 

11 MR. KELLER: Right. I just didn't want to eliminate wood

12 doors.

13 MS. HOFFMAN: Okay. Michael?

14 MR. ROY: I think Manny then Michael.

15 MS. HOFFMAN: Okay. 

16 MR. SANTANA: I don't think we can move on from the

17 prescriptive table without talking about the footnote. 

18 MS. HOFFMAN: Okay. Footnotes.

19 MR. SANTANA: They're pretty much critical to how the

20 prescriptive table will be used. You know, they set parameters.

21 MS. HOFFMAN: Okay. And about how long do you think will

22 be the discussion?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

255

1 MR. SANTANA: Well, it depends on who is in the room.

2 (Laughter.) 

3 MS. HOFFMAN: Okay. We've got -- just so you know in terms

4 of our timeframe. We've got obviously you're right, footnotes

5 for the prescriptive part. We also have definitions, Lois'

6 presentation, that's important too. And I guess we have an end

7 time today of six o'clock.

8 MR. HAGERMAN: Do you want recommendations?

9 MS. HOFFMAN: Yes.

10 MR. HAGERMAN: Since Manny chaired the IECC document

11 committee, maybe tonight you could write over a straw man of

12 what those footnotes should be; right? And then we could just

13 go through them. We hate to sit here and like, you know,

14 brainstorm footnotes that could or could not be on the table and

15 that's an endless discussion. We're done having endless

16 discussions. 

17 MS. HOFFMAN: So a suggestion is for Manny to come up with

18 suggested footnotes to present -- 

19 (Simultaneous conversation.) 

20 MS. HOFFMAN: -- tomorrow. Yes, Michael? Yes, Michael

21 Lubliner.

22 MR. LUBLINER: Maybe I could help him if he wants my help.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

256

1 MS. HOFFMAN: Maybe he wants the beer you mentioned

2 earlier. 

3 MR. LUBLINER: We may be able to establish the one

4 footnote that allows you the area weight solar heat gain

5 coefficient. Is that correct? 

6 MS. HOFFMAN: Excuse me? Could you repeat that?

7 MR. LUBLINER: I don't know if we voted on that or what,

8 but we established that one footnote to this will be solar heat

9 gain coefficient is averaged. It can be any average.

10 MS. HOFFMAN: I'm not certain, but definitely talk to

11 Manny so it will be mentioned.

12 MR. LUBLINER: Here it is. So I want to make sure that

13 that's one -- 

14 MR. RAMIREZ: So all of these are averaged?

15 MR. LUBLINER: Yeah, and then the other thing I want to

16 point out on footnotes is, I think it's important that whatever

17 the analysis assumed in the way of, for example, the insulation

18 density number of bags, slope, truss height for the ceiling or

19 any assumptions in the floor that Dave talked about, you know,

20 are we changing the frame, all those things need to be footnoted

21 or discussed as potential footnotes so we're clearly apples and

22 apples.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

257

1 MS. HOFFMAN: Mark.

2 MR. EZZO: I think the way to address what you're saying

3 is every one of those R values for those components had a U

4 value attached to it for calculation. So my suggestion to

5 Manny's committee would be, and I'm glad to sit on the

6 committee. 

7 MR. SANTANA: You're on the committee. 

8 MS. HOFFMAN: It's meeting at the bar? You know, the

9 committee is meeting after this meeting. Yeah. 

10 MR. EZZO: We'll go and find those U values that we used

11 for each of those components and put those in the table.

12 MR. LUBLINER: Absolutely. 

13 MR. EZZO: And so that's your prescriptive -- your pass. 

14 So for red ceiling, they'll say 30/U value is .047 or whatever

15 it is.

16 MR. SANTANA: I'll take it under consideration. 

17 (Laughter.) 

18 (Simultaneous conversation.) 

19 MR. KELLER: This is Bert.

20 MS. HOFFMAN: Oh, I'm sorry, Bert was next. Bert, please

21 speak.

22 MR. KELLER: Yeah, I was just wondering what happened to
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

258

1 Lubby's statement in one of the first meetings about U as what

2 it is and I know he and I discussed it or tried to discuss it

3 via e-mails, but he left me speechless just as he is doing it

4 again. You know, I can't see creating a set of prescriptive

5 requirements that are somehow attached to a U value. It doesn't

6 make sense because if we have to look at the U value and whether

7 it complies or not, then why have a prescriptive path?

8 MR. SANTANA: We'll work something out.

9 MS. HOFFMAN: Okay. 

10 MR. RAMIREZ: Okay. So Manny has some homework to do and

11 he will definitely keep in consideration your comments, Bert, as

12 he's putting it together. 

13 MS. HOFFMAN: Right. Right. Lubby, did you have another

14 comment? 

15 MR. LUBLINER: Just a response to Bert. I appreciate our

16 attempt to dialogue and that. I was just trying to keep it

17 simple. And that was a straw man that was early on in the

18 discussion because I was trying to get clarity as to whether or

19 not the incremental costs that are being proposed here

20 associated with these upgrades reflect what they reflect. Do

21 they reflect frame changing in trusses, or what? So I just want

22 to make sure that whatever we put in here for U value, I don't
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

259

1 care if it is the same as what was used in the analysis. That's

2 my important point.

3 And those U values came -- so you guys have those U values

4 that went into this. They could be put right in here and then

5 the question beyond what Mark is suggesting, which I totally

6 agree with, U values need to be next to nominal R in this table.

7 I'd like to understand -- go back to the notes and better

8 understand so we're clear as to what the density and what are

9 the assumptions that are made into that. But I don't know that

10 that's going to impact what we vote on. But I think it's

11 important that DOE be clear and establish what was meant. 

12 Because I saw a lot of distinctions. I saw somebody saying, you

13 know, up to 3.8 pounds per cubic foot of blown in the attic. I

14 heard another proposal and saw a proposal that assumed 2.6 is

15 the density. And this is a huge difference in terms of how many

16 bags go up in the attic and what it costs the consumer. So I

17 just want to make sure those things are all documented, that's

18 all I really meant.

19 MS. HOFFMAN: Thank you. What we think is we'll take a

20 five-minute, one function break. And when we come back Lois

21 will be leading a discussion on definitions.

22 Thank you.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

260

1 (Brief recess taken.)

2 MS. HOFFMAN: Let's formally get back. We have from now

3 until six o'clock today. And Lois and her committee want to

4 thank you, will lead us on definitions which will be part of the

5 term sheet. 

6 MR. RAMIREZ: And let me put out one incentive here. 

7 We're going to go through these -- Lois is going to take us

8 through the definitions and then we talked about dealing with

9 some recommendations that we wanted to make to the ASRAC

10 committee. And what I'm going to suggest is that we have a list

11 of some of them already. And so when Lois is done we'll put it

12 up there and then take a look at them. If you have any others

13 that you could think of, e-mail them to me before ten o'clock

14 tonight and I'll put them all together and then we'll start back

15 in the morning and we'll take a look at that and see what

16 recommendations we can agree to make going forward so that we

17 can -- and I think we're all in the same boat here. It's been a

18 pretty long day and you guys have been working really hard with

19 minimal breaks especially with the working lunch. So let's go

20 through the definitions and then we'll try to wrap it up from

21 there. 

22 MS. HOFFMAN: Right. And tomorrow it's an early day. We
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

261

1 start at eight in the morning and we'll be ending at noon. And

2 then a tour of NREL's energy systems integration facility from

3 one to two. That's optional. But I think -- do they need to

4 know how many people?

5 We'll check tomorrow morning.

6 We'll also be hearing tomorrow from Manny and his

7 committee on the footnotes and the term sheet. We'll be getting

8 that tomorrow too to put that together. So we want to

9 compliment you on all your hard work over all these many

10 meetings, both you here in person and the folks on remote. So

11 thank you.

12 Take it away, Lois.

13 MS. STARKEY: I volunteered to put together -- I put

14 together some definitions based on what we thought, based on all

15 of our conversations what needed to be in definitions. And I

16 basically used the HUD code, subpart F of the HUD code which is

17 the energy standards and of course the IECC 2015 definitions. 

18 And so sorry you don't have handouts of that is, but I just

19 started off with definitions. And I'm calling it subpart F, but

20 I think that needs to just be whatever it is that DOE, you know,

21 puts in when they make the suggestions. Obviously it's not

22 going to be R201 general. I just used subpart F because that's
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

262

1 subpart F of 3280 of the HUD code. 

2 And then the scope, I think we just are suggesting -- and,

3 by the way, I had basically the MHI members, manufacture members

4 on this committee work with me on this. So, it is just a draft.

5 So anyways, the first -- the scope, it's pretty self-evident

6 that we're just following the definitions as applicable to the

7 energy provisions of the code, or energy efficiency provisions

8 of the code. So if we want to change that subpart F, we can,

9 but I think you understand that that's the intent. 

10 Interchangeability, we didn't change anything from the

11 IECC. We removed 201.3 because we just thought DOE could define

12 after we get the entire proposed rule made, after the term sheet

13 is made and DOE can identify which codes that aren't defined,

14 but are defined in other codes. 

15 Retained the current R201.4 under general definitions. 

16 Above grade wall, we just took that out because we are only

17 talking about -- 

18 MR. RAMIREZ: I'm sorry, Lois, hold on one second. 

19 MS. STARKEY: Yes.

20 MR. RAMIREZ: So is everyone okay with the first grouping

21 there of R201? Could I see a show of thumbs for okay?

22 MR. WEISS: Just a quick question.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

263

1 MR. RAMIREZ: You have a question? Yeah, I'm sorry.

2 MR. WEISS: I assume you did this but I want to make sure,

3 did you check to see if any of the defined terms are already

4 defined in the HUD standards and regulations?

5 MS. STARKEY: Yes. Yes.

6 MR. RAMIREZ: Thank you. Okay. R201 section there, let's

7 see a show of thumbs if you're okay with those recommendations.

8 (Showing of thumbs.) 

9 MR. HAGERMAN: Aside from correcting the Subpart F stuff?

10 MS. STARKEY: yeah.

11 MR. HAGERMAN: Definitions applicable to the term sheet.

12 MR. LUTER: I'm sorry, Mark, say that again?

13 MR. WEISS: Nobody will believe me. There's visible

14 evidence -- 

15 (Laughter.) 

16 MR. RAMIREZ: All right. Let's see a show of thumbs if

17 we're okay with these recommendations on 201?

18 (Showing of thumbs.) 

19 MR. RAMIREZ: Okay. Anyone on line with a thumbs down? 

20 And I'd like to note that Mark was a yes. 

21 (Laughter.) 

22 MR. RAMIREZ: All right. So that's unanimous. All right.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

264

1

2 Next.

3 MS. STARKEY: So Section 202 we deleted the above grade

4 wall. We didn't think that was applicable to what we were

5 discussing in terms of this addresses issues outside the home

6 itself. So we proposed to delete that because the home is built

7 in a factory. We retained accessible. We removed "addition"

8 because again we're only talking about the home that's built in

9 a factory, not something that's added on site, and not under the

10 scope of our responsibility here. 

11 We retained "air barrier" as the same as in the IECC. We

12 removed "alteration" again because we're only talking about new

13 construction and the home itself that's built in a factory. The

14 same with "approved" code official because that's outside the

15 scope of what's done in a factory. The same with "approve

16 agency". 

17 We retained "automatic". We deleted "basement wall" for

18 the reasons discussed previously that it's not a part of our

19 scope.

20 The same with "building" but we did, as you'll see

21 further, we did define what a manufactured home is. The same

22 "building site" we didn't think that was applicable to our
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

265

1 discussion. "Building thermal envelope" we retained this with

2 no changes. The same with "C factor" thermal conduits, the same

3 with "circulating hot water systems".

4 MR. RAMIREZ: Lois, there's a question. 

5 MR. UNGAR: Buildings are more envelope, it looks like it

6 begins with a comma, is that -- 

7 MS. STARKEY: I don't think so. Let me just -- oh, maybe

8 I took out -- 

9 MR. UNGAR: You might want to take that for later. I

10 assume they may need to be -- 

11 MS. STARKEY: Yeah, just take the comma out. I might -- I

12 will have to look. Yeah, basement. Yeah, that's what I took

13 out. I'm sorry. It should -- yeah, basement walls, so it

14 should -- that should have been underlined. Yeah. Apologize. 

15 MR. UNGAR: Something struck out.

16 MS. STARKEY: Yeah. If you wanted to change that. 

17 (Simultaneous conversation.) 

18 MS. STARKEY: So basement walls, which is in the current

19 IECC, I struck out. So we might want to just make a note to add

20 "basement walls" and then strike it out. 

21 MR. UNGAR: Okay. 

22 MR. LUBLINER: Lois, I notice that there's a different --
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

266

1 there's a thermal envelope area definition on manufactured

2 housing standards. I think a tenth is the same thing, just a

3 little different. 

4 MS. STARKEY: Yes, that's correct. We just took -- 

5 (Simultaneous conversation.) 

6 MR. LUBLINER: -- the definition of thermal envelope area

7 here as opposed to building thermal envelope. Just a little

8 different wording.

9 MS. STARKEY: Yeah, we just made a -- I just made a

10 judgment that we just take the ECC, it's the current code, but

11 in looking at the two definitions, they were essentially the

12 same.

13 PARTICIPANT: Where are you Mike?

14 MR. LUBLINER: I see 328502 definition in A1 or A2, excuse

15 me.

16 PARTICIPANT: 502A2?

17 MR. LUBLINER: Yeah, A2.

18 MR. RAMIREZ: So let me ask the group this, do we need to

19 make all the edits or -- because I'm hearing that you might have

20 mixed some things together here. Do you want me to put area on

21 here and then strike it out?

22 MR. LUBLINER: I'm good with what she's -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

267

1 MS. STARKEY: Well, no, no, because that -- yeah, I took

2 -- I basically took the IECC code and I may have put that at the

3 bottom of this document. And I should have mentioned that. I

4 have added things that were in the HUD code that we felt needed

5 to be retained. Those are underlined in red. And I've struck

6 out items that are in the current IECC that we don't need. So

7 -- 

8 MR. RAMIREZ: Okay. 

9 PARTICIPANT: Hey, Lois?

10 MS. STARKEY: Yes.

11 PARTICIPANT: Suggestion, your microphone, if you put it

12 up closer to your -- 

13 MS. STARKEY: Thank you. Technology is not one of my

14 strong points here. Okay. 

15 MS. DICKENS: Javier?

16 MR. RAMIREZ: Yes, Ishbel?

17 MS. DICKENS: I didn't realize we were commenting as we

18 went through. I thought we were waiting until we got to the end

19 of the section. Because there were a couple of things a little

20 earlier if you could scroll down, not that far. It's between

21 the A's and the B's. Thank you. 

22 Where was it? It was something that I saw. Oh, yeah,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

268

1 approved, approved and approved agency. I thought I heard in

2 one of our earlier conversations that there may be some

3 in-factory testing at some point either by DOE or HUD, and I

4 don't know that that ever got resolved and so I'm wondering if

5 that ought to just stay in there in case there is at some point

6 any kind of in-factor inspection?

7 MR. HAGERMAN: I think too if, you know, once we start 

8 once this group continues to deal with enforcement

9 certification, I'm sure there are other definitions -- 

10 (Simultaneous conversation.) 

11 MS. DICKENS: Okay. So something could go out now, it

12 might come back in later in some format or other?

13 MR. HAGERMAN: Just like I'm sure as we're taking the term

14 sheet and turning it into a rule, there is no way we contemplate

15 that we finally go in and we have the rule is going to deal with

16 and have other things to add to that.

17 MR. RAMIREZ: Mark.

18 (Simultaneous conversation.) 

19 MS. STARKEY: I guess we were on climate zone. We

20 retained the definition as in the IECC. Removed "code official"

21 but we have added -- 

22 (Microphone squealing.)
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

269

1 (Pause.)

2 MS. STARKEY: We did add DOE, the definition for DOE. And

3 I think like Joe said, with code official, I mean, I think when

4 we get into enforcement and compliance, I mean, you'll have, you

5 know, third-party design approval agents and inspectors that

6 will want to be -- you'll want to define those terms. Those are

7 defined in the HUD code outside of the current -- of the HUD --

8 of the energy efficiency provisions in the HUD code. 

9 Retained condition floor area, this might be one that you

10 want to take a look at based on our previous conversations with

11 respect to the underbelly, blah-blah-blah, several meetings ago.

12 But we retained the IECC definition. The same with condition

13 space. Same with continuous air barrier and continuous

14 insulation. We retained crawl space. We took out curtain wall.

15 And I think the reason is we defined fenestration some in other

16 areas. Didn't think this had any bearing on our discussions,

17 but I would defer to the fenestration expert in the room.

18 MR. LUTER: Which one? Curtain wall is not relevant. So

19 discussion -- 

20 MR. LACEY: We don't see those too often.

21 MR. LUTER: No. High end stuff up in Lubby's

22 neighborhood.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

270

1 MS. STARKEY: We retained demand recirculation water

2 system, duct system. And dwelling unit, I think -- I don't have

3 any -- I think we restruck this because it's in the current HUD

4 code. But if you want to keep it because you're doing a

5 separate, you know, rule here, then I would suggest keeping it. 

6 But I think the reason why we struck it was because it's already

7 in the HUD code. But I think I would probably say to keep it

8 now that I'm looking at it again.

9 MR. KELLER: This is Bert.

10 MS. STARKEY: Yeah. Bert?

11 MR. KELLER: This is Bert.

12 MS. STARKEY: Yeah.

13 MR. KELLER: Yeah, dwelling unit as its defined here is

14 like for an R2 or an R1 system which we don't have. So that

15 should just go out.

16 MS. STARKEY: But -- 

17 MR. KELLER: It doesn't have any place in here.

18 MS. STARKEY: So even though there is a definition of the

19 -- I guess but there is a definition that is pretty close in the

20 HUD code, right, of dwelling unit. I think it's -- 

21 MR. KELLER: Well, what we're talking about here is a

22 dwelling unit inside like a multifamily unit which we're not
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

271

1 dealing with. We're a single-family only. So that just can

2 come out.

3 MR. TOMPOS: Dave Tompos from NTA. I would highly

4 recommend we stick with the definition in the HUD code. 

5 MR. WEISS: Yes, this is not the same, so -- 

6 MR. RAMIREZ: Suggestion that you strike it; is that what

7 you're saying, David?

8 MR. TOMPOS: Yes, I think to strike it.

9 MS. STARKEY: And the current definition in the HUD code

10 just for your information is, "one or more habitable rooms which

11 are designed to be occupied by one family with facilities for

12 living, sleeping, cooking, and eating."

13 PARTICIPANT: Pretty close.

14 MS. DICKENS: I would ask that we switch it around and put

15 -- 

16 MR. KELLER: It's not the same though. It's not the same,

17 guys. It's not the same.

18 MR. WEISS: It's not the same. And I don't know why -- 

19 MR. KELLER: That's why it needs to come out.

20 MR. WEISS: -- different definition here.

21 MS. STARKEY: And then the question becomes, do you want

22 to include in these definitions the definition in the HUD code?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

272

1 MR. RAMIREZ: Well, let me ask though, are we going to be

2 adding a lot of stuff that's in the HUD code? Because I heard

3 you say already that there was something you didn't address

4 because they were in the HUD code. 

5 MS. STARKEY: That's right. Because they weren't

6 applicable to the discussion. 

7 MR. RAMIREZ: Okay. 

8 MS. STARKEY: Yeah.

9 MR. WEISS: That's existing law, you know, as long as you

10 don't contradict it in here, you don't need to put it in. It's

11 on the books.

12 MR. RAMIREZ: So let me see a show of thumbs on this one,

13 if you're okay with striking "dwelling unit"? We'll get all of

14 it, but I just want to make sure since there was some discussion

15 on this. A show of thumbs of striking dwelling units okay?

16 (Showing of thumbs.) 

17 MR. RAMIREZ: Anyone on line with your thumbs down?

18 (No response.)

19 MR. RAMIREZ: Okay. That's unanimous. Okay. Lois.

20 MS. STARKEY: Okay. Then we added a definition for DOE. 

21 I guess we probably would want to say the U.S. Department of

22 Energy. I don't know. Yeah, it doesn't matter. I mean,
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

273

1 they'll do what they -- 

2 MR. WEISS: The lawyers will clean this up.

3 MS. STARKEY: Yeah. Right. 

4 Retained energy analysis, energy costs, energy simulation

5 tool. I don't know why that's -- 

6 PARTICIPANT: The word "approved"? Leave the word

7 "approved" in there?

8 MS. STARKEY: Yeah, that was a question I had and I think

9 we ended up keeping it.

10 MR. RAMIREZ: I'm sorry, where are we again?

11 MS. STARKEY: Under "energy simulation tool". 

12 MR. RAMIREZ: Got you.

13 MR. HAGERMAN: Under the discussion when we were talking

14 about software to do the U value calculations and whatnot there

15 was discussion that there was software that was developed and

16 DOE approved it, that was back and forth, DOE and HUD would have

17 approved it. HUD just approved it. That's when we said we

18 can't force HUD to do things. So I think you can put a DOE

19 approved software. 

20 PARTICIPANT: Agreed.

21 MR. HAGERMAN: You don't want people self-approving your

22 software. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

274

1 MR. LUBLINER: So that's clarification. So that would

2 allow -- and if you guys get this REScheck thing going what Mark

3 wanted to do his own beacon and just run it through.

4 MR. HAGERMAN: Or if some third party wanted to sell you

5 that as a service or something. 

6 MR. RAMIREZ: Mark?

7 MR. WEISS: I agree with Joe, you have to clarify some of

8 that because we're striking the defined term "approved" that's

9 in there. But I don't necessarily agree that it would just be

10 OE for the reasons stated previously.

11 MR. HAGERMAN: I was close to getting a positive vote.

12 MR. RAMIREZ: So just to be clear for the record, let's

13 look at energy simulation tool as proposed here. Let's do a

14 show of thumbs if you're okay with it.

15 (Showing of thumbs.) 

16 MR. RAMIREZ: Anyone on line with your thumbs down?

17 (No response.) 

18 MR. RAMIREZ: All right. Let the record show that there

19 were two no votes on that one, Rob Luter and Mark Weiss. 

20 MR. LUTER: My concern is the sole authority approving. 

21 There are a number of accreditation bodies out there. Does DOE

22 approve --
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

275

1 (Audio interference.)

2 MR. LUTER: -- software? Do they come to you for your

3 sign off on it?

4 MR. HAGERMAN: In our statute, our authority to oversee a

5 standard we in most cases -- I think in all cases we approve the

6 software.

7 (Simultaneous conversation.) 

8 MR. LUTER: Okay. I wanted to make sure -- 

9 MR. HAGERMAN: The tax deduction we allow or the

10 government allowed software to be used and it was DOE approved. 

11 So there is a DOE attached to it.

12 MR. LUTER: I don't want to exclude tools just by virtue

13 of you having approved it. If not, there's a mechanism for you

14 to review and approve, that's fine. 

15 MS. HOFFMAN: Mark?

16 MR. KELLER: This is Bert.

17 MS. HOFFMAN: Go ahead, Bert.

18 MR. KELLER: Hello? Yeah, Joe, if I wanted to use my heat

19 loss program which I'm pretty proud of, do you have to approve

20 it?

21 MR. HAGERMAN: If you're just using it to generate your Uo

22 values then we don't usually approve that. I think this was --
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

276

1 I forget where this -- 

2 (Simultaneous conversation.) 

3 MR. EZZO: Any simulated performance alternative. 

4 PARTICIPANT: Yeah, it's to the rating.

5 (Simultaneous conversation.) 

6 MR. SANTANA: Yeah, but this is for projecting annual

7 energy use of the building. That's not what -- you know, our

8 accounts are to come up with a Uo value. 

9 PARTICIPANT: It should be struck then.

10 MR. KELLER: That's true.

11 MR. HAGERMAN: I'm not sure we ever used energy

12 simulation.

13 MR. RAMIREZ: Lowell then Michael.

14 MR. HAGERMAN: Compliance path having some other

15 compliance path, right. We had prescriptive, U value and some

16 alternative. We got rid of the alternative. I think this is

17 where -- this more before the alternative fact. So I think you

18 just strike it and move on. 

19 MR. RAMIREZ: Let me get Lowell then Michael. 

20 MR. UNGAR: I think for energy analysis, energy cost and

21 energy simulation tool, I agree it's used for a performance path

22 that we haven't discussed including -- that said, in the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

277

1 labeling, which we haven't talked about yet in the proposal, it

2 is relevant, actually. So, yeah, once we discuss that we might

3 come back.

4 MS. STARKEY: I think I left it in because of the

5 discussion we had on the possibility of developing some sort of

6 a tool that would allow the industry to take a performance path.

7 And I would think that, you know, maybe it didn't happen and

8 somebody else had the tool, I guess DOE would still have to

9 approve it. So I guess -- 

10 MR. HAGERMAN: You're going to get used to generating

11 labels. I think we would want to leave it.

12 MR. LUBLINER: That was my comment. If we come to that

13 point and we're actually going to put on the labels some sort of

14 annualized energy use, then that is definition would be really

15 important. 

16 MR. HAGERMAN: There's no harm in leaving it right now.

17 MR. LUBLINER: So let's leave it in and if we decide we're

18 not going to do that, we can discuss whether -- 

19 MR. RAMIREZ: All right. So then there were two no votes

20 on it, Mark Weiss and Rob Luter, everyone else was okay with

21 leaving it in. So we're leaving it in. Next.

22 MS. STARKEY: We deleted ERI reference design. I don't
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

278

1 even know what that is, but it didn't seem to be relevant. 

2 Maybe somebody else has another approach. 

3 Exterior wall, we added that. Separate walls that

4 separate interior space from the outdoors and deleted "including

5 both above-grade walls and basement walls" primarily for the

6 purposes discussed previously that we're really only concerned

7 about the home itself. 

8 We retained fenestration and fenestration product. We

9 deleted "site built" but I guess the question is, if "site

10 built" means that there's some sort of a product that somebody

11 designs that aren't classified as either vertical fenestration

12 or skylights that they need to be defined. So I don't know have

13 any great feeling either way. If site built means that these

14 fenestration products are built like in the factory, you know,

15 or designed -- 

16 (Simultaneous conversation.) 

17 MR. LUTER: Typically they'll be KD, knocked down. 

18 They're too big to put on a truck, so they'll come in parts,

19 they'll be assembled on site and installed. That very rarely

20 occurs in a HUD code situation. 

21 MS. STARKEY: Right. 

22 (Simultaneous conversation.) 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

279

1 MR. KELLER: I agree, we should strike that.

2 MS. STARKEY: Strike the whole -- 

3 MR. KELLER: Take it out completely.

4 MS. STARKEY: Strike the whole fenestration product

5 MR. KELLER: Yeah.

6 MS. STARKEY: Okay. 

7 MR. WEISS: The last sentence refers to on site though. 

8 It's not.

9 MR. RAMIREZ: Let's get Eric, Michael, and then Lowell.

10 MR. UNGAR: I was going to say, strike the whole thing.

11 MR. RAMIREZ: Is that where everyone is going?

12 All right. Lowell.

13 MR. UNGAR: Question.

14 MR. RAMIREZ: What?

15 MR. UNGAR: So back to exterior wall.

16 MR. RAMIREZ: I'm sorry. You know what, let me see a show

17 of thumbs if we're okay with striking fenestration product.

18 (Showing of thumbs.) 

19 MR. RAMIREZ: Anyone on line with your thumbs down?

20 (No response.) 

21 MR. RAMIREZ: All right. Then we're going to go ahead and

22 strike that unanimously.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

280

1 So, Lowell, you want to go back to exterior wall?

2 MR. UNGAR: Yeah, I don't know if that is matters, but the

3 IECC definition going back to above-grade wall refers to a wall

4 that encloses condition and space. And I don't know that that's

5 necessarily the same as separating interior space from the

6 outdoors or whether it creates a problem if it's different. 

7 PARTICIPANT: -- wall separated from the outdoors.

8 MR. UNGAR: All right. Then I don't know what the

9 implications of that are. I'm pointing that out so that people

10 wiser than me can answer whether this is the right definition or

11 whether we should go back to -- 

12 PARTICIPANT: Lois, would you accept that?

13 MS. STARKEY: Yeah. Uh-huh. 

14 MR. RAMIREZ: What was that?

15 PARTICIPANT: (Off microphone.) 

16 MR. UNGAR: And then it specifically includes floor

17 spindles, peripheral edges of floors, roof and business knee

18 walls, dormer walls, gable end walls, walls enclosing a mansard

19 roof and skylight -- 

20 MS. STARKEY: Is that the 2015 version? I guess maybe I'm

21 looking -- because I only see walls including both above-grade

22 walls and basement walls. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

281

1 MR. UNGAR: I was skipping basement wall. I was going

2 back to the above-grade wall. Because this -- the IECC exterior

3 wall is an above-grade wall.

4 MS. STARKEY: Oh, you went back to the -- I see.

5 MR. UNGAR: Above-grade wall to say, okay, what is an

6 above-grade wall. 

7 MS. STARKEY: I see.

8 MR. UNGAR: And it had all that and I don't think -- 

9 MS. STARKEY: I don't think -- 

10 MR. UNGAR: -- we don't need all those.

11 MS. STARKEY: I don't think we need them. It's really

12 outside the scope of what we're, you know, it's not a site-built

13 -- but I -- does that work? 

14 MR. UNGAR: Could it separate the conditioned space from

15 unconditioned space?

16 MR. RAMIREZ: Conditioned space from?

17 MR. UNGAR: Yeah. Should it just be walls and enclosed

18 conditioned space? That's what the above-grade wall is. 

19 MR. KELLER: I'm good for that.

20 PARTICIPANT: From the outdoors.

21 MS. HOFFMAN: We don't need the outdoors? Its walls that

22 enclose conditioned space, period? 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

282

1 MR. RAMIREZ: Is everyone okay with that? Let me see a

2 show of thumbs on exterior walls, the changes that we just made

3 there. If everyone is okay with that. 

4 (Showing of thumbs.) 

5 MR. RAMIREZ: Okay. I don't see any thumbs down. Anyone

6 on line with your thumbs down?

7 (No response.)

8 MR. RAMIREZ: Okay. And we also did the fenestration. So

9 F factor.

10 MS. STARKEY: Yeah, we didn't think that was necessary for

11 reasons discussed previously. Same with heated slab. 

12 High-efficiency lamps, we just took out the provisions as they

13 relate to 40 lumens. We took out that because I think it just

14 related to historic buildings. 

15 (Pause.) 

16 MS. STARKEY: Well, actually it has three provisions, 40

17 lumens per watt for lamps, 15 watts or less. So, I don't know,

18 maybe we should keep that in. I don't know why. Maybe that was

19 just a typo.

20 MR. RAMIREZ: Lowell.

21 MR. UNGAR: You know, I think if you're looking at a CFL

22 or LED, you could have -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

283

1 MS. STARKEY: Yeah.

2 MR. UNGAR: -- the equivalent of a 60 watt or less, 40

3 watt -- 

4 MS. STARKEY: Yeah.

5 MR. UNGAR: -- incandescent lamp that would be under 15

6 watts. 

7 MS. STARKEY: Yeah, I think that was just a typo,

8 actually. There's deleted historic buildings, but I'm looking

9 at it and there are three efficacy requirements there. Historic

10 buildings. That was kind of a no-brainer. Infiltration -- 

11 MS. DICKENS: Lois, this is Ishbel. I wonder if there is

12 anywhere an old single wide with some fancy architectural

13 custom-made thing that might well be -- 

14 MS. STARKEY: Could be. 

15 MS. DICKENS: -- throughout the country or whatever. I

16 mean, it isn't going to impact one way or the other and why not

17 just leave it in, in case there is something. 

18 (Simultaneous conversation.) 

19 MR. UNGAR: I can't imagine with the build and disparate

20 buildings.

21 MR. RAMIREZ: Okay. So, again, we're keeping it struck?

22 MS. STARKEY: Retained infiltration definition, insulated
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

284

1 siding, and insulated sheathing.

2 Took out labeled since they -- that did not seem

3 applicable to our HUD code product. The same with listed. 

4 MR. UNGAR: For labeling did you use IECC?

5 MR. LACEY: I have a comment on that.

6 MR. RAMIREZ: Eric.

7 MR. LACEY: I had a comment on both of those labeled and

8 listed when we get there.

9 MR. RAMIREZ: Yeah, go ahead. That's where we are.

10 MR. LACEY: There's been a lot of blood spilled over these

11 two definition in the IECC. And there are a couple of scenarios

12 that have come up where an insulation manufacturer has this

13 great new product and they have kind of an effective R value and

14 it doesn't match the FTC label, but they go around and get a

15 code official to say, well, even though it's only rated at an

16 R11, you know, it has these other great qualities and I'll deem

17 it to be an R21. And likewise, you know, window manufacturers

18 sometimes they'll look at the center of glass U factor rather

19 than the assembly U factor. Or in Florida they're shipping

20 windows from other countries, from South America and using them

21 and they lack the label -- you know, the NFRC label that windows

22 typically have in this country. So I hate to throw those out
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

285

1 without seeing what the other definitions are. I'm sorry, I

2 didn't go through the HUD definition, so I don't know how

3 comparable they are. 

4 MS. HOFFMAN: I don't think we have any.

5 MR. LACEY: Either are significant requirements because

6 when you look at the sections related to the labeling of

7 insulation and windows and other things, the terms labeled and

8 listed are used in there. And I think those are kind of

9 important. 

10 MR. RAMIREZ: Lowell, did you have a comment?

11 MR. UNGAR: No, that answered my question.

12 MR. LUTER: Rob Luter, I would concur with Eric. I think

13 it's important that we at least visit these a little further,

14 not delete them. 

15 MS. HOFFMAN: So your proposal would be keeping these in,

16 labeling and listing at this point?

17 MR. LUTER: At this point without knowing exactly how

18 it's addressed in the current HUD code. I know there is

19 language to this effect in the HUD code. I don't have -- 

20 MS. STARKEY: It's short, there's one definition. It

21 means a label, symbol, or other identifying mark of a nationally

22 recognized testing laboratory, inspection agency, or other
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

286

1 organization concerned with product evaluation that maintains

2 periodic inspections of production of labeled equipment or

3 materials and by who's labeling is indicated compliance with

4 nationally recognized standards or tests to determine suitable

5 usage in a specified manner. 

6 MR. UNGAR: So essentially exactly what's up there?

7 MS. STARKEY: It's pretty close.

8 MR. UNGAR: Yeah. 

9 MS. STARKEY: And it's in the general definitions of the

10 HUD code.

11 MR. UNGAR: Is there a listed definition, Lois?

12 MS. STARKEY: I don't believe so. A listed or certified

13 means yes, that there is. 

14 Included in a list published by a nationally recognized

15 testing laboratory, inspection agency, or other organization

16 concerned with product evaluation that maintains period

17 inspection of production of listed equipment or materials and

18 whose listing states either that the equipment or materials

19 meets nationally recognized standards or has been tested and

20 found suitable for use in a specified manner. 

21 MR. LUTER: Based on that, I'll withdraw any concerns I

22 had about striking this.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

287

1 MR. RAMIREZ: Yeah, so it is another one of those things

2 that it's covered in the HUD code where we can delete it here

3 because it's covered there. 

4 PARTICIPANT: Do we import the language into this code, or

5 does that matter?

6 PARTICIPANT: We already addressed that in the books.

7 MR. RAMIREZ: Yeah, that was one of the things that we

8 were talking about before. It's in there, do we duplicate it?

9 (Simultaneous conversation.) 

10 MS. STARKEY: I mean, I think that's up for DOE to decide.

11 So, I mean, I think it's up to you guys. I don't really care. 

12 But I think ultimately DOE will decide. I think if I can speak

13 out of line, I think some provision I saw earlier that DOE had

14 proposed, they didn't have these definitions in their proposal. 

15

16 MR. RAMIREZ: So let me ask the group, what do you want to

17 do with this? Strike it according to the HUD, or leave it in?

18 MR. LUTER: I propose it be struck from this document

19 based on it already being in the HUD code essentially verbatim.

20 MR. RAMIREZ: The label was pretty close.

21 (Simultaneous conversation.) 

22 MS. HOFFMAN: Exactly. That's the only thing. There are
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

288

1 some words here in the listed that are different, that mean

2 something. 

3 MR. LUTER: I guess I didn't hear that. 

4 MR. RAMIREZ: Eric?

5 MR. LACEY: I mean, I don't think it would hurt to leave

6 it in there since labeled and listed are used in this code. I

7 don't know how this is going to be folded into the HUD code, if

8 it will be. I think I would be fine with using the HUD

9 definition in here, but I want to make sure that there is a

10 definition for labeled and listed in this document however it

11 comes out. Either one is -- 

12 MS. STARKEY: I'm fine with that.

13 MR. RAMIREZ: Michael.

14 MR. LUBLINER: I don't know if this applies here, but I'm

15 going to throw it out. There have been some issues with the way

16 HUD defines "listed" for heat-producing appliances that a lot of

17 people have an issue with. Its way too general. And so I have

18 some concerns. Until we change HUD's definition listing on

19 heat-producing appliances -- what I'm talking about is specially

20 approved for a HUD code home. 

21 But what happens is that you buy an electric water heater

22 and you have to get one with a special tag that says it's
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

289

1 approved for HUD. You buy a new innovative heating system

2 that's got to have a special tag approved for HUD. That was

3 never the intent of that HUD special listing. So maybe I'm off

4 on the wrong audience for that, but I think that there's general

5 agreement that that HUD listing constrains the ability of the

6 manufacturers to do things.

7 (Simultaneous conversation.) 

8 MR. TOMPOS: Michael, that's not part of the definition,

9 though. That's another objection of the HUD code. So I don't

10 think changing the definition is going to affect that at all.

11 MR. LUBLINER: Great. Thanks. That's what I needed. 

12 MR. TOMPOS: I would assume that we have one definition. 

13 I hate having two definitions unless they're exactly the same. 

14 So unless HUD can change -- or unless DOE can change the HUD

15 code definition, I would prefer to stick with the HUD

16 definition. 

17 MR. RAMIREZ: All right. So let's separate these. Right.

18 So the first one, the label I just put in there, use HUD

19 language. So whatever that is we'll cut and paste it and put it

20 in here. Right? How does that sound as far as the first part? 

21 We'll discuss listing in just a second. But does that sound

22 okay to everyone, using the HUD language in labeled?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

290

1 Show of thumbs?

2 (Showing of thumbs.) 

3 MR. RAMIREZ: Okay. Now, listed. Sounds like the

4 verbiage might be a bit different. So, what do you want to do

5 with the listed?

6 Yeah, Mark.

7 MR. WEISS: For one thing, you're using "code official"

8 which is another definition that we got rid of. So you would

9 have to make some sort of substitution for that. I can't read

10 the right-hand side of it. I don't know why they use the word

11 in the definition, but that's okay.

12 Yeah, I think you need to correct code official and take

13 out "code official".

14 MR. RAMIREZ: Where should that be?

15 MR. WEISS: Well, if you want overtime keep it consistent

16 with the way you did before would be DOE. Acceptable to DOE,

17 but of course I object to that.

18 (Laughter.) 

19 MR. WEISS: It's not my suggestion, but it could -- 

20 MR. RAMIREZ: I didn't hear it. Why don't we put DOE

21 right there?

22 MR. UNGAR: I think there was a suggestion to just use the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

291

1 HUD definition. Or did we use this language, it should be DOE. 

2 But -- 

3 MR. RAMIREZ: When she read it, it sounded like it was a

4 bit different than what was here. If you all want to use that,

5 that's fine. We'll do the same thing that we did right above and

6 put "use HUD language"; right? 

7 MR. LUTER: I would suggest we do that and perhaps put an

8 asterisk that when these documents are both reviewed that

9 someone reconcile the two nearly identical definitions. I think

10 the HUD language has served well for quite a while.

11 (Simultaneous conversation.) 

12 MR. LUTER: And we're not aware of any shortcomings in

13 it. 

14 MR. RAMIREZ: Well, if we didn't use HUD language, then

15 there would be no reconciliation there; right? 

16 MS. STARKEY: The language -- do you want me to read it

17 again? 

18 MR. RAMIREZ: Yeah.

19 MS. STARKEY: Included in a list published by a nationally

20 recognized testing laboratory inspection agency or other

21 organization concerned with product evaluation that maintains

22 periodic inspection of production of listed equipment or
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

292

1 materials and whose listing states either that the equipment or

2 material meets nationally recognized standards or has been

3 tested and found is suitable for use in a specified manner.

4 MR. RAMIREZ: That is pretty close actually.

5 MS. STARKEY: Yeah, it's just semantics.

6 MR. WEISS: Well, no, I mean, it's more liberal in the

7 sense it could be any nationally -- what was it national

8 accepted or nationally -- 

9 (Simultaneous conversation.) 

10 MR. WEISS: -- nationally recognized approach as opposed

11 to acceptable to DOE.

12 MS. DICKENS: Take a vote for that, would you, Mark?

13 MR. WEISS: I'm sorry?

14 MS. DICKENS: You would vote for that then, wouldn't you?

15 MR. WEISS: It's already there. I'm fine with that.

16 MR. RAMIREZ: So, do the same as above then, use HUD

17 language?

18 MR. LUTER: That would be my suggestion.

19 MR. RAMIREZ: Let me see a show of thumbs if you're okay

20 with doing the same for "listed" as we did above and use the HUD

21 language there. Let me see a show of thumbs.

22 (Showing of thumbs.) 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

293

1 MR. RAMIREZ: On line, any thumbs down?

2 (No response.)

3 MR. RAMIREZ: Okay. So low voltage lighting.

4 MS. STARKEY: That's retained in the IECC. Now, the other

5 two additions which have now been crossed out and I'm going to

6 have Bert address this because I added them actually because I

7 think it was somebody who Joe mentioned that we might need a

8 definition. So I just took them right out of the general

9 definitions of the HUD code. So we are being a little

10 consistent -- inconsistent by adding some definitions here that

11 are in the general definitions of 3280, but I thought they

12 needed to be here. 

13 So, Bert, if you have some reasons why they shouldn't be,

14 or give us the reason why they're crossed out. 

15 Are you there, Bert?

16 MR. KELLER: Well, because they're already defined in the

17 280. You mean manufacturer and manufacture -- 

18 MS. STARKEY: Yes. Yes. That's what I thought. 

19 MR. KELLER: They're already defined. No need to redefine

20 them again. And, again, all of those definitions only pertain

21 to subpart F.

22 MS. STARKEY: Yeah. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

294

1 MR. HAGERMAN: So the reason that I think you need to

2 define or you may consider defining manufacturers, a lot of

3 times we talk about just manufacture in general and we mean the

4 people -- you guys making the homes. And sometimes we say, you

5 need to go install the insulation per the manufacturer's

6 instructions. Well, which manufacturer, the home manufacturer

7 or the insulation manufacturer? So, I mean, we could probably

8 clarify that by putting insulation manufacturer more clearly in

9 the parts of the term sheet that talk about it. But that's the

10 only reason I thought you might need to call it out. 

11 I could see it could be confusing sometimes.

12 MR. RAMIREZ: I remember we had that discussion. Let's

13 get Rob and then Michael.

14 MR. LUBLINER: Yeah, I totally agree. We had that

15 discussion and it seems like there's still a little confusion

16 when it comes to are we installing this to the manufacturer of

17 the insulation or are we installing it to the manufacturer's

18 quality assurance -- I think it's important.

19 MR. RAMIREZ: Rob?

20 MR. LUTER: I would concur. I think if this is meant to

21 -- in this context, refer to the HUD code home manufacturer, it

22 should say that. If it's meant to refer to a manufacturer of a
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

295

1 component, or something like that, it should say that as well so

2 you can differentiate.

3 MR. RAMIREZ: Okay. So in this case they're talking about

4 the manufacturer of the home; correct?

5 MR. LUTER: Right. And in that case I might call that the

6 home manufacturer, the HUD code home manufacturer. And further

7 elaborate assembling HUD code manufactured homes.

8 MR. RAMIREZ: All right. So we're talking about keeping

9 it. 

10 MR. KELLER: This is Bert. It sounds like somebody is

11 talking in the background. I can't tell. But, we're the

12 manufacturer of the home. We're attaching a label to it, you

13 know, we're supplying, by the way, duplicate copies, all the

14 other appliances and all the other things that we install,

15 instructions with the home. So I don't know why that needs to

16 be a distinction.

17 MR. TOMPOS: My opinion would be we don't need to

18 duplicate definitions that are already in the HUD code. 

19 Manufacturer being one of them unless this is a separate code

20 that those definitions in the HUD code won't apply.

21 My other comment would be that I would recommend not

22 defining manufactured home unless DOE wants to deal with RVIA. 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

296

1 (Laughter.) 

2 MR. RAMIREZ: Yes, so I'm going to stay focused on the

3 first part, right? And again, I think the distinction is

4 they're just -- so when it talks about manufacturer everywhere

5 else that it's defining -- it's drawing a distinction between

6 the manufacturer of the home itself versus the manufacturer of

7 any of the components.

8 Is that the understanding of the folks?

9 (No response.) 

10 MR. RAMIREZ: So with that, let me see a show of thumbs if

11 you're okay with keeping in "home manufacturer" as drafted here?

12 (Showing of thumbs.) 

13 MR. RAMIREZ: Okay. And any thumbs down?

14 (No response.) 

15 MR. RAMIREZ: All right. Manufactured home are you all

16 good with keeping that struck?

17 (Pause.) 

18 MR. RAMIREZ: Lowell?

19 MR. UNGAR: We seem to go back and forth as to whether we

20 need to include definitions that are also in the HUD code.

21 MR. RAMIREZ: Yeah.

22 MR. UNGAR: We don't know whether this is going to be part
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

297

1 of the HUD code or not. It seems to me it's safer to leave them

2 in for now and then if it is, they can be deleted. But -- 

3 MR. WEISS: Well, this is also for the general provision

4 in saying that, you know, the definitions used herein are

5 similarly defined in the HUD standards and regulations by the

6 same meaning.

7 MR. UNGAR: But we haven't -- 

8 MR. WEISS: That's the simplest way to do it.

9 MR. HAGERMAN: They're sort of like all subjects our

10 general counsel's office, as they read the final standards and

11 this isn't properly defined. I think this section in particular

12 is one that, you know, we're going to copy the Uo values and

13 other values that we come up with. This section will probably

14 change, right, once our lawyers get ahold of it. So I think

15 we're spending a lot of time on it and I'd like to vote that we

16 see if we can't wrap it up in the next three minutes. 

17 MS. STARKEY: We are almost -- we are halfway through the

18 alphabet. 

19 MR. RAMIREZ: All right. 

20 MS. STARKEY: I'll tell you what and there's hardly

21 anything added. I think pressure envelope is going to be the

22 last big thing.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

298

1 MR. RAMIREZ: Well, let's look at it.

2 (Pause.) 

3 MS. STARKEY: Is everybody okay with that?

4 MR. RAMIREZ: Michael, you had a question or a comment?

5 MR. LUBLINER: I know there was some confusion about where

6 the pressure envelope was at the floor. I'm not suggesting we

7 need to discuss that now, but just get this definition right. 

8 But I do think at some point when we get into the enforcement

9 and compliance discussion it will be appropriate to do that.

10 MR. RAMIREZ: Mark?

11 MR. WEISS: I can just see problems down the road with

12 what does limit leakage mean? How limited is limit? And

13 interior skin, unless that's a term of art for you guys, I don't

14 know what that means. Unless you define it somewhere else. 

15 You've used other terms, interior this, interior that. I just

16 don't remember "skin".

17 MR. RAMIREZ: Let me see a show of thumbs if you're okay

18 with this definition of pressure envelop?

19 MR. HAGERMAN: Is that really similar to the HUD code

20 definition?

21 MS. STARKEY: I think -- and Bert correct me -- I think

22 this was when we were doing our own -- 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

299

1 MR. LUBLINER: It's identical. It's identical to the HUD

2 code. 

3 MS. STARKEY: -- update. 

4 MR. LUBLINER: The pressure envelope means that the

5 primary air barrier surrounding the living space which serves to

6 limit air -- in construction using ventilated cavities, the

7 pressure envelope is the interior skin.

8 MR. RAMIREZ: So, I heard air was missing right here. 

9 (Simultaneous conversation.) 

10 MR. RAMIREZ: I'm sorry, what was that? Right here?

11 MS. STARKEY: Yeah, that's in subpart F.

12 MR. TOMPOS: Dave Tompos, and I apologize -- 

13 MR. KELLER: We could go on and on about this. 

14 MR. TOMPOS: I'm assuming that because we say in

15 construction using ventilating cavities the pressure envelope is

16 the exterior skin.

17 MR. RAMIREZ: Interior.

18 MR. TOMPOS: If we say if it's an unventilated cavity,

19 does that mean we can use the exterior skin?

20 (Laughter.) 

21 (Simultaneous conversation.) 

22 MR. RAMIREZ: -- that's what that means.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

300

1 MR. TOMPOS: Okay. That's all I wanted to know.

2 MR. RAMIREZ: Yes.

3 MR. TOMPOS: That was my understanding also. So I just

4 wanted to make sure. 

5 MR. KELLER: Apply that to the floor and Lubby's theory

6 goes to the -- what 15th century or something like that. 

7 MR. RAMIREZ: Michael, do you have something?

8 MR. LUBLINER: I would recommend that DOE sit down with

9 the building science group and HUD's building science group and

10 adequately make sure that your definition of pressure envelope

11 in the floor is the same as theirs. And I think the distinction

12 really has to do with what's the primary or the secondary. And

13 we'll discuss your other comments off line.

14 MR. RAMIREZ: All right. But the definition you're

15 saying, the primary, though, so let me see a show of thumbs if

16 you're okay with this proposed language?

17 (Showing of thumbs.) 

18 MR. RAMIREZ: Okay. 

19 MR. SANTANA: One comment. When we were working through

20 the tightness of the envelope, I remember that we went through

21 pains to try to avoid the term "pressure envelope" because it

22 wasn't currently defined in the IECC. Was that "pressure
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

301

1 envelope" or was that another term?

2 PARTICIPANT: Thermal envelope.

3 MR. SANTANA: Which one wasn't in the IECC?

4 (Simultaneous conversation.) 

5 MR. SANTANA: It was this one here?

6 PARTICIPANT: You pick it, I don't know.

7 MR. RAMIREZ: Well, would this define it.

8 (Simultaneous conversation.) 

9 MR. SANTANA: I remember that we went through a great deal

10 to try to avoid this term. You know, so I think including it

11 now -- if we had a need to include it, we would have included it

12 then. So I think we might be introducing problems. A motion to

13 strike.

14 MR. HAGERMAN: Let's take a vote, a motion to strike.

15 MR. RAMIREZ: Let me see a show of thumbs to strike.

16 (Showing of thumbs.) 

17 MR. RAMIREZ: Anyone on line with your thumbs down?

18 (No response.) 

19 MR. RAMIREZ: All right. Move on.

20 MS. STARKEY: Okay. Proposed design, rated design, readily

21 accessible, we took out -- 

22 MR. WEISS: Comment on that.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

302

1 MS. STARKEY: Yeah.

2 MR. WEISS: Readily accessible, I had proposed striking

3 that area of definition of accessible and that's very loose

4 terminology and could be done -- anticipating consequences.

5 (Simultaneous conversation.) 

6 MR. WEISS: It's either accessible or it's not. 

7 MR. HAGERMAN: Are those energy consuming liners?

8 (Laughter.) 

9 MR. WEISS: Yeah, how quick is quick? You know, it's just

10 -- 

11 MR. RAMIREZ: Let me see a show of thumbs for striking

12 "readily accessible"?

13 MS. DICKENS: Well, I just want to point out that in an

14 earlier definition of accessible it says, "see readily

15 accessible".

16 (Laughter.) 

17 MS. DICKENS: I'm sorry, I mean, being the lawyer in the

18 room right now. 

19 (Laughter.) 

20 MR. UNGAR: Do we know if this term is used or not?

21 MR. RAMIREZ: There's accessible.

22 Nice, Ishbel.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

303

1 (Laughter.) 

2 MR. RAMIREZ: So with that, we would have to keep "readily

3 accessible" then.

4 MS. STARKEY: Just strike "see readily" -- yeah.

5 (Simultaneous conversation.) 

6 MR. RAMIREZ: Okay. So we're striking that and going back

7 to "readily accessible".

8 (Pause.) 

9 MR. RAMIREZ: Let me see a show of thumbs for okay, we're

10 striking "readily accessible". 

11 (Showing of thumbs.) 

12 MR. RAMIREZ: All right. Anyone on line with your thumbs

13 down? 

14 (No response.) 

15 MR. RAMIREZ: Okay. Moving on.

16 I'm sorry, Lowell?

17 MR. UNGAR: Rated design looks to me like it's only used

18 for energy rating index which we don't have. So I would strike

19 it unless there's something -- 

20 MR. RAMIREZ: You said we could strike that? Let me see a

21 show of thumbs if you're okay with striking "rated design"?

22 (Showing of thumbs.) 
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

304

1 MR. LUBLINER: Proposed design too can be crossed out.

2 MR. RAMIREZ: All right. Show of thumbs for striking both

3 of those? 

4 (Showing of thumbs.) 

5 MR. RAMIREZ: Anyone on line with your thumbs down?

6 (No response.) 

7 MR. RAMIREZ: All right. Residential building. 

8 MS. STARKEY: All those down to R value didn't seem to be

9 applicable. 

10 MR. UNGAR: Do we know how roof assembly was used?

11 MR. HAGERMAN: I think we always just talk about roof

12 installation. I don't think we ever talk about roof assemblies.

13 MR. LACEY: I think that's related to the roof repair,

14 recovery, replacement, and these sections. Typically it's a

15 commercially focused section. That's the only context I can

16 think of for that. 

17 MR. LUBLINER: It's like for substantial remodels where

18 they have to use -- 

19 MR. RAMIREZ: So nothing objectionable with those strike

20 throughs it sounds like. R value.

21 (Pause.) 

22 MS. STARKEY: I debated about whether to delete "sun room"
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

305

1 because it is generally an add-on. 

2 MR. RAMIREZ: Let me see a show of thumbs if you're okay

3 with striking "sun room".

4 (Showing of thumbs.) 

5 MR. RAMIREZ: Anyone on line with your thumbs down?

6 (No response.)

7 MR. RAMIREZ: Okay. Lowell.

8 MR. UNGAR: Standard reference design, we already deleted

9 "proposed design".

10 MR. RAMIREZ: So to remain consistent we have to strike

11 that as well?

12 MR. UNGAR: That's correct. 

13 MS. STARKEY: Yeah.

14 MR. RAMIREZ: A show of thumbs?

15 (Showing of thumbs.) 

16 MR. RAMIREZ: Anyone on line with your thumbs down?

17 (No response.) 

18 MR. RAMIREZ: Unanimous. 

19 MS. STARKEY: The thermal envelope is -- that's defined in

20 subpart F of the current HUD code. Would you like to keep it

21 in?

22 MR. HAGERMAN: Why do you feel the need in that definition
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

306

1 to sort of explain the calculation of that? The wall area is

2 measured by an outside wall, et cetera, et cetera.

3 MS. STARKEY: I'll defer to the experts.

4 MR. EZZO: Why did you add this in?

5 MS. STARKEY: It's in the current subpart F, I believe. 

6 MR. EZZO: It's not in -- okay -- 

7 MS. STARKEY: No, I just took it from subpart F, because

8 we talk about the thermal envelop all the time in subpart F. 

9 But as far as -- 

10 (Simultaneous conversation.) 

11 MR. RAMIREZ: So, Joe, are you thinking that this might

12 not be necessary, this line right here that's highlighted?

13 MR. HAGERMAN: Well, the reason I brought it up is, you

14 know, we heard today that Emanuel had a different Uo calculation

15 than Lowell, but there's two different methods. There's

16 somebody -- whatever the issue was, right. And it just reminded

17 me that calculation method we probably should settle on at some

18 point in time. Because we shouldn't come up with two different

19 number -- hold on. And so it just worries me that in that Uo

20 calculation is going to tell you how to measure a wall, we

21 think. Because we don't need a wall measurement definition

22 here. And then separately, you know, when you put it on the
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

307

1 table, we ground Uo calculation. 

2 MR. BARBOUR: Uo calculation was defined by Patel

3 (inaudible) - what's different is, I think, you've got slightly

4 different retaining factors and a little bit different

5 assumptions -- numbers, I can recreate yours if I tweaked a

6 couple things there. I think they've very small. The actual

7 calculation method has been defined by Patel, and I think

8 everybody uses that one. And we were going to reference that

9 anyway.

10 MR. HAGERMAN: Yeah, I think it's referenced in the

11 modeling assumption document, and the document. I remember

12 seeing the Patel 1992.

13 MR. RAMIREZ: Let me get Lowell, then Manny, then Eric.

14 MR. UNGAR: Somebody pointed out that we already had a

15 definition for building thermal envelop that we went through. I

16 would propose striking this one because we don't want two

17 different definitions of thermal envelope.

18 MR. HAGERMAN: Accept that one, reject the next one.

19 MS. STARKEY: Okay. Moving right along.

20 MR. RAMIREZ: Okay. So with the understanding that this

21 has already been defined. Let me see a show of thumbs if

22 everyone is okay with striking this one?
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

308

1 (Showing of thumbs.) 

2 MR. RAMIREZ: Okay. Anyone on line with your thumbs down?

3 (No response.)

4 MR. RAMIREZ: All right. Moving on.

5 MS. STARKEY: All these others I felt we needed to keep,

6 but -- 

7 (Pause.) 

8 MR. RAMIREZ: Eric?

9 MR. LACEY: There are no requirements for visible

10 transmittance as far as I know in this section of the code. I

11 don't think it hurts to leave it in there, but this is going

12 beyond the window label. But I don't think we set any

13 requirement. We can probably delete that one.

14 MR. RAMIREZ: So, do what with this?

15 MR. UNGAR: Delete it.

16 MR. RAMIREZ: All right. So let me see a show of thumbs

17 and I'm going to do a big one here from "thermal insulation down

18 to striking of the visible transmittance"; is everyone okay with

19 that? See a show of thumbs.

20 (Showing of thumbs.) 

21 MR. LUTER: One question.

22 MR. RAMIREZ: Yeah.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

309

1 MR. LUTER: We're striking it because it's already

2 defined somewhere else?

3 PARTICIPANT: No criteria.

4 MR. LUTER: Oh, no criteria. Okay.

5 MR. RAMIREZ: Anyone on line with your thumbs down?

6 (No response.)

7 MR. RAMIREZ: All right. Then we're moving on.

8 Last two, right?

9 MS. STARKEY: Last two, any comments?

10 It's after six.

11 MR. RAMIREZ: You know what, because we screwed up on the

12 technology we had to hold you over.

13 (Simultaneous conversation.) 

14 MS. HOFFMAN: So were the last two okay? In or out?

15 MR. UNGAR: Out of curiosity, did we define "climate

16 zone"?

17 MS. HOFFMAN: No. That probably should be defined.

18 MR. RAMIREZ: We agreed on what the climate zones were. 

19 MS. HOFFMAN: But there's no definition of "climate zone".

20 (Simultaneous conversation.) 

21 MS. HOFFMAN: Oh, here it is. Geographic region based on

22 climactic criteria as specified in this code.
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

310

1 (Simultaneous conversation.) 

2 MS. HOFFMAN: You may want to -- in this code, if this

3 code is the new code, the Department of Energy code, but if it's

4 a climate zone in the HUD code, it's a different answer. 

5 MR. HAGERMAN: Can I make a move, I think we're done with

6 this. 

7 (Chorus of yes.)

8 MR. HAGERMAN: I know we're trying to get out of here, if

9 we spend like two minutes of you all walking us through what we

10 need to do tomorrow since we only have a half day coming here at

11 eight. We want to expedite trying to get things done. I think

12 what you're going to see from us is now that we've got all this

13 settled on, we're going to take what we've gotten thus far and

14 put it in the term sheet. We're going to get you to review that

15 tonight and then you're going to have that first thing tomorrow

16 morning. And it should not be shocking to you; right? And

17 you're also not allowed to get buyer's remorse either.

18 But anyways, so you'll see the whole thing.

19 MS. HOFFMAN: Yeah, tomorrow Manny is going to -- and his

20 committee will be reporting out on the footnotes where

21 prescriptive. We'll also be talking about other recommendations

22 and we'll talk about labeling and some other aspect. We'll look
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

311

1 at the term sheets.

2 I'm trying to think. There will be a moment for public

3 comment as well. And I'm trying to think if there's anything

4 else. 

5 MR. RAMIREZ: Yeah, we'll start off with the public

6 comments since we're way over right now. And on the other

7 recommendations, what I'm going to do is we've identified a few

8 possible recommendations and what I'm going to do is I'm going

9 to e-mail that to you all. And then e-mail me back by 10

10 o'clock if there's anything else that you want to add onto this

11 list for recommendations for tomorrow. We're going to all bring

12 something tomorrow, we could try to expedite it a bit that way.

13 And, Manny, if you have whatever you have, e-mail it to me

14 and that way we could have it on there in the morning ready to

15 go for discussion.

16 On labeling, who is taking care of the labeling?

17 MS. HOFFMAN: Lowell and Lois.

18 MR. RAMIREZ: Okay. So are there documents related to

19 that that we're going to need to put up here for tomorrow?

20 MR. UNGAR: I sent one to you last night or this morning. 

21 MR. RAMIREZ: All right. Then just hang out for just a

22 couple minutes afterwards to make sure that I can identify it
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

312

1 and have that ready to go.

2 And then the term sheet. And I'm assuming you're going to

3 probably make some adjustments to that from what we've done

4 today?

5 MR. HAGERMAN: Yeah, I think we're going to make it as

6 current as possible. 

7 MR. RAMIREZ: Well, good. Mark, you had a question? 

8 MR. WEISS: Logistically, the same drill as today, or can

9 we keep the badge and come directly back here?

10 MR. HAGERMAN: You should be able to keep the badge and as

11 you drive in, you just show the badge to the security person.

12 MR. RAMIREZ: Do they need to check in the building, or

13 just come straight here?

14 MR. HAGERMAN: No, you come straight up here.

15 MR. RAMIREZ: Okay. 

16 MS. HOFFMAN: Okay. Well, thank you. 

17 MR. LUTER: We'll be driving up here tomorrow, any

18 different protocol? Just show them and they'll park us in

19 visitor parking or -- 

20 MR. CHRISTENSEN: Yeah, just stay in that left lane when

21 you come up to the gates and show them your visitor badge. Make

22 sure you hang onto that badge because you'll need it again in
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

313

1 the morning and they'll direct you to park over here in our

2 visitor lot and just walk straight up here. We'll have some

3 staff out here at the front door just like today to let you in.

4 MR. HAGERMAN: Could we all apologize to you, Dan, because

5 this is probably the most painful meeting you've had to sit

6 through. 

7 MS. HOFFMAN: We want to thank all of you. We'll see you

8 tomorrow morning at 8 a.m.

9 (Whereupon, at 6:15 p.m., the meeting was recessed to be

10 reconvened on October 24, 2014 at 8 a.m.)

11

12

13

14

15

16

17

18

19

20

21

22
Manufactured Housing Working Group 10/23/2014

Washington, D.C. Baltimore, MD Florida

Olender Reporting, Inc. (888) 445-3376 WORLDWIDE

314

1 CERTIFICATE OF REPORTER

2

3 I, Jordan Bruce, Professional Reporter, do

4 hereby certify that I was authorized to and did

5 technologically report the proceeding

6 and that the transcript is a true and correct

7 transcription.

8

9 I further certify that I am not a relative,

10 employee, attorney or counsel of any of the parties,

11 nor am I a relative or employee of any of the

12 parties' attorneys or counsel connected with the

13 action, nor am I financially interested in the

14 action.

15

16 Dated this 3rd day of November, 2014.

17

18

19 ______________________________

20 Jordan Bruce

21 Professional Reporter

22