To: File From: Michael Jensen, DOE GC-71 Date: July 27, 2010 Re: Ex parte discussion with T. R. Arnold & Associates, Inc.

On July 27, 2010, Michael Jensen (GC-71), Harr y Indig (EE-2J), Bob Lucas (PNL), and Dave Conover (PNL) spoke with Robert Tanger, President of T.R. Arnold & Associates. Inc. (TRA), on his company’s role as bot h a production inspection primary inspection agency (IPIA) and as a design approval pr imary inspection agency (DAPIA) under the U.S. Department of Housing and Urba n Development (HUD) manufactured housing

program.

First, Mr. Tanger explained that TRA conducts three different levels of IPIA-related inspections of manufactured homes and that manufacturers have the capability of issuing certification labels in ninety percent of TRA’s inspections. Mr. Tanger noted that manufacturers would not experience much of an increase in inspection fees if TRA were

to take on the additional re sponsibility of ensuring compliance with DOE’s energy efficiency standards because TRA already insp ects for energy efficiency measures and inspects modular homes for compliance with the International Ener gy Conservation Code (IECC) in a number of states that have adopted the IECC. However, he mentioned that any additional fees for DOE plan review a nd inspection, as compared to the current HUD regulations for energy, would be the administ rative costs to report to DOE. Mr. Tanger

stated his clients are in the eastern United St ates, the southern states, including Alabama, and northern states, includi ng Pennsylvania. He commented that, in many ways, his business is no different from a typical s ite-built code official department.

Mr. Tanger also noted that TRA seldom conducts onsite in spections of manufactured homes and does so only then in conjunction with a consumer complaint or via an SAA request. However, Mr. Tanger stated that TRA conducts onsite re views of homes under HUD’s process of allowing alternative construc tion. Mr. Tanger estimated that the cost for onsite inspections is $350 per home or inspection visit, on average. Mr. Tanger also

noted that most manufacturers build modular homes and that the production of modular homes had increased in recent years.

Mr. Tanger mentioned that, under the ENERGY STAR program, two percent of homes are inspected at the home site and that such inspections include blower door and duct blaster tests. He estimated that twenty-f ive percent of manufactured homes from his client base are ENERGY STAR compliant a nd that manufacturers th at choose to build ENERGY STAR compliant homes typically devo te the entire operations of a plant to building such homes. Mr. Tanger estimated that the cost for ENERGY STAR-related tests is in the range of $ 500 to $800 per house. Mr. Tanger guessed that most current manufactured homes regulated under the HUD program would meet the energy efficiency requirements found in the 2003 (or possibly the 2006) vers ion of the IECC. Mr. Tanger also estimated that eighty per cent of manufactured homes his company inspects are built with 2x6 walls with R-19 or R-21 insulation, including homes built at plants located in warm climates. Mr. Tange r further noted that the manufactured homesthat TRA inspects generally use blanket syst ems in the floor and that considerable compression occurred with the blanket syst ems (although noting that batt systems are used in homes designed to be installed over basements, which are becoming more popular) and that homes with window U-values of 0.35 to 0.27 were common in northern

climates.

Mr. Tanger also stated that TRA interacts with IBTS on a regular basis, but not as frequently in recent years. Mr. Tanger al so noted that TRA sta ff receives training from IBTS, HUD, and State Admi nistrative Agencies.

End of conversation.