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), Harry 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 both a production inspection primary inspection 

agency (IPIA) and as a design approval primary inspection agency (DAPIA) under the 

U.S. Department of Housing and Urban 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 responsibility of ensuring compliance with DOE’s energy 

efficiency standards because TRA already inspects for energy efficiency measures and 

inspects modular homes for compliance with the International Energy Conservation Code 

(IECC) in a number of states that have adopted the IECC. However, he mentioned that 

any additional fees for DOE plan review and inspection, as compared to the current HUD 

regulations for energy, would be the administrative costs to report to DOE. Mr. Tanger 

stated his clients are in the eastern United States, the southern states, including Alabama, 

and northern states, including Pennsylvania. He commented that, in many ways, his 

business is no different from a typical site-built code official department. 

Mr. Tanger also noted that TRA seldom conducts onsite inspections 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 reviews of homes under 

HUD’s process of allowing alternative construction. 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-five percent of manufactured homes from his 

client base are ENERGY STAR compliant and that manufacturers that choose to build 

ENERGY STAR compliant homes typically devote 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) version of the IECC. 

Mr. Tanger also estimated that eighty percent 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. Tanger further noted that the manufactured homes 
that TRA inspects generally use blanket systems in the floor and that considerable 

compression occurred with the blanket systems (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 also noted that TRA staff receives training from 

IBTS, HUD, and State Administrative Agencies. 

End of conversation.