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### Natural	Resources	Defense	Council • California	Energy	Commission	•

National Manufactured	Ho me	Owners	Association • National	Association of	State

Energy	Officials • Manufactured	Housing	Institute	•	Corporation	for	Enterprise

Development • Environmental	and Energy	Study	Institute • Systems	Building	Research

Alliance • National	Rural	Electric	Cooperative	Association • Washington	State

University	Ext	Energy	Program	• American	Council	for	an	Energy

- Efficient	Economy •

Northwest	Energy	E f ficiency Alliance • Responsible	Energy	Codes	Alliance

May 2 8 , 2014 (revised with an additional signer, and resent May 29,2014)

To: Members of the Appliance S tandards and Rulemaking Federal Advisory Committee

(ASRAC)

Sent via email to ASRAC Designated Federal Officer, ASRAC@ee.energy.gov

Re: Energy Efficiency Standards for Manufactured Housing

We are pleased that e nergy efficiency in manufactured housing is on the agenda for ASRAC’s

June 6 meeting, and are writing to express our support for ASRAC’s efforts on this topic.

As you may know, a draft Notice of Propos ed Rulemaking (NOPR) has been pending at the

Office of Management and Budget since 2011, and DOE published a Request for Information

(RFI) seeking additional information in June 2013. We note that the revised standards are long

overdue, and have been working jointly with diverse stakeholders following the RFI with the aim

of accel erating the process to a successful standard.

We believe that ASRAC is an appropriate mechanism to engage stakeholders in a discussion of

energy efficiency standards for manufactured housing, and to develop recommendations for

l ong overdue changes to the current standards. An ASRAC process would facilitate even

greater communication and importantly, also provide analytic support, both of which we believe

would be helpful to the timely resolution of remaining issues.

In order to ensure that an ASRAC process is as pragmatic and efficient as possible, we

recommend that DOE:

• Use the process for effective communication and data gathering, and for seeking

general consensus where possible for key elements of a standard and regulato ry

framework , e.g., including on U

- value , air infiltration, window specifications and

enforcement

.

• Establi sh and hold to a tight meeting schedule with a minimum of meetings , e.g., 2 two

day meetings to be concluded by September

.

• Consider using the draft NO PR and Technical Support Documents for opening

discussion , i.e., distributed in advance of the first meeting

.

• Commit a strong project leader and an ASRAC subcommittee that is comprised of a

balanced group, who have the time and expertise to serve in a mean ingful capacity;2 • Appoint a strong facilitator to ensure the effective flow of information, and restrict time

spent on repetitive or non

- germane discussion, and;

• Provide prompt, effective analysis (e.g., running scenarios through their cost

effectiveness, n ational impacts and other models in advance of meetings).

Thank you in advance for yo ur consideration , and we look forward to your further efforts.

Respectfully submitted,

Robin Roy Robert B. Weisenmiller, Chair

Natural Resources Defense Council Californ ia Energy Commission

rroy@nrdc.org Catherine.Cross@energy.ca.gov

David Terry Ishbel Dickens

National Association of State National Manufactured Home

Energy Officials Owners Association

dterry@naseo.org ishbel@nmhoa.org

Doug Ryan Carol Werner

Corporation for Enterprise Development Environmental and Energy Study Institute

dryan@CFED.org cwerner@eesi.org

Lois Starkey Emmanuel Levy

Manufactured Housing Institute Systems Building Research Alliance

Lois.Starkey@mfghome.org elevy@research

- alliance.org

Keith Dennis Michael Lubliner

National Rural Electric Cooperative Washington St ate University

Association Ext. Energy Program

K eith. dennis@nreca.coop LublinerM@energy.wsu.edu

Lowell Ungar Christopher Dymond

American Cou ncil for an Northwest Energy Efficiency Alliance

Energy

- Efficient Economy CDymond@neea.org

lungar@aceee.org

Eric Lacey

Responsible Energy Codes Alliance

Eric.Lacey@bbrslaw.com