1

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### U.S. Department of Energy 1

2

3

4

5


### Manufactured Housing Working Group 6

7

8

9



### 9:05 to 5:03 p.m. 10


### Tuesday, September 23 , 201 4 11

12


### 1000 Independence Avenue, S.W. 13


### Washington, D.C. 20585 14

15

16

17

18

19

20

21

222

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### APPEARANCES 1

2



### TED BANTLE , Federal Mediation 3


### JAVIER RAMIREZ, Federal Mediation 4



### J OSEPH HAGERMAN, DOE 5



### RICHARD MENDLEN , HUD 6


### ROBERT LUTER, Lippert Components 7


### STACEY EPPERSON, Next Step 8


### MARK EZZO, Clayton Homes 9


### RICK HANGAR, State of Colorado 10


### BERT KESSLER, Palm Harbor 11



### EMANUEL LEVY, SBRA 12



### PETER SCHNEIDER , Efficiency Vermont 13



### MANUEL SANTANA, Ca vco Industries, Inc. 14


### ERIC LACEY, Responsible Energy Codes Alliance 15



### ISHBEL DICKENS, NMHOA 16



### LOWELL UNGAR, ACEEE 17



### MARK WEISS, MHARR 18



### DAVID TOMPOS, MTA 19


### LOIS STARKEY, the Manufactured Housing Institute 20


### MICHAEL LUBLINER, Washington State University 21



### ROBIN ROY, Natur al Resources Defense Council 223

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### APPEARANCES (Cont'd) 1

2


### RICHARD POTTS, Virginia DHCD 3


### MATTHEW WALKER, Navigant 4


### EDWARD BARBOUR, Navigant 5


### KAVITA VAIDYANATHAN, DOE General Counsel's Office 6



### BRIAN SLOBODA, NREC A 7



### KEITH DENNIS , NRECA 8

9

10

11

12

13

14

15

16

17

18

19

20

21



### P R O C E E D I N G S 224

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### MR. BANTLE: Good morning, everybody. 1



### This is Ted Bantle with Federal Mediation. I 2


### just want to get started today. 3


### Like yesterday, we are going to start off 4


### with any introductions from members of the public 5



### that are in the room. 6



### MR. MENDLEN: Rick Mendlen with HUD. 7


### MR. BANTLE: Okay. And we will come back 8


### to public comment after these introductions. 9


### Okay. Any GoToMeeting participants? 10


### Who's on the GoToMeeting? 11



### (Pause.) 12


### MR. LUTER: Rob Luter with Lippert 13


### Components. 14


### MR. BANTLE: Yeah, members. 15



### MS. EPPER SON: Stacey Epperson with Next 16


### Step. 17


### MR. EZZO: Mark Ezzo, Clayton Homes. 18


### MR. HANGAR: Rick Hangar, State of 19



### Colorado. 20


### MR. KESSLER: Bert Kessler, Palm Harbor. 21


### MR. LEVY: Emanuel Levy, SBRA. 225

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### MR. BANTLE: Yeah, who was the last one? 1


### I apologize. 2



### (Pause.) 3



### FEMALE VOICE: Bert Kessler. 4


### MR. HAGERMAN: So, we heard Bert Kessler 5


### from Palm Harbor. We heard Richard Hangar, and 6


### then we also heard Emanuel Levy. 7


### MR. BANTLE: And Stacey Epperson. 8


### MR. HAGERMAN: Mark Ezzo, Rob Luter. 9


### MR. BANTLE: Are there any other working 10


### group members on the line? 11



### (Pause.) 12


### MR. BANTLE: Okay. Any members of the 13


### public on the conference line? 14



### MR. SCHNEIDER: This is Peter Schneider. 15


### I'm here as well. I was just muted. 16


### MR. BANTLE: No problem. Good morning, 17



### Peter. 18



### One final call for working group members 19


### or public on the line? 20



### (Pause.) 21


### MR. BANTLE: Okay. We will go around the 226

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### table next with the working group members. We'll 1


### start with Manny. 2


### MR. SANTANA: Manny Santana, Cavco Homes. 3


### MR. LACEY: Eric Lacey, Responsible 4


### Energy Co des Alliance. 5


### MR. HAGERMAN: Joe Hagerman, DOE. 6


### MS. DICKENS: Ishbel Dickens, National 7



### Manufactured Homeowners Association. 8


### MR. UNGAR: Lowell Ungar, American 9


### Council for an Energy Efficient Economy. 10


### MR. WEISS: Mark Weiss, Manufactured 11


### Housing Association for Regulatory Reform. 12



### MR. TOMPOS: Dave Tompos , MTA. 13


### MS. STARKEY: Lois Starkey, the 14


### Manufactured Housing Institute. 15


### MR. LUBLINER: Mike Lubliner, Washington 16


### State University Extension Energy Program. 17


### MR. ROY: Robin Roy, Natural Resources 18



### Defense Counci l. 19


### MR. POTTS: Richard Potts, Virginia 20


### Department of Housing and Community Development. 21


### MR. WALKER: Matthew Walker, Navigant. 227

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### MR. BARBOUR: Ed Barbour, Navigant. 1


### MS. VAIDYANATHAN: Kavita Vaidyanathan, 2



### DOE General Counsel's Office. 3



### MR. RAMIREZ: And Javie r Ramirez, Federal 4



### Mediation. 5


### So, let's go ahead and review the agenda 6


### that we have for today. It was modified from 7


### yesterday since we had a lot of dialog on the 8


### cost data. So after we do some public comment, 9


### then we'll see if there's any additional comm en ts 10


### from working group members. 11


### And then we're going to continue our 12



### discussion on the cost data. There were a number 13



### of items that were left in the air that there's a 14


### possibility that we could reach consensus on. So 15


### we'll pick up where we left off from yesterday. 16


### Then we have the subcommittee reports, 17


### and we'll start off with Stacey on the finance, 18


### then go to David on manufacturing, Manny with the 19


### 2015 IECC mandatory components, and then Rob Roy 20


### with affordability. 21


### Hopefully, at some point, before we le ave 228

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### today, see if we could take any additional 1


### action. See if we could agree on which climate 2



### zones we're going to use, the compliance paths 3


### one, two, three, or

-- and if you want to go down 4


### the path of multiple products, is that something 5



### that we need to figure out before we go? 6


### And then we'll do next steps after that. 7


### So, any questions on the agenda? 8



### (Pause.) 9


### MR. RAMIREZ: All right. Then comments 10


### from the public. 11


### Rick, I believe you had some comments? 12



### MR. MENDLEN: I do. 13


### MR. RAMIREZ: And thank you for deferring 14


### yesterday and letting everyone go. So the floor 15


### is yours. 16


### MR. MENDLEN: Well, I can do that. First 17


### of all, I'd like to begin this morning by telling 18


### the group how impressed I am with the work that's 19



### been done to date and the commitment that the 20


### members have had to the work and the ability of 21


### the facilitators you have here and the others to 229

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### keep the work on track. 1


### However, I'd also like to remind the 2


### group, as Joe Hagerman d id yesterday, and one of 3



### our HUD 's regulatory partners, Richard Potts , 4


### that time is beginning to become of the essence 5


### in completing your task. 6


### I would recommend that you look at trends 7


### in the life cycle cost results, which indicate 8


### that the proposals for the water climate zones 9


### appear to be excessive, and proposals for the 10


### colder climate zones appear to be appropriate or 11


### may need some tweaking. 12


### There are so many variables in the 13


### assumptions that impact the data from degree day 14


### selection for the cities chosen in the analysis, 15


### the climate zone assumptions, the fuel type 16



### distr ibution, the mortgage period and type, not 17


### to mention consumer preferences for thermostat 18


### settings that all impact energy consumption and 19



### cost. 20


### I'm going to spend the weekend in 21


### Charlottesville with my friends, who typically 2210

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### set their thermostat at 60 degr ees, and it 1



### doesn't matter whether it's winter or summer. So 2


### we're going to freeze over the weekend. I'm also 3


### going to be with my mother

- in

- law, who sets the 4


### thermostat at about 80 degrees. So consumer 5


### preferences on this is also a variable all this 6



### ana lysis doesn't take into account. 7


### I also wanted to remind you that both DOE 8


### and HUD economists will need to prepare a 9


### regulatory impact analysis on whatever is finally 10


### agreed to. And I'm reasonably confident that 11


### they will express the costs and benefits in terms 12


### of ranges of costs and energy savings and suggest 13


### that you begin to think in those types of terms 14



### as well. 15



### There's too much exactness in what I've 16


### seen, and there's a lot of flexibility for all 17


### the reasons I just stated before, in the analysis 18


### being done. 19


### From my observations and perspective, the 20


### work appears to be bogged down in the weeds in 21


### trying to make adjustments to make the numer ous 2211

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### PNN L and Navigant data runs support the initial 1


### assumptions, which is not always the case. 2


### With regard to the tw o
- tier regulatory 3


### approach, I've already spoken out against the 4


### concept, but would recommend that you consider a 5


### single regulatory approach and make suggestions 6


### for upgrading the current ENERGY STAR program on 7


### a voluntary basis as a second product type or 8



### tier. 9


### HUD is also concerned about other things 10


### just other than energy consumption and quality 11


### and so forth. We're also concerned about safety 12


### and durability and livability not being 13


### compromised. And for example, I understand that 14


### certain window requireme nts being considered 15


### would not make it possible to meet HUD's egress 16


### window requirements , and suggest for that that a 17


### weighted average be used to meet those criteria. 18


### Also, Rob, your subcommittee is proposing 19


### a 7 percent glazing approach, which is below th e 20


### 8 percent minimum for livability in the HUD 21


### standards. I want to tell you, when I started 2212

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### with that, it was 10 percent. And it was reduced 1



### to 8 later on. 2


### Discussions on compliance and testing are 3


### premature, as DOE and HUD have not yet worked out 4



### an agr eement as to how enforcement is going to be 5



### handled. 6


### I also wanted to comment briefly about 7


### some of Mike's comments yesterday with regards to 8


### compliance testing. I'm reasonably confident, as 9


### we have done in the past, that we would defer 10


### compliance testing on air leakage, whole

- house 11


### air leakage, for some period to allow 12


### manufacturers to become familiar with testing 13


### procedures. 14


### There was also a reference yesterday by 15



### Mike to HUD's reliance on NPA standards, 501 16



### standards. And while that was true at the ons et 17


### of the program in the '70s, today we rely 18


### primarily on public comment and the Manufactured 19


### Housing Consensus Committee to develop 20



### recommendations for the standards. And that's 21


### why HUD does intend to consult with the MHCC with 2213

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### regard to whatever standar ds are recommended by 1



### the DOE. 2


### And finally, if you have any questions 3


### about the HUD standards and program, please feel 4



### free to call upon me. 5


### I've tried to obey the ground rules, 6


### Javier, that you set out about not speaking 7


### during the meeting unless called u p. But I 8


### assure you it's been difficult at times. 9


### MR. RAMIREZ: Thank you. 10


### MR. MENDLEN: Thank you. 11


### MR. RAMIREZ: All right. Thank you, 12



### Rick. 13


### Any other comments from working group 14



### members? 15



### (Pause.) 16



### MR. RAMIREZ: Go ahead. 17


### MR. LUBLINER: Thanks, Rick. I 18


### appreciate your participation and your comments. 19


### MR. RAMIREZ: Okay. Go ahead. 20



### MR. UNGAR: I have a comment and also a 21


### couple of questions for Rick. Would it be 2214

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### appropriate to follow up from his comments? So 1


### let me do that first, I guess. 2


### You said, one was that you believe that 3


### some window requirements that are under 4


### consideration would not allow for egress? Could 5



### you
-- 6



### MR. MENDLEN: It would not allow for the 7


### operating force to be met. 8



### MR. UNGAR: That a window that met the 9


### egress requirements could not also meet which? 10


### Which requirements? 11


### MR. MENDLEN: No, it's the other way 12


### around. One of the windows that's being proposed 13



### will not meet the

-- will not allow the operating 14


### force requirements in our standards to be met. 15



### It would take too much force to operate it. 16


### That's according to information that I was 17


### provided by Rob Luter. I don't know if Rob's on 18


### the phone or not and can speak to that. 19


### MR. LUTER: I am, and I can address that. 20



### This has to do with the consideration of one 21



### element of the IECC that could virtually affect 2215

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### operating force. I think that will be part of 1


### Manny's report later today. 2


### MR. UNGAR: But we're not talking about a 3


### U factor as HGC. It's some other requirement. 4



### MR. LUTER: That is correct. 5


### MR. UNGAR: Okay. Sorry. I couldn 't 6


### quite figure out what the connection was. But 7



### that's fine. Thanks. 8



### MR. LUTER: Understandable. 9


### MR. UNGAR: I've forgotten the other one, 10



### so I'll defer it. 11


### My own comment was that I think yesterday 12


### we spent a lot of time on life cycle costing, 13



### which I think produced some very good information 14


### and discussion. But in the end, we don't need to 15


### consense on life cycle cost analysis. We need to 16



### consense on the standard. 17


### I think it's worth keeping in mind that 18


### even if we came to consensus on the assumptions, 19



### we haven't consensed on the criteria for a life 20


### cycle cost analysis. So it's not clear that that 21


### in itself would yield consensus on a standard. 2216

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### I think this is very useful information. 1


### I think it will affect people's thinking. But 2


### there's a point at wh ich if we don't agree on the 3


### life cycle costing, we don't agree, and that's 4


### fine. Each person can take the information for 5


### what it is and for how they want to interpret it. 6



### We need in the end to decide on a 7


### standard. And what we haven't, and Joe raised 8



### t his at one point yesterday, and we never did 9


### really get to it in a glancing fashion, is it's 10


### great to talk about the cost, but i n the end, 11



### what are their numbers in terms of the standard, 12



### not in terms of the analysis that people can live 13



### with? 14


### I really don 't still have a sense of that 15


### for a number of the people here. So, I hope at 16


### some point we can get to that and really discuss 17


### whether we're on track for, not for an analysis, 18



### but for a standard that we can live with. 19



### MR. RAMIREZ: Mark? 20


### MR. WEISS: Well, I just go back to the 21


### initial meeting, I think it was the initial 2217

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### meeting, when OGC opined that it was up to us to 1


### define "affordability" for purposes of our 2


### analysis. And I think we need to do that in some 3


### fashion. So I don't know if you could divorce 4



### t his type of analysis we had yesterday from 5


### determining what would be the appropriate 6


### standard. I think the statute requires that. 7


### Javier, I understand your concern about 8


### moving forward and not getting bogged down in the 9


### weeds. But affordability is an ess ential element 10


### of what we're doing. 11



### MR. MENDLEN: That was me about the 12



### weeds. 13


### MR. RAMIREZ: Any other working group 14



### members? 15



### Mark? 16



### MR. WEISS: I do have one clarification. 17


### I don't know if we're going to go around, but I 18


### do have one clarification for yest erday. I 19



### referenced some of the AHS numbers, the American 20


### Housing Survey. And I neglected to mention that 21


### the numbers I was talking about were all the 2218

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### median numbers from that chart. 1


### MR. RAMIREZ: All right. Then any other 2


### comments from working group me mbers? 3



### (Pause.) 4


### MR. RAMIREZ: All right. So, yesterday, 5



### we had left off with some conversation with the 6


### insulation on the pipes, as well as air leakage. 7


### And I don't know if the groups had an opportunity 8



### between now and then to have some additional 9



### discus sion on that to bring back any information. 10


### But what do you want to do with

-- let's 11


### start off with the pipes, because it seemed like 12


### that one was one that was fairly close, but we 13


### just were running out of time yesterday. So I'll 14


### let you resume your discu ssion on the pipes as 15


### far as insulating the

-- we're talking about R3 16


### or pipes of all three

- quarter or larger and 17


### outside of conditioned space regardless of size, 18


### and from water heater to distribution point, from 19


### water heater to distribution point. 20



### (Pause. ) 21


### MR. SANTANA: Manny with Cavco

. 2219

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### You know, I'll start off by identifying 1



### the section that it refers to in the IECC. It's 2


### section 403.5.3. And, you know, what section it 3


### requires, it requires an insulation of R3 for 4


### settling conditions, one of which is

- - and the 5


### way that I read it, it's all pipe three

- quarter 6


### of an inch or larger, all hot water pipe three

7


### quarter of an inch or larger, and all pipe

-- all 8


### hot water pipe outside of the conditioned space. 9


### And I don't know that if the pipe that's 10



### inside the conditioned space and is three

11


### quarters of an inch or larger, if it's exempt 12



### from the insulation. 13


### I don't have a problem with insulating 14


### the pipe that's outside of conditioned space. 15


### But when it gets inside of conditioned space, 16



### that's when I start raisin g my opposition to it, 17



### because , you know, you have constructability 18


### concerns. You know, you have pipes that run 19


### through walls. You have pipes that run through 20


### joists. 21


### You know, what do you do? Does the 2220

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### insulation have to follow the pipe? Can it butt 1



### up to the joist? You know, and although the 2



### costs of the insulation itself isn't

-- I don't 3


### think it's any significant, the costs of

-- or 4


### not the cost, but the effort to implement it 5


### versus the benefits gained if it's in conditioned 6


### space, that's what I'm not sure of. 7



### MS. DICKENS: So I was looking for

-- 8


### this is Ishbel, Manufactured Homeowners 9



### Association

. 10


### I was just looking for the definition of 11


### "conditioned space," but it's not in this book. 12


### MR. SANTANA: Yeah, it is. 13



### MS. DICKENS: It is? Somewhere. Ok ay. 14


### (Pause, inaudible conversation.) 15


### MR. LACEY: This is Eric. Maybe to 16


### streamline this and figure out something that 17


### works, would it be acceptable to carve out an 18


### exception for, you know, the point where the pipe 19


### passes through a framing member, for exam ple? So 20


### you could insulate up to the framing member and 21


### not have to cut out a giant hole to include both 2221

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### the pipe and the insulation? 1



### I think there are purposes for insulating 2


### the pipes even within the conditioned space. 3


### It's a hot water pipe. You have some latent 4



### loads in there that remain warm for a certain 5


### period, especially if there are a lot of draws on 6


### it. You know, if it's like in the kitchen sink 7


### and it's going to be used again, you won't have 8


### to wait as long for the warm water to come 9


### through b ecause there will still be some warm 10



### water in there. 11


### MR. SANTANA: Right. I understand. I 12



### understand that. 13


### MR. LACEY: So I wondered if, you know, 14


### is there a way to maybe clarify this? Because 15


### obviously, this section is not entirely clear on 16


### what you do with pipes inside conditioned space 17


### and pipes that are inside other insulation. I 18


### mean, we talked about that briefly yesterday. 19


### Maybe you carve out an exception for 20


### those, you know, or one or both of those 21


### scenarios. If there's other insulation, then 2222

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### it 's at least R3 on either side of it, you know, 1



### you attempt to

-- or is there still some value in 2


### insulating around the pipe? And unfortunately, 3


### I'm not an expert in, you know, pipe insulation. 4



### MR. SANTANA: And neither am I. This is 5


### Manny again. 6



### And that 's the reason why

-- so the 7


### question that I have is, is there any way to put 8


### a number or a value on how much energy will be 9


### saved if we insulate the pipe that's in 10


### conditioned space? Even if we take into 11


### consideration not having to insulate when it goes 12



### t hrough a framing member, you know, is there any 13



### -- you know, is that quantifiable? 14


### Because if we're talking about the water 15


### that's in the pipe when the fixture isn't in use, 16


### that energy is going to get lost, right? But if 17


### we're talking about loss of heat when it's on 18


### demand, you know, I don't know if that would be 19


### substantial enough to, you know, warrant 20


### insulating the pipe throughout the entire house. 21


### MS. DICKENS: I'm sorry. This is Ishbel, 2223

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### Manufactured Homeowners Association. 1


### So, yesterday, I heard a n umber of, I 2 

### think a very conservative $50 was what it was 3


### goin g to cost to do this insulation. If the 4


### amount of energy, cost of the energy saved is 5


### $25, it seems like a no

- brainer that you would do 6 

### it. But if the cost of the energy saved is $75 7


### or $100, then it's definitely cost effective. 8


### I feel like we should be able to get to 9


### consensus on this fairly quickly, because it 10


### seems like just a math problem as much as 11


### anything else. But I don't know that we have 12



### that number of what's saved. 13



### MR. RAMIREZ: Let me get Keith and 14



### Michael. 15



### MR. D E N NI S : I recently renovated my 16


### house, and I was really mad when I heard about 17


### that you could insulate the water pipes in the 18


### house, and I realized I hadn't done it. So I 19


### actually researched it. 20



### And there was

-- the way tha t the draw 21


### patterns work with water, you tend to use a lot 2224

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### and then you don't use it . And if you had an R3 1



### insulation in it, R3 conditioned space, my 2


### understanding is that you wouldn't really gain 3


### anything and that I shouldn't be worried. 4



### I was sufficient ly, you know, going from 5


### very upset. I'm an energy efficiency person. 6


### You know, they didn't insul ate my pipes, just PEX 7


### pipe . You know, I'm going to lose all this 8


### energy. Why am I turning my shower off? L ike, 9


### oh, I was being crazy, like this is not 10



### ne cessary. 11


### Because when it's in the line and you 12


### stop using the fixture for a certain amount of 13


### time, you're going to lose it no matter if you 14


### have the insulation or not. So, I think like 15


### even at $50 it would be overkill. 16


### I mean, you know, it's in condition ed 17


### space anyway. If you're going to use it within 18


### the next five minutes, but after you don't use 19


### your sink for about five minutes, you don't use 20


### it for about a couple hours. It's not like 21


### you're going to want to maintain that heat in 2225

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### that pipe that's in the wall for so long. It's 1


### not that big a deal. 2



### So I don't know if it's worth a lot of 3



### time to think about. But if it's not in 4


### conditioned space, I see that. But mostly 5


### because, you know, it can freeze and burst the 6


### pipe. I mean, that's the big concern . And it 7


### also gets really cold, obviously. So , for what 8



### it's worth. 9


### And I talked to people who have studies 10


### on it. You can find, you know, people who 11


### decide, try to maximize these things. There are 12


### at the AC triple

- E hot water forum will be there, 13



### and I know you guys probably know a lot of them 14


### and can get that information. 15


### MR. RAMIREZ: Manny had raised some 16


### concerns as far as just if this were to go in, 17


### what does the code really say and how do we have 18


### to apply this? So, hearing some of the 19



### discussion in here that the real savings on this 20


### even though it is a very low

- cost item, 21


### potentially, right, because depending on if you 2226

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### have to make the bigger hole and things like 1



### that. 2


### Does somebody have a recommendation on 3


### what we could gauge consensus on? 4



### Manny ? 5



### MR. SANTANA: I'd like to recommend that 6


### we insulate all hot water pipe outside of 7


### conditioned space. That should be easy enough 8


### for everybody. 9


### MR. LACEY: Regardless of size. 10


### MR. SANTANA: Regardless of size. 11



### MR. RAMIREZ: David? 12



### MR. TOMPOS: Based on this definition of 13


### "conditioned space," if we, like we talked about 14


### yesterday, insulate

-- right now we're insulating 15


### the underside of the belly. And to get more 16


### insulation to meet some of these requirements, 17


### we're going to have to put insulation above th at. 18


### There's heat ducts that typically have 19



### some insulation to them. They don't use the 20


### metal runs because they're loud and noisy, so 21


### they fix service problems by using a fiberglass 2227

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### heat duct in the belly. But that's where those 1


### pipes are running. 2



### But if I read this, spaces

-- they're 3


### trying to define conditioned

-- it says, "Spaces 4


### are indirectly heated or cooled, or they 5


### communicate through openings with conditioned 6


### spaces where they are separated from conditioned 7


### spaces by uninsulated walls, floors, or 8


### ceilings." 9



### So as soon as I insulate that floor above 10


### this space, in my opinion, that is now an 11


### unconditioned space, even though I have 12



### insulation below it. 13


### MR. SANTANA: Conditioned space. 14



### MR. TOMPOS: No, it's unconditioned space 15


### in that area in the belly . Because you're no 16


### longer communicating with the conditioned space 17


### because you have insulation directly in contact 18



### with the floor now. 19


### MR. SANTANA: But, Dave, you know, and 20


### again, going to section 2

-- 21



### MR. TOMPOS: Section 2 of what? 2228

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### MR. SANTANA: Chap ter 2 of the IECC, 1


### right, where everything is defined. And the 2


### definition for "conditioned space"

-- I'll read 3



### the whole thing. 4



### MR. TOMPOS: Are you looking at the 5


### commercial or the original? 6


### MR. SANTANA: No, the original part. 7



### MR. TOMPOS: Okay. 8



### MR. SA NTANA: Yeah. 9



### MR. TOMPOS: R7, correct? 10


### MR. SANTANA: No. Yeah, that's right, 11


### that's right. It's R7. So it's "an area, room, 12


### or space that is enclosed within the building 13


### thermal envelope and that is directly or 14


### indirectly heated or cooled. Spaces a re 15


### indirectly heated or cooled, one "

-- and I added 16



### the "one"

-- "where they communicate through 17


### openings with conditioned spaces;"

-- " two, " I 18



### added

-- "where they are separated from 19


### conditioned space by uninsulated walls, floors, 20


### or ceilings, and three, or where they contain 21


### uninsulated ducts, uninsulated piping, or other 2229

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### sources of heating and cooling." 1


### So, you know, the way that I read that 2


### definition and the way that manufactured homes 3


### are typically constructed, you have the belly, 4


### and then you have insul ation, and then you have 5


### an uninsulated duct. So by the definition of 6


### "conditioned space," I'd say that makes the belly 7


### a conditioned space. 8



### MR. TOMPOS: You don't always have an 9


### uninsulated space. A lot of manufacturers are 10


### using insulated fiberglass. 11



### M R. SANTANA: Oh, no. Because you have 12


### an uninsulated duct. If you have an insulated 13


### duct, then that's no longer a conditioned space. 14



### MR. TOMPOS: But that fiberglass is still 15


### insulated. I mean, the only time I would 16



### consider it an uninsulated duct would be your 17



### metal duct run. 18


### MR. SANTANA: Right. That's what I'm 19


### referring to, yeah. 20



### MR. TOMPOS: A lot of manufacturers are 21


### using

-- 2230

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### MR. SANTANA: You have an uninsulated 1


### duct, then that's a conditioned space. 2



### MR. TOMPOS: Okay. 3



### MR. RAMIREZ: Let me get M ichael, then 4



### Eric. 5


### MR. LUBLINER: My understanding is that 6


### we should be considering all of the things in 7



### that I

- codes, and this is one of them. 8


### And I thought in the spreadsheet analysis 9


### there was an estimate of cost for pipe insulation 10


### and energy savings. And I'd like to, as Ishbel 11


### said, kind of focus

-- if we're going to focus at 12


### all on this, look at that and decide. 13


### But as far as, I totally agree with you. 14


### Any piping that's outside the belly in the crawl 15


### space or in a vented attic, which I don't think 16



### y ou do crossovers in attics, but if you do, 17


### doesn't the code already in the installation 18


### manual and the setup code require that all those 19


### crossover pipings be insulated? 20



### MR. MENDLEN: Yes. 21



### MR. LUBLINER: So that means that we're 2231

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### voting on something that's a lready code. Why are 1


### we wasting our time on that? Let's focus on the 2


### insulation in the belly, and let's decide whether 3


### it's in the conditioned space or not. 4


### MR. MENDLEN: Right. 5



### MR. LUBLINER: I find it

-- 6


### MR. MENDLEN: I thought you were talking 7



### about the ducts, Mike. I'm sorry. 8



### MR. LUBLINER: The ducts or the crossover 9


### pipe? 10



### MR. MENDLEN: The crossover ducts are 11


### required to be insulated. 12


### MR. LUBLINER: But the piping for freeze 13


### protection is not required by HUD? 14


### MR. MENDLEN: Not specifically. 15



### MR. SA NTANA: You're required freeze 16


### protection. That's a heat

- tape reset. But just 17


### in summertime, you're not going to have any 18


### insulation. You know, you're not going to have 19



### -- so you're required freezing protection, but 20



### there's no insulation that I

-- 21



### MR. MENDLEN: You got heat tapes. 2232

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### MR. LUBLINER: So, you have a heat tape 1


### on the crossover with no insulation on the pipe. 2


### And that's acceptable in the installation manual? 3



### MR. SANTANA: I have to double

- check 4



### that. But I know it's not in the HUD code. 5



### MR. LUBLINER: I would argue that the 6


### heat tape should be looked at more importantly 7


### than pipe insulation in the belly if that's the 8



### case. 9


### MR. SANTANA: That might be the case. 10


### But going back to this

-- 11



### (Cross

- talk.) 12


### MR. SANTANA: You know, going back to the 13


### issue at hand, I think it's a good idea to take 14


### things in chunks. You know, so we can all agree 15


### on one facet of it, and then we can

-- you know, 16



### so let's not kill the whole issue because we 17


### don't agree on part of the issue, all right? 18



### MR. HAGERMAN: This is Joe Hagerman, DOE. 19


### What do we need to agree on? It seems 20


### like the question was, there's two questions, 21


### right? One question is, if the pipe is running 2233

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### -- this is my interpretation of you all's dialog 1


### here. If the pipe is running through the belly 2



### in sulation, is it in conditioned space or not 3


### conditioned space? 4


### I would argue that that's inside 5


### conditioned space. It's insulated, right? 6


### MR. SANTANA: Right. 7



### MR. HAGERMAN: It's insulated with belly 8


### insulation on top of a log. So it seems that you 9



### would n't need to go put more insulation there. A 10


### reasonable person, I think, would conclude that, 11


### right? 12


### So is that the first thing we need to 13



### decide? 14


### MR. SANTANA: I think the first thing we 15


### need to decide and the easy thing is, should all 16


### hot water pipe outs ide the conditioned space have 17



### insulation? 18



### MR. LUBLINER: I think we all decided 19



### that. I think that's reasonable. 20



### (Cross

- talk.) 21


### MR. RAMIREZ: Are there any objections to 2234

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### that? That pipes outside of conditioned space be 1



### insulated? 2


### MR. LUBLINER: I just ha ve a 3



### clarification question

. 4



### MR. RAMIREZ: But, s o we're good? All 5


### right. So no objections to that. It's 6



### unanimous. 7


### And any objections on the phone? 8



### (Pause.) 9


### MR. RAMIREZ: Okay. Now, you have a 10


### clarification question? 11


### MR. LUBLINER: Yeah, I was just 12



### w ondering. This gets back to the heat tape, 13



### which is some thing that's used regularly in 14



### N orthern climates to keep pipes from freezing in 15



### the crossover duct

. 16



### MR. SANTANA: Yeah. 17


### MR. LUBLINER: So, if we insulate

-- if 18


### we all agree that the crossover needs t o be 19


### insulated, then what do you do with the heat 20


### tape? 21



### MR. SANTANA: Don't know. 2235

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### MR. LUBLINER: You what? 1


### MR. SANTANA: I don't know. See, that's 2


### another issue. The heat tape is to provide 3


### protection against freeze, right? Insulation is 4


### to prevent heat loss, you know. And secondarily , 5


### it's going to protect against freezing as well

. 6


### But it's mainly to prevent loss, you know. 7


### So there's two separate issues here, 8


### because even if we said that the pipe is going to 9


### be insulated, this section only refers to hot 10


### water pipe. The freezing concern is on all pipes 11



### that have water. 12


### MR. HAGERMAN: So, Joe Hagerman, DOE. 13


### In D.C., because I've seen this 14


### insulation a lot of times in condo buildings. 15



### And it is commercial. So take that for what it 16


### means. They wrap t he heat tape on the pipe. 17


### Then they insulate it, right? So you would think 18


### that the heating element wouldn't have to turn on 19


### as much, right? Because it's insulated, right? 20


### So I don't know if you can get

-- I don't 21


### know if you should, to be honest with y ou, get 2236

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### rid of that provision in real extreme conditions, 1



### because there is that loss. There is that chance 2


### that it freezes, right? That's pretty severe 3


### damage when it freezes, right? If somebody's not 4



### there. 5


### MR. SANTANA: You know, and that

-- 6



### MR. EZZO : This is Mark. Hey, Manny, 7



### this is Mark Ezzo. 8


### I found the section in the HUD standards, 9



### installation standards that talks about this. It 10


### says, "There is an area subject to freezing, 11


### exposed sections of water supply piping, shut

- off 12


### valves, pressure red ucers, and pipes must be 13


### insulated or otherwise protected from freezing. 14


### MR. SANTANA: Freezing, freezing. 15


### MR. EZZO: So, to me that says, and I 16


### think that gets to Mike Lubliner's questions 17


### about, you know, what your setup manual says. So 18



### for water line c rossovers, we've got, the HUD 19


### setup standards give you two choices. One, you 20


### can either insulate it or, two, you can use a 21


### heat tape. 2237

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### And then I looked in

-- now I don't know 1


### if everybody's installation manual says this. 2



### But I think we most of us in the industry use a 3


### similar one. And under "Water line crossovers," 4


### it says, "Wrap water lines with insulation or 5


### otherwise protect to prevent from freezing." 6


### So I guess bottom line with that is it 7


### gives us two options today about how to protect 8



### those crossove r lines during installation. 9


### My recommendation would be for our energy 10


### code to say, simply, two things. You either 11



### install the hot water line in a conditioned 12


### space, or you protect it with R3 insulation. 13


### That would be my recommendation. 14



### MR. RAMIREZ: Wel l, let's see a show of 15



### thumbs on that. 16



### (Pause.) 17



### MR. EZZO: Pardon me? 18


### MR. RAMIREZ: I'm gauging consensus on 19


### that. I'm asking for a show of thumbs. And 20


### David has a question. 21



### MR. TOMPOS: I just have a question. 2238

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### MR. RAMIREZ: Yeah. 1



### MR. TOMPOS: I still t hink we need to 2


### define "conditioned space," because let me give 3


### you an example. Let's say we put a

-- this 4


### doesn't exist, I don't think

-- but an R4 down. 5


### And we put those cold and hot water pipes under 6



### that. Now we have all the other insulation that 7



### we 're going to add an R30 above it so that that 8


### insulation is between the conditioned space and 9


### this little section of air where the piping runs. 10


### I'm going to have all kinds of service 11


### problems because all my pipes are going to freeze 12


### all the time. So, at w hat level of insulation do 13


### I have to have below the pipes? You know, when I 14


### read this definition, it says that that 15


### conditioned space has to have communication with 16


### the living area and have uninsulated floors. 17


### So I'm not going to stop this thing. But 18


### I j ust want to make the point that I'm not 19


### convinced that that area where we're putting 20


### these pipes is conditioned space, because you 21



### don't know

-- you're going to have pipes 2239

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### freezing. So I think there's going to be a 1


### service problem if we don't define what that is. 2


### In my opinion, I think we should put the 3


### insulation on all the pipes, conditioned or 4


### unconditioned. So I'm not going to stop this. I 5


### just wanted to clarify my position on whether or 6


### not that area in the belly is conditioned space 7



### or not. 8



### MR. TOM POS: Well, it's Dave. 9


### Today those water lines aren't freezing. 10


### MR. EZZO: Right. But you don't have 11



### insulation above them. 12



### MR. SCHNEIDER: This is Peter Schneider 13


### from Efficiency Vermont. 14


### I'd have to agree. But I'm going to 15


### disagree with that last state ment, which is these 16


### pipes are not breathing, because they are 17


### breathing. And I have plenty of homeowners in 18



### Vermont in manufactured, uncertified homes t hat 19



### run their water

-- 20


### MR. RAMIREZ: Peter, let me jump in real 21


### quick. You started off strong, but th en you 2240

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### tailed off there. I don't know if maybe you need 1


### to pick up the phone versus speaker, if you're on 2


### speaker, when you want to speak. Can you try 3



### that for us? 4


### MR. SCHNEIDER: I can call in on my 5


### phone. Is that any better? 6



### (Cross

- talk.) 7



### MR. RAMIREZ: Yeah, yeah, yeah. 8


### MR. SCHNEIDER: Yeah. So I was just 9


### saying that I certainly wouldn't consider, for 10


### me, that belly to be conditioned. And that's 11


### shown year after year in Vermont, particularly 12


### last winter, where we had plenty of pipes 13


### freezing in, you know, relatively new HUD

14



### certified manufactured homes. 15


### In addition, I consider, you know, a 16


### conditioned space to have an air barrier aligned 17


### with the thermal envelope. And in my opinion, 18


### there's no air barrier associated with the belly 19


### of a typical manufa ctured home that has the ducts 20


### and the piping in the belly, even above that 21


### compressed batt insulation that's exposed to 2241

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### outside conditions. 1


### MR. RAMIREZ: So, is this one of those 2


### things where it's not a one

- size

- fits

- all? And 3



### if there's different climate zones, then it has 4



### to be clear that it has to be insulated? 5


### MR. LUTER: This is Robert at Lippert. 6


### Just an observation. We're discussing 7


### whether or not this belly area is conditioned or 8


### not. I think it's clear that it's not, because 9



### it doesn't communica te with the conditioned 10



### space. 11



### But it does have insulation that we're 12


### hearing is not effective. I'd be inclined to say 13


### it's not conditioned space and the belly 14


### insulation does not serve to satisfy the pipe 15


### insulation requirement. 16


### MR. RAMIREZ: Okay. Eric ? 17


### MR. LACEY: I'm going to throw out a 18


### potential compromise. I looked at the Washington 19


### State University Extension Energy Program 20


### website. And there was a code interpretation by 21


### the state building code council on this subject. 2242

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### And I wanted to see if may be this would work as a 1


### sort of compromise to address the issues raised 2



### here. 3



### The insulation is allowed to be 4


### discontinuous when it passes through wall studs, 5


### floor joists, or other structural members

-- t his 6


### is something we talked about

-- provided the 7



### in sulation is tied to either side of the 8



### obstruction. 9


### Also, if the piping is in an exterior 10


### wall, cavity, or other insulated space, no 11


### additional pipe insulation is needed if the 12


### insulation provides at least R4 coverage around 13


### the piping. Sort of

-- 14



### MR. TO MPOS: I still think you're going 15


### to have service problems with

-- like I said, I'm 16


### not going to stop this. 17


### MR. HAGERMAN: Joe Hagerman, DOE. 18


### I mean, manufacturers have to take that 19


### into consideration, right? 20



### MR. TOMPOS: Right. 21


### MR. HAGERMAN: If they thin k that there's 2243

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### going to be service problems. We're not

-- our 1


### code, even if you wrote the code, you could still 2


### make a unit that would have service problems. 3



### MR. TOMPOS: No, I agree. But I

-- right 4


### now, I don't think we have too many issues. I 5



### mean, ap parently we have some in Vermont. But 6


### right now we don't have insulation

-- right now, 7


### that area is a conditioned space, because it 8



### communicates and there's no insulation between 9


### the floor and the belly blanket. 10


### But what we're going to require, because 11



### we have to put more insulation somewhere, is that 12


### we are going to make that an unconditioned space. 13


### That's what I'm trying to bring up. We are 14


### creating a problem that currently doesn't exist. 15


### But again, in my opinion, I think we 16


### should insulate the pipes w hether they're 17



### conditioned or unconditioned. So it doesn't make 18


### a difference on this topic, as long as it's the 19



### three

- quarter

- inch pipes. 20


### MR. HAGERMAN: If you were a 21


### manufacturer, you would insulate

-- 2244

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### MR. TOMPOS: If I were a manufacturer, I 1



### would insu late the pipes. 2



### MR. HAGERMAN: And I think a lot of 3


### manufacturers will probably interpret this

-- 4



### MR. TOMPOS: Not all the pipes, by the 5



### way. 6



### MR. HAGERMAN: Yes. 7



### MR. TOMPOS: But what the IECC requires. 8



### MR. RAMIREZ: Mark? 9


### MR. WEISS: When you say that, I mean, do 10


### you mean all zones, all areas, everywhere? Or 11



### does that factor into it? 12



### MR. TOMPOS: I would say we should follow 13


### IECC per the IECC 2015. 14



### MR. WEISS: Which is? 15



### MR. TOMPOS: Which, I believe, is all

-- 16


### MR. WEISS: Everything? 17



### MR. TOMPOS: All zo nes everywhere. I 18


### think we're talking about a real small amount of 19


### money. And I think Eric just addressed all of 20


### Manny's concerns about butting up against the 21


### pipe. You're not going to have to create bigger 2245

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### holes in the joist. 1


### It's partially a personal frustration 2


### that I have to wait five minutes to get water in 3


### my shower every morning. So I should probably 4


### insulate my own pipes. And they are all in 5


### conditioned space. 6


### MR. RAMIREZ: Manuel, what do you think? 7



### MR. SANTANA: I still think we're 8


### confusing two issues. One is freeze protection, 9


### and the other one is heat loss. You know, and 10


### again, because the section that started the whole 11


### thing was specifically for hot water pipes. 12


### I think we're confusing or we're turning 13



### the definition of , as written of co nditioned 14



### space into what we want it to read. Y ou know, 15



### there's a

-- it doesn't have to be

-- it doesn't 16



### have to communicate each time. 17


### I appreciate and agree with what Dave 18


### said, that we might create a problem by having 19



### insulation above and below the duc ts, because 20


### we're going to create another little void there. 21


### Whereas currently, you don't insulate above the 2246

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### duct, you just insulate the majority of the time. 1


### Some manufacturers might insulate above and 2



### below. 3


### But, you know, going back to what 4



### conditione d space is, you know, there is an "or" 5


### there. It says you have space that comm unicate 6


### or you have uninsulated

-- or uninsulated pipes. 7


### So the definition of "conditioned space" is 8



### broader. And it does include areas that have 9


### uninsulated ducts, even if th ey don't communicate 10


### with other parts of conditioned space. 11


### So I mean, going back to this, I think we 12


### need to, you know, take chunks of what we're 13


### talking about specific to the hot water pipe. 14


### And again, it isn't because of the cost of the 15



### insulation itse lf. It's because of the 16


### difficulties, I think, in construction. 17


### MR. RAMIREZ: What about the language 18


### that Eric had presented? 19


### MR. SANTANA: Makes it a lot easier, 20


### sure. But then, you know, going back to what 21


### Keith said, you know, and what I said earlier , 2247

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### one of the benefits to preventing heat loss when 1


### the water is coming through the pipe to the point 2


### of use. Because, as he said, you know, the 3


### insulation in the pipe, if we're talking about 4


### preventing losses in the pipe, right, are really 5


### only going to h elp as it's being conveyed. 6


### Because once it's sitting there

-- you 7


### know, so to the water

-- you know, if so you 8


### shower in the morning, and then you shower at 9


### night, right, the water in the pipe from your hot 10


### water heater to your shower head, during the tim e 11


### when you're at work and do whatever you do and 12


### then come back and shower, it's still going to 13


### come out cold. You're still going to lose it. 14


### You know, you're still going to wait. 15


### You might not wait five minutes for your 16


### water, but, you know, it's not go ing to come out 17


### tepid, you know, unless you live where I live. 18


### (Laughter.) 19


### MR. SANTANA: See, where I live, you wait 20


### for it to get cold. 21


### But anyway, I mean, so that's

-- so we're 2248

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### talking about freeze protection. Let's talk 1


### about freeze protection. And we 're talking about 2


### insulating it because we're trying to prevent 3


### heat losses. And we might just be spinning our 4


### wheels and wasting time insulating it in 5


### conditioned space. 6


### So, you know, I really appreciated what 7


### Keith said, because one of my concerns when I 8


### first joined the committee is that I think 9


### everybody on this working group really feels that 10


### energy standards for manufactured housing are 11


### lagging way behind and need to be improved. You 12


### know, and I think that's a given. 13


### One of the concerns I had coming into 14


### this thing is, how much is practicality and 15


### pragmatism going to play a role? You know, are 16


### we going to just shoot for the stars regardless 17


### of the cost? Are we going to try to implement 18


### items that really make sense? 19


### You know, and so this one

-- that 's why I 20


### really appreciated what Keith said, because he 21


### said this, you're not really going to have a 2249

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### whole lot to gain. So why even worry about it? 1


### MR. RAMIREZ: Okay. Lois? 2


### MS. STARKEY: I'd like to support that 3


### comment. Maybe we could take a vote on k eeping 4


### the definition as it is. And then if we don't go 5


### there, we can amend it for Eric. 6


### Alternatively, perhaps just postpone this 7



### whole discussion until the next round of 8



### standards

- making, which, by statute, DOE has to 9


### do every three years. 10



### MR. RAMIREZ: Michael? 11


### MR. LUBLINER: I guess I have a comment, 12



### but I'd like to

-- I'm real interested in MHI's 13


### position on reviewing every three years. Is this 14


### something that we should be doing? 15



### MS. STARKEY: Both the MHCC and the DOE 16


### statutes require this. 17



### MR. LUBLI NER: So we're going to be back 18


### here in three years doing this again? 19



### MS. STARKEY: No. 20


### (Inaudible conversation and laughter.) 21



### MS. STARKEY: No. 2250

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### MR. HAGERMAN: She's talking about the 1



### statute says

-- 2



### MS. STARKEY: Yes. 3



### MR. HAGERMAN:

-- when the IECC upda tes, 4


### we update that. 5


### MR. WEISS: You can exercise your 6



### discretion. 7


### MR. LUBLINER: It's more of just kind of 8



### an observation. 9


### MR. RAMIREZ: Michael, then David. 10


### MR. LUBLINER: So my point is that I 11



### think I'm

-- I've taken an observation. You have 12



### manufactur ers and you have engineers. And we're 13


### disagreeing on the fundamental of heat loss, 14


### which is defining the conditioned space. That 15



### concerns me. 16


### What does HUD say the conditioned space 17


### is? And what does HUD say the pressure envelope 18



### is? I read the definit ion in the HUD standard. 19


### They're two different things for the belly, as I 20


### understand. The belly is not the pressure 21


### envelope; the floor is. Therefore, the pipes in 2251

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### the belly are below

-- are outside the pressure 1


### envelope. But because the insulation gen erally 2


### is in the belly, it's within the conditioned 3


### space, but it's outside the pressure envelope. 4


### Would you concur that's the definition? 5



### MR. MENDLEN: I think that's accurate 6


### without me actually sitting there and reading the 7



### lines. 8


### MR. LUBLINER: Thank y ou. 9



### MR. MENDLEN: But it sounds correct. 10



### MR. TOMPOS: I disagree. 11


### MR. LUBLINER: The point on freeze 12


### protection, it's a question for kind of our 13



### scope. 14


### MR. WEISS: You know what's really great 15



### about this? 16



### (Cross

- talk.) 17


### MR. LUBLINER: Really, we're focused on 18


### the energy savings of this pipe insulation 19



### measure. And

-- 20



### (Cross

- talk.) 21


### MR. RAMIREZ: Sorry, Mike. 2252

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### MR. LUBLINER: I'm sorry. So we're 1


### really focused, I think, our charge is on whether 2


### the pipe insulation energy savings versus its 3


### cost is something w e want to include. 4



### If we want to talk about freeze 5


### protection, I'd like to point out that most times 6


### the crossover pipes freeze is when the power goes 7


### out. And the heat tape doesn't do anything. And 8


### if you look at insurance records and things like 9


### that, claims, you'll find that a lot of this 10


### stuff happens when the power goes out. 11


### So if I was a manufacturer, I would be 12


### using belt and suspenders in climate zone 3. I 13


### would put my heat tape, just like Joe says the 14


### condo guys do, for good reason, around the p ipe. 15


### That's all with the crossover. And any other

-- 16



### and then I would insulate it. 17


### And I would find a product that allows 18


### you to do that, which are on the market. Thank 19



### you. 20


### MR. RAMIREZ: All right. So is there 21



### value then to looking at the life cycle c ost 2253

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### analysis to see if there is savings sufficient 1


### enough to even talk about the insulation 2


### component? Is it worth talking about? 3


### MR. HAGERMAN: Joe Hagerman, DOE. 4



### I don't think we have

-- I think, so the 5


### model, as I remember correctly, models with 6



### insula tion everywhere. We have not modeled it 7



### without insulation. 8


### We have allocated $50, which I think is 9


### generous, for the insulation of the pipes. So I 10


### don't think if you just looked at energy numbers, 11


### we could disassociate what the energy savings is 12



### for ins ulating the pipe or not. 13


### And I'd have to say if we did do that, I 14



### don't think

-- I doubt it would move very much. 15


### MR. RAMIREZ: All right. So this

-- it 16


### sounds like the savings, if I interpret that 17


### correctly, is negligible. 18


### MR. HAGERMAN: That's my gut fe eling. 19



### MR. RAMIREZ: But as well as the cost , as 20


### well. So let me ask the group then. Is it more 21


### a question of, I think, to what David's getting 2254

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### at is that whether the belly is conditioned space 1


### or not? There may be a stronger argument that 2



### it's not once you start insulating the floor. 3


### And does that now have an impact on whether those 4


### pipes will freeze or not? 5



### And do we need to talk about the 6


### possibility of insulating those pipes because of 7


### freezing versus energy savings? 8



### David? 9



### MR. TOMPOS: Well, now yo u're talking 10


### about insulating all the pipes, because there's 11


### hot and cold water that run through that , period. 12



### So

-- 13


### MR. RAMIREZ: Well, was that accurate, 14


### though, as far as you're concerned , that once you 15


### insulate the floors, now there's a stronger 16



### argu ment that that's not conditioned space? 17



### MR. TOMPOS: That's my argument. But it 18


### sounds like I have a lot of disagreement. 19


### MR. RAMIREZ: Yeah. Okay. 20


### MR. SANTANA: Well, I think Luby really 21


### brought up a good point in that freeze protection 2255

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### is really outsi de the scope of what we're doing, 1


### you know. So we're worried about energy. I 2


### think we try to focus on energy. And if it isn't 3


### an energy issue, you know

-- I mean, if one of 4


### the energy issues brings up constructability 5


### issues, then that should be conside red. 6


### You know, but I think we should restrict 7



### this discussion to heat loss and the benefits of 8


### insulating for preventing heat loss. Because 9


### freezing is a separate issue. 10


### MR. RAMIREZ: Okay. So, Manny's point is 11


### that if the cost is truly negligible as far as 12


### the cost and the savings, and the issue is more 13


### about pipe freezing, then that's out of scope. 14



### The manufacturers will have to deal with that as 15


### they feel appropriate. You're in a cold climate, 16


### and you need to do it because you have a cold 17



### turn with i t, you're going to have to do it. 18



### Richard. 19



### MR. POTTS: Richard Potts. 20


### Is it something that we could note in our 21


### report or findings, something to pay attention 2256

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### to? Say we were aware that these may cause 1


### adverse problems, possibly, to frost protection 2



### or fr eezing in certain climates, so something for 3


### the main committee to look at, or something along 4


### those lines? Just so we do our due diligence. 5



### MR. RAMIREZ: Joe was indicating that

-- 6



### MR. HAGERMAN: I think we can note that. 7



### I don't think that

-- you know, this

-- 8


### you know, we're all

-- you know, the 9


### manufacturers, everybody on the committee was 10


### selected because they have experience in this 11


### domain, right? And your term sheet needs to 12


### reflect your professional judgment, right? And I 13



### think if there's other reasonable clauses we need 14


### to add, we should add them, right? 15



### We're not asking for this document to be 16


### War and Peace and its link, okay ? 17


### MR. RAMIREZ: Yeah. I think Manny was

-- 18



### MR. SCHNEIDER: Peter Schneider from 19


### Efficiency Vermont. 20



### MR. RAMIREZ: Go ah ead, Peter. 21



### MR. SCHNEIDER: Thanks. So, I'm just 2257

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### wondering. There is definitel y energy savings 1


### potential here, a n d probably the payback 2


### certainly in best climate zone 3 is going to be 3



### sure. H ot water pipes alone allows, you know, 4


### water temperature to be delivered to

-- warmer 5


### than it otherwise would, which would allow water 6



### heaters to be tested slower with regards to, you 7


### know, thermostatic control valves. 8


### And, you know, we're looking at a pretty 9



### small incremental cost and then so as energy 10


### savings in a pretty quick payback. 11



### It also notes , under 55 degrees, you 12


### know, in Vermont, we never exceed more or less 50 13


### degrees ground

-- that is, cold water. So, you 14


### know, I think it would be silly to ignore the 15


### durability improvement associated with insulating 16



### the se pipes in the belly in regards to not only 17


### freeze protection, energy savings, but also in a 18


### hot, humid climate. 19



### P articularly up here even, where we have 20


### 50 degree water and we have hot, humid days, it 21


### eliminates condensation that it leads to wetting 2258

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### and potentially mold and mildew. 1


### MR. RAMIREZ: Okay. Manny? 2


### MR. SANTANA: You know, I think that we 3


### need to go back to the core concept. You know, 4



### the ter m sheet doesn't have to be word

- for

- word 5



### this is what DOE should have verbatim in the 6



### standard. You kno w, it can be conceptual. 7


### And I think, without getting into what's 8


### conditioned space and what's not conditioned 9


### space, you know, we all agree that pipes of all 10


### sizes outside conditioned space should be 11


### insulated. So the question is, do pipes in 12



### conditioned space
-- regardless of how you define 13


### what conditioned space is, do pipes in 14


### conditioned space need to be insulated? 15


### We haven't had a vote on that yet . Maybe 16



### -- I think it's an ELMO moment. We've beat this 17


### thing to a pulp making sausages now. So I thin k 18


### we should, you know, get a gauge as to where 19



### we're at. 20


### MR. RAMIREZ: Michael, and then Mark. 21



### MR. BANTLE: I pass. 2259

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### MR. RAMIREZ: Mark? 1


### MR. WEISS: This is just a general 2


### comment. I mean, you can't get to the issue 3



### without

-- seems to me without defining what 4


### "conditioned space" is. And if you put any kind 5


### of note in the document, whichever document it 6


### is, the term sheet or the final regulation, you 7


### know, if terms, key terms, are not defined, we're 8


### going to create more problems and more confusion 9



### than if we're saying nothing, it seems to me from 10



### this discussion. 11


### MR. RAMIREZ: All right. 12


### So, let me ask the group, then. I'm 13


### hearing that you want to table the pipe, which 14


### was the easy one. 15


### (Laughter.) 16


### MR. RAMIREZ: Table it for what, though? 17



### MR. HAGERMAN: Le t's just decide. I 18


### mean, so Eric found a website here on DOE that 19


### says, for every 10 degrees you reduce your water 20 

### heater, annually it saves $12. 21


### MR. LACEY: Twelve to thirty. 2260

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### MR. HAGERMAN: I'm sorry, $12 to $30. 1


### And if Peter just said that when you ins ulate the 2


### pipe in Vermont, you can reduce your w ater heater 3


### by 2 to 4 degrees. Y ou take this data, it's 4 

### really, you know, you're saving maybe $15 over 5


### five years, right? 6


### MR. SANTANA: We're taking stuff as fact 7



### that we don't know is fact. I mean

-- 8



### MR. HAGERMAN: We don't, but

-- 9


### MR. SANTANA: You know, I can say

-- 10



### (Cross

- talk.) 11



### MR. HAGERMAN: I would say that we don't 12



### insulate. Y ou know, I say we don't insulate the 13


### pipe in the conditioned space and we move on. 14



### MR. TOMPOS: I agree. 15



### MR. WEISS: Get c onsensus down here? 16


### MR. RAMIREZ: Okay. Don't insulate the 17


### pipes in conditioned space. 18



### MR. SCHNEIDER: This is Peter. 19


### I just wanted to add, you know, I wasn't 20


### speaking specifically to Vermont, this 2 to 4 21


### degrees. My guess is you insulate pipes in the 2261

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### be lly in a manufactured home in Vermont, and 1


### you're well exceeding the 10 degrees . T his is a 2


### national average that is documented by the EPA's 3


### website for temperature increase when adding R3 4


### pipe insulation. 5


### So I would say that, you know, 6


### ultimately, it come s down to whether we're 7


### considering the belly, above the belly insulation 8



### insulated for conditioned or unconditioned. I 9


### think it's pretty clear that is done in 10


### conditioned space and that we've all agreed that 11


### we should insulate the pipes in unconditioned 12



### spaces. 13



### MR. EZZO: This is Mark Ezzo. 14


### I agree with that, and I think that's 15


### exactly what Dave Tompos was saying. When you 16


### have insulation above and below a pipe, it's no 17


### longer conditioned. And I agree with that. 18


### So, the way it could read is, you either 19


### install the pipe in the conditioned space, and I 20


### think most of us agree that if insulation is 21


### above and below it's not conditioned. So you 2262

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### would have to insulate that to

-- you'd have to 1


### add another level of insulation to that. Or you 2


### install the pipe in a conditioned space. And I 3


### agree with that. 4


### MR. RAMIREZ: So, I think that Joe's 5


### phrasing still holds true to what I just heard, 6


### which was no requirement to insulate pipes in 7


### conditioned space. Right? 8



### So let me see a show of thumbs on that. 9



### MR. KESSLER: Bert at Palm Harbor. 10


### MR. RAMIREZ: I'm sorry? Go ahead, Bert. 11



### MR. KESSLER: This is Bert at Palm 12



### Harbor. 13


### We keep talking about pipe freezing. 14


### This requirement applies to hot water pipe only. 15


### It doesn't say anything about cold. 16



### MR. RAMIREZ: Yeah. No. There was some 17


### discussion on that, but

-- 18


### MR. KESSLER: It's hot water pipe 19



### insulation. 20


### MR. RAMIREZ: Right. There was some 21


### discussion on that, but I think we've moved on 2263

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### from that. So

-- 1


### MR. KESSLER: And I don't agree with the 2



### definition of "condit ioned space." You know, if 3


### we have insulation and an air space between, that 4


### becomes part of the whole assembly. 5


### And then, last comment, for the intent to 6


### work for that pipe insulation, you have to have 7


### the insulation all the way around the pipe. If 8



### it's just laying on top of a blanket insulation 9


### in the belly, that doesn't do anything for the 10


### intent of that requirement. Thank you. 11


### MR. RAMIREZ: All right. So, just so 12


### that everyone is on the same page, Mark, Mark 13


### Ezzo, can I ask you that between now and probably 14


### after our next break, would you be able to draft 15


### a couple of lines of what that would look like so 16


### that we would all have something to look at and 17


### gauge consensus on? 18


### MR. EZZO: Well, it would be one 19


### sentence, Javier. 20



### MR. RAMIREZ: That's fine. 21



### MR . RAMIREZ: Go ahead and give it to us. 2264

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### MR. SCHNEIDER: This is Pete. I just 1


### want to note, just on the last comment that was 2


### made, you know, the language says, "mechanical 3


### system piping capable of carrying fluids above 4



### 105 Fahrenheit or below 55 Fahrenhei t shall be 5



### insulated to a mi nimum of R3." Okay? So that's 6



### -- 7



### (Cross

- talk.) 8


### MR. KESSLER: That does not apply to 9


### water lines. That's for refrigerant lines. 10



### (Pause.) 11


### MR. RAMIREZ: Okay. 12


### MR. LUTER: This is Rob at Lippert. 13


### Are we still contending we don' t have a 14



### definition for " conditioned space " ? 15


### MR. RAMIREZ: No, I don 't think so. I 16


### think what we're just trying to capture right now 17


### is the verbiage of not requiring to insulate 18


### pipes in conditioned space. So we're just trying 19


### to capture a line so that e veryone sees the same 20


### thing, so that we can gauge consensus on it. 21


### MR. LUTER: Oh, okay. For what it's 2265

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### worth, IECC does define "conditioned space." So. 1


### MR. RAMIREZ: Yeah, I know. I think 2


### we're not quite there yet. 3


### Keith, did you have something? 4



### MR. DEN NIS : Is there any way to avoid 5


### the issue by just doing it the opposite way and 6


### saying "underbelly and unconditioned space" so 7


### that we don't have to argue about why the belly? 8


### It seems like people don't want to insulate in 9


### conditioned space because it doe sn't make sense, 10


### and that they do want to insulate in the belly 11


### and other unconditioned space or other 12


### conditioned space. 13


### And you say "other , " "and other 14


### unconditioned space," you're making an 15


### interpretation on that. But it sounds like 16


### everyone is in agre ement, we're just arguing 17



### about

-- 18


### MR. RAMIREZ: So, insulate hot water 19


### pipes in

-- 20



### MR. DENNIS : In unconditioned space, 21


### yeah. Underbelly and unconditioned space. And 2266

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### just say that that doesn't have any

-- that's not 1


### interpreting what underbelly

-- 2



### MR . MENDLEN: That's in fact on the heat 3



### tape. 4



### MR. RAMIREZ: David? 5



### MR. TOMPOS: Well, in some zones, we are 6


### going

-- it is still going to be conditioned 7


### space in the belly. So I don't think we can just 8


### say "the belly." Because you have some in the, 9


### you kn ow, zones 1, 2, and 3, you're going to be 10


### able to get away with an R22 blanket, where, by 11


### my definition of "unconditioned space," that's 12


### now a conditioned space, because I don't have 13


### insulation on top of that section. 14



### So I don't think we should include all 15


### bellies, because in some zones you are going to 16


### be conditioned space. 17



### MR. DENNIS : So the belly may be 18


### conditioned or unconditioned. Just say "insulate 19


### in unconditioned space." And then can we just 20



### move on? 21


### MS. STARKEY: Yeah. Exactly. 2267

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### MR. TOMPOS: I'm fine with that. We can 1


### work out the problems with conditioned space 2



### later. 3


### MR. HAGERMAN: You could also say, "Where 4


### pipe runs to the insulation in the underbelly, it 5



### shall be insulated." 6



### MR. TOMPOS: That was my point. In the 7


### underbelly, I may have con ditioned space. 8


### MR. HAGERMAN: Right. 9



### (Cross

- talk.) 10


### MR. HAGERMAN: And so, where it runs 11


### through the insulation of the underbelly, it 12



### shall be insulated. 13



### MR. TOMPOS: Okay. 14



### MR. DENNIS : Or in unconditioned portions 15


### of the underbelly. 16



### MR. TOMPOS: My opini on would be we just 17


### say that we don't do it in conditioned space, and 18


### we'll let DOE figure out the definition of 19


### "conditioned space." 20


### MR. SANTANA: Exactly. 21


### MR. RAMIREZ: So, which is the top line? 2268

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### (Cross

- talk and laughter.) 1


### MR. RAMIREZ: Which is the top line? "Do 2


### not insulate in conditioned space"? 3


### MR. SANTANA: Well, no. It's 4


### interpreting what we say. All hot water pipe 5



### should have R3 insulation outside of conditioned 6



### space. 7


### MR. HAGERMAN: Right. 8


### MR. SANTANA: So that's all inclusive by 9



### -- you know, l ike you guys said, what we end up 10


### with defining as conditioned space, if you have, 11


### you know, insulation in the belly and then none 12


### in between in the joist space and that's 13


### considered conditioned space, then that's fine. 14



### You don't have to insulate in there

. 15


### If you have insulation in the floor and 16


### under the duct, then that's considered 17


### unconditioned space, then

-- I mean, this little 18


### pipe, the pipe and

-- I guess the concept, again, 19


### the core concept is that if the pipe is in 20


### conditioned space, there's no nee d to insulate 21



### it. 2269

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### MR. RAMIREZ: Okay. So, folks that are 1


### on line, can you see the screen? 2



### (Pause.) 3



### MALE VOICE: Yes. 4


### MR. RAMIREZ: Okay. Eric, you had 5


### something? 6


### MR. LACEY: One more thing to add. And I 7


### hate to prolong the discussion, but there was one 8


### other scenario required by the insulation in here 9


### that I didn't want to miss. That is, from the 10



### water heater to the distribution manifold. You 11


### want to just throw that one in there and include 12



### that? 13


### I know you don't always have a 14



### distribution manifold. 15



### M R. SANTANA : I don't think we ever had a 16



### distribution manifold. 17



### MR. LACEY: There is one. 18


### MR. RAMIREZ: So, if there is no 19


### distribution manifold, then it's irrelevant. 20



### MR. LACEY: Yeah. 21



### (Pause.) 2270

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### MR. SANTANA: But if you have a

-- okay. 1



### Now, this is a toug h one . But if you have a 2


### distribution manifold inside a conditioned space, 3


### would we want to insulate the lines by go ing to 4



### the distribution manifold? 5


### MR. RAMIREZ: The way I read that, yes. 6



### MR. SANTANA: Wouldn't that be the same 7


### thing? I think that woul d be fine, because that 8


### would probably be

-- if you have a distribution 9


### manifold, it probably won't be in the wall or it 10



### won't be in some kind of inaccessible hard

- to

11


### reach place, you know? I do n't know where we 12



### would have it. 13



### MR. RAMIREZ: David? 14



### MR. TOM POS: If we include that, make it 15



### not

-- "should" is a bad word. You've got

-- 16



### (Cross

- talk.) 17



### MR. TOMPOS: No, "shall." 18


### MR. BANTLE: Do you want "shall"? 19



### MR. TOMPOS: "Shall." It has to be 20


### "shall." "Should" is an option, yeah. 21



### (Cross

- talk.) 2271

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### MR. MENDLEN: First line, too? 1


### MR. WEISS: I would suggest adding "if 2


### any" in there. "Distribution manifold," comma, 3


### "if any." 4


### MR. RAMIREZ: Okay. I'm sorry. Mark? 5


### MR. WEISS: I would just suggest, after 6


### "distribution manifold," comma, "if any," because 7


### apparently they're not used. 8


### MR. RAMIREZ: Oh, okay. 9



### MALE VOICE: It reads the same. 10



### MALE VOICE: Yeah. 11


### MR. RAMIREZ: All right. So, let me see 12



### a show of thumbs for those two lines. 13



### (Pause.) 14


### MR. RAMIREZ: And folks on line, if 15


### anyone is in disagreement, speak up. O therwise, 16


### we're assuming you're good with that. 17


### MR. LUTER: Looks good to me. 18


### MR. RAMIREZ: Okay. Then, those two 19



### lines have unanimous consensus. And now that 20


### we've got that easy one out of the way, let me 21



### ask. Do we want to take a one function before w e 2272

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### move on to the next one? 1


### Okay. So let's take 10 minutes. And 2


### then we're going to go into the air leakage. 3


### (Recess from 10:08 a.m. until 1 0 : 22 a.m.) 4


### MR. RAMIREZ: Okay. Let's go ahead and 5


### tackle the air leakage issue. And we still have 6


### quite a bit on the agenda. So let's try to put 7


### this in a time box. So it's 10:22. So let's go 8


### until eleven o'clock, right, at the latest, 9


### assuming we don't get this done in five minutes, 10


### right? 11



### MS. DICKENS: Because that would be so 12



### standard. 13


### (Laughter.) 14



### MR. RAMIREZ: Yeah. So let's put this in 15



### a time box. 16


### Air leakage. How do we want to tackle 17



### this one? 18


### MR. HAGERMAN: This is Joe Hagerman, DOE. 19



### Where we started last time to start the 20


### conversation off, we put up on the screen, and 21


### maybe Matthew could just talk to it, the cost 2273

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### that Matthew assumed for the air leakage numbers, 1


### right? And I believe he derived

-- I believe 2


### they derived, you know, since yesterday when we 3


### talked, I believe they derived the air leakage 4


### and the duct leakage costs and a performance 5


### specificati on largely off this ENERGY STAR report 6


### that was circulated pretty early in our 7



### discussions. So those were the costs that came 8



### into it. 9


### You know, yesterday we defined what "duct 10


### leakage" was . And so I think it would be nice to 11



### define first what "air leaka ge" or, you know, the 12


### steps that one would take to reduce the air 13


### leakage in the house, to talk through what the 14


### measure actually includes, and then just have a 15


### frank discussion of, does the number that we 16


### report up there, does it reflect the amount of 17



### wor k that you take to achieve that, right , in 18


### one's professional opinion? 19



### (Pause.) 20



### MR. RAMIREZ: So

-- 21


### MR. BANTLE: You might have to log in 2274

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### again. 1



### MR. RAMIREZ: I think I am in. 2



### (Pause.) 3


### MR. HAGERMAN: I mean, I think the 4


### committee needs to, the group nee ds to recognize 5


### that, as we've pretty tightly insulated the 6


### house, I would think , and maybe Emanue l Levy 7


### should speak up here. A s you insulate the house, 8


### your air leakage is going to improve, right? 9


### It's going to be less leaky. 10


### There's just still some co nditions that 11


### need some attention, like, you know, around the 12


### windows and the door openings, and stuff like 13


### that, pathways that need to be considered. So 14


### it's really, what's the cost of insulating those 15


### pathways? 16


### MR. RAMIREZ: So, what are the additional 17


### things that would need to be done in order to 18


### increase the efficiency around that air leakage? 19


### MR. HAGERMAN: We talked yesterday about, 20


### you know, you have to put some type of sealant at 21


### the bottom plate and the top plate, right? 2275

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### That's one big continuous area, you know, gap 1


### that you'd have to close. 2


### And then, as you sheathe the building, 3


### and you put the sheathing on the studs and the 4


### headers, there's usually spaces in between the 5


### header and the top plate, or the header and the 6


### window opening, or the windo w where the window 7


### sits in the wall assembly, in the voids there 8


### that would have to be insulated, right? 9


### Can you think of anywhere else? Oh, any 10


### penetrations

-- any time you'd have a hole 11


### through an assembly, you'd have to caulk around 12


### the hole, of course , like a piping. Maybe the 13


### outlets, like the outlets for the electrical. 14


### You'd have a punch

- out there. You'd have to 15



### insulate around that. 16


### I'm just trying to think through the 17


### steps that you'd have to do to achieve the 18


### highest, as a least

-- 19



### MR. RAMIRE Z: So it sounds like any time 20


### that you cut the exterior, you need to make sure 21



### that it's insulated around it. 2276

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### MR. TOMPOS: Dave Tompos

. 1


### Most of that is already in the standard, 2



### in section 505. I think there was some side 3


### discussion on maybe having to def ine what the 4


### pressure envelope is, because currently, the 5


### industry is using the belly board as the pressure 6


### envelope on the bottom. 7


### Now, when we go

-- I can see when we get 8



### into the

-- there's ways to move the pressure 9


### envelope to the exterior skin so they would not 10


### have to insulate around the recepts and all 11


### penetrations in the gypsum or the wall sheathing. 12


### But that exterior sheathing, if we tape that, 13


### that is now the pressure envelope , is the way I 14



### see it. 15


### So I think we're already doing pretty 16


### much every thing that the DOE , or prescriptively 17


### that we could possibly do to seal all these 18


### things. 19



### MR. HAGERMAN: So, could somebody speak, 20


### you know, if you were to just do below

- door tests 21


### on a unit that just met HUD code, and then a unit 2277

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### that met HUD code ENERGY STAR, could somebody, 1


### could maybe Emanuel Levy, or David, you, could 2


### you comment what air exchange rate you're 3


### getting? 4



### MR. TOMPOS: I think Emanuel did have 5



### some data on that. We had some also because we 6


### do that testing. And ours ranged anywhere from 7



### th ree to seven. So it was

-- 8


### MR. LUBLINER: And I submitted a report 9



### to you

-- 10



### MR. TOMPOS: It was kind of all over the 11



### board. 12



### MR. POTTS: For both HUD code and ENERGY 13



### STAR. 14



### MR. TOMPOS: Those were all ENERGY STAR. 15



### So. 16



### MR. LEVY: This is Emanuel. 17


### Yeah, w e looked at five outer homes. And 18


### the ranges, as David has indicated, anywhere from 19



### three to five or seven. Five is kind of the 20


### average. But these are homes that are tested out 21


### in the field, not in the plant. 2278

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### (Pause.) 1


### MR. HAGERMAN: So, maybe just to cu t to 2


### the chase then, so is

-- do you feel like five is 3


### a reasonable level, and that $390 and $230 are 4


### reasonable prices, so that, you know, to the end 5


### consumer on achieving a five? 6


### MR. LEVY: Well, this is Emanuel. 7


### If you recall in the white paper on 8



### whole

- house leakage, we had a list of

-- and this 9


### is what you're getting at right now, Joe. It 10



### lists the seven d ifferent measures that we would 11



### -- they would be associated with that 12



### p referential, that target leakage level. 13


### And if we look at those, I think it will 14


### give you a good sense of what

-- and particularly 15


### the manufacturers in the problem, what the items 16


### are and probably what goes out. 17


### I want to say whether those numbers seem 18


### a little bit high or low. They don't seem to be 19



### out of whack. 20



### MR. RAMIREZ: Mi chael? 21


### MR. LUBLINER: We have been testing for a 2279

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### long time in the plant and in the field, more 1


### like Emanuel, in the field. 2


### I think five is a reasonable number, 3


### based on our experience. And I provided research 4


### to DOE to support that. The IECC for the cold 5


### climates has three. I think they were 6


### compromising the five here. And I think that's 7



### reasonable. 8



### And I'd like to take note of what Rick 9


### said about giving

-- and my recommendation that 10


### we look at a period of learning without 11


### enforcement to see, and then HUD can

-- DOE can 12


### work out what they want, if they want to tweak 13


### those numbers if there's undue hardship or if 14


### it's way too much. But I think five is really 15


### where we're going to land. 16


### My interest is looking at the specifics. 17


### As I noted yesterday, I have a proposal that was 18


### reje cted by the consensus committee because HUD 19


### was going to deal with it. I thought that 20


### proposal provided more specifics to the quality 21


### assurance plan to allow for adequate inspection 2280

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### of the penetrations through the floor. 1



### And I fun damentally disagree that the 2


### belly is the predominant pressure envelope. I 3


### think it's the floor. I fundamentally disagree 4



### from the side

- built standpoint, too. I think we 5


### can agree to disagree. 6


### Anyway, I have an example of, you know , 7


### if the belly is the pressure boundary, then why 8


### is the plant caulking holes in the floor? 9



### MR. TOMPOS: They don't know any better. 10


### MR. LUBLINER: Well, no. Wait a minute, 11


### wait a minute. "They don't know better"? I 12


### mean, come on. They're cost conscious, right? 13



### So here's a picture of a plant that I went 14


### through, and they have one hole. And I'm sorry 15


### you guys can't see it. 16



### (Cross

- talk.) 17


### MR. LUBLINER: They have a penetration in 18


### the floor that's foamed. I wouldn't say it's 19


### foamed effectively, but it's foamed. But right 20



### nex t to it is a P

- trap that's like two inches by 21



### four inches that isn't caulked. 2281

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### It seems to me there's a systematic 1


### breakdown in defining

-- just like the systematic 2


### breakdown in defining what "conditioned space" 3


### is, there's a systematic breakdown in definin g 4


### what the pressure envelope is and what is 5


### required for air sealant. 6


### I'm just showing you the side that shows 7



### the holes and

-- and so I would say that we're 8


### going to get the five if we just figure out a way 9



### to seal the P

- trap in the floor, if you believe 10


### my definition that the floor is the primary air 11



### barrier. 12



### MR. TOMPOS: And that was exactly why I 13


### brought up the point that we needed to define the 14



### air barrier. 15


### MR. LUBLINER: Yep, I agree totally, 16



### Dave. 17


### MR. RAMIREZ: So, maybe I need a little 18


### help connecti ng one of the dots here. Because 19


### you're saying that in order to get to five, you 20



### would have to seal like the P

- trap and things 21


### like that, correct? 2282

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### (Pause.) 1



### MR. RAMIREZ: Michael? 2



### MR. LUBLINER: Yes. 3


### MR. RAMIREZ: So, if the group were to 4


### agree, and we hav en't taken the gauge at five, do 5


### you need to specify where that pressure envelope 6


### is? Whether it be on the belly or the actual 7


### floor, do you have to define that if that's a 8



### five? 9



### MR. LUBLINER: I'm not sure I understand. 10


### If you look at ENERGY STAR, the D OE programs, I 11


### think it would be consistent with my definition 12


### of where the pressure envelope is, being the 13


### floor, the primary pressure envelope. We work in 14


### an ENERGY STAR program, and so we caulk the 15



### floor. Because that's ENERGY STAR's definition. 16



### It's unclear to me what the definition is 17


### in this industry, and that's why Dave raised the 18


### question. I think Building Science Fundamentals 19


### suggests that you need to insulate the floor 20


### because the belly, which is really a rodent 21



### barrier. That's the reason that I understand 2283

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### that the belly insulation was originally put in 1


### there, was not for pressure envelope. It was to 2


### permit transport of the insulation and limit 3


### rodent entry into the unit. 4


### Now, I have a home with a triple

- wide. 5



### And it has numerous failures of the rodent 6


### barrier, and it's 12 years old, predominantly 7


### because the tape that was used to seal the belly, 8


### after penetrations were made, has failed. It's 9


### duct tape. It's another reason. 10


### So that when you test a home in the 11


### factory, it may have a really ti ght belly, and 12


### one could argue that belly's really tight. But 13


### over the life of the home, I think it would be 14



### fair to say that that belly, there's a high 15


### probability that that belly would be compromised. 16


### Would you agree with that, Dave? 17



### MR. TOMPOS: I woul d agree that there is 18


### a probability that that can happen. 19



### MR. LUBLINER: Thanks. 20


### MR. RAMIREZ: Okay. So you're talking 21


### about the initial testing where that might work, 2284

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### but after time, if it's the belly, then you're 1


### more likely to fall below that five over time. 2


### MR. LUBLINER: Yeah. I mean, I'm adamant 3


### that the pressure boundary is the floor. But I 4


### could see someone argue or think it was at the 5


### factory if they put one of these pressure gauges, 6


### which is what all good building scientists choose 7



### in the indus try. 8


### Have you seen one of these, Rick? 9



### (Pause.) 10



### MR. MENDLEN: No. 11



### MR. LUBLINER : So this is used for all 12



### blow er
- door testing and duct

- blaster testing. 13



### It's also used to measure blow rates. 14


### But if you put a pressure in the belly, 15


### and you measure what the pressure is in the belly 16


### versus what it is in the crawl space or outside, 17


### and what it is in the house, you'll find out 18


### pretty quickly that the predominant

-- that the 19


### pressure is really affected by the tightness of 20


### the belly versus the tightness of the flo or. 21


### I measured for two years in my house, 2285

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### every five seconds, the pressure in all these 1


### places, under a Building America program. My 2


### experience based on that is that we should be 3


### focused on the floor, as the manufacturer is 4


### attempting to do here, but not very well, because 5


### the lack of specificity in the quality assurance 6


### plan. 7


### MR. RAMIREZ: Okay. 8


### MR. SANTANA: You know, I think that 9


### there's going to be a time and a place where

-- 10


### we know the place. There's going to be a time 11


### later where we're going to ge t into the air 12


### barrier and the pressure envelope and the thermal 13


### envelope and all that stuff. 14


### I think right now what we're saying is, 15


### you know, with respect to the cost analysis, do 16


### we think that it's reasonable to say that it's 17


### going to cost X amount to g et a house to this 18


### many air changes? 19


### And, you know, I'm at a disadvantage to, 20


### say, Mike and Dave and Emanuel, because I don't 21


### have any empirical data, right, to allow me to 2286

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### know what it takes to get from an air leakage of 1


### eight to one of five to one of thr ee. 2


### But, you know, given my lack of, I guess, 3


### knowledge as to what specific elements it takes 4


### to get that improvement, I think, with respect to 5


### the cost analysis, that the costs presented here 6



### seem reasonable. 7


### MR. RAMIREZ: Okay. 8



### MR. SANTANA: I think tha t will be a 9



### thumbs

- up, and let's move on then. 10



### MR. RAMIREZ: Joe? 11


### MR. HAGERMAN: Well, if we want to just 12


### take a vote right now, to thumbs up, thumbs down, 13


### if you think

-- I just wanted to

-- so, Emanuel's 14


### last proposal, or

-- I'm sorry. 15


### One of the proposa ls that Emanuel 16


### provided at the last meeting about whole

- house 17


### leakage goes through the seven items or areas 18


### that you would have to seal and visual inspect, 19


### of course, in his proposal. So we can read 20


### through this. I think you read through them last 21


### time, but they're pretty straightforward. 2287

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### Like David said, I think you're doing a 1


### lot of them already. 2



### MR. RAMIREZ: Did David send these? 3



### MR. HAGERMAN: No. Emanuel sent this. 4



### MR. TOMPOS: No. Emanuel. 5



### (Cross

- talk.) 6


### MR. SANTANA: We're not saying, you know, 7


### that we're going to enforce seven or five or 8



### three or

-- 9


### (Chorus of "Right.") 10


### MR. SANTANA: We're just saying, for this 11


### level of enforcement, this price

-- 12


### MR. HAGERMAN: Costs, right. 13



### MR. SANTANA:

-- is reasonable to assume. 14



### MR. HAGERMAN: Let's move i t to a vote, 15



### then. 16


### MR. RAMIREZ: All right. So, setting 17


### aside what is the pressure envelope, the 18


### definition of it, the standard of five with the 19


### costs that are associated with it, is that 20


### something the group can reach consensus on? 21



### MR. HAGERMAN: Yeah. I f Ted maybe could 2288

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### pull those back up just real quick so everybody 1



### can see it. 2



### (Pause.) 3


### MR. WEISS: While he's doing that? 4


### MR. RAMIREZ: Yeah, Mark. 5


### MR. WEISS: And again, where do the 6


### numbers come from, the cost numbers? 7


### MR. HAGERMAN: I believe Navigant modeled 8


### those off of the ENERGY STAR program, that 9


### actually did

-- did actually study what it would 10


### take to go from a seven to a five. 11


### MR. WEISS: Okay. Is that based on 12


### empirical analysis of homes? 13


### MR. HAGERMAN: Yeah, it is. 14



### MR. LACEY: And it included the testing 15


### costs and records and other things, paperwork. 16



### Yeah. 17


### MR. LUBLINER: This isn't just caulking? 18


### MR. LACEY: Right. 19


### MR. SANTANA: Testing costs? 20



### (Cross

- talk.) 21


### MR. LUBLINER: No one is saying this is 2289

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### just caulking materials costs. 1



### MR. HAGERMAN: R ight. The ENERGY STAR

-- 2



### so we were conservative there. So the numbers 3


### you see up there included everything that ENERGY 4


### STAR looked at, which is the material costs to 5


### achieve it and the testing costs. We have not 6


### brought up testing here in our discussio n yet. 7


### MR. BARBOUR: To be clear, do you 8


### actually think it is? 9



### (Cross

- talk.) 10



### MR. BARBOUR: But it's not always there 11



### in the EPA documentation for the ENERGY STAR 12


### version 3, I don't think. 13


### MR. RAMIREZ: All right. Let me get

-- 14



### (Cross

- talk.) 15



### MR. RAMIREZ: Let me get David, then 16



### Michael. David? 17



### MR. TOMPOS: If we can, we'd love to get 18


### the seven things on the board. Are we

-- I guess 19


### I'm asking a question. Is the proposal to 20


### potentially do a number of prescriptive things 21


### that we believe will consistently get us to a 2290

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### five ACH, and then just do a visual inspection? 1


### Make sure that it's in the quality control 2


### manual, make sure that it's being done 3


### consistently, and not have to do any type of 4


### testing? 5


### Because if that's the case, I'm in full 6


### support of that. I think the testing is going to 7


### become another issue for manufacturers, because 8


### they're going to lean towards testing every 9


### single house . And I don't know if that's 10



### necessary. 11


### If we do some of these prescriptive 12


### things to make sure that we're always going to 13


### hit that five, I'd prefer not to see testing have 14


### to be done, especially out in the field. 15


### MR. HAGERMAN: So let me clarify 16


### something I said. So we just relooked at the 17



### ENERGY STAR data. And for the ducts, it included 18



### the cost to do the ducts that are tighter and the 19


### testing. 20


### The whole house air, the whole house 21


### leakage just included the materials. It did not 2291

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### include the testing. 1


### So what you see up there is just the 2


### material, not the testing. I'm sorry; I 3


### corrected myself. 4



### MR. RAMIREZ: Michael? 5



### MR. LUBLINER: So, if you take the 650 6


### and you divide by 2.2, which I think we got some 7



### consensus was a reasonable factor for the cost of 8


### manufacture to the retail, you end up with about 9


### $282 of materials and labor. 10


### And I would contend that, as you said, 11



### much of this stuff is already in the HUD code, 12


### and they should be doing it. And the only thing 13


### that they're not really doing is the plate and 14



### the P

- gaskets. And so, I think that you could 15


### easily do that for a lot less than 280. 16


### I mean, how many cans of Great Stuff is 17


### that, or tubes of caulking at manufacturer's 18 

### price, $280? That seems like you could do a lot 19


### of homes for that, so, and especially when 20


### they're caulking when using production costs and 21


### production systems. 2292

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### So I guess I'm a little concerned that 1



### th at price at a manufactured is very high. I 2


### think it would be much more appropriate in a 3



### site

- built home with all the subtrades and 4


### things. But again, our experience is it's 5


### nowhere close to that if the HUD code is being 6


### enforced and the specifics of the HUD code are 7



### well defined. 8



### MR. HAGERMAN: I think it's a 9


### conservative number. It's, you know, 23 cents a 10


### square foot. 11


### MR. RAMIREZ: So, do you want to gauge 12


### consensus? Or did you want to see those seven 13


### items? Because if you want to see the seven 14


### items, Emanuel, can you help us out? 15



### MR. BANTLE: Is it these seven? 16



### MR. LEVY: Yeah. 17


### MR. RAMIREZ: Okay. 18



### MR. LEVY: These are the seven. 19


### Let me interject a comment here, which is 20


### that I think if we can go back to the table, 21



### we'll come back to these seven items in a second. 2293

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### (Pause.) 1


### MR. LEVY: I think we can say with some 2


### confidence that the industry, if it's doing a 3


### good job in implementing the seven items that are 4


### on that list, some variation, can get to five. 5


### And that's what Mike said; that's what I said 6



### ea rlier, that our experience is that getting to 7


### five is something that is documentable to a lot 8


### of experience that we have, using good practice. 9



### And that's what ENERGY STAR has revealed. 10


### Whether or not it cost 390 is, we can 11


### look at the items and say whethe r those add up to 12


### 390 or not. I think we can, with some 13


### confidence, put a number on that. 14


### I don't think we can put a number on that 15


### that 390 investment saves two ACH, that the 16


### starting point is seven as opposed to eight or 17


### six. That's the piece of this w hich is important 18


### to the life cycle cost analysis that I don't 19


### think we can say with great confidence that we 20


### know what those seven items, once implemented, 21


### does for you in terms of reducing ACH levels. 2294

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### And that's why I suggested the other day 1


### that we just take this out of the cost

- benefit 2


### analysis and just say this is good practice to do 3



### those seven items and that those seven items are 4


### associated with a five ACH, and not worry about 5


### whether they're cost effective or not. 6


### They're doable. We're pretty confi dent 7


### from our experience that they do make a lot of 8


### sense, that they're reasonable things. Let's 9


### just include it as a prescriptive proposal. 10



### MR. RAMIREZ: Mark? 11


### MR. WEISS: I just want to be clear. Is 12



### th e five ACH based on complies with ENERGY STAR 13



### or co mplies with the base HUD code? 14


### MR. LEVY: They're only my comments , and 15


### Mike can say what his comments are about. Our 16


### comments that five is reasonable is based upon 17


### our testing of about 500 homes in the field all 18


### over the country that were ENERGY STAR hom es that 19



### had these features incorporated in them. 20


### MR. WEISS: Okay. Thank you. 21


### MR. RAMIREZ: All right. So I don't know 2295

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### if I mentioned this to the group before. But how 1


### many of you worked on an oil rig? 2



### (Pause.) 3



### MR. RAMIREZ: First rule of oil folks is 4



### t hat when you hit oil, stop drilling, right? And 5


### I'm hearing everybody saying that they're okay 6


### with this five. Right? So let me see a show of 7


### thumbs if we're okay with five and the costs 8



### associated with it there. 9



### (Pause.) 10


### MR. RAMIREZ: Okay. 11



### MR. EZZO: Hey, Javier, this is Mark 12



### Ezzo. 13



### MR. RAMIREZ: Yeah. 14



### MR. EZZO: I'm fine with that and with a 15


### condition, though. And the condition is, if you 16


### look at Emanuel's proposal, where we're talking 17


### about the seven items under visual inspection of 18


### prescript ive air sealing, I just want to make 19


### sure everybody is aware and agrees that that is

- 20



### - that's one of the means of achieving the whole

21


### house leakage standard, meaning it's a way of 2296

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### doing it without having to perform a physical 1



### test. 2


### So in Emanuel's paper, his whi te paper, 3


### it says you either hit

-- you either test the 4


### home and hit a certain air change per hour 5


### number, or you follow the visual inspection of 6


### prescriptive air sealing measures, which is these 7



### seven items. 8


### MR. RAMIREZ: Okay. And is that

-- 9



### MR. EZZO: And I think that's a really 10


### good proposal. And I support it. And I'm fine 11


### with the cost numbers associated with doing that. 12


### MR. RAMIREZ: All right. 13


### Joe, and then Lowell. 14


### MR. HAGERMAN: Joe Hagerman, DOE. 15


### So, do you think, Mark, then

-- I'm 16


### assuming you can see what's on the screen right 17



### now? Is that correct? 18



### (Pause.) 19


### MR. EZZO: Yeah, I can see it. 20


### MR. HAGERMAN: Are you trying to say 21


### that, instead of the word "all" there, you could 2297

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### say "one means for manufactured homes to be 1


### sealed against air leakage ," and then include the 2



### list ? Is that what you're

-- 3



### MR. EZZO: I think if a manufacturer is 4


### going to use this list of seven as their means 5


### for compliance, they have to do it on every home. 6


### MR. HAGERMAN: Right. 7


### MR. RAMIREZ: This or testing? 8



### MR. HAGERMA N: This or testing, right? 9



### MR. EZZO: Correct. 10


### MR. HAGERMAN: Okay. 11



### MR. RAMIREZ: Lowell? 12


### MR. UNGAR: I have a couple of questions. 13


### One is, Mike had raised some issues, and it's not 14


### clear to me whether those are included, captured 15


### here or not captured h ere. 16



### MR. LUBLINER: This is Mike Lubliner. 17


### I have no idea, because we still can't 18


### define the conditioned space and the pressure 19


### envelope. So I really

-- my feeling is anything 20



### in the floor needs to be caulked. If there's a 21


### hole in the floor, it needs to be caulked. I 2298

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### don't care what you call it, where it is, it 1


### should be caulked. And that's my feeling. 2


### And my other feeling is just that I think 3


### the costs that are being used are a little high. 4


### And once you get into a mode, production

-- and 5


### again, but th ose are my
-- that's kind of why I 6



### have some concern about this. The manufacturers 7



### know what the costs are. And I

-- 8


### MR. BANTLE: Just for somebody on the 9


### phone who's having another conversation, if you 10


### could mute your phone, that would be greatly 11



### appre ciated. Thank you. 12


### MR. LUBLINER: I'd certainly defer to 13



### Mark as to what the costs are. I'm not

-- I can 14


### just tell you from our experience is that, as you 15


### do it on every home in the line, it's going to

-- 16 

### it's not going to be $280 worth of labor and 17



### mate rials. 18


### I do have some significant concerns about 19



### the other issue that Emanuel raised of 20


### eliminating this from the life cycle cost 21


### analysis. I fundamentally disagree with that. 2299

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### I would be willing to talk about the 1


### testing criteria. I don't think it should be you 2


### either test or you do the caulk. You always do 3


### the caulk. You use the testing as a feedback 4


### tool to teach the plants what they're missing. 5


### And I think Emanuel's proposal was adequate of 6


### testing quarterly. 7


### What I'd like to see is, once a quarter, 8


### manufacturers set up a home and test the ducts, 9


### test the envelope, test the flow rates of the 10


### HCVAC system to see they're in compliance with 11



### the HUD code and the manufacturers' 12


### recommendations. And we do this all at once, 13


### four times a year in each plant for the first 14


### couple of years, under DOE's auspices, and see 15



### where we're at. 16


### So anyway, that's kind of my 17



### recommendation. 18


### MR. HAGERMAN: So, just to interject real 19


### quick

-- 20



### MR. SCHNEIDER: This is Peter from 21


### Efficiency Vermont. 22100

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### MR. HAGERMAN: Peter, let m e
-- 1


### MR. SCHNEIDER: I'd like to interject. 2


### MR. HAGERMAN: Hey, Peter, let me get a 3


### first real quick, just because I think that

-- 4


### and you tell me, Peter, how you're voting because 5


### we can't see your thumb. 6


### I think, Michael, you were the only 7


### negative. 8



### MR. LUBLINER: Mark. 9



### MR. RAMIREZ: Mark. 10


### MR. HAGERMAN: Oh, Mark was negative, 11


### too? Okay. 12



### (Cross

- talk.) 13


### MR. HAGERMAN: I was just going to say I 14


### think your objection for the negative was just 15


### the thermal envelope floor issue. And I think a 16


### suitable, maybe , compromise here may be just 17


### under three, where it says "gaps in penetration 18


### of thermal envelopes sealed with caulk, foam, 19


### gasket, and other suitable materials, including 20


### the following," we just add in there, 21


### "penetrations in the floor." 22101

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### MR. LUBLINER: All penetrations in floor 1



### would be

-- 2


### MR. HAGERMAN: All penetrations in the 3


### floor. And then you go from a negative to a 4


### positive, right? 5



### MR. EZZO: This is Mark Ezzo. I'm fine 6



### with that. 7


### MR. HAGERMAN: Okay. 8


### MR. LUBLINER: Peter wanted to say 9


### something. 10


### MR. HAGERMAN: And I'm sorry, Peter. I 11



### cut Peter off. 12


### MR. RAMIREZ: Let's get Peter, then 13


### Manny, then Lowell. Yeah, Peter, Manny, then 14



### Lowell. 15


### MR. SCHNEIDER: Thank you. 16


### I just want to echo what Michael said. 17


### That's the thing I think is critical is that of 18


### this standard and this particular parameter with 19


### regards to air sealing measure. So I think, at 20


### the bare minimum, quar terly ducts and envelope 21



### blower

- door testing. 22102

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### Having done that for the past 15 years 1


### myself, even working with some of the best 2



### modul ar home builders up here, there's always 3


### room for improvement. Every single year, there 4


### are new improved products that are more cost 5


### effective and work better over the long term. 6


### And so, I think that, in addition to the 7


### visual inspection and the prescript ive list of 8


### measures, which astounds me that we're not doing 9


### this as due course in all of our buildings, I 10


### think that testing quarterly should be a part of 11


### this just to ensure that we're continuing to 12


### improve the envelope and reduce air infiltration. 13



### I'd l ike to see three ACH in, you know, 14


### three years time. 15


### MR. RAMIREZ: All right. We have Manny, 16


### Lowell, I think Bert wanted to speak. Lois, and 17



### then Michael. 18


### But one thing before we continue on with 19


### the conversation, the testing piece or the 20


### enforcement pie ce may be something that's 21



### discussed with the next committee that we form. 22103

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### So I don't want to bog down this conversation too 1



### much. 2


### I think we're making great progress. I 3


### think we're just about there, right? But I don't 4


### want to go down that path too far. 5


### Okay. So let me get Manny, Lowell, Bert, 6


### Lois, Michael, and then Mark. 7


### MR. SANTANA: You know, I think Javier 8


### said what I was going to say, is that how we 9


### verify the air changes isn't what we're trying to 10


### decide on. We're trying to say, is the cost 11



### reas onable for the air changes? 12


### Regardless of whether you, you know

-- if 13


### you consider the air barrier to be the belly 14


### board or the air barrier to be the floor, and 15


### you're going to test, the test doesn't know

-- 16


### there is no input that says, "What do you 17



### consid er the air barrier?" 18


### So you either have this loss, or you 19


### don't have this loss. So the only thing we're 20


### saying, without getting in the weeds, is, is the 21


### cost associated with obtaining this tightness 22104

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### reasonable? 1


### You know, I mean, I don't know that we 2



### have to put up the seven items or go over them, 3


### because, you know, we haven't even decided on how 4


### many air changes we're going to enforce, whether 5



### it's five or whether it's seven or whether it's 6



### less. 7



### MR. RAMIREZ: I'll add Keith to the list. 8


### So, Lowell is nex t. 9


### MR. UNGAR: So, that's not my 10


### understanding of what we're discussing. So 11


### perhaps we should clarify what

-- I mean, I 12


### thought we were not discussing just the cost 13


### numbers, but we were discussing whether this 14



### would

-- what would be part of the standard. 15



### MR. RAMIREZ: Yes. 16



### (Cross

- talk.) 17



### MR. RAMIREZ: And the level of five. 18



### MR. HAGERMAN: Five and the costs. 19



### (Pause.) 20



### MR. UN GAR: Well, so my understanding, w e 21


### have the level five or, at the moment, this 22105

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### visual list. And in addition, for whichever, 1



### either one of those, the costs, what the cost 2


### would be associated with that. Okay. 3



### MR. RAMIREZ: Yeah. Yeah. 4


### MR. UNGAR: So, given that, it seems to 5



### me what would make most sense is to have both a 6


### performance level. And unless we assume that all 7



### homes would be te sted to that performance level, 8


### that we have a kind of prescriptive description 9


### that we know would apply to all homes. And that 10



### would be

-- you know, some combination would be 11


### the way of making sure that we're achieving the 12


### kind of air leakage that we're aiming for. 13



### I understand the concern that even if 14


### you're not requiring

-- and this gets into 15


### testing, but I don't think it's separable, that 16


### even if you're not requiring all homes, even if 17


### you don't require all homes to be tested to meet 18


### the performance le vel, that puts manufacturers in 19



### a bind. 20


### So I wonder whether there's a way of 21


### incorporating the performance level not as a 22106

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### mandatory requirement for all homes, but to 1


### incorporate

-- it would be a prescriptive 2


### requirement for all homes, and in addition, a 3



### re quirement that the testing be done 4


### periodically. 5


### And if the testing does not show meeting 6


### the target level, that you wouldn't then have a 7


### recourse of going and requiring every home that's 8


### been manufactured for the last period to be 9


### fixed, but you would req uire the manufacturer to 10


### fix the process and retest so that that ensure d 11


### that homes going forward are in fact meeting that 12



### target. 13


### MR. RAMIREZ: Okay. So you're, it's like 14


### we're seconding the idea of some type of 15


### quarterly testing or some type of testing 16


### periodically to make sure that they're on track? 17


### MR. UNGAR: Yeah. It seems to me you 18


### need both these prescriptive description and 19



### tes ting. But if you can do that, if the problem 20


### is that once you put a requirement on the 21


### performance standard as a require ment on homes 22107

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### that you then force

-- in practice, force 1


### manufacturers to test all homes, whether the way 2


### of reframing the performance requirement so that 3


### it's a performance requirement on the factory and 4


### not on the homes, basically, so that you would 5



### then require the factory to fix their process if 6


### they're not meeting that target. 7


### MR. RAMIREZ: Okay. Thank you. 8


### Bert, did you have something? 9



### MR. KESSLER: Yeah. I was just going to 10


### ask the group if anybody had a chance to review 11


### the white paper that Javier emailed, I believe, 12


### Saturday, that Joe Lstiburek put out relative to 13



### floor assemblies and what to do and what not to 14


### do, which is right up our alley here, and in 15


### fact, caused the addition of the exception in 16



### 402.2.8 of the 2015 IECC. 17


### And once you have a ch ance to review 18


### that, I think you'll probably lean more towards 19


### using the bottom board as the air barrier than 20


### the floor decking. Because if we're 21


### concentrating on the floor decking and continue 22108

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### installing the insulation as it's typically 1



### installed in our industry in the belly, then we 2


### may achieve our goal on the infiltration side, 3


### but we're losing the effectiveness on the thermal 4



### insulation side. 5


### MR. RAMIREZ: Okay. Thank you. 6



### Lois? 7



### MR. SCHNEIDER: This is Peter. I have to 8



### agree
-- 9



### MR. RAMIREZ: Peter, let me add you to 10


### the list. We'll make sure that we get your 11



### comments. 12



### Lois? 13


### MS. STARKEY: I just wanted a 14


### clarification from Peter, and also to point out 15



### on
-- Peter, when you talk about testing, were 16


### you testing those modulars in the plant? Or were 17



### you testing them onsite? 18



### MR. SCHNEIDER: We do both. 19


### MS. STARKEY: Okay. 20


### MR. RAMIREZ: Okay. Was that it, Lois? 21



### MS. STARKEY: Um

- hm. 22109

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### MR. RAMIREZ: Okay. Michael? 1



### MR. LUBLINER: Yeah. I am in 2



### communications with Joe Lstiburek , and I did 3


### reply to you, Bert. I haven't heard back from 4



### you. 5


### I think there's an equitable way of 6


### dealing with this by providing an exemption for 7


### the floor cover, that the floor insulation needs 8



### to contact the under

- decking between the I

- beams. 9


### What I think is if y ou get the first fe w feet 10



### dense

- packed or insulated well, that you'll be

-- 11


### that this would be a way to address your problem. 12


### In other words, after you get past the I

13


### beam, the insulation would go under the ducts, 14


### under the plumbing, under everything. And that's 15


### basically

- - it falls into the belly. And that's 16


### the way we've been doing it in 100,000 homes. 17


### I would also suggest that if you talk to 18



### Joe Lstiburek , he will adamantly disagree that 19


### the pressure boundary, the primary pressure 20


### boundary is the belly insulation. And if you'd 21


### like, I can get him on the phone right now if you 22110

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### want. 1



### (Pause.) 2



### MR. RAMIREZ: Let's hold off on that. 3


### MR. KESSLER: No, I don't think that's 4



### necessary. 5


### MR. LUBLINER: Thanks. You definitely

-- 6


### that was a good call, Bert. 7


### (Laughter.) 8



### MR. RAMIREZ: Mark? 9


### MR. WEISS: Just wanted to provide some 10


### explanation of my NOVA. 11


### I do have some concern about essentially 12


### mandating ENERGY STAR levels. But my primary 13


### concern again goes to the derivation of the cost 14


### figures. And I explained what those concerns 15



### we re. Yes, I won't repeat them; I'm just trying 16


### to be consistent through this line of 17


### exploration. 18


### MR. RAMIREZ: Thank you. Okay. 19



### Keith? 20



### MR. DENNIS : I don't know if it matters. 21


### But where that red is, all penetration

-- I don't 22111

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### know if that's supposed to be up

-- 1



### MR. BANTLE: To here? 2


### MR. DENNIS: Up higher. Yeah, just I 3



### don't know. Because I think if it's not a 4


### thermal envelope, then you kind of miss it. And 5



### that's kind of where the duct

-- it just seems 6


### like it goes

-- what is this penetration and 7



### t hermal envelope, penetration at the floor. 8


### But all these things seem like things 9


### that somebody would have to do if they went into 10



### a retrofit situation. And I kind of understand 11


### the argument between, you know, where the gaps 12



### are and

-- I mean, where the ba rrier is. Is it 13


### up here or down here ? 14


### But the reality is that if there is a 15


### problem with the belly board , you're going to 16


### have to go in and somebody's going to look at all 17


### the holes in the floor and start caulking them. 18


### And it's just easier to do it up f ront. 19


### So, you know, I think that idea, I think 20



### it was

-- maybe Manny was saying, you know, there 21


### is a test to see if the air penetration is, you 22112

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### kno w, acceptable or not. And then there 1


### shouldn't be any, you know, a prescription here 2


### or there. It should j ust be whether or not that 3


### test is being met. 4


### But, you know, in reality, I think that 5


### these things operate a little bit differently 6


### when you test them and in the actual 7


### manufacturing facility than when they're actually 8


### in the field. And, you know, just ca ulking holes 9


### in the floor is something that you don't want to 10


### have to do later, especially around a dirty 11



### toilet. 12


### But, you know, there doesn't need to be 13


### holes in the floor if you can get, you know, 14



### manufacture r discounts on the caulking and just 15


### do it up front. Because the person going in with 16 

### the caulking gun to fix somebody who has a $600

- 17



### a
- month bill isn't going to bother to figure out 18


### if that's the actual problem. They're going to 19


### caulk that hole. So you might as well just have 20



### all the holes caulked

. 21


### And you don't want holes in the floor. I 22113

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### mean, you just don't want it. So, I think it 1


### makes sense to do it this way. I think, you 2


### know, that's the only thing I take a position on. 3


### I think taking something out of the life 4


### cycle assessment is kind of

-- I don't know. 5


### That seems tenuous to me, taking things out. But 6



### this seems like commonsense measures that are 7


### going to have to be done in a retrofit situation 8


### if there's a problem. So you should probably 9


### just do them up front. 10


### MR. RAMIREZ: Thanks, Keit h. 11



### David? 12



### MR. TOMPOS: Dave Tompos

. 13


### I just wanted to make a comment that I 14


### agree that this should be included on all 15


### manufactured homes. I agree with Lowell on 16


### possibly doing a quarterly test if we can somehow 17


### avoid subpart I. And I don't know how that c an 18


### be done, but I'll leave that up to DOE. 19


### MR. RAMIREZ: All right. So, what is 20


### subpart I? 21



### (Cross

- talk.) 22114

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### MR. TOMPOS: I don't know who is in 1


### charge of that. 2



### (Cross

- talk and laughter.) 3



### MR. LUBLIN ER: T humbs up on that one? 4



### (Pause.) 5



### MR. TOMPOS: That's a b ig "if," I think. 6


### I just want to clarify that. Because if we don't 7


### somehow avoid that, you're going to have to 8


### include the cost of testing every home. 9


### MR. HAGERMAN: Joe Hagerman, DOE. 10


### Let's just keep in mind we're here to set 11


### the standard, and we can ma ke recommendations to 12


### the committee for the compliance enforcement like 13


### testing stuff. But I think we'll take all your 14



### comments into

-- 15



### MR. TOMPOS: But I think it's difficult 16


### to make a decision on what we're going to do here 17


### if we're going to say that testing may or may not 18



### be involved. 19


### MR. HAGERMAN: I don't disagree with you. 20


### But all you can do is make a recommendation. So. 21


### MR. RAMIREZ: Yes. So we're going to put 22115

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### that under the suggestions right there that will 1


### go to recommendations, right, for qu arterly 2


### testing, excluding subpart I. 3


### MR. HAGERMAN: Just keep in mind that the 4



### committee can make a recommendation to ASRAC to 5



### form this same committee to talk

-- to do 6


### compliance and testing and enforcement. 7



### (Cross

- talk.) 8



### MR. TOMPOS: Then I'm going to m ake a 9


### proposal that we just do a prescriptive method 10


### with a visual inspection and no testing. I'm 11


### just going to put that on the table as one 12


### proposal. 13


### MR. RAMIREZ: Okay. Let me get Peter, 14



### then Mark. 15



### Peter? 16


### MR. SCHNEIDER: I'm good. 17



### MR. RAMIREZ: You're good? Okay. 18



### Mark? 19


### MR. WEISS: I just wish the OGC folks 20


### were here. And this goes back to part of what I 21


### was saying yesterday. And that is that cost to 22116

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### the consumer in any regulatory situation is an 1


### amalgam of what it costs to comply with the 2


### standard p lus regulatory compliance costs. 3


### The way that this committee has been put 4


### together and its jurisdiction, its authority, has 5


### been defined necessarily excludes part of the 6


### cost that is inevitably going to occur as an 7


### incident of developing a standard. 8



### Theref ore, to me, that is an arbitrary 9



### delineation of our function that excludes a 10


### critical element. And that's part of my 11


### objection to the development of the cost data. 12


### It's okay to say, "W ell, we're going to 13


### have another committee and we're going to look at 14



### t his later. " But I have no assurance now, 15


### sitting here, deciding yes, no, whatever, of how 16


### that's going to play out. 17



### MR. RAMIREZ: David? 18



### MR. TOMPOS: Here would be my addition. 19


### I would say we eliminate these ACH requirement of 20


### five. We have a set of pre scriptive measures 21


### that can be visually inspected, and that's what 22117

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### we could push forward as a consensus. And then 1


### DOE outside of the regulations could come back 2


### and we could do a study to find out whether or 3


### not we're meeting that ACH of five. 4



### But as soon as we put an ACH of five in 5


### there, there's going to have to be some kind of 6


### testing component. And I really, personally, 7


### don't think there's any way you're going to get 8


### around subpart I. 9


### So, my p roposal would be, and we can add 10


### to this if we want to, but we include all these 11


### ENERGY STAR provisions. I think if we make sure 12


### that we're sealing the floor, I don't think

-- my 13


### personal opinion is, based on what I've seen in 14


### ENERGY STAR, you're not going to have any 15


### problems meeting five as long as we seal the 16


### floors and everything that we're supposed to do. 17


### So that would be my

-- a way to move this 18


### forward would be to say, forget the testing. Let 19


### DOE do that outside as a different study to make 20


### sure that we're getting the five ACH. And then 21


### just have a presc riptive visually inspected 22118

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### requirement. 1


### MR. RAMIREZ: Okay. So, Michael and Joe. 2


### MR. LUBLINER: So, the site

- built 3


### industry requires that all blow er
-- all houses 4



### to be blowe r - door tested. But my understanding 5


### is, the way it's being enforced is that it's

-- 6


### they don't get red

- tagged for it. 7



### MR. TOMPOS: Exactly. 8



### MR. LUBLINER: But it's an educational 9



### tool. Until the time that I don't see this 10


### anymore, to a QA plan, I would like to see this 11


### part quarterly testing as when analysts proposed. 12


### I would say th at we should err on the 13


### conservative side and do the testing until it's 14


### shown that the testing isn't needed. 15


### Based on my experience of going in any 16


### home on any dealer or lot and seeing holes that 17



### -- I mean, this one was actually caulked. But 18



### this is a bi g gap. I have been saying this for 19


### 10 years on the consensus committee. All it will 20


### take is an enforced prescriptive approach that is 21


### in the quality assurance plan. And if there's a 22119

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### systematic breakdown in the plan, like the P

1


### traps aren't being sealed, that should get a 2


### subpart I. 3



### MR. TOMPOS: It should. 4


### MR. LUBLINER: I represent the consumer 5


### on that committee, you know? And so I think that 6



### we should leave it at five. We should have a 7


### prescriptive that five should be advisory. And 8


### DOE should go out and see whether or not the 9


### enforcement process is effective in getting five. 10


### And I think if we do quarterly

-- what 11


### happens is we get feedback to the plant, says, 12


### "Hey, you know, we need to figure out a system, 13


### because we're missing this at one more point. " 14


### The majority of leakage problems we see with 15


### ducts and envelopes has to do with setup code, 16


### has to do with the people after the fact not 17


### puttin g the marriage lin e in. 18


### We find that if the marriage li ne is 19


### installed at the factory, as opposed to shipped 20



### l oose in the vat and then left up to the retailer 21


### to install, we get much more effective blower

- 22120

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### door tests in the field. 1



### One consideration for a manufacturer is 2


### to require that the gasketing for the mating line 3


### be engineered and installed at the factory so 4


### that we improve the process. And I also would 5


### recommend strongly that the installation manuals 6



### recommend that the homes be blower

- door tested. 7



### And I think that's a recommendation that would be 8


### a very good one for consumers. 9



### And I also think

-- and this i s a final 10


### point. The State of Minnesota went ahead and 11


### asked HUD if the state energy code, which 12


### requires all site

- built homes to be blower

13


### doored, if they could go in and require 14


### manufactured homes during setup to be blower

15



### doored. 16



### And if I understand HU D's legal staff, 17


### they said that that was a federal

-- that was a 18


### violation of the federal preemption. 19


### Well, while I fundamentally disagree with 20


### that legal interpretation, I would certainly ask 21


### legal counsel to talk to HUD's legal counsel and 22121

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### look into that interpretation, because in 1


### reality, that

-- if we have the

-- if you agree, 2


### then we're going to have to take an approach 3



### that's focused more on the installation manual. 4


### If you think that states do have the right to 5


### enforce requirements for blower

- door te sts at 6


### setup, then that opens it up for us to

-- the 7


### states to be able to evaluate what's being sealed 8


### and what's not in the factory and on site. 9


### So this is kind of an adjunct. It's a 10


### request for legal counsel at HUD to dialog, 11


### liaison, with the person t hat made that 12


### interpretation, come back to the committee, and 13


### see if we agree. At that point, I'd be in a 14


### position to do a better job of solving this 15


### problem. But it's the weak link in the chain is 16


### the setup. 17



### Am I clear

-- I mean, Rick, can we get 18



### the in terpretation on this to the committee? 19



### MR. MENDLEN: If I can? 20



### MR. RAMIREZ: Yeah. 21


### MR. MENDLEN: HUD's attorneys, together 22122

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### with HUD staff, made the determination that it is 1


### preempted. Simple, end of story. Any 2


### consultation with DOE's attorneys it not goi ng to 3


### change that opinion. 4


### Now, since you gave me the floor

-- 5


### MR. LUBLINER: Thank you. 6


### (Laughter.) 7


### MR. MENDLEN: We don't do advisory 8


### standards. We're not going to put something in 9


### our standards that says that if you want to, you 10


### can test quarterly and the results don't mean 11


### anything. We're just not going to do that. And 12


### this is a regulatory program. 13


### And then while I'm at it, if you want to 14


### make that more of a regulatory piece, you ought 15


### to say, whoever's typing, "and penetrations in 16



### floors must be se aled." 17


### MR. RAMIREZ: Okay. 18


### MR. WEISS: Do you want to say a 19


### regulatory program with criminal penalties for 20


### not complying? 21



### MR. MENDLEN: With criminal and civil 22123

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### penalties. Thank you for not cutting one

. 1



### Thanks for that. 2


### (Laughter.) 3


### MR. RAMIREZ: Joe, th en David. 4



### MR. HAGERMAN: You had your hand up, so 5



### if it addresses

-- 6



### MR. TOMPOS: I did. I think we're real 7


### close here, Mike, on coming to something. 8


### My suggestion would be

-- because the 9


### problem here is somewhat the regulatory end of 10



### it. My suggestion would be, okay, we require all 11


### these prescriptively. I don't think there's any 12


### way we can have an advisory

-- as HUD said, an 13


### advisory that we're going to meet five or 14



### whatever it is. 15


### Don't make it a responsibility of the 16



### manufacturer. We'll do all this. It will go in 17


### the QC plan, and we will make sure that the 18


### manufacturer does it. Or we will have a subpart 19


### I. If they decide not to caulk around something, 20


### the manufacturer is going to have to go out, do 21


### inspections, make sure that the floors are all 22124

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### ca ulked. 1


### And based on our experience, we're going 2



### to meet five consistently if they do all these 3


### things consistently, like they will if we put it 4


### in the QC plan. 5


### My suggestion would be, as far as the 6


### testing, make that the responsibility of DOE. If 7


### they wan t to verify that we're meeting five ACH, 8


### have them go out quarterly and do a study. I 9


### don't think it needs to be quarterly. But go out 10


### and do a study of some kind. They've got all 11


### kinds of money. 12


### (Laughter.) 13



### MR. TOMPOS: The manufacturers don't, and 14



### th e consumers don't. 15


### So that would be my suggestion. I think 16


### that gets us where we want to go. We're 17


### prescriptively getting to something that we think 18


### will get five ACH. We don't make five ACH a 19


### requirement, but DOE will do a study to make sure 20



### that we ar e meeting that. 21


### And if not, we'll come back to the table 22125

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### and say, "Okay. We're going to flash all the 1


### windows." I don't know what the next step would 2


### be to make sure we get that on a consistent 3



### basis. 4


### MR. RAMIREZ: Joe, and then

-- 5



### MR. HAGERMAN: I'm re ady for a vote if

-- 6


### I'll put my placard down. I just have a 7


### technical question for Emanuel. But it's

-- 8


### MR. RAMIREZ: Okay. Then, what I'm 9


### hearing then is the amended vote is to adopt a 10


### prescriptive path of the seven components here, 11



### without the leve l. Right? 12


### So, let me see a

-- 13



### (Cross

- talk.) 14


### MR. RAMIREZ: I'm sorry, and the costs. 15



### MR. TOMPOS: It's going to cost the same. 16


### We're just not saying that we have to meet this 17


### level. Because if we do that, now we have to 18



### test. 19


### MR. RAMIREZ: Right. The c osts are the 20



### same. 21



### MR. TOMPOS: Yeah. 22126

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### MR. RAMIREZ: It's just without the 1


### testing. 2


### So let me see a show of thumbs, the seven 3


### prescriptive paths

-- the seven items here using 4


### a prescriptive path. 5


### MR. HAGERMAN: I just want one. So let 6


### me go ahead and ask my question. I'm not trying 7


### to stop a vote here, by any means. But I believe 8


### Emanuel Levy said that these seven prescriptive 9


### measures were a product of ENERGY STAR. And 10


### there's a study out there, after doing 500 tests 11


### on homes, that said these seven mea sures roughly 12


### get you a five. 13


### Is that correct? And if that is correct, 14


### I mean, if you could point us to that study, that 15


### would just help. I mean, it would help to have 16


### that study referenced here. 17


### MR. LUBLINER: Five on average. 18


### MR. HAGERMAN: On average, right, on 19



### average. 20



### MR. LUBLINER: Half of them don't make 21



### it. 22127

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### MR. HAGERMAN: And half of them get 1



### three. 2


### MR. LUBLINER: Right. 3



### MR. TOMPOS: Just real quick, I think if 4


### you define that air barrier, I think you're going 5



### to find that our consistent values ar e going to 6


### go way down. So. 7


### MR. HAGERMAN: Way down, right, okay. 8


### But otherwise, I'd like to see that study. But 9


### it's not going to stop my vote from being 10


### positive. 11



### MR. RAMIREZ: Let's see the vote. 12



### (Pause.) 13


### MR. BANTLE: Are we voting with the red 14



### in or the red out ? 15


### MR. RAMIREZ: Yeah. The way it's up 16



### there. 17


### So, Michael, you were sideways? 18


### MR. LUBLINER: Yeah, I'm sideways other 19



### than cost. 20


### MR. RAMIREZ: Okay. Was anyone on the 21


### phone a no vote? 22128

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### (Pause.) 1


### MR. RAMIREZ: All right. Then let it be 2



### shown tha t there was one no vote. 3



### MR. HAGERMAN: I think two no votes? 4


### MR. RAMIREZ: I'm sorry. 5



### (Cross

- talk.) 6



### MR. SCHNEIDER: Three. 7


### MR. RAMIREZ: Okay. And Lowell. 8



### MR. RAMIREZ: And Peter. 9


### MR. KESSLER: This is Bert. I'm voting 10



### no. 11


### MR. RAMIREZ: So, we have

-- 12



### (Pause.) 13



### MR. RAMIREZ: Bert. 14



### MR. SCHNEIDER: This is Peter. 15



### MR. RAMIREZ: Peter. 16


### MR. SCHNEIDER: Could you scroll back up? 17


### I was just wondering

-- 18



### (Pause.) 19


### MR. RAMIREZ: Okay? 20



### MR. SC HNEIDER: I have just a comment 21


### from Peter, Efficiency Vermont, just in regards 22129

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### to the language at number three. 1


### It just seems redundant, and maybe gap 2


### penetration for thermal envelope. Could we just 3


### spell that out as "gaps and penetration for 4


### walls, ceilings, and floors"? Just so it's 5


### really clear ? 6


### MR. BANTLE: Could you s ay that again, 7



### Peter? 8



### MR. S CHNEIDER: I was saying that if the 9


### language could be just

-- so it does n't

-- or it 10



### does make sense to me. To others it won't. But 11



### " gap s and penetrations in the walls, ceilings, 12



### and floors." 13


### MR. BANTLE: You're breaking up a little, 14


### Peter. Did you say " gaps in penetrations in the 15


### walls, ceilings, and "

-- 16



### MR. SCHNEIDER: Floors. 17



### MR. BANTLE: Floors? 18



### MR. SCHNEIDER: " Shall be caulked, " as 19


### opposed to putting " thermal envelopes and 20



### floors. " And I sent a, just a picture with a red 21



### line of the section of the manufactured home. 22130

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### And I just

-- all I wanted to say was in regards 1


### to that, I sent it along to Javier and didn't 2


### know if we wanted to look at it as a group. 3


### It might

-- it would just help as far as 4


### what we're actually defin ing as that air barrier 5


### and in regards to cost as we move forward now 6


### with this, with bringing it outside of the wall 7


### to this building and floor plane, which it sounds 8


### like we're in agreement on. Then it's easier to 9


### just describe what needs to be done at each 10


### place. 11



### That's a t a fairly good number. But, 12


### yeah. I think that that's better. Thank you. 13



### MR. BANTLE: So this is now the 14


### suggestion from Peter. 15



### (Pause.) 16



### MR. TOMPOS: Dave Tompos

. 17


### Just maybe something that makes it a 18


### little clearer is, instead of sa ying "walls, 19


### ceilings, floors," we say "in the pressure 20


### envelope." And then make sure that we define the 21


### floor as the pressure envelope, instead of the 22131

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### belly. 1


### MS. DICKENS: And the pressure envelope 2


### including walls, ceilings, and floor. 3



### MR. TOMPOS: But t he pressure envelope 4


### basically is around the entire

-- 5


### MS. DICKENS: Right. But that way, at 6


### least the floors are being included for sure. 7



### MR. RAMIREZ: Michael? 8


### MR. LUBLINER: Subpart F, "thermal 9


### protection definitions: Pressure envelope means 10


### the prim ary air barrier surrounding the living 11


### space which serves to limit air leakage. In 12


### construction," and then it talks about ventilated 13



### cavities. 14


### In construction using ventilated 15


### cavities, which isn't a discussion here, the 16


### pressure envelope is the interior skin. 17


### So I would ask Rick to define, is the 18


### floor the pressure envelope? Or is the belly? 19


### MR. MENDLEN: I don't give 20


### interpretations. 21


### (Laughter.) 22132

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### MR. LUBLINER: I didn't think you would. 1



### MR. TOMPOS: Well, no. I can answer 2



### that. 3



### (Cross

- talk.) 4



### MR. TOMPOS: Here's how the industry is 5


### interpreting

- - I shouldn't say "interpreting, " 6



### b ut how we're looking at that section, is that 7



### because it does reference ventilator wall 8


### cavities. So if you have a ventilated wall 9


### cavity, then it is the interior surface. 10



### If I put an exterior sheathing on the 11



### home like an air barrier

-- like a house wrap, or 12


### I seal those gaps on that exterior sheathing, in 13


### my opinion, now, the air barrier is the exterior 14



### of that wall. 15



### That's

-- and the industry has looked at 16


### the belly board as t hat exterior sheathing. All 17


### I'm saying is, if we want to ensure that we get 18


### that five ACH, we need to make sure that we 19


### change the industry's understanding of that and 20



### make sure we're real clear that the pressure 21


### envelope is that

-- is the floor. 22133

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### I think there's going to be some 1



### contention

-- and we also need to make sure that 2



### we understand that it can be the exterior of the 3


### walls. So that's why I was using pressure 4


### envelope instead of thermal envelope or walls, 5


### ceilings

-- 6



### MR. LUBLINER: Even Rick would n't give an 7


### interpretation, but you're the engineer that 8


### represents manufacturing. 9



### MR. TOMPOS: Well, I follow what HUD 10



### tells me. So

-- 11


### MR. LUBLINER: If HUD doesn't tell you 12


### something, what do you do? 13



### MR. TOMPOS: I follow what it says in 14



### black and whit e. 15


### MR. RAMIREZ: Manny? 16


### MR. SANTANA: Irrespective of whether you 17



### think the bottom board is the air barrier or the 18


### floor is the air barrier, you know, the IECC 19



### doesn't have a

-- it doesn't define what pressure 20


### barrier is. You know, but like I said, 21


### regard less of which one you think, it's a good 22134

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### idea to have them both. You don't want to have 1



### holes in either for a lot of reasons. 2


### I don't think that's really, I think, 3


### important right now. You know, we're going to 4


### get into that later on. I'd be against call ing 5


### the floor the pressure barrier if there is a 6


### bottom board there. But for other reasons, but 7


### as far as tightness goes, you want to have 8


### everything sealed. 9


### MR. RAMIREZ: So that verbiage wouldn't 10



### work then? 11



### (Pause.) 12



### MR. TOMPOS: Manny, I'm curious. Wh at 13


### other problems are you going to have with calling 14


### the floor the pressure envelope? Because I

-- 15



### MR. SANTANA: Well, the insulation is 16


### required to be in substantial contact with the 17


### decking. That's about it. 18


### MR. LUBLINER: So, Manny, if we were able 19



### t o make an exception on the substantial contact 20



### of the insulation between the I

- beams, would that 21


### satisfy your problem? 22135

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### MR. SANTANA: Yeah, I think so. 1


### Reserving the right in case there's other 2


### information. But, yeah, I think so. 3


### MR. LUBLINER: My unders tanding right now 4


### is that there's lots of homes out there where, 5


### when you get past the I

- beam, the insulation is 6


### no longer in contact. 7


### MR. SANTANA: Okay. 8


### MR. LUBLINER: Right now. 9


### MR. SANTANA: Okay. 10


### MR. LUBLINER: Belly insulation by 11


### physics, right? So we're not doing anything 12


### different, right? By adding more insulation, you 13


### still don't have belly insulation contact from 14



### the I

- beam to I

- beam now. And it's not a 15


### problem. Why would it be a problem when we add 16



### more insulation? 17


### And I would strongly rec ommend we make it 18


### explicit and say, "Between the I

- beams, the 19



### insulation does not need to be in full contact 20


### with the floor." That will force us to put 21



### insulation from the I

- beam to the rim, where air 22136

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### leaks in through the staples on the belly 1



### insulation a nd travels across. 2


### The more insulation you have horizontally 3


### there, the more infiltration you're limiting. 4


### And I think it's overkill to require insulation 5


### contact with the decking. And I don't think HUD 6


### requires it now. 7



### So I think this is a

-- if we coul d get 8


### that explicitly in there, it might help Rick not 9


### having to make an interpretation, and it would 10


### also solve this problem. 11


### MR. MENDLEN: We'll get back to you on 12


### that, Mike. 13


### (Laughter.) 14


### MR. LUBLINER: Thanks, Rick. 15


### MR. RAMIREZ: Okay. 16



### MR. BANTLE: What would you like me to 17



### write? 18


### MR. RAMIREZ: Yeah, for number three. 19


### MALE VOICE: It's a consistent position

. 20


### MR. LUBLINER: Well, I think when we get 21


### to the discussion of floor insulation, and let's 22137

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### make the exception between the I

- beams, floor 1



### insulation c ontact with the decking is exempt

. 2


### And that way, that solves your problem and then 3


### we can move forward with requiring this proposal. 4



### (Pause.) 5


### MR. RAMIREZ: Does that do it, Manny? 6



### MR. SANTANA: Yeah. I think so. 7



### MR. LUBLINER: And that's kind of what I 8



### p roposed to you, Bert, the other day on the 9


### weekend. But I didn't hear back from you. 10



### MR. KESSLER: That was intentional. 11


### (Laughter.) 12



### MR. LUBLINER: I resemble that. 13



### MR. RAMIREZ: What do we need to do with 14


### three, though? Is that

-- I think that, Bert, 15



### we 're just still not quite wrapped up. 16



### (Pause.) 17


### MR. RAMIREZ: Yeah, Richard? 18



### MR. POTTS: Richard Potts. 19


### So the question is, is it floors or the 20


### belly board or belly wrap? That's what we

-- do 21


### we need to vote on that? Or just f igure that out 22138

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### right now? Is that something we can just live 1



### with this and come back to it? 2


### MR. SANTANA: Well, we can't use the term 3


### "pressure envelope , " because it's not defined in 4


### IECC. In order for us to use it, we'd have to 5



### add what defines that. 6


### MR. RAMIREZ: So, do we exclude "pressure 7


### envelope" and specifically say "the walls, 8


### ceilings, and floor"? 9



### (Pause.) 10


### MR. RAMIREZ: Okay. So how does that 11



### look for number three? 12


### And, Michael, yo u might want to take a 13


### peek at that one. 14


### MR. LUBLINER: I'm sorry. My wife lost 15


### her purse. 16



### MR. RAMIREZ: And found it? 17



### MR. LUBLINER: It was stolen from the 18



### hotel. And so I've been kind of multi

- tasking 19



### here. 20



### (Pause.) 21



### MR. LUBLINER: Yes. 22139

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### (Pause.) 1



### MR. TOMPOS: I'm not trying to slow us 2


### down. Let me just throw one thing out there. 3


### I'm going to ju st throw it all on t he table here. 4


### If I put a recept in the interior side of that 5


### wall, is that a penetration or not? Because in 6


### my opinion, the pressure envelope can be on the 7


### exterior of the wall, and I do not have to seal 8


### completely around every re c e p t that's put in the 9



### house. 10


### Now, if I have electrical going up into 11


### the roof cavity, I have to seal around that 12



### because I have to make sure I have a continuous 13


### pressure barrier around the entire house. 14


### MR. MENDLEN: You have to seal joints 15


### between major env elopes. 16



### MR. TOMPOS: So there's a big difference 17


### between saying that the

-- I guess it's somewhat 18


### in the interpretation. I don't want to get into 19


### a disagreement with Rick. Kind of down the road 20


### on an interpretation of where that penetration is 21


### actually p enetrating the wall. 22140

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### MR. SANTANA: But wouldn't that be part 1


### of the performance aspect of the code, where you 2


### define what your envelope is? It is the interior 3



### standard next? 4



### MR. TOMPOS: Well, yeah, you have to do 5


### certain things to make it the exterior. So if 6


### you don't put some type of exterior board and 7


### sealant on the exterior, you're going to have to 8


### use house wrap or you're going to have to use 9


### some type of tape to seal between your OSB or 10


### your, you know, foam board or whatever you put on 11



### the exterior. 12


### MR. SANTANA: Right. 13



### MR. TOMPOS: Then you don't have it on 14


### the exterior. Then you would have to seal around 15


### every recept, in my opinion. I just want to make 16



### sure it's

-- that the manufacturers have that 17


### option. Because I think you're going to prefer 18



### t o put a house wrap on every house, which we may 19


### have to do anyway, but as opposed to sealing 20


### around every single recept that you put in the 21



### house. 22141

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### MR. RAMIREZ: So what about adding the 1


### verbiage, "exterior surfaces of walls, ceilings, 2



### and floors"? 3



### MR. TOMP OS: Well, now we run into the 4


### problem with the belly. Because you say it that 5


### way, the exterior surface is my bottom board. 6



### The exterior surface

-- 7



### MR. RAMIREZ: " Of walls " ? " Of walls, " 8


### period, and " the ceilings and floors " separate? 9


### MR. DENNIS: Or y ou could just put 10


### "ceilings and floors" first. And then "exterior 11



### surfaces." 12


### MR. RAMIREZ: All right. So, Ted, put 13


### the "ceilings and floors" in front of "exterior 14



### surface s ." 15



### MR. TOMPOS: We could just move forward 16


### and let DOE work on the language. 17



### MR. RA MIREZ: You know what, though? But 18


### I think we're right about there. I think we're 19


### right about there. So I

-- 20


### MR. SANTANA: Okay. But what if you 21



### don't have a house that

-- what if your air 22142

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### pressure
-- or what if your, you know, if you're 1


### going to seal every one of your recesses

-- 2



### (Cross

- talk.) 3



### MR. TOMPOS: Then you're going to have to 4



### seal it. 5


### MR. SANTANA: It wouldn't give you that 6


### option. 7



### MR. TOMPOS: That's fine. 8


### MR. SANTANA: I'm not saying I want to. 9


### But this here wouldn't give you that option, you 10


### know. Okay. So what if you're a manufacturer 11



### that currentl y foams around all your recepts? 12



### MR. RAMIREZ: Have at it. 13



### MR. TOMPOS: You can continue to do that. 14


### MR. SANTANA: But this here says

-- I 15


### mean, what if you foam around the penetrations on 16



### th e inside of the wall, but you don't want a 17


### house wrap? And you don't want it through the X 18


### here? This will encourage you to do the X here. 19



### MR. TOMPOS: Well, then your pressure 20


### envelope is on the interior, because you have a 21


### ventilated cap roof. 22143

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### MR. SANT ANA: Right. 1



### MR. TOMPOS: That's why I had pressure on 2


### the opening there. But

-- 3



### MR. RAMIREZ: There seems to be too much 4


### complication around that term. 5


### MR. SANTANA: Well, why don't we just

-- 6


### I like the idea of the pressure envelope here. 7


### Why don't we just add the definition that HUD has 8


### for "pressure envelope"? I think it's valid. 9



### MR. TOMPOS: Well, because there's a 10



### little clarification issue on if that's the floor 11


### or the belly board. There's industry practice 12


### right now that assumes that it's the b elly board. 13


### MR. RAMIREZ: We need to change that. 14


### MR. SANTANA: But that's up to the

-- I 15


### mean, I don't see that's it. 16



### MR. TOMPOS: But I don't think we need to 17



### -- I don't think

-- once these regulations come 18


### out, we can't determine that layer. We need to 19


### know that it is the floor. In my opinion, it has 20


### to be that floor, and we need to seal everything 21



### in the floor. 22144

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### MR. HAGERMAN: Can you just say "pressure 1


### envelope at the floor"? Go ahead and define 2


### where you think the pressure envelope is? Say 3


### "the pre ssure envelope at the floor"? 4



### MR. TOMPOS: Yeah. As long as you put 5


### out an interpretive bulletin that explains it. 6


### MR. HAGERMAN: Well, that's obviously not 7


### the pressure envelope at the belly board, right? 8



### MR. TOMPOS: That's correct. 9



### MR. HAGERMAN: It's the pressure envelope 10



### at the floor. 11



### MR. TOMPOS: Okay. But the opposite of 12


### that is, where is the pressure envelope on the 13



### wall? 14


### MR. HAGERMAN: Well, we just keep the 15



### exterior surface rule on. 16



### (Cross

- talk.) 17


### MR. LUBLINER: Separate that discussion. 18



### MR. TOM POS: Not everybody is going to 19


### have it at the exterior, because they're not 20


### going to

-- they may or may not

-- 21


### MR. HAGERMAN: They have a vented wall 22145

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### cabinet? 1


### MR. SANTANA: You know, if you have

-- 2


### when you have a vented wall

-- 3



### MR. TOMPOS: There's wal ls that do not 4


### have exterior sheathing on them. 5



### (Cross

- talk.) 6



### MR. TOMPOS: I don't know how you install 7


### house wrap. We'll get to that when we talk about 8


### requiring house wrap. You can't install house 9


### wrap on a house that does not have exterior 10


### sheathing. 11



### MR. HAGERMAN: Not all houses need house 12



### wrap. 13



### MR. TOMPOS: Okay. 14


### MR. HAGERMAN: Is what you just said, 15


### right? 16



### MR. TOMPOS: Yeah. Well, we can't 17



### install it in some houses. 18


### MR. MENDLEN: Let's just seal the 19


### receptacles, then. 20



### MR. TOMPOS: Then you would h ave to 21


### reseal the receptacles. 22146

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### I just want to make sure it's clear. I 1


### mean, I think we all are on the same page as to 2



### what we need to do. 3



### MR. RAMIREZ: Michael? 4


### MR. LUBLINER: Yeah. My understanding is 5


### that you try to align the pressure boundary and 6



### the vapor barrier. And most of the time, for 7


### moisture purposes, most o f the time in building 8



### science when we advise large production builders 9


### and stuff, we tell them to caulk and seal all the 10


### penetrations in the drywall walls. 11



### Because most of the moisture tha t enters 12


### into a house isn't through diffusion. It's 13


### through those places. And so, that's why you 14


### want to align that. And I would say that if

-- I 15


### would be willing to say, if you put foam 16


### sheathing or

-- and you tape it all, tape every 17


### joint and everythi ng, and you don't caulk all 18


### that other stuff, that you probably are going to 19


### have a hard time meeting five on all houses. 20


### But I also would argue that you should do 21


### it for moisture reasons, that it should be 22147

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### aligned for moisture reasons. That's basically 1



### w hat Building America has taught me over the 2



### years. 3



### MR. TOMPOS: Well, my comment to that 4


### would be, we aren't doing it now. And we're only 5



### -- 6


### MR. LUBLINER: Right. We're meeting 7



### five. 8



### MR. TOMPOS: Yeah, on an average. 9


### MR. LUBLINER: Okay. Good. So when you 10


### do tape the penetrations and use Tyvek and don't 11


### caulk the plate

-- do you have to caulk the 12


### plate? 13



### MR. TOMPOS: It's not being done that way 14


### anywhere other than Wisconsin right now. 15


### MR. LUBLINER: Okay. Because I was going 16


### to say it's kind of

-- if it's not being done, 17


### it's kind of tough. But I don't have a lot of 18


### experience testing homes with the primary 19


### pressure boundary's exterior. So I would defer 20


### to you. But I would caution you that you will 21


### run into moisture problems in certain areas if 22148

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### you don't align the vapor barrier with the 1


### pressure barrier. 2


### MR. RAMIREZ: All right. Ishbel? 3


### MS. DICKENS: So, as the nontechnical 4


### expert in the room, I'm just wondering if the 5


### sort of introductory sentence above all of the 6


### conditions really encapsulates what you all are 7


### talking about, and we don't need more. 8



### (Pause.) 9



### MR. WEISS: I want to make sure I 10


### understand what you're saying . Could you say 11


### that again? 12


### MR. SCHNEIDER: I would just argue that, 13


### you know, there are not going to

-- 14



### (Cross

- talk.) 15



### MR. RAMIREZ : Hold on a second. Okay. 16



### Was that Mark? 17



### (Chorus of "It was Peter.") 18



### MR. RAMIREZ: Peter? 19



### MR. SCHNEIDER: Hi. Yeah. This is 20


### Peter, Efficiency Vermont. 21


### Ishbel, I would just suggest there are 22149

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### not

-- it gets subjecti ve with that opening 1



### sentence

-- crite ria below that and guidance, 2



### manufactured installation instructions were 3


### really not exactly what we're talking about here. 4


### And that's because it's such a confusing topic. 5


### I would note again that there

-- I would 6


### agree with what Michael said in regards to the 7


### vapor barrier aligned with our air barrier or 8


### pressure boundary. 9


### Unfortunately, our manufactured housing 10



### b elly is a very poor air barrier. You know, in 11


### Vermont, we require a rigid air barrier aligned 12



### with the exterior of the thermal envelope , so it 13



### wo uldn't allow, you know, something flexible like 14


### the nylon belly stapled , and have certain tapes 15


### that are approved as well. 16


### So, I think that that just causes 17


### complications. And I would refer back to the 18


### diagram that I sent to Javier in regards to, you 19



### know , what is the ideal alignment of the air 20


### barrier all the way around? 21



### And I th ink that we're going to need to 22150

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### -- the DOE needs to provide good guidance on how 1


### people are dealing with the transition in your 2


### horizontal, for example, like your floor and 3



### ceilin gs, with the walls. And be sure that we're 4


### not providing guidance that puts, you know, our 5


### manufacturers' envelope at risk of condensation 6



### issues and mold and mildew. 7


### MS. DICKENS: Peter, thank you. This is 8



### Ishbel. 9


### Just in response, I was not suggesting 10


### that we just take the first phrase and delete the 11


### seven criteria. Simply that I felt the first 12


### phrase encapsulated all the sort of nuances in 13


### the language that people were suggesting. 14


### And so, just to keep in mind that we're 15


### not just looking at criterion t hree, but we're 16


### looking at the introductory phrase as well, and 17


### then keep continuing to keep the list in place. 18


### MR. RAMIREZ: All right. Michael, Michael 19


### Wade, did you have something? 20


### MR. WADE: Can you guys really hear me? 21



### MR. RAMIREZ: Yeah. 22151

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### (Chorus of " Yeah.") 1


### MR. WADE: Son of a gun! 2


### Congratulations, whoever is controlling the 3


### voice. This is the very first call since we have 4


### started this whole program that I've been able to 5


### speak, and I greatly appreciate it. 6


### (Laughter.) 7



### MR. WADE: And if I sound sarc astic, I 8


### am. And I apologize. 9


### MR. RAMIREZ: All right. The floor is 10


### yours, Michael Wade. 11


### MR. WADE: All right. Here's my comment, 12


### and here's my question. You know, I'm all for 13


### sealing. And Lubliner, you don't have to throw 14


### any comments. And we do it already. Been doing 15


### it for years, been doing it since the year 2000, 16


### okay? 17


### But here's a question. How do we seal at 18



### the P

- trap opening? Okay? If we do that, we 19


### seal those off, how are we going to have access? 20


### Anybody? 21


### MR. RAMIREZ: Yeah, Michael? 22152

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### MR. LUBLINER: Yeah. Using EPDM rubber 1


### that's commonly found on tires or in the plant as 2


### scrap. You staple it down over the P

- trap. You 3


### cut an X in it. And you push the

-- and you 4


### caulk the edges. And you push the pipe up 5


### through it. I'd be happy to show you details and 6


### the way it's done in the factory if you're 7



### interested. 8


### MR. WADE: We can get a pipe through it. 9


### How are you going to get your hands in there to 10


### work on it if you have to? 11



### MR. LUBLINER: You cut the

-- 12


### MR. WADE: I mean, we can do that, M ike. 13



### But then we'll have

-- but you'll destroy it if 14


### you get in there to work on it, if anybody has 15



### to. 16


### MR. LUBLINER: Yeah, that's a big "if." 17


### Rarely do you have to fix a leak in a P

- trap. 18


### MR. WADE: No, it's not a big "if." It 19


### happens. 20



### MR. LUBLINER: Yeah, it does happen, but 21


### not very often. 22153

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### MR. WADE: No, I disagree. 1


### MR. LUBLINER: So if you want me to 2


### answer your question, I will. 3



### MR. WADE: Go ahead. 4


### MR. LUBLINER: You take a piece of EPDM 5


### that's a little bit bigger than the hole, the P

6



### trap. You s taple it down and caulk the seams. 7


### You scribe an X in the rubber, which gives you a 8


### seal when you bring the plumbing through that 9


### penetration. 10


### If you have to access that, you cut that. 11


### You cut it, access it. It's just like

-- it's no 12



### different than what they do now with the bottom 13


### board has an access port. It's just making the 14


### access point above it. 15


### I would suggest that the requirement in 16


### HUD for that access port be that

-- be there is 17


### part of the problem. I think that this would 18


### solve that problem, if we could fix the problem 19


### with the access being in the belly by just 20


### requiring a label that says, "This is where the 21



### P

- trap is." 22154

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### In reality, what happens is they cut into 1


### the belly anyway. So, but getting back to your 2


### question, that's how we do it. We us e an EPDM 3


### rubber, and if in the one out of a hundred or one 4



### out of a thousand homes the plumbing leaks at the 5



### P

- trap, then you just cut in and , right now, you 6


### go to that access port that HUD requires

-- and I 7


### don't think it's necessary

-- a nd you cut that 8



### rubber and fix it. 9



### MR. RAMIREZ: I feel like

-- 10


### MR. WADE: It's a possibility. 11


### MR. RAMIREZ: I'm sorry. What was that, 12



### Michael? 13


### MR. WADE: That is a possibility. What 14


### Mike's proposing, is possible, is doable. 15


### MR. LUBLINER: Thank you, sir. 16



### MR. WADE: An d I appreciate the 17


### opportunity to speak. I've tried dozens, 18


### literally dozens of times to speak over all the 19


### meetings we've had. And this is the first time 20



### I've been able to. 21


### MR. RAMIREZ: All right. Well, we'll 22155

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### make sure that Emily passes on the secret sauce 1


### there for whoever's manning the computer next 2



### time. 3


### I feel like the greyhound chasing the 4


### rabbit. You know, like I'm almost there, right? 5


### I'm almost there, but I can never quite get it. 6


### So, let me ask the group, do we need to 7



### end this conversation? Or are we there? 8



### MS. DICKENS: We're there. 9



### MR. TOMPOS: I think we're there. 10


### MR. RAMIREZ: All right. So, what we 11



### have on here is "G aps of penetrations in the 12


### ceilings, floors, and exterior surfaces of walls 13



### shall be sealed." 14


### And Ishbel pointed out tha t the

-- some 15


### of the little nuances that we were talking about 16


### are somewhat covered in that introductory 17


### paragraph as well. But there's just more detail 18


### in the seven points. That, without the level 19


### five, without referencing to testing, but with 20



### the same cost numbers

-- 21



### MR. HAGERMAN: With recommendations for 22156

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### DOE to consider testing. 1



### MR. RAMIREZ: Is that the consensus? Let 2



### me see a show of thumbs. 3



### (Pause.) 4


### MR. HAGERMAN: Or it's throughout the 5



### whole standard. 6



### MR. TOMPOS: The manufacturer will not 7



### have to do testing. 8


### MR. RAMIREZ: Correct. It's just a 9


### recommendation passed on to ASRAC. 10



### Mike? 11


### MR. LUBLINER: I'd be willing to vote for 12


### this, except I'm a little uncomfortable with this 13


### "exterior surface." So I would ask DOE, if they 14


### could, to talk to thei r moisture people and do 15


### some WUfi analysis on this. That's the way that 16


### they look at moisture requirements and whether 17


### the walls are going to rot or condense. 18


### If you could do some WUfi analysis on 19


### this and come back to us, but I'd be willing to 20



### vote for it now pending some WUfi analysis. 21



### Because what I don't want to do is make the walls 22157

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### colder and then increase condensation with that. 1



### MR. TOMPOS: And I would agree with that. 2


### I think the industry wants to do whatever the 3


### best practice is. 4



### MR. LUBLINER: Right, right. 5


### MR. RAMIREZ: All right. So I'm probably 6


### butchering this one, but can you do a WUfi 7


### analysis? 8


### MR. LUBLINER: Sorry, Joe. 9


### MR. RAMIREZ: Okay. 10



### MR. LUBLINER : I don't want to 11


### unanticipate the consequences from our action. 12



### MR. RAMIREZ: Is tha t something that's 13



### doable? 14


### (Mr. Hagerman nodded yes.) 15


### MR. RAMIREZ: Okay. So, DOE is saying 16


### that that is something that they could do. 17


### So with that, let me see the thumbs. 18



### (Pause.) 19


### MR. RAMIREZ: Okay. So, anyone on the 20


### phone have their thumbs down? 21



### (Pau se.) 22158

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### MR. KESSLER: One F in WUfi. 1



### ( Inaudible conversation .) 2


### MR. RAMIREZ: So, any thumbs down on the 3


### phone? 4



### (Pause.) 5


### MR. RAMIREZ: Okay. All right. 6


### MR. SCHNEIDER: This is Peter, Efficiency 7



### Vermont. 8


### Just a quick

-- I was just wondering, 9


### what percentage of manufactured homes, if any, 10



### are delivered with sheetrock? 11


### MR. RAMIREZ: Peter, hold on. I'm trying 12


### to wrap this one up. We'll get that question 13


### later. Right now, I'm just looking to count the 14



### votes. 15



### And it looks like there were three folks 16



### that had the ir thumb down. That was Mark, 17


### Lowell, and Manny. Is that accurate? 18


### MR. HAGERMAN: Can we ask them just to 19


### explain real quick why they're down? Just if 20


### it's a big thing or a small thing? 21


### MR. SANTANA: Manny with Cavco

. 22159

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### I've got a small thing. The only r eason 1


### why I'm down is that I'm just not completely 2


### comfortable that we're considering all the 3


### sidings that are currently in use. 4


### I don't know if, you know, will metal 5


### siding still be available to install if we have 6


### to seal? You know, they have gaps along the 7



### bottom. So it could be something, you know. I'm 8


### not an expert in insulation of metal siding. 9



### MR. RAMIREZ: Ted. 10



### MR. TOMPOS: Again, Manny, if you do that 11


### without an exterior air barrier, then you're 12


### going to have to seal around the recepts. I 13



### don't think there's a huge cost to that. And I 14


### do think that probably is best practice. 15


### MR. SANTANA: Well, all I'm saying, you 16


### know, so with my understanding of how metal 17


### siding is installed, do you install the metal 18


### siding directly to the stud, so there is no 19


### sheathing on the exterior? If this says "gaps, 20


### penetrations on the exterior surfaces of the 21


### walls," it doesn't say whether the exterior 22160

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### surface is not the interface between the outside 1


### and inside, then you do the inside. 2


### You know, so I just don't see the option 3


### for doing the inside if that's what your assembly 4


### calls for. And that's the only reason why I'm 5



### not

-- everything else is fine. 6


### MR. RAMIREZ: Well, correct me if I'm 7


### wrong, but these are minimums. Correct? 8



### MS. DICKENS: I think so. 9



### MR. RAMIREZ: If you wanted to do more

-- 10


### MR. SANTANA: Right. But I wouldn't do 11


### the exterior surface is what I'm saying. 12



### MR. RAMIREZ: Ah. 13



### MR. SANTANA: Because there is no 14



### exterior surface. 15


### MR. RAMIREZ: I see what you're saying. 16


### MS. DICKENS: If there's none, then you 17



### can't do it. 18


### MR. SANTANA: That's what I'm saying. So 19



### the

-- and I want to be able to meet the minimum. 20


### MR. RAMIREZ: Got you. 21


### MR. SANTANA: Do you see what I mean? 22161

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### MR. RAMIREZ: Um

- hm. 1


### MR. LUBLINER: You're doing metal siding. 2


### You've got to caulk th e breaks on the

-- 3



### MR. SANTANA: But this doesn't allow me 4


### to caulk. That is what I'm saying, because it's 5


### mandating that you caulk the exterior surface of 6


### the walls. But you can't. If you can't, then 7


### you can't meet the minimum. That's one reason 8


### why I have

-- so it's just a wording issue. 9


### MR. RAMIREZ: Is there a way to tweak 10



### that to fix it? 11


### MR. SANTANA: Well, I'll vote yes if I 12



### can add a suggestion for DOE to consider the 13


### option for the interior

-- 14



### MR. HAGERMAN: That's fine. 15


### Did you hear that, Ted ? He's asking just 16


### for the suggestion. 17



### MR. SANTANA: That DOE consider the 18


### scenario where you can't caulk the exterior 19



### surface of the wall , and find a way to 20


### incorporate that. 21



### MR. HAGERMAN: Such as? 22162

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### MR. LUBLINER: Would that be 1



### characterized as " no struc tural sheathing "? 2



### MR. BANTLE: Cannot be caulked. 3



### MR. SANTANA: Yeah. Cannot be sealed. 4



### Where the exterior surface cannot be sealed to 5


### provide an option for the interior surface. 6



### MR. HAGERMAN: So it's like such as the 7


### case where the exterior sheathing b ecomes the 8


### structural sheathing. Isn't that right? Or it's 9



### the same? 10


### MR. LUBLINER: Yeah. How do you guys

-- 11


### MR. SANTANA: Well, I think if we just 12


### leave that first part of the sentence, that will 13


### capture, you know, without muddying up anything. 14



### MR. RA MIREZ: All right. Lowell, what 15


### was your thumbs

- down? 16


### MR. UNGAR: So, my concern is that we 17


### still have no testing at all by the 18


### manufacturers. And so while there's prescriptive 19


### requirements, they're somewhat vague. And you 20


### know, what we're hearing is th ere's a huge range 21


### in the actual sealing , that is, once it's tested. 22163

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### And other than an eventual study by DOE, should 1


### DOE have the funds, there's kind of nothing to 2



### address that. 3


### And so, my

-- so first of all, I would 4


### note, I mean, I think unlike some of t he other 5


### things we've discussed, this strikes me as very 6


### important. When I look at the numbers, there's 7


### really large energy savings here. 8


### And second, I would note, on my

-- being 9


### I'm not an expert in manufactured housing, my 10


### understanding is, unlike stick

- built homes, where 11


### the fundamental mechanism is an inspection of 12


### every home, the fundamental mechanism for 13


### manufactured homes is a quality control procedure 14


### in the factory, that you try to make sure the 15


### factory is doing it. And it seems to me that 16


### period ic testing should be a part of that quality 17


### control procedure. 18


### Now, I understand in the end we're not 19


### addressing all of the

-- we're not addressing the 20



### enforcement here. But if there's no mention of 21


### ACH, no mention of actual performance 22164

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### achievement, I don 't know how you later get to 1


### that point of , then, how do you incorporate 2


### testing to make sure that the factory is doing an 3


### effective job? 4


### And so, I understand the argument not to 5


### have it as a mandatory requirement on each home. 6


### But to not put it

-- you kn ow, it seems to me 7


### there should be something here about that we're 8


### trying to achieve a performance level that then 9


### enables DOE or this future committee, or whoever 10


### is then going to determine enforcement, to take 11


### that into account and try to come up with a 12


### procedure that works. 13


### MR. RAMIREZ: Okay. I think Michael has 14


### a response to that before I get to Mark. 15


### So, Michael? 16



### MR. LUBLINER: Yeah. So I kind of held 17


### my notes on the

-- when I voted up on that one, 18


### because I agree totally with you. But I was in 19



### the understanding that if this was found in the 20


### field, there would be a subpart I. 21



### MR. TOMPOS: Yes. That is a requirement. 22165

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### MR. LUBLINER: So if I go out with a 1


### utility program and look at existing homes that 2



### have been built after this code

-- and I want to 3



### make sure this is on the record

-- and we find 4


### that these things are being missed, then there 5


### will be a class subpart I? 6


### (Mr. Tompos nodded yes.) 7


### MR. LUBLINER: Thank you. 8


### MR. MENDLEN: He can't confirm that, but 9



### I will. 10


### MR. RAMIREZ: Thank you. 11


### (Laughter. ) 12



### MR. MENDLEN: That's what we do. I can 13



### confirm that. 14


### MR. RAMIREZ: Okay. Mark? 15



### MR. WEISS: I think

-- Mark Weiss, MHARR. 16



### I think Joe was out of the room when I 17


### explained previously once or twice the reason for 18


### my no vote. And as I said then, I do have some 19


### concern about essentially mandating ENERGY STAR 20



### for all manufactured homes. 21



### But more importantly, again, it becomes a 22166

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### question of the derivations, the costs, and the 1


### completeness of the cost information, as I 2


### explained yesterday, at length. 3



### MR. RAMIR EZ: Got you. I assumed that's 4


### what it was. But I wanted to at least give you 5


### the opportunity to just put it on the record. 6


### MR. WEISS: Thank you. 7



### MR. RAMIREZ: Lois? 8


### MS. STARKEY: Yes. Just FYI, Mark, 9


### understand, but we're looking at a 2015 IECC. So 10



### t his proposal is pretty much below what the IECC 11


### requires. 12


### MR. WEISS: I understand. Again, my main 13


### concern, as I've indicated, is with the 14



### derivation cost information rather than the 15



### substance of this. 16


### MR. RAMIREZ: So, with those 17


### explanations, Manny, wit h the addition of that 18


### suggestion for consideration there, you're good. 19


### Lowell and Mark, I do n 't think that the 20


### suggestions that were raised on there 21


### sufficiently address what you had raised, nor to 22167

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### switch your consensus vote. Is that accurate? 1



### MR. UNGAR: Yeah, at this point. 2


### MR. RAMIREZ: Okay. 3



### David? 4


### MR. TOMPOS: I just want to respond a 5



### l ittle bit to Lowell. D id Emanuel send that 6


### document yet? I mean, you mentioned that there 7



### was not data. And I think there is data that 8


### shows that, with what we're doing now , and we're 9


### improving on that, our average is around five. 10


### You made the comment about the testing 11


### being done in the site

- built world. And there is 12



### no re quirement for a certified HERS rater to do a 13



### blower

- door testing. It's done by the HVAC guy 14



### t hat went out and bought a piece of equipment. 15


### He has no requirement to be trained. And I 16


### promise you that that is a test that should be 17


### done by somebody that's trained. 18


### MR. UNGAR: And I certainly wasn't trying 19


### to say that the site

- built is more effectiv e 20


### enforcement than factory out. That was not at 21


### all my point. 22168

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### MR. TOMPOS: And we do have a lot of 1


### experience with that. I mean, I've been in a 2



### net

- zero home. At least that's what they called 3


### it. And we could not get it to pass ENERGY STAR , 4



### y ou know, j ust because the blower

- door testing 5


### didn't work. They had gaps everywhere. They 6



### didn't know how to install it. 7


### So, to say that I guarantee you if we do 8


### this, it's going to be regulated to the point 9


### where we're going to make sure they do it. And 10



### like Mic hael alluded to, if we find out they 11


### aren't doing it, we're going to have to go out 12


### and fix all those houses they didn't do it to. 13


### So I think there's already that 14


### regulatory aspect to this, where based on my 15


### experience with doing blower

- door testing, if we 16


### do these things and make sure the manufacturer is 17


### doing that, I think we can keep this

-- this is 18



### the most cost

- effective way to save energy, right 19



### here. And if we can do this and avoid the 20


### testing of every home, I think we're doing what 21


### the statute says we need to do. 22169

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### We're keeping it affordable by avoiding 1


### the testing. I'm confident that we're going to 2


### consistently be below that five ACH. I think 3


### we're going to even be better if we do all these 4


### things. 5


### MR. RAMIREZ: Lowell, anything? 6



### (Cross

- talk.) 7



### MR. RAMIREZ: I'm not trying to twist 8


### your arm. I just want to make sure that the 9


### record is reflected accurately. 10


### MR. UNGAR: I'll just note that I think 11


### we're actually close. I agree that I'm not 12


### trying to push for, you know, testing every home. 13


### You know, that certainly isn't in terms of what I 14


### could live with. I just think there should be a 15


### solution, which I understand you could live with 16


### if you could see a way of doing it 17


### administratively, there being periodic testing. 18


### So I think we're actually in the s ame 19


### place in terms of where we could

-- you know, we 20


### could agree on what could actually be done. We 21


### just don't seem to be able to get there under the 22170

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### terms of the committee and their requirements. 1


### MR. RAMIREZ: Right. Right. 2


### Let me wrap this up, unless y ou're

-- 3



### MR. UNGAR: Sure. Sure. 4



### MR. RAMIREZ: So

-- I'm sorry, is someone 5



### on the line? 6


### MR. SCHNEIDER: It's Peter, when I have a 7


### chance to say something. 8


### MR. RAMIREZ: Yeah. I just want to wrap 9


### this one up because it sounds like we have 10



### consensus. The re were two no votes with Mark and 11


### Lowell. There's the leakage

-- ah, what's it 12



### called?

-- air leakage issues wrapped up right 13



### there. 14



### Peter? 15


### MR. SCHNEIDER: Yes. I would suggest 16


### that, of the suggestions below, that if this 17


### worked for Lowell, this would b e better for me if 18


### instead of it saying, let's see, "recommendations 19


### for DOE" since you're testing not manufactured, 20


### is there a way that we could just stick with 21


### saying that we would adopt these st rategies for 22171

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### achieving ACH five, DOE test for

-- 1



### MR. RAMIRE Z: I'm sorry, Peter. That 2


### whole last part was just too garbled. 3


### MR. SCHNEIDER: Oh. Sorry. I'll get my 4


### phone for the afternoon. I apologize. 5


### I was just saying that, is there any way 6


### that, instead of a recommendation to DOE for just 7


### testing, that we ac tually

-- 8


### MR. BANTLE: We lost you again, Peter. 9


### MR. HAGERMAN: Peter, can you just type 10


### in your comment? We're having a hard time 11


### hearing you. So if you could just send us an 12


### email, we'll capture that. We apologize. 13



### MR. RAMIREZ: Yeah. I think it's a 14


### definite "maybe." 15


### (Laughter.) 16


### MS. DICKENS: Possibly. 17


### MR. SANTANA: It's possible. 18


### MR. RAMIREZ: All right. But I do want 19



### to make it clear that it is consensus. I 20


### understand that Peter's trying to make some 21


### suggestion on there. And if we could add that 22172

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### without modifying it, I'm sure that won't be an 1



### issue. 2


### We have just about eight minutes left 3


### being before lunch. Emanuel just did send in the 4



### data for the whole

- house leakage. Did you want 5


### to use those last few minutes just to take a peek 6



### at that? Or a re we good? 7


### MR. HAGERMAN: I think we're good. Joe 8


### Hagerman, DOE. 9


### I think we're good. I mean, if we go up, 10


### scroll up to the top of the page, I don't think 11


### we've addressed the cost issue yet, have we? So 12


### do we think we agree that the measures are there? 13


### And I think we agree that the measures, you know, 14


### represent the five, so we can get rid of the 15



### five. 16


### And I think now we just have to agree on 17


### the costs that we should use in the life cycle 18


### analysis. 19


### Again, I think DOE's official position is 20



### we modeled tho se costs after the ENERGY STAR, so 21


### we're comfortable with those costs, even though 22173

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### we believe, in just the observation of it, that 1


### they seem pretty conservative. But we're okay 2


### with them being conservative. 3



### MR. SANTANA: Didn't we vote on the costs 4



### and ha ve two no's? 5


### MR. HAGERMAN: Well, let's just take a 6



### revote on the costs. 7


### MR. LUBLINER: I have a question on the 8


### costs before we revote, actually. 9


### MR. RAMIREZ: Yeah, go ahead. 10


### MR. LUBLINER: So, we have a cost that 11


### was defined by you guys. I wonder if it included 12


### the cost of sealing those receptacles and 13


### everything that energy requires. Because if 14


### we're saying now that if it does, then those 15


### costs stay the same. If it doesn't

-- 16


### MR. HAGERMAN: So we can provide you

-- 17


### it's from an ENERGY STAR report. 18



### M R. LUBLINER: But

-- yeah. 19


### MR. HAGERMAN: So we can provide, and you 20



### can review what it includes. But it doesn't 21



### include

-- it does not include the test, though. 22174

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### MR. LUBLINER: No, no. I still 1


### understand that. What I'm saying is that we 2


### agreed that that report includes just this labor 3


### and materials. What I'm saying is, does it 4


### include, does the labor and materials include the 5


### caulking of all the wall switch plates or not? 6



### If this includes the cost of the switch 7


### plates and you're not requiring that, then the 8



### costs have to come down. 9



### (Pause.) 10



### MR. RAMIREZ: David? 11


### MR. TOMPOS: I think that is going to be 12


### required in some cases on a lot of the houses 13



### that do not have an exterior

-- I don't even want 14


### to say the word " air barrier " or " pressure 15


### envelope. " So t here are some cases where that 16


### can happen. 17


### You've got to also remember they're not 18


### doing some of the foaming around the windows. So 19


### there are a lot of things that they're not doing 20


### right now that we are going to make them do. So 21



### there is some costs in th ere. 22175

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### I don't know how we break it down. I 1


### think we're in the weeds again as far as trying 2


### to take off 50 bucks or 100 bucks off that price. 3


### Because at the end of the day when you do your 4


### life cycle cost analysis, I think you could put a 5


### $500 cost in ther e, and sealing of the envelope 6


### is going to show that it is a cost

- effective way 7



### to do

-- 8


### MR. HAGERMAN: I can read to you real 9


### quick what it entails. It requires "air sealing 10


### of penetration cracks and other openings in the 11


### home's thermal enclosure system ." Let's hope we 12


### don't have to define that. It requires "all 13


### joints, seams, and other penetrations, other 14


### sources of infiltration, any utility penetrations 15


### be caulked, gasketed, weather

- stripped, or 16



### otherwise sealed with an air barrier material." 17



### The cod e specifically requires that "the 18


### junction of the foundation's seal plate be 19


### sealed, that the space between the window, door 20


### jambs , and framing be sealed, the duct shafts, 21


### utility penetration, the walls, and flue shafts 22176

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### open to the exterior unconditioned s paces be 1


### sealed, recessed luminaries be sealed." 2


### The code requires that "access doors from 3


### conditioned space to unconditioned space be 4



### weather

- stripped and insulated to a level 5


### equivalent." So I mean, I think that's 6


### everything. I mean

-- 7



### MR. TOMPOS: No w, sealed luminaries, 8


### you're probably going to have that cost right 9


### there if we have to go to a

-- I mean, Manny, I 10


### don't know if you're

-- I don't t hink you're 11


### using sealed candle lights right now, are you? 12



### MR. SANTANA: No. No, I don't think so. 13



### MR. TOM POS: What's the cost difference 14


### on those candle lights? I mean, we're trying to 15



### -- Michael's contention is, do we need to lower 16



### that cost? I think there's some reason to 17


### believe that we can make arrangements for some

-- 18


### can we just agree to agree that i t's close 19


### enough? 20


### MS. DICKENS: Yeah, really. 21


### MR. TOMPOS: And it doesn't make that big 22177

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### of a difference? 1


### MR. LUBLINER: If they're going to do a 2


### subpart I on this if we find problems, I'm good. 3


### MR. RAMIREZ: All right. So let's see a 4



### show of thumbs for th ose costs. 5



### (Pause.) 6


### MR. RAMIREZ: Okay. Anyone on the phone 7



### have their thumb down? 8



### (Pause.) 9


### MR. RAMIREZ: All right. So, let the 10


### record show that Mark was the only no vote. And 11


### we're assuming it's the same rationale. 12



### MR. WEISS: Yes. 13


### MR. RAMIREZ: Okay. And then

-- 14


### MR. HAGERMAN: Let me just state, too, so 15


### we have it. Everything I was reading from was 16



### the ENERGY STAR Certified Home , version 3 , Costs 17


### and Savings Estimate , that was distributed to 18


### everybody. It's the November 1st, 2013 , edition. 19



### MR. RAM IREZ: All right. Now, I just 20


### want to read what Peter was trying to say. 21


### And, Peter, I think that this goes to the 22178

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### enforcement piece, but there's a little part on 1


### the bottom where there is going to be a 2


### recommendation for the DOE to do testing, right? 3



### So the recommendation is up there already. 4


### But Peter's comment was, "DOE will do 5


### quarterly testing for three years post

6


### implementation to ensure each is achieved." 7


### Okay. So it's just a bit more detailed 8


### than what the suggestion is up there. But that 9


### goes i nto the enforcement piece, which will be

-- 10


### hopefully, Peter, you'll be joining the committee 11



### at the next round with enforcement. 12


### Okay? Let's break for one hour for 13



### lunch. And we'll be back at one o'clock. Thank 14



### you. 15


### (Recess from 1 1 :5 7 a.m. until 1:05 p .m.) 16



### AFTERNOON SESSION 17


### MR. RAMIREZ: Let's get started. All 18


### right, folks. 19


### Stacey, are you on the line? 20


### (Inaudible conversation.) 21



### MR. RAMIREZ: Yeah. I think we're 22179

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### getting some side chatter there. But, Stacey, 1


### are you on the line? 2



### MS. EPPERSON: This is Stacey. Can you 3



### hear me now? 4


### MR. RAMIREZ: Oh, yeah, that's much 5



### better. 6


### MR. RAMIREZ: All right. We're going to 7


### start on the committee reports. So, Stacey, 8


### which documents would you like to lead off with? 9


### MS. EPPERSON: Okay. I think let's go to 10



### the N ADA documents, if you have those. 11


### MR. RAMIREZ: All right. 12



### (Pause.) 13



### MR. RAMIREZ: Is that a PDF or a Word? 14



### MS. EPPERSON: A PDF. 15



### MR. BANTLE: Is this the document in 16


### question? 17


### MS. EPPERSON: This works; thank you. 18



### (Pause.) 19


### MR. RAMIREZ: Okay, Stacey. The floor is 20



### yours. 21


### MS. EPPERSON: Okay. Okay, thank you. 22180

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### So, the finance committee has not met 1


### again since our last meeting. However, I believe 2


### we had two outstanding issues that we were 3


### exploring, looking at data. 4


### The first one is the NADA guidelines for 5


### valuing ENERGY STAR improvements. And NADA is an 6


### evaluation guide. It is

-- a good analogy for it 7



### is kind of like the B lue Book on a car, the 8


### value. You know, the NADA guide is a value guide 9


### for manufactured housing. It's often used with 10



### Chattel Financ e, and it sometimes is used rather 11


### than an appraisal. 12


### So the question that we had outstanding 13


### was, you know, is this current information ? 14



### W hich it is. We have verified that. And so, for 15


### a single

- section home, you can see the amount of 16


### $2,190 is credited for an ENERGY STAR qualified 17



### manufactured home. 18


### And then, you can see that valuation at 19


### one to two years, three to four years, and then 20


### five years. And then we have a breakdown for the 21



### multi

- section home at $2,640, and again with a 22181

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### graduated valuation, d epending on time. And then 1


### if there are additional tags or triple

- sections , 2



### that can also be added. 3


### So let me pause here and see if there are 4


### questions. 5



### (Pause.) 6


### MR. RAMIREZ: So that triple section is 7



### added on to the multi

- section ? 8



### MS. EPPERSON: Yes. 9



### MR . RAMIREZ: Okay. 10



### (Pause.) 11


### MR. HAGERMAN: This is Joe Hagerman, DOE. 12


### So, Stacey, do you think that, given this 13


### what you're seeing here, do you think that the 14


### way Matthew is calculating the resale value or 15


### the recapture value is

-- what's your opinion of 16



### that? 17


### MS. EPPERSON: You know, remind me of the 18


### most recent. I think I saw that we were looking 19


### at that, we're loo king at a 10

- year at this 20


### point. Is that correct? 21


### MR. HAGERMAN: Right. I think at 10 22182

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### years
-- Matthew can speak. 1



### MS. EPPERSON: Yeah. 2



### MR. HAGERMAN: But at 10 years, the 3



### resale value was

-- 4



### MR. WALKER: Two

- thirds. 5



### MR. HAGERMAN:

-- two

- thirds. 6


### MS. EPPERSON: Okay. Okay. You know, 7


### maybe. If others want to chime in here, I think, 8


### you know, I'd want to look at the amount to see 9



### how close w e are to this. But what impresses me 10


### here is that ENERGY STAR is given a value, and 11


### that it's there for a number of years. However, 12


### that amount does go down. 13


### It has been my experience with 14


### appraisals, though, I will say, getting the 15



### valuation for ENERGY STAR seems impossible in 16


### many markets. So I think looking at this 17


### valuation from NADA is a good way to look at it 18



### and look at these amounts. 19


### Others from the finance committee, your 20


### feelings on this? 21



### MR. ROY: This is Robin. 22183

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### I think it's naturally an area of 1


### substantial uncertainty. I like that NADA has 2


### given it some thought. I like that they have 3


### something which we can point to. 4



### And about the two

- thirds valuation at 5


### year 10, that is consistent with what we see 6


### here. This is showing what? That's showing 78 7


### percent at year five and up. So we're talking 8


### something somewhat south of that. So this is not 9


### inconsistent with the straight line. 10



### MR. RAMIREZ: Lois? 11


### MS. STARKEY: I agree with that. I think 12


### Stacey alluded to it. I think that using the 13


### approach t hat DOE did might be more acceptable 14


### across the board, because of what Stacey said 15


### about trying to get these valuations. 16


### You're going to have a lot of people

-- 17


### you know, it's not really going to happen the 18


### NADA way across the board. So I like the idea of 19


### sticking with the DOE approach. 20


### MR. RAMIREZ: Thank you. 21


### MR. WEISS: I had a question before we go 22184

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### -- 1


### MR. SANTANA: 73 percent exactly. 2


### MR. WEISS: Before we go to the next guy. 3


### MR. SANTANA: 72 percent. 4


### MR. WEISS: Okay. I guess this is for 5



### Emanuel. E manuel, I'm looking at this as 6


### reference to SBRA at the bottom, and then 7


### Research Alliance at the top. I assume that's 8


### referencing System Building Research Alliance? 9



### Is that correct? 10



### (Pause.) 11


### MR. HAGERMAN: So, I believe that's 12


### correct. They are the imp lementer of the ENERGY 13


### STAR program, are they not? 14


### MR. WEISS: Thank you. I appreciate it. 15


### MS. EPPERSON: This is Stacey. 16



### I believe it's correct. 17



### MR. WEISS: Thanks. 18


### MR. RAMIREZ: All right. Any other 19


### questions on the NADA document? 20



### (Pause.) 21



### MR. RAMIREZ: Great. Thanks, Stacey. 22185

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### Where do you want to go next? 1


### MS. EPPERSON: So, let's pull up the tax 2


### document. We had another outstanding issue on 3



### that. 4



### (Pause.) 5



### MR. RAMIREZ: Is that a Word or a PDF? 6


### MR. HAGERMAN: I think it's right there. 7



### It's Sales and Property Taxes? 8


### MS. EPPERSON: You're right there at the 9


### pointer. Sales and Property Taxes. 10


### MR. RAMIREZ: Oh, yeah. 11


### MS. EPPERSON: Okay. Okay. Working with 12


### Matthew and the team, I think what we want to say 13


### about property taxes is that, particularly

-- l et 14


### me start with sales tax. This varies greatly, 15


### and there are an abundance of jurisdictions. And 16


### it became very complicated to think about how 17


### this data might feed the model. 18


### And then, we also know there was some 19


### complications around how each state look ed at 20


### property tax with manufactured housing. So an 21


### outstanding issue for us has been the approach. 22186

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### And so, one of the ideas was to look at this 1


### model and the cities where we're running our data 2


### and actually look to see what the sales and 3


### property tax im plications are for those 4


### jurisdictions and those states. 5


### And Lois is going to look into talking 6


### to, I think, the state manufactured housing 7


### associations to get some more of that data . And 8



### if I can call on Lois to see if we've been able 9


### to get any of that information. 10


### MS. STARKEY: Yes, I have. I haven't

-- 11


### don't have all of the states in yet. I have like 12


### Texas, Illinois, Maryland. And they're all over 13


### the board. And I can give you an example here. 14


### So, for Texas, and generally this is 15


### going to apply sta tewide. But there might be 16


### some obviously real properties, some

-- that's 17


### all pretty much local unless there is a state 18


### law, which there , in some cases , are specifically 19


### to manufactured housing. 20


### But, for example, Chattel loans have a 21


### sales tax that's 3.2, 3.25 percent on new homes. 22187

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### And it's based on a calculation of the sales tax 1


### in that state. So it's based on 65 percent of 5 2



### percent. 3



### There's an ad valorem tax charged for 4



### manufactured homes financed and sold as real 5


### property. It's charged annually on t he personal 6


### property, and the rate varies from local taxing 7


### jurisdictions, by local taxing jurisdictions. 8


### And then for real estate loans, there is 9



### a sales tax. There would be no sales tax in 10


### Texas. They have to pay some taxes on raw 11



### materials. 12



### So that's sort of how complicated it is. 13



### And I can

-- you know, as soon as I can provide 14


### these as you wish, to use examples, or I can just 15


### get them to you as I

-- I'm hoping to get them 16


### wrapped up by the end of the week. Usually, my 17


### guys are really good about gett ing back to me, 18


### but we had a meeting last week. So I have about 19


### three more states, four more states to go. But 20


### they're all over the map. 21


### MS. EPPERSON: Thank you, Lois. 22188

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### So in any event, this shows you the 1


### complexity we're dealing with, the tax situation. 2


### But I think our approach is a valid one, unless 3


### anyone would like to give us some feedback on 4



### that. 5



### MS. DICKENS: This is Ishbel. 6


### I think the Washington State tax is 9, 7


### 9.5 percent. So it's a little higher than it's 8


### showing there. And it's a sales tax state, 9


### unfortunately. 10


### MR. UNGAR: And that's applied to all 11



### sales of manufactured homes? 12



### MS. DICKENS: I don't know. I would 13


### assume it would be because it's applied to all 14


### sales of everything else. And I think it is. 15



### MR. UNGAR: When I did a web search 16



### b efore the last time, there was an excise tax in 17


### Washington State between 1 and 2 percent. 18



### MS. DICKENS: Yeah. 19


### MR. LUBLINER: That's my understanding. 20


### But I'm not knowledgeable on that. Joan Brown, 21


### from Washington Manufactured Housing Association. 22189

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### MS. STA RKEY: Right. Yeah. I just don't 1



### have it

-- I just don't have it back from her 2


### yet. But generally, what these states , you know, 3


### they all get legislation passed to modify 4



### whatever the statewide sales tax is. Because 5


### it's such a big

- ticket item. 6



### MS. DICK ENS: Right, right. 7


### MS. STARKEY: So we can assume that, if 8


### you wanted to just assume a number just for the 9



### time , it's not going to mean that much in terms 10


### of our analysis, in my opinion. And it would be 11


### nice to have those specifics, but it's not going 12



### to vary by state. But we can plug them in if 13


### it's not hard, because you're going to have to go 14


### individually and plug each change in. 15


### Or just take some percentage of each, 16


### less of each, of the overall sales tax. 17


### But I just

-- others chime in who are 18



### familiar with this, Emanuel. But I think, you 19


### know, it's not going to make that mu ch of a 20


### difference. But I will, Javier. 21



### MR. RAMIREZ: Michael? 22190

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### MR. LUBLINER: Yeah. I had that 1


### spreadsheet and talked to some of my associates, 2


### and they had a question about the an alysis. 3


### Because they were saying , this is an example, 4 

### "Miami has a property tax of $17.54 per month on 5


### any EEM of 19,048. Seems an order of magnitude 6


### high. I suspect the property tax value is 7


### annual, but the way the net present value is done 8



### assumes mon thly loans." 9


### So anyway, I'm just asking that you 10



### double

- check to make sure that the calculation is 11


### being done consistently. Thank you. 12


### MR. RAMIREZ: Stacey, anything else? 13



### MS. EPPERSON: No. That concludes our 14


### report, but there are two outstanding issues

. 15


### MR. RAMIREZ: Okay. Now, I don't believe 16


### there are any action items that need to be taken 17


### on the finance, correct? That was just more 18


### informational to assist with understanding, as 19


### well as costing. Is that accurate? 20


### MS. EPPERSON: That's my understand ing. 21


### MR. RAMIREZ: Okay, great. 22191

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### Michael 1


### MR. LUBLINER: Stacey, I had a question. 2


### Is there any assumption about the percentage of 3


### homes that are purchased with cash? 4



### MS. EPPERSON: T hank you for reminding 5



### us. We were going to look into that. And we 6



### did. And I think the assumption was as many as, 7


### close to 30 percent. I'd have to check my exact 8


### amount, unless Lois has that number in front of 9



### her. 10


### MS. STARKEY: I think we're using 30 11


### percent. But it's kind of a hard number to come 12


### up with. But that's the number that MHI has been 13


### consistently, based on our contacts with our 14



### lenders. 15


### MR. LUBLINER: Thank you. 16



### MS. EPPERSON: Thanks for the reminder. 17


### MR. RAMIREZ: Thank you, Stacey. 18


### All right. Then, the next one would be 19


### manufactured housing. 20



### MR. TOMPOS: Mi ne? 21



### MR. RAMIREZ: Yes. 22192

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### MR. TOMPOS: Okay. What I did, I was 1


### tasked with trying to figure out what 2


### manufacturing problems we might have with some of 3


### the smaller homes. And I do want to point out 4


### I'm not a manufacturer. So I'm the only one on 5



### the committ ee in trying to figure out what all 6


### the manufacturing problems are, and I'm not a 7



### manufacturer. 8


### But what I did was I put together a

-- 9



### MR. BANTLE: Which document? 10


### MR. TOMPOS: I sent it to you on

-- let's 11



### see
-- Saturday, I believe. I also made copies. 12


### MR. RAMIREZ: Okay. We just want to make 13


### sure that we have it up for the folks that are

-- 14



### (Pause.) 15



### MR. TOMPOS: I don't see it in there. 16



### (Pause.) 17


### MR. TOMPOS: There you go. 18


### So, the front page is just an example 19


### calculation. I was trying to figure out w hat my 20



### maximum effective U value is. A lot of the talk 21



### has been about

-- and I think Emanuel even 22193

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### mentioned that these are just labels, as far as 1


### the R38 down to the R22 or whatever we're using. 2


### And once we get to the point where we 3



### have to define what th e U values are, the overall 4


### U value, we've got to nail down what is the 5


### number U value? We can't just say we're putting 6


### an R38 insulation in the roof, because that's not 7


### what we end up with. And I think some of that 8



### has been taken into account. 9



### What this spreadsheet will allow us to do 10


### is you can come in here and change all these 11


### numbers and figure out what you get for an 12


### overall U value. I just

-- it is not probably as 13


### far as it needs to go, because it does not take 14


### into account framing members. It doe sn't take 15



### into account air films or the resistance in the 16



### gypsum. 17


### But I also included some diagrams so that 18



### we could take a look at what some of the smaller 19



### units look like and what some of the shipping 20



### restrictions are. 21


### This first one, I'm trying to stay within 22194

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### the 13

- 6 as far as height goes, because in the 1



### document that was sent around on

-- I don't off 2


### the top of my head remember what that title of 3


### that was. But it was a shipping study, and 4


### mostly for the Northeast, because you don't run 5



### into a lot of t hese problems in the Southern 6


### regions because they don't have the smaller 7


### bridge heights. 8


### I don't have any statistics on how many 9


### homes we're talking about. I know there are also 10


### height limitations in all the states. But I 11


### don't know what they are. I kn ow when we dealt 12


### with a particular project, there was another 13


### height limitation of 15 feet. 14



### And what I want to make sure that we do 15


### at the end of the day is that we can physically 16


### put enough insulation in these homes. So it's 17


### great to say we want an R38 e verywhere in the 18


### ceiling, but when we deal with some of these 19


### smaller, you know, especially single

- wide homes, 20


### there's going to be some restrictions on whether 21



### or not we can do it or not. 22195

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### Now, I'm not saying that there aren't any 1



### solutions for that. There 's always the solutions 2


### of going to some type of a dense pack or a foam 3


### insulation to be able to get those. But I want 4


### to make sure that we're recognizing that in some 5


### of the cost provisions here. So, I don't think 6


### there's a lot of going

- back

- and

- forth. I don't 7


### want to get in the weeds on this. 8


### The next drawing here shows a typical 9


### cathedral configuration. And this is where it 10


### does become a problem, because we, obviously, 11


### again have less physical space. 12



### So I don't like

-- again, I don't want to 13


### get into the weeds. I don't know if we need to 14


### have any back

- and

- forth discussion on this. I'm 15


### trying to just make DOE aware of the situation, 16


### that I provided a small calculation. I'm only 17


### one nerd. So I didn't have anybody review my 18



### work. 19


### If anyone else wants to scrutinize this, 20


### I'm more than happy to go back and forth or talk 21


### with them offline about it on how I got it. 22196

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### The method I used

-- and this is a page 1



### from that

-- is the Battelle method, which is the 2



### method that's been used in the manufactured 3


### housing world as far as I can remember. 4


### This one is a diagram of what it looks 5


### like in the floor cavity. And the reason I put 6



### this in here is I did want to talk about the 7


### implications of potentially putting that 8


### insulation above the area in the belly. 9



### We kind of hammered that to death earlier 10


### this morning. So I don't

-- I mean, unless 11


### somebody has some additional questions, I really 12


### don't want to drag it out again. 13


### I just want to put on the record that I 14


### am afraid, you know

-- and if you look at some of 15



### the confi gurations that PNNL already put 16


### together, they show an R11 blanket and then an 17


### R21, I believe, above everything. And I'm 18


### concerned that we're going to create some service 19


### problems. 20


### Even if you assume that there's not going 21


### to be any rodents or tears in th e bottom board 22197

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### after the fact, after it's been installed, I 1


### think you're going to find out in some of the 2


### colder climates, and maybe somebody can do some 3


### type of a thermal curve through that area to find 4


### out what my temperatures are going to be in that 5



### are a, especially when I'm sealing the floor and 6


### nothing's getting in there with an R11, when it 7


### gets to be minus

- 20 or minus

- 30 degrees in North 8


### Dakota and some of the Northern regions. 9


### So I'm just putting that out there as a 10


### potential service complaint down the road. And I 11



### don't know how to deal with that. 12


### So, I'm not going to talk about the 13



### width. I think there is

-- I don't want to get 14


### into an argument with anybody in the Northwest. 15


### I just want to make everybody aware that there 16



### are some additional costs that could come in, and 17


### I never did get a cost of what an additional 18


### transport costs or if we're even going to 19


### recognize the additional, you know, thousands of 20



### miles that some of these travel with an 21


### additional car if we have to expand the width of 22198

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### some o f these because we have to go to two

- by

1



### four or two

- by

- six walls. 2


### So I'm just pointing it out as concerns 3


### for DOE to recognize and make sure that we can 4


### physically do this with current building 5


### techniques. 6


### MR. RAMIREZ: So, from what we've been 7


### hearing, is there anything

-- now, there's a 8



### difference between an inconvenience or you
- don't

9



### like

- it versus you

- can't

- do

- it. Is there 10


### anything that hasn't been discussed that is not 11


### figured out physically? 12


### MR. TOMPOS: Well, again, I can build a 13



### home that's tornado proof. But you can't afford 14



### it. 15


### (Laughter.) 16


### MR. TOMPOS: Or most people can't afford 17


### it. I shouldn't say you, Javier. I don't know 18


### your financial situation. 19


### MR. RAMIREZ: I probably couldn't. I 20


### probably couldn't. 21


### MR. TOMPOS: Yeah, good. You probably 22199

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### couldn't. 1


### MR. RAMIREZ: I'm a government employee. 2



### So. 3


### (Laughter.) 4


### MR. TOMPOS: Exactly. So, you know, I 5


### can do anything. I can put

-- I'd love to build 6


### houses with all sip panel roofs. But they're not 7


### going to be affordable. So that's a concern. 8



### No thing is impossible; it's just, can we do with 9


### current industry practice? 10


### MR. RAMIREZ: Manny? 11


### MR. SANTANA: It might help if you go 12


### back, just talking about the roof, if you go back 13


### and explain looking at the cathedral single

- wide, 14


### why that's significant, why R38 or more in that 15



### roof would be an issue? 16


### You know, so if you provide R38 means 17


### this many inches in height, and then everybody 18


### can see that visual there, and see, you know, if 19


### R38 requires, you know, 12

- inch height, you can 20


### see you're only going to go so far. You know 21



### what I mean? 22200

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### MR. TOMPOS: Yeah, you know, as my 1


### example calc shows, you know, I put an R40 at the 2


### king post. And overall value

-- and again, we've 3


### got to remember these don't take into account 4


### framing members. So it's going to be les s than 5



### this. It's not even an R25. And this is not the 6



### smallest house that we build. This is a 13

-- 7


### what's the total? Well, the unit, it's 13

- 2, and 8


### then you have the eaves on it. So that's where 9


### you get 13

- 6. 10


### But that's a big concern. So once you 11


### start lowering the rise and run, the slope on the 12


### roof, we can go down to

-- there's no requirement 13


### in the manufactured housing standards. But the 14


### shingle manufacturers only let you go down to 15



### 212. 16



### MR. SANTANA: 212. 17


### MR. TOMPOS: So, you know, I can

-- I 18



### didn't do worst

- case on this. So we could

-- you 19


### know, you guys all have this calculation. It was 20



### in an additional file. So there is an Excel 21


### spreadsheet that allows you to change this, play 22201

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### with it, you know, reduce the unit size. You can 1


### change all those numbers in there, and it will 2


### show you what your effective value is. 3


### If our effective value is going to have 4


### to be around an R38 for a cathedral ceiling, I 5


### don't think we're going to be able to do it 6


### unless you change the technology that we're 7


### using. 8


### And there's not any manufacturers on this 9


### committee that are building primarily cathedral 10


### ceilings. But there are a number of 11


### manufacturers in the industry that that's their 12



### main market. 13


### The other thing I want to point out, some 14



### of the other things we ca n do to help this is, 15


### I'm doing an eight

- foot side wall here, which is 16


### pretty typical. I don't know if any of you have 17


### been in any seven

- foot or six

- and

- a
- half

- foot 18


### side wall heights. But I get a little 19


### claustrophobic. 20



### And I don't want to tell

-- I don't think 21


### we should have to tell a homeowner that, "Well, 22202

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### to save you 50 bucks on your energy, we're going 1


### to have to put you in a seven

- foot side wall to 2


### meet the requirements." I think that's a 3



### disservice to the consumer. 4


### MR. RAMIREZ: Okay. Any questions for 5



### David? 6



### (Pause.) 7



### MR. RAMIREZ: Is that it? 8



### MR. TOMPOS: That's it. 9


### MR. RAMIREZ: Great. Okay, thank you, 10



### David. 11


### Was there a question on the line? 12


### MR. SCHNEIDER: Yeah, this is Peter. 13


### I was trying to get on mute on my phone , 14



### s o you would just get the m essages and then I can 15


### make my comment on my phone. 16



### MR. HAGERMAN: You can make your comment. 17


### MR. RAMIREZ: Yeah, you're coming across 18


### pretty clear, Peter. 19


### MR. SCHNEIDER: Oh, I am? Okay. Great. 20


### I have an echo on this end, so. 21


### I just wanted to make a re commendation 22203

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### that seven

- and

- a
- half ceiling height with a 1


### cathedralized space that goes to eight

- and

- a
- half 2


### works extremely well. It is very well received 3


### up here. And that that provides plenty of room 4


### for the R values that we're looking to achieve. 5



### (Paus e.) 6


### MR. TOMPOS: He said you can do it with 7



### seven
- and

- a
- half feet. 8


### MR. MENDLEN: That drops it down six 9



### inches. 10



### MR. EZZO: This is Mark Ezzo. 11


### Peter, can you tell me what R value 12


### you're talking about? 13


### MR. SCHNEIDER: Well, 38 or 49, and 14


### actually, setting a much higher R value over the 15


### outside of the exterior wall, which is what we're 16


### trying to achieve. 17


### In our climate, we have a lot of issues 18


### with ice damming as a result of very poor 19



### installation details with the insulation at the 20


### eave, as well as venting app roaches that don't 21


### work. So, providing more of a buffer in that 22204

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### space to both get a higher R value and a better 1


### vented space makes a really big difference. 2


### MR. RAMIREZ: Yeah, Manny? 3


### MR. SANTANA: Peter, can you explain to 4


### me how you get the R49? Is that installed or is 5


### that once you calculate the assembly as a whole? 6



### Is that installed insulation? 7



### (Pause.) 8


### MR. SCHNEIDER: Yeah. Well, we're using 9


### a dense pack in a 50

- to

- life stage. Hold on a 10


### second. Just give me one second just to mute my 11


### phone

. Do I still sound okay? 12



### (Chorus of "Yes.") 13


### MR. SCHNEIDER: Okay. So, we use a 14


### parallel chord truss. So two

- by

- four bottom and 15


### top cord with a webbing in between. And you can 16


### do that in any width that you want. So we get 17



### the same R value over the outside of o ur exterior 18


### wall as we have at our ridge. 19



### And so , that allows you to accommodate 20



### both a dense

- pack assembly, but also have a 21


### vented assembly from the eave to the ridge, if 22205

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### that answers your question, Manny. 1


### MR. SANTANA: Well, yes and no. Because 2



### I still have a hard time visualizing how you can 3


### get R49 at the heel or above the wall, as you've 4


### said. You know, so is the truss configuration 5


### that you use, is that similar to what Dave had on 6



### the screen? 7


### MR. SCHNEIDER: Well, that's a scissors 8


### truss, where you' d have a different height at the 9


### eaves than the ridge. And regards to the depth 10


### of that truss, a parallel chord truss is even the 11


### whole way. 12


### MR. SANTANA: Okay. 13


### MR. SCHNEIDER: So you could do it with 14


### either. But, you know, in this case, I like the 15


### paral lel chord truss. Just to give you an idea, 16


### we have 2 by 10, 16 on center dense pack with 17


### fiberglass. We have a vertical wall assembly at 18



### seven
- and

- a
- half feet where it meets the ceiling 19


### height. And then we have our parallel chord 20



### truss. 21


### We're doing a 14

- inch parallel chord 22206

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### truss dense pack with fiberglass there, as well. 1


### MR. SANTANA: Okay. I think I'm starting 2


### to come around a little bit, little by little. 3


### MR. SCHNEIDER: Okay. 4


### MR. SANTANA: So, what's the height at 5


### the heel? Or what's the height of the truss 6



### above the exterior wall? 7



### MR. SCHNEIDER: Fourteen inches. 8


### MR. SANTANA: Okay. Fourteen inches. 9


### So, yeah, I would agree with you that if you had 10



### a truss that had 14 inches at its minimum 11


### dimension, you can get an installed R38 or R49 in 12



### there. I'd agree that that is the case. 13



### But I will state that , at least with my 14


### experience with the product that we make, the 15


### only product that we make that has a 14

- inch

- tall 16



### truss at the heel is the Santa Fe product in the 17


### Southwest, where

-- and it's a whole different

-- 18


### you know, it's at the parapet wall. 19


### But, you know, everything else that we do 20



### has

-- it's a ranch

- style house. So it has a 21


### gabled truss. And I think that's what Dave was 22207

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### trying to say, is that, you know, if you change 1



### the construction of the truss so that you 2


### increase the height of the heel, that might be 3


### what you have to do to get this installed R value 4



### in the roof. 5


### And I think the position we were taking 6


### is that that's going to have additional costs and 7


### shipping height concerns and the othe r stuff we 8


### were talking about. 9


### MR. SCHNEIDER: Manny, this shows a one

10



### and

- a
- half 12 cathedralized ceiling on the 11



### inside. And I don't know if that's a two

- and

- a
12


### half 12 on the outside. Our roof system

-- 13



### MR. SANTANA: It's a three

-- yeah. 14



### MR. SCHNEIDER : Three 12? 15



### MR. SANTANA: Yeah. 16


### MR. SCHNEIDER: So just to give you an 17


### idea, you know, I'm in the Northeast. We have 18


### 13.5 feet, we need to travel down the road. And 19


### we're meeting the 13.5

- foot height. We have a 20



### two

- and

- a
- half 12 cathedralized space on the 21


### interior, from 7.5 feet at the aegis, 2.5 at the 22208

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### ridge, a very comfortable space that feels like a 1


### big volume, even a steeper cathedralized space 2


### than shown here in the picture. 3



### And we have the same two

- and

- a
- half 12 4


### pitch on the outside, which is pret ty darn close 5


### to the 3.3 shown here. And I'll go back to what 6


### Mark has said over and over again, which is we're 7 

### trying to make housing for people making $25,000 8


### a year more affordable. 9


### Having ice damming issues and heat loss 10



### at the eaves as a r esult of ge tting an additional 11



### one
- 12 pitch on the exterior of the roof doesn't 12



### seem to make sense to me or meet the intent of 13


### that goal, if that's what we're doing here. 14


### MR. SANTANA: Right. I follow you, and I 15



### unders tand it. I think, you know

-- well, I'm 16


### glad th at you explained that because it makes 17


### sense that if you increase the size of the truss, 18


### you're going to have more free space. 19


### But, you know, unfortunately, when I 20


### start my discussions, it's always with base HUD 21


### code, not what can be done. We can do a lot of 22209

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### stuff. But, you know, the way it's going to be 1


### most cost effective is if we can modify the 2


### existing product as little as possible, but gain 3


### the most energy efficiency from it. 4


### So, you know, and if we can't, that's one 5


### of the things that we need to ill u strate, because 6


### in Texas, where, if you look at the data that I 7


### think HUD provided, that state is responsible for 8


### 20 percent of all the HUD shipments last year, 9


### you're going to find that the vast majority of 10


### the product looks like what we have on the scre en 11



### and won't have the 14

- inch heel. 12


### So we can do that, yeah. Yeah, we can do 13


### that. But there's going to be costs. And it's 14


### going to be a pretty drastic change. 15


### MR. RAMIREZ: So, I guess tapping into 16


### the manufacturers' expertise

-- 17


### MR. SCHNEIDER: I gue ss I'm just

-- 18


### MR. RAMIREZ: Hold on a second, Peter. 19


### Let me just ask this question of the 20


### manufacturers. So, just using your expertise and 21


### your years of experience, you're saying that to 22210

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### make those adjustments to the structure, to get 1


### in that higher R v alue, would make it cost 2



### ineffective? 3


### MR. SANTANA: There's a chance for that, 4


### yeah. I can't say that it won't. But it's going 5



### to be

-- it's not just the cost of the materials. 6



### You have to

-- you know, increased height is 7


### going to have an effect of wind pressures. So 8


### that's going to have an effect on your lateral 9


### resisting system. 10


### You know, that can mean

-- well, at a 11



### minimum , it's going to mean redesign of that 12


### manufacturer's entire product line. That 13


### includes floor plan, since the middles

-- it can 14



### a ffect the strength of sheer walls. It can 15


### affect some floor plans, you know, because they 16


### can have a lot of window space. It could affect 17



### sheer walls. 18


### It can all be done. But changing the 19


### exterior dimensions of something can have a big 20


### impact. 21



### MR. RAMIR EZ: Domino effect. 22211

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### MR. SANTANA: Yeah. 1


### MR. SCHNEIDER: I'm just not 2


### understanding how the exterior dimensions are 3


### getting changed here. I mean, in terms of the 4



### cathedralized

-- I'm not sure what exterior 5


### dimensions are getting changed that would be 6



### outsi de of business

- as
- usual. 7


### Because if we're talking about an eight

8


### foot wall, we're talking about a seven

- and

- a
- half 9


### foot wall and taking that height and putting it 10



### into an eave and the raised heel insulation 11


### depth. 12


### MR. SANTANA: Right. Well, the heel 13


### depth is the issue. If you go from 5 inches to 14


### 14, that will change the way that wind sees the 15


### exterior of the house. And that has an impact on 16


### everything else, structurally speaking. 17



### MR. SCHNEIDER: I'd like

-- instead of

-- 18


### I mean, that seems, Manny

-- I ap ologize, but 19


### that just seems like sort of a subjective 20


### statement there. I mean, I'd like to see the 21


### numbers to show why that's not

-- A, that it 22212

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### wouldn't still be cost effective, and B, why that 1



### wouldn't work. 2


### Again, we're talking about the same 3



### surface a rea. And we're talking about the way 4


### that truss system attaches to the vertical wall 5


### at that length. 6


### MR. TOMPOS: Manny, if you don't change 7


### this pitch of the roof, because basically what 8


### he's saying is we drop this down to about here so 9



### we have a six

- foo t

-- or I'm sorry, seven

- six 10


### ceiling height. This all becomes your wall. So 11


### I'm not changing my

-- I don't think you're going 12


### to change your structural loads on your
-- 13



### MR. LUBLINER: Reducing your wall area. 14


### Reducing the cost to the wall. 15



### (Cross

- talk .) 16


### MR. SANTANA: It's changed a little bit 17



### because

-- 18


### MR. TOMPOS: You're going to increase the 19



### cost to your truss. 20


### MR. SANTANA: It might be a wash if you 21


### keep the overall height the same. Yeah, that 22213

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### might be a wash. But it's still going to have a 1



### litt le bit of an effect, because although your 2


### wall height is shorter, right? 3


### I don't want to get into the weeds. But 4


### everything above the diaphragm gets added into 5


### the diaphragm. So if you have a five

- inch heel, 6


### five inches of wind pressure is going to go 7



### t hrough your diaphragm. If you have a 14

- inch 8


### heel, 14 inches is going through your d iaphragm. 9


### If you have a 30

- inch heel, all of that 10



### goes into the

-- the wall gets split in half. 11



### You know? So if you reduce the wall, you still 12


### split that in half. When the wind blows, half 13


### the load goes up, half the load goes down. All 14


### the load that hits the heel goes into the 15


### diaphragm. 16



### So it's not

-- I mean, it might be pretty 17


### close, but it won't be an exact wash. 18


### MR. TOMPOS: I do have a question for 19



### Peter. You know , if I come down six inches, I'm 20


### going to increase my heel height to 11.5 inches. 21


### But to get a full R

-- 22214

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### MR. SANTANA: R49? 1


### MR. LUBLINER: No. 38 we're talking 2



### about. 3



### MR. TOMPOS: R38 ? Well, you're going to 4



### need about 15 inches. 5



### MR. SANTANA: At what d ensity? 6



### (Cross

- talk.) 7


### MR. SCHNEIDER: No, no, no. You know, if 8



### I could

-- John s Man ville 's Climate Pro, which is 9



### the blo wn
- in fiberglass insulation, i s R4.3 per 10


### inch. So there's no reason to have any more than 11


### 11 inches there to get R49. 12



### And then if we'r e talking R38, we're 13


### talking about even a less gap there and plenty of 14


### room for venting. 15


### MR. RAMIREZ: Okay. Hold on a second. 16


### Let's make sure that everyone is on the same page 17



### here. 18



### (Pause.) 19


### MR. SANTANA: At 4.3 per inches it ceases 20



### as the stuff that we blow. We're blowing stuff 21



### -- 22215

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### (Cross

- talk.) 1


### MR. TOMPOS: Right. I mean, that's my 2


### point. Typical fiberglass blown insulation, 3


### based on the calculations I've seen, give either 4


### a 2.6 or a 2.7 per inch. What Peter is talking 5



### about is a

-- this is a diff erent product than 6


### what the industry is using. 7


### MR. MENDLEN: Worse than about 4 per 8


### inch, that over 4. 9


### MALE VOICE: Four per inch? 10



### MR. MENDLEN: I'm just looking at the 11



### table

-- says for 10 inches, you have 38. 12


### MR. SCHNEIDER: I'd be fairly interested 13



### in w hy there's such a drastic difference for 14



### blown fiberglass that has enhanced PF tested 15



### r ating of 4.3 and what the blown

- in fiberglass is 16



### that the industry has. This is an R value of 17



### half of what John s Man ville and

-- that can go 18


### across every single large f iberglass insulation 19



### manufacturer has a blown

- in fiberglass product 20



### that's R4 .3 or 4.1 per inch. 21


### MR. SANTANA: But rigid board gives you 22216

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### what? R5 per inch? And that's rigid board

-- 1



### MR. LUBLINER: R7? 2



### MR. MENDLEN: No. 4.2. 3


### MR. TOMPOS: I'm telling you that the 4


### heat loss calcs that we're using right now in the 5


### industry are using 2.6 and 2.7. So, if maybe the 6


### industry has been using the wrong numbers all 7


### along, we don't even have this conversation 8


### because we're doing a lot better than we thought 9



### we were
. 10


### (Laughter.) 11



### MR. EZZO: This is Mark Ezzo. 12


### I think what Peter is talking about is 13



### not what we see off the shelf from John s Manville 14



### or Owens Corning or anybody that sells blown 15


### fiberglass, because all those blown fiberglass 16



### charts

-- 17


### MR. RAMIREZ: Mark, I'm sorry. Hold on a 18



### second. 19


### MR. EZZO: They're not based on

-- 20


### MR. RAMIREZ: Mark, I'm sorry. Hold on 21


### one second. I just want to make sure everyone is 22217

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### on the same page. 1


### MR. EZZO: Sorry. 2


### MR. RAMIREZ: Could you start all over, 3



### Mark? 4



### MR. LUBLINER: He wants you to start 5


### again, Mark. 6



### MR. EZZO: Yeah. The JM blown 7


### fiberglass, Climate Pro, if you go on their 8


### website, you'll find it's around 3 R per inch. 9


### And that's not dense pack. And I think what 10


### Peter is talking about is different than what 11


### typical ma nufacturers are using. 12


### Most manufacturers, and I don't want to 13


### speak for all because I don't know. But I don't 14



### think most of us are dense

- packing insulation. 15


### We're blowing it to just the regular recommended, 16


### whether it's Johns Manville or Owens Corning o r 17


### whoever making blown fiberglass, we're just 18


### blowing to the typical off

- the

- shelf standard. 19



### We're not dense

- packing. 20



### And I think that's what Peter

-- I think 21


### that's where you're getting 4.3 per inch, because 22218

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### like Dave Tompos said, I know the bags that we 1


### get from JM, they don't hit 4.3 per inch. And I 2


### think if you go to the

-- 3


### MR. SCHNEIDER: We're just putting it in 4



### at the rate it

-- 5



### MR. EZZO: Go ahead. 6


### MR. SCHNEIDER: 1.8 pounds per

-- yeah, I 7


### was just going to say, we're putting it in at 1.8 8


### pounds per cubic foot, which tested to the FTM 9



### is R4.3 for Johns Manville's Climate Pro. The 10


### 877, I believe it is, with Owens Corning, is 11


### exactly the same rating. So

-- 12


### MR. EZZO: Okay. You're talking about a 13


### density that's twice what we normally do. Our 14



### d ensities are more about half of what you're 15


### talking about. 16


### MR. SCHNEIDER: Okay. 17



### MR. EZZO: I think that's where the 18


### disconnect is. I think we're talking about

-- 19


### when we say

-- when Dave Tompos and I say 3 R per 20


### inch, we're not talking about dense pack. 21



### MR. SCHNEIDER: That's fine. But let's 22219

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### just

-- whatever the R value is of the material 1


### that you're using, I'd like to return to, I think 2


### the key approach is to go to a seven

- and

- a
- half

3



### foot wall because our homeowners don't care if 4


### it's eight or seven

- an d

- a
- half if you have a nice 5


### cathedralized space that goes to eight

- and

- a
- half 6



### feet. 7


### And we can have a much larger raised

- heel 8


### truss regardless of what material we're using 9


### there. We're getting a higher R value in that 10



### 11

- inch heel, let's call it, as oppos ed to a 11



### five

- and

- a
- half

- inch heel. 12


### And it would appear there would be no 13



### cost penalty to achieve this , short of maybe just 14


### a different truss design and wall height. 15


### MR. EZZO: Yeah, the other comment I'd 16


### like to make on just the geometry we're looking 17



### at here is, we're looking at a single

- wide home. 18


### If you take that same concept of your parallel 19


### chord truss that's a 2.5 and 12 pitch, that 13

- 6 20


### shipping height goes to 14

- 6. And multi

- section 21


### homes are, I think, more of the volume in the 22220

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### industry than sin gles. 1



### (Pause.) 2


### MR. EZZO: So, I mean, we've got to 3



### address multi

- section homes, too. We've got to 4



### address multi

- section homes, too, not just 5


### single

- wides. 6


### MR. LUBLINER: Mark, doesn't the multi

7


### section home have a larger percentage of space 8


### where you can get the full insulation in? 9


### MR. EZZO: Oh, yeah, definitely. 10


### MR. LUBLINER: Okay. Thanks. 11


### MR. EZZO: Yeah. My comment was more 12


### about shipping height. 13


### MR. SANTANA: You know, one thing that 14


### stood by me the first time, but if you have a 15


### parallel chord trus s, how do you drain the roof? 16



### (Pause.) 17


### MR. EZZO: Manny, what do you mean by 18



### "drain the roof"? 19


### MR. SANTANA: Well, when it rains, where 20


### does the water go? 21


### MR. TOMPOS: It's still sloped, Manny. 22221

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### MR. SANTANA: How much? 1


### MR. TOMPOS: Well, it can't be less t han 2



### 2

- 12. 3



### MR. SCHNEIDER: Two

- and

- a
- half 12. 4



### MR. SANTANA: Two

- and

- a
- half 12. Okay. 5


### MR. EZZO: I think it's still peaked, 6



### Manny. 7


### MR. SANTANA: Okay, thanks. 8


### MR. EZZO: It's still got a peak on it, 9


### doesn't it, Peter? 10


### MR. SANTANA: Yeah, it still has a peak , 11


### yeah. 12


### MR. SCHNEIDER: Yeah. Yeah, yeah. 13


### Parallel chord truss. It's parallel. The two, 14


### the top chord and the bottom chord are parallel. 15


### So you're two

- and

- a
- half 12 inside, you 're two

16



### and

- a
- half 12 outside. 17


### And if you happen to be delivering your 18



### home to a place where you don't have to meet the 19



### 13

- foot fixed requ irement, you could have even a 20



### st eeper pitch than that when you're going to 14

- 8 21


### or the other height requirements in the Southern 22222

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### sphere

. 1


### MR. RAMIREZ: So, is the reason that all 2


### this is going on to see if R38 is truly feasible 3


### in the ceiling? Is that why we're having this 4



### discussion? 5


### MR. SANTANA: This is Manny with Cavco. 6


### The reason why this whole thing was 7


### brought up is to give everybody an idea as to the 8


### existing constraints in the majority of the 9


### industry when it comes to size and room available 10



### for insulation. 11


### And that you know, if

-- you know, it's 12


### one thing to say, "I want R38 in the ceiling" or 13


### "I want R49 in the ceiling." And it's another 14


### thing to know that, in order to achieve that, you 15


### might not be able to do that with standard 16


### construction today. You're going to have to 17


### change some things. 18


### MR. RAMIREZ: Okay. 19



### MR. SCHNEIDER: This is Peter. 20


### And yeah, I mean, I think I heard from 21


### minutes ago, maybe from Manny, that, you know, 22223

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### this i s why we can't achieve R38. And I just 1



### wanted to note that I think we do need to rethink 2


### the way these are designed and constructed. 3


### You know, I think the belly and the 4


### manufacturing of that whole system is a bit 5


### flawed in regards to how it comes together . And 6


### that's why it's been such a challenge to 7


### determine whether the belly space is conditioned 8



### or unconditioned. 9


### And you know, the limitations that 10


### manufacturers are suggesting with regards to R 11


### value in the cap are a result of, you know, just 12


### going with the standard eight

- foot wall height, 13


### and not thinking about dropping that wall height, 14


### which will have, I think, no compromise on the 15


### interior volume and only improve the actual 16


### envelope and durability of that home. 17


### MR. RAMIREZ: All right. Let me get 18



### Da vid and Manny. 19


### MR. TOMPOS: Did you call me? 20


### MR. RAMIREZ: Yeah. I'm sorry. That was 21



### Mike. Mike? 22224

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### MR. LUBLINER: I live in a triple

- section 1


### home. It's got a vaulted ceiling throughout, and 2


### it's got a seven

- and

- a
- half

- foot end wall, and 3


### it's just fine. But that's a triple. But, and 4


### you haven't experienced in a single. 5


### The other comment I make is when I do go 6


### to retailers around the country, I always ask 7


### Emanuel Levy, I do see advertising of R38 as an 8


### option. And I'm wondering, if this is so new, 9



### how ar e they getting it now? 10


### MR. TOMPOS: Well, I can

-- again, it's 11



### not impossible . It just costs more money. I 12


### want to make sure that we capture that. 13



### MR. LUBLINER: Good. 14


### MR. TOMPOS: You know, I've got some 15


### manufacturers, too, that their market is nine

16



### foo t side walls. So, you know, I mean, that's 17


### what they're able to sell. You know, you go into 18


### some of the Northern regions, that's what the 19


### consumers expect, at least in the Midwest, 20


### because, you know, my

-- 21


### MR. LUBLINER: Would that be the entry

- 22225

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### level co nsumer? 1


### MR. TOMPOS: Well, again, I don't know if 2



### that's the

-- probably not, you know. So, again, 3


### if the consumer is willing to pay for it, it is 4


### possible. I'm not saying that we need to make 5


### sure we can do everything for a nine

- foot side 6



### wall. 7


### I'm just saying there is some

-- they're 8


### going to have to change their designs because of 9


### what we're requiring. And I just want to make 10


### sure that that is looked at by DOE to make sure 11


### we're not, you know, that we're including that 12



### additional cost into some of the se life cycle 13


### cost analyses. 14


### MR. RAMIREZ: Do you have those costs? 15



### MR. TOMPOS: I don't. Because I'm not a 16



### manufacturer. So I don't know what the 17


### percentages are. I'm just telling you that I 18


### think that it's going to change some of the 19



### manufacturers' wa ys that they have to build these 20


### homes. And I want to make sure we capture that 21



### cost. 22226

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### But, no. That would

-- I mean, Manny or 1


### Mark would have to help them with some of that. 2



### MS. DICKENS: This is Ishbel. 3


### Can we extrapolate out from what it does 4



### cost to d o the nine

- foot walls? Because that 5


### much obviously also costs more to subtract that 6



### from what it therefore costs to do the seven

- and

7



### a
- half foot walls. Is that too simplistic? 8



### MR. TOMPOS: I'd like to know what the 9



### difference between the dense

- packed

-- if I can 10


### get an R4 per inch

-- 11


### MR. LUBLINER: Change your model. Put in 12



### 4.5. 13



### MR. TOMPOS: We could do that. I can't 14


### do it right now because I don't have a laptop. 15


### But I mean, I will look at that and how much 16



### difference that makes. But I don't know if

-- I 17


### don't think Emanuel Levy maybe did get this 18



### information. 19


### But it would be interesting to me to see, 20


### okay, to achieve some of these things, we have to 21


### go to a dense pack. And if we can get over an 22227

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### R4, that's going to solve, I think, a lot of the 1


### proble ms, especially if the cost is relatively, 2


### you know, reasonable. 3


### MR. RAMIREZ: To get to that higher dense 4


### pack, is that a different material or is that 5


### just a different process? 6



### MR. LEVY: I can answer that. Emanuel. 7


### In fact, the R38 example we showed at the 8



### cost table assumed that the eaves were dense 9


### packed because we needed to get an R30 R value at 10



### the eave. So w e've assumed that they're dense 11


### packed. 12


### And that's something that's doable. And 13



### we've done it before with some test homes. But 14



### dense

- packing the roof is not a big stumbling 15



### block. 16


### MR. LUBLINER: I say we're ELMO. 17



### MR. SANTANA: We've talk ed about design 18



### elements or, you know, construction elements that 19


### the plant's going to have to do. And, you know, 20


### insulating pipes and ceiling openings and st uff 21


### like that, and all that stuff, when everything is 22228

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### said and done, you're not going to be able to 1


### see, and the customer won't really be able to see 2



### the difference. And that's fine. You know, 3



### that's reasonable. We can do all of that. 4


### If you start to ta lk about changing the 5


### geometry of the house, you know, there are plants 6


### that only build eight

- foot walls, right? 7


### If we're saying just drop the side wall 8


### height down and nobody's going to care, you know, 9


### I think that's unreasonable to think that you can 10



### -- you know, for an industry that's always trying 11


### to play catch

- up and always

-- you know, in some 12


### circles, manufactured housing is almost taboo. 13


### And so we're trying to gain equality with 14



### stick

- bui lt in terms of construction. And so we 15


### say manufactured house s now are going to have 16



### seven
- foot

- wall standard with a taller

-- I mean, 17


### what's that going to do to the market? 18



### I'd like to see what retailers think 19


### that's going to do to their business. You know, 20


### if we have plants that are going to nine

- foot 21



### walls flat and eight

- foot walls flat because

-- 22229

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### and it's all in trying to compete with what 1



### stick

- built is doing, we're going to take a huge 2


### step back if we think we're going to offset a 3


### shorter wall height with more insulation at the 4



### heel. 5


### MR. RAMIREZ: Manny, did I understand, 6


### though, that

-- I'm sorry. Emanuel, did I 7


### understand that you could currently pack in an 8


### R38 without changing the structure? 9



### MR. LEVY: You can put a

-- well, let's 10


### distinguish what we're talking about in terms of 11



### the maximum insulation leve l, which you can get 12


### well above a 38 or 49, or even 60. That's in the 13


### field there in the middle of the house, as 14


### opposed to what you can achieve at the eave. 15


### When we did our analysis, we wanted to 16


### get an R30 at the eave for the 38 in the field 17


### case, the o nly way to achieve that was to dense

18


### pack what the insulation that's in the eave area 19


### at a heel height of seven

- and

- a
- half inches. But 20


### go ahead. 21


### MR. RAMIREZ: And what did that produce, 22230

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### dense

- packing in that area, as far as the R 1



### value? 2


### MR. LEVY: Well, i t allowed you to get a 3


### much higher overall

-- or a higher. I wouldn't 4


### say much higher

-- a higher overall R value and 5



### therefore a lower U value for the same area. 6



### But in dense

- packing, you're putting a 7



### lot more mater ial into that area that's dense 8


### packed, so it's costing you some money. And that 9



### cost was included in our estimate. 10


### MR. RAMIREZ: Okay. So that costing has 11


### already been submitted. 12


### MR. SANTANA: Right. Emanuel, but I 13


### think he was asking what R value do you get at 14


### that restricted height area? Because that isn't 15


### R38. You know, what you do is

-- so you pack in 16


### as much as you can in the restricted area. You 17


### account for the restricted area. And then you 18



### blow more insulation. 19


### And as Michael said, if you have a 20



### double

- wide or a triple

- wide, you h ave a lot more 21


### area that's unrestrained that you can actually 22231

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### put more insulation versus what's restricted on 1



### the eaves. 2


### So then, you do a calculation to say 3


### what's your U value in the brook? You don't say 4


### what's the U value there? Because that might not 5


### be R30. This might be R49. And overall, you 6


### say, "Okay, this is R38." 7


### MR. RAMIREZ: And so, if it's overall

-- 8


### MR. SANTANA: Right. It depends what 9


### we're talking about. You know, and I think if 10


### Peter is saying we need to

-- or if members are 11


### saying we need to have R38 uniform throughout the 12


### roof, that's going to be a problem. 13


### If you say we're going to need R38 in the 14


### roof, we'll figure out how to do it. 15



### Manufacturers do that now. But there's a

-- 16



### (Cross

- talk.) 17


### MR. RAMIREZ: Let me get David and Pete r. 18


### MR. TOMPOS: I just would point out that 19


### I don't think the IRC requires you to have an R38 20


### throughout the roof. 21



### MR. SCHNEIDER: This is Peter

-- 22232

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### MR. TOMPOS: So, we're not going that 1



### far. 2



### MR. SANTANA: That's what Peter is 3


### saying, right, that it's R16 and

-- 4


### MR. TOMPOS: But he's getting an R30. 5


### IRC requires you can go down to an R30 over the 6



### eaves. 7


### MR. SCHNEIDER: Right. And this is 8



### Peter. 9


### And Manny and other working group 10


### members, I mean, the idea here is that, looking 11


### at what the overall average R v alue is of this 12


### roof assembly, y ou guys can come up to any 13


### Northern climate that gets regular snowfall, and 14


### you go to manufacturing housing lots, private or 15



### leased land. 16



### A nd everybody is out shoveling off their 17


### roof, because the ice damming is so bad that they 18


### all get water infiltration and compromise their 19


### building's durability, as well as the R value of 20



### that insulation that' s wet after the first 21



### snowstorm i f they aren't out there with roof 22233

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### rinks or standing up on their roofs shoveling off 1



### the snow. 2



### So, t his is about getting the proper 3



### insulation value over the exterior wall where 4



### there's the most heat loss. We need to resolve 5



### that issue. And I find it hard to believe that 6


### we're trying to serve the lowest

- income sector 7



### and we're concerned about seven

- and

- a
- half versus 8


### eight

- foot ceiling heights, when I'm talking 9


### about having even a deeper pitch cathedralized 10



### space. 11


### I can just say anecdotally that over the 12



### last mo nth I've had over probably 600

- 700 people 13


### tour our mobile home replacement unit in 14


### Burlington, Vermont. Every single person that's 15


### come into that unit can't believe how the space 16


### feels and how big it feels compared to what they 17


### anticipated. So, and that's with a seven

- and

- a
18



### half

- foot ceiling and eight

- and

- a
- half foot ridge 19



### with a two

- and

- a
- half 1 2 pitch on the inside and 20



### outside. 21



### MR. JACKSON: Michael? 22234

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### MR. LUBLINER: Yeah. I think we've 1


### thoroughly discussed the thermodynamic issue and 2



### resolved that. 3


### But I do want to bring up the cost 4


### savings to the consumer from avoiding ice dams in 5



### Northern clim ates. We have a similar experience 6


### with a program in Montana and northern 7


### Washington. 8



### So I would like to ask either the SAA 9


### program that HUD runs if they're willing to share 10


### that information with DOE, as to how many 11


### thousands of ice dam complaints nationa lly, or 12


### maybe it's hundreds, or maybe it's not even that 13


### many, they get every year. And look at what the 14


### cost to repair those ice dams are. 15



### Manufacturers have some of that 16



### information as well because of the warranties 17


### associated with the project. 18



### I think that our group agreed that 19


### durability was a factor we wanted to consider 20


### here. We have some very compelling reasons 21


### thermodynamically that we can do it. The costs 22235

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### already assume that. And I think the ice 1


### damming, avoiding ice damming is, anecdotally and 2


### probably quantifiable, a significant reason that 3



### the consumer would want the better insulation at 4


### the eaves. Thank you. 5


### MR. TOMPOS: A question for Manny. You 6


### know, if we raise the heel height to seven

- and

- a
7


### half inches, that only gives me six

- and

- a
- hal f 8


### inches to put insulation. We still aren't 9


### achieving an R30 over that wall. Is that

-- so 10


### your costs don't take into account that we may 11


### have to get to an R30. I mean, this is a 12


### conversation. The IRC requires an R30 over that 13


### edge. 14



### MR. LUBLINER: It i s what it is. 15


### MR. TOMPOS: So, well, if we get to go by 16


### the KISS program, it is what it is. But

-- 17


### MR. LUBLINER: After making all the 18


### attempts to do it as well as possible. 19


### MR. TOMPOS: Okay. But even at a seven

20



### and

- a
- half heel height, which we don't d o now, so 21


### what I'm understanding is that cost is included. 22236

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### At some point we're going to have to decide what 1



### that minimum value is and what other cost 2


### implications there are to getting to that, unless 3


### we're going to say it is what it is. 4



### MR. LUBLINER: Whe n I said "it is what it 5


### is," what I was saying is you attempt to use the 6


### highest density insulation that you can, which 7



### seems that

-- and maybe we'll have a little issue 8


### with some homes that you won't get the full R30 9


### at the eave. And that's why I would s ay we can 10


### work on this as a unique thing that isn't

-- that 11


### because of transport, and make potentially an 12


### exception for certain situations where that 13



### occurs. 14



### But I don't think it is what it is at the 15


### 2.6 density. And I don't think we costed that 16



### out. 17



### MR. TOMPOS: Apparently, we didn't . I 18



### wasn't aware of that. 19


### MR. RAMIREZ: So, I think just to try to 20


### capture what I think are a coup le of the concerns 21



### here is that you're trying to get the R38 in as 22237

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### many places as possible, if not all of them. But 1



### I understa nd that there may be some restrictions 2


### by the wall where the eave is tighter. 3



### And I think that the concern on the 4


### manufacturing side is that, if the standard says 5


### R38, and by the eaves it does not, we don't have 6


### R38, am I going to get in trouble? Right. And 7


### so, if so, do I have to then figure out ways to 8


### get R38 in that area? 9


### But what I'm hearing is that there may be 10



### a way to say that, "Hey, let's get R38 in the 11


### most places possible with a few exceptions." And 12


### we could deal with those exceptions. And th en I 13


### would ask, how? What is the verbiage that we 14


### would need in order to look at, right? 15



### David? 16


### MR. TOMPOS: No, I'll let Mark. I'll 17



### pass. 18


### MR. RAMIREZ: Okay. Mark? 19


### MR. WEISS: Somebody correct me if I'm 20


### wrong. Are we talking about redesigning every 21



### HU D code home to address this, potentially? 22238

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### Manny? 1


### MR. LUBLINER: Every one? 2


### MR. WEISS: That's what I'm asking. 3



### (Cross

- talk.) 4



### MR. MENDLEN: Yeah, but just the 14

- wides 5



### and smaller. 6



### MR. WEISS: Just what? 7



### MR. MENDLEN: Fourteen

- wides and smaller, 8



### it looks l ike. 9


### MR. WEISS: Okay. 10


### MR. TOMPOS: No. I mean, we have 5.5 11



### inch heel life on

-- 2.5 inch on some, on 12


### everything. So what we're talking about, and 13


### maybe Manny can help us, is, was your cost 14


### assuming that we have to redesign and retest 15


### every truss in the industry? 16



### MR. SANTANA: No. No, no. 17



### MR. TOMPOS: But don't we have to do that 18


### if we change the heel height on everything? 19


### MR. SANTANA: If you change the truss 20


### design from what it is, you're going to have to 21


### redesign. 22239

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### MR. TOMPOS: Okay. 1



### MR. WEISS: And just to finish the 2


### thought, to me, that's ridiculous. Okay? You 3


### know, Vermont

-- I've calculated. Vermont is 2

- 4


### 10th of 1 percent of the manuf actured housing 5



### market in 2014

- 2013. I realize there are other 6


### states with cold climates. But the majority of 7


### our production is going into warmer climates. 8


### And to start talking about redesigning 9


### all these homes with the market implications that 10


### Manny mentioned before just seems to me to be an 11


### absurd stretch for what we're doing here. 12


### MR. LUBLINER: You know, I'm h aving deja 13



### vous because when we discussed the wind 14


### standards, and then HUD upgraded it, I heard the 15


### same argument. And after the wind standards were 16


### adopted, we didn't lose the industry. We didn't 17


### change the market share significantly. 18


### And we ended up wi th more durable houses 19


### that made this industry's recognition of a 20


### product that can make it through a hurricane, 21


### recognized that by the insurance companies, the 22240

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### banks. 1


### And so I'm hearing deja vous, Mark. I 2


### understand what you're saying. I'm not disputing 3



### that there isn't a cost associated with 4


### reengineering the trusses. But I think that 5


### change is something that the only people that 6


### like change are babies with lousy diapers. At 7


### some point, you accept change because it's the 8


### best thing for the consumer. 9



### MR . WEISS: Well, and you know, I just

-- 10


### but I don't think you have a comparable argument 11


### from wind standards to what we're talking about 12



### here. 13


### MR. LUBLINER: Okay. 14


### MR. WEISS: You have legitimate concerns, 15


### issues with wind damage

-- 16



### (Cross

- talk.) 17



### MR. WEI SS: Well, excuse me. Let me 18



### finish. 19


### You had specific issues with wind, and 20


### you had consumer issues, consumer problems. What 21


### we're talking about here, again, I'll go back to 22241

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### the AHS information, okay? Operating costs for 1


### manufactured homes equal to in t he case of 2


### electricity site

- built homes, less than other 3


### fuel types, site

- built homes. 4


### I have not heard, you know, in relation 5


### to this statute and the process we're talking 6


### about, a great consumer outcry that there's this 7


### deficiency that is a problem and t hey need to be 8


### changed through drastic measures. 9


### So I think yo u're talking, you know, 10



### oranges
- to

- apples, Mike, I'm sorry, in this 11



### instance. 12


### MR. RAMIREZ: Let me get Lowell, then 13



### Peter. 14



### MR. UNGAR: I'm confused on two counts. 15


### One is, there were a couple of references to 16


### redesign, and I'm not quite sure what that means. 17



### I mean, this is a standard. It's my 18


### understanding that very little manufactured 19


### housing meets the standard or is as good in terms 20


### of efficiency as IECC 2015. 21


### So, there would be some changes required. 22242

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### But that doesn't necessarily mean a whole 1


### redesign of each model. 2


### In terms of the latter, I thought the 3


### discussion we were just having was about 4


### cathedral ceilings, which I gather are more 5


### popular, but are still a small, relatively small 6



### fracti on of the market. And was this past 7


### discussion about all homes with flat ceilings as 8



### well? Or

-- I mean, I thought that was

-- 9


### MR. TOMPOS: Yeah. I mean, it's going to 10



### affect all homes. 11


### MR. UNGAR: So I guess, I mean, we 12


### started yesterday at the beginn ing of yesterday 13


### with a detailed presentation of the cost in order 14


### to get up to different levels of insulation. I 15


### mean, that's

-- those were from industry. 16


### I mean, you know, we have not vetted 17


### those outside the manufactured housing industry, 18



### but that was my understanding of the presentation 19


### from the manufactured housing industry of their 20



### best estimate of the cost to meet these. 21


### And so, are you arguing that those costs, 22243

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### which we went over in some detail yesterday 1


### morning, are completely misrepresentative of what 2



### it would cost to meet those levels? 3



### MR. RAMIREZ: David? 4


### MR. TOMPOS: Well, I wasn't on the 5


### subcommittee. But I mean, I think some new 6


### information came to light. Because there is a 7


### provision in the IRC that says you have to have a 8



### certain R value o ver the eave. Correct? 9



### MALE VOICE: Yes. 10


### MR. TOMPOS: And you can't get that with 11


### the trusses that are being sold to the industry 12


### right now . And if we have to go to a seven

- and

13



### a
- half or a
-- you know, I think Vermont 14


### suggested a 14

- inch heel height, you 're talking 15


### about redesigning

-- I mean, there's going to 16



### have to

-- we're going to have to go to the truss 17


### manufacturers. They have to redesign the truss. 18



### Then we have to test the truss because we 19


### test 99 percent of the trusses in the in dustry. 20



### And I'm just asking. I don't know. Maybe 21



### Emanuel did include that cost. 22244

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### MR. UNGAR: So, the issue is we're not 1


### talking about the overall R value of the ceiling 2


### insulation? You're concerned about a separate 3


### provision that requires a certain

-- 4



### MR. TOMPOS: Cor rect. 5


### MR. UNGAR: And this is a mandatory 6


### provision? 7



### MR. TOMPOS: In the IRC, yes. 8


### And I have a conflict here, because if 9


### you change all the designs, and I'm going to have 10


### to review all those, so I'm going to make a lot 11


### of money off this. 12



### MR. UNGAR: I'm s orry. You're also

-- 13


### MR. TOMPOS: Maybe I shouldn't be 14


### arguing. 15


### MR. UNGAR: I'm sorry. You're also 16


### saying that IRC, you don't mean

-- are you 17


### talking about the IECC or a separate version of 18



### the IRSM? 19



### MR. TOMPOS: It is in the

-- somebody 20



### that knows the code better than me. 21


### MR. LACEY: Yes, it's the same thing. 22245

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### MR. TOMPOS: Same in both codes, okay. 1



### (Cross

- talk.) 2


### MR. UNGAR: So, we're arguing about a 3


### mandatory provision in the IECC, which presumably 4


### Manny's subcommittee looked at. And is that an 5



### unresolv ed issue under that subcommittee? 6


### MR. SANTANA: It's not mandatory. 7


### MR. LACEY: No. Let me clarify. I just 8



### -- I want to maybe clarify where this R30 comes 9


### from, or at least where I think it comes from, if 10



### I could. 11


### The prescriptive attic or ceiling 12



### insula tion requirements that are laid out in the 13


### IECC prescriptive path range from an R30 to an 14


### R49, depending on the climate zone. 15


### Now, the IECC prescriptive path has some 16


### exceptions that play into this. One of them is 17


### if the ceiling has an attic space and if the 18


### requirement is R38, so that would apply to 19



### climates IECC

-- every climate zone except for 20


### basically the most s outhern Miami climate zone. 21


### If the requirement is R38, you're 22246

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### permitted to go down to R30 as long as the 1


### uncompressed insulation over the eave is at least 2


### an R30. So it gives you kind of an exception, I 3


### mean, a lower insulation requirement, as long as 4


### you have the right kind of truss out there. 5



### And then , it's similar for

-- 6


### MR. UNGAR: And, sorry. That's

-- so 7


### where the overall requirement is for an R38, you 8


### don't have to meet the overall requirement

-- 9


### MR. LACEY: The whole thing could be R30 10


### as long as it extended out to the eaves. 11



### MR. UNGAR: To the eaves? 12



### MR. LACEY: Uh

- huh. 13


### MR. UNGAR: So there's two options. You 14



### could either meet the R 38 overall. 15


### MR. LACEY: Right. 16


### MR. UNGAR: Or you could meet the R30 17



### over the eaves? 18


### MR. LACEY: Yes. And it's important to 19


### remember, too, that this is just one of the 20


### options. But you could also do a U factor 21


### alternative, which would allow you to trade it 22247

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### off and to do other things other than redesigning 1


### the whole, you know, roof maybe. There are 2


### other means of making up, you know, an equivalent 3



### level of overall UA. 4


### And so, I think the confusion

-- I think 5


### the confusion is coming from the fact that the re 6



### is a carve

- out in here that allows you to go down 7


### to R30 as long as the R30 is all the way out to 8


### the ends. But that's just an exception to the 9


### prescriptive path. 10


### You could put R5 in there if you wanted 11


### to as long as you made up for the energy losses 12



### s omewhere else i f we're incorporating all the 13


### different paths in the IECC. 14


### Am I explaining that correctly? 15



### MR. WEISS: Yeah. 16


### MR. TOMPOS: Yeah. And again, before I 17


### can tell you if we can or can't do it, I need to 18



### know where we fall on the U values. And I don't 19



### think

-- we've been talking more about 20


### prescriptive path. And you know, I've got to put 21



### it in an R38. But I don't

-- I haven't seen

-- I 22248

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### don't know where those U values are going to 1



### fall. 2


### MR. LACEY: Yeah. And it may be that if 3


### you build to the pr escr ip tive, you would have to 4


### do the roof a certain way. But if you didn't 5


### want to do the roof that way, you could use the 6


### UA or the performance or whatever compliance 7


### options

-- 8



### (Cross

- talk.) 9


### MR. RAMIREZ: So then, does this have to 10



### be taken care of in your report? 11



### MR. SANTANA: No, I don't think so 12


### because this isn't one of the mandatory

-- you 13


### know, the mandatory sections don't get into the 14


### compliance paths. So, what was that? 15


### MR. LUBLINER: Why are we talking about 16


### it? It's not mandatory. 17



### MR. TOMPOS : Because if we want to have a 18


### prescriptive path, which I thought that was your 19


### proposal, Michael, we're going to have to

-- I 20



### think we have to address this. 21



### MR. LUBLINER: Yeah. We have to address 22249

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### it if and when we run into that situation if it 's 1


### legiti mate. After you dense

- packed it and you 2


### dealt with that, if it's still a problem, we can 3


### change it from R30 to whatever it is. 4



### (Cross

- talk.) 5


### MR. SANTANA: Well, the whole thing 6



### started because

-- 7



### MR. TOMPOS: Make it R25 and I think 8


### we're okay. 9


### (Laughter .) 10



### MALE VOICE: That makes sense. 11


### MR. SANTANA: Dave was just providing the 12



### restrictions of the construction. And I think 13


### now it's been very well explained. 14


### MR. RAMIREZ: Very well discussed? Okay. 15


### (Laughter.) 16



### MR. RAMIREZ: Mark? 17


### MR. WEISS: Eric, thank you. I 18


### appreciate the explanation. This just kind of 19


### goes back to something I mentioned more or less 20


### in passing yesterday when we first started 21


### talking about costs. 22250

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### And that is, I don't know why DOE

-- I 1



### wish Joe was here to

-- DOE hasn't or doesn't 2


### jus t build, commission the building of homes to 3


### meet these various requirements, and then you can 4


### really see what the cost is based on the outfit 5


### of a going concern. 6


### You get a large company, small company, 7


### medium company, and just build some of these 8


### things. And you're not talking about necessarily 9


### a long period of time to do it. And see what all 10


### this looks like, you know. 11


### I'm all for theoretical discussion. But, 12


### you know, some facts on the ground might help. 13


### MR. RAMIREZ: Okay. Michael? 14



### MR. LUBLINER: So, I said before that I 15


### go out into factories, and I see R38s sold as an 16


### option currently. How are they doing it? It's 17


### your plant. Plants that you represent, other 18


### plants, how are they doing it? 19


### MR. EZZO: Michael, this is Mark Ezzo. 20



### I'll answer that. 21



### MR . LUBLINER: Thanks, Mark. 22251

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### MR. EZZO: So, the insulation folks that 1


### we buy from

-- and we buy from some of the 2


### biggest suppliers in the country. We buy a lot 3


### from JM, right? They give us these bag charts. 4


### And it says, if you want to put R38 in the roof, 5



### and the ceiling is 13 feet 2 inches wide, and 6


### it's 68 feet long, and if you want to hit R38, 7


### you've got to put in 18.4 bags. 8


### And I'll tell you that today, for the 9


### most part, it may not be 100 percent, but a huge 10


### majority of our rafter profiles, we can fit 18 11


### bags in and hit R38. Okay? That's on paper. 12


### That's according to the Johns Manville chart t hat 13


### says, if you put 18 bags in at a ceiling that 14


### size, you're going to hit R38, okay? 15


### Now, JM doesn't take into consideration a 16


### lot of geometry and heel heigh ts and roof slopes 17


### and ceiling slopes. They just say, if you put 18


### this much insulation in the roof, you're going to 19



### meet our tabulated R value. And that's what we 20


### do, and that's what everybody in the industry 21


### does. Okay? 22252

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### So, we tell consumers they're get ting

-- 1


### they order an R38 roof. And that's what's in our 2


### option package. And that's what's in our sales 3


### literature. And that's what we're doing. 4


### MR. LUBLINER: Thanks, Mark. 5


### MR. EZZO: Now, to Dave Tompos's point, 6


### when we run an energy calculation to co mply with 7


### the HUD code, right, heat loss calc, we're taking 8


### into consideration all that truss geometry and 9


### coming up with a U value of all the components. 10


### And I know I'm telling you stuff you already 11



### know. 12


### And when we do that, the net U value that 13



### comes o ut of that roof or ceiling, because of the 14


### geometry, it doesn't always equate to a true R38. 15


### Okay? It may be something a little bit less than 16


### that based on that truss geometry. But we're 17


### still putting in all the prescribed insulation 18



### amount that Johns M anville tells us to put in the 19


### roof. Okay? 20


### So, I mean, all that said, I understand 21


### that, you know, we're taking a 20

- year leap in 22253

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### energy standards. So, I mean, to me it's natural 1


### that we're going to run into situations like 2


### we're looking at here on the s creen, where in the 3


### coldest climates those profiles are probably not 4


### going to work in a lot of cases. 5


### For one thing, you can't get 18 bags of 6



### insulation in that roof that I'm looking at 7


### there. It's just physically impossible. So 8


### there's going to be situa tions like this that's 9



### like we're looking at that, even if you try to do 10


### the UA tradeoff or even if you try to go 11


### prescriptive or even if you do overall U value, 12


### we're still going to have situations where that 13


### geometry just flat

- out doesn't work and we're 14


### going to have to do, you know, one of several 15


### things. 16


### Lower wall heights. Lower ceiling 17


### pitches. Raise roof pitches. Increase heel 18


### heights. A combination of those things

-- I 19


### mean, we're going to have to do something to make 20



### it work. 21



### Does that a nswer t he question? 22254

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### MR. LUBLINER: It totally answers my 1


### question. Totally answers my question. Thank 2


### you very much. 3



### (Pause.) 4



### MR. RAMIREZ: What do we need to do with 5



### this information? 6


### MR. SANTANA: Internalize it. It might 7


### come out later on, to sections of t he code. 8



### (Cross

- out.) 9


### MR. TOMPOS: As we get into the specifics 10


### on the prescriptive methods, I think we're going 11


### to have to look at this again. 12


### MR. RAMIREZ: So, does everyone go with 13


### moving on then, with respect to

-- 14


### MR. WEISS: We'll go on into Manny's 15


### area? I just didn't hear what you said. 16


### MR. RAMIREZ: Oh. Yes. He was saying 17


### that we're going to have to deal with it later 18


### when we're talking about different compliance 19


### paths. 20



### MR. SANTANA: Because we haven't even 21


### started talking about how we're going to comply. 22255

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### MR. WEISS: Yeah. Yeah. 1


### MR. SANTANA: You know? So we've got to 2


### keep this in mind, just internalize it. 3



### MR. RAMIREZ: Which I would like to do 4


### sometime today. We'll see if we can get there. 5



### Ever yone's smiling at me like, "Oh. It's a 6



### landmi ne. " But let's see. 7


### All right, so good to move on? 8



### (Pause.) 9


### MR. RAMIREZ: Then the next one is Manny. 10


### MR. SANTANA: Okay. Can we get a break 11



### before this? 12


### MR. RAMIREZ: Let's do that. Thank you. 13



### Let's take a 10

- minute break, and then we'll come 14



### back at 2:30. 15


### (Recess from 2:19 p .m. until 2 : 35 p .m.) 16


### MR. RAMIREZ: All right. So, Manny is 17


### going to go next. And what we did was, Mark had 18


### the good idea

-- thank you

-- for continuing the 19


### same format that we had last time, when we were 20


### discussing some of these items as far as, if 21


### there's a consensus agreement, any comments on 22256

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### the cost or savings impact, and then whether this 1


### is a current practice or not. All right? So 2


### those are some of the things that we had 3



### discussed last time. 4


### So, with that, Manny, I'd like to turn it 5


### over to you to guide the discussion here. 6


### MR. SANTANA: Okay. So, this 7


### subcommittee was focused on identifying the parts 8


### of the IECC that are required as mandatory, and 9


### then go through and recommend whether or not, 10


### Dave, this should be added t o the MH standard or 11



### not. 12


### And we went through the easiest at the 13


### last meeting. And so now we're going through the 14


### items that required some more consideration and 15


### that may not get accepted as is, although we did 16



### come to a determination that several of them may 17


### be accepted as is, or we recommend they could be 18


### accepted as is. 19



### So

-- and again, speaking to the idea of 20


### poor concepts, you know, some of these issues, we 21


### can accept in principle, but didn't want to

-- 22257

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### couldn't spend the time to come up with any kind 1


### of language for them. So, you know, you might 2


### see that in here, where we just

-- you know, we 3


### accept the concept in principle, but don't know 4


### exactly how it should read. 5


### With that, I think the best thing to do 6


### is to just go in order. I may jump around a 7


### little bit if we come across an item that may be 8


### time consuming. 9


### So, if everybody has a copy of the IECC, 10


### and you go over to section R401.3, and that's on 11


### page R29, R401.3

-- 12


### MR. RAMIREZ: Give folks just a second 13



### there. 14



### MR. LUBLINER: Are there extra co pies of 15



### the IECC around? 16


### MR. RAMIREZ: Emily, do you know where 17



### those books are at? 18


### MR. LUBLINER: I didn't get one. 19



### (Pause.) 20


### MR. LUBLINER: I had to buy mine, but I 21



### didn't

-- 22258

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### (Cross

- talk.) 1



### MALE VOICE: We can share. 2



### MR. LACEY: I can look on. 3



### MR. RAMIREZ : We can share, yeah, yeah. 4


### MR. LUBLINER: Thank you. 5



### (Pause.) 6


### MR. SANTANA: So, R401.3 deals with the 7


### certificate. And, you know, Ted, if you can put 8


### up the suggested

-- what everybody suggested, not 9


### language, but

-- okay. 10



### When it comes to the certifi cate, and if 11


### you could scroll down a little bit

-- 12



### (Pause.) 13


### MR. SANTANA: You know, the IECC has a 14


### requirement to install a certificate that lists 15


### several items which would duplicate the 16


### certificate requirements currently in the HUD 17



### code. 18


### So, without gett ing into, or without 19


### knowing how it's going to be implemented or 20


### enforced and without wanting to get into that, 21



### the committee recommends that DOE refer to the 22259

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### HUD code requirements for what's currently 1


### required in their certificates, but make sure and 2



### incl ude fenestration U values and SHGC values 3


### which currently aren't required by the HUD code. 4



### So that's the recommendation there. 5



### (Pause.) 6


### MR. SANTANA: I'll open it up to 7



### discussion. 8


### MR. RAMIREZ: Yeah. Questions? 9



### Mark? 10


### MR. WEISS: Manny, could you be a lit tle 11


### bit more specific and say "information for 12



### fenestration U values and SHGC"

-- are you 13


### talking about general information or information 14


### for that particular unit? 15


### MR. SANTANA: Well, okay. The 16


### requirement in the IECC, one of the things that 17


### it requires is that the manufacturer have a label 18


### where you list the U values for your windows and 19


### the solar heat gain coefficient for the window. 20


### And the reason why we added that 21


### specifically is because that item isn't included 22260

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### in the HUD current requirements, and we think 1


### it's a good idea. 2



### MR. WEISS: So it's the data for that 3



### home? 4


### MR. SANTANA: Yeah, for that particular 5



### home. 6


### MR. WEISS: That's what I figured. 7



### MR. LACEY: Windows that are NFRC labeled 8


### will have that in big numbers right on the label. 9



### (Cross

- talk.) 10


### MR. LACEY: That's why you should put it 11


### on the certificate, yeah. 12


### MR. UNGAR: I had a couple of questions 13



### about that. When you look ed at it, I mean, did 14


### you decide that the other things that are on the 15


### IECC's certificate are already included on the 16



### HUD c ode? 17



### MR. SANTANA: Most of them are. One of 18



### the ones that

-- one of the items that isn't is 19


### the efficiencies of appliances. And one of the 20


### things that HUD's data plate requires is that you 21


### list the appliance. You know, so you list the 22261

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### model, you list th e appliance. You don't list 1



### the efficiencies. 2



### And we wouldn't include that as a 3



### recommended ; I guess you could suggest that. But 4


### we didn't really see the benefit of it. You 5


### know, the U values for the fenestration and the 6


### solar heat gain value for the fe nestration, we 7


### could see the value in that. But the efficiency 8


### on the appliances, you know, didn't really find 9



### that to be essential. 10



### MR. RAMIREZ: Michael? 11


### MR. LUBLINER: I really like providing 12



### more information on that label for a number of 13



### reasons. For the consumer to shop around. 14


### They're in a lot. Look at what they're getting 15


### for their price and given the market and given 16



### the consumer choice. But also, we find that a 17


### lot of lenders, as we are starting to recognize 18


### energy ratings, like third

- party fo lks, provide 19


### preferable financing. 20


### So, the more information that's readily 21



### available means that the rater doesn't have to 22262

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### spend a lot of time figuring things out and can 1



### cost

- effectively rate the home and might help 2


### those homeowners, second

- homeowners or w hoever, 3


### or utility program that wants to verify that this 4


### home is going to meet their standards. 5


### So I think this is a really good thing. 6


### I think as far as the appliances go, if it's new, 7


### you've got the energy guide label. But once that 8


### home is sold, that energy guide label kind of 9


### isn't there anymore. So you kind of lose that. 10


### But I think it's appropriate that the energy 11



### raters can go look at the appliance and figure 12


### out what the rating is. 13


### But this is a good thing. I think it's 14


### transparency, it's cons umer choice. It's better 15


### information for the heating contractor to 16



### calculate the size of the air conditioner after 17



### market if there's a need for that. So I think we 18


### did good on that one. 19



### MR. RAMIREZ: Let me see a show of thumbs 20


### if everyone is okay with t he committee 21



### recommendation. 22263

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### MR. UNGAR: Sorry. I have one more thing 1



### to ask before. 2



### MR. RAMIREZ: Go ahead. Yeah. 3


### MR. UNGAR: You know, on that it seems to 4


### me that the appliance information might be useful 5


### for programs, but I don't feel really strongly 6



### about it. 7



### I'm m ore wondering, Robin in his 8


### presentation last time made a strong pitch for 9


### energy use estimates on labels. And I don't 10


### know, I'm curious both whether you considered 11


### that, and then you know, I guess, if particularly 12


### if Robin, given his stron g
-- has any comment on 13



### that. 14


### Because it would seem to me that this, if 15


### we were to do it, this would be, I assume, where 16


### it would be included. So I just wanted to flag 17


### that as, that seems to me that that would be the 18



### issue here. 19


### MR. ROY: Okay. Then I ha ve to say 20


### something. 21


### (Laughter.) 22264

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### MR. RAMIREZ: Go ahead. 1



### MR. ROY: Robin. 2


### In the context of having different 3


### product types, it seemed particularly useful to 4



### make it easier for consumers to understand what 5


### they might be buying or what they might be 6


### trading off. 7


### In that case, it seemed very useful to 8


### have something which is particularly 9



### understandable to consumers. And some of the 10


### stuff isn't really very useful anyway. 11


### FTC labels like I put up on the screen a 12


### couple of weeks ago show how much money you're 13



### sp ending at currently projected prices and where 14


### this particular unit fits within the spectrum of 15


### homes, typical stuff you see for refrigerators, 16


### for example. 17


### Dollars are, I think, helpful both to 18


### consumers, the first buyers, subsequent buyers, 19


### and perhaps w ill help twig with some of the 20


### raters. I don't know. I suspect raters are 21


### sophisticated enough to not need that, but it's 22265

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### always useful to have that to push a 1



### conversation. 2


### I wouldn't be proposing it here if you 3


### have a single product type, particularly. I 4


### wouldn't object to it. I'd like to see it. I 5


### think it's helpful for folks to kind of 6


### understand. But they won't be trading off 7



### between nearly so much as they would in a two

8


### product

- type world. 9



### Does that make sense? 10


### MR. SCHNEIDER: This is Peter, from 11


### Efficiency Vermont. 12



### MR. RAMIREZ: Yeah. Go ahead , Peter

. 13


### MR. SCHNEIDER: I was just going to say, 14


### in Vermont, you know, our MLS listing is an 15


### example as the home energy rating index, any 16



### other certifications that have been earned with 17


### regards to ENERGY S TAR or E nergy C ode P lus. 18


### Where I think that labeling is going to 19


### be the most important is with regards to 20


### appraisers . And right now, in our units, we have 21


### an energy light bulb that has the home energy 22266

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### rating index for the home s and the

-- yeah. 1



### And so I t hink that having a label in 2



### here which no

-- this is the code that the home 3


### has achieved, whether it's achieved ENERGY STAR 4


### as well, but provides compliance , ju st will help 5


### the appraiser identify this home and provides 6



### value over the costs that ma k e other homes that 7



### are sold or that have met a lesser code that may 8


### not carry the ENERGY STAR label. 9



### MR. RAMIREZ: David? 10


### MR. TOMPOS: I think some type of an 11


### energy rating would be a good idea. I think it 12



### can be done when the manufacture r does their heat 13



### loss ca lc. So I don't think there would be much 14


### additional expense. 15


### However, I am opposed to the idea of 16


### giving a dollar amount. Because this industry, 17


### for whatever reason, the consumers like to sue 18



### the manufacture r
. And if we put a dollar amount 19


### on appliances , you can't really relate that to 20


### anything because your energy bill is added up 21


### among a lot of things. 22267

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### So now if I have a dollar amount that 1 

### says, "You're going to spend $100 a month on this 2


### house," but if I've got six kids in the house and 3


### I'm leaving the windows open and the air 4 

### conditioning on 60, and I'm spending $200, you 5


### know, a month, I'm going to go sue that 6



### manufacture r because they lied to me about what I 7


### was going to spend on this house. 8


### So, if we come up with a rating that's 9



### like a HERS rating, is zero to 100 or whatever it 10


### is, I can live with that. But I would be opposed 11


### to some type of a dollar amount. 12



### MR. ROY: This is Robin. 13


### That kind of means you're saying that 14


### it's less transparent to a consumer. And that 15


### makes it positive. I hear what y ou're saying 16



### with that. 17


### My qualifier for it

-- and I take the 18


### point that one might, a buyer might end up 19


### spending a lot more and has some dissatisfaction. 20


### But I think in all of those, even in the 21


### appliance world , there is

-- it's qualified, 22268

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### s aying "in typ ical use" and "in typical 1



### circumstances." 2


### And I think it's appropriate to have that 3


### kind of language. And if you have six kids and 4


### you don't get to this, it's going to be 5


### different. Where do we go with that? 6


### MR. RAMIREZ: Mark, and then Emanuel. 7



### I'm sor ry, Manny. 8


### MR. WEISS: I'll go beyond Dave. I mean, 9


### even a rating that's calculated by the 10


### manufacturer is litigation bait. I mean, when 11


### you're talking about fenestration U values and 12


### you're getting that number from the manufacturer , 13


### or SHGC also, you're just passing through 14


### information you get from the manufacturer. 15


### Somebody sues you, you say, "Hey, over 16


### there." But once you start making calculations 17


### and dollar values like Dave was talking about, 18



### it's Katie

- bar

- the

- door. I mean, there's all 19


### sorts of po tential for problems there. 20


### MR. RAMIREZ: All right. Manny? 21


### MR. WEISS: I mean, I know what you're 22269

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### trying to accomplish. But there's blowback from 1



### it. 2


### MR. RAMIREZ: Let me get Manny, and then 3


### we'll see if there's anyone on line. 4


### MR. SANTANA: You know, o ne of the ways 5


### that we were able to get through the section was 6


### to try to keep as narrow a scope as we were 7


### comfortable with. And although I see the 8


### benefits to having an energy rating for the house 9


### or an energy usage for the house, I don't think 10



### that tha t's the same as the certificate that's 11


### required in the IECC. 12


### You know, it's in addition to that. So, 13


### you know, I would suggest that we close this 14



### issue off before

-- and this energy use label is 15


### probably going to be a separate issue altogether. 16



### All the i nformation probably wouldn't be on the 17



### same label. 18


### You know, the reason why we made this 19


### suggestion is so that we can try to contain the 20



### information on one sticker. 21



### MR. RAMIREZ: Ishbel? 22270

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### MS. DICKENS: May I just suggest that we 1


### put energy label on the park ing lot then, so that 2


### we don't forget about it? 3



### MR. RAMIREZ: Eric? 4


### MR. LACEY: I was just going to back up 5


### what Manny said. You know, we've kind of

-- we 6



### have this fundamental choice. Do we start with 7


### the HUD label and add something to it? Or do we 8



### sta rt with the IECC certificate and try and add 9



### the HUD stuff to it? 10


### And we took the approach of starting with 11


### the HUD label that already goes on these homes, 12



### said , what are a couple of things we could add to 13


### this to get basically the same information out 14



### the re? Right or wrong, that's kind of the 15


### approach we took. 16


### MR. RAMIREZ: So, Ted started an 17


### electronic parking lot and threw in the energy 18



### labels in there. 19



### Lowell? 20


### MR. UNGAR: So, as I understand that, for 21


### energy ratings, there was also the suggestion 22271

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### just if it's ENERGY STAR home, to put that one. 1



### And I don't know what it could also do based for 2


### UO value, not all homes

-- we haven't discussed 3


### compliance paths. But it's not clear that all 4



### homes will have a calculated UO value. 5


### But if that was part of the c alculation , 6


### it would seem to me that those two things could 7


### easily be added there. They're set information. 8



### It's not

-- I don't see those as particularly 9


### litigation bait, and would be helpful then for 10


### appraisals or for future programs. 11



### MR. EZZO: This is Mark Ezzo. 12


### MR. UNGAR: Or ENERGY STAR, whatever

-- 13



### (Cross

- talk.) 14


### MR. EZZO: Don't those already come with 15



### their own labels? 16


### MR. UNGAR: Yeah, but separately labeled, 17



### that's fine. 18



### (Cross

- talk.) 19


### MR. UNGAR: If there's a separate label 20


### on the home, then I w ithdraw it, separate 21



### certification. 22272

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### MR. RAMIREZ: Okay. Mark, what was your 1


### question? 2


### MR. EZZO: It wasn't a question; it was a 3


### statement. ENERGY STAR homes already come with 4



### their own labels. 5


### MR. TOMPOS: Yep. 6


### MR. LUTER: This is Rob. I've got a 7



### commen t if I can sneak it in? 8



### MR. RAMIREZ: Yeah. 9


### MR. LUTER: Rob Luter with Lippert. 10


### I would be very cautious about putting 11


### anything on the label that is not objective and 12


### supportable, you know. About two to three ALMA 13


### (phonetic) meetings ago, we had a very ni ce 14


### person from the FTC come in and give us a lecture 15



### on how it was verboten to make claims about 16


### percentage of energy saved if someone bought our 17


### fenestration or potential dollars saved. 18


### In fact, the FTC has brought suit against 19


### parties for making just the kind of claims that I 20


### think we're contemplating putting on a label. 21


### MR. WEISS: That's an excellent point. 22273

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### Also, there could be concerns with state

- level 1


### enforcement as well regarding false claims. 2


### MR. LUTER: No. I've just always found 3



### that if one

-- I think it's a good idea to put 4


### some sort of rating on this label. The more 5


### useful information for the consumer, the better. 6


### But I wouldn't want it to be misleading 7


### or at all subjective or something that had to be 8


### qualified. Because the consumer's just no t going 9



### to understand. 10


### MR. RAMIREZ: So, let me understand, 11


### though. I think what's being recommended by the 12



### subcommittee is the U value. Is that

-- 13


### MR. LACEY: Yeah. Just to be clear, Rob, 14


### you're not opposing listing the labeled 15



### fenestration U values a nd SHGC's. You're talking 16


### about the issue of a rating system or making 17


### claims about the dollars or percentage energy 18


### efficiency, right? 19


### MR. LUTER: That's correct, Eric. 20


### MR. LACEY: Okay. 21


### MR. LUTER: I think it's a good idea to 22274

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### make supportable claims us ing objective measures. 1


### In fact, we do that on all fenestration as it's 2



### delivered. It's labeled with the NFRC certified 3


### U values, solar heat gain, air leakage, 4


### condensation rating, in some cases. 5



### And I don't

-- I'm just sharing that 6


### regarding the fenestr ation. But if there's going 7


### to be a rating plate on the home, I think it's 8


### important that that feature only objective data 9


### that can be supported, and not potential savings 10


### or, you know, dollars

- a
- month or what

- have

- you. 11


### MR. RAMIREZ: So let me clarify it then 12


### with the subcommittee. That is what you're 13


### suggesting, correct? 14


### MR. LACEY: Yes. We parked the other 15


### issue for now, right? 16


### MR. RAMIREZ: On the energy label? 17


### MR. LACEY: The labeling. 18


### MR. RAMIREZ: Yeah, yeah, yeah. 19


### MR. LUBLINER: And since we put this in 20


### the parking lot, could I make a suggestion? 21


### Because I understand DOE has a labeling rating 22275

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### program already. And what I'm hearing from Rob 1



### is that the FTC has some concerns. And maybe I'm 2


### hearing this wrong. 3



### But I would recommend that whatever we 4


### do, we have liaison with the Federal Trades 5


### Commission to make sure that it's appropriate. 6


### And I'd make that recommendation to DOE legal 7



### counsel and to Joe. 8


### MR. LUTER: Michael, I believe you are 9


### hearing me correctly. It was a real head

10



### scratcher for us when we sat through a 11


### presentation telling us exactly what not to do. 12


### And we brought up the ENERGY STAR site, and they 13


### were doing the exact same thing that we were just 14



### told not to do. 15


### Now, maybe it's because we're 16


### fenestration people and not well liked; I don't 17



### know. 18


### (Laughter.) 19



### MR. LUTER: Sarcasm intended. 20



### MR. LUBLINER: I kind of attribute it to 21


### silos in Washington, D.C., to tell you the truth. 22276

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### MS. VAIDYANATHAN: This is Kavita 1


### Vaidyanathan, DOE legal counsel. 2


### We have some questions about labeling. 3



### A nd we do have some authority on labeling, but 4


### not all the authority. FTC does have authority 5


### over labeling. So we will be talking to them to 6


### see what authority we have for this type of 7


### labeling before we can move forward with it. 8


### MR. RAMIREZ: All right. Then, what was 9


### suggested by the subcommittee, I think there was 10


### one little amendment to that, is

-- does that 11


### work for the group here? There it is. 12


### All right. Let me see a show of thumbs 13


### for ones okay with that. 14



### (Pause.) 15


### MR. RAMIREZ: Yeah, M ark? 16



### MR. R OY: I can't believe it. He's got 17


### his thumb up. 18


### (Laughter.) 19


### MR. WEISS: Hey, hey! 20


### FEMALE VOICE: Can we take a picture of 21


### this, Mark? 22277

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### MR. WEISS: Aw, come on. I've had my 1


### thumb up, what, a t least 60 percent of the time. 2


### (Laughter.) 3



### MR. WEISS: Anyway, ju st a comment that I 4



### have to make . My thumbs up is subject to what I 5


### said last week, and I forget exactly how or what 6


### I said. But the gist of it was, the thumbs up is 7


### with respect to the recommendation subject to 8


### cost analysis, something along those lines

. 9


### MR. RAMIREZ: Okay. Thank you. 10


### So, any thumbs down on the phone? 11



### (Pause.) 12


### MR. RAMIREZ: Okay. Then that one has 13


### unanimous support. 14



### Next one? 15


### MR. SANTANA: Okay. The next one is on 16


### page R33, and it's a grouping of items. It 17


### encompasses 402.4 all the w ay through 402.4.4. 18


### And don't know if you want to, you know

-- we'll 19


### take them as they go. You might not be able to 20


### vote on the first one until we get through them 21



### all because one references some of the other 22278

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### ones. But we'll just go in order. 1


### On page R3 3 of your IECC, R402.4, Air 2


### Leakage. And this here, we suggested that it 3


### just go through as it is. You know, the only 4


### thing that it says is that your thermal envelope 5


### shall comply with other sanctions and that 6


### however you seal this cylinder, materials wi ll 7


### allow for differential expansion. And we didn't 8



### have an issue with that. 9


### MR. WEISS: Manny, it sounds like 10


### basically just an introduction to the sections 11


### that follow, right? 12


### MR. SANTANA: Right. 13


### MR. WEISS: And I have a question for 14


### Dave, or this goes

-- I hope it doesn't. But 15


### perhaps, does this go back to the argument we had 16


### previously? Is there any problem with the term 17


### "building thermal envelope" and then the 18


### definition, understand what that means? Because 19


### if you have a problem with that, then you 're 20


### going to have a problem , even if it's just an 21



### intro. 22279

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### MR. TOMPOS: Well, I don't think it's 1


### "thermal envelope" that we were having problems 2


### with. It's "pressure envelope." 3


### MR. WEISS: Okay. 4


### MR. TOMPOS: So I'm okay with this. 5



### MR. WEISS: Thanks. 6



### MR. TO MPOS: And we're just talking about 7



### 402.4? 8


### MALE VOICE: At this point. 9



### MR. TOMPOS: Or all the subsections? 10


### MR. SANTANA: 402.4, but we're going to 11


### get into all the subsections one at a time. 12


### MR. TOMPOS: Oh, one at a time? 13



### (Chorus of "Yeah.") 14



### MR. SANTANA: Yeah, so we might have to 15


### go through them all before we can come back and 16



### vote on 402.4 , because you might not be 17


### comfortable with what 402.1 through 402.4.4 18



### contain. 19


### MR. TOMPOS: Okay. 20


### MR. WEISS: But there's no controversy 21


### about what they mean by "bui lding thermal 22280

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### envelope"? 1



### MR. SANTANA: We'll define

-- it's 2


### defined in Chapter 2. 3


### MR. WEISS: Okay. Great. 4


### MR. RAMIREZ: Okay. So, any questions on 5



### that one? 6



### (Pause.) 7


### MR. RAMIREZ: We may later, but as of 8


### right now, everyone understand that? 9


### Okay. So, l et's go on with the next one. 10


### MR. SANTANA: Okay. The recommendation 11


### for 402.4.1 is the same. You know, we recommend 12


### that that one be adopted as is, didn't find 13


### anything wrong with it. 14



### (Pause.) 15


### MR. SANTANA: Okay. And that one also 16



### references other sect ions. So we want to keep 17



### that in mind. 18


### Now, 402.4.1.1, that deals with 19


### installation. The only thing we wanted to strike 20



### was the reference to the code official or 21



### ap proved third party, as that gets into, you 22281

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### know. Now, this references the table, which is 1



### down the line as well. But we didn't find 2


### anything else wrong with that. 3


### 402.4.1.2, that deals with testing of air 4


### leakage. And so we pondered on that one. 5


### Highlighted the entire section, and it says that 6



### it would

-- we deferred to the Emanuel proposal 7



### a nd all of the discussion that that is going to 8


### require. 9



### MR. TOMPOS: Didn't we vote? 10



### MR. LACEY: Yeah. 11


### MR. TOMPOS: We were going to have 12


### descriptives? So can we

-- we're basically 13


### striking all the testing, correct? 14



### MR. LACEY: Yeah. I think we can del ete 15


### this whole thing now, don't you? 16



### MR. SANTANA: Yeah. 17


### MR. WEISS: We're striking that? 18


### MALE VOICE: yeah. 19


### MR. SANTANA: So then, as we strike 20


### things, the sections that reference them are 21


### going to have to be updated. That goes without 22282

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### saying. 1


### Okay. So, 402.4.2 is F ireplaces. So you 2


### might want to change that. 3


### MR. RAMIREZ: I'm sorry. So one of the 4


### quick amendments is under 402.4.1, where it 5



### references 402.4.1.2. That could be deleted 6



### then? 7


### MR. SANTANA: Well, it will be updated, 8


### yeah. 9



### MR. BANTLE: Jus t strike that? 10



### MR. RAMIREZ: Yeah. 11


### MR. SANTANA: Okay. 12


### MR. RAMIREZ: Right? 13


### MR. SANTANA: Right. 14


### MR. RAMIREZ: Okay. 15


### MR. LACEY: It's probably just editorial 16



### stuff. 17


### MR. RAMIREZ: Okay. Yeah. Let's skip 18


### that then, yeah. 19


### All right. Go ahead. 20



### MR. SANTANA : Okay. 402.4.2, it's on the 21


### same page. And this one deals with the tight

- 22283

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### fitting doors or dampers on wood

- burning 1


### appliances, or wood

- burning fireplaces. And we 2


### struck the first part of it because the HUD code 3


### references the same thing. 4


### The only diffe rence between the HUD code 5


### and this section is the year of the standard. 6


### And I don't know if we want to get into the ins 7



### and outs of UO 127. I haven't read either. So I 8



### couldn't comment on it. 9


### The only section we retained was the one 10



### that's outside of t he HUD code, and it only 11


### affects fireplaces that you build out of masonry, 12


### which I don't know are a big segment of 13


### production. 14



### (Pause.) 15


### MR. ROY: Zero, right? 16


### MR. SANTANA: I think so. But if we do, 17


### then how do you put a door in there? 18


### (Laughter.) 19



### MR. WEI SS: We're checking on something. 20


### MR. RAMIREZ: Mark, yes. Sorry. 21


### MR. WEISS: We're checking on something. 22284

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### I might have a question. 1


### MR. RAMIREZ: Okay. 2


### MR. WEISS: I'm not sure yet. 3


### MR. RAMIREZ: Okay. 4


### MR. SANTANA: Okay. So then

-- 5



### MR. RAMIREZ: Hol d on a second. Just one 6



### second. 7


### MR. SANTANA: Okay. 8



### (Pause.) 9


### MR. SANTANA: Oh, by the way, so the 10


### language that's below that is an excerpt from the 11



### HUD code that will show what's

-- 12


### MR. RAMIREZ: Yeah, Mark. 13



### (Cross

- talk.) 14


### MR. WEISS: Manny, the term "ti ght

15


### fitting door , " I mean, is this language here in 16


### black, is that in the IECC? Or did you put that 17


### together? 18



### MR. SANTANA: That's verbatim out of the 19



### IECC. 20


### MR. WEISS: Okay. 21


### MR. SANTANA: Right. They use the strike 22285

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### underline format. 1


### MR. WEISS: Okay. 2



### M R. SANTANA: So anything struck is

-- 3


### well, anything underlined is added. 4


### MR. WEISS: Okay. That wasn't the 5


### question, but thanks. 6


### "Tight

- fitting doors," is that defined 7


### anywhere here? Or is it recognized as a term of 8



### art? 9


### MR. SANTANA: We got into that a little 10



### bit. 11


### MR. WEISS: Okay. 12


### MR. SANTANA: And, but to narrow the 13


### scope again , what we decided is that, since we 14


### didn't expect masonry fireplaces to be very much 15


### of an issue, we decided to just let it go. 16


### MR. WEISS: I'm sorry, Rick. Did you 17



### have somet hing? 18


### MR. MENDLEN: They don't use masonry 19


### fireplaces. 20



### MR. WEISS: We don't use them? 21



### MR. MENDLEN: Yeah. 22286

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### MR. WEISS: So why are we talking about 1



### them? 2



### (Cross

- talk.) 3



### MR. LUBLINER: If a client wanted to 4


### order and the manufacturers want to build it, 5


### it's go t to have a standard. 6


### MR. WEISS: I don't want to hold up 7


### progress in the world. But just make a note, I 8


### mean, "tight

- fitting doors," what does that mean? 9


### You know, again, you have to comply with this , on 10


### criminal penalty if you don't. And even if 11



### there 's two of them in the country. You know? 12


### So what's a tight

- fitting door? That's all. 13



### (Cross

- talk.) 14


### MR. SANTANA: You know, I guess

-- 15


### MR. ROY: It's something to be avoided, 16


### according to this. 17


### (Laughter.) 18


### MR. ROY: You only put in a tight

- fitting 19



### door on a masonry fireplace. 20



### (Cross

- talk.) 21


### MR. RAMIREZ: Hold on a second, folks. 22287

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### (Laughter.) 1


### MR. RAMIREZ: All right. So

-- 2



### MR. MENDLEN: It has to be listed and 3



### labeled. That's the answer. 4



### (Pause.) 5


### MR. RAMIREZ: All right. Move on? 6


### MR. ROY: You're sugges ting something, G, 7


### in place of what's there? 8


### MR. SANTANA: No, no, no, no. G was for 9



### reference. 10



### (Cross

- talk.) 11


### MR. ROY: It's already been covered. 12


### MR. SANTANA: Yeah, it's already covered. 13



### So this G is

-- so if you say, "I don't believe 14


### Manny. He's a li ar." So this is what the HUD 15



### code

-- 16


### MR. RAMIREZ: Mark, you know, I think 17


### that might be relevant. I don't know if that was 18


### quite clear before. But it's referencing the HUD 19


### code, and all Manny did was cut and paste it for 20


### our purposes just so that way we could see what 21



### does that reference. 22288

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### MR. SANTANA: Right. We're not adding 1


### anything. 2


### MR. RAMIREZ: So, the suggestion isn't to 3


### add that verbiage in there that's in the black. 4


### It's just referencing the HUD code. That is the 5



### HUD code reference that's in the document. 6


### MR. WEISS: I'm not sure we're saying the 7


### same thing. I mean, I understand that's part of 8


### the black sentence there, is part of the IECC. 9


### I'm just asking, is there a definition somewhere 10


### in the IECC or UO 907 of what a "tight

- fitting 11



### door" is so somebody doing this knows how to 12


### comport their conduct with the law? That's all. 13


### MR. SANTANA: We didn't find "tight

14


### fitting" in the IECC. 15


### MR. WEISS: Okay. 16



### MR. SANTANA: Don't know about the UO, 17


### though. 18


### MR. WEISS: Okay. I'll put it down. If 19



### I c an find it on the internet, I'll see what it 20


### says. 201, UO 907. 21


### MR. SANTANA: Okay. 402.4.3, on the same 22289

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### page, it's R33. This one deals with fenestration 1


### air leakage. And we kind of touched on this 2


### earlier today. And the suggestion is to strike 3



### the en tire section. And the reasoning is HUD has 4


### specific requirements that deal with the force 5


### required to open an egress window. 6


### And so, if you meet those requirements, 7


### you can only tighten it up to a certain level. 8


### So if you comply with 402.4.3 and tighten it up 9


### even further, you might no t comply with the 10


### egress end, but you're in the HUD code. 11



### (Pause.) 12


### MR. RAMIREZ: Okay. Next? 13


### MR. SANTANA: Okay. 402.4.4, we didn't 14



### resolve this one. And it's not bec ause it was so 15


### complex. It was we didn't reach a disc ussion on 16


### this one because there is a portion of the HUD 17


### code that deals with appliances in rooms, or 18


### rooms that contain reverberating appliances, and 19


### we just didn't have the time to do the research 20


### to find out how they compare. 21



### So we don't have a recommen dation, don't 22290

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### know if what's in the HUD code mirrors this, it's 1


### less than this, or exceeds this. I don't know 2


### how we could put a placeholder on it. But there 3



### is a chance that the requirements are parallel or 4


### overlap. And so, you know, DOE would have to 5


### compare them both, I think. 6


### MR. RAMIREZ: So you just need more time 7



### for that one? 8



### MR. SANTANA: Yeah. We needed more time 9



### for that one. Ran out of time. 10


### MR. RAMIREZ: Okay. 11



### MR. SANTANA: So that concludes this 12



### block of sections of related sections. 13



### MR. RAMIREZ: Okay. So, let me ask the 14


### group, are you okay with adopting these 15



### recommendations? 16



### (Pause.) 17


### MR. RAMIREZ: Again, in the context of 18


### seeing it all, similar to the way we were doing 19


### the other ones, right? 20


### So, let me see a show of thumbs if we're 21



### oka y with these recommendations. 22291

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### (Pause.) 1


### MR. RAMIREZ: Anyone on the phone, your 2



### thumbs down? 3


### All right. So that one's unanimous as 4


### well, or that block, rather. 5



### (Pause.) 6


### MR. SANTANA: Okay. So now we're on 7


### section R402.5, which is also on page R33. And 8



### th at deals with maximum fenestration U factors 9


### and solar heat gain coefficients. 10


### Are you going to explain this one, Eric? 11


### MR. LACEY: Yeah. I can explain this. 12



### This is a kind of a tradeoff count that 13


### applies when you use one of the tradeoff options 14



### in the I ECC. You built to the prescriptive path. 15


### You have to meet whatever the window requirements 16


### are that are specified. 17


### But if you use the UA tradeoff path of 18


### the performance path, you can trade the windows 19


### up a certain amount, but it kind of draws a hard 20



### lin e. It says, "Okay, you can't put in terrible 21


### windows. As much as you trade off, you can't go 22292

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### beyond these limits." 1


### And so, this is one area, you know, at 2


### least when we were looking through the code, I 3


### thought, you know, if there's an area where I 4



### think w e might be able to do a little better than 5


### the IECC, it would be in a tradeoff cap. Because 6



### based on what I saw from the fenestration 7


### offerings in the paper that Emanuel handed out, I 8


### think in most cases, you know, the manufacturers 9


### aren't going to bump u p against these caps. 10



### So what it s ays, basically, is that in 11



### the N orthern two HUD climate zones, climate zone 12


### 2 and 3, there is a cap on the amount of U factor 13


### tradeoff for the window. U factor, obviously, 14


### being the most important factor in those climate 15



### zones. 16


### If the base requirement is at 32, then 17



### the 40 is

-- still gives you quite a bit of 18


### tradeoff leeway there if you wanted to get the 19


### efficiency somewhere else still. 20



### And then in the Southern two climate 21


### zones, climate zones 1 and 2, where there would 22293

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### b e an SHGC requirement, you know, if the SHGC is 1


### a 25 or a 33 or whatever we land on that, you 2


### know, a 40 would be the outer limit for 3



### tradeoffs. 4


### And just to make sure, you know, the 5


### window, which is typically the weakest part of 6


### the law, isn't gobbling up tons of energy. So 7



### that's the idea here. 8


### And again, you know, we could play with 9


### the numbers a little bit. But I thought this is 10


### an area where I think you could do better than 11


### the IECC. The IECC's tradeoff caps are pretty 12



### loose. And I don't think this would really 13


### impact the manufacturer all that much. 14


### MR. RAMIREZ: Any questions? 15



### David? 16


### MR. TOMPOS: Are we basically saying that 17


### we're eliminating all the windows with a U value 18


### of 0.40 or higher? 19


### MR. LACEY: No. It's an area weighted 20


### average. And so, i f you put in a piece of 21


### decorative glass or something that, you know, is 22294

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### higher than that, then on average your windows 1



### would need to be a 40 or lower on U factor. 2



### MR. TOMPOS: But I wouldn't be able to 3


### put in vinyl framed clear dual glazing 4


### everywhere, be cause in here it says that the U 5



### value is 0.49. 6


### MR. LACEY: That particular window, yeah. 7


### You'd need to use something better than that. 8


### MR. TOMPOS: Okay. 9



### MR. LACEY: And in those two climate 10


### zones, that 's climate zone 2 and 3 of the 11



### n orthern part of the country. See, there 12


### currently isn't a cap on climate zone 1. So if 13


### you wanted to put in the

-- I wouldn't put them 14


### in, but if you put in the dual

- pane clear in 15


### climate zone 1, so there's two parts to this. 16


### There's the U factor cap and the SHGC cap. 17



### And the U factor cap doesn't apply to the 18


### southernmost climate zone. That's the way it is 19


### in the IECC. We could add that in there if you 20


### decided you wanted to have good windows in every 21


### climate zone, which I think would be a good idea. 22295

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### But for now, climate zone 1 doesn't have that U 1


### factor limitation on it, on tradeoffs. 2


### MR. SANTANA: So, you know, and again, 3



### this is a section

-- well, this is one of the 4


### sections where we accepted it in principle. So 5


### we accepted the concept, you know. There's 6



### should be a cap. We like the idea for there to 7


### be a cap on the windows so if you choose a 8


### performance cap, where you calculate your

-- say, 9


### your total U not for the house as a whole, you 10


### could have great insulation, horrible windows, 11


### and still pass, theoretically. 12



### So this puts a cap on that. And the 13


### suggestion is that we accept it in principle, we 14


### accept the concept. But the language, the 15


### values, the zones, you know, we don't know if 16


### we're going to end up with a UA path or not. It 17


### might just be a prescriptive path and a U not

-- 18



### we don't know. I mean, REScheck, we probably 19


### can't reference to REScheck. But, you know, 20


### conceptually, we thought it was a good idea. 21



### MR. RAMIREZ: Mark? 22296

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### MR. TOMPOS: I think what's co nfusing me 1


### is that you've got, this is SHGC saying UA 2



### RE Scheck or UO. Is that the right language? 3



### MR . LACEY: Yeah. The idea was, in the 4


### IECC, it applies to basically the UA path on the 5


### performance path. But I don't know if we're 6


### going to end up with a performance path or a UO 7


### or a REScheck option in the end

. 8


### So, all of those have, I think have or 9


### should have an SHGC requirement. And so that's 10



### kind of in there as a placeholder for, you know, 11



### this trade

- up cap, applies wherever you have a 12


### tradeoff option, you know? 13



### MR. UNGAR: But is there a tradeoff if 14


### you d o a UA or a UO option? Is SHGC traded off? 15


### I thought I was hearing those. 16


### MR. LACEY: In a straight

- up UA or UO, 17


### no. I think that that's what we been talking 18



### about. Even the UO would have an SHGC 19


### requirement. Whether you can trade that off, I 20



### don't kn ow. It will depend on what our final 21


### package looks like. 22297

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### (Cross

- talk.) 1


### MR. RAMIREZ: Let me get Mark, and then 2



### David. 3


### MR. UNGAR: All right. If there is a 4


### tradeoff, then we would expand it? 5



### MR. LACEY: Yeah. 6


### MR. UNGAR: Yeah. It might be this, or 7



### no nee d for it. 8


### MR. LACEY: We might not need it. 9


### MR. UNGAR: Okay. 10


### MR. RAMIREZ: Mark, then David. 11



### MR. WEISS: I don't know if it makes a 12


### question or just seemed to me like we have a lot 13


### here that's contingent. And maybe the thing to 14


### do with this is just tabl e it until we can get 15


### some other, further development in these issues. 16


### I don't know. Just, you're dependent on 17


### zones, you're dependent on, you know, what was 18


### the other thing? Anyway, dependent on a couple 19


### of things. 20



### MR. RAMIREZ: David? 21



### MR. TOMPOS: Well , I think zones really 22298

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### are the only one, and we can expand that later if 1


### we decide we're going to have multiple zones. 2


### Rob Luter, one of the windows 3


### manufacturers, was involved with this. And if he 4


### doesn't see a problem in supplying the industry, 5



### I have n o problem going above the IECC. 6


### MR. SANTANA: Well, he wasn't involved 7



### with this. 8


### MR. LACEY: Rob wasn't on this particular 9



### call. 10


### MR. SANTANA: Right. 11


### MR. TOMPOS: Well, then, maybe we need to 12


### ask that question. 13


### MR. LACEY: We generally got it, but

-- 14



### (Cr oss
- talk.) 15


### MR. LACEY: But I don't know what you 16



### think

-- 17


### MR. SANTANA: But if I can pull back a 18


### little bit, conceptually speaking, without 19


### worrying about the exact va lues and content, the 20



### concept, does that seem sound? 21


### MR. RAMIREZ: Does the concept? Th e 22299

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### question is, does the concept seem sound? 1



### (Pause.) 2



### (Cross

- talk.) 3



### MS. STARKEY: I'd like to know what Rob 4


### thinks, Rob Luter. 5


### MR. LUTER: Yeah. If I understand this, 6


### what you're saying is that in the event you 7


### choose to use tradeoffs, in this case, better 8


### insulation in exchange for lousy windows

-- even 9


### though I don't make any lousy windows

-- 10


### (Laughter.) 11



### MR. LU TER: We'll use that argument, that 12


### you won't be able to use any windows with a U 13


### value lousier than 0.40 in climate zone 2 through 14



### 3. And I'm fi ne with that. This real ly doesn't 15


### present any issues. 16


### I think that, if I recollect the values 17


### that we saw earlier, just going to a dual

18


### insulated window within a vinyl frame, even with 19


### clear glass, it's going to get us a little better 20


### than that. Perhaps not. Maybe it will take low

21


### E. But in those climate zones, it's probably 22300

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### justified. 1


### MR. RAMIREZ: So, either way, though, 2


### we're probably going to have to come back to this 3


### one because we have not yet identified the 4



### climate zones. 5


### MR. HAGERMAN: Yeah, but you can do

-- 6



### (Cross

- talk.) 7


### MALE VOICE: What would you suggest at 8


### that point, Javier? 9


### MR. HAGERMAN: Joe Hagerman, DOE. 10


### Even if we don't come up with, do we use 11


### the HUD climate zones or the other climate zones, 12


### they easily map. So let's go ahead and vo te on 13


### this, conceptually, and then start putting some 14


### values. I mean, it's very easy to disentangle 15


### the climate zone, whichever decision the group 16


### ultimately decides. 17


### MR. RAMIREZ: So is the group okay with 18



### this one? Let's see a show of thumbs. 19



### (Pause.) 20


### MR. RAMIREZ: Any thumbs down on the 21


### phone? 22301

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### All right. Then we have unanimous 1


### approval on that one. 2



### MR. SANTANA: Should we add that it's 3


### conceptual? 4



### MR. RAMIREZ: Yeah. 5


### MR. SANTANA: To your approval. 6



### MR. RAMIREZ: Yeah. 7


### MR. LACEY: Once we get the compl iance 8



### down. 9


### MR. SANTANA: Okay. Next item on the 10


### agenda is the table. 11


### MR. RAMIREZ: I'm sorry. We need 12


### compliance paths and zones. 13



### MR. SANTANA: And values. 14



### MR. RAMIREZ: And values. 15



### (Pause.) 16



### MR. RAMIREZ: But the formula is sound. 17


### MR. SANTANA: Right. 18



### M R. RAMIREZ: Okay. 19



### (Pause.) 20


### MR. SANTANA: So we're going to skip the 21



### table for n ow, just because I think we can double 22302

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### back and take care of some of the easier ones 1



### first. 2



### Section R40 3.1.2. That one's on page 3


### R35. And it is Heat Pump Supplementary Heat. 4



### (Pause.) 5


### MR. SANTANA: And you might want to open 6


### up the PDF. 7



### (Pause.) 8


### MR. SANTANA: Okay. We think this can go 9


### through as is. You know, we didn't have an issue 10



### with it. 11


### MR. RAMIREZ: Any discussion on that one? 12



### Mark? 13


### MR. WEISS: Is this representing th is in 14


### practice? 15


### MR. SANTANA: I don't know that it does, 16


### just because we don't purchase heat pumps, you 17


### know. Is this in practice? I don't know that it 18



### is. But I don't know that it's not. 19


### MR. LUBLINER: I could provide some 20


### feedback. So what the proble m is is that 21



### sometimes consumers will fiddle with their 22303

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### thermostats. And like it will be in setback 1


### mode, and then all of a sudden, in the morning it 2



### will kick in to

-- and instead of going into heat 3


### pump mode, it goes straight into electric 4



### resistance. So the heat pump is running like a 5



### furnace. 6


### So that's what it was about. So that, 7


### yeah, to answer your question, yes, it's pretty 8



### standard in site

- built that either the thermostat 9


### or the heat pump itself has a lock

- out that keeps 10


### it from operating above a certain

-- strip keeps 11


### it operating above a certain temperature. 12


### Except if there's emergency heat need or 13



### if there's defrost. And what we find is that 14


### that's an incredibly cost

- effective way of making 15


### your heat pump perform like a heat pump. Our 16


### utility programs can sanitize that, and our state 17


### code requires that lock

- out in our setup 18


### inspections in heat pumps. 19


### MR. WEISS: Okay. Yeah. And thank you. 20


### The question was, though, is it existing practice 21


### on HUD code homes at this point? I guess the 22304

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### answer is we don't know at this point. So. 1



### MR. SANTANA: Not sure. 2


### MR. HAGERMAN: I think if you buy any 3


### modern heat pump, with emergency supplemental 4


### heat, it's going to have that, unless you just 5


### cobbled it together yourself. 6


### (Laughter.) 7


### MR. RAMIREZ: All righ t. So let me see a 8


### show of thumbs if we're okay with that 9



### recommendation. 10



### (Pause.) 11


### MR. RAMIREZ: All right. Any thumbs down 12


### on the phone? 13


### All right. We have unanimous on that one 14



### as well. 15


### MR. SANTANA: Okay. Section 403.3.3, on 16


### page R35, we pondered on this one as well, 17


### because it deals with duct testing. And that was 18


### going to be a

-- we might have already handled 19


### that yesterday. But it was going to be dependent 20



### on , almost on the Emanuel proposal. 21


### So then the suggestion is to strike that 22305

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### and we'll fix it with whatever we come up with. 1


### MR. WEISS: Say again, Manny? I'm sorry. 2



### MR. SANTANA: That we deferred to the 3


### Emanuel proposal for that one. 4


### MR. RAMIREZ: Is everyone okay with that? 5



### Let me see a show of thumbs. 6



### (Pause.) 7


### MR. RAMIREZ: Okay. Any thu mbs down? 8



### (Pause.) 9


### MR. RAMIREZ: All right. Then that one's 10



### unanimous. And that's unanimous on the 11



### recommendation. 12


### All right. Next? 13


### MR. SANTANA: Next up, 403.5.1, also on 14


### page R35, and it comes over to R36 a little bit, 15


### but it's on your screen. It dea ls with heated 16


### water circulation and temperature maintenance 17


### systems. So, for those of you that are concerned 18


### whether you're getting cold water in the shower, 19


### this is for you. 20


### (Laughter.) 21



### MR. RAMIREZ: This is the David section? 22306

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### MR. SANTANA: Yeah. You w ant to

-- 1


### MR. TOMPOS: This is my proposal right 2



### here. 3


### (Laughter.) 4


### MR. SANTANA: So again, we didn't have an 5



### issue with it. We don't think that

-- well, I 6



### don't think that there's a lot of manufactured 7


### homes using this feature. And if they are, they 8



### sho uld probably adhere to this, you know. 9



### MR. RAMIREZ: Mark? 10


### MR. WEISS: The technical aspects of it 11


### are fine. But I'm just looking at this section, 12



### the line up from the bottom, it says, 13



### "T emperature sensors in the heat pump should be 14



### accessible." What doe s that mean? And I'm 15


### asking for a specific reason. 16


### MR. RAMIREZ: Do you want to state the 17


### reason? That might help apply to the context. 18



### MR. WEISS: Yeah. The reason is there is 19


### a whole separate area in standards and 20


### regulations of accessibility in terms of disabled 21


### persons. And sometimes, language like this is 22307

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### seized on to mean something it's not necessarily 1



### intended to mean. 2


### MR. RAMIREZ: Okay. Yes. 3



### MR. WEISS: I assume this means 4


### accessible for repair, consumer , whatever. 5


### MR. RAMIREZ: Yeah, accessib le for 6


### repair. Yeah. Yeah, you don't

-- 7


### MR. EZZO: Hey, Mark, this is Mark Ezzo. 8


### Yeah, there is an actually a definition 9


### in the IECC that says "accessible," and it says, 10


### "admitting close approach as a result of not 11


### being guarded by locked doors, elevati on, or 12



### other effective means." 13


### MR. WEISS: Okay. 14


### MR. EZZO: But I think what Manny is 15


### saying is right. It's just for

-- it's for 16


### repair. 17


### MR. WEISS: Okay. Okay, well, if there's 18


### a definition, I'll take a look at it and I'll get 19


### back to you on it. 20



### MR. RAM IREZ: Okay. As far as accepting 21



### the recommendation

-- 22308

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### MR. SANTANA: Well, we can't just accept 1



### it as is , because it encompasses the next two 2



### sections as well. 3


### MR. RAMIREZ: Okay. So let's hear the 4



### next two then. 5


### MR. SANTANA: Well, the next two, we 6



### did n't have any recommendations for those either 7


### other than to accept them as they were. So 8


### they're part of the same system, a system that 9


### isn't in great use. We didn't have a problem 10



### with it. 11


### MR. RAMIREZ: So, the recommendation is 12


### to accept as is 403.5.1, 403.5.1.1, and 13



### 403.5.1.2. 14



### MR. SANTANA: Correct. 15



### MR. RAMIREZ: Let me see a show of thumbs 16


### if the working group is okay with that 17



### recommendation. 18



### (Pause.) 19


### MR. RAMIREZ: Okay. Anyone with their 20


### thumbs down on the phone? 21



### (Pause.) 22309

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### MR. RAMIREZ: All right. Then that one 1



### is unanimous as well. 2


### MR. RAMIREZ: Okay. What else, Manny? 3


### MR. SANTANA: Okay. So now we're going 4


### to jump over to section R404.1.1. That's on page 5



### R37. 6



### (Pause.) 7



### MR. SANTANA: This has to do

-- this is 8


### Lighting Equipment. I guess I thoug ht it was 9


### just lighting equipment for a pilot light for, 10


### say, a water heater. But I guess it also applies 11


### to if you have gas lamps in your house, or gas 12


### lights in your house. You can't have a pilot 13


### light that burns all day long. You've got to 14



### have anoth er kind of ignition system. 15



### MR. ROY: Fortunate to keep the horse 16



### warm. 17


### (Laughter.) 18


### MR. SANTANA: Yeah. Exactly. 19


### MR. UNGAR: This is only for new homes. 20


### If you have any heat lights in this century in 21



### manufactured homes. 22310

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### MR. SANTANA: Then you're okay. Y ou're 1


### exempt. If you're a forward

- thinking individual 2


### with gas lights, this is what you have to do. 3



### (Cross

- talk.) 4


### MR. SANTANA: So anyway, yeah. We're 5


### proposing that it be adopted as is. 6


### MR. RAMIREZ: Okay. Questions? 7


### All right. Let's see a show of thu mbs if 8


### you're okay with that recommendation. 9



### (Pause.) 10


### MR. RAMIREZ: Anyone on the phone with 11


### your thumbs down? 12



### (Pause.) 13



### MR. RAMIREZ: And the steamroller is 14


### sparking up. I didn't see any thumbs down. So 15


### we're good. 16


### All right. Now what? 17



### MR. SANTANA: Oka y. So now I think the 18


### steamroller is going to come to a halt for a 19



### minute. 20


### (Laughter.) 21


### MR. SANTANA: We're going back to table 22311

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### 402.4.1.1. 1


### MR. RAMIREZ: Okay. 2



### MR. SANTANA: And this table is the air 3



### barrier and insulation installation table. And 4



### it has a lot of provisions to it. And the 5


### majority of the provisions are because we believe 6



### the element wasn't written with manufactured 7


### housing in mind, y ou know, because of the 8


### different construction practices. 9


### So the first one is, when you get to 10



### walls

-- and this again, it's in the strike and 11


### underline format. So anything that has a strike

12


### through is currently part of the IECC, and we're 13


### suggesting that it be removed. Anything that's 14


### underlined is an addition. So it's currently not 15


### part of the IECC. 16



### So look ing at walls, the first line is a 17



### strike

- through that reads, "The junction of the 18



### foundat ion sill plate shall be sealed." And the 19


### reason why we're suggesting that removed is 20



### because the

-- in manufactured housing, every 21


### manufactured house has a floor, whe reas this was 22312

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### written with the intention that your sill plate, 1


### or the first piece of wood that sits on the 2


### foundation of the slab, constitutes the bottom of 3



### a wall. 4


### So they seal that, whereas in 5


### manufactured housing, the interface you're 6



### concerned with is the bottom of the wall and the 7


### top of the floor. 8


### And the next line is for the top of the 9


### wall and the bottom of the ceiling. You know, 10


### there aren't any walls per se, and so then we 11


### added, "The junction of the bottom plate and the 12


### floor along the exterior walls shall be sealed" 13


### just because we wanted to capture what the 14


### junction of the foundation and the sill plate was 15


### trying to convey. 16



### So , in essence, we're requiring that the 17



### bottom of the wall where it meets the floor be 18


### sealed and the top of the wall whe re it meets the 19


### ceiling be sealed. 20


### MR. RAMIREZ: I hope that's the 21


### controversial part. 22313

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### MR. SANTANA: No. No, that's

-- 1



### MR. RAMIREZ: It doesn't sound too bad. 2


### (Laughter.) 3


### MR. SANTANA: I'm going to keep going 4


### unless somebody pipes up. 5


### MR. RAMIREZ: Okay. 6


### MR. WEISS: So that's existing practice? 7


### MR. SANTANA: No. No, it's not existing 8


### practice. I wouldn't say it's existing practice, 9


### because the HUD code currently says that you have 10


### all your joints designed to resist air 11


### infiltration. It doesn't say you have to seal 12



### them. 13


### MR. WEISS: Okay. So it's construction 14


### versus performance? 15



### MR. SANT ANA: Right. Performance. And 16



### so, say you could have a joint where you overlap 17


### the siding, and some people may say, "W ell, that 18



### restricts air infiltration. " But it's not 19



### sealed. 20


### MR. WEISS: Thank you. 21


### MR. RAMIREZ: Okay. 22314

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### MR. SANTANA: Okay. So, over to the 1


### right, "Cavities within the stud bay called by 2


### blocking "

-- you know, I'll read what the IECC 3



### first said. "Cavities within corners and headers 4



### a frame walls shal l be insulated by completely 5


### fitting the cavity with a material having a 6



### thermal resistance of R3." 7


### And the reason for that is, in stick

8


### built conventional construction, the corners have 9


### a lay

- flat, or they have a stud which is faced 10


### the other way so they can be fastened to the wall 11


### that runs on the other plane. So we call those 12


### lay

- flats in the industry. 13


### So what they're trying to get at is 14


### they're trying to make sure that where you have 15


### less depth than the entire stud bay, you fill 16


### that. Or to give you a nother scenario, where you 17



### have

-- in stick

- built construction, your headers 18


### may not have, they may not be the same depth or 19



### the same thickness as the wall. 20



### In conventional manufactured 21


### constructions, manufacturers add shims in between 22315

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### the headers to make the depth the same, or the 1


### thickness the same, whereas in stick

- built, you 2


### could have a gap. 3


### You know, so the recommended language 4


### here just makes it a little bit clearer as to 5


### what cavities we're talking about. So it reads, 6


### "Cavities within a stud bay ca used by blocking 7


### lay

- flats or headers of exterior walls shall be 8


### insulated by completely filling the cavity with 9



### a"

-- so it essentially gives you the same thing, 10


### only we believe it does it in a way where it's 11



### easier to understand. 12



### (Pause.) 13



### MR. SANTANA: A ll right. Moving on, the 14



### one underneath that

-- scroll up a little bit

-- 15


### read, "Exterior thermal envelope insulation for 16



### framed walls shall be installed in substantial 17


### contact in continuous alignment with the air 18



### barrier." And that's where we touched on that 19



### earlier. 20


### The subcommittee thought it was a good 21


### idea to strike that, because most two

- by

-- well, 22316

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### most stud bays are filled with insulation anyway. 1



### And the whole substantial contact with continuous 2


### alignment of the air barrier, you know, as we all 3



### h eard earlier today, some people say the air 4


### barrier's on the outside, air barrier's on the 5



### inside. 6


### You know, we didn't see the benefit to 7



### a dding to that confusion. And I don't want to 8


### speak for anybody. 9


### Go ahead, Mike. 10


### MR. LUBLINER: I just want to make i t 11


### clear, because I have seen two

- by

- six walls in 12


### the Northwest starting to show up with R11 in the 13


### walls. Do you

-- and I don't personally believe 14


### that the FTC reading is valid for that, when you 15


### have a big air gap like that, particularly if 16


### you're not ca ulking things that we said, you 17


### know, to caulk, depending on the air barrier. 18


### So, my question would be, if we eliminate 19


### this, are we allowing a manufacturer to continue 20



### to do that? Build a two

- by

- six wall and put R11 21


### in it so that there's a big gap in the wall, so 22317

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### that you don't have

-- you haven't filled it? 1


### I don't know if it applies here, but I 2


### thought it may. And so I wanted to ask you for 3


### your kind of clarification. 4


### MR. SANTANA: I think that you could have 5


### that in a scenario where you have a two

- by

- six 6



### wall with R11. 7


### MR. LUBLINER: You know, do n't ask me why 8


### they do it, Mark. 9


### (Laughter.) 10


### MR. WEISS: Why would anybody do that? 11


### MR. LUBLINER: They're doing it. 12


### MR. SANTANA: You know, you've got 13


### requirements to seal penetrations, you know, in 14



### the air ba rrier that it had before. 15


### MR. LUBLINER: So, I guess my concern is 16


### that I don't think that's a very cost

- effective 17


### thing to do. If you're going to frame out the 18


### wall, you might as well fill it. And I want to 19


### make sure that excluding this doesn't continue to 20


### allow that to happen. 21



### MR. LACEY: I'm not sure that this 22318

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### specific requirement would fix that scenario. 1


### But maybe we can have something in there if you 2


### think that's important to fill the cavity. This 3


### one, I think, just addresses the issue

-- 4



### MR. LUBL INER: At least the walls. Have 5


### you seen any of that in preapproved? 6



### MR. TOMPOS: I have not seen that. If 7


### they do the six

- inch wall, th ey're putting in at 8



### least an R19

. 9



### (Cross

- talk.) 10


### MR. LUBLINER: I mean, I was really 11


### surprised when I saw it show up in Idaho. 12


### MR. TOMPOS: I mean, the question again 13


### comes to, where's the air barrier? 14



### MR. WE ISS: Large fries at McDonald's; is 15



### this size back? 16


### (Laughter.) 17


### MR. LUBLINER: Right. I just say hello 18


### to MoneyBites. I f you still meet the minimum UO. 19



### MR. RAMIREZ: So, how would that have to 20



### be modified in order to take care of that? 21


### MR. LUBLINER: If you leave it in

-- 22319

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### MR. RAMIREZ: David? 1



### MR. TOMPOS: I think with the additional 2


### R values that we're going to require, I don't 3


### think they're going to be able to do it

. 4


### MR. RAMIREZ: Okay. 5


### MR. TOMPOS: I mean, I guess you could 6


### have a situation in the South where you'd have a 7



### six

- inch wall and still put in an R11. I just, I 8


### don't know why anybody would do that. 9


### MR. HAGERMAN: It says up there right 10


### now, "Walls shall b e insulated by completely 11


### filling the cavity." 12


### MR. SANTANA: Right. But these are 13


### cavities caused by blocking or headers or 14


### something else, corners. It isn't saying all 15



### cavities. 16


### MR. HAGERMAN: Why don't we just repeat 17


### that? Why don't we just say "All c avities shall 18


### be insulated completely"? "Cavities within a 19


### stud bay," blah

- blah

- blah. 20


### MR. SANTANA: You know, and they can 21



### occur
-- okay, if you're in the South or you're 22320

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### in a high

- winds area, you could

-- you know, that 1


### may necessitate two

- by

- six framing , right? But 2


### not necessarily necessitate anything greater than 3



### R11 insulation. 4


### You know, so the question is, do we want 5



### to have R19 insulation be mandated even if the 6


### climate zone doesn't require it? 7


### MR. LUBLINER: So you're saying that 8


### people will build the two

- by

- six wall in Southern 9



### zones where there's

-- because they get better 10


### structural integrity out of the wall? 11



### MR. SANTANA: Yeah. Because of the wind 12



### zone. 13


### MR. LUBLINER: Okay. That's good to 14



### note. 15


### My feeling is if you built the two

- by

- six 16


### wall, a s long as the WUfi model shows it's 17


### acceptable in the hot, humid climates

-- because 18


### what I would want to do is make sure that hot, 19


### humid air can't get into that gap and get right 20


### behind the vinyl drywall and condense when the 21



### air conditioner is on. 22321

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### MR. SA NTANA: You know, the problem that 1


### I have with substantial contact and continuously 2


### with the air barrier is, how do you

-- you know, 3



### these things are going to go down the road 4


### hundreds of miles, right, through bumps and wind 5


### and, you know, who

- knows

- what e lse. 6


### So, how do you then prove that the thing 7



### is in substantial contact when it arrives? If 8


### somebody opens up a hole in the wall to see if 9


### that's in substantial contact after going 1,000 10


### miles and it isn't, what happens? 11


### You know, and so taking that into 12


### consideration, how important is it to have 13



### substantial contact with it continuously ? 14



### MR. LUBLINER: I think the ENERGY STAR 15


### program requires it. But I mean, like I said, if 16


### it's a moisture reason and it's hot, then I was 17


### responding to your point. And it' s interesting 18


### to note that, you know, there's actually 19


### structural benefit in the high

- wind zones. 20


### MR. SANTANA: Yeah. And the thing to 21


### state my concerns in a more general fashion is, I 22322

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### am generally against having requirements that you 1


### can't verify or that it's hard to

-- you know, 2


### it's going to be hard to verify and prove that 3


### it's so. It's going to be a perpetual issue. 4


### You can't prove that it's in a substantial 5



### contact. 6


### MR. LUBLINER: Yeah. Generally, what we 7



### do is a blower test with an infrared scan. And 8


### it would show up if it's a question. Now, open 9


### up the cavity and see if it's true. 10


### MR. SANTANA: See, I don't want to do 11



### that. 12


### (Laughter.) 13



### MR. RAMIREZ: David? 14


### MR. TOMPOS: Manny, you talked about the 15


### cost, reducing the SKU numbers in a manufacturin g 16


### plant. 17


### Wouldn't you

-- typically you're going to 18



### be

-- well, maybe all of the homes that y ou build 19



### are, I would assume that you've got some two

- by

20



### fours and two

- by

- sixes. Are you going to have to 21


### all go to two

- by

- sixes and then put in R21 in all 22323

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### of the walls? 1


### I don't see the advantage. I guess what 2


### I'm saying is, why wouldn't we want to fill the 3


### cavity? Can't you just put less insulation in 4


### the roof cavity? 5



### MR. SANTANA: You could. 6


### MR. TOMPOS: So it may solve some 7


### transportation problems. 8



### MR. SANTANA: I mean, so that's a good 9


### question to ask. You know, on the one hand, 10


### somebody could comply with R11 in the walls. You 11


### know, the two

- by

- sixes is required by another 12


### unrelated issue, right? 13


### So what we're asking is if, do they have 14


### to fill the cavity just to maintain the 15


### substantial contact? You know, what is the 16


### benefit versus the cost? I'm not saying

-- I 17


### know manufacturers do. So the question is, do we 18


### have enough reasons to tell them they can't do 19


### that anymore? You know, if the unit

-- 20



### MR. EZZO: Hey, Manny, it's Mark. 21



### MR. SANTANA: Yeah. 22324

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### MR. EZZO: Would it be better to say 1


### "Exterior thermal envelope insulation shall 2


### completely fill the cavity," period? And forget 3


### about mentioning "substantial contact"? 4


### MR. SANTANA: You could say that. You 5



### coul d say that. But then you're still

-- you 6


### know, as long as we recognize that we're going to 7


### be requiring R19 in anything built with two

- by

8


### six walls. And as long as that's what we 9


### understand we're doing

-- 10


### MR. HAGERMAN: As long as the 11



### manufacturers take that into account when they do 12


### their UO calculation, right? 13



### MR. SANTANA: Yeah. 14



### MR. LACEY: Get credit for it. 15


### MR. HAGERMAN: And they'll get credit for 16


### it, so you won't have to put it so much

-- I 17


### mean, the end cost to the consumer is probably a 18



### wash. 19



### MR . SANTANA: How do you mean that? 20


### MR. HAGERMAN: Meaning because you could 21


### reduce the insulation that's in the ceiling, 22325

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### right? 1


### MR. SANTANA: Oh, okay. 2


### MR. HAGERMAN: I mean, net out, you're 3


### not buying more insulation because of that 4


### requirement, right? 5



### MR. SANTANA: Maybe. Maybe not. 6


### MR. RAMIREZ: Mark, can you repeat the 7


### change there? 8



### MR. EZZO: Yeah. Where the red font has 9



### all the strike

- through where it starts to say, 10


### "Exterior thermal envelope insulation for framed 11



### walls"? 12



### MR. RAMIREZ: Yeah. 13



### MR. EZZO : Take out "in substantial 14


### contact and continuous alignment with the air 15


### barrier," and insert

-- let's see, "Exterior 16


### thermal envelope insulation for framed walls 17


### shall completely fill the cavity." 18


### MR. SANTANA: You know, wouldn't it be 19



### easier

-- this is Manny with Cavco. 20


### Wouldn't it be easier to just eliminate 21


### all of that and say, "Exterior walls shall have 22326

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### the cavities filled with insulation"? 1



### MR. HAGERMAN: No. " Shall completely 2


### fill the cavity. " 3


### MR. SANTANA: I mean, why? We're worried 4



### about the bloc ks and the lay

- flats and the 5



### headers. 6



### MR. LACEY: I do think there

-- if I 7


### could throw something in there. The reason why 8


### this language was added was because it wasn't 9


### getting filled. They were filling the cavity, 10



### but not the header. 11


### And so, would it be okay to add

-- you 12


### know, to leave that language that you've got in 13



### the bottom there. I think that covers most of 14


### it. But to say, "including within stud bays 15


### caused by blocking lay

- flats or headers," or 16


### something like that? Or including

-- just so 17



### that t hose sections are not being left out. 18


### Because that was a problem. Everybody 19


### understood that the stud cavity needed to be 20


### filled. Nobody understood that it included that 21


### little section at the top. 22327

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### MR. SANTANA: So then, you do that and 1


### then strike everyth ing above it? 2


### MR. LACEY: Right. Yes. 3



### MR. RAMIREZ: Mark? 4


### MR. WEISS: This is for Eric. And I hope 5


### I'm framing this right. 6


### Don't other provisions of the IECC 7


### already address what you have to put in the 8


### exterior walls or framing walls? 9



### MR. LACEY: There a re requirements for 10


### how much insulation you put in, generally. 11


### MR. WEISS: Right. 12


### MR. LACEY: But if you get in a tradeoff 13


### scenario, you may not be filling that whole 14


### cavity, and then you run into other issues. So 15


### this just says

-- 16



### MR. WEISS: Does that undermine the 17



### tradeoff? 18



### MR. LACEY: What's that? 19



### MR. WEISS: Does this undermine the 20


### tradeoff in some way? 21



### MR. LACEY: No. 22328

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### MR. TOMPOS: No. You can take

-- 1


### MR. LACEY: Because you get full credit 2



### for whatever is in the wall. 3



### MR. SANTANA: It will undermi ne the 4


### tradeoff with walls, because now you can't trade 5



### off the walls. You have to fill it to capacity

. 6


### MR. WEISS: So, isn't that a problem? 7


### MR. LACEY: If your wall is already 8


### required to be six inches thick for requirements 9


### outside the energy code, y ou 're kind of stuck 10



### with that. 11


### And I think what we're saying here is, if 12


### it's already going to be that much thicker, fill 13


### that with insulation. And then you can take the 14



### insulation from somewhere else. You don't have 15


### to put as much in in the attic, for exa mple. 16


### So I tend to agree that it's probably a 17



### net wash to the consumer. 18


### MR. HAGERMAN: But this is good building 19



### science. 20


### MR. KESSLER: This is Bert, Palm Harbor. 21



### MR. RAMIREZ: Yes. 22329

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### MR. KESSLER: Have you guys thought about 1


### if somebody, if a manufacturer decided to use 2


### spray foam? Now we're making

-- we're forcing 3


### the manufacturer to completely fill that cavity 4


### with spray foam? 5


### MS. DICKENS: Good point. No. 6



### (Chorus of "No.") 7



### MR. KESSLER: I don't think that was the 8


### intent. I think the way this was writt en 9


### originally, as Manny had it, was just fine. And 10


### keep in mind, too, that the requirements for that 11



### insulation to be in substantial contact with the 12


### air barrier is to prevent air movement or air 13


### flow. So, that's why that's there. 14


### If you keep an air spac e between the air 15


### barrier and the insulation, and the insulation is 16


### air permeable, you get air flow. And that's what 17


### you're trying to prevent by keeping it in 18



### substantial contact with the air barrier. 19



### MR. RAMIREZ: David? 20


### MR. TOMPOS: Okay. Bert is makin g a 21


### really good point. Can we say something about 22330

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### the type of insulation? Because I think it's bad 1


### building practice to not fill it if we're using a 2



### batt or a type of insulation that will allow 3



### convection of the air in there. 4


### So, but he's right. If we u se a closed 5


### cell foam, we shouldn't have to do this. 6


### MR. RAMIREZ: So do we need a separate 7



### line for foam insulation? 8


### MR. LUBLINER: Just do an exception for 9



### closed

- cell foam. 10



### Is it closed

- cell foam, or are there 11



### other

-- are you talking about just closed

- cell, 12



### Bert? 13


### MR. KESSLER: No. I'm talking about any 14



### foam. 15


### MR. LUBLINER: So, let's just say 16


### exception for foam. 17


### MR. WEISS: Why don't we just go back to 18



### what we had? 19



### MR. KESSLER: I don't think we need to 20


### have an exception. Why can't I

-- and the reason 21


### for using some two

- by

- six construction with R11 22331

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### and R13 insulation is because the green building 1


### is getting more and more popular. 2


### Manny mentioned the fact that in high

3


### wind areas you might be able to get by with two

4


### by

- sixes at 24 on center, versus the, y ou know, 5


### 16. Or, you know, even double two

- by

- fours, 6


### which some people are doing. And you should not 7


### be limited by the code to not be able to do that. 8


### MS. DICKENS: That's a good point. 9



### MR. KESSLER: Install the insulation 10


### correctly, and as it's supposed to, and there's 11


### no problem. 12


### MR. LUBLINER: I wouldn't disagree with 13


### being

-- I don't want to

-- my recommendation was 14



### focused on non

- foam insulation products. I 15


### totally agree. If there's

-- I don't want to 16


### limit your ability to put foam in there if it's 17


### going to provide the listed R value. 18


### No, I think that's good. And that's why 19


### I proposed the exception. But I'm not 20



### comfortable with a two

- by

- six wall where there's 21


### five of us in there, if the testing for that R 22332

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### value has been based on a two

- by

- four wall

. 1


### Maybe we should just get some 2



### clarification from the FTC or the manufacturers 3



### of the batt insulation as to whether they accept 4


### stating that R values are

-- to get some clarity 5


### as to whether they feel that their R value 6


### represented is consistent when it's in a two

- by

7


### six cavity with a two

- inch gap. 8


### And if they say that's okay, then I'm 9


### okay with it. But I know that when I do infrared 10


### scans, you can tell it's an R11 wall. 11


### MR. HAGERMAN: This is Joe Hagerman, DOE. 12



### MR. LUBLINER: And this is a minor 13



### detail. 14



### MR. HAGERMAN: It is a minor detail. But 15


### what is wrong with just having the exception for 16


### spray foam insu lations? Seems like that 17



### addresses the concern and then

-- 18



### (Cross

- talk.) 19


### MR. LACEY: Can you just say what the 20


### exception

-- 21



### MR. SANTANA: What if s omething new comes 22333

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### up? 1


### MR. HAGERMAN: Yeah. Exactly. 2



### MR. SANTANA: Foam

-- I don't know. 3


### MR. LACEY: Could you just say instead, 4


### at the beginning of the suggestion, "air 5


### permeable exterior thermal envelope insulation"? 6



### MR. HAGERMAN: You can do that. 7



### MR. LACEY: I'd be concerned with adding 8


### in a word like "exception." What are you 9


### excepting them from? 10


### MR. SANTANA: Okay. 11



### MR. LUBLINER: That's fine. That's fine. 12



### That's fine. 13


### Fiberglass batts , or
-- 14


### MR. LACEY: It's not everything. 15


### MR. LUBLINER: Air pe rmeable, that's 16



### fine. 17



### (Pause.) 18


### MR. LUBLINER: You know, this is a small 19


### percentage of the homes. So maybe we need to 20


### move on on this one and do the investigation with 21



### the window

-- I mean, with the insulation 22334

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### manufacture r s? 1



### (Cross

- talk.) 2



### MR. RAMIREZ: Ma rk. 3


### MR. WEISS: Just again, I'm more 4


### comfortable with the original suggestion from the 5


### committee. Anytime you put an exception into a 6


### regulation or something, again it becomes an 7


### invitation for problems. 8


### And the more narrow you make that 9


### exception, as Man ny just said, the more you're 10


### limiting that technological advancement and, you 11


### know, different methods that could satisfy the 12


### requirement and potentially lower costs. It 13



### constrains innovation. 14


### MR. RAMIREZ: I think the suggestion that 15


### Eric just had addres ses those concerns you just 16


### brought up by saying that "air permeable exterior 17


### thermal envelope," right? 18


### MR. LACEY: That's right. 19


### MR. WEISS: To me, that sounded narrower. 20


### But that could be right. 21


### MS. DICKENS: So, I just came up wit h a 22335

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### phrase that connec t the two so we don't have to 1


### choose one or the other. So, at the end of the 2



### first

-- the black, three per inch minimum, just 3


### say, "bearing in mind that air permeable exterior 4


### thermal envelope insulation for framed walls 5


### shall completely fill the cavity." So you can 6


### just connect them both, and we can have the whole 7



### combined sentence. 8


### Does that work for people? 9



### MR. WEISS: No. 10



### (Cross

- talk.) 11


### MR. KESSLER: This is Bert. I just

-- 12



### I'm Bert. 13



### MR. RAMIREZ: Who is on the line? 14



### MR. KESSLER: Bert. 15


### Yeah, I was ju st going to mention the 16


### fact that when the insulation is air permeable, 17


### it doesn't matter whether it's filling the cavity 18


### or not. If you're putting something on the 19


### exterior surface that's also air permeable, then 20


### in fact it would probably be better if yo u did 21


### have a bit of air space. 22336

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### But again, I think we need to look at the 1


### thermodynamics and see what happens when we do 2



### this. And as far as the R value is concerned 3


### that is certified, we all calculate the U for the 4


### framing members separately. But whether it's 5


### full depth of the framing or not, the R value is 6


### not affected by it. 7


### MR. RAMIREZ: All right. So, what do you 8


### all want to do? Do you want to gauge the level 9


### of consensus on that suggestion there and see 10



### where we're at as far as consensus or not? 11



### Le t's try that. The part that's 12


### highlighted, and you need to move it a little. 13


### There you go. Give you a second to read that, 14



### and then I'm going to ask for where you're at. 15



### (Pause.) 16


### MR. RAMIREZ: Okay. Are you okay with 17


### that verbiage? Let's see a show of thumbs. 18



### (Pause.) 19


### MR. RAMIREZ: Okay. And then anyone on 20



### line thumbs down? 21



### MR. KESSLER: A no vote for me. This is 22337

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### Bert. 1


### MR. RAMIREZ: Okay. Then, we'll note 2



### that Bert was a no. And then the rest of the 3


### committee was okay. And okay, either thumbs up 4



### o r sideways, right? 5



### (Pause.) 6


### MR. SANTANA: So, all the stuff above 7


### that is kaput, right? 8


### MR. RAMIREZ: Correct. It's just the 9


### part that was shaded. That's the way I 10



### understand that. 11


### So, we'll strike that right now. 12



### (Pause.) 13


### MR. RAMIREZ: Okay. 14



### MR. SANTAN A: Okay. Should we vote on 15


### the other part of the wall section? 16



### MR. RAMIREZ: On the air barrier 17



### criteria? 18



### MR. SANTANA: Yeah. 19


### MR. RAMIREZ: All right. So, left of 20


### what we just approved, how does that look to 21


### everyone? Is everyone okay with that? Let m e 22338

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### see a show of thumbs if you're okay with that 1



### part. 2



### (Pause.) 3


### MR. RAMIREZ: Okay. Michael, I saw your 4


### thumb down. Do you want to comment on that? 5


### MR. LUBLINER: No. I guess I'm okay with 6


### that. I'm going to do one of these. 7



### MR. RAMIREZ: Sideways . Oka y. 8


### Is anyone on the phone thumbs down on 9



### that section? 10



### (Pause.) 11


### MR. RAMIREZ: All right. Then that one 12



### is unanimous. 13


### And I thought we were going to go through 14


### all of these, and I think we are. But I don't 15


### think we talked about the first two general 16


### requi rement s. 17


### MR. SANTANA: Okay. Right. We didn't 18


### have any changes to the first two. 19


### MR. RAMIREZ: All right. So, are those 20


### okay to keep as is then? Let me see a show of 21


### thumbs if you're okay with keeping those as is. 22339

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### (Pause.) 1


### MR. RAMIREZ: Joe, you have a question ? 2


### MR. HAGERMAN: I just have a question. 3


### Do you have somewhere in here that the

-- and 4


### this could be completely obvious, that the 5


### insulation has to be installed per the insulation 6



### manufacturer's recommendations? 7



### MR. LUBLINER: I think HUD code r equires 8



### that. 9


### Does it, Rick? 10



### MR. MENDLEN: Um

- hm. I don't think 11


### there's anything specific about that. 12


### MR. RAMIREZ: I'm sorry? 13



### MR. MENDLEN: I don't think there 's 14


### anything specific about that below a 12. 15


### (Inaudible conversation.) 16


### MR. SANTANA: Well, all m anufacturers 17


### usually have it. I mean, in general, the HUD 18


### code requires all manufacturers' insulation 19



### instructions to be

-- 20


### MALE VOICE: Exactly. 21



### MR. HAGERMAN: Because I think that some 22340

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### of these issues are going to be taken care of by 1



### the insulation ins tallation instructions. 2



### MR. SANTANA: Yes. 3


### MR. LACEY: And we actually approved that 4


### language earlier today at R402.4.1.1. It says , 5



### "T he components of the building or model shall be 6


### installed according to the manufacturer's 7



### instructions and this criteria

. " 8



### MR. HAGERMAN: And this criteria. 9



### MR. LACEY: Yeah. 10


### MR. HAGERMAN: All right. Thank you. 11


### Sorry. I must have missed that one. 12


### MR. RAMIREZ: You approved it; don't 13


### worry about it. 14


### MR. LUBLINER: It's a very important 15



### issue. 16


### MR. RAMIREZ: All right. So then, was 17


### there anyone on the phone that was objectionable 18


### to those first two as far as general requireme nts 19


### in ceiling

- slash

- attic? 20



### (Pause.) 21


### MR. RAMIREZ: Okay. Then those two are 22341

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### unanimously as is. 1


### All right. So, and then I see windows, 2


### skylights, and doors, and rim joists. Those are 3



### as is as well? 4


### MR. SANTANA: Right. We have made them 5


### trilogies. 6


### MR. RAMIREZ: Any questions or concerns 7



### with that one? 8



### (Pause.) 9


### MR. RAMIREZ: All right. Let me see a 10


### show of thumbs if we're okay with keeping those 11



### as i s. 12



### (Pause.) 13


### MR. RAMIREZ: Any objections on the 14


### phone? 15



### (Pause.) 16


### MR. RAMIREZ: Okay. Those are good. 17


### All right. This one would take some 18


### explaining, on floors. 19


### MR. SANTANA: Okay. On floors, yes. So, 20


### floors, the component includes including above 21



### garage and cantilevered floors. And so we just 22342

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### struck that because this applies to all floor 1



### models. 2


### I don't know if you want to vote on that 3



### or not. 4


### MR. RAMIREZ: Yeah. Any questions on 5



### that one? 6



### (Pause.) 7



### MR. RAMIREZ: Let me see a show of thumbs 8


### if you're ok ay with the recommendation. 9



### (Pause.) 10


### MR. RAMIREZ: Any thumbs down on the 11


### phone? 12



### (Pause.) 13


### MR. RAMIREZ: All right. That's 14



### unanimous as well. 15


### MR. SANTANA: You know, and I'd like to 16


### skip floors for now, because other ones are easy. 17


### (Laughter.) 18



### MR. SANTANA: If you don't mind. So I 19


### can go down to crawl space walls. 20


### Crawl space walls, we struck the whole 21


### thing because they don't apply to

-- you know, 22343

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### it's outside the scope of manufactured homes 1


### construction. We just struck the entire line, 2



### the entire row. 3


### Do you want to have a vote on that? 4


### MR. RAMIREZ: For crawl space walls? 5



### MR. SANTANA: Yeah. 6



### MR. RAMIREZ: Let's see s show of thumbs 7


### if you're okay with the elimination of that one. 8



### (Pause.) 9


### MR. RAMIREZ: Okay. Anyone on the phone 10


### objectionable? 11


### Okay. T hat one's unanimous. 12


### MR. SANTANA: Okay. Shafts and 13


### penetrations. The air barrier criteria. It 14


### originally read, "Duct shafts, utility 15


### penetrations, and flue shafts opening to exterior 16


### or unconditioned space shall be sealed." And we 17


### thought it was easie r to just say, "Duct shafts, 18


### utility penetrations, and flue shafts that 19


### penetrate the air barrier shall be sealed." 20



### And I think that's consistent with what 21


### we said earlier today about sealing penetration. 22344

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### MR. RAMIREZ: Mark? 1


### MR. WEISS: Is that current pra ctice, 2


### Manny, or is that something that is new here? 3


### MR. SANTANA: It's new. It would be new, 4


### yeah. 5


### MR. RAMIREZ: All right. Let's see a 6


### show of thumbs if you're okay with the 7



### recommendation. 8



### (Pause.) 9


### MR. HAGERMAN: Joe Hagerman, DOE. 10


### It's new, but we do take into account in 11


### the life cycle costs per our earlier discussions. 12


### MR. SANTANA: Yeah, we're considering it. 13


### Yeah, it's in the costs, yeah. 14


### MR. RAMIREZ: Okay. And then, anyone on 15


### the phone with a thumbs down? 16



### (Pause.) 17


### MR. RAMIREZ: Okay. That's un animous as 18



### well. 19


### MR. SANTANA: Okay. The following items, 20


### narrow cavities, we didn't have any issues with 21



### it. 22345

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### MR. RAMIREZ: So, as is? 1



### MR. SANTANA: As is. 2


### MR. RAMIREZ: I'll give folks a second to 3



### take a look at that. 4



### (Pause.) 5



### MR. RAMIREZ: Yeah? 6



### MR. TOM POS: Question. Manny, help me. 7


### Is that saying

-- let's say we have a panel box 8



### on the exterior wall

-- that we don't need to 9


### meet the full depth of insulation? 10


### Okay. I have what's covered in the HUD 11



### code under thermal shorts. 12


### MR. SANTANA: Okay. I thi nk that would, 13


### that's for if you have an offset stud in a wall, 14


### you have, say, maybe a six

- inch cavity, you can't 15


### get your batting to stuff it in there. You know? 16


### You can't just fold it over and stuff it in there 17


### however you want. You have to cut it to f it the 18


### width and place it. 19



### (Pause.) 20


### MR. SANTANA: Correct me if I'm wrong, 21


### anybody. 22346

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### MR. LACEY: Yeah. 1


### MR. HAGERMAN: Joe Hagerman, DOE. 2


### If it would help, maybe you say "narrow 3



### width cavities." 4


### MR. TOMPOS: No, that's fine. I can live 5



### with that. 6



### MR. SANTAN A: It's a little repetitive. 7


### MR. HAGERMAN: Right. Yes. 8


### MR. SANTANA: Because you go up to the 9


### wall section where it says you need to fill 10


### everything. 11


### MR. HAGERMAN: Right. 12


### MR. SANTANA: You know, this one just 13


### gives you more

-- you know, it's a little 14


### repetitive. 15


### MR. TOMPOS: It's repetitive. It says I 16


### can't shove it in there; I've got to cut it. 17



### MR. SANTANA: You 've got to cut it. 18


### MR. TOMPOS: So I don't have any gaps in 19



### there. 20


### MR. HAGERMAN: You weren't doing that 21


### anyway, though, right? 22347

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### MR. TOMPOS: No. We cut everything. It 1


### fits perfectly. 2


### (Laughter.) 3



### MR. RAMIREZ: Mark. 4


### MR. WEISS: Manny or somebody, give me a 5


### read on what "readily conforms" means. 6


### MR. TOMPOS: Yeah, that held me up, too. 7


### That's strange language. 8


### MR. SANTANA: Okay. The way that I 9


### understand it is, you know, okay, so everybody

-- 10


### "Batting in narrow cavities shall be cut to fit, 11


### or narrow cavities shall be filled by insulation 12


### that, on installation, readily confirms to the 13


### available cavity space." 14


### You know, so you either cut the batt to 15


### fit it, or if say you don't have a batt, you're 16


### going in your wall, by the time it's installed 17


### it's going to conform to the space. You know? 18


### If you're using blown or foam. 19


### MR. HAGERMAN: You could say "readily 20


### fills the available cavity space." 21



### M R. SANTANA: Yeah. 22348

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### MR. WEISS: You don't want stuff hanging 1



### out. 2



### (Cross

- talk.) 3


### MR. TOMPOS: You don't want air gaps. 4


### MR. WEISS: Exactly. Corners you're 5


### trying to avoid. And if there are problems

-- 6


### MR. RAMIREZ: I'm sorry? 7


### MR. UNGAR: I'm not sure why we would 8


### change that language. 9



### (Cross

- talk.) 10


### MR. TOMPOS: I agree. 11


### MR. UNGAR: My preference is leave the 12


### language in the IECC unless there's a reason to 13


### change it. And this is a case where, you know

-- 14


### MR. WEISS: Yeah. I mean, it's a 15


### concern, but I ca n see positives and negatives to 16



### it. 17



### MR. RAMIREZ: Michael? 18


### MR. LUBLINER: I have a question about 19


### this. So, sometimes we have the vaulted ceiling

20


### type. Do you have to cut the rake? Because batt 21


### comes in rectangles. Now all of a sudden, you're 22349

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### having t o cut an angle up there. 1


### And quite often, what we'll see is that 2


### they're cutting the angles by hand. There's no 3


### jig or anything. And so, sometimes, there is 4



### like kind of a gap, you know, in the wall, with 5



### no insulation right at that break, right at that 6



### intersection there. 7


### And I think this helps to clarify that 8



### that needs to be

-- you know, it needs to be done 9


### with readily confo rmed batting so that you don't 10



### have that void in the insulation. I think it 11


### just helps to give attention to detail on that, 12



### for an MP to have that to be able to point that 13



### out. 14


### MR. RAMIREZ: All right. Let's see a 15


### show of thumbs if everyone is okay with that. 16



### (Pause.) 17


### MR. RAMIREZ: Any objections on the 18


### phone? 19


### All right. That's unanimous as well. 20



### Next one? 21


### MR. SANTANA: Okay. Ga rage separation. 22350

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### That one was easy. We don't build garages. So 1


### then it's outside scope. 2


### MR. RAMIREZ: All right. So let's see a 3


### show of thumbs if you're okay with eliminating 4



### that one. 5



### (Pause.) 6


### MR. RAMIREZ: Any objections? 7



### MR. TOMPOS: I want that on the record

-- 8


### MR. MENDLEN: Garages. 9



### (L aughter.) 10


### MR. WEISS: Other people build them. 11



### MR. RAMIREZ: So that one is unanimous. 12



### Next? 13



### MR. SANTANA: Next is recess ed lights. 14



### And I had a little bit of an issue with this 15



### because I don't know that our current recessed 16


### lights are IC rated or air tight. I don't know 17


### what they cost. So this is a potential cost 18


### consideration. But, you know, outside of that we 19


### didn't see any issues. And that was my own 20



### issue. I don't know if it was a committee issue. 21



### MR. RAMIRE Z: Yeah. 22351

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### MR. LUBLINER: So, my observation is 1


### that, next to P

- traps, a lot of those recessed 2


### lights are the next big leak, after you've done 3


### everything correctly. I guess, is there

-- what 4


### is the assumption? I would assume that the cost 5



### of the air seali ng included the cost of some way 6


### of addressing that, whether it's buying an IC can 7


### or covering it with something that's 8


### nonpermeable. 9


### MR. HAGERMAN: I would assume that, too, 10



### but we can relook at it. 11



### MR. WEISS: How? 12


### MR. LUBLINER: You just buy one that 13



### sa ys, "proved by the Washington State energy 14


### code." Actually, we're the state that started 15


### it. Now it's the national one now, the I

- codes. 16


### There's listing on it. You know that, because 17


### you need to do it for modular, right? 18



### MR. TOMPOS: As far as the IC r ating ? 19


### MR. ROY: The IC rating. 20


### MR. TOMPOS: I mean, we don't do that now 21



### in the HUD code. 22352

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### MR. LUBLINER: But you do it in modular? 1


### MR. TOMPOS: Well, I don't know where 2


### this provision

-- I can't remember when this 3


### provision started. 4



### MR. LUBLINER: I was just going to ask 5


### you, do you know what the products are? 6



### MR. TOMPOS: No, we don't do it

-- 7


### (Laughter and cross

- talk.) 8



### MR. HAGERMAN: It was in '09 or

-- well. 9


### (Inaudible conversation.) 10


### MR. TOMPOS: Yeah, that's

-- so, yeah. 11


### If we're building modulars a nd that is all 12


### resolved, we do that. So eventually, all modular 13


### guys are going to have to go to this anyway. 14


### MR. HAGERMAN: Right. 15


### MR. TOMPOS: The point I wanted to make 16


### was, you know, we talked earlier about meeting 17


### that five air changes. We aren't doi ng this now, 18


### but we're, on average, pretty much meeting the 19


### five air changes. That provision right there 20


### will make a huge difference in the air changes. 21


### Because that is a big area of air leakage in most 22353

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### homes. 1


### MR. RAMIREZ: Okay. So, we have Manny 2



### for 1 5 minutes. So I want to try and get through 3


### as much as we can while Manny is here. 4



### So let me see a show of thumbs if we're 5


### okay with that recommendation. 6



### (Pause.) 7


### MR. RAMIREZ: We're thumbing that 8


### recommendation on the lights, the recessed 9


### lights, the rec essed lighting. 10



### (Pause.) 11


### MR. RAMIREZ: Okay. Anyone objectionable 12


### on the phone? 13


### All right. Unanimous. 14



### Next one? 15


### MR. SANTANA: Okay. Plumbing and wiring. 16


### Plumbing and wiring, this is one of my pet 17


### peeves. It currently calls out for, "Batt 18



### insulation sh all be cut neatly to fit around 19


### wiring and plumbing in exterior walls or 20


### installations that, on installation, readily 21


### conforms to available space and shall expand 22354

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### behind piping and wiring." 1


### You know, I think, one, that it's a 2


### little redundant, because we h ave other sections 3


### that call for the cavity to be full a nd the 4


### requirement to neatly cut around wiring and 5


### plumbing

. I don't know that we get the benefit 6



### from that for the trouble we have or the 7


### potential cost. 8


### MR. RAMIREZ: So, the recommendation is 9



### to e xclude it? 10



### MR. SANTANA: Exclude it. 11


### MR. RAMIREZ: Any questions? Yeah. 12


### MR. LUBLINER: I want to ask Emanuel, 13


### because I know in our ENERGY STAR homes program, 14


### if there is a wire going horizontally, an 15


### electrical wire, we make sure that that wire 16



### isn't com pressing the insulation. And that's in 17



### ENERGY STAR. 18


### So I'm just wondering

-- and to actually, 19


### you know, peel the insulation and put the wire 20


### between didn't represent a lot of effort. But 21


### I'm just wondering if that's something you're 22355

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### finding in your ENERG Y STAR program, whether or 1


### not there's a problem here with, say, the costs 2



### or the

-- what is the practice in your ENERGY 3


### STAR program, I guess is the question, Emanuel, 4


### on this one? Is this something that you require 5



### in ENERGY STAR? 6



### MR. LEVY: I can say w e expect that it 7


### won't be compressing the insulation. But as to 8


### whether it's a question, Mike, as to whether it's 9


### cost or whether it's a requirement? 10



### MR. LUBLINER: No, I'm just wondering if 11


### this is practice that you're doing in ENERGY STAR 12


### right now. Th e cost is a separate thing I should 13


### have kept

-- that we can talk about that after we 14



### answer the first question

. 15


### MR. LEVY: Yes. The wiring should not be 16


### compressing the insulation. 17


### MR. LUBLINER: So this step provides more 18


### specificity to the quality assu rance plan. 19


### That's why I wanted to leave it in. 20



### MR. SANTANA: Yeah. 21


### MR. ROY: I have a quick one. 22356

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### MR. RAMIREZ: Yeah, Robin. 1


### MR. ROY: Do you have a one

- or two

2


### sentence explanation as to why this provision is 3


### less suitable in the manufactured housing wor ld 4



### than it is in the site

- built world? 5



### MR. SANTANA: No. I think it's

-- well, 6



### for conservative

-- I don't think the site

- built 7


### world has the same level of inspection 8


### requirement, or in practice, right, that general 9


### manufactured housing world does, as far as 10


### scrutiny goes. 11


### You know, so that is why. So just 12


### because you have the same requirement in both 13


### worlds doesn't mean you have the same level of 14


### enforcement and subsequent recall potential, you 15


### know, corrective action potential. 16


### MR. ROY: Right. 17



### MR. SANT ANA: So that's the reason why I 18



### don't

-- you know, in my mind, the compression 19


### caused on insulation by wire doesn't necessitate 20


### the level of attention that this is going to 21



### dictate. 22357

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### MR. LUBLINER: I guess that's where we 1


### disagree. 2



### MR. SANTANA: Yeah. Tha t's where we 3


### disagree. The only thing I think we don't see 4



### eye to eye on. 5



### MR. LUBLINER: That's cool. 6



### MR. RAMIREZ: Joe? 7


### MR. HAGERMAN: So is there a compromise 8


### position here, that we can just say, "Batt 9



### insulation shall be installed such that the wire 10



### do es not compress it"? Is it the word "neatly" 11


### that bothers you? 12


### MR. SANTANA: No. It's that you need to 13


### just cut around it. You know, you need to cut 14


### around boxes. You need to cut around pipes. You 15



### need to cut around

-- where I think the 16


### compression, w hen you take the area, right, why 17


### can't the loss from that compressed insulation be 18


### accounted for in the calculation? You know, why 19



### can't that loss

-- 20


### You know, on the one hand, we're saying, 21


### you know, if you're building a two

- by

- six wall 22358

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### where R11 insul ation is going to work, we say 1


### it's just good practice to fill the void, right? 2


### To just fill the entire cavity. 3



### So , on the one hand, we're saying, you 4


### know, put more insulation in. But on the other 5


### hand, we can account for some compression. You 6



### know? S o that would be a way, that would be a 7


### tradeoff that, if you can quantify the losses, 8


### right, that are generated by compressing 9


### insulation, trade that off with something else. 10


### Can you have something, deep cut somewhere else ? 11


### MR. HAGERMAN: So then, so my f ollow

- up 12


### question is, does Emanuel's seven, you know, 13


### prescriptive measures for envelope leakage take 14


### this into account? Or would that impact this at 15


### all? Do you remember? I don't have that in 16



### front of me. 17


### MR. SANTANA: The leakage? 18



### MR. HAGERMAN: Does it talk about

-- 19


### MR. SANTANA: I don't think leakage has 20


### anything to do with it. 21


### MR. HAGERMAN: Because, I mean, you're 22359

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### going to be held to

-- 1


### MR. RAMIREZ: Right there, it's separated 2



### there. 3



### MR. HAGERMAN:

-- achieving this. 4


### MR. SANTANA: If you use tha t account. 5



### (Pause.) 6


### MR. SANTANA: Because, you know, it's one 7


### thing for us to sit here and, you know, spend the 8


### time that we're spending. But these, the 9


### products that we generate , are going to live for 10


### a long time. And it's going to have to be dealt 11



### with by everybody in the industry for a long 12



### time. 13


### And I just don't want to set us up for a 14


### perpetual failure, you know, or for a mode of 15



### failure. 16


### MR. HAGERMAN: So, do you know , if you 17


### look up the installation instructions for batt 18


### insulation, what they say? As the insulation 19


### goes around wiring and plumbing, do you know what 20


### they say? 21


### MR. SANTANA: I think they require you to 22360

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### cut around. Yeah. They require you to cut 1



### around. 2


### And I'm thinking the losses are 3


### negligible, or can at least be accounted for. 4



### MR. L UBLINER: So this is where I'm 5


### coming from. We see so much wiring in exterior 6


### walls, because code mandates a switch in eve ry 7


### room, and every so many feet there's another 8


### recept. And so, all of those areas are getting, 9


### without that attention, are getting compressed. 10


### Now, if that's being calculated in the 11


### quality assurance plan, I sure don't know about 12


### it, or in the UO. So I'm just saying, rather 13


### than make it really complicated and go back to 14


### the void thing, just do it the way the 15


### manufacturer says it shou ld be done. 16


### Now, if it costs more, we should look at 17


### the implications of that. 18


### MR. HAGERMAN: Well, it seems like if the 19



### insulation installation instructions

-- that's so 20


### complicated

-- from the manufacturers say you do 21


### it, you need to do it, then we sort of don't even 22361

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### need t he provision anyway ; you've got to do it. 1


### I mean, whether you've been doing it or 2


### not, that's between you and somebody else, right? 3



### (Cross

- talk.) 4


### MR. LUBLINER: And this gets back to the 5


### ability of the IBEA (phonetic) to have the 6


### specif ics and say, "Hey, it says specifically 7


### this needs to be." That was my concern. It 8


### gives more guidance to the quality assurance 9


### plan, which includes the DAPEA (phonetic) , the 10


### IPEA, HUD, all the players. 11


### MR. HAGERMAN: I can say this provision, 12



### this row i n its entirety, is sort of like an 13


### exception, because it just calls out batt 14


### insulation, right? 15



### MR. SANTANA: Um

- hm. 16


### MR. HAGERMAN: So if we just want to say 17


### "Plumbing and wiring, all insulation shall be 18


### installed per the manufacturer's installation 19



### instru ctions" to take into account only on 20


### electrical wiring, and just move on, it seems 21



### like that's a

-- 22362

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### MR. SANTANA: Well, yeah. I mean, we 1


### approved that section already. 2


### MR. WEISS: Well, keep the strike. 3



### You're fine. 4


### MR. ROY: Is that a way of winking an d 5


### nodding but not actually doing this? 6


### MR. HAGERMAN: No. That's a winking and 7


### nodding that, if a manufacturer of insulation has 8


### done the study that says, "If you don't do that," 9


### but it's so equivalent, then we're fine with it, 10


### right? But the burden is o n the manufacturer of 11


### the insulation. They would get sued by FTC 12


### because this actually has a deduction in the 13



### insulation values. 14


### MR. LUBLINER: I guess my point is

-- 15


### MR. HAGERMAN: You don't buy that? 16


### MR. SANTANA: No, that makes sense. Joe, 17


### my point w ould be

-- 18


### MR. LUBLINER: ENERGY STAR best practice 19


### also does that. And so, I just feel this is one 20


### that we run into a discussion in the QA in the 21


### factory. Is this required or not? 22363

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### MR. HAGERMAN: It sounds like all 1



### installation instructions for batt ins ulation 2


### require you to do this. So why they haven't been 3


### doing it altogether means they haven't been 4


### installing insulation

-- 5


### MR. LUBLINER: And I don't want to go 6


### there. So I'm saying, if we make it explicit, 7


### then we don't have that problem. 8



### MR. RAMIRE Z: Why? Why don't you want to 9


### go there? 10


### The only reason I'm asking this is that 11


### it kind of goes back to a lot of stuff that we 12


### do, is why do you want to fight this? Or go over 13



### the same road twice? 14


### MR. LUBLINER: Why I don't want to go 15



### there is because t hen it suggests that everything 16


### that they've been building is out of compliance 17


### with that procedure. And I don't know that to be 18



### the case. 19


### But what I just heard was the 20


### manufacturers' installation instructions requires 21


### you to cut around it. I was just po inting out, 22364

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### ENERGY STAR does, too. If ENERGY STAR is a 1


### voluntary program, but I think that's best 2


### practice, and there's reasons for it. 3


### But I think it's getting back to what I 4


### originally said. The more specific detailing 5



### about air sealing, the better the quality 6


### assurance plan can evaluate whether it's 7


### acceptable or not. And this is where Manny and I 8


### disagree, is that I think that that's a very 9


### important thing in overall because of the amount 10


### of wiring and plumbing, wiring particularly, in 11



### exterior walls

. 12


### I mean, on a single

- section home, it 13


### could be a large percentage. And I haven't seen 14


### any calculations that look at it. 15


### MR. SANTANA: Well, you know, why can't 16



### you account

-- I'm sorry. Who's next? 17


### MR. RAMIREZ: Let's get David real quick. 18



### MR. TOMPOS: Well, I just pulled up an 19


### installation instruction. And what we're talking 20


### about is the grading of the instructions. And 21


### what it says in here is that when grading is 22365

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### necessary, that you recommend

-- it reco mmends 1


### that you use the RESNET grading quality. 2



### So I'm not

-- I'd have to do a little 3



### more research to find out if there are 4


### installation instructions that say you cut around 5



### wires. But I don't think it's in there. I think 6


### it's like this, where it says, "Well, if it's 7


### required, if there's a grading re quirement, you 8


### go and use the RESNET system." So I don't think 9


### we're violating manufacturers' instructions on 10


### all homes right now. 11


### MR. LUBLINER: Again, regardless, I just 12


### think it's a good practice or something we run 13


### into difficulty interpreting. 14



### MR. HA GERMAN: And so, Johns Manville's 15


### installation instructions for insulation says, 16


### "Insulating around electrical wiring and walling. 17


### When electrical wiring passes through a 18


### subcavity, split the insulation with a utility 19



### knife"

-- 20


### MR. LUBLINER: Bingo. 21



### MR. HAGERMAN:

-- "and fit half in front 22366

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### of and half behind the wire," blah

- blah

- blah. 1


### MR. SANTANA: And so, what I was saying 2


### is the HUD code currently allows you to take into 3


### account voids or areas that have compression, you 4


### know. And you're penalized for t hat in your U 5


### value calculations. So why wouldn't that be an 6


### option ? 7


### What I'm against is making it a mandatory 8


### provision where it has to be done 100 percent of 9


### the time. If there's a way you can quantify it 10


### and account for it, why not have that option? 11


### Why not have that bit of

-- 12


### MR. HAGERMAN: Well, that sounds like an 13


### exception for installing it not per the 14



### installation instructions. 15


### MR. LUBLINER: That's exactly what that 16



### is. 17


### MR. SANTANA: There are exceptions for 18


### installing materials all over the place, you 19


### know? It depends. If you can

-- you know, we 20



### have letters from manufacturers on all sorts of 21


### products when you ask them for a specific 22367

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### scenario and they write you a letter. So that 1


### wouldn't be an option if you have this. 2


### MR. HAGERMAN: No, ab solutely it wouldn't 3


### be an option. If this line was just struck, 4


### because it's actually not even new

-- 5


### MR. SANTANA: Right. 6


### MR. HAGERMAN: If we just said, you know, 7


### just as a reminder here, "Install your 8


### installation per the manufacturers' 9


### instructions, " it's incumbent on the manufacturer 10


### with the FTC to say, "If you don't cut it, then 11


### it's equivalent," right? 12


### MR. SANTANA: Exactly. Right, right. 13


### So say that Johns Manville

-- 14


### MR. HAGERMAN: So the burden is on them, 15


### right? 16


### MR. SANTANA: Right. 17



### MR. HAGE RMAN: I don't think you'll ever 18


### get them to say that. 19


### MR. SANTANA: That might be the case. 20


### MR. RAMIREZ: Unless Manny is willing to 21


### concede on this, my suggestion is that we end it 22368

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### here for this thing. Because I want to be 1


### respectful of his time that he 's been working on 2


### this hard on this stuff, along with Eric and some 3



### of the other committee members, right? And he 4


### needs to catch a flight. And I think he did give 5


### us as much time as possible. 6


### MR. HAGERMAN: Absolutely. Joe Hagerman, 7



### DOE. 8


### We really appr eciate this work. And this 9


### is good work. 10



### MR. RAMIREZ: Yeah. Yeah. 11


### MR. ROY: Two thumbs up. 12


### MR. HAGERMAN: Yeah, two thumbs up. And, 13


### you know, I agree with it being struck. I don't 14



### think that

-- 15



### MR. SANTANA: Make an executive decision. 16


### (Laughter.) 17



### MR . HAGERMAN: Yeah. I'll vote on it 18


### being struck. 19


### MR. RAMIREZ: All right. Well, let's 20


### gauge the consensus of it being struck. Let me 21



### check the level of consensus. 22369

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### MR. ROY: Is it being captured in the 1



### calculation in the U value for walls? 2



### MR. LUBLINER: Yeah. As long as it's in 3



### the calculation

-- 4


### MR. HAGERMAN: No, no, no. Hold on. 5



### Time out here. 6



### So we assume with all the calculations 7


### and the simulations that you install the products 8


### like the manufacturers say you do. So our 9



### simulation would show th at you're cutting for 10



### wire. 11



### MR. RAMIREZ: Mark? 12


### MR. HAGERMAN: If they don't do that, you 13


### know, they're not installing it per the 14



### manufacturer's installation instructions. 15


### MR. LUBLINER: Could I get a sense, maybe 16


### I'll change my vote

-- 17



### MR. HAGERMAN: Do you not follow that? 18



### MR. ROY: I follow that. But it's not a 19


### satisfying answer. That's what I thought he 20


### would say, and it's not a pleasing one. 21


### MR. HAGERMAN: That's the reality, 22370

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202

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### though. 1


### MR. ROY: I'm reading from the industry, 2


### too. I get that, too. 3



### MR . RAMIREZ: Michael? 4


### MR. LUBLINER: Yeah. I was just wondering 5


### what Mark from Clayton or the other manufacturers 6



### think about this. Do they consider the 7


### compression around the wiring in the exterior 8



### walls in their void calculation? Or not? 9



### MR. HAGERMAN: I think HUD allows that, 10


### right, Manny, 1 percent? 11



### MR. SANTANA: I know. 12


### MR. LUBLINER: But just because HUD 13


### allows something now, we're sitting here to 14



### evaluate whether what HUD allows that's been 15



### around for

-- that compression void thing has 16



### been around s ince '76. 17


### MR. MENDLEN: I've got to say something. 18


### MR. LUBLINER: Sorry, Rick. 19



### MR. MENDLEN: It's in the standards. But 20


### what isn't in the standards, Joe, is it has to 21


### comply with the insulation manufacturers' 22371

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### instructions. Be careful about whose 1



### instruct ions you're talking about. 2


### MR. HAGERMAN: Right. 3



### MR. MENDLEN: What's in the code talks 4


### about the manufacturers' instructions, not the 5



### insulation manufacturers' instructions. It's 6



### different. 7



### MR. HAGERMAN: I would assume that the 8



### manufacturers of insulati on are manufacturers, 9


### right? Just like GE makes refrigerators, right? 10


### MR. LUBLINER: Well, maybe we should

-- 11



### MR. HAGERMAN: You have to install that 12


### correctly. 13


### MR. LUBLINER: Maybe we should recommend 14



### the HUD at that

-- 15


### MR. UNGAR: I've been hearing so mething 16


### different. You're saying the manufacturers' 17


### instructions. You're talking about , the home 18


### manufacturer is not in the HUD code a requirement 19


### that the components be installed? 20



### MR. MENDLEN: The insulation 21


### manufacturers' instructions is not specifica lly 22372

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### referenced in our standards. 1



### MR. HAGERMAN: But we did reference that 2


### earlier today. 3



### (Cross

- talk.) 4


### MR. MENDLEN: But you talked about 5


### manufacturers' instructions, Joe. Which 6


### manufacturer are you talking about? Home or 7



### insulation? 8



### MR. HAGERMAN: So we 've said, we've 9


### already voted that R402.4.1, insulation, the 10


### components of the building thermal envelope as 11



### listed in table blah

- blah

- blah shall be installed 12



### in accordance to the manufacturer ' s instructions. 13



### Those manufacturers' instructions are the 14



### manuf acturers of the building thermal envelope 15



### components. 16


### MR. LUBLINER: So we just change the HUD 17


### code to represent that. 18


### MR. HAGERMAN: Okay. All right. 19


### MR. LUBLINER: I mean, you have to talk 20



### to HUD about that. 21



### MR. HAGERMAN: You have to install the 22373

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### insula tion per the manufacturers' instructions, 1


### the people that make the insulation. 2


### MR. RAMIREZ: So, let me see a show of 3


### thumbs again for striking

-- 4



### MALE VOICE: No, no, no. 5


### (Simultaneous conversation.) 6


### MR. RAMIREZ: That's 402.4.1, the first 7


### page of Manny' s document. 8


### So, again, let me see a show of thumbs 9


### for striking

-- I'm trying to find it

-- the 10


### plumbing and wiring section of this chart. 11



### (Pause.) 12


### MR. RAMIREZ: Any thumbs down on the 13


### phone? 14


### Okay. No thumbs down. That one is 15



### unanimous. 16



### MR. WEISS: For t he strike, correct? 17


### MR. RAMIREZ: For striking. 18


### Okay. Again, Manny, thank you very much. 19


### Let me suggest this. Are you guys okay 20


### with a quick five

- minute one function here? And 21



### then we'll come back and then see

-- we'll 22374

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### discuss as a group how you want to use the 1


### remaining 40 minutes that we have. Okay? 2


### So, a quick five

- minute break. 3


### (Recess from 4:20 until 4:29 p .m.) 4


### MR. RAMIREZ: All right. We're still 5


### missing a few bodies. While we're getting the 6


### group back together, I want to offer an 7


### opportunity fo r public comment. And then let's 8


### see what time that takes, or not, and then we can 9


### see what we have remaining and see how to fill it 10


### properly. 11


### So, Rick, I believe that you are the only 12


### member of the public present. Would you like to 13


### make any comments? 14



### MR . MENDLEN: I will defer my comments 15


### for the day and let the committee continue to do 16



### its work. 17


### MR. RAMIREZ: Okay, great. 18



### Then I'll as k the committee here. You 19



### know what? 20



### MR. WEISS: Javier. 21


### (Inaudible conversation.) 22375

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### MR. WEISS: Javier, I just want to say 1


### one thing for the sake of consistency, as I make 2


### this point at just about every MHCC meeting, 3


### where I'm considered a member of the public. 4


### And that is, I just have a problem with 5


### referring to HUD, our regulatory agency, as "a 6


### member of the public." I understand the process 7


### we have here, but you know, they're not just Joe 8


### Shmo from the public. 9


### MR. RAMIREZ: Right. 10


### MR. WEISS: You know, they have a direct 11


### interest in this proceeding. 12


### MR. RAMIREZ: Right. 13


### MR. WEISS: And I appreciate you giving 14



### Rick the o pportunity to comment when he feels 15


### it's appropriate. But again, I just have a 16


### problem with that terminology. 17


### MR. RAMIREZ: Yeah, I understand that. 18


### And Rick has been very compliant with the rules 19


### that this committee has set up, and also very 20


### helpful wit h giving us information offline and 21


### online. So we do appreciate that, Rick. 22376

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### It's a formality. I hope that everyone 1



### understands that. 2



### MR. MENDLEN: I understand it. 3


### Thank you, Mark. 4



### MR. WEISS: I'll cite this next time I'm 5


### called upon, right? 6



### MR. RAMIREZ: Yeah. 7


### (Laughter.) 8


### MR. RAMIREZ: Okay. So, we have about 30 9


### minutes left. And I'm looking at this. I want 10



### to see if we could

-- I'm going to defer on the 11


### affordability report right now. I think that 12


### that's still probably a bit premature for the 13



### afford ability report, which we get to it at the 14


### next meeting. 15


### But as far as action items go, that kind 16


### of goes to the multiple product types, which 17


### leaves climate zones and compliance paths. 18


### Can this group make a decision on either 19



### one of those with the remainin g time that we 20


### have? Has there been enough data thrown out 21


### there, say, for the climate zones, to adopt 22377

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### either

-- and correct me if I'm wrong. We're 1


### talking about either HUD or IECC. I don't think 2


### we're getting creative here and trying to create 3



### our own type of climate zone structure. Is that 4



### accurate? 5



### MR. ROY: This is Robin. 6


### I think it's accurate. But if the IECC, 7


### it may be a subset of those or a combination of 8



### those. We would treat them all the same. I can 9


### imagine of the eight IECC zones, ending up with 10


### three that happen to be just a different 11


### geographies than the HUD. It's imaginable. 12


### It could be all eight. But then several 13


### of them would be identical. I can picture that. 14


### MR. WEISS: I mean, I just see it as such 15


### an important issue that to addres s it at the end 16


### of a meeting, for me, I just don't think it 17



### works. 18


### MR. RAMIREZ: And that's why I'm asking. 19


### MALE VOICE: I agree. 20



### MR. RAMIREZ: We have 30

-- a little over 21


### 30 minutes. Is that enough time to address 22378

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### either one of those issues? 1



### MR. LUBLINER : So, since the first 2


### meeting, I've been trying to get a sense of the 3


### feeling of the group about, should we just leave 4


### the HUD climate zones the way they are? And I've 5


### been one that's been a advocate for doing that, 6


### not going to the IECC climate zones, b ecause I 7


### think it's a bigger burden in the industry and 8



### it's harder

-- it may be more difficult. 9


### But I'm willing to hear arguments as to 10


### why we should make it more climate zones. 11


### I feel like a place like California, 12



### where this could really be an issue, bec ause it's 13


### just very diversified climates, that they will 14


### probably during public comment decide whether or 15


### not they think this is adequate or not, and they 16


### will tell us, "Well, wait a minute. We're 17



### California." 18


### But anyway, so, Robin, that's kind of my 19



### thou ght. So I'm wondering, is it useful at all 20


### in getting a sense from the group how far off we 21



### are on the issue of climate zones? 22379

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### MR. RAMIREZ: Okay. And, Lois, you had a 1



### comment? 2



### MS. STARKEY: I'd like to hear from the 3


### rest of the group, and then I will. 4



### M R. RAMIREZ: Okay. I saw perfectly a 5


### hand. Is that you, Mark? 6


### MR. WEISS: Yeah. I'm probably the wrong 7


### one to be saying this. Part of the problem we're 8


### going to have here is Manny's not here. And, you 9


### know, I think he would have some important input. 10


### But I don't know if the analysis works, 11


### Mike's analysis works, because the HUD zones are 12


### more, are broader, okay? You have three zones 13


### versus, what is it, eight in the IECC. And 14


### you're making the requirements more prescriptive 15


### if nothing else, probably m ore costly as well. 16


### By applying those higher requirements 17


### over potentially broader areas, aren't you 18


### increasing the cost of the burden rather than 19


### having more targeted areas? I don't know. I'm 20


### just raising this. 21


### MR. LUBLINER: So, Mark, my feeling is if 22380

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### the industry wants the IECC climate zones, I'm 1


### fully supportive of it. I just want to know what 2


### the industry wants, you know. 3


### (Laughter.) 4



### MR. ROY: This is Robin. 5


### I hear your view, Mark, about this one. 6



### I take a look at some of the numbers on the 7



### increme ntal home costs that they've whipped up. 8


### And I can see that they seem to correlate with 9



### some of the

-- you can find some places where it 10


### looks like, "Gosh, Phoenix or Houston should not 11


### be here. We should not be treating it as HUD 12



### zone 2." You can easil y see, well, it works 13



### better in an IECC definition. 14


### I don't know the answer, but I was kind 15


### of keen to see what the costs, and the cost 16


### effectiveness, would guide us to do. And we're 17


### just getting to that now. So I think it is 18


### premature. We won't solve i t today. But we're 19


### getting the numbers that will allow us to do it. 20


### MR. WEISS: Yeah, not being a technical 21


### person or any of that, the question just occurs 22381

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### to me, you know. 1



### MR. ROY: Me, too. 2


### MR. RAMIREZ: All right. I'm sorry. 3


### Eric, then Lowell. 4



### MR. LA CEY: You know, I'm not sure 5


### whether you will come down on the climate zones. 6



### And I think I'm fine with either. I see the 7



### value in either of them. 8


### The IECC has nominally eight climate 9


### zones. But if you look at insulation 10


### requirements, there's kind of th ree different 11


### insulation requirements that applied in groups of 12


### climate zones. And window requirements , there 13


### are essentially three window requirements that 14


### apply to three groups of climate zones. 15


### And so, what I like about the Luby 16


### prescriptive proposal i s that it sort of took, on 17


### balance, you know, levels that were equivalent, 18


### or in some cases kind of the better requirements 19


### of those climate zones. If you were to package 20


### the climate zones from eight packages into three, 21


### it picked reasonably efficient lev els for each of 22382

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### those climate zones. 1


### So I think, if you keep that in mind, you 2


### know, whether we end up with three or eight 3


### climate zones, or some other number, as long as 4


### we're keeping an eye on those groupings of 5


### efficiency levels for the components, I th ink 6


### we'll be okay. 7


### But, you know, I'm interested in hearing 8



### from the manufacturers on how that would affect 9



### them to have maybe more climate zones. 10


### MR. LUBLINER: That's what I'm waiting to 11



### hear from the manufacturers, or Emanuel, because 12



### he's looked into t his pretty extensively. 13



### MR. LACEY: Yeah. 14


### MR. LUBLINER: I don't think we're ready 15


### for a vote today. I was just trying to get a 16


### sense of the group. I agree with Robin. 17



### MR. LEVY: Javier? 18



### MR. RAMIREZ: Yeah. 19


### MR. LEVY: Hi, this is Emanuel. Can I 20


### weigh in here? 21


### MR. RAMIREZ: Yeah. Please, please. 22383

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### MR. LEVY: Javier, did you get the email 1



### I sent? 2



### MR. RAMIREZ: Let me check. 3



### (Pause.) 4


### MR. RAMIREZ: Yeah. We'll pull it up 5


### here in just a second. I see it. It did come 6


### through. 7



### (Pause.) 8



### MR. RAMIREZ: While Ted takes a minute, 9


### because I know how my Outlook is just brutally 10


### slow to open, are there any of the other 11



### manufacturers that want to chime in as far as 12


### just initial perceptions on the climate zones? 13



### MR. KESSLER: This is Bert from Palm 14



### Harbor. 15



### I think the c onsensus among manufacturers 16


### is to keep it simple, like we have it. I'm going 17


### to go out on a limb and some of my brethren will 18


### probably hate me. But I think we should look at 19


### making at least a couple of changes, just looking 20


### at the map. If you look at t he Texas panhandle, 21


### I think perhaps that line in the sand could be 22384

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### redrawn and kind of follow a little bit more of 1



### what the IECC folks show. 2


### Just because, you know, we can design a 3


### house for Amarillo, Texas, to climate zone 1 and 4


### design a house for, you kn ow, down around

-- for 5


### thermal zone 1, but there's a huge difference. 6


### The other thing that I believe is part of 7


### an issue relating to the thermal zones is 8


### equipment sizing, because that gets a little bit 9


### more diluted. So that's all I'm going to say 10



### about t hat. 11


### MR. RAMIREZ: So if I could try to sum 12


### that up, basically what you're saying is that 13


### there's a comfort in keeping what you have. But 14


### there may be a good argument to restructure that 15



### a bit. 16


### MR. KESSLER: Yeah. And especially for 17



### Texas. And I think s omebody brought up Arizona. 18


### You know, I think we could streamline 19


### efficiencies a little bit more if we went away 20


### from just following state lines. 21


### And I know that was a big deal back in 22385

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### '94 when we changed the wind standards. But I 1


### think everybody is used to it. And I think it's 2


### manageable. 3


### MR. RAMIREZ: Okay. Thank you. 4



### MR. KESSLER: Lois? 5



### MS. STARKEY: Yes. 6


### MR. KESSLER: You got any comments? 7



### MS. STARKEY: No. We talked about this. 8


### You know, we've been talking about this as a 9


### group most recently in t he last couple of years. 10


### So I think it's worth putting it on the table, 11


### because I think you can get some tradeoffs if you 12



### added at least one other zone. 13


### MR. RAMIREZ: Okay. Emanuel, do you want 14


### to walk us through what we're looking at? 15



### MR. EZZO: Can I m ake a comment? This is 16


### Mark, Clayton. 17



### MR. RAMIREZ: Yeah. 18


### MR. EZZO: My vote or my preference would 19


### be to keep the three HUD zone boundaries as they 20


### are. And I completely recognize and agree with 21


### the logic that Bert just expressed. I mean, it 22386

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### makes perf ect sense. 1



### But I also am concerned about the 2


### complexity of changing the boundaries, not only 3


### for manufacturers, but for the retail world. 4


### It's going to cause a lot of confusion for them 5


### if we change the boundaries. 6


### You've got to keep in mind that not 7



### ev erything we build is customer sold. Our 8


### industry deals with a lot of stock homes, a lot 9


### of retailers carrying inventory. A lot of those 10


### retailers are in areas that hit multiple zones. 11


### So my preference would be that we keep the 12


### boundaries the way they ar e. 13


### And then couple that with, like Mike 14


### Lubliner's approach, where he took what I thought 15


### was a pretty practical stab at putting together 16


### as a thermal requirement by zone, you know, 17


### prescriptive approach, that I know we haven't 18


### gotten through that yet and I hope we do in more 19



### detail. 20


### But it really makes sense to me the way 21


### he broke it down between 1, 2, and 3 in terms of 22387

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### what's required for insulation in the cavities, 1


### the thermal performance of the window 2


### requirements, and all those kinds of things. 3



### So that 's my input for what I think the 4



### boundaries ou gh t to be, going forward. Thanks. 5


### MR. LUBLINER: Thanks, Mark. 6


### MR. RAMIREZ: All right. Emanuel, you 7


### want to walk us through what we're looking at? 8



### MR. LEVY: Yeah. This is

-- and all the 9


### comments leading up to this were very good 10


### because it will be very helpful. 11


### This is the mapping of the results from 12


### our analysis of U values, with the various zones. 13


### And you see what you're looking at is two maps 14



### overlaid . The thick line you'll recognize is 15


### carving out the three HUD zones. So, Texas over 16


### to Georgia and down to Florida, or South Carolina 17


### down to Florida, is zone 1. And the middle area 18


### there is zone 2, and the northern zone is zone 3. 19


### And you can see how what this means in 20


### terms of the consistency of the U v alues. And I 21


### think what Mark was saying just now about keeping 22388

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### them where they are makes some sense, or that's 1


### reflected somewhat in the U values in that, if 2


### you look at zone 2, for example, all the way 3



### across there

-- now, there are exceptions, as 085 4



### an d there's 059. But generally, that whole band 5



### is around 067. 6


### So just for U value matching up to the 7


### IECC, you can pretty much soft focus on that area 8


### and say, "Okay. Zone 2 should be about 067. 9


### Let's develop a prescriptive package from that." 10


### And you c an now look at the South and see it's 11


### somewhere between 067 and 085. In the North, you 12


### can see that it ranges anywhere from 067 down to 13



### 051. 14


### And also, you see on the table there's 15


### the LCC range. And I've just picked two

. I've 16



### bracketed that with kind of a high

- low set of 17


### assumptions. And you can see that, in zone 1, 18



### those U values tend to

-- some of them are cost 19


### effective, some of them are not cost effective. 20


### They're pretty much straddled. So the overall 21


### impression is that that range there is within the 22389

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### band of what you'd expect, without much change. 1


### Same thing, less so, in zone 2, and zone 2


### 3, probably, there's some opportunity there to 3


### make things a little bit more stringent. 4


### But I just threw this map out there to 5


### kind of get the debate going so you can see what 6


### the ramification would be in terms of overlying 7


### the two zones and what it really means in terms 8


### of the use of all zoning. 9


### MR. RAMIREZ: Great. Thank you. It 10



### looks very useful. And I just forwarded it on to 11


### the complete work group. 12



### Mark? 13



### MR. WEISS: Question. Maybe I'm missing 14


### something. Why is the brown shaded area, both 15


### the brown shaded area and the yellow shaded area 16



### 0.067? 17


### MR. LEVY: Same prescriptive requirements 18



### in the IECC. 19


### MR. WEISS: Why are they shaded 20


### differently then? 21



### MR. LEVY: Because they're different 22390

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### zones. They're called out as different zones by 1



### the IECC. 2


### MR. WEISS: But the same requirement? 3


### MR. LEVY: The same requirement. 4



### MR. UNGAR: In 2015 IECC. 5


### MR. WEISS: Oh, okay. Okay. All right. 6



### Thanks. 7


### MR. RAMIREZ: Yeah, Eri c? 8



### MR. LACEY: T his is Eric. And just to be 9


### clear, you aren't including any of the cost or 10


### benefits of a lower SHGC in the fenestration, 11


### right? This is just a use of O calculation? 12



### MR. LEVY: We used the lower solar heat 13


### gain coefficient, but we picked a window that 14


### gave you that value. And that helped to trade 15


### off against the rest of the envelope. So it does 16


### include the glazing. It does include the solar 17


### heat gain coefficient in here, in the package. 18


### But what you're looking at is use of O 19



### values. And the use of O values, of course, are 20


### only reflective of what U values are in a 21



### component. 22391

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### MR. LACEY: So I guess you use the SHGC 1


### in your cost effectiveness, but that won't be 2



### reflected in the use of O values that are on this 3


### page? 4


### MR. LEVY: I think I jus t said it the 5


### opposite way. The first thing is the cost 6


### effectiveness is just using the tool that NCI 7


### developed. The U values here are developed from 8


### the packages that were on the chart that we 9


### talked about yesterday, which included the solar 10


### heat gain c oefficient windows, the windows with a 11


### lower solar heat gain coefficient. 12


### MR. HAGERMAN: This is Joe Hagerman, DOE. 13



### So I think he used

-- all your packages 14


### had the same solar heat gain coefficient, which 15


### says 0.33. 16


### MR. LEVY: That's right. 17



### MR. HAGERMAN: O kay. 18


### MR. LEVY: Right. 19



### MR. HAGERMAN: So I think the number that 20


### you're showing here reflect your single

- section 21


### home from the chart that he provided us 22392

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### yesterday. 1


### MR. LEVY: Right. 2


### MR. HAGERMAN: The proposed prescriptive 3


### packages. 4


### MR. LEVY: That's righ t. Now, we can go 5


### in and tweak those. It might impact these 6



### numbers a little bit. 7


### MR. HAGERMAN: And just to be clear, too, 8


### you did two ana lysis periods here, one 10 and one 9



### 30? And on the 10

- year, you did not include 10


### residual value, and in the 30, you included 11


### residual value. Is that right? 12


### MR. LEVY: Right. Right. And of course, 13



### we discussed

-- you can throw in any set of 14


### assumptions in here and come up with your LCC 15



### range. 16


### MR. HAGERMAN: Yeah, just to be clear, 17



### that's backwards of what we talked ab out 18


### yesterday. We talked yesterday about 10 years 19


### with residual value and 30 years without residual 20


### value. So is that a typo? 21


### MR. LEVY: No. You know, this was

-- I 22393

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### characterize this as a quick and dirty just to 1


### get some numbers out , just to be able to have a 2


### visual display of this information so we could 3



### have a discussion about how to make decisions in 4



### that climate zone. 5


### MR. HAGERMAN: Okay. 6



### MR. LEVY: This is not a final

-- this is 7


### not a recommendation. This is not a proposal. 8


### MR. HAGERMAN: Right. 9



### M R. LEVY: This is just a way, a proposed 10


### way to get at that discussion. 11


### MR. RAMIREZ: And so I guess I sent that 12


### out without that clarification. I just forwarded 13


### it. Just so everyone, when you get that, don't 14


### get worked up on any numbers. 15



### MR. HAGERMAN: Joe Hagerman, DOE. 16


### Just to be clear, I think once you put in 17



### 10 years with residual value, your LCC range 18


### where you're showing negative 105, negative 1068 19


### and 263, are going to be less severely negative. 20


### MR. LEVY: Right, right. Actually, both 21


### numbers, yo u get in a little closer

-- 22394

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### MR. HAGERMAN: To zero. 1


### MR. LEVY: From what you've said, Joe. 2


### But you're right. 3


### MR. HAGERMAN: Okay. 4


### MR. LEVY: The U value, that won't affect 5


### the U value range. 6


### MR. HAGERMAN: That's right. 7



### MR. LEVY: But the tweaks in the window 8


### might affect the U value range a little bit. 9


### MR. RAMIREZ: Any other questions on this 10



### one? 11



### (Pause.) 12


### MR. RAMIREZ: So, we have about 10 13



### minutes left. And I'd like to take a few minutes 14


### to at least start the outline of a proposed 15


### agenda for the next meeting, where we continue 16


### with the 2015 IECC scope report that Manny had 17


### put together for us. 18


### And then, I think on that affordability 19


### report, that's going to the question of multiple 20


### product types, which there may be some benefit to 21


### holding that conversa tion off for a little bit to 22395

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### see if that's something that we actually are 1


### seriously considering, or

-- Robin? 2


### MR. ROY: I think it's worth holding off 3



### till we see a few more of the numbers to see 4


### whether it's something that we actually need. 5



### MR. RAMIREZ: Right. 6



### MR. ROY: If we find that in the first 7


### buyer's perspective and in the full life cycle 8


### cost perspective there's an overlap in the energy 9


### efficiency levels, then there's no reason to do 10


### something that separates them. 11


### MR. RAMIREZ: Okay. 12



### MR. ROY: To h ave two product types. So 13



### we should take a look at some numbers first. 14


### MR. RAMIREZ: Okay. Joe? 15


### MR. HAGERMAN: So I'm just

-- so we're 16


### meeting next week, right? And isn't it next 17



### week? 18


### MS. DICKENS: Yes, it's next Wednesday 19


### and Thursday, right? 20



### MR. HAGE RMAN: Yeah, next Wednesday and 21


### Thursday. So, just like let's talk turkey and 22396

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### let's do a reality check real quick. 1


### So, usually I'll walk away with a ton of 2


### homework. And today it seems like I'm not 3


### getting very much homework. I'm going to have 4



### PNNL relo ok at the U values, right, for the 5


### packages that Emanuel gave us, just to see how 6


### the savings numbers differs. We talked about 7


### that yesterday, right? 8


### Matthew will correct the life cycle tool, 9


### where we saw some errors or there were some price 10


### discrepancies , you know, per the discussion on 11


### everything we voted on with the price or the 12



### costs. 13


### What else do we need here? I mean, you 14



### know , next week when we meet, how does the 15


### situation change between now and next week to 16


### make this group get closer to a decision? Right? 17


### Let's just talk turkey about that, right? 18



### MR. ROY: This is Robin. 19


### In my estimation, it changes a lot. We 20


### had a few things which will change the life cycle 21


### costs and the first buyer perspective costs of 22397

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### effectiveness analyses. So much of what w e're 1


### discussing hinges on what those numbers show us, 2



### I think. 3



### I didn't even have that much time to 4


### reflect on what we received on Friday, before 5


### today. We'll have plenty of time, I'm presuming. 6


### Matthew, how long before you send that out? In 7


### advance, I would hope, by more than the previous 8


### day. 9


### If it is, then we'll be able to actually 10



### have a conversation about some of the numbers 11



### that we see in there. We should have some idea 12



### of whether we think some of them are sensible 13


### already, from the discussion we' ve had over the 14


### last couple of days. But we need to see the 15



### numbers coming through as well. 16


### MR. HAGERMAN: Let's just say that all 17


### the DOE stuff will get done by Thursday close of 18


### business. We'll send it out to you Thursday 19



### close of business. 20



### MR. ROY: T hursday next week or this 21



### week? 22398

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### (Laughter.) 1



### MR. HAGERMAN: This week. 2


### MR. ROY: Sorry. Can we strike that from 3



### the record? 4


### MR. HAGERMAN: And do you also think it 5


### would be helpful if we showed

-- so we're doing 6


### two things right now. We're going to update the 7


### life cycle tool. We're going to give you the new 8


### runs, those two things. 9


### Would it be helpful for us to add a 10



### third? And that is revise the chart that Emanuel 11


### sent out and show you that graphic with the new 12


### numbers in it for the single and the double ? I 13


### thought it was pretty helpful. Is that something 14


### you would like to see, as well? 15


### MR. RAMIREZ: I've seen some heads bob, 16



### so yes. 17


### MR. HAGERMAN: So we'll do that, too. So 18


### there's three things. Update the life cycle, new 19


### PNNL runs so we can get the c orrect numbers, and 20



### then take Emanuel's c limate zone chart and update 21


### it. Right? So we can be responsible for getting 22399

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### all that to you Thursday, close of business. GC 1


### will agree to approve what we send very quickly. 2



### So. 3


### MR. UNGAR: One question on that. The 4


### one thing I've heard a lot of discussion on 5


### yesterday was on the windows costs. And I don't 6


### know how to handle that dispute. And we can 7


### either go ahead, recognizing that some people 8


### think the costs on that portion will be 9


### considerably

-- I mean, no t just a small amount, 10



### but a lot lower. 11


### Or I suppose we could do

-- we could ask 12



### for a new set of numbers from a new evidence and 13


### run another set of, you know, calculations based 14



### on two different sets. 15


### I just

-- that's one thing that seemed to 16



### me like it m ight be material. 17


### MR. HAGERMAN: I forgot to say, too, that 18


### when we got Emanuel's cost data from the 19


### industry, I asked Navigant to compare those costs 20


### with just publicly available data sources just to 21


### make sure there weren't any discrepancies, just 22400

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### as a co urse of good measure, not that we don't 1


### trust the manufacturers or anything. 2


### So they've been doing that RSMeans 3


### evaluation. They didn't get it done by time to 4


### share it with anybody. But we're also doing that 5


### site analysis, too. And once they get that 6



### RS Means calculation, we can share that as well. 7


### MR. WEISS: From part of the industry. 8


### MR. HAGERMAN: For part of the

-- 9


### MR. WEISS: From part. 10



### MR. HAGERMAN: Yeah. 11



### (Cross

- talk.) 12



### MR. HAGERMAN: All of the information 13


### that's been publicly provided by this gr oup. 14



### MR. BARBOUR: Joe, on the RSMeans, is 15


### that part of Navigant ? It's not an apples

- to

16


### apples? 17


### MR. HAGERMAN: Right. Yeah. We should 18


### say that, because

-- 19


### MR. BARBOUR: Actually, I don't know how 20


### useful it's going to be

. I'm just going to 21


### preface it b y saying that. 22401

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### MR. HAGERMAN: To me, it's a gut check, 1


### right? It's like, hey, we've got these numbers. 2


### Let's just do a first

- order, does it kind of

-- 3


### is it in the same ballpark? But, obviously, 4



### RSMeans does not have a volume from manufactured 5


### housing. And you are right. It's not apples

- to

6


### apples. 7


### But you guys are smart guys. 8


### MR. BARBOUR: But it's going to

-- 9


### MR. HAGERMAN: You guys are smart guys. 10



### MR. BARBOUR: But it's not

-- 11


### MALE VOICE: You guys are smart guys. 12


### You all figure it out. 13


### (Laughter. ) 14


### MR. RAMIREZ: Let's get Michael, then 15


### Eric, Mark, Lois. 16


### MR. LUBLINER: A couple of meetings ago, 17


### I suggested that you might want to go and talk 18



### with the associations like NAIMA. And now that 19


### we know what the markups are and we have the 20


### retail costs, you might want to go back to NAIMA 21



### and just confirm with them that, is it two cents 22402

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### per R? Or one cent? Or for high density, low 1


### density? That would be very useful for me to 2



### understand. 3


### Now, again, not that I'm questioning the 4



### manufacturers' costs. But th is is a third

- party 5


### independent way of assessing things that might 6


### help with perception. Thanks. 7



### MR. HAGERMAN: We have reached out. We 8


### just haven't heard back. 9


### MR. LUBLINER: Okay. Thanks. 10



### MR. RAMIREZ: Eric? 11



### MR. HAGERMAN: And we welcome other 12



### members to reach out to other sources, too. I 13


### mean, any data that you can provide us helps all 14



### of us. 15


### MR. RAMIREZ: But the sooner you get it, 16


### the sooner it can be plugged in and then out to 17


### you all for review. So. 18


### Eric? Mark, and then Lois. 19



### MR. WEISS: I was just going to ask, when 20


### Navigant does that analysis, just indicate what 21


### public sources you're looking at. Thank you. 22403

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### MR. RAMIREZ: Thank you. 1



### Lois? 2


### MS. STARKEY: I'd like to suggest that 3


### once we get the information from DOE, that 4


### perhaps I can get with Em anuel and the 5


### manufacturers and we can take this and put it 6


### into another straw man, based on everything that 7


### we've talked about that would include zones, U 8


### values, you know, prescriptive requirements, duct 9


### leakage, all of the components

-- 10



### MR. RAMIREZ: Y ou're talking about a full 11


### package? 12



### MS. STARKEY:

-- of a package, a draft 13


### term sheet, very draft, just to throw out. 14


### Because I think we just need something on the 15


### table that we can just mark up. Not with any, 16


### you know, this is our proposal, just somethi ng 17



### that we can

-- 18


### MR. RAMIREZ: That's what a straw man, 19


### technically, is. 20



### MS. STARKEY: Yeah. Yeah. 21



### MR. HAGERMAN: I think we're at the third 22404

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### step of grieving. We're at the third phase. 1


### (Laughter.) 2



### MR. HAGERMAN: So we welcome whatever 3



### materials the mem bers can produce to help, you 4


### know, move that conversation along. I mean, 5


### we're very thankful of ya'll's time, your 6


### participation, your comments, all the data you 7


### have provided, the discussion. We're very 8


### thankful for all of that, right? 9



### And we think we' re at the cusp here of 10


### closing it out and getting to a term sheet. But, 11


### you know, at the end of next week we'll 12


### reevaluate whether or not we need the meeting in 13



### Golden. 14


### MS. DICKENS: So don't book your flights 15


### yet. Is that what you're saying? 16



### MR. HAGERMA N: I wouldn't necessarily 17


### book your flight yet because, I mean, if we get 18


### to the end of next week and, you know, we're not 19


### there, I'm sort of thinking we need to just go 20


### back to ASRAC and say, you know, we did our best, 21


### we just couldn't get there. 22405

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### MS. DIC KENS: Okay. 1


### MR. HAGERMAN: So, I mean, that's my 2


### personal opinion, and I think that

-- you know, I 3



### don't want to

-- I'm very conscious of your time 4


### and your effort. I don't want to necessarily 5


### waste your time. And if we just have a couple of 6



### more meeti ngs, are we going to get to closure? 7


### You know, I'm a little bit unknown at this point 8



### in time. 9


### MR. RAMIREZ: So, my interpretation is 10


### we're beyond the wish list, right? And let's

-- 11


### so, Lois, when you're working with Emanuel, put 12


### something out there that

-- and I think there has 13


### been enough dialog, right, where you kind of have 14


### an idea of where the poisoned pills are, and see 15


### if we can't get close to hitting that target, 16


### with no ownership, right, no wing tips. 17


### MS. STARKEY: Emanuel, does that sound 18


### good t o you? 19



### MR. LEVY: Yeah. 20


### MR. RAMIREZ: Great. Great. Okay. 21


### And then, there may be a procedural 22406

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### question. Good? Okay. 1


### MR. HAGERMAN: So, just so

-- Kavita just 2


### asked me if we got the extension. John Cymbalsky 3


### has been out. It's my understanding he's a sked 4


### the ASRAC members for extension, and I've seen a 5


### lot of them pull back saying, "Yes, I don't see a 6


### problem there." But I'll reconfirm that we did 7


### get the extension. 8


### And when we do get the extension 9


### formally, we have to quickly put out our Federal 10



### Reg ister notes. So you'll see all that 11


### materialize within, you know, the next couple of 12


### days. 13


### MR. RAMIREZ: So, just to recap, it looks 14


### like we're going to be getting some additional 15


### reports. We'll get them by Thursday of next 16



### week. And then

-- 17



### MR. HAGERM AN: This week. Thursday of 18



### this week. 19



### (Cross

- talk.) 20


### MR. RAMIREZ: I'm sorry. Thursday of 21



### this week. Robin's rubbing off on me, sitting 22407

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### too close to him. 1


### (Laughter.) 2


### MR. RAMIREZ: And then, once we get those 3


### reports, then Lois and Emanuel and the 4



### manufa cturers are going to get together and try 5


### to put together a straw men. 6



### We will also continue with the 2015 IECC 7


### report that Manny has. But you all have that 8


### one, right? You kind of have a feel for how 9


### that's going so you could use that when you're 10



### develo ping the straw man. 11


### And then, next week, we're going to have 12


### to start making some decisions, right? Climate 13


### zones, compliance paths, and then analyzing the 14



### straw man. 15


### MR. HAGERMAN: I would just like to put 16


### on the table, too, I think you framed it up 17



### corr ectly. Next week, we have to make some 18


### decisions. And the decisions, in my mind, are 19


### one of two things. One is, everything you just 20


### said in terms of finding a term sheet, and

- or the 21



### decision whether or not we need to continue as a 22408

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### group. Right? Whethe r we think that one 1


### additional meeting will get us to closure or not, 2


### right? And that's just the decision we're going 3



### to have to make as a group. 4


### MR. RAMIREZ: Okay. So we'll make sure 5


### that we incorporate time for that in the agenda 6



### to have that discussi on and not just 30 minutes 7


### at the end of the day. 8


### MR. LEVY: Javier, can I just throw one 9


### certainly unpopular suggestion? We have a 10


### meeting scheduled for October 1

- 2, correct? 11



### MR. RAMIREZ: Yeah. That's the one for 12



### next week. 13



### MR. LEVY: That's the one ne xt week. You 14


### know, it's unfortunate we don't have that the 15


### 8th, one week later than that, you know, so 16


### there's two weeks between now and then, and 17



### another two weeks before then and the Golden 18


### meeting. 19


### Because I think what we need by the next 20


### meeting, the next step together is something 21


### pretty complete in order to be sure that Golden 22409

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### is going to close things out. It's not possible 1


### to move that meeting date, is it? 2



### MR. LUBLINER: Not for me. 3



### MR. LACEY: It's not for me. 4


### MR. HAGERMAN: But also, I think, you 5


### know, unfortunately, I think it is what it is, 6


### and I think it's good that we continue. And then 7


### next week, if we need another meeting, we can do 8


### it. We can try to schedule 11R or something like 9


### that. I just think we've got to keep on. I 10


### mean, I think that, unfortunately, you've got two 11


### weeks of work to do in a week, just like we did. 12



### (Pause.) 13


### MR. RAMIREZ: I think maybe at this point 14


### it might be

-- 15


### MR. HAGERMAN: I think you're really 16


### close, though, Emanuel, to be honest with you. I 17


### think that, you k now, the working group members 18


### outside of us have done just a really good job of 19


### getting together and working. And what we've 20


### seen in the discussions today, even though 21


### they've been painful, right? I mean, I think 22410

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### we're seeing some positive direction. I think we 1


### can see a horizon now, right? 2


### I would think. I mean, I don 't think 3


### we're far off. I mean, nobody really said too 4


### much complaining when we looked at the life cycle 5


### and looked at the numbers and the savings. I 6


### mean, sure, we have some problems i n a couple of 7


### climate zones, but I feel like we're in the 8


### ballpark, right? 9


### MR. RAMIREZ: Logistically, I think that 10


### it has been a heavy lift. And, Emanuel, I know 11


### that you've been putting in a lot of time and 12


### resources into the research, and Lois, as well , 13


### and quite a few other committee members have 14


### really been putting in a lot of time and effort. 15



### And I understand that next week seems 16


### awfully tight. For where we're at, 17


### unfortunately, it probably does seem like we're 18


### going to have to do a little bit more homework 19


### and just try to push it and make this final push 20


### and see if it does, if we can get an agreement or 21



### if it makes sense to meet that last time. 22411

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### But I think to try to rearrange 1


### everyone's schedules at this last minute for next 2


### week, I think would be a challenge. 3


### MR. LEVY: I certainly appreciate that. 4


### Unfortunately, I can't physically be there; I'll 5


### be in California. But I will be calling in. 6


### You know, you're right. We'll do what we 7


### can do. And if we don't get it done, we'll still 8



### have those decisi ons we need to make and perhaps 9



### have another one

- day meeting, or whatever is 10


### required before the Go lden meeting. Yes. Sounds 11



### fine

. 12


### MR. RAMIREZ: All right. Anything else 13



### before we close out? 14


### MS. DICKENS: Well, I'm hoping I won't 15


### see you in Golden, beca use I'm hoping we'll be 16


### done by then. 17


### (Laughter.) 18


### MR. RAMIREZ: Okay. Yeah, we did the 19


### public comment when you were gone. We wanted to 20


### see how much time we were going to have. 21


### MR. LUBLINER: I just want to thank the 22412

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### facilitators and all the people that h ave been 1


### making this ship float here, everybody, including 2


### the team. I mean, I've been in a lot of public 3


### consensus standards meetings and stuff. And 4


### they're grueling. But I think you guys , I'm 5


### impressed with the quality of the turnaround and 6


### the qualit y of the dialog. So, thank you. 7


### MR. RAMIREZ: Yeah, it's been a real team 8


### effort. So, thank you, everyone. 9


### All right. We'll see you all next week, 10


### or hear you next week, depending. 11


### (Proceedings adjourned at 5 :0 3 p.m.) 12

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22413

1 

### CERTIFICATE OF NOTARY PUBLIC

2 

### I, Brian Knieser, Notary Public in and

3 

### for the District of Columbia, the officer before

4 

### whom the foregoing testimony was taken, do hereby



### s certify that the testimony which appears in the

6 

### foregoing transcript was taken by me and

7 

### thereafter reduced to typewriting under my

8 

### direction; that said testimony is a true record

g 

### of the testimony given; that I am neither counsel

10 

### for, related to, nor employed by any of the

11 

### parties to the action in which this testimony is

12 

### taken; and, further, that I am not a relative or

13 

### employee of any of the parties hereto, nor

14 

### financially or otherwise interested in the



### 1s outcome of the action.

16

17

18

19 

### BRIAN KNIESER

20 

### Notary Public in and f or

21 

### The District

22 

### Commission Expires: 03.14.2019