1

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1 U.S. Department of Energy

2

3

4

5

6 Manufactured Housing Working Group

7

8

9

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

11 Tuesday, September 23, 2014

12

13 1000 Independence Avenue, S.W.

14 Washington, D.C. 20585

15

16

17

18

19

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2

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1 APPEARANCES

2

3 TED BANTLE, Federal Mediation

4 JAVIER RAMIREZ, Federal Mediation

5 JOSEPH HAGERMAN, DOE

6 RICHARD MENDLEN, HUD

7 ROBERT LUTER, Lippert Components

8 STACEY EPPERSON, Next Step

9 MARK EZZO, Clayton Homes

10 RICK HANGAR, State of Colorado

11 BERT KESSLER, Palm Harbor

12 EMANUEL LEVY, SBRA

13 PETER SCHNEIDER, Efficiency Vermont

14 MANUEL SANTANA, Cavco Industries, Inc.

15 ERIC LACEY, Responsible Energy Codes Alliance

16 ISHBEL DICKENS, NMHOA

17 LOWELL UNGAR, ACEEE

18 MARK WEISS, MHARR

19 DAVID TOMPOS, MTA

20 LOIS STARKEY, the Manufactured Housing Institute

21 MICHAEL LUBLINER, Washington State University

22 ROBIN ROY, Natural Resources Defense Council
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1 APPEARANCES (Cont'd)

2

3 RICHARD POTTS, Virginia DHCD

4 MATTHEW WALKER, Navigant

5 EDWARD BARBOUR, Navigant

6 KAVITA VAIDYANATHAN, DOE General Counsel's Office

7 BRIAN SLOBODA, NRECA

8 KEITH DENNIS, NRECA

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20

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22 P R O C E E D I N G S
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1 MR. BANTLE: Good morning, everybody. 

2 This is Ted Bantle with Federal Mediation. I 

3 just want to get started today.

4 Like yesterday, we are going to start off 

5 with any introductions from members of the public 

6 that are in the room.

7 MR. MENDLEN: Rick Mendlen with HUD.

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

9 to public comment after these introductions.

10 Okay. Any GoToMeeting participants? 

11 Who's on the GoToMeeting?

12 (Pause.) 

13 MR. LUTER: Rob Luter with Lippert 

14 Components.

15 MR. BANTLE: Yeah, members.

16 MS. EPPERSON: Stacey Epperson with Next 

17 Step.

18 MR. EZZO: Mark Ezzo, Clayton Homes.

19 MR. HANGAR: Rick Hangar, State of 

20 Colorado.

21 MR. KESSLER: Bert Kessler, Palm Harbor.

22 MR. LEVY: Emanuel Levy, SBRA.
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1 MR. BANTLE: Yeah, who was the last one? 

2 I apologize.

3 (Pause.) 

4 FEMALE VOICE: Bert Kessler.

5 MR. HAGERMAN: So, we heard Bert Kessler 

6 from Palm Harbor. We heard Richard Hangar, and 

7 then we also heard Emanuel Levy.

8 MR. BANTLE: And Stacey Epperson.

9 MR. HAGERMAN: Mark Ezzo, Rob Luter.

10 MR. BANTLE: Are there any other working 

11 group members on the line?

12 (Pause.) 

13 MR. BANTLE: Okay. Any members of the 

14 public on the conference line?

15 MR. SCHNEIDER: This is Peter Schneider. 

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

17 MR. BANTLE: No problem. Good morning, 

18 Peter.

19 One final call for working group members 

20 or public on the line?

21 (Pause.) 

22 MR. BANTLE: Okay. We will go around the 
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1 table next with the working group members. We'll 

2 start with Manny.

3 MR. SANTANA: Manny Santana, Cavco Homes.

4 MR. LACEY: Eric Lacey, Responsible 

5 Energy Codes Alliance.

6 MR. HAGERMAN: Joe Hagerman, DOE.

7 MS. DICKENS: Ishbel Dickens, National 

8 Manufactured Homeowners Association.

9 MR. UNGAR: Lowell Ungar, American 

10 Council for an Energy Efficient Economy.

11 MR. WEISS: Mark Weiss, Manufactured 

12 Housing Association for Regulatory Reform.

13 MR. TOMPOS: Dave Tompos, MTA.

14 MS. STARKEY: Lois Starkey, the 

15 Manufactured Housing Institute.

16 MR. LUBLINER: Mike Lubliner, Washington 

17 State University Extension Energy Program.

18 MR. ROY: Robin Roy, Natural Resources 

19 Defense Council.

20 MR. POTTS: Richard Potts, Virginia 

21 Department of Housing and Community Development.

22 MR. WALKER: Matthew Walker, Navigant.
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1 MR. BARBOUR: Ed Barbour, Navigant.

2 MS. VAIDYANATHAN: Kavita Vaidyanathan, 

3 DOE General Counsel's Office.

4 MR. RAMIREZ: And Javier Ramirez, Federal 

5 Mediation.

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

7 that we have for today. It was modified from 

8 yesterday since we had a lot of dialog on the 

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

10 then we'll see if there's any additional comments 

11 from working group members.

12 And then we're going to continue our 

13 discussion on the cost data. There were a number 

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

15 possibility that we could reach consensus on. So 

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

17 Then we have the subcommittee reports, 

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

19 then go to David on manufacturing, Manny with the 

20 2015 IECC mandatory components, and then Rob Roy 

21 with affordability.

22 Hopefully, at some point, before we leave 
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1 today, see if we could take any additional 

2 action. See if we could agree on which climate 

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

4 one, two, three, or -- and if you want to go down 

5 the path of multiple products, is that something 

6 that we need to figure out before we go? 

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

8 So, any questions on the agenda?

9 (Pause.) 

10 MR. RAMIREZ: All right. Then comments 

11 from the public.

12 Rick, I believe you had some comments?

13 MR. MENDLEN: I do.

14 MR. RAMIREZ: And thank you for deferring 

15 yesterday and letting everyone go. So the floor 

16 is yours.

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

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

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

20 been done to date and the commitment that the 

21 members have had to the work and the ability of 

22 the facilitators you have here and the others to 
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1 keep the work on track.

2 However, I'd also like to remind the 

3 group, as Joe Hagerman did yesterday, and one of 

4 our HUD's regulatory partners, Richard Potts, 

5 that time is beginning to become of the essence 

6 in completing your task.

7 I would recommend that you look at trends 

8 in the life cycle cost results, which indicate 

9 that the proposals for the water climate zones 

10 appear to be excessive, and proposals for the

11 colder climate zones appear to be appropriate or 

12 may need some tweaking.

13 There are so many variables in the 

14 assumptions that impact the data from degree day 

15 selection for the cities chosen in the analysis, 

16 the climate zone assumptions, the fuel type 

17 distribution, the mortgage period and type, not 

18 to mention consumer preferences for thermostat 

19 settings that all impact energy consumption and 

20 cost.

21 I'm going to spend the weekend in 

22 Charlottesville with my friends, who typically 
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1 set their thermostat at 60 degrees, and it 

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

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

4 going to be with my mother-in-law, who sets the 

5 thermostat at about 80 degrees. So consumer 

6 preferences on this is also a variable all this 

7 analysis doesn't take into account.

8 I also wanted to remind you that both DOE 

9 and HUD economists will need to prepare a 

10 regulatory impact analysis on whatever is finally 

11 agreed to. And I'm reasonably confident that 

12 they will express the costs and benefits in terms 

13 of ranges of costs and energy savings and suggest 

14 that you begin to think in those types of terms 

15 as well.

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

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

18 the reasons I just stated before, in the analysis 

19 being done.

20 From my observations and perspective, the 

21 work appears to be bogged down in the weeds in 

22 trying to make adjustments to make the numerous 
11

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1 PNNL and Navigant data runs support the initial 

2 assumptions, which is not always the case.

3 With regard to the two-tier regulatory 

4 approach, I've already spoken out against the 

5 concept, but would recommend that you consider a 

6 single regulatory approach and make suggestions 

7 for upgrading the current ENERGY STAR program on 

8 a voluntary basis as a second product type or 

9 tier.

10 HUD is also concerned about other things 

11 just other than energy consumption and quality 

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

13 and durability and livability not being 

14 compromised. And for example, I understand that 

15 certain window requirements being considered 

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

17 window requirements, and suggest for that that a 

18 weighted average be used to meet those criteria.

19 Also, Rob, your subcommittee is proposing 

20 a 7 percent glazing approach, which is below the 

21 8 percent minimum for livability in the HUD 

22 standards. I want to tell you, when I started 
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1 with that, it was 10 percent. And it was reduced 

2 to 8 later on.

3 Discussions on compliance and testing are 

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

5 an agreement as to how enforcement is going to be 

6 handled.

7 I also wanted to comment briefly about 

8 some of Mike's comments yesterday with regards to 

9 compliance testing. I'm reasonably confident, as 

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

11 compliance testing on air leakage, whole-house 

12 air leakage, for some period to allow 

13 manufacturers to become familiar with testing 

14 procedures.

15 There was also a reference yesterday by 

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

17 standards. And while that was true at the onset 

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

19 primarily on public comment and the Manufactured 

20 Housing Consensus Committee to develop 

21 recommendations for the standards. And that's 

22 why HUD does intend to consult with the MHCC with 
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1 regard to whatever standards are recommended by 

2 the DOE.

3 And finally, if you have any questions 

4 about the HUD standards and program, please feel 

5 free to call upon me.

6 I've tried to obey the ground rules, 

7 Javier, that you set out about not speaking 

8 during the meeting unless called up. But I 

9 assure you it's been difficult at times.

10 MR. RAMIREZ: Thank you.

11 MR. MENDLEN: Thank you.

12 MR. RAMIREZ: All right. Thank you, 

13 Rick.

14 Any other comments from working group 

15 members?

16 (Pause.)

17 MR. RAMIREZ: Go ahead.

18 MR. LUBLINER: Thanks, Rick. I 

19 appreciate your participation and your comments.

20 MR. RAMIREZ: Okay. Go ahead.

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

22 couple of questions for Rick. Would it be 
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1 appropriate to follow up from his comments? So 

2 let me do that first, I guess.

3 You said, one was that you believe that 

4 some window requirements that are under 

5 consideration would not allow for egress? Could 

6 you --

7 MR. MENDLEN: It would not allow for the 

8 operating force to be met.

9 MR. UNGAR: That a window that met the 

10 egress requirements could not also meet which? 

11 Which requirements?

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

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

14 will not meet the -- will not allow the operating 

15 force requirements in our standards to be met. 

16 It would take too much force to operate it. 

17 That's according to information that I was 

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

19 the phone or not and can speak to that.

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

21 This has to do with the consideration of one 

22 element of the IECC that could virtually affect 
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1 operating force. I think that will be part of 

2 Manny's report later today.

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

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

5 MR. LUTER: That is correct.

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

7 quite figure out what the connection was. But 

8 that's fine. Thanks.

9 MR. LUTER: Understandable.

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

11 so I'll defer it.

12 My own comment was that I think yesterday 

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

14 which I think produced some very good information 

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

16 consense on life cycle cost analysis. We need to 

17 consense on the standard.

18 I think it's worth keeping in mind that 

19 even if we came to consensus on the assumptions,

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

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

22 in itself would yield consensus on a standard.
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1 I think this is very useful information. 

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

3 there's a point at which if we don't agree on the 

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

5 fine. Each person can take the information for 

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

7 We need in the end to decide on a 

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

9 this at one point yesterday, and we never did 

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

11 great to talk about the cost, but in the end, 

12 what are their numbers in terms of the standard, 

13 not in terms of the analysis that people can live 

14 with?

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

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

17 some point we can get to that and really discuss 

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

19 but for a standard that we can live with.

20 MR. RAMIREZ: Mark?

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

22 initial meeting, I think it was the initial 
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1 meeting, when OGC opined that it was up to us to 

2 define "affordability" for purposes of our 

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

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

5 this type of analysis we had yesterday from 

6 determining what would be the appropriate 

7 standard. I think the statute requires that.

8 Javier, I understand your concern about 

9 moving forward and not getting bogged down in the 

10 weeds. But affordability is an essential element 

11 of what we're doing.

12 MR. MENDLEN: That was me about the 

13 weeds.

14 MR. RAMIREZ: Any other working group 

15 members?

16 Mark?

17 MR. WEISS: I do have one clarification. 

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

19 do have one clarification for yesterday. I 

20 referenced some of the AHS numbers, the American 

21 Housing Survey. And I neglected to mention that 

22 the numbers I was talking about were all the 
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1 median numbers from that chart.

2 MR. RAMIREZ: All right. Then any other 

3 comments from working group members?

4 (Pause.)

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

6 we had left off with some conversation with the 

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

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

9 between now and then to have some additional 

10 discussion on that to bring back any information.

11 But what do you want to do with -- let's 

12 start off with the pipes, because it seemed like 

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

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

15 let you resume your discussion on the pipes as 

16 far as insulating the -- we're talking about R3 

17 or pipes of all three-quarter or larger and 

18 outside of conditioned space regardless of size, 

19 and from water heater to distribution point, from 

20 water heater to distribution point.

21 (Pause.)

22 MR. SANTANA: Manny with Cavco.
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1 You know, I'll start off by identifying 

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

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

4 requires, it requires an insulation of R3 for 

5 settling conditions, one of which is -- and the 

6 way that I read it, it's all pipe three-quarter 

7 of an inch or larger, all hot water pipe three8 quarter of an inch or larger, and all pipe -- all 

9 hot water pipe outside of the conditioned space.

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

11 inside the conditioned space and is three12 quarters of an inch or larger, if it's exempt 

13 from the insulation.

14 I don't have a problem with insulating 

15 the pipe that's outside of conditioned space. 

16 But when it gets inside of conditioned space, 

17 that's when I start raising my opposition to it, 

18 because, you know, you have constructability 

19 concerns. You know, you have pipes that run 

20 through walls. You have pipes that run through 

21 joists.

22 You know, what do you do? Does the 
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1 insulation have to follow the pipe? Can it butt 

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

3 costs of the insulation itself isn't -- I don't 

4 think it's any significant, the costs of -- or 

5 not the cost, but the effort to implement it 

6 versus the benefits gained if it's in conditioned 

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

8 MS. DICKENS: So I was looking for --

9 this is Ishbel, Manufactured Homeowners 

10 Association.

11 I was just looking for the definition of 

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

13 MR. SANTANA: Yeah, it is.

14 MS. DICKENS: It is? Somewhere. Okay.

15 (Pause, inaudible conversation.)

16 MR. LACEY: This is Eric. Maybe to 

17 streamline this and figure out something that 

18 works, would it be acceptable to carve out an 

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

20 passes through a framing member, for example? So 

21 you could insulate up to the framing member and 

22 not have to cut out a giant hole to include both 
21

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1 the pipe and the insulation?

2 I think there are purposes for insulating 

3 the pipes even within the conditioned space. 

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

5 loads in there that remain warm for a certain 

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

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

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

9 to wait as long for the warm water to come 

10 through because there will still be some warm 

11 water in there.

12 MR. SANTANA: Right. I understand. I 

13 understand that.

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

15 is there a way to maybe clarify this? Because 

16 obviously, this section is not entirely clear on 

17 what you do with pipes inside conditioned space 

18 and pipes that are inside other insulation. I 

19 mean, we talked about that briefly yesterday.

20 Maybe you carve out an exception for 

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

22 scenarios. If there's other insulation, then 
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1 it's at least R3 on either side of it, you know, 

2 you attempt to -- or is there still some value in 

3 insulating around the pipe? And unfortunately, 

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

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

6 Manny again.

7 And that's the reason why -- so the 

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

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

10 saved if we insulate the pipe that's in 

11 conditioned space? Even if we take into 

12 consideration not having to insulate when it goes 

13 through a framing member, you know, is there any 

14 -- you know, is that quantifiable?

15 Because if we're talking about the water 

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

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

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

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

20 substantial enough to, you know, warrant 

21 insulating the pipe throughout the entire house.

22 MS. DICKENS: I'm sorry. This is Ishbel, 
23

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1 Manufactured Homeowners Association.

2 So, yesterday, I heard a number of, I 

3 think a very conservative $50 was what it was 

4 going to cost to do this insulation. If the 

5 amount of energy, cost of the energy saved is 

6 $25, it seems like a no-brainer that you would do 

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

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

9 I feel like we should be able to get to 

10 consensus on this fairly quickly, because it 

11 seems like just a math problem as much as 

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

13 that number of what's saved.

14 MR. RAMIREZ: Let me get Keith and 

15 Michael.

16 MR. DENNIS: I recently renovated my 

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

18 that you could insulate the water pipes in the 

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

20 actually researched it.

21 And there was -- the way that the draw 

22 patterns work with water, you tend to use a lot 
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1 and then you don't use it. And if you had an R3 

2 insulation in it, R3 conditioned space, my 

3 understanding is that you wouldn't really gain 

4 anything and that I shouldn't be worried.

5 I was sufficiently, you know, going from 

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

7 You know, they didn't insulate my pipes, just PEX 

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

9 energy. Why am I turning my shower off? Like, 

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

11 necessary.

12 Because when it's in the line and you 

13 stop using the fixture for a certain amount of 

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

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

16 even at $50 it would be overkill.

17 I mean, you know, it's in conditioned 

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

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

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

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

22 you're going to want to maintain that heat in 
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1 that pipe that's in the wall for so long. It's 

2 not that big a deal.

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

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

5 conditioned space, I see that. But mostly 

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

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

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

9 it's worth.

10 And I talked to people who have studies 

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

12 decide, try to maximize these things. There are 

13 at the AC triple-E hot water forum will be there, 

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

15 and can get that information.

16 MR. RAMIREZ: Manny had raised some 

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

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

19 to apply this? So, hearing some of the 

20 discussion in here that the real savings on this 

21 even though it is a very low-cost item, 

22 potentially, right, because depending on if you 
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1 have to make the bigger hole and things like 

2 that.

3 Does somebody have a recommendation on 

4 what we could gauge consensus on?

5 Manny?

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

7 we insulate all hot water pipe outside of 

8 conditioned space. That should be easy enough 

9 for everybody.

10 MR. LACEY: Regardless of size.

11 MR. SANTANA: Regardless of size.

12 MR. RAMIREZ: David?

13 MR. TOMPOS: Based on this definition of 

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

15 yesterday, insulate -- right now we're insulating 

16 the underside of the belly. And to get more 

17 insulation to meet some of these requirements, 

18 we're going to have to put insulation above that.

19 There's heat ducts that typically have 

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

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

22 they fix service problems by using a fiberglass 
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1 heat duct in the belly. But that's where those 

2 pipes are running.

3 But if I read this, spaces -- they're 

4 trying to define conditioned -- it says, "Spaces 

5 are indirectly heated or cooled, or they 

6 communicate through openings with conditioned 

7 spaces where they are separated from conditioned 

8 spaces by uninsulated walls, floors, or 

9 ceilings."

10 So as soon as I insulate that floor above 

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

12 unconditioned space, even though I have 

13 insulation below it.

14 MR. SANTANA: Conditioned space.

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

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

17 longer communicating with the conditioned space 

18 because you have insulation directly in contact 

19 with the floor now.

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

21 again, going to section 2 --

22 MR. TOMPOS: Section 2 of what?
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1 MR. SANTANA: Chapter 2 of the IECC, 

2 right, where everything is defined. And the 

3 definition for "conditioned space" -- I'll read 

4 the whole thing.

5 MR. TOMPOS: Are you looking at the 

6 commercial or the original?

7 MR. SANTANA: No, the original part.

8 MR. TOMPOS: Okay. 

9 MR. SANTANA: Yeah.

10 MR. TOMPOS: R7, correct?

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

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

13 or space that is enclosed within the building 

14 thermal envelope and that is directly or 

15 indirectly heated or cooled. Spaces are 

16 indirectly heated or cooled, one" -- and I added 

17 the "one" -- "where they communicate through 

18 openings with conditioned spaces;" -- "two," I 

19 added -- "where they are separated from 

20 conditioned space by uninsulated walls, floors, 

21 or ceilings, and three, or where they contain 

22 uninsulated ducts, uninsulated piping, or other 
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1 sources of heating and cooling."

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

3 definition and the way that manufactured homes 

4 are typically constructed, you have the belly, 

5 and then you have insulation, and then you have 

6 an uninsulated duct. So by the definition of 

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

8 a conditioned space.

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

10 uninsulated space. A lot of manufacturers are 

11 using insulated fiberglass.

12 MR. SANTANA: Oh, no. Because you have 

13 an uninsulated duct. If you have an insulated 

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

15 MR. TOMPOS: But that fiberglass is still 

16 insulated. I mean, the only time I would 

17 consider it an uninsulated duct would be your 

18 metal duct run.

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

20 referring to, yeah.

21 MR. TOMPOS: A lot of manufacturers are 

22 using --
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1 MR. SANTANA: You have an uninsulated 

2 duct, then that's a conditioned space.

3 MR. TOMPOS: Okay. 

4 MR. RAMIREZ: Let me get Michael, then 

5 Eric.

6 MR. LUBLINER: My understanding is that 

7 we should be considering all of the things in 

8 that I-codes, and this is one of them.

9 And I thought in the spreadsheet analysis 

10 there was an estimate of cost for pipe insulation 

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

12 said, kind of focus -- if we're going to focus at 

13 all on this, look at that and decide.

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

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

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

17 you do crossovers in attics, but if you do, 

18 doesn't the code already in the installation 

19 manual and the setup code require that all those 

20 crossover pipings be insulated?

21 MR. MENDLEN: Yes.

22 MR. LUBLINER: So that means that we're 
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1 voting on something that's already code. Why are 

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

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

4 it's in the conditioned space or not.

5 MR. MENDLEN: Right.

6 MR. LUBLINER: I find it --

7 MR. MENDLEN: I thought you were talking 

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

9 MR. LUBLINER: The ducts or the crossover 

10 pipe?

11 MR. MENDLEN: The crossover ducts are 

12 required to be insulated.

13 MR. LUBLINER: But the piping for freeze 

14 protection is not required by HUD? 

15 MR. MENDLEN: Not specifically.

16 MR. SANTANA: You're required freeze 

17 protection. That's a heat-tape reset. But just 

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

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

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

21 there's no insulation that I --

22 MR. MENDLEN: You got heat tapes.
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1 MR. LUBLINER: So, you have a heat tape 

2 on the crossover with no insulation on the pipe. 

3 And that's acceptable in the installation manual?

4 MR. SANTANA: I have to double-check 

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

6 MR. LUBLINER: I would argue that the 

7 heat tape should be looked at more importantly 

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

9 case.

10 MR. SANTANA: That might be the case. 

11 But going back to this --

12 (Cross-talk.)

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

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

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

16 on one facet of it, and then we can -- you know, 

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

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

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

20 What do we need to agree on? It seems 

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

22 right? One question is, if the pipe is running
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1 -- this is my interpretation of you all's dialog 

2 here. If the pipe is running through the belly 

3 insulation, is it in conditioned space or not 

4 conditioned space?

5 I would argue that that's inside 

6 conditioned space. It's insulated, right?

7 MR. SANTANA: Right.

8 MR. HAGERMAN: It's insulated with belly 

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

10 wouldn't need to go put more insulation there. A 

11 reasonable person, I think, would conclude that, 

12 right?

13 So is that the first thing we need to 

14 decide?

15 MR. SANTANA: I think the first thing we 

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

17 hot water pipe outside the conditioned space have 

18 insulation?

19 MR. LUBLINER: I think we all decided 

20 that. I think that's reasonable.

21 (Cross-talk.)

22 MR. RAMIREZ: Are there any objections to 
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1 that? That pipes outside of conditioned space be 

2 insulated?

3 MR. LUBLINER: I just have a 

4 clarification question.

5 MR. RAMIREZ: But, so we're good? All 

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

7 unanimous.

8 And any objections on the phone?

9 (Pause.) 

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

11 clarification question?

12 MR. LUBLINER: Yeah, I was just 

13 wondering. This gets back to the heat tape, 

14 which is something that's used regularly in 

15 Northern climates to keep pipes from freezing in 

16 the crossover duct.

17 MR. SANTANA: Yeah.

18 MR. LUBLINER: So, if we insulate -- if 

19 we all agree that the crossover needs to be 

20 insulated, then what do you do with the heat 

21 tape?

22 MR. SANTANA: Don't know.
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1 MR. LUBLINER: You what?

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

3 another issue. The heat tape is to provide 

4 protection against freeze, right? Insulation is 

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

6 it's going to protect against freezing as well. 

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

8 So there's two separate issues here, 

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

10 be insulated, this section only refers to hot 

11 water pipe. The freezing concern is on all pipes 

12 that have water.

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

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

15 insulation a lot of times in condo buildings. 

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

17 means. They wrap the heat tape on the pipe. 

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

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

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

21 So I don't know if you can get -- I don't 

22 know if you should, to be honest with you, get 
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1 rid of that provision in real extreme conditions, 

2 because there is that loss. There is that chance 

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

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

5 there.

6 MR. SANTANA: You know, and that --

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

8 this is Mark Ezzo.

9 I found the section in the HUD standards, 

10 installation standards that talks about this. It 

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

12 exposed sections of water supply piping, shut-off 

13 valves, pressure reducers, and pipes must be 

14 insulated or otherwise protected from freezing.

15 MR. SANTANA: Freezing, freezing.

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

17 think that gets to Mike Lubliner's questions 

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

19 for water line crossovers, we've got, the HUD 

20 setup standards give you two choices. One, you 

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

22 heat tape.
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1 And then I looked in -- now I don't know 

2 if everybody's installation manual says this. 

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

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

5 it says, "Wrap water lines with insulation or 

6 otherwise protect to prevent from freezing."

7 So I guess bottom line with that is it 

8 gives us two options today about how to protect 

9 those crossover lines during installation.

10 My recommendation would be for our energy 

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

12 install the hot water line in a conditioned 

13 space, or you protect it with R3 insulation. 

14 That would be my recommendation.

15 MR. RAMIREZ: Well, let's see a show of 

16 thumbs on that.

17 (Pause.) 

18 MR. EZZO: Pardon me?

19 MR. RAMIREZ: I'm gauging consensus on 

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

21 David has a question.

22 MR. TOMPOS: I just have a question.
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1 MR. RAMIREZ: Yeah.

2 MR. TOMPOS: I still think we need to 

3 define "conditioned space," because let me give 

4 you an example. Let's say we put a -- this 

5 doesn't exist, I don't think -- but an R4 down. 

6 And we put those cold and hot water pipes under 

7 that. Now we have all the other insulation that 

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

9 insulation is between the conditioned space and 

10 this little section of air where the piping runs.

11 I'm going to have all kinds of service 

12 problems because all my pipes are going to freeze 

13 all the time. So, at what level of insulation do 

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

15 read this definition, it says that that 

16 conditioned space has to have communication with 

17 the living area and have uninsulated floors.

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

19 I just want to make the point that I'm not 

20 convinced that that area where we're putting 

21 these pipes is conditioned space, because you 

22 don't know -- you're going to have pipes 
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1 freezing. So I think there's going to be a 

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

3 In my opinion, I think we should put the 

4 insulation on all the pipes, conditioned or 

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

6 just wanted to clarify my position on whether or 

7 not that area in the belly is conditioned space 

8 or not.

9 MR. TOMPOS: Well, it's Dave.

10 Today those water lines aren't freezing.

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

12 insulation above them.

13 MR. SCHNEIDER: This is Peter Schneider 

14 from Efficiency Vermont.

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

16 disagree with that last statement, which is these 

17 pipes are not breathing, because they are 

18 breathing. And I have plenty of homeowners in 

19 Vermont in manufactured, uncertified homes that 

20 run their water --

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

22 quick. You started off strong, but then you 
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1 tailed off there. I don't know if maybe you need 

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

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

4 that for us?

5 MR. SCHNEIDER: I can call in on my 

6 phone. Is that any better?

7 (Cross-talk.)

8 MR. RAMIREZ: Yeah, yeah, yeah.

9 MR. SCHNEIDER: Yeah. So I was just 

10 saying that I certainly wouldn't consider, for 

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

12 shown year after year in Vermont, particularly 

13 last winter, where we had plenty of pipes 

14 freezing in, you know, relatively new HUD15 certified manufactured homes.

16 In addition, I consider, you know, a 

17 conditioned space to have an air barrier aligned 

18 with the thermal envelope. And in my opinion, 

19 there's no air barrier associated with the belly 

20 of a typical manufactured home that has the ducts 

21 and the piping in the belly, even above that 

22 compressed batt insulation that's exposed to 
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1 outside conditions.

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

3 things where it's not a one-size-fits-all? And 

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

5 to be clear that it has to be insulated?

6 MR. LUTER: This is Robert at Lippert.

7 Just an observation. We're discussing 

8 whether or not this belly area is conditioned or 

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

10 it doesn't communicate with the conditioned 

11 space.

12 But it does have insulation that we're 

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

14 it's not conditioned space and the belly 

15 insulation does not serve to satisfy the pipe 

16 insulation requirement.

17 MR. RAMIREZ: Okay. Eric?

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

19 potential compromise. I looked at the Washington 

20 State University Extension Energy Program 

21 website. And there was a code interpretation by 

22 the state building code council on this subject. 
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1 And I wanted to see if maybe this would work as a 

2 sort of compromise to address the issues raised 

3 here.

4 The insulation is allowed to be 

5 discontinuous when it passes through wall studs, 

6 floor joists, or other structural members -- this 

7 is something we talked about -- provided the 

8 insulation is tied to either side of the 

9 obstruction.

10 Also, if the piping is in an exterior 

11 wall, cavity, or other insulated space, no 

12 additional pipe insulation is needed if the 

13 insulation provides at least R4 coverage around 

14 the piping. Sort of --

15 MR. TOMPOS: I still think you're going 

16 to have service problems with -- like I said, I'm 

17 not going to stop this.

18 MR. HAGERMAN: Joe Hagerman, DOE.

19 I mean, manufacturers have to take that 

20 into consideration, right?

21 MR. TOMPOS: Right.

22 MR. HAGERMAN: If they think that there's 
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1 going to be service problems. We're not -- our 

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

3 make a unit that would have service problems.

4 MR. TOMPOS: No, I agree. But I -- right 

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

6 mean, apparently we have some in Vermont. But 

7 right now we don't have insulation -- right now, 

8 that area is a conditioned space, because it 

9 communicates and there's no insulation between 

10 the floor and the belly blanket.

11 But what we're going to require, because 

12 we have to put more insulation somewhere, is that 

13 we are going to make that an unconditioned space. 

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

15 creating a problem that currently doesn't exist.

16 But again, in my opinion, I think we 

17 should insulate the pipes whether they're 

18 conditioned or unconditioned. So it doesn't make 

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

20 three-quarter-inch pipes.

21 MR. HAGERMAN: If you were a 

22 manufacturer, you would insulate --
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1 MR. TOMPOS: If I were a manufacturer, I 

2 would insulate the pipes.

3 MR. HAGERMAN: And I think a lot of 

4 manufacturers will probably interpret this --

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

6 way.

7 MR. HAGERMAN: Yes.

8 MR. TOMPOS: But what the IECC requires.

9 MR. RAMIREZ: Mark?

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

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

12 does that factor into it?

13 MR. TOMPOS: I would say we should follow 

14 IECC per the IECC 2015.

15 MR. WEISS: Which is?

16 MR. TOMPOS: Which, I believe, is all --

17 MR. WEISS: Everything?

18 MR. TOMPOS: All zones everywhere. I 

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

20 money. And I think Eric just addressed all of 

21 Manny's concerns about butting up against the 

22 pipe. You're not going to have to create bigger 
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1 holes in the joist.

2 It's partially a personal frustration 

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

4 my shower every morning. So I should probably 

5 insulate my own pipes. And they are all in 

6 conditioned space.

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

8 MR. SANTANA: I still think we're 

9 confusing two issues. One is freeze protection, 

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

11 again, because the section that started the whole 

12 thing was specifically for hot water pipes.

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

14 the definition of, as written of conditioned 

15 space into what we want it to read. You know, 

16 there's a -- it doesn't have to be -- it doesn't 

17 have to communicate each time.

18 I appreciate and agree with what Dave 

19 said, that we might create a problem by having 

20 insulation above and below the ducts, because 

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

22 Whereas currently, you don't insulate above the 
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1 duct, you just insulate the majority of the time. 

2 Some manufacturers might insulate above and 

3 below.

4 But, you know, going back to what 

5 conditioned space is, you know, there is an "or" 

6 there. It says you have space that communicate 

7 or you have uninsulated -- or uninsulated pipes. 

8 So the definition of "conditioned space" is 

9 broader. And it does include areas that have 

10 uninsulated ducts, even if they don't communicate 

11 with other parts of conditioned space.

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

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

14 talking about specific to the hot water pipe. 

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

16 insulation itself. It's because of the 

17 difficulties, I think, in construction.

18 MR. RAMIREZ: What about the language 

19 that Eric had presented?

20 MR. SANTANA: Makes it a lot easier, 

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

22 Keith said, you know, and what I said earlier, 
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1 one of the benefits to preventing heat loss when 

2 the water is coming through the pipe to the point 

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

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

5 preventing losses in the pipe, right, are really

6 only going to help as it's being conveyed.

7 Because once it's sitting there -- you 

8 know, so to the water -- you know, if so you 

9 shower in the morning, and then you shower at 

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

11 water heater to your shower head, during the time 

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

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

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

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

16 You might not wait five minutes for your 

17 water, but, you know, it's not going to come out 

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

19 (Laughter.)

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

21 for it to get cold.

22 But anyway, I mean, so that's -- so we're 
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1 talking about freeze protection. Let's talk 

2 about freeze protection. And we're talking about 

3 insulating it because we're trying to prevent 

4 heat losses. And we might just be spinning our 

5 wheels and wasting time insulating it in 

6 conditioned space.

7 So, you know, I really appreciated what 

8 Keith said, because one of my concerns when I 

9 first joined the committee is that I think 

10 everybody on this working group really feels that 

11 energy standards for manufactured housing are 

12 lagging way behind and need to be improved. You 

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

14 One of the concerns I had coming into 

15 this thing is, how much is practicality and 

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

17 we going to just shoot for the stars regardless 

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

19 items that really make sense?

20 You know, and so this one -- that's why I 

21 really appreciated what Keith said, because he 

22 said this, you're not really going to have a 
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1 whole lot to gain. So why even worry about it?

2 MR. RAMIREZ: Okay. Lois?

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

4 comment. Maybe we could take a vote on keeping 

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

6 there, we can amend it for Eric.

7 Alternatively, perhaps just postpone this 

8 whole discussion until the next round of 

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

10 do every three years.

11 MR. RAMIREZ: Michael?

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

13 but I'd like to -- I'm real interested in MHI's 

14 position on reviewing every three years. Is this 

15 something that we should be doing?

16 MS. STARKEY: Both the MHCC and the DOE 

17 statutes require this.

18 MR. LUBLINER: So we're going to be back 

19 here in three years doing this again?

20 MS. STARKEY: No.

21 (Inaudible conversation and laughter.)

22 MS. STARKEY: No.
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1 MR. HAGERMAN: She's talking about the 

2 statute says --

3 MS. STARKEY: Yes.

4 MR. HAGERMAN: -- when the IECC updates, 

5 we update that.

6 MR. WEISS: You can exercise your 

7 discretion.

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

9 an observation.

10 MR. RAMIREZ: Michael, then David.

11 MR. LUBLINER: So my point is that I 

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

13 manufacturers and you have engineers. And we're 

14 disagreeing on the fundamental of heat loss, 

15 which is defining the conditioned space. That 

16 concerns me.

17 What does HUD say the conditioned space 

18 is? And what does HUD say the pressure envelope 

19 is? I read the definition in the HUD standard. 

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

21 understand. The belly is not the pressure 

22 envelope; the floor is. Therefore, the pipes in 
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1 the belly are below -- are outside the pressure 

2 envelope. But because the insulation generally 

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

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

5 Would you concur that's the definition?

6 MR. MENDLEN: I think that's accurate 

7 without me actually sitting there and reading the 

8 lines.

9 MR. LUBLINER: Thank you.

10 MR. MENDLEN: But it sounds correct.

11 MR. TOMPOS: I disagree.

12 MR. LUBLINER: The point on freeze 

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

14 scope.

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

16 about this?

17 (Cross-talk.)

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

19 the energy savings of this pipe insulation 

20 measure. And --

21 (Cross-talk.)

22 MR. RAMIREZ: Sorry, Mike.
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1 MR. LUBLINER: I'm sorry. So we're 

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

3 the pipe insulation energy savings versus its 

4 cost is something we want to include.

5 If we want to talk about freeze 

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

7 the crossover pipes freeze is when the power goes 

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

9 if you look at insurance records and things like 

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

11 stuff happens when the power goes out.

12 So if I was a manufacturer, I would be 

13 using belt and suspenders in climate zone 3. I 

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

15 condo guys do, for good reason, around the pipe. 

16 That's all with the crossover. And any other --

17 and then I would insulate it.

18 And I would find a product that allows 

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

20 you.

21 MR. RAMIREZ: All right. So is there 

22 value then to looking at the life cycle cost 
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1 analysis to see if there is savings sufficient 

2 enough to even talk about the insulation 

3 component? Is it worth talking about?

4 MR. HAGERMAN: Joe Hagerman, DOE.

5 I don't think we have -- I think, so the 

6 model, as I remember correctly, models with 

7 insulation everywhere. We have not modeled it 

8 without insulation.

9 We have allocated $50, which I think is 

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

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

12 we could disassociate what the energy savings is 

13 for insulating the pipe or not.

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

15 don't think -- I doubt it would move very much.

16 MR. RAMIREZ: All right. So this -- it 

17 sounds like the savings, if I interpret that 

18 correctly, is negligible.

19 MR. HAGERMAN: That's my gut feeling.

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

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

22 a question of, I think, to what David's getting 
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1 at is that whether the belly is conditioned space 

2 or not? There may be a stronger argument that 

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

4 And does that now have an impact on whether those 

5 pipes will freeze or not?

6 And do we need to talk about the 

7 possibility of insulating those pipes because of 

8 freezing versus energy savings?

9 David?

10 MR. TOMPOS: Well, now you're talking 

11 about insulating all the pipes, because there's 

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

13 So --

14 MR. RAMIREZ: Well, was that accurate, 

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

16 insulate the floors, now there's a stronger 

17 argument that that's not conditioned space?

18 MR. TOMPOS: That's my argument. But it 

19 sounds like I have a lot of disagreement.

20 MR. RAMIREZ: Yeah. Okay. 

21 MR. SANTANA: Well, I think Luby really 

22 brought up a good point in that freeze protection 
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1 is really outside the scope of what we're doing, 

2 you know. So we're worried about energy. I 

3 think we try to focus on energy. And if it isn't 

4 an energy issue, you know -- I mean, if one of 

5 the energy issues brings up constructability 

6 issues, then that should be considered.

7 You know, but I think we should restrict 

8 this discussion to heat loss and the benefits of 

9 insulating for preventing heat loss. Because 

10 freezing is a separate issue.

11 MR. RAMIREZ: Okay. So, Manny's point is 

12 that if the cost is truly negligible as far as 

13 the cost and the savings, and the issue is more 

14 about pipe freezing, then that's out of scope. 

15 The manufacturers will have to deal with that as 

16 they feel appropriate. You're in a cold climate, 

17 and you need to do it because you have a cold 

18 turn with it, you're going to have to do it.

19 Richard.

20 MR. POTTS: Richard Potts.

21 Is it something that we could note in our 

22 report or findings, something to pay attention 
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1 to? Say we were aware that these may cause 

2 adverse problems, possibly, to frost protection 

3 or freezing in certain climates, so something for 

4 the main committee to look at, or something along 

5 those lines? Just so we do our due diligence.

6 MR. RAMIREZ: Joe was indicating that --

7 MR. HAGERMAN: I think we can note that.

8 I don't think that -- you know, this --

9 you know, we're all -- you know, the 

10 manufacturers, everybody on the committee was 

11 selected because they have experience in this 

12 domain, right? And your term sheet needs to 

13 reflect your professional judgment, right? And I 

14 think if there's other reasonable clauses we need 

15 to add, we should add them, right?

16 We're not asking for this document to be

17 War and Peace and its link, okay?

18 MR. RAMIREZ: Yeah. I think Manny was --

19 MR. SCHNEIDER: Peter Schneider from 

20 Efficiency Vermont.

21 MR. RAMIREZ: Go ahead, Peter.

22 MR. SCHNEIDER: Thanks. So, I'm just 
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1 wondering. There is definitely energy savings 

2 potential here, and probably the payback

3 certainly in best climate zone 3 is going to be 

4 sure. Hot water pipes alone allows, you know, 

5 water temperature to be delivered to -- warmer 

6 than it otherwise would, which would allow water 

7 heaters to be tested slower with regards to, you 

8 know, thermostatic control valves.

9 And, you know, we're looking at a pretty 

10 small incremental cost and then so as energy 

11 savings in a pretty quick payback.

12 It also notes, under 55 degrees, you 

13 know, in Vermont, we never exceed more or less 50 

14 degrees ground -- that is, cold water. So, you 

15 know, I think it would be silly to ignore the 

16 durability improvement associated with insulating 

17 these pipes in the belly in regards to not only 

18 freeze protection, energy savings, but also in a 

19 hot, humid climate.

20 Particularly up here even, where we have 

21 50 degree water and we have hot, humid days, it 

22 eliminates condensation that it leads to wetting 
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1 and potentially mold and mildew.

2 MR. RAMIREZ: Okay. Manny?

3 MR. SANTANA: You know, I think that we 

4 need to go back to the core concept. You know, 

5 the term sheet doesn't have to be word-for-word

6 this is what DOE should have verbatim in the 

7 standard. You know, it can be conceptual.

8 And I think, without getting into what's 

9 conditioned space and what's not conditioned 

10 space, you know, we all agree that pipes of all 

11 sizes outside conditioned space should be 

12 insulated. So the question is, do pipes in 

13 conditioned space -- regardless of how you define 

14 what conditioned space is, do pipes in 

15 conditioned space need to be insulated?

16 We haven't had a vote on that yet. Maybe 

17 -- I think it's an ELMO moment. We've beat this 

18 thing to a pulp making sausages now. So I think 

19 we should, you know, get a gauge as to where 

20 we're at.

21 MR. RAMIREZ: Michael, and then Mark.

22 MR. BANTLE: I pass.
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1 MR. RAMIREZ: Mark?

2 MR. WEISS: This is just a general 

3 comment. I mean, you can't get to the issue 

4 without -- seems to me without defining what 

5 "conditioned space" is. And if you put any kind 

6 of note in the document, whichever document it 

7 is, the term sheet or the final regulation, you 

8 know, if terms, key terms, are not defined, we're 

9 going to create more problems and more confusion 

10 than if we're saying nothing, it seems to me from 

11 this discussion.

12 MR. RAMIREZ: All right.

13 So, let me ask the group, then. I'm 

14 hearing that you want to table the pipe, which 

15 was the easy one.

16 (Laughter.)

17 MR. RAMIREZ: Table it for what, though?

18 MR. HAGERMAN: Let's just decide. I 

19 mean, so Eric found a website here on DOE that 

20 says, for every 10 degrees you reduce your water 

21 heater, annually it saves $12.

22 MR. LACEY: Twelve to thirty.
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1 MR. HAGERMAN: I'm sorry, $12 to $30. 

2 And if Peter just said that when you insulate the 

3 pipe in Vermont, you can reduce your water heater 

4 by 2 to 4 degrees. You take this data, it's 

5 really, you know, you're saving maybe $15 over 

6 five years, right?

7 MR. SANTANA: We're taking stuff as fact 

8 that we don't know is fact. I mean --

9 MR. HAGERMAN: We don't, but --

10 MR. SANTANA: You know, I can say --

11 (Cross-talk.) 

12 MR. HAGERMAN: I would say that we don't 

13 insulate. You know, I say we don't insulate the 

14 pipe in the conditioned space and we move on.

15 MR. TOMPOS: I agree.

16 MR. WEISS: Get consensus down here?

17 MR. RAMIREZ: Okay. Don't insulate the 

18 pipes in conditioned space.

19 MR. SCHNEIDER: This is Peter.

20 I just wanted to add, you know, I wasn't 

21 speaking specifically to Vermont, this 2 to 4 

22 degrees. My guess is you insulate pipes in the 
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1 belly in a manufactured home in Vermont, and 

2 you're well exceeding the 10 degrees. This is a 

3 national average that is documented by the EPA's

4 website for temperature increase when adding R3 

5 pipe insulation.

6 So I would say that, you know, 

7 ultimately, it comes down to whether we're 

8 considering the belly, above the belly insulation 

9 insulated for conditioned or unconditioned. I 

10 think it's pretty clear that is done in 

11 conditioned space and that we've all agreed that 

12 we should insulate the pipes in unconditioned 

13 spaces.

14 MR. EZZO: This is Mark Ezzo.

15 I agree with that, and I think that's 

16 exactly what Dave Tompos was saying. When you 

17 have insulation above and below a pipe, it's no 

18 longer conditioned. And I agree with that.

19 So, the way it could read is, you either 

20 install the pipe in the conditioned space, and I 

21 think most of us agree that if insulation is 

22 above and below it's not conditioned. So you 
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1 would have to insulate that to -- you'd have to 

2 add another level of insulation to that. Or you 

3 install the pipe in a conditioned space. And I 

4 agree with that.

5 MR. RAMIREZ: So, I think that Joe's 

6 phrasing still holds true to what I just heard, 

7 which was no requirement to insulate pipes in 

8 conditioned space. Right?

9 So let me see a show of thumbs on that.

10 MR. KESSLER: Bert at Palm Harbor.

11 MR. RAMIREZ: I'm sorry? Go ahead, Bert.

12 MR. KESSLER: This is Bert at Palm 

13 Harbor.

14 We keep talking about pipe freezing. 

15 This requirement applies to hot water pipe only. 

16 It doesn't say anything about cold.

17 MR. RAMIREZ: Yeah. No. There was some 

18 discussion on that, but --

19 MR. KESSLER: It's hot water pipe 

20 insulation.

21 MR. RAMIREZ: Right. There was some 

22 discussion on that, but I think we've moved on 
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1 from that. So --

2 MR. KESSLER: And I don't agree with the 

3 definition of "conditioned space." You know, if 

4 we have insulation and an air space between, that 

5 becomes part of the whole assembly.

6 And then, last comment, for the intent to 

7 work for that pipe insulation, you have to have 

8 the insulation all the way around the pipe. If 

9 it's just laying on top of a blanket insulation 

10 in the belly, that doesn't do anything for the 

11 intent of that requirement. Thank you.

12 MR. RAMIREZ: All right. So, just so 

13 that everyone is on the same page, Mark, Mark 

14 Ezzo, can I ask you that between now and probably 

15 after our next break, would you be able to draft 

16 a couple of lines of what that would look like so 

17 that we would all have something to look at and 

18 gauge consensus on?

19 MR. EZZO: Well, it would be one 

20 sentence, Javier.

21 MR. RAMIREZ: That's fine.

22 MR. RAMIREZ: Go ahead and give it to us.
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1 MR. SCHNEIDER: This is Pete. I just 

2 want to note, just on the last comment that was 

3 made, you know, the language says, "mechanical 

4 system piping capable of carrying fluids above 

5 105 Fahrenheit or below 55 Fahrenheit shall be 

6 insulated to a minimum of R3." Okay? So that's

7 --

8 (Cross-talk.)

9 MR. KESSLER: That does not apply to 

10 water lines. That's for refrigerant lines.

11 (Pause.) 

12 MR. RAMIREZ: Okay.

13 MR. LUTER: This is Rob at Lippert.

14 Are we still contending we don't have a 

15 definition for "conditioned space"?

16 MR. RAMIREZ: No, I don't think so. I 

17 think what we're just trying to capture right now 

18 is the verbiage of not requiring to insulate 

19 pipes in conditioned space. So we're just trying 

20 to capture a line so that everyone sees the same 

21 thing, so that we can gauge consensus on it.

22 MR. LUTER: Oh, okay. For what it's 
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1 worth, IECC does define "conditioned space." So.

2 MR. RAMIREZ: Yeah, I know. I think 

3 we're not quite there yet.

4 Keith, did you have something?

5 MR. DENNIS: Is there any way to avoid 

6 the issue by just doing it the opposite way and 

7 saying "underbelly and unconditioned space" so 

8 that we don't have to argue about why the belly? 

9 It seems like people don't want to insulate in 

10 conditioned space because it doesn't make sense, 

11 and that they do want to insulate in the belly 

12 and other unconditioned space or other 

13 conditioned space.

14 And you say "other," "and other 

15 unconditioned space," you're making an 

16 interpretation on that. But it sounds like 

17 everyone is in agreement, we're just arguing 

18 about --

19 MR. RAMIREZ: So, insulate hot water 

20 pipes in --

21 MR. DENNIS: In unconditioned space, 

22 yeah. Underbelly and unconditioned space. And 
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1 just say that that doesn't have any -- that's not 

2 interpreting what underbelly --

3 MR. MENDLEN: That's in fact on the heat 

4 tape.

5 MR. RAMIREZ: David?

6 MR. TOMPOS: Well, in some zones, we are 

7 going -- it is still going to be conditioned 

8 space in the belly. So I don't think we can just 

9 say "the belly." Because you have some in the, 

10 you know, zones 1, 2, and 3, you're going to be 

11 able to get away with an R22 blanket, where, by 

12 my definition of "unconditioned space," that's 

13 now a conditioned space, because I don't have 

14 insulation on top of that section.

15 So I don't think we should include all

16 bellies, because in some zones you are going to 

17 be conditioned space.

18 MR. DENNIS: So the belly may be 

19 conditioned or unconditioned. Just say "insulate 

20 in unconditioned space." And then can we just 

21 move on?

22 MS. STARKEY: Yeah. Exactly.
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1 MR. TOMPOS: I'm fine with that. We can 

2 work out the problems with conditioned space 

3 later.

4 MR. HAGERMAN: You could also say, "Where 

5 pipe runs to the insulation in the underbelly, it 

6 shall be insulated."

7 MR. TOMPOS: That was my point. In the 

8 underbelly, I may have conditioned space.

9 MR. HAGERMAN: Right.

10 (Cross-talk.)

11 MR. HAGERMAN: And so, where it runs 

12 through the insulation of the underbelly, it 

13 shall be insulated.

14 MR. TOMPOS: Okay. 

15 MR. DENNIS: Or in unconditioned portions 

16 of the underbelly.

17 MR. TOMPOS: My opinion would be we just 

18 say that we don't do it in conditioned space, and 

19 we'll let DOE figure out the definition of 

20 "conditioned space."

21 MR. SANTANA: Exactly.

22 MR. RAMIREZ: So, which is the top line?
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1 (Cross-talk and laughter.)

2 MR. RAMIREZ: Which is the top line? "Do 

3 not insulate in conditioned space"?

4 MR. SANTANA: Well, no. It's 

5 interpreting what we say. All hot water pipe 

6 should have R3 insulation outside of conditioned 

7 space.

8 MR. HAGERMAN: Right.

9 MR. SANTANA: So that's all inclusive by 

10 -- you know, like you guys said, what we end up 

11 with defining as conditioned space, if you have, 

12 you know, insulation in the belly and then none 

13 in between in the joist space and that's 

14 considered conditioned space, then that's fine. 

15 You don't have to insulate in there.

16 If you have insulation in the floor and 

17 under the duct, then that's considered 

18 unconditioned space, then -- I mean, this little 

19 pipe, the pipe and -- I guess the concept, again, 

20 the core concept is that if the pipe is in 

21 conditioned space, there's no need to insulate 

22 it.
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1 MR. RAMIREZ: Okay. So, folks that are 

2 on line, can you see the screen?

3 (Pause.)

4 MALE VOICE: Yes. 

5 MR. RAMIREZ: Okay. Eric, you had 

6 something?

7 MR. LACEY: One more thing to add. And I 

8 hate to prolong the discussion, but there was one

9 other scenario required by the insulation in here 

10 that I didn't want to miss. That is, from the 

11 water heater to the distribution manifold. You 

12 want to just throw that one in there and include 

13 that?

14 I know you don't always have a 

15 distribution manifold.

16 MR. SANTANA: I don't think we ever had a

17 distribution manifold.

18 MR. LACEY: There is one.

19 MR. RAMIREZ: So, if there is no 

20 distribution manifold, then it's irrelevant.

21 MR. LACEY: Yeah.

22 (Pause.)
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1 MR. SANTANA: But if you have a -- okay. 

2 Now, this is a tough one. But if you have a 

3 distribution manifold inside a conditioned space, 

4 would we want to insulate the lines by going to 

5 the distribution manifold?

6 MR. RAMIREZ: The way I read that, yes.

7 MR. SANTANA: Wouldn't that be the same 

8 thing? I think that would be fine, because that 

9 would probably be -- if you have a distribution 

10 manifold, it probably won't be in the wall or it 

11 won't be in some kind of inaccessible hard-to12 reach place, you know? I don't know where we 

13 would have it.

14 MR. RAMIREZ: David?

15 MR. TOMPOS: If we include that, make it 

16 not -- "should" is a bad word. You've got --

17 (Cross-talk.)

18 MR. TOMPOS: No, "shall."

19 MR. BANTLE: Do you want "shall"?

20 MR. TOMPOS: "Shall." It has to be 

21 "shall." "Should" is an option, yeah.

22 (Cross-talk.)
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1 MR. MENDLEN: First line, too?

2 MR. WEISS: I would suggest adding "if 

3 any" in there. "Distribution manifold," comma, 

4 "if any."

5 MR. RAMIREZ: Okay. I'm sorry. Mark?

6 MR. WEISS: I would just suggest, after 

7 "distribution manifold," comma, "if any," because 

8 apparently they're not used.

9 MR. RAMIREZ: Oh, okay.

10 MALE VOICE: It reads the same.

11 MALE VOICE: Yeah.

12 MR. RAMIREZ: All right. So, let me see 

13 a show of thumbs for those two lines.

14 (Pause.)

15 MR. RAMIREZ: And folks on line, if 

16 anyone is in disagreement, speak up. Otherwise, 

17 we're assuming you're good with that.

18 MR. LUTER: Looks good to me.

19 MR. RAMIREZ: Okay. Then, those two 

20 lines have unanimous consensus. And now that 

21 we've got that easy one out of the way, let me 

22 ask. Do we want to take a one function before we 
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1 move on to the next one?

2 Okay. So let's take 10 minutes. And 

3 then we're going to go into the air leakage.

4 (Recess from 10:08 a.m. until 10:22 a.m.)

5 MR. RAMIREZ: Okay. Let's go ahead and 

6 tackle the air leakage issue. And we still have 

7 quite a bit on the agenda. So let's try to put 

8 this in a time box. So it's 10:22. So let's go 

9 until eleven o'clock, right, at the latest, 

10 assuming we don't get this done in five minutes, 

11 right?

12 MS. DICKENS: Because that would be so 

13 standard.

14 (Laughter.)

15 MR. RAMIREZ: Yeah. So let's put this in 

16 a time box.

17 Air leakage. How do we want to tackle 

18 this one?

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

20 Where we started last time to start the 

21 conversation off, we put up on the screen, and 

22 maybe Matthew could just talk to it, the cost 
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1 that Matthew assumed for the air leakage numbers, 

2 right? And I believe he derived -- I believe 

3 they derived, you know, since yesterday when we 

4 talked, I believe they derived the air leakage 

5 and the duct leakage costs and a performance 

6 specification largely off this ENERGY STAR report 

7 that was circulated pretty early in our 

8 discussions. So those were the costs that came 

9 into it.

10 You know, yesterday we defined what "duct 

11 leakage" was. And so I think it would be nice to 

12 define first what "air leakage" or, you know, the 

13 steps that one would take to reduce the air 

14 leakage in the house, to talk through what the 

15 measure actually includes, and then just have a 

16 frank discussion of, does the number that we 

17 report up there, does it reflect the amount of 

18 work that you take to achieve that, right, in 

19 one's professional opinion?

20 (Pause.)

21 MR. RAMIREZ: So --

22 MR. BANTLE: You might have to log in 
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1 again. 

2 MR. RAMIREZ: I think I am in.

3 (Pause.)

4 MR. HAGERMAN: I mean, I think the 

5 committee needs to, the group needs to recognize 

6 that, as we've pretty tightly insulated the 

7 house, I would think, and maybe Emanuel Levy 

8 should speak up here. As you insulate the house, 

9 your air leakage is going to improve, right? 

10 It's going to be less leaky.

11 There's just still some conditions that 

12 need some attention, like, you know, around the 

13 windows and the door openings, and stuff like 

14 that, pathways that need to be considered. So 

15 it's really, what's the cost of insulating those 

16 pathways?

17 MR. RAMIREZ: So, what are the additional 

18 things that would need to be done in order to 

19 increase the efficiency around that air leakage?

20 MR. HAGERMAN: We talked yesterday about, 

21 you know, you have to put some type of sealant at 

22 the bottom plate and the top plate, right? 
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1 That's one big continuous area, you know, gap 

2 that you'd have to close.

3 And then, as you sheathe the building, 

4 and you put the sheathing on the studs and the 

5 headers, there's usually spaces in between the 

6 header and the top plate, or the header and the 

7 window opening, or the window where the window 

8 sits in the wall assembly, in the voids there 

9 that would have to be insulated, right?

10 Can you think of anywhere else? Oh, any 

11 penetrations -- any time you'd have a hole 

12 through an assembly, you'd have to caulk around 

13 the hole, of course, like a piping. Maybe the 

14 outlets, like the outlets for the electrical. 

15 You'd have a punch-out there. You'd have to 

16 insulate around that.

17 I'm just trying to think through the 

18 steps that you'd have to do to achieve the 

19 highest, as a least --

20 MR. RAMIREZ: So it sounds like any time 

21 that you cut the exterior, you need to make sure 

22 that it's insulated around it.
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1 MR. TOMPOS: Dave Tompos.

2 Most of that is already in the standard, 

3 in section 505. I think there was some side 

4 discussion on maybe having to define what the 

5 pressure envelope is, because currently, the 

6 industry is using the belly board as the pressure 

7 envelope on the bottom.

8 Now, when we go -- I can see when we get 

9 into the -- there's ways to move the pressure 

10 envelope to the exterior skin so they would not 

11 have to insulate around the recepts and all 

12 penetrations in the gypsum or the wall sheathing. 

13 But that exterior sheathing, if we tape that, 

14 that is now the pressure envelope, is the way I 

15 see it.

16 So I think we're already doing pretty 

17 much everything that the DOE, or prescriptively 

18 that we could possibly do to seal all these 

19 things.

20 MR. HAGERMAN: So, could somebody speak, 

21 you know, if you were to just do below-door tests 

22 on a unit that just met HUD code, and then a unit 
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1 that met HUD code ENERGY STAR, could somebody, 

2 could maybe Emanuel Levy, or David, you, could 

3 you comment what air exchange rate you're 

4 getting?

5 MR. TOMPOS: I think Emanuel did have 

6 some data on that. We had some also because we 

7 do that testing. And ours ranged anywhere from 

8 three to seven. So it was --

9 MR. LUBLINER: And I submitted a report 

10 to you --

11 MR. TOMPOS: It was kind of all over the 

12 board.

13 MR. POTTS: For both HUD code and ENERGY 

14 STAR.

15 MR. TOMPOS: Those were all ENERGY STAR. 

16 So.

17 MR. LEVY: This is Emanuel.

18 Yeah, we looked at five outer homes. And 

19 the ranges, as David has indicated, anywhere from 

20 three to five or seven. Five is kind of the 

21 average. But these are homes that are tested out 

22 in the field, not in the plant.
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1 (Pause.)

2 MR. HAGERMAN: So, maybe just to cut to 

3 the chase then, so is -- do you feel like five is 

4 a reasonable level, and that $390 and $230 are 

5 reasonable prices, so that, you know, to the end 

6 consumer on achieving a five?

7 MR. LEVY: Well, this is Emanuel.

8 If you recall in the white paper on 

9 whole-house leakage, we had a list of -- and this 

10 is what you're getting at right now, Joe. It 

11 lists the seven different measures that we would

12 -- they would be associated with that 

13 preferential, that target leakage level.

14 And if we look at those, I think it will 

15 give you a good sense of what -- and particularly 

16 the manufacturers in the problem, what the items 

17 are and probably what goes out.

18 I want to say whether those numbers seem 

19 a little bit high or low. They don't seem to be 

20 out of whack.

21 MR. RAMIREZ: Michael?

22 MR. LUBLINER: We have been testing for a 
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1 long time in the plant and in the field, more 

2 like Emanuel, in the field.

3 I think five is a reasonable number, 

4 based on our experience. And I provided research 

5 to DOE to support that. The IECC for the cold

6 climates has three. I think they were 

7 compromising the five here. And I think that's 

8 reasonable.

9 And I'd like to take note of what Rick 

10 said about giving -- and my recommendation that 

11 we look at a period of learning without 

12 enforcement to see, and then HUD can -- DOE can 

13 work out what they want, if they want to tweak 

14 those numbers if there's undue hardship or if 

15 it's way too much. But I think five is really 

16 where we're going to land.

17 My interest is looking at the specifics. 

18 As I noted yesterday, I have a proposal that was 

19 rejected by the consensus committee because HUD 

20 was going to deal with it. I thought that 

21 proposal provided more specifics to the quality 

22 assurance plan to allow for adequate inspection 
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1 of the penetrations through the floor.

2 And I fundamentally disagree that the 

3 belly is the predominant pressure envelope. I 

4 think it's the floor. I fundamentally disagree 

5 from the side-built standpoint, too. I think we 

6 can agree to disagree.

7 Anyway, I have an example of, you know,

8 if the belly is the pressure boundary, then why 

9 is the plant caulking holes in the floor?

10 MR. TOMPOS: They don't know any better.

11 MR. LUBLINER: Well, no. Wait a minute, 

12 wait a minute. "They don't know better"? I 

13 mean, come on. They're cost conscious, right? 

14 So here's a picture of a plant that I went 

15 through, and they have one hole. And I'm sorry 

16 you guys can't see it.

17 (Cross-talk.)

18 MR. LUBLINER: They have a penetration in 

19 the floor that's foamed. I wouldn't say it's 

20 foamed effectively, but it's foamed. But right 

21 next to it is a P-trap that's like two inches by 

22 four inches that isn't caulked.
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1 It seems to me there's a systematic 

2 breakdown in defining -- just like the systematic 

3 breakdown in defining what "conditioned space" 

4 is, there's a systematic breakdown in defining 

5 what the pressure envelope is and what is 

6 required for air sealant.

7 I'm just showing you the side that shows 

8 the holes and -- and so I would say that we're 

9 going to get the five if we just figure out a way 

10 to seal the P-trap in the floor, if you believe 

11 my definition that the floor is the primary air 

12 barrier.

13 MR. TOMPOS: And that was exactly why I 

14 brought up the point that we needed to define the 

15 air barrier.

16 MR. LUBLINER: Yep, I agree totally, 

17 Dave.

18 MR. RAMIREZ: So, maybe I need a little 

19 help connecting one of the dots here. Because 

20 you're saying that in order to get to five, you 

21 would have to seal like the P-trap and things 

22 like that, correct?
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1 (Pause.)

2 MR. RAMIREZ: Michael?

3 MR. LUBLINER: Yes.

4 MR. RAMIREZ: So, if the group were to 

5 agree, and we haven't taken the gauge at five, do 

6 you need to specify where that pressure envelope 

7 is? Whether it be on the belly or the actual 

8 floor, do you have to define that if that's a 

9 five?

10 MR. LUBLINER: I'm not sure I understand. 

11 If you look at ENERGY STAR, the DOE programs, I 

12 think it would be consistent with my definition 

13 of where the pressure envelope is, being the 

14 floor, the primary pressure envelope. We work in 

15 an ENERGY STAR program, and so we caulk the 

16 floor. Because that's ENERGY STAR's definition.

17 It's unclear to me what the definition is 

18 in this industry, and that's why Dave raised the 

19 question. I think Building Science Fundamentals 

20 suggests that you need to insulate the floor 

21 because the belly, which is really a rodent 

22 barrier. That's the reason that I understand 
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1 that the belly insulation was originally put in 

2 there, was not for pressure envelope. It was to 

3 permit transport of the insulation and limit 

4 rodent entry into the unit.

5 Now, I have a home with a triple-wide. 

6 And it has numerous failures of the rodent 

7 barrier, and it's 12 years old, predominantly 

8 because the tape that was used to seal the belly, 

9 after penetrations were made, has failed. It's 

10 duct tape. It's another reason.

11 So that when you test a home in the 

12 factory, it may have a really tight belly, and 

13 one could argue that belly's really tight. But 

14 over the life of the home, I think it would be 

15 fair to say that that belly, there's a high 

16 probability that that belly would be compromised.

17 Would you agree with that, Dave?

18 MR. TOMPOS: I would agree that there is 

19 a probability that that can happen.

20 MR. LUBLINER: Thanks.

21 MR. RAMIREZ: Okay. So you're talking 

22 about the initial testing where that might work, 
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1 but after time, if it's the belly, then you're 

2 more likely to fall below that five over time.

3 MR. LUBLINER: Yeah. I mean, I'm adamant 

4 that the pressure boundary is the floor. But I 

5 could see someone argue or think it was at the 

6 factory if they put one of these pressure gauges, 

7 which is what all good building scientists choose 

8 in the industry.

9 Have you seen one of these, Rick?

10 (Pause.) 

11 MR. MENDLEN: No.

12 MR. LUBLINER: So this is used for all 

13 blower-door testing and duct-blaster testing. 

14 It's also used to measure blow rates.

15 But if you put a pressure in the belly, 

16 and you measure what the pressure is in the belly 

17 versus what it is in the crawl space or outside, 

18 and what it is in the house, you'll find out 

19 pretty quickly that the predominant -- that the 

20 pressure is really affected by the tightness of 

21 the belly versus the tightness of the floor.

22 I measured for two years in my house, 
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1 every five seconds, the pressure in all these 

2 places, under a Building America program. My 

3 experience based on that is that we should be 

4 focused on the floor, as the manufacturer is 

5 attempting to do here, but not very well, because 

6 the lack of specificity in the quality assurance 

7 plan.

8 MR. RAMIREZ: Okay. 

9 MR. SANTANA: You know, I think that 

10 there's going to be a time and a place where --

11 we know the place. There's going to be a time 

12 later where we're going to get into the air 

13 barrier and the pressure envelope and the thermal 

14 envelope and all that stuff.

15 I think right now what we're saying is, 

16 you know, with respect to the cost analysis, do 

17 we think that it's reasonable to say that it's 

18 going to cost X amount to get a house to this 

19 many air changes?

20 And, you know, I'm at a disadvantage to, 

21 say, Mike and Dave and Emanuel, because I don't 

22 have any empirical data, right, to allow me to 
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1 know what it takes to get from an air leakage of 

2 eight to one of five to one of three.

3 But, you know, given my lack of, I guess, 

4 knowledge as to what specific elements it takes 

5 to get that improvement, I think, with respect to 

6 the cost analysis, that the costs presented here 

7 seem reasonable.

8 MR. RAMIREZ: Okay. 

9 MR. SANTANA: I think that will be a 

10 thumbs-up, and let's move on then.

11 MR. RAMIREZ: Joe?

12 MR. HAGERMAN: Well, if we want to just 

13 take a vote right now, to thumbs up, thumbs down, 

14 if you think -- I just wanted to -- so, Emanuel's 

15 last proposal, or -- I'm sorry.

16 One of the proposals that Emanuel 

17 provided at the last meeting about whole-house 

18 leakage goes through the seven items or areas 

19 that you would have to seal and visual inspect, 

20 of course, in his proposal. So we can read 

21 through this. I think you read through them last 

22 time, but they're pretty straightforward.
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1 Like David said, I think you're doing a 

2 lot of them already.

3 MR. RAMIREZ: Did David send these?

4 MR. HAGERMAN: No. Emanuel sent this.

5 MR. TOMPOS: No. Emanuel.

6 (Cross-talk.)

7 MR. SANTANA: We're not saying, you know, 

8 that we're going to enforce seven or five or 

9 three or --

10 (Chorus of "Right.")

11 MR. SANTANA: We're just saying, for this 

12 level of enforcement, this price --

13 MR. HAGERMAN: Costs, right.

14 MR. SANTANA: -- is reasonable to assume.

15 MR. HAGERMAN: Let's move it to a vote, 

16 then.

17 MR. RAMIREZ: All right. So, setting 

18 aside what is the pressure envelope, the 

19 definition of it, the standard of five with the 

20 costs that are associated with it, is that 

21 something the group can reach consensus on?

22 MR. HAGERMAN: Yeah. If Ted maybe could 
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1 pull those back up just real quick so everybody 

2 can see it.

3 (Pause.) 

4 MR. WEISS: While he's doing that?

5 MR. RAMIREZ: Yeah, Mark.

6 MR. WEISS: And again, where do the 

7 numbers come from, the cost numbers?

8 MR. HAGERMAN: I believe Navigant modeled 

9 those off of the ENERGY STAR program, that 

10 actually did -- did actually study what it would 

11 take to go from a seven to a five.

12 MR. WEISS: Okay. Is that based on 

13 empirical analysis of homes?

14 MR. HAGERMAN: Yeah, it is.

15 MR. LACEY: And it included the testing 

16 costs and records and other things, paperwork. 

17 Yeah.

18 MR. LUBLINER: This isn't just caulking?

19 MR. LACEY: Right.

20 MR. SANTANA: Testing costs?

21 (Cross-talk.)

22 MR. LUBLINER: No one is saying this is 
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1 just caulking materials costs.

2 MR. HAGERMAN: Right. The ENERGY STAR --

3 so we were conservative there. So the numbers 

4 you see up there included everything that ENERGY 

5 STAR looked at, which is the material costs to 

6 achieve it and the testing costs. We have not 

7 brought up testing here in our discussion yet.

8 MR. BARBOUR: To be clear, do you 

9 actually think it is?

10 (Cross-talk.)

11 MR. BARBOUR: But it's not always there

12 in the EPA documentation for the ENERGY STAR 

13 version 3, I don't think.

14 MR. RAMIREZ: All right. Let me get --

15 (Cross-talk.)

16 MR. RAMIREZ: Let me get David, then 

17 Michael. David?

18 MR. TOMPOS: If we can, we'd love to get 

19 the seven things on the board. Are we -- I guess 

20 I'm asking a question. Is the proposal to 

21 potentially do a number of prescriptive things 

22 that we believe will consistently get us to a 
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1 five ACH, and then just do a visual inspection? 

2 Make sure that it's in the quality control 

3 manual, make sure that it's being done 

4 consistently, and not have to do any type of 

5 testing?

6 Because if that's the case, I'm in full 

7 support of that. I think the testing is going to 

8 become another issue for manufacturers, because 

9 they're going to lean towards testing every 

10 single house. And I don't know if that's 

11 necessary.

12 If we do some of these prescriptive 

13 things to make sure that we're always going to 

14 hit that five, I'd prefer not to see testing have 

15 to be done, especially out in the field.

16 MR. HAGERMAN: So let me clarify 

17 something I said. So we just relooked at the 

18 ENERGY STAR data. And for the ducts, it included 

19 the cost to do the ducts that are tighter and the 

20 testing.

21 The whole house air, the whole house 

22 leakage just included the materials. It did not 
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1 include the testing.

2 So what you see up there is just the 

3 material, not the testing. I'm sorry; I 

4 corrected myself.

5 MR. RAMIREZ: Michael?

6 MR. LUBLINER: So, if you take the 650 

7 and you divide by 2.2, which I think we got some 

8 consensus was a reasonable factor for the cost of 

9 manufacture to the retail, you end up with about 

10 $282 of materials and labor.

11 And I would contend that, as you said, 

12 much of this stuff is already in the HUD code, 

13 and they should be doing it. And the only thing 

14 that they're not really doing is the plate and 

15 the P-gaskets. And so, I think that you could 

16 easily do that for a lot less than 280.

17 I mean, how many cans of Great Stuff is 

18 that, or tubes of caulking at manufacturer's 

19 price, $280? That seems like you could do a lot 

20 of homes for that, so, and especially when 

21 they're caulking when using production costs and 

22 production systems.
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1 So I guess I'm a little concerned that 

2 that price at a manufactured is very high. I 

3 think it would be much more appropriate in a 

4 site-built home with all the subtrades and 

5 things. But again, our experience is it's 

6 nowhere close to that if the HUD code is being 

7 enforced and the specifics of the HUD code are 

8 well defined.

9 MR. HAGERMAN: I think it's a 

10 conservative number. It's, you know, 23 cents a 

11 square foot.

12 MR. RAMIREZ: So, do you want to gauge 

13 consensus? Or did you want to see those seven 

14 items? Because if you want to see the seven 

15 items, Emanuel, can you help us out?

16 MR. BANTLE: Is it these seven?

17 MR. LEVY: Yeah.

18 MR. RAMIREZ: Okay. 

19 MR. LEVY: These are the seven.

20 Let me interject a comment here, which is 

21 that I think if we can go back to the table, 

22 we'll come back to these seven items in a second.
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1 (Pause.) 

2 MR. LEVY: I think we can say with some 

3 confidence that the industry, if it's doing a 

4 good job in implementing the seven items that are 

5 on that list, some variation, can get to five. 

6 And that's what Mike said; that's what I said 

7 earlier, that our experience is that getting to 

8 five is something that is documentable to a lot 

9 of experience that we have, using good practice. 

10 And that's what ENERGY STAR has revealed.

11 Whether or not it cost 390 is, we can 

12 look at the items and say whether those add up to 

13 390 or not. I think we can, with some 

14 confidence, put a number on that.

15 I don't think we can put a number on that 

16 that 390 investment saves two ACH, that the 

17 starting point is seven as opposed to eight or 

18 six. That's the piece of this which is important 

19 to the life cycle cost analysis that I don't 

20 think we can say with great confidence that we 

21 know what those seven items, once implemented, 

22 does for you in terms of reducing ACH levels.
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1 And that's why I suggested the other day 

2 that we just take this out of the cost-benefit 

3 analysis and just say this is good practice to do 

4 those seven items and that those seven items are 

5 associated with a five ACH, and not worry about 

6 whether they're cost effective or not.

7 They're doable. We're pretty confident 

8 from our experience that they do make a lot of 

9 sense, that they're reasonable things. Let's 

10 just include it as a prescriptive proposal.

11 MR. RAMIREZ: Mark?

12 MR. WEISS: I just want to be clear. Is 

13 the five ACH based on complies with ENERGY STAR 

14 or complies with the base HUD code?

15 MR. LEVY: They're only my comments, and 

16 Mike can say what his comments are about. Our 

17 comments that five is reasonable is based upon 

18 our testing of about 500 homes in the field all 

19 over the country that were ENERGY STAR homes that 

20 had these features incorporated in them.

21 MR. WEISS: Okay. Thank you.

22 MR. RAMIREZ: All right. So I don't know 
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1 if I mentioned this to the group before. But how 

2 many of you worked on an oil rig?

3 (Pause.)

4 MR. RAMIREZ: First rule of oil folks is 

5 that when you hit oil, stop drilling, right? And 

6 I'm hearing everybody saying that they're okay 

7 with this five. Right? So let me see a show of 

8 thumbs if we're okay with five and the costs 

9 associated with it there.

10 (Pause.)

11 MR. RAMIREZ: Okay. 

12 MR. EZZO: Hey, Javier, this is Mark 

13 Ezzo.

14 MR. RAMIREZ: Yeah.

15 MR. EZZO: I'm fine with that and with a 

16 condition, though. And the condition is, if you 

17 look at Emanuel's proposal, where we're talking 

18 about the seven items under visual inspection of 

19 prescriptive air sealing, I just want to make 

20 sure everybody is aware and agrees that that is -

21 - that's one of the means of achieving the whole22 house leakage standard, meaning it's a way of 
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1 doing it without having to perform a physical 

2 test.

3 So in Emanuel's paper, his white paper, 

4 it says you either hit -- you either test the 

5 home and hit a certain air change per hour 

6 number, or you follow the visual inspection of 

7 prescriptive air sealing measures, which is these 

8 seven items.

9 MR. RAMIREZ: Okay. And is that --

10 MR. EZZO: And I think that's a really 

11 good proposal. And I support it. And I'm fine 

12 with the cost numbers associated with doing that.

13 MR. RAMIREZ: All right.

14 Joe, and then Lowell.

15 MR. HAGERMAN: Joe Hagerman, DOE.

16 So, do you think, Mark, then -- I'm 

17 assuming you can see what's on the screen right 

18 now? Is that correct?

19 (Pause.) 

20 MR. EZZO: Yeah, I can see it.

21 MR. HAGERMAN: Are you trying to say 

22 that, instead of the word "all" there, you could 
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1 say "one means for manufactured homes to be 

2 sealed against air leakage," and then include the 

3 list? Is that what you're --

4 MR. EZZO: I think if a manufacturer is 

5 going to use this list of seven as their means 

6 for compliance, they have to do it on every home.

7 MR. HAGERMAN: Right.

8 MR. RAMIREZ: This or testing?

9 MR. HAGERMAN: This or testing, right?

10 MR. EZZO: Correct.

11 MR. HAGERMAN: Okay. 

12 MR. RAMIREZ: Lowell?

13 MR. UNGAR: I have a couple of questions. 

14 One is, Mike had raised some issues, and it's not 

15 clear to me whether those are included, captured 

16 here or not captured here.

17 MR. LUBLINER: This is Mike Lubliner.

18 I have no idea, because we still can't 

19 define the conditioned space and the pressure 

20 envelope. So I really -- my feeling is anything 

21 in the floor needs to be caulked. If there's a 

22 hole in the floor, it needs to be caulked. I 
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1 don't care what you call it, where it is, it 

2 should be caulked. And that's my feeling.

3 And my other feeling is just that I think 

4 the costs that are being used are a little high. 

5 And once you get into a mode, production -- and 

6 again, but those are my -- that's kind of why I 

7 have some concern about this. The manufacturers 

8 know what the costs are. And I --

9 MR. BANTLE: Just for somebody on the 

10 phone who's having another conversation, if you 

11 could mute your phone, that would be greatly 

12 appreciated. Thank you.

13 MR. LUBLINER: I'd certainly defer to 

14 Mark as to what the costs are. I'm not -- I can 

15 just tell you from our experience is that, as you 

16 do it on every home in the line, it's going to --

17 it's not going to be $280 worth of labor and 

18 materials.

19 I do have some significant concerns about 

20 the other issue that Emanuel raised of 

21 eliminating this from the life cycle cost 

22 analysis. I fundamentally disagree with that.
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1 I would be willing to talk about the 

2 testing criteria. I don't think it should be you 

3 either test or you do the caulk. You always do 

4 the caulk. You use the testing as a feedback 

5 tool to teach the plants what they're missing. 

6 And I think Emanuel's proposal was adequate of 

7 testing quarterly.

8 What I'd like to see is, once a quarter,

9 manufacturers set up a home and test the ducts, 

10 test the envelope, test the flow rates of the 

11 HCVAC system to see they're in compliance with 

12 the HUD code and the manufacturers' 

13 recommendations. And we do this all at once, 

14 four times a year in each plant for the first 

15 couple of years, under DOE's auspices, and see 

16 where we're at.

17 So anyway, that's kind of my 

18 recommendation.

19 MR. HAGERMAN: So, just to interject real 

20 quick --

21 MR. SCHNEIDER: This is Peter from 

22 Efficiency Vermont.
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1 MR. HAGERMAN: Peter, let me --

2 MR. SCHNEIDER: I'd like to interject.

3 MR. HAGERMAN: Hey, Peter, let me get a 

4 first real quick, just because I think that --

5 and you tell me, Peter, how you're voting because 

6 we can't see your thumb.

7 I think, Michael, you were the only 

8 negative.

9 MR. LUBLINER: Mark.

10 MR. RAMIREZ: Mark.

11 MR. HAGERMAN: Oh, Mark was negative, 

12 too? Okay. 

13 (Cross-talk.)

14 MR. HAGERMAN: I was just going to say I 

15 think your objection for the negative was just 

16 the thermal envelope floor issue. And I think a 

17 suitable, maybe, compromise here may be just 

18 under three, where it says "gaps in penetration 

19 of thermal envelopes sealed with caulk, foam, 

20 gasket, and other suitable materials, including 

21 the following," we just add in there, 

22 "penetrations in the floor."
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1 MR. LUBLINER: All penetrations in floor 

2 would be --

3 MR. HAGERMAN: All penetrations in the 

4 floor. And then you go from a negative to a 

5 positive, right?

6 MR. EZZO: This is Mark Ezzo. I'm fine 

7 with that.

8 MR. HAGERMAN: Okay. 

9 MR. LUBLINER: Peter wanted to say 

10 something.

11 MR. HAGERMAN: And I'm sorry, Peter. I 

12 cut Peter off.

13 MR. RAMIREZ: Let's get Peter, then 

14 Manny, then Lowell. Yeah, Peter, Manny, then 

15 Lowell.

16 MR. SCHNEIDER: Thank you.

17 I just want to echo what Michael said. 

18 That's the thing I think is critical is that of 

19 this standard and this particular parameter with 

20 regards to air sealing measure. So I think, at 

21 the bare minimum, quarterly ducts and envelope 

22 blower-door testing.
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1 Having done that for the past 15 years 

2 myself, even working with some of the best 

3 modular home builders up here, there's always 

4 room for improvement. Every single year, there 

5 are new improved products that are more cost 

6 effective and work better over the long term.

7 And so, I think that, in addition to the 

8 visual inspection and the prescriptive list of 

9 measures, which astounds me that we're not doing 

10 this as due course in all of our buildings, I 

11 think that testing quarterly should be a part of 

12 this just to ensure that we're continuing to 

13 improve the envelope and reduce air infiltration.

14 I'd like to see three ACH in, you know, 

15 three years time.

16 MR. RAMIREZ: All right. We have Manny, 

17 Lowell, I think Bert wanted to speak. Lois, and 

18 then Michael.

19 But one thing before we continue on with 

20 the conversation, the testing piece or the 

21 enforcement piece may be something that's 

22 discussed with the next committee that we form. 
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1 So I don't want to bog down this conversation too 

2 much.

3 I think we're making great progress. I 

4 think we're just about there, right? But I don't 

5 want to go down that path too far.

6 Okay. So let me get Manny, Lowell, Bert, 

7 Lois, Michael, and then Mark.

8 MR. SANTANA: You know, I think Javier 

9 said what I was going to say, is that how we 

10 verify the air changes isn't what we're trying to 

11 decide on. We're trying to say, is the cost 

12 reasonable for the air changes?

13 Regardless of whether you, you know -- if 

14 you consider the air barrier to be the belly 

15 board or the air barrier to be the floor, and 

16 you're going to test, the test doesn't know --

17 there is no input that says, "What do you 

18 consider the air barrier?"

19 So you either have this loss, or you 

20 don't have this loss. So the only thing we're 

21 saying, without getting in the weeds, is, is the 

22 cost associated with obtaining this tightness 
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1 reasonable?

2 You know, I mean, I don't know that we 

3 have to put up the seven items or go over them, 

4 because, you know, we haven't even decided on how 

5 many air changes we're going to enforce, whether 

6 it's five or whether it's seven or whether it's 

7 less.

8 MR. RAMIREZ: I'll add Keith to the list. 

9 So, Lowell is next.

10 MR. UNGAR: So, that's not my 

11 understanding of what we're discussing. So 

12 perhaps we should clarify what -- I mean, I 

13 thought we were not discussing just the cost 

14 numbers, but we were discussing whether this 

15 would -- what would be part of the standard.

16 MR. RAMIREZ: Yes.

17 (Cross-talk.)

18 MR. RAMIREZ: And the level of five.

19 MR. HAGERMAN: Five and the costs.

20 (Pause.)

21 MR. UNGAR: Well, so my understanding, we 

22 have the level five or, at the moment, this 
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1 visual list. And in addition, for whichever, 

2 either one of those, the costs, what the cost 

3 would be associated with that. Okay.

4 MR. RAMIREZ: Yeah. Yeah.

5 MR. UNGAR: So, given that, it seems to 

6 me what would make most sense is to have both a 

7 performance level. And unless we assume that all 

8 homes would be tested to that performance level, 

9 that we have a kind of prescriptive description 

10 that we know would apply to all homes. And that 

11 would be -- you know, some combination would be 

12 the way of making sure that we're achieving the 

13 kind of air leakage that we're aiming for.

14 I understand the concern that even if 

15 you're not requiring -- and this gets into 

16 testing, but I don't think it's separable, that 

17 even if you're not requiring all homes, even if 

18 you don't require all homes to be tested to meet 

19 the performance level, that puts manufacturers in 

20 a bind.

21 So I wonder whether there's a way of 

22 incorporating the performance level not as a 
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1 mandatory requirement for all homes, but to 

2 incorporate -- it would be a prescriptive 

3 requirement for all homes, and in addition, a 

4 requirement that the testing be done 

5 periodically.

6 And if the testing does not show meeting 

7 the target level, that you wouldn't then have a 

8 recourse of going and requiring every home that's 

9 been manufactured for the last period to be 

10 fixed, but you would require the manufacturer to 

11 fix the process and retest so that that ensured

12 that homes going forward are in fact meeting that 

13 target.

14 MR. RAMIREZ: Okay. So you're, it's like 

15 we're seconding the idea of some type of 

16 quarterly testing or some type of testing 

17 periodically to make sure that they're on track?

18 MR. UNGAR: Yeah. It seems to me you 

19 need both these prescriptive description and 

20 testing. But if you can do that, if the problem 

21 is that once you put a requirement on the 

22 performance standard as a requirement on homes 
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1 that you then force -- in practice, force 

2 manufacturers to test all homes, whether the way 

3 of reframing the performance requirement so that 

4 it's a performance requirement on the factory and 

5 not on the homes, basically, so that you would 

6 then require the factory to fix their process if 

7 they're not meeting that target.

8 MR. RAMIREZ: Okay. Thank you.

9 Bert, did you have something?

10 MR. KESSLER: Yeah. I was just going to 

11 ask the group if anybody had a chance to review 

12 the white paper that Javier emailed, I believe, 

13 Saturday, that Joe Lstiburek put out relative to 

14 floor assemblies and what to do and what not to 

15 do, which is right up our alley here, and in 

16 fact, caused the addition of the exception in 

17 402.2.8 of the 2015 IECC.

18 And once you have a chance to review 

19 that, I think you'll probably lean more towards 

20 using the bottom board as the air barrier than 

21 the floor decking. Because if we're 

22 concentrating on the floor decking and continue 
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1 installing the insulation as it's typically 

2 installed in our industry in the belly, then we 

3 may achieve our goal on the infiltration side, 

4 but we're losing the effectiveness on the thermal 

5 insulation side.

6 MR. RAMIREZ: Okay. Thank you.

7 Lois?

8 MR. SCHNEIDER: This is Peter. I have to 

9 agree --

10 MR. RAMIREZ: Peter, let me add you to 

11 the list. We'll make sure that we get your 

12 comments.

13 Lois?

14 MS. STARKEY: I just wanted a 

15 clarification from Peter, and also to point out 

16 on -- Peter, when you talk about testing, were 

17 you testing those modulars in the plant? Or were 

18 you testing them onsite?

19 MR. SCHNEIDER: We do both.

20 MS. STARKEY: Okay. 

21 MR. RAMIREZ: Okay. Was that it, Lois?

22 MS. STARKEY: Um-hm.
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1 MR. RAMIREZ: Okay. Michael?

2 MR. LUBLINER: Yeah. I am in 

3 communications with Joe Lstiburek, and I did 

4 reply to you, Bert. I haven't heard back from 

5 you.

6 I think there's an equitable way of 

7 dealing with this by providing an exemption for 

8 the floor cover, that the floor insulation needs 

9 to contact the under-decking between the I-beams. 

10 What I think is if you get the first few feet 

11 dense-packed or insulated well, that you'll be --

12 that this would be a way to address your problem.

13 In other words, after you get past the I14 beam, the insulation would go under the ducts, 

15 under the plumbing, under everything. And that's 

16 basically -- it falls into the belly. And that's 

17 the way we've been doing it in 100,000 homes.

18 I would also suggest that if you talk to 

19 Joe Lstiburek, he will adamantly disagree that 

20 the pressure boundary, the primary pressure 

21 boundary is the belly insulation. And if you'd 

22 like, I can get him on the phone right now if you 
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1 want.

2 (Pause.)

3 MR. RAMIREZ: Let's hold off on that.

4 MR. KESSLER: No, I don't think that's 

5 necessary.

6 MR. LUBLINER: Thanks. You definitely --

7 that was a good call, Bert.

8 (Laughter.)

9 MR. RAMIREZ: Mark?

10 MR. WEISS: Just wanted to provide some 

11 explanation of my NOVA.

12 I do have some concern about essentially 

13 mandating ENERGY STAR levels. But my primary 

14 concern again goes to the derivation of the cost 

15 figures. And I explained what those concerns 

16 were. Yes, I won't repeat them; I'm just trying 

17 to be consistent through this line of 

18 exploration.

19 MR. RAMIREZ: Thank you. Okay. 

20 Keith?

21 MR. DENNIS: I don't know if it matters. 

22 But where that red is, all penetration -- I don't 
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1 know if that's supposed to be up --

2 MR. BANTLE: To here?

3 MR. DENNIS: Up higher. Yeah, just I 

4 don't know. Because I think if it's not a 

5 thermal envelope, then you kind of miss it. And 

6 that's kind of where the duct -- it just seems 

7 like it goes -- what is this penetration and 

8 thermal envelope, penetration at the floor.

9 But all these things seem like things 

10 that somebody would have to do if they went into 

11 a retrofit situation. And I kind of understand 

12 the argument between, you know, where the gaps 

13 are and -- I mean, where the barrier is. Is it 

14 up here or down here?

15 But the reality is that if there is a 

16 problem with the belly board, you're going to 

17 have to go in and somebody's going to look at all 

18 the holes in the floor and start caulking them. 

19 And it's just easier to do it up front.

20 So, you know, I think that idea, I think 

21 it was -- maybe Manny was saying, you know, there 

22 is a test to see if the air penetration is, you 
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1 know, acceptable or not. And then there 

2 shouldn't be any, you know, a prescription here 

3 or there. It should just be whether or not that 

4 test is being met.

5 But, you know, in reality, I think that 

6 these things operate a little bit differently 

7 when you test them and in the actual 

8 manufacturing facility than when they're actually 

9 in the field. And, you know, just caulking holes 

10 in the floor is something that you don't want to 

11 have to do later, especially around a dirty 

12 toilet.

13 But, you know, there doesn't need to be 

14 holes in the floor if you can get, you know, 

15 manufacturer discounts on the caulking and just 

16 do it up front. Because the person going in with 

17 the caulking gun to fix somebody who has a $600-

18 a-month bill isn't going to bother to figure out 

19 if that's the actual problem. They're going to 

20 caulk that hole. So you might as well just have 

21 all the holes caulked.

22 And you don't want holes in the floor. I 
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1 mean, you just don't want it. So, I think it 

2 makes sense to do it this way. I think, you 

3 know, that's the only thing I take a position on.

4 I think taking something out of the life 

5 cycle assessment is kind of -- I don't know. 

6 That seems tenuous to me, taking things out. But 

7 this seems like commonsense measures that are 

8 going to have to be done in a retrofit situation 

9 if there's a problem. So you should probably 

10 just do them up front.

11 MR. RAMIREZ: Thanks, Keith.

12 David?

13 MR. TOMPOS: Dave Tompos.

14 I just wanted to make a comment that I 

15 agree that this should be included on all 

16 manufactured homes. I agree with Lowell on 

17 possibly doing a quarterly test if we can somehow 

18 avoid subpart I. And I don't know how that can 

19 be done, but I'll leave that up to DOE.

20 MR. RAMIREZ: All right. So, what is 

21 subpart I?

22 (Cross-talk.)
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1 MR. TOMPOS: I don't know who is in 

2 charge of that.

3 (Cross-talk and laughter.)

4 MR. LUBLINER: Thumbs up on that one?

5 (Pause.) 

6 MR. TOMPOS: That's a big "if," I think. 

7 I just want to clarify that. Because if we don't 

8 somehow avoid that, you're going to have to 

9 include the cost of testing every home.

10 MR. HAGERMAN: Joe Hagerman, DOE.

11 Let's just keep in mind we're here to set 

12 the standard, and we can make recommendations to 

13 the committee for the compliance enforcement like 

14 testing stuff. But I think we'll take all your 

15 comments into --

16 MR. TOMPOS: But I think it's difficult 

17 to make a decision on what we're going to do here 

18 if we're going to say that testing may or may not 

19 be involved.

20 MR. HAGERMAN: I don't disagree with you. 

21 But all you can do is make a recommendation. So.

22 MR. RAMIREZ: Yes. So we're going to put 
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1 that under the suggestions right there that will 

2 go to recommendations, right, for quarterly 

3 testing, excluding subpart I.

4 MR. HAGERMAN: Just keep in mind that the 

5 committee can make a recommendation to ASRAC to 

6 form this same committee to talk -- to do 

7 compliance and testing and enforcement.

8 (Cross-talk.)

9 MR. TOMPOS: Then I'm going to make a 

10 proposal that we just do a prescriptive method 

11 with a visual inspection and no testing. I'm 

12 just going to put that on the table as one 

13 proposal.

14 MR. RAMIREZ: Okay. Let me get Peter, 

15 then Mark.

16 Peter?

17 MR. SCHNEIDER: I'm good.

18 MR. RAMIREZ: You're good? Okay. 

19 Mark?

20 MR. WEISS: I just wish the OGC folks 

21 were here. And this goes back to part of what I 

22 was saying yesterday. And that is that cost to 
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1 the consumer in any regulatory situation is an 

2 amalgam of what it costs to comply with the 

3 standard plus regulatory compliance costs.

4 The way that this committee has been put 

5 together and its jurisdiction, its authority, has 

6 been defined necessarily excludes part of the 

7 cost that is inevitably going to occur as an 

8 incident of developing a standard.

9 Therefore, to me, that is an arbitrary 

10 delineation of our function that excludes a 

11 critical element. And that's part of my 

12 objection to the development of the cost data.

13 It's okay to say, "Well, we're going to 

14 have another committee and we're going to look at 

15 this later." But I have no assurance now, 

16 sitting here, deciding yes, no, whatever, of how 

17 that's going to play out.

18 MR. RAMIREZ: David?

19 MR. TOMPOS: Here would be my addition. 

20 I would say we eliminate these ACH requirement of 

21 five. We have a set of prescriptive measures 

22 that can be visually inspected, and that's what 
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1 we could push forward as a consensus. And then 

2 DOE outside of the regulations could come back 

3 and we could do a study to find out whether or 

4 not we're meeting that ACH of five.

5 But as soon as we put an ACH of five in 

6 there, there's going to have to be some kind of 

7 testing component. And I really, personally, 

8 don't think there's any way you're going to get 

9 around subpart I.

10 So, my proposal would be, and we can add 

11 to this if we want to, but we include all these 

12 ENERGY STAR provisions. I think if we make sure 

13 that we're sealing the floor, I don't think -- my 

14 personal opinion is, based on what I've seen in 

15 ENERGY STAR, you're not going to have any 

16 problems meeting five as long as we seal the 

17 floors and everything that we're supposed to do.

18 So that would be my -- a way to move this 

19 forward would be to say, forget the testing. Let 

20 DOE do that outside as a different study to make 

21 sure that we're getting the five ACH. And then 

22 just have a prescriptive visually inspected 
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1 requirement.

2 MR. RAMIREZ: Okay. So, Michael and Joe.

3 MR. LUBLINER: So, the site-built 

4 industry requires that all blower -- all houses 

5 to be blower-door tested. But my understanding 

6 is, the way it's being enforced is that it's --

7 they don't get red-tagged for it.

8 MR. TOMPOS: Exactly.

9 MR. LUBLINER: But it's an educational 

10 tool. Until the time that I don't see this 

11 anymore, to a QA plan, I would like to see this 

12 part quarterly testing as when analysts proposed. 

13 I would say that we should err on the 

14 conservative side and do the testing until it's 

15 shown that the testing isn't needed.

16 Based on my experience of going in any 

17 home on any dealer or lot and seeing holes that 

18 -- I mean, this one was actually caulked. But 

19 this is a big gap. I have been saying this for 

20 10 years on the consensus committee. All it will 

21 take is an enforced prescriptive approach that is 

22 in the quality assurance plan. And if there's a 
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1 systematic breakdown in the plan, like the P2 traps aren't being sealed, that should get a 

3 subpart I.

4 MR. TOMPOS: It should.

5 MR. LUBLINER: I represent the consumer 

6 on that committee, you know? And so I think that 

7 we should leave it at five. We should have a 

8 prescriptive that five should be advisory. And 

9 DOE should go out and see whether or not the 

10 enforcement process is effective in getting five.

11 And I think if we do quarterly -- what 

12 happens is we get feedback to the plant, says, 

13 "Hey, you know, we need to figure out a system, 

14 because we're missing this at one more point." 

15 The majority of leakage problems we see with 

16 ducts and envelopes has to do with setup code, 

17 has to do with the people after the fact not 

18 putting the marriage line in.

19 We find that if the marriage line is 

20 installed at the factory, as opposed to shipped 

21 loose in the vat and then left up to the retailer 

22 to install, we get much more effective blower-
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1 door tests in the field.

2 One consideration for a manufacturer is 

3 to require that the gasketing for the mating line 

4 be engineered and installed at the factory so 

5 that we improve the process. And I also would 

6 recommend strongly that the installation manuals 

7 recommend that the homes be blower-door tested. 

8 And I think that's a recommendation that would be 

9 a very good one for consumers.

10 And I also think -- and this is a final 

11 point. The State of Minnesota went ahead and 

12 asked HUD if the state energy code, which 

13 requires all site-built homes to be blower14 doored, if they could go in and require 

15 manufactured homes during setup to be blower16 doored.

17 And if I understand HUD's legal staff, 

18 they said that that was a federal -- that was a 

19 violation of the federal preemption.

20 Well, while I fundamentally disagree with 

21 that legal interpretation, I would certainly ask 

22 legal counsel to talk to HUD's legal counsel and 
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1 look into that interpretation, because in 

2 reality, that -- if we have the -- if you agree, 

3 then we're going to have to take an approach 

4 that's focused more on the installation manual. 

5 If you think that states do have the right to 

6 enforce requirements for blower-door tests at 

7 setup, then that opens it up for us to -- the 

8 states to be able to evaluate what's being sealed 

9 and what's not in the factory and on site.

10 So this is kind of an adjunct. It's a 

11 request for legal counsel at HUD to dialog, 

12 liaison, with the person that made that 

13 interpretation, come back to the committee, and 

14 see if we agree. At that point, I'd be in a 

15 position to do a better job of solving this 

16 problem. But it's the weak link in the chain is 

17 the setup.

18 Am I clear -- I mean, Rick, can we get 

19 the interpretation on this to the committee?

20 MR. MENDLEN: If I can?

21 MR. RAMIREZ: Yeah.

22 MR. MENDLEN: HUD's attorneys, together 
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1 with HUD staff, made the determination that it is 

2 preempted. Simple, end of story. Any 

3 consultation with DOE's attorneys it not going to

4 change that opinion.

5 Now, since you gave me the floor --

6 MR. LUBLINER: Thank you.

7 (Laughter.)

8 MR. MENDLEN: We don't do advisory 

9 standards. We're not going to put something in 

10 our standards that says that if you want to, you 

11 can test quarterly and the results don't mean 

12 anything. We're just not going to do that. And 

13 this is a regulatory program.

14 And then while I'm at it, if you want to 

15 make that more of a regulatory piece, you ought 

16 to say, whoever's typing, "and penetrations in 

17 floors must be sealed."

18 MR. RAMIREZ: Okay. 

19 MR. WEISS: Do you want to say a 

20 regulatory program with criminal penalties for 

21 not complying?

22 MR. MENDLEN: With criminal and civil 
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1 penalties. Thank you for not cutting one. 

2 Thanks for that.

3 (Laughter.)

4 MR. RAMIREZ: Joe, then David.

5 MR. HAGERMAN: You had your hand up, so 

6 if it addresses --

7 MR. TOMPOS: I did. I think we're real 

8 close here, Mike, on coming to something.

9 My suggestion would be -- because the 

10 problem here is somewhat the regulatory end of 

11 it. My suggestion would be, okay, we require all 

12 these prescriptively. I don't think there's any 

13 way we can have an advisory -- as HUD said, an 

14 advisory that we're going to meet five or 

15 whatever it is.

16 Don't make it a responsibility of the 

17 manufacturer. We'll do all this. It will go in 

18 the QC plan, and we will make sure that the 

19 manufacturer does it. Or we will have a subpart 

20 I. If they decide not to caulk around something, 

21 the manufacturer is going to have to go out, do 

22 inspections, make sure that the floors are all 
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1 caulked.

2 And based on our experience, we're going 

3 to meet five consistently if they do all these 

4 things consistently, like they will if we put it 

5 in the QC plan.

6 My suggestion would be, as far as the 

7 testing, make that the responsibility of DOE. If 

8 they want to verify that we're meeting five ACH, 

9 have them go out quarterly and do a study. I 

10 don't think it needs to be quarterly. But go out 

11 and do a study of some kind. They've got all 

12 kinds of money.

13 (Laughter.)

14 MR. TOMPOS: The manufacturers don't, and 

15 the consumers don't.

16 So that would be my suggestion. I think 

17 that gets us where we want to go. We're 

18 prescriptively getting to something that we think 

19 will get five ACH. We don't make five ACH a 

20 requirement, but DOE will do a study to make sure 

21 that we are meeting that.

22 And if not, we'll come back to the table 
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1 and say, "Okay. We're going to flash all the 

2 windows." I don't know what the next step would 

3 be to make sure we get that on a consistent 

4 basis.

5 MR. RAMIREZ: Joe, and then --

6 MR. HAGERMAN: I'm ready for a vote if -- 

7 I'll put my placard down. I just have a 

8 technical question for Emanuel. But it's --

9 MR. RAMIREZ: Okay. Then, what I'm 

10 hearing then is the amended vote is to adopt a 

11 prescriptive path of the seven components here, 

12 without the level. Right?

13 So, let me see a --

14 (Cross-talk.)

15 MR. RAMIREZ: I'm sorry, and the costs.

16 MR. TOMPOS: It's going to cost the same. 

17 We're just not saying that we have to meet this 

18 level. Because if we do that, now we have to 

19 test.

20 MR. RAMIREZ: Right. The costs are the 

21 same.

22 MR. TOMPOS: Yeah. 
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1 MR. RAMIREZ: It's just without the 

2 testing.

3 So let me see a show of thumbs, the seven 

4 prescriptive paths -- the seven items here using 

5 a prescriptive path.

6 MR. HAGERMAN: I just want one. So let 

7 me go ahead and ask my question. I'm not trying 

8 to stop a vote here, by any means. But I believe 

9 Emanuel Levy said that these seven prescriptive 

10 measures were a product of ENERGY STAR. And 

11 there's a study out there, after doing 500 tests 

12 on homes, that said these seven measures roughly 

13 get you a five.

14 Is that correct? And if that is correct, 

15 I mean, if you could point us to that study, that 

16 would just help. I mean, it would help to have 

17 that study referenced here.

18 MR. LUBLINER: Five on average.

19 MR. HAGERMAN: On average, right, on 

20 average.

21 MR. LUBLINER: Half of them don't make 

22 it.
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1 MR. HAGERMAN: And half of them get 

2 three.

3 MR. LUBLINER: Right.

4 MR. TOMPOS: Just real quick, I think if 

5 you define that air barrier, I think you're going 

6 to find that our consistent values are going to 

7 go way down. So.

8 MR. HAGERMAN: Way down, right, okay. 

9 But otherwise, I'd like to see that study. But 

10 it's not going to stop my vote from being 

11 positive.

12 MR. RAMIREZ: Let's see the vote.

13 (Pause.)

14 MR. BANTLE: Are we voting with the red 

15 in or the red out?

16 MR. RAMIREZ: Yeah. The way it's up 

17 there.

18 So, Michael, you were sideways?

19 MR. LUBLINER: Yeah, I'm sideways other 

20 than cost.

21 MR. RAMIREZ: Okay. Was anyone on the 

22 phone a no vote?
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1 (Pause.)

2 MR. RAMIREZ: All right. Then let it be 

3 shown that there was one no vote.

4 MR. HAGERMAN: I think two no votes?

5 MR. RAMIREZ: I'm sorry.

6 (Cross-talk.)

7 MR. SCHNEIDER: Three.

8 MR. RAMIREZ: Okay. And Lowell.

9 MR. RAMIREZ: And Peter.

10 MR. KESSLER: This is Bert. I'm voting 

11 no.

12 MR. RAMIREZ: So, we have --

13 (Pause.)

14 MR. RAMIREZ: Bert.

15 MR. SCHNEIDER: This is Peter.

16 MR. RAMIREZ: Peter.

17 MR. SCHNEIDER: Could you scroll back up? 

18 I was just wondering --

19 (Pause.) 

20 MR. RAMIREZ: Okay?

21 MR. SCHNEIDER: I have just a comment 

22 from Peter, Efficiency Vermont, just in regards 
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1 to the language at number three.

2 It just seems redundant, and maybe gap 

3 penetration for thermal envelope. Could we just 

4 spell that out as "gaps and penetration for 

5 walls, ceilings, and floors"? Just so it's 

6 really clear?

7 MR. BANTLE: Could you say that again, 

8 Peter?

9 MR. SCHNEIDER: I was saying that if the 

10 language could be just -- so it doesn't -- or it 

11 does make sense to me. To others it won't. But 

12 "gaps and penetrations in the walls, ceilings, 

13 and floors." 

14 MR. BANTLE: You're breaking up a little, 

15 Peter. Did you say "gaps in penetrations in the 

16 walls, ceilings, and" --

17 MR. SCHNEIDER: Floors.

18 MR. BANTLE: Floors?

19 MR. SCHNEIDER: "Shall be caulked," as 

20 opposed to putting "thermal envelopes and 

21 floors." And I sent a, just a picture with a red 

22 line of the section of the manufactured home. 
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1 And I just -- all I wanted to say was in regards 

2 to that, I sent it along to Javier and didn't 

3 know if we wanted to look at it as a group.

4 It might -- it would just help as far as 

5 what we're actually defining as that air barrier 

6 and in regards to cost as we move forward now 

7 with this, with bringing it outside of the wall 

8 to this building and floor plane, which it sounds 

9 like we're in agreement on. Then it's easier to 

10 just describe what needs to be done at each 

11 place.

12 That's at a fairly good number. But, 

13 yeah. I think that that's better. Thank you.

14 MR. BANTLE: So this is now the 

15 suggestion from Peter.

16 (Pause.)

17 MR. TOMPOS: Dave Tompos.

18 Just maybe something that makes it a 

19 little clearer is, instead of saying "walls, 

20 ceilings, floors," we say "in the pressure 

21 envelope." And then make sure that we define the 

22 floor as the pressure envelope, instead of the 
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1 belly.

2 MS. DICKENS: And the pressure envelope 

3 including walls, ceilings, and floor.

4 MR. TOMPOS: But the pressure envelope 

5 basically is around the entire --

6 MS. DICKENS: Right. But that way, at 

7 least the floors are being included for sure.

8 MR. RAMIREZ: Michael?

9 MR. LUBLINER: Subpart F, "thermal 

10 protection definitions: Pressure envelope means 

11 the primary air barrier surrounding the living 

12 space which serves to limit air leakage. In 

13 construction," and then it talks about ventilated 

14 cavities.

15 In construction using ventilated 

16 cavities, which isn't a discussion here, the 

17 pressure envelope is the interior skin.

18 So I would ask Rick to define, is the 

19 floor the pressure envelope? Or is the belly?

20 MR. MENDLEN: I don't give 

21 interpretations.

22 (Laughter.)
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1 MR. LUBLINER: I didn't think you would.

2 MR. TOMPOS: Well, no. I can answer 

3 that.

4 (Cross-talk.)

5 MR. TOMPOS: Here's how the industry is

6 interpreting -- I shouldn't say "interpreting," 

7 but how we're looking at that section, is that 

8 because it does reference ventilator wall 

9 cavities. So if you have a ventilated wall 

10 cavity, then it is the interior surface.

11 If I put an exterior sheathing on the 

12 home like an air barrier -- like a house wrap, or 

13 I seal those gaps on that exterior sheathing, in 

14 my opinion, now, the air barrier is the exterior 

15 of that wall.

16 That's -- and the industry has looked at 

17 the belly board as that exterior sheathing. All 

18 I'm saying is, if we want to ensure that we get 

19 that five ACH, we need to make sure that we 

20 change the industry's understanding of that and 

21 make sure we're real clear that the pressure 

22 envelope is that -- is the floor.
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1 I think there's going to be some 

2 contention -- and we also need to make sure that 

3 we understand that it can be the exterior of the 

4 walls. So that's why I was using pressure 

5 envelope instead of thermal envelope or walls, 

6 ceilings --

7 MR. LUBLINER: Even Rick wouldn't give an 

8 interpretation, but you're the engineer that 

9 represents manufacturing.

10 MR. TOMPOS: Well, I follow what HUD 

11 tells me. So --

12 MR. LUBLINER: If HUD doesn't tell you 

13 something, what do you do?

14 MR. TOMPOS: I follow what it says in 

15 black and white.

16 MR. RAMIREZ: Manny?

17 MR. SANTANA: Irrespective of whether you 

18 think the bottom board is the air barrier or the 

19 floor is the air barrier, you know, the IECC 

20 doesn't have a -- it doesn't define what pressure 

21 barrier is. You know, but like I said, 

22 regardless of which one you think, it's a good 
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1 idea to have them both. You don't want to have 

2 holes in either for a lot of reasons.

3 I don't think that's really, I think, 

4 important right now. You know, we're going to 

5 get into that later on. I'd be against calling 

6 the floor the pressure barrier if there is a 

7 bottom board there. But for other reasons, but 

8 as far as tightness goes, you want to have 

9 everything sealed.

10 MR. RAMIREZ: So that verbiage wouldn't 

11 work then?

12 (Pause.) 

13 MR. TOMPOS: Manny, I'm curious. What 

14 other problems are you going to have with calling 

15 the floor the pressure envelope? Because I --

16 MR. SANTANA: Well, the insulation is 

17 required to be in substantial contact with the 

18 decking. That's about it.

19 MR. LUBLINER: So, Manny, if we were able 

20 to make an exception on the substantial contact 

21 of the insulation between the I-beams, would that 

22 satisfy your problem?
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1 MR. SANTANA: Yeah, I think so. 

2 Reserving the right in case there's other 

3 information. But, yeah, I think so.

4 MR. LUBLINER: My understanding right now 

5 is that there's lots of homes out there where, 

6 when you get past the I-beam, the insulation is 

7 no longer in contact.

8 MR. SANTANA: Okay. 

9 MR. LUBLINER: Right now.

10 MR. SANTANA: Okay. 

11 MR. LUBLINER: Belly insulation by 

12 physics, right? So we're not doing anything 

13 different, right? By adding more insulation, you 

14 still don't have belly insulation contact from 

15 the I-beam to I-beam now. And it's not a 

16 problem. Why would it be a problem when we add 

17 more insulation?

18 And I would strongly recommend we make it 

19 explicit and say, "Between the I-beams, the 

20 insulation does not need to be in full contact 

21 with the floor." That will force us to put 

22 insulation from the I-beam to the rim, where air 
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1 leaks in through the staples on the belly 

2 insulation and travels across.

3 The more insulation you have horizontally 

4 there, the more infiltration you're limiting. 

5 And I think it's overkill to require insulation 

6 contact with the decking. And I don't think HUD 

7 requires it now.

8 So I think this is a -- if we could get 

9 that explicitly in there, it might help Rick not 

10 having to make an interpretation, and it would 

11 also solve this problem.

12 MR. MENDLEN: We'll get back to you on 

13 that, Mike.

14 (Laughter.)

15 MR. LUBLINER: Thanks, Rick.

16 MR. RAMIREZ: Okay.

17 MR. BANTLE: What would you like me to 

18 write?

19 MR. RAMIREZ: Yeah, for number three.

20 MALE VOICE: It's a consistent position.

21 MR. LUBLINER: Well, I think when we get 

22 to the discussion of floor insulation, and let's 
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1 make the exception between the I-beams, floor 

2 insulation contact with the decking is exempt. 

3 And that way, that solves your problem and then 

4 we can move forward with requiring this proposal.

5 (Pause.)

6 MR. RAMIREZ: Does that do it, Manny?

7 MR. SANTANA: Yeah. I think so.

8 MR. LUBLINER: And that's kind of what I 

9 proposed to you, Bert, the other day on the 

10 weekend. But I didn't hear back from you.

11 MR. KESSLER: That was intentional.

12 (Laughter.)

13 MR. LUBLINER: I resemble that.

14 MR. RAMIREZ: What do we need to do with 

15 three, though? Is that -- I think that, Bert, 

16 we're just still not quite wrapped up.

17 (Pause.)

18 MR. RAMIREZ: Yeah, Richard?

19 MR. POTTS: Richard Potts.

20 So the question is, is it floors or the 

21 belly board or belly wrap? That's what we -- do 

22 we need to vote on that? Or just figure that out 
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1 right now? Is that something we can just live 

2 with this and come back to it?

3 MR. SANTANA: Well, we can't use the term 

4 "pressure envelope," because it's not defined in 

5 IECC. In order for us to use it, we'd have to 

6 add what defines that.

7 MR. RAMIREZ: So, do we exclude "pressure 

8 envelope" and specifically say "the walls, 

9 ceilings, and floor"?

10 (Pause.)

11 MR. RAMIREZ: Okay. So how does that 

12 look for number three?

13 And, Michael, you might want to take a 

14 peek at that one.

15 MR. LUBLINER: I'm sorry. My wife lost 

16 her purse.

17 MR. RAMIREZ: And found it?

18 MR. LUBLINER: It was stolen from the 

19 hotel. And so I've been kind of multi-tasking 

20 here.

21 (Pause.)

22 MR. LUBLINER: Yes.
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1 (Pause.) 

2 MR. TOMPOS: I'm not trying to slow us 

3 down. Let me just throw one thing out there. 

4 I'm going to just throw it all on the table here. 

5 If I put a recept in the interior side of that 

6 wall, is that a penetration or not? Because in 

7 my opinion, the pressure envelope can be on the 

8 exterior of the wall, and I do not have to seal 

9 completely around every recept that's put in the 

10 house.

11 Now, if I have electrical going up into 

12 the roof cavity, I have to seal around that 

13 because I have to make sure I have a continuous 

14 pressure barrier around the entire house.

15 MR. MENDLEN: You have to seal joints 

16 between major envelopes.

17 MR. TOMPOS: So there's a big difference 

18 between saying that the -- I guess it's somewhat 

19 in the interpretation. I don't want to get into 

20 a disagreement with Rick. Kind of down the road 

21 on an interpretation of where that penetration is 

22 actually penetrating the wall.
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1 MR. SANTANA: But wouldn't that be part 

2 of the performance aspect of the code, where you 

3 define what your envelope is? It is the interior 

4 standard next?

5 MR. TOMPOS: Well, yeah, you have to do 

6 certain things to make it the exterior. So if 

7 you don't put some type of exterior board and 

8 sealant on the exterior, you're going to have to 

9 use house wrap or you're going to have to use 

10 some type of tape to seal between your OSB or 

11 your, you know, foam board or whatever you put on 

12 the exterior.

13 MR. SANTANA: Right.

14 MR. TOMPOS: Then you don't have it on 

15 the exterior. Then you would have to seal around 

16 every recept, in my opinion. I just want to make 

17 sure it's -- that the manufacturers have that 

18 option. Because I think you're going to prefer 

19 to put a house wrap on every house, which we may 

20 have to do anyway, but as opposed to sealing 

21 around every single recept that you put in the 

22 house.
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1 MR. RAMIREZ: So what about adding the 

2 verbiage, "exterior surfaces of walls, ceilings, 

3 and floors"?

4 MR. TOMPOS: Well, now we run into the 

5 problem with the belly. Because you say it that 

6 way, the exterior surface is my bottom board. 

7 The exterior surface --

8 MR. RAMIREZ: "Of walls"? "Of walls,"

9 period, and "the ceilings and floors" separate?

10 MR. DENNIS: Or you could just put 

11 "ceilings and floors" first. And then "exterior 

12 surfaces."

13 MR. RAMIREZ: All right. So, Ted, put 

14 the "ceilings and floors" in front of "exterior 

15 surfaces."

16 MR. TOMPOS: We could just move forward 

17 and let DOE work on the language.

18 MR. RAMIREZ: You know what, though? But 

19 I think we're right about there. I think we're 

20 right about there. So I --

21 MR. SANTANA: Okay. But what if you 

22 don't have a house that -- what if your air 
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1 pressure -- or what if your, you know, if you're 

2 going to seal every one of your recesses --

3 (Cross-talk.)

4 MR. TOMPOS: Then you're going to have to 

5 seal it.

6 MR. SANTANA: It wouldn't give you that 

7 option.

8 MR. TOMPOS: That's fine.

9 MR. SANTANA: I'm not saying I want to. 

10 But this here wouldn't give you that option, you 

11 know. Okay. So what if you're a manufacturer 

12 that currently foams around all your recepts?

13 MR. RAMIREZ: Have at it.

14 MR. TOMPOS: You can continue to do that.

15 MR. SANTANA: But this here says -- I 

16 mean, what if you foam around the penetrations on 

17 the inside of the wall, but you don't want a 

18 house wrap? And you don't want it through the X 

19 here? This will encourage you to do the X here.

20 MR. TOMPOS: Well, then your pressure 

21 envelope is on the interior, because you have a 

22 ventilated cap roof.
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1 MR. SANTANA: Right.

2 MR. TOMPOS: That's why I had pressure on 

3 the opening there. But --

4 MR. RAMIREZ: There seems to be too much 

5 complication around that term.

6 MR. SANTANA: Well, why don't we just --

7 I like the idea of the pressure envelope here. 

8 Why don't we just add the definition that HUD has 

9 for "pressure envelope"? I think it's valid.

10 MR. TOMPOS: Well, because there's a 

11 little clarification issue on if that's the floor 

12 or the belly board. There's industry practice 

13 right now that assumes that it's the belly board.

14 MR. RAMIREZ: We need to change that.

15 MR. SANTANA: But that's up to the -- I 

16 mean, I don't see that's it.

17 MR. TOMPOS: But I don't think we need to 

18 -- I don't think -- once these regulations come 

19 out, we can't determine that layer. We need to

20 know that it is the floor. In my opinion, it has 

21 to be that floor, and we need to seal everything 

22 in the floor.
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1 MR. HAGERMAN: Can you just say "pressure 

2 envelope at the floor"? Go ahead and define 

3 where you think the pressure envelope is? Say 

4 "the pressure envelope at the floor"?

5 MR. TOMPOS: Yeah. As long as you put 

6 out an interpretive bulletin that explains it.

7 MR. HAGERMAN: Well, that's obviously not 

8 the pressure envelope at the belly board, right?

9 MR. TOMPOS: That's correct.

10 MR. HAGERMAN: It's the pressure envelope 

11 at the floor.

12 MR. TOMPOS: Okay. But the opposite of 

13 that is, where is the pressure envelope on the 

14 wall?

15 MR. HAGERMAN: Well, we just keep the 

16 exterior surface rule on.

17 (Cross-talk.)

18 MR. LUBLINER: Separate that discussion. 

19 MR. TOMPOS: Not everybody is going to 

20 have it at the exterior, because they're not 

21 going to -- they may or may not --

22 MR. HAGERMAN: They have a vented wall 
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1 cabinet?

2 MR. SANTANA: You know, if you have --

3 when you have a vented wall --

4 MR. TOMPOS: There's walls that do not 

5 have exterior sheathing on them.

6 (Cross-talk.)

7 MR. TOMPOS: I don't know how you install 

8 house wrap. We'll get to that when we talk about 

9 requiring house wrap. You can't install house

10 wrap on a house that does not have exterior 

11 sheathing.

12 MR. HAGERMAN: Not all houses need house 

13 wrap.

14 MR. TOMPOS: Okay. 

15 MR. HAGERMAN: Is what you just said, 

16 right?

17 MR. TOMPOS: Yeah. Well, we can't 

18 install it in some houses.

19 MR. MENDLEN: Let's just seal the 

20 receptacles, then.

21 MR. TOMPOS: Then you would have to 

22 reseal the receptacles.
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1 I just want to make sure it's clear. I 

2 mean, I think we all are on the same page as to 

3 what we need to do.

4 MR. RAMIREZ: Michael?

5 MR. LUBLINER: Yeah. My understanding is 

6 that you try to align the pressure boundary and 

7 the vapor barrier. And most of the time, for 

8 moisture purposes, most of the time in building 

9 science when we advise large production builders 

10 and stuff, we tell them to caulk and seal all the 

11 penetrations in the drywall walls.

12 Because most of the moisture that enters 

13 into a house isn't through diffusion. It's 

14 through those places. And so, that's why you 

15 want to align that. And I would say that if -- I 

16 would be willing to say, if you put foam 

17 sheathing or -- and you tape it all, tape every 

18 joint and everything, and you don't caulk all 

19 that other stuff, that you probably are going to 

20 have a hard time meeting five on all houses.

21 But I also would argue that you should do 

22 it for moisture reasons, that it should be 
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1 aligned for moisture reasons. That's basically 

2 what Building America has taught me over the 

3 years.

4 MR. TOMPOS: Well, my comment to that 

5 would be, we aren't doing it now. And we're only 

6 --

7 MR. LUBLINER: Right. We're meeting 

8 five.

9 MR. TOMPOS: Yeah, on an average.

10 MR. LUBLINER: Okay. Good. So when you 

11 do tape the penetrations and use Tyvek and don't 

12 caulk the plate -- do you have to caulk the 

13 plate?

14 MR. TOMPOS: It's not being done that way 

15 anywhere other than Wisconsin right now.

16 MR. LUBLINER: Okay. Because I was going 

17 to say it's kind of -- if it's not being done, 

18 it's kind of tough. But I don't have a lot of 

19 experience testing homes with the primary 

20 pressure boundary's exterior. So I would defer 

21 to you. But I would caution you that you will 

22 run into moisture problems in certain areas if 
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1 you don't align the vapor barrier with the 

2 pressure barrier.

3 MR. RAMIREZ: All right. Ishbel?

4 MS. DICKENS: So, as the nontechnical 

5 expert in the room, I'm just wondering if the 

6 sort of introductory sentence above all of the 

7 conditions really encapsulates what you all are 

8 talking about, and we don't need more.

9 (Pause.)

10 MR. WEISS: I want to make sure I 

11 understand what you're saying. Could you say 

12 that again?

13 MR. SCHNEIDER: I would just argue that, 

14 you know, there are not going to --

15 (Cross-talk.)

16 MR. RAMIREZ: Hold on a second. Okay. 

17 Was that Mark?

18 (Chorus of "It was Peter.")

19 MR. RAMIREZ: Peter?

20 MR. SCHNEIDER: Hi. Yeah. This is 

21 Peter, Efficiency Vermont.

22 Ishbel, I would just suggest there are 
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1 not -- it gets subjective with that opening 

2 sentence -- criteria below that and guidance, 

3 manufactured installation instructions were 

4 really not exactly what we're talking about here. 

5 And that's because it's such a confusing topic.

6 I would note again that there -- I would 

7 agree with what Michael said in regards to the 

8 vapor barrier aligned with our air barrier or 

9 pressure boundary.

10 Unfortunately, our manufactured housing 

11 belly is a very poor air barrier. You know, in 

12 Vermont, we require a rigid air barrier aligned 

13 with the exterior of the thermal envelope, so it 

14 wouldn't allow, you know, something flexible like 

15 the nylon belly stapled, and have certain tapes 

16 that are approved as well.

17 So, I think that that just causes 

18 complications. And I would refer back to the 

19 diagram that I sent to Javier in regards to, you 

20 know, what is the ideal alignment of the air 

21 barrier all the way around?

22 And I think that we're going to need to
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1 -- the DOE needs to provide good guidance on how 

2 people are dealing with the transition in your 

3 horizontal, for example, like your floor and 

4 ceilings, with the walls. And be sure that we're 

5 not providing guidance that puts, you know, our 

6 manufacturers' envelope at risk of condensation 

7 issues and mold and mildew.

8 MS. DICKENS: Peter, thank you. This is 

9 Ishbel.

10 Just in response, I was not suggesting 

11 that we just take the first phrase and delete the 

12 seven criteria. Simply that I felt the first 

13 phrase encapsulated all the sort of nuances in 

14 the language that people were suggesting.

15 And so, just to keep in mind that we're 

16 not just looking at criterion three, but we're 

17 looking at the introductory phrase as well, and 

18 then keep continuing to keep the list in place.

19 MR. RAMIREZ: All right. Michael, Michael 

20 Wade, did you have something?

21 MR. WADE: Can you guys really hear me?

22 MR. RAMIREZ: Yeah.
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1 (Chorus of "Yeah.")

2 MR. WADE: Son of a gun! 

3 Congratulations, whoever is controlling the 

4 voice. This is the very first call since we have 

5 started this whole program that I've been able to 

6 speak, and I greatly appreciate it.

7 (Laughter.)

8 MR. WADE: And if I sound sarcastic, I 

9 am. And I apologize.

10 MR. RAMIREZ: All right. The floor is 

11 yours, Michael Wade.

12 MR. WADE: All right. Here's my comment, 

13 and here's my question. You know, I'm all for 

14 sealing. And Lubliner, you don't have to throw 

15 any comments. And we do it already. Been doing 

16 it for years, been doing it since the year 2000, 

17 okay?

18 But here's a question. How do we seal at 

19 the P-trap opening? Okay? If we do that, we 

20 seal those off, how are we going to have access? 

21 Anybody?

22 MR. RAMIREZ: Yeah, Michael?
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1 MR. LUBLINER: Yeah. Using EPDM rubber 

2 that's commonly found on tires or in the plant as 

3 scrap. You staple it down over the P-trap. You 

4 cut an X in it. And you push the -- and you 

5 caulk the edges. And you push the pipe up 

6 through it. I'd be happy to show you details and 

7 the way it's done in the factory if you're 

8 interested.

9 MR. WADE: We can get a pipe through it. 

10 How are you going to get your hands in there to 

11 work on it if you have to?

12 MR. LUBLINER: You cut the --

13 MR. WADE: I mean, we can do that, Mike. 

14 But then we'll have -- but you'll destroy it if 

15 you get in there to work on it, if anybody has 

16 to.

17 MR. LUBLINER: Yeah, that's a big "if." 

18 Rarely do you have to fix a leak in a P-trap.

19 MR. WADE: No, it's not a big "if." It 

20 happens.

21 MR. LUBLINER: Yeah, it does happen, but 

22 not very often.
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1 MR. WADE: No, I disagree.

2 MR. LUBLINER: So if you want me to 

3 answer your question, I will.

4 MR. WADE: Go ahead.

5 MR. LUBLINER: You take a piece of EPDM 

6 that's a little bit bigger than the hole, the P7 trap. You staple it down and caulk the seams. 

8 You scribe an X in the rubber, which gives you a 

9 seal when you bring the plumbing through that 

10 penetration.

11 If you have to access that, you cut that. 

12 You cut it, access it. It's just like -- it's no 

13 different than what they do now with the bottom 

14 board has an access port. It's just making the 

15 access point above it.

16 I would suggest that the requirement in 

17 HUD for that access port be that -- be there is 

18 part of the problem. I think that this would 

19 solve that problem, if we could fix the problem 

20 with the access being in the belly by just 

21 requiring a label that says, "This is where the 

22 P-trap is."
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1 In reality, what happens is they cut into 

2 the belly anyway. So, but getting back to your 

3 question, that's how we do it. We use an EPDM 

4 rubber, and if in the one out of a hundred or one 

5 out of a thousand homes the plumbing leaks at the 

6 P-trap, then you just cut in and, right now, you 

7 go to that access port that HUD requires -- and I 

8 don't think it's necessary -- and you cut that 

9 rubber and fix it.

10 MR. RAMIREZ: I feel like --

11 MR. WADE: It's a possibility.

12 MR. RAMIREZ: I'm sorry. What was that, 

13 Michael?

14 MR. WADE: That is a possibility. What 

15 Mike's proposing, is possible, is doable.

16 MR. LUBLINER: Thank you, sir.

17 MR. WADE: And I appreciate the 

18 opportunity to speak. I've tried dozens, 

19 literally dozens of times to speak over all the 

20 meetings we've had. And this is the first time 

21 I've been able to.

22 MR. RAMIREZ: All right. Well, we'll 
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1 make sure that Emily passes on the secret sauce 

2 there for whoever's manning the computer next 

3 time.

4 I feel like the greyhound chasing the 

5 rabbit. You know, like I'm almost there, right? 

6 I'm almost there, but I can never quite get it.

7 So, let me ask the group, do we need to 

8 end this conversation? Or are we there?

9 MS. DICKENS: We're there.

10 MR. TOMPOS: I think we're there.

11 MR. RAMIREZ: All right. So, what we 

12 have on here is "Gaps of penetrations in the 

13 ceilings, floors, and exterior surfaces of walls 

14 shall be sealed."

15 And Ishbel pointed out that the -- some 

16 of the little nuances that we were talking about 

17 are somewhat covered in that introductory 

18 paragraph as well. But there's just more detail 

19 in the seven points. That, without the level 

20 five, without referencing to testing, but with 

21 the same cost numbers --

22 MR. HAGERMAN: With recommendations for 
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1 DOE to consider testing.

2 MR. RAMIREZ: Is that the consensus? Let 

3 me see a show of thumbs.

4 (Pause.) 

5 MR. HAGERMAN: Or it's throughout the 

6 whole standard.

7 MR. TOMPOS: The manufacturer will not 

8 have to do testing.

9 MR. RAMIREZ: Correct. It's just a 

10 recommendation passed on to ASRAC.

11 Mike?

12 MR. LUBLINER: I'd be willing to vote for 

13 this, except I'm a little uncomfortable with this 

14 "exterior surface." So I would ask DOE, if they 

15 could, to talk to their moisture people and do 

16 some WUfi analysis on this. That's the way that 

17 they look at moisture requirements and whether 

18 the walls are going to rot or condense.

19 If you could do some WUfi analysis on 

20 this and come back to us, but I'd be willing to 

21 vote for it now pending some WUfi analysis. 

22 Because what I don't want to do is make the walls 
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1 colder and then increase condensation with that.

2 MR. TOMPOS: And I would agree with that. 

3 I think the industry wants to do whatever the 

4 best practice is.

5 MR. LUBLINER: Right, right.

6 MR. RAMIREZ: All right. So I'm probably 

7 butchering this one, but can you do a WUfi 

8 analysis?

9 MR. LUBLINER: Sorry, Joe.

10 MR. RAMIREZ: Okay. 

11 MR. LUBLINER: I don't want to 

12 unanticipate the consequences from our action.

13 MR. RAMIREZ: Is that something that's 

14 doable?

15 (Mr. Hagerman nodded yes.)

16 MR. RAMIREZ: Okay. So, DOE is saying 

17 that that is something that they could do.

18 So with that, let me see the thumbs.

19 (Pause.) 

20 MR. RAMIREZ: Okay. So, anyone on the 

21 phone have their thumbs down?

22 (Pause.)
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1 MR. KESSLER: One F in WUfi.

2 (Inaudible conversation.)

3 MR. RAMIREZ: So, any thumbs down on the 

4 phone?

5 (Pause.)

6 MR. RAMIREZ: Okay. All right.

7 MR. SCHNEIDER: This is Peter, Efficiency 

8 Vermont.

9 Just a quick -- I was just wondering, 

10 what percentage of manufactured homes, if any, 

11 are delivered with sheetrock?

12 MR. RAMIREZ: Peter, hold on. I'm trying 

13 to wrap this one up. We'll get that question 

14 later. Right now, I'm just looking to count the 

15 votes.

16 And it looks like there were three folks 

17 that had their thumb down. That was Mark, 

18 Lowell, and Manny. Is that accurate?

19 MR. HAGERMAN: Can we ask them just to 

20 explain real quick why they're down? Just if 

21 it's a big thing or a small thing?

22 MR. SANTANA: Manny with Cavco.
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1 I've got a small thing. The only reason 

2 why I'm down is that I'm just not completely 

3 comfortable that we're considering all the 

4 sidings that are currently in use.

5 I don't know if, you know, will metal 

6 siding still be available to install if we have 

7 to seal? You know, they have gaps along the 

8 bottom. So it could be something, you know. I'm 

9 not an expert in insulation of metal siding.

10 MR. RAMIREZ: Ted.

11 MR. TOMPOS: Again, Manny, if you do that 

12 without an exterior air barrier, then you're 

13 going to have to seal around the recepts. I 

14 don't think there's a huge cost to that. And I 

15 do think that probably is best practice.

16 MR. SANTANA: Well, all I'm saying, you 

17 know, so with my understanding of how metal 

18 siding is installed, do you install the metal 

19 siding directly to the stud, so there is no

20 sheathing on the exterior? If this says "gaps, 

21 penetrations on the exterior surfaces of the 

22 walls," it doesn't say whether the exterior 
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1 surface is not the interface between the outside 

2 and inside, then you do the inside.

3 You know, so I just don't see the option 

4 for doing the inside if that's what your assembly 

5 calls for. And that's the only reason why I'm 

6 not -- everything else is fine.

7 MR. RAMIREZ: Well, correct me if I'm 

8 wrong, but these are minimums. Correct?

9 MS. DICKENS: I think so.

10 MR. RAMIREZ: If you wanted to do more --

11 MR. SANTANA: Right. But I wouldn't do 

12 the exterior surface is what I'm saying.

13 MR. RAMIREZ: Ah.

14 MR. SANTANA: Because there is no 

15 exterior surface.

16 MR. RAMIREZ: I see what you're saying.

17 MS. DICKENS: If there's none, then you 

18 can't do it.

19 MR. SANTANA: That's what I'm saying. So 

20 the -- and I want to be able to meet the minimum.

21 MR. RAMIREZ: Got you.

22 MR. SANTANA: Do you see what I mean?
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1 MR. RAMIREZ: Um-hm.

2 MR. LUBLINER: You're doing metal siding. 

3 You've got to caulk the breaks on the --

4 MR. SANTANA: But this doesn't allow me 

5 to caulk. That is what I'm saying, because it's 

6 mandating that you caulk the exterior surface of 

7 the walls. But you can't. If you can't, then 

8 you can't meet the minimum. That's one reason 

9 why I have -- so it's just a wording issue.

10 MR. RAMIREZ: Is there a way to tweak 

11 that to fix it?

12 MR. SANTANA: Well, I'll vote yes if I 

13 can add a suggestion for DOE to consider the 

14 option for the interior --

15 MR. HAGERMAN: That's fine.

16 Did you hear that, Ted? He's asking just 

17 for the suggestion.

18 MR. SANTANA: That DOE consider the 

19 scenario where you can't caulk the exterior 

20 surface of the wall, and find a way to 

21 incorporate that.

22 MR. HAGERMAN: Such as?
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1 MR. LUBLINER: Would that be 

2 characterized as "no structural sheathing"?

3 MR. BANTLE: Cannot be caulked.

4 MR. SANTANA: Yeah. Cannot be sealed. 

5 Where the exterior surface cannot be sealed to 

6 provide an option for the interior surface.

7 MR. HAGERMAN: So it's like such as the 

8 case where the exterior sheathing becomes the 

9 structural sheathing. Isn't that right? Or it's 

10 the same?

11 MR. LUBLINER: Yeah. How do you guys --

12 MR. SANTANA: Well, I think if we just 

13 leave that first part of the sentence, that will 

14 capture, you know, without muddying up anything.

15 MR. RAMIREZ: All right. Lowell, what 

16 was your thumbs-down?

17 MR. UNGAR: So, my concern is that we 

18 still have no testing at all by the

19 manufacturers. And so while there's prescriptive 

20 requirements, they're somewhat vague. And you 

21 know, what we're hearing is there's a huge range 

22 in the actual sealing, that is, once it's tested. 
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1 And other than an eventual study by DOE, should 

2 DOE have the funds, there's kind of nothing to 

3 address that.

4 And so, my -- so first of all, I would 

5 note, I mean, I think unlike some of the other 

6 things we've discussed, this strikes me as very 

7 important. When I look at the numbers, there's 

8 really large energy savings here.

9 And second, I would note, on my -- being 

10 I'm not an expert in manufactured housing, my 

11 understanding is, unlike stick-built homes, where 

12 the fundamental mechanism is an inspection of

13 every home, the fundamental mechanism for 

14 manufactured homes is a quality control procedure 

15 in the factory, that you try to make sure the 

16 factory is doing it. And it seems to me that 

17 periodic testing should be a part of that quality 

18 control procedure.

19 Now, I understand in the end we're not 

20 addressing all of the -- we're not addressing the 

21 enforcement here. But if there's no mention of 

22 ACH, no mention of actual performance 
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1 achievement, I don't know how you later get to 

2 that point of, then, how do you incorporate 

3 testing to make sure that the factory is doing an 

4 effective job?

5 And so, I understand the argument not to 

6 have it as a mandatory requirement on each home. 

7 But to not put it -- you know, it seems to me 

8 there should be something here about that we're 

9 trying to achieve a performance level that then 

10 enables DOE or this future committee, or whoever 

11 is then going to determine enforcement, to take 

12 that into account and try to come up with a 

13 procedure that works.

14 MR. RAMIREZ: Okay. I think Michael has 

15 a response to that before I get to Mark.

16 So, Michael?

17 MR. LUBLINER: Yeah. So I kind of held 

18 my notes on the -- when I voted up on that one, 

19 because I agree totally with you. But I was in 

20 the understanding that if this was found in the 

21 field, there would be a subpart I.

22 MR. TOMPOS: Yes. That is a requirement.
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1 MR. LUBLINER: So if I go out with a 

2 utility program and look at existing homes that 

3 have been built after this code -- and I want to 

4 make sure this is on the record -- and we find 

5 that these things are being missed, then there 

6 will be a class subpart I?

7 (Mr. Tompos nodded yes.)

8 MR. LUBLINER: Thank you.

9 MR. MENDLEN: He can't confirm that, but 

10 I will.

11 MR. RAMIREZ: Thank you.

12 (Laughter.)

13 MR. MENDLEN: That's what we do. I can 

14 confirm that.

15 MR. RAMIREZ: Okay. Mark?

16 MR. WEISS: I think -- Mark Weiss, MHARR.

17 I think Joe was out of the room when I 

18 explained previously once or twice the reason for 

19 my no vote. And as I said then, I do have some 

20 concern about essentially mandating ENERGY STAR 

21 for all manufactured homes.

22 But more importantly, again, it becomes a 
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1 question of the derivations, the costs, and the 

2 completeness of the cost information, as I 

3 explained yesterday, at length.

4 MR. RAMIREZ: Got you. I assumed that's 

5 what it was. But I wanted to at least give you 

6 the opportunity to just put it on the record.

7 MR. WEISS: Thank you.

8 MR. RAMIREZ: Lois?

9 MS. STARKEY: Yes. Just FYI, Mark, 

10 understand, but we're looking at a 2015 IECC. So 

11 this proposal is pretty much below what the IECC 

12 requires.

13 MR. WEISS: I understand. Again, my main 

14 concern, as I've indicated, is with the 

15 derivation cost information rather than the 

16 substance of this.

17 MR. RAMIREZ: So, with those 

18 explanations, Manny, with the addition of that 

19 suggestion for consideration there, you're good.

20 Lowell and Mark, I don't think that the 

21 suggestions that were raised on there 

22 sufficiently address what you had raised, nor to 
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1 switch your consensus vote. Is that accurate?

2 MR. UNGAR: Yeah, at this point.

3 MR. RAMIREZ: Okay. 

4 David?

5 MR. TOMPOS: I just want to respond a 

6 little bit to Lowell. Did Emanuel send that 

7 document yet? I mean, you mentioned that there 

8 was not data. And I think there is data that 

9 shows that, with what we're doing now, and we're 

10 improving on that, our average is around five.

11 You made the comment about the testing 

12 being done in the site-built world. And there is 

13 no requirement for a certified HERS rater to do a 

14 blower-door testing. It's done by the HVAC guy 

15 that went out and bought a piece of equipment. 

16 He has no requirement to be trained. And I 

17 promise you that that is a test that should be 

18 done by somebody that's trained.

19 MR. UNGAR: And I certainly wasn't trying 

20 to say that the site-built is more effective 

21 enforcement than factory out. That was not at 

22 all my point.
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1 MR. TOMPOS: And we do have a lot of 

2 experience with that. I mean, I've been in a 

3 net-zero home. At least that's what they called 

4 it. And we could not get it to pass ENERGY STAR, 

5 you know, just because the blower-door testing 

6 didn't work. They had gaps everywhere. They 

7 didn't know how to install it.

8 So, to say that I guarantee you if we do 

9 this, it's going to be regulated to the point 

10 where we're going to make sure they do it. And 

11 like Michael alluded to, if we find out they 

12 aren't doing it, we're going to have to go out 

13 and fix all those houses they didn't do it to.

14 So I think there's already that 

15 regulatory aspect to this, where based on my 

16 experience with doing blower-door testing, if we

17 do these things and make sure the manufacturer is 

18 doing that, I think we can keep this -- this is 

19 the most cost-effective way to save energy, right 

20 here. And if we can do this and avoid the 

21 testing of every home, I think we're doing what 

22 the statute says we need to do.
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1 We're keeping it affordable by avoiding 

2 the testing. I'm confident that we're going to

3 consistently be below that five ACH. I think 

4 we're going to even be better if we do all these 

5 things.

6 MR. RAMIREZ: Lowell, anything?

7 (Cross-talk.)

8 MR. RAMIREZ: I'm not trying to twist 

9 your arm. I just want to make sure that the 

10 record is reflected accurately.

11 MR. UNGAR: I'll just note that I think 

12 we're actually close. I agree that I'm not 

13 trying to push for, you know, testing every home. 

14 You know, that certainly isn't in terms of what I 

15 could live with. I just think there should be a 

16 solution, which I understand you could live with 

17 if you could see a way of doing it 

18 administratively, there being periodic testing.

19 So I think we're actually in the same 

20 place in terms of where we could -- you know, we 

21 could agree on what could actually be done. We 

22 just don't seem to be able to get there under the 
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1 terms of the committee and their requirements.

2 MR. RAMIREZ: Right. Right.

3 Let me wrap this up, unless you're --

4 MR. UNGAR: Sure. Sure.

5 MR. RAMIREZ: So -- I'm sorry, is someone 

6 on the line?

7 MR. SCHNEIDER: It's Peter, when I have a 

8 chance to say something.

9 MR. RAMIREZ: Yeah. I just want to wrap 

10 this one up because it sounds like we have 

11 consensus. There were two no votes with Mark and 

12 Lowell. There's the leakage -- ah, what's it 

13 called? -- air leakage issues wrapped up right 

14 there.

15 Peter?

16 MR. SCHNEIDER: Yes. I would suggest 

17 that, of the suggestions below, that if this 

18 worked for Lowell, this would be better for me if 

19 instead of it saying, let's see, "recommendations 

20 for DOE" since you're testing not manufactured, 

21 is there a way that we could just stick with 

22 saying that we would adopt these strategies for 
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1 achieving ACH five, DOE test for --

2 MR. RAMIREZ: I'm sorry, Peter. That 

3 whole last part was just too garbled.

4 MR. SCHNEIDER: Oh. Sorry. I'll get my 

5 phone for the afternoon. I apologize.

6 I was just saying that, is there any way 

7 that, instead of a recommendation to DOE for just 

8 testing, that we actually --

9 MR. BANTLE: We lost you again, Peter.

10 MR. HAGERMAN: Peter, can you just type 

11 in your comment? We're having a hard time 

12 hearing you. So if you could just send us an 

13 email, we'll capture that. We apologize.

14 MR. RAMIREZ: Yeah. I think it's a

15 definite "maybe."

16 (Laughter.)

17 MS. DICKENS: Possibly.

18 MR. SANTANA: It's possible.

19 MR. RAMIREZ: All right. But I do want 

20 to make it clear that it is consensus. I 

21 understand that Peter's trying to make some 

22 suggestion on there. And if we could add that
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1 without modifying it, I'm sure that won't be an 

2 issue.

3 We have just about eight minutes left 

4 being before lunch. Emanuel just did send in the 

5 data for the whole-house leakage. Did you want 

6 to use those last few minutes just to take a peek 

7 at that? Or are we good?

8 MR. HAGERMAN: I think we're good. Joe 

9 Hagerman, DOE.

10 I think we're good. I mean, if we go up, 

11 scroll up to the top of the page, I don't think 

12 we've addressed the cost issue yet, have we? So 

13 do we think we agree that the measures are there? 

14 And I think we agree that the measures, you know, 

15 represent the five, so we can get rid of the 

16 five.

17 And I think now we just have to agree on 

18 the costs that we should use in the life cycle 

19 analysis.

20 Again, I think DOE's official position is 

21 we modeled those costs after the ENERGY STAR, so 

22 we're comfortable with those costs, even though 
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1 we believe, in just the observation of it, that 

2 they seem pretty conservative. But we're okay 

3 with them being conservative.

4 MR. SANTANA: Didn't we vote on the costs 

5 and have two no's?

6 MR. HAGERMAN: Well, let's just take a 

7 revote on the costs.

8 MR. LUBLINER: I have a question on the 

9 costs before we revote, actually.

10 MR. RAMIREZ: Yeah, go ahead.

11 MR. LUBLINER: So, we have a cost that 

12 was defined by you guys. I wonder if it included 

13 the cost of sealing those receptacles and

14 everything that energy requires. Because if 

15 we're saying now that if it does, then those 

16 costs stay the same. If it doesn't --

17 MR. HAGERMAN: So we can provide you --

18 it's from an ENERGY STAR report.

19 MR. LUBLINER: But -- yeah.

20 MR. HAGERMAN: So we can provide, and you 

21 can review what it includes. But it doesn't 

22 include -- it does not include the test, though.
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1 MR. LUBLINER: No, no. I still 

2 understand that. What I'm saying is that we 

3 agreed that that report includes just this labor 

4 and materials. What I'm saying is, does it 

5 include, does the labor and materials include the 

6 caulking of all the wall switch plates or not?

7 If this includes the cost of the switch 

8 plates and you're not requiring that, then the 

9 costs have to come down.

10 (Pause.)

11 MR. RAMIREZ: David?

12 MR. TOMPOS: I think that is going to be 

13 required in some cases on a lot of the houses 

14 that do not have an exterior -- I don't even want 

15 to say the word "air barrier" or "pressure 

16 envelope." So there are some cases where that 

17 can happen.

18 You've got to also remember they're not 

19 doing some of the foaming around the windows. So 

20 there are a lot of things that they're not doing 

21 right now that we are going to make them do. So 

22 there is some costs in there.
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1 I don't know how we break it down. I 

2 think we're in the weeds again as far as trying 

3 to take off 50 bucks or 100 bucks off that price. 

4 Because at the end of the day when you do your 

5 life cycle cost analysis, I think you could put a 

6 $500 cost in there, and sealing of the envelope 

7 is going to show that it is a cost-effective way 

8 to do --

9 MR. HAGERMAN: I can read to you real 

10 quick what it entails. It requires "air sealing 

11 of penetration cracks and other openings in the 

12 home's thermal enclosure system." Let's hope we 

13 don't have to define that. It requires "all 

14 joints, seams, and other penetrations, other 

15 sources of infiltration, any utility penetrations 

16 be caulked, gasketed, weather-stripped, or 

17 otherwise sealed with an air barrier material."

18 The code specifically requires that "the 

19 junction of the foundation's seal plate be 

20 sealed, that the space between the window, door 

21 jambs, and framing be sealed, the duct shafts, 

22 utility penetration, the walls, and flue shafts 
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1 open to the exterior unconditioned spaces be 

2 sealed, recessed luminaries be sealed."

3 The code requires that "access doors from 

4 conditioned space to unconditioned space be 

5 weather-stripped and insulated to a level 

6 equivalent." So I mean, I think that's 

7 everything. I mean --

8 MR. TOMPOS: Now, sealed luminaries, 

9 you're probably going to have that cost right 

10 there if we have to go to a -- I mean, Manny, I 

11 don't know if you're -- I don't think you're 

12 using sealed candle lights right now, are you?

13 MR. SANTANA: No. No, I don't think so.

14 MR. TOMPOS: What's the cost difference 

15 on those candle lights? I mean, we're trying to

16 -- Michael's contention is, do we need to lower 

17 that cost? I think there's some reason to 

18 believe that we can make arrangements for some --

19 can we just agree to agree that it's close 

20 enough?

21 MS. DICKENS: Yeah, really.

22 MR. TOMPOS: And it doesn't make that big 
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1 of a difference?

2 MR. LUBLINER: If they're going to do a 

3 subpart I on this if we find problems, I'm good.

4 MR. RAMIREZ: All right. So let's see a 

5 show of thumbs for those costs.

6 (Pause.)

7 MR. RAMIREZ: Okay. Anyone on the phone 

8 have their thumb down?

9 (Pause.)

10 MR. RAMIREZ: All right. So, let the 

11 record show that Mark was the only no vote. And 

12 we're assuming it's the same rationale.

13 MR. WEISS: Yes.

14 MR. RAMIREZ: Okay. And then --

15 MR. HAGERMAN: Let me just state, too, so 

16 we have it. Everything I was reading from was 

17 the ENERGY STAR Certified Home, version 3, Costs 

18 and Savings Estimate, that was distributed to 

19 everybody. It's the November 1st, 2013, edition.

20 MR. RAMIREZ: All right. Now, I just 

21 want to read what Peter was trying to say.

22 And, Peter, I think that this goes to the 
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1 enforcement piece, but there's a little part on 

2 the bottom where there is going to be a 

3 recommendation for the DOE to do testing, right? 

4 So the recommendation is up there already.

5 But Peter's comment was, "DOE will do 

6 quarterly testing for three years post7 implementation to ensure each is achieved."

8 Okay. So it's just a bit more detailed 

9 than what the suggestion is up there. But that 

10 goes into the enforcement piece, which will be --

11 hopefully, Peter, you'll be joining the committee 

12 at the next round with enforcement.

13 Okay? Let's break for one hour for 

14 lunch. And we'll be back at one o'clock. Thank 

15 you.

16 (Recess from 11:57 a.m. until 1:05 p.m.)

17 AFTERNOON SESSION

18 MR. RAMIREZ: Let's get started. All 

19 right, folks.

20 Stacey, are you on the line?

21 (Inaudible conversation.)

22 MR. RAMIREZ: Yeah. I think we're 
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1 getting some side chatter there. But, Stacey, 

2 are you on the line?

3 MS. EPPERSON: This is Stacey. Can you 

4 hear me now?

5 MR. RAMIREZ: Oh, yeah, that's much 

6 better.

7 MR. RAMIREZ: All right. We're going to 

8 start on the committee reports. So, Stacey, 

9 which documents would you like to lead off with?

10 MS. EPPERSON: Okay. I think let's go to 

11 the NADA documents, if you have those.

12 MR. RAMIREZ: All right.

13 (Pause.)

14 MR. RAMIREZ: Is that a PDF or a Word?

15 MS. EPPERSON: A PDF.

16 MR. BANTLE: Is this the document in 

17 question?

18 MS. EPPERSON: This works; thank you.

19 (Pause.) 

20 MR. RAMIREZ: Okay, Stacey. The floor is 

21 yours.

22 MS. EPPERSON: Okay. Okay, thank you.
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1 So, the finance committee has not met 

2 again since our last meeting. However, I believe 

3 we had two outstanding issues that we were 

4 exploring, looking at data.

5 The first one is the NADA guidelines for 

6 valuing ENERGY STAR improvements. And NADA is an 

7 evaluation guide. It is -- a good analogy for it 

8 is kind of like the Blue Book on a car, the 

9 value. You know, the NADA guide is a value guide 

10 for manufactured housing. It's often used with 

11 Chattel Finance, and it sometimes is used rather 

12 than an appraisal.

13 So the question that we had outstanding 

14 was, you know, is this current information?

15 Which it is. We have verified that. And so, for 

16 a single-section home, you can see the amount of 

17 $2,190 is credited for an ENERGY STAR qualified 

18 manufactured home.

19 And then, you can see that valuation at 

20 one to two years, three to four years, and then 

21 five years. And then we have a breakdown for the 

22 multi-section home at $2,640, and again with a 
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1 graduated valuation, depending on time. And then 

2 if there are additional tags or triple-sections,

3 that can also be added.

4 So let me pause here and see if there are 

5 questions.

6 (Pause.)

7 MR. RAMIREZ: So that triple section is 

8 added on to the multi-section?

9 MS. EPPERSON: Yes.

10 MR. RAMIREZ: Okay. 

11 (Pause.) 

12 MR. HAGERMAN: This is Joe Hagerman, DOE.

13 So, Stacey, do you think that, given this 

14 what you're seeing here, do you think that the 

15 way Matthew is calculating the resale value or 

16 the recapture value is -- what's your opinion of 

17 that?

18 MS. EPPERSON: You know, remind me of the 

19 most recent. I think I saw that we were looking 

20 at that, we're looking at a 10-year at this 

21 point. Is that correct?

22 MR. HAGERMAN: Right. I think at 10 
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1 years -- Matthew can speak.

2 MS. EPPERSON: Yeah.

3 MR. HAGERMAN: But at 10 years, the 

4 resale value was --

5 MR. WALKER: Two-thirds.

6 MR. HAGERMAN: -- two-thirds.

7 MS. EPPERSON: Okay. Okay. You know, 

8 maybe. If others want to chime in here, I think, 

9 you know, I'd want to look at the amount to see 

10 how close we are to this. But what impresses me 

11 here is that ENERGY STAR is given a value, and 

12 that it's there for a number of years. However, 

13 that amount does go down.

14 It has been my experience with 

15 appraisals, though, I will say, getting the 

16 valuation for ENERGY STAR seems impossible in 

17 many markets. So I think looking at this 

18 valuation from NADA is a good way to look at it 

19 and look at these amounts.

20 Others from the finance committee, your 

21 feelings on this?

22 MR. ROY: This is Robin.
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1 I think it's naturally an area of 

2 substantial uncertainty. I like that NADA has 

3 given it some thought. I like that they have 

4 something which we can point to.

5 And about the two-thirds valuation at 

6 year 10, that is consistent with what we see 

7 here. This is showing what? That's showing 78 

8 percent at year five and up. So we're talking 

9 something somewhat south of that. So this is not 

10 inconsistent with the straight line.

11 MR. RAMIREZ: Lois?

12 MS. STARKEY: I agree with that. I think 

13 Stacey alluded to it. I think that using the 

14 approach that DOE did might be more acceptable 

15 across the board, because of what Stacey said 

16 about trying to get these valuations.

17 You're going to have a lot of people --

18 you know, it's not really going to happen the 

19 NADA way across the board. So I like the idea of

20 sticking with the DOE approach.

21 MR. RAMIREZ: Thank you.

22 MR. WEISS: I had a question before we go 
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1 --

2 MR. SANTANA: 73 percent exactly.

3 MR. WEISS: Before we go to the next guy.

4 MR. SANTANA: 72 percent.

5 MR. WEISS: Okay. I guess this is for 

6 Emanuel. Emanuel, I'm looking at this as 

7 reference to SBRA at the bottom, and then 

8 Research Alliance at the top. I assume that's 

9 referencing System Building Research Alliance? 

10 Is that correct?

11 (Pause.)

12 MR. HAGERMAN: So, I believe that's 

13 correct. They are the implementer of the ENERGY 

14 STAR program, are they not?

15 MR. WEISS: Thank you. I appreciate it.

16 MS. EPPERSON: This is Stacey.

17 I believe it's correct.

18 MR. WEISS: Thanks.

19 MR. RAMIREZ: All right. Any other 

20 questions on the NADA document?

21 (Pause.)

22 MR. RAMIREZ: Great. Thanks, Stacey. 
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1 Where do you want to go next?

2 MS. EPPERSON: So, let's pull up the tax 

3 document. We had another outstanding issue on 

4 that.

5 (Pause.)

6 MR. RAMIREZ: Is that a Word or a PDF?

7 MR. HAGERMAN: I think it's right there. 

8 It's Sales and Property Taxes?

9 MS. EPPERSON: You're right there at the 

10 pointer. Sales and Property Taxes.

11 MR. RAMIREZ: Oh, yeah.

12 MS. EPPERSON: Okay. Okay. Working with 

13 Matthew and the team, I think what we want to say 

14 about property taxes is that, particularly -- let 

15 me start with sales tax. This varies greatly, 

16 and there are an abundance of jurisdictions. And 

17 it became very complicated to think about how 

18 this data might feed the model.

19 And then, we also know there was some 

20 complications around how each state looked at 

21 property tax with manufactured housing. So an 

22 outstanding issue for us has been the approach. 
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1 And so, one of the ideas was to look at this 

2 model and the cities where we're running our data 

3 and actually look to see what the sales and 

4 property tax implications are for those 

5 jurisdictions and those states.

6 And Lois is going to look into talking 

7 to, I think, the state manufactured housing 

8 associations to get some more of that data. And 

9 if I can call on Lois to see if we've been able 

10 to get any of that information.

11 MS. STARKEY: Yes, I have. I haven't --

12 don't have all of the states in yet. I have like 

13 Texas, Illinois, Maryland. And they're all over 

14 the board. And I can give you an example here.

15 So, for Texas, and generally this is 

16 going to apply statewide. But there might be 

17 some obviously real properties, some -- that's 

18 all pretty much local unless there is a state 

19 law, which there, in some cases, are specifically 

20 to manufactured housing.

21 But, for example, Chattel loans have a 

22 sales tax that's 3.2, 3.25 percent on new homes. 
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1 And it's based on a calculation of the sales tax 

2 in that state. So it's based on 65 percent of 5 

3 percent.

4 There's an ad valorem tax charged for 

5 manufactured homes financed and sold as real 

6 property. It's charged annually on the personal 

7 property, and the rate varies from local taxing 

8 jurisdictions, by local taxing jurisdictions.

9 And then for real estate loans, there is 

10 a sales tax. There would be no sales tax in 

11 Texas. They have to pay some taxes on raw 

12 materials.

13 So that's sort of how complicated it is. 

14 And I can -- you know, as soon as I can provide 

15 these as you wish, to use examples, or I can just 

16 get them to you as I -- I'm hoping to get them 

17 wrapped up by the end of the week. Usually, my 

18 guys are really good about getting back to me, 

19 but we had a meeting last week. So I have about 

20 three more states, four more states to go. But 

21 they're all over the map.

22 MS. EPPERSON: Thank you, Lois.
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1 So in any event, this shows you the 

2 complexity we're dealing with, the tax situation. 

3 But I think our approach is a valid one, unless 

4 anyone would like to give us some feedback on 

5 that.

6 MS. DICKENS: This is Ishbel.

7 I think the Washington State tax is 9, 

8 9.5 percent. So it's a little higher than it's 

9 showing there. And it's a sales tax state, 

10 unfortunately.

11 MR. UNGAR: And that's applied to all 

12 sales of manufactured homes?

13 MS. DICKENS: I don't know. I would 

14 assume it would be because it's applied to all 

15 sales of everything else. And I think it is.

16 MR. UNGAR: When I did a web search 

17 before the last time, there was an excise tax in 

18 Washington State between 1 and 2 percent.

19 MS. DICKENS: Yeah.

20 MR. LUBLINER: That's my understanding. 

21 But I'm not knowledgeable on that. Joan Brown, 

22 from Washington Manufactured Housing Association.
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1 MS. STARKEY: Right. Yeah. I just don't 

2 have it -- I just don't have it back from her 

3 yet. But generally, what these states, you know, 

4 they all get legislation passed to modify 

5 whatever the statewide sales tax is. Because 

6 it's such a big-ticket item.

7 MS. DICKENS: Right, right.

8 MS. STARKEY: So we can assume that, if 

9 you wanted to just assume a number just for the 

10 time, it's not going to mean that much in terms 

11 of our analysis, in my opinion. And it would be 

12 nice to have those specifics, but it's not going 

13 to vary by state. But we can plug them in if 

14 it's not hard, because you're going to have to go 

15 individually and plug each change in.

16 Or just take some percentage of each, 

17 less of each, of the overall sales tax.

18 But I just -- others chime in who are 

19 familiar with this, Emanuel. But I think, you 

20 know, it's not going to make that much of a 

21 difference. But I will, Javier.

22 MR. RAMIREZ: Michael?
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1 MR. LUBLINER: Yeah. I had that 

2 spreadsheet and talked to some of my associates, 

3 and they had a question about the analysis. 

4 Because they were saying, this is an example, 

5 "Miami has a property tax of $17.54 per month on 

6 any EEM of 19,048. Seems an order of magnitude 

7 high. I suspect the property tax value is 

8 annual, but the way the net present value is done 

9 assumes monthly loans."

10 So anyway, I'm just asking that you 

11 double-check to make sure that the calculation is 

12 being done consistently. Thank you.

13 MR. RAMIREZ: Stacey, anything else?

14 MS. EPPERSON: No. That concludes our 

15 report, but there are two outstanding issues.

16 MR. RAMIREZ: Okay. Now, I don't believe 

17 there are any action items that need to be taken 

18 on the finance, correct? That was just more 

19 informational to assist with understanding, as 

20 well as costing. Is that accurate?

21 MS. EPPERSON: That's my understanding.

22 MR. RAMIREZ: Okay, great.
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1 Michael

2 MR. LUBLINER: Stacey, I had a question. 

3 Is there any assumption about the percentage of 

4 homes that are purchased with cash?

5 MS. EPPERSON: Thank you for reminding 

6 us. We were going to look into that. And we 

7 did. And I think the assumption was as many as, 

8 close to 30 percent. I'd have to check my exact 

9 amount, unless Lois has that number in front of 

10 her.

11 MS. STARKEY: I think we're using 30 

12 percent. But it's kind of a hard number to come 

13 up with. But that's the number that MHI has been 

14 consistently, based on our contacts with our 

15 lenders.

16 MR. LUBLINER: Thank you.

17 MS. EPPERSON: Thanks for the reminder.

18 MR. RAMIREZ: Thank you, Stacey.

19 All right. Then, the next one would be 

20 manufactured housing.

21 MR. TOMPOS: Mine?

22 MR. RAMIREZ: Yes. 
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1 MR. TOMPOS: Okay. What I did, I was 

2 tasked with trying to figure out what 

3 manufacturing problems we might have with some of 

4 the smaller homes. And I do want to point out 

5 I'm not a manufacturer. So I'm the only one on 

6 the committee in trying to figure out what all 

7 the manufacturing problems are, and I'm not a 

8 manufacturer.

9 But what I did was I put together a --

10 MR. BANTLE: Which document?

11 MR. TOMPOS: I sent it to you on -- let's 

12 see -- Saturday, I believe. I also made copies.

13 MR. RAMIREZ: Okay. We just want to make 

14 sure that we have it up for the folks that are --

15 (Pause.)

16 MR. TOMPOS: I don't see it in there.

17 (Pause.)

18 MR. TOMPOS: There you go.

19 So, the front page is just an example 

20 calculation. I was trying to figure out what my 

21 maximum effective U value is. A lot of the talk 

22 has been about -- and I think Emanuel even 
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1 mentioned that these are just labels, as far as 

2 the R38 down to the R22 or whatever we're using.

3 And once we get to the point where we 

4 have to define what the U values are, the overall 

5 U value, we've got to nail down what is the 

6 number U value? We can't just say we're putting 

7 an R38 insulation in the roof, because that's not 

8 what we end up with. And I think some of that 

9 has been taken into account.

10 What this spreadsheet will allow us to do 

11 is you can come in here and change all these 

12 numbers and figure out what you get for an 

13 overall U value. I just -- it is not probably as 

14 far as it needs to go, because it does not take 

15 into account framing members. It doesn't take 

16 into account air films or the resistance in the 

17 gypsum.

18 But I also included some diagrams so that 

19 we could take a look at what some of the smaller 

20 units look like and what some of the shipping 

21 restrictions are.

22 This first one, I'm trying to stay within 
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1 the 13-6 as far as height goes, because in the 

2 document that was sent around on -- I don't off 

3 the top of my head remember what that title of 

4 that was. But it was a shipping study, and 

5 mostly for the Northeast, because you don't run 

6 into a lot of these problems in the Southern 

7 regions because they don't have the smaller 

8 bridge heights.

9 I don't have any statistics on how many 

10 homes we're talking about. I know there are also 

11 height limitations in all the states. But I 

12 don't know what they are. I know when we dealt 

13 with a particular project, there was another 

14 height limitation of 15 feet.

15 And what I want to make sure that we do 

16 at the end of the day is that we can physically 

17 put enough insulation in these homes. So it's 

18 great to say we want an R38 everywhere in the 

19 ceiling, but when we deal with some of these 

20 smaller, you know, especially single-wide homes, 

21 there's going to be some restrictions on whether 

22 or not we can do it or not.
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1 Now, I'm not saying that there aren't any 

2 solutions for that. There's always the solutions 

3 of going to some type of a dense pack or a foam 

4 insulation to be able to get those. But I want 

5 to make sure that we're recognizing that in some 

6 of the cost provisions here. So, I don't think 

7 there's a lot of going-back-and-forth. I don't 

8 want to get in the weeds on this.

9 The next drawing here shows a typical 

10 cathedral configuration. And this is where it 

11 does become a problem, because we, obviously, 

12 again have less physical space.

13 So I don't like -- again, I don't want to 

14 get into the weeds. I don't know if we need to 

15 have any back-and-forth discussion on this. I'm 

16 trying to just make DOE aware of the situation, 

17 that I provided a small calculation. I'm only 

18 one nerd. So I didn't have anybody review my 

19 work.

20 If anyone else wants to scrutinize this, 

21 I'm more than happy to go back and forth or talk 

22 with them offline about it on how I got it.
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1 The method I used -- and this is a page 

2 from that -- is the Battelle method, which is the 

3 method that's been used in the manufactured 

4 housing world as far as I can remember.

5 This one is a diagram of what it looks 

6 like in the floor cavity. And the reason I put 

7 this in here is I did want to talk about the 

8 implications of potentially putting that 

9 insulation above the area in the belly.

10 We kind of hammered that to death earlier 

11 this morning. So I don't -- I mean, unless 

12 somebody has some additional questions, I really 

13 don't want to drag it out again.

14 I just want to put on the record that I 

15 am afraid, you know -- and if you look at some of 

16 the configurations that PNNL already put 

17 together, they show an R11 blanket and then an 

18 R21, I believe, above everything. And I'm 

19 concerned that we're going to create some service 

20 problems.

21 Even if you assume that there's not going 

22 to be any rodents or tears in the bottom board 
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1 after the fact, after it's been installed, I 

2 think you're going to find out in some of the 

3 colder climates, and maybe somebody can do some 

4 type of a thermal curve through that area to find 

5 out what my temperatures are going to be in that 

6 area, especially when I'm sealing the floor and 

7 nothing's getting in there with an R11, when it 

8 gets to be minus-20 or minus-30 degrees in North 

9 Dakota and some of the Northern regions.

10 So I'm just putting that out there as a 

11 potential service complaint down the road. And I 

12 don't know how to deal with that.

13 So, I'm not going to talk about the 

14 width. I think there is -- I don't want to get 

15 into an argument with anybody in the Northwest. 

16 I just want to make everybody aware that there 

17 are some additional costs that could come in, and 

18 I never did get a cost of what an additional 

19 transport costs or if we're even going to 

20 recognize the additional, you know, thousands of 

21 miles that some of these travel with an 

22 additional car if we have to expand the width of 
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1 some of these because we have to go to two-by2 four or two-by-six walls.

3 So I'm just pointing it out as concerns 

4 for DOE to recognize and make sure that we can 

5 physically do this with current building 

6 techniques.

7 MR. RAMIREZ: So, from what we've been 

8 hearing, is there anything -- now, there's a 

9 difference between an inconvenience or you-don't10 like-it versus you-can't-do-it. Is there 

11 anything that hasn't been discussed that is not 

12 figured out physically?

13 MR. TOMPOS: Well, again, I can build a 

14 home that's tornado proof. But you can't afford 

15 it.

16 (Laughter.)

17 MR. TOMPOS: Or most people can't afford 

18 it. I shouldn't say you, Javier. I don't know 

19 your financial situation.

20 MR. RAMIREZ: I probably couldn't. I 

21 probably couldn't.

22 MR. TOMPOS: Yeah, good. You probably
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1 couldn't.

2 MR. RAMIREZ: I'm a government employee. 

3 So.

4 (Laughter.)

5 MR. TOMPOS: Exactly. So, you know, I 

6 can do anything. I can put -- I'd love to build 

7 houses with all sip panel roofs. But they're not 

8 going to be affordable. So that's a concern. 

9 Nothing is impossible; it's just, can we do with 

10 current industry practice?

11 MR. RAMIREZ: Manny?

12 MR. SANTANA: It might help if you go 

13 back, just talking about the roof, if you go back 

14 and explain looking at the cathedral single-wide, 

15 why that's significant, why R38 or more in that 

16 roof would be an issue?

17 You know, so if you provide R38 means 

18 this many inches in height, and then everybody 

19 can see that visual there, and see, you know, if 

20 R38 requires, you know, 12-inch height, you can 

21 see you're only going to go so far. You know 

22 what I mean?
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1 MR. TOMPOS: Yeah, you know, as my 

2 example calc shows, you know, I put an R40 at the 

3 king post. And overall value -- and again, we've 

4 got to remember these don't take into account 

5 framing members. So it's going to be less than 

6 this. It's not even an R25. And this is not the 

7 smallest house that we build. This is a 13 --

8 what's the total? Well, the unit, it's 13-2, and 

9 then you have the eaves on it. So that's where 

10 you get 13-6. 

11 But that's a big concern. So once you

12 start lowering the rise and run, the slope on the 

13 roof, we can go down to -- there's no requirement 

14 in the manufactured housing standards. But the 

15 shingle manufacturers only let you go down to 

16 212.

17 MR. SANTANA: 212.

18 MR. TOMPOS: So, you know, I can -- I

19 didn't do worst-case on this. So we could -- you 

20 know, you guys all have this calculation. It was 

21 in an additional file. So there is an Excel 

22 spreadsheet that allows you to change this, play 
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1 with it, you know, reduce the unit size. You can 

2 change all those numbers in there, and it will 

3 show you what your effective value is.

4 If our effective value is going to have 

5 to be around an R38 for a cathedral ceiling, I 

6 don't think we're going to be able to do it 

7 unless you change the technology that we're 

8 using.

9 And there's not any manufacturers on this 

10 committee that are building primarily cathedral 

11 ceilings. But there are a number of 

12 manufacturers in the industry that that's their 

13 main market.

14 The other thing I want to point out, some 

15 of the other things we can do to help this is, 

16 I'm doing an eight-foot side wall here, which is 

17 pretty typical. I don't know if any of you have 

18 been in any seven-foot or six-and-a-half-foot 

19 side wall heights. But I get a little 

20 claustrophobic.

21 And I don't want to tell -- I don't think 

22 we should have to tell a homeowner that, "Well, 
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1 to save you 50 bucks on your energy, we're going 

2 to have to put you in a seven-foot side wall to 

3 meet the requirements." I think that's a 

4 disservice to the consumer.

5 MR. RAMIREZ: Okay. Any questions for 

6 David?

7 (Pause.)

8 MR. RAMIREZ: Is that it?

9 MR. TOMPOS: That's it.

10 MR. RAMIREZ: Great. Okay, thank you, 

11 David.

12 Was there a question on the line?

13 MR. SCHNEIDER: Yeah, this is Peter.

14 I was trying to get on mute on my phone, 

15 so you would just get the messages and then I can 

16 make my comment on my phone.

17 MR. HAGERMAN: You can make your comment.

18 MR. RAMIREZ: Yeah, you're coming across 

19 pretty clear, Peter.

20 MR. SCHNEIDER: Oh, I am? Okay. Great. 

21 I have an echo on this end, so.

22 I just wanted to make a recommendation 
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1 that seven-and-a-half ceiling height with a 

2 cathedralized space that goes to eight-and-a-half 

3 works extremely well. It is very well received 

4 up here. And that that provides plenty of room 

5 for the R values that we're looking to achieve.

6 (Pause.)

7 MR. TOMPOS: He said you can do it with 

8 seven-and-a-half feet.

9 MR. MENDLEN: That drops it down six 

10 inches.

11 MR. EZZO: This is Mark Ezzo.

12 Peter, can you tell me what R value 

13 you're talking about?

14 MR. SCHNEIDER: Well, 38 or 49, and 

15 actually, setting a much higher R value over the 

16 outside of the exterior wall, which is what we're 

17 trying to achieve.

18 In our climate, we have a lot of issues 

19 with ice damming as a result of very poor 

20 installation details with the insulation at the 

21 eave, as well as venting approaches that don't 

22 work. So, providing more of a buffer in that 
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1 space to both get a higher R value and a better 

2 vented space makes a really big difference.

3 MR. RAMIREZ: Yeah, Manny?

4 MR. SANTANA: Peter, can you explain to 

5 me how you get the R49? Is that installed or is 

6 that once you calculate the assembly as a whole? 

7 Is that installed insulation?

8 (Pause.)

9 MR. SCHNEIDER: Yeah. Well, we're using 

10 a dense pack in a 50-to-life stage. Hold on a 

11 second. Just give me one second just to mute my 

12 phone. Do I still sound okay?

13 (Chorus of "Yes.")

14 MR. SCHNEIDER: Okay. So, we use a 

15 parallel chord truss. So two-by-four bottom and 

16 top cord with a webbing in between. And you can 

17 do that in any width that you want. So we get 

18 the same R value over the outside of our exterior 

19 wall as we have at our ridge.

20 And so, that allows you to accommodate 

21 both a dense-pack assembly, but also have a 

22 vented assembly from the eave to the ridge, if 
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1 that answers your question, Manny.

2 MR. SANTANA: Well, yes and no. Because 

3 I still have a hard time visualizing how you can 

4 get R49 at the heel or above the wall, as you've 

5 said. You know, so is the truss configuration 

6 that you use, is that similar to what Dave had on 

7 the screen?

8 MR. SCHNEIDER: Well, that's a scissors 

9 truss, where you'd have a different height at the 

10 eaves than the ridge. And regards to the depth 

11 of that truss, a parallel chord truss is even the 

12 whole way.

13 MR. SANTANA: Okay.

14 MR. SCHNEIDER: So you could do it with 

15 either. But, you know, in this case, I like the 

16 parallel chord truss. Just to give you an idea, 

17 we have 2 by 10, 16 on center dense pack with 

18 fiberglass. We have a vertical wall assembly at 

19 seven-and-a-half feet where it meets the ceiling 

20 height. And then we have our parallel chord 

21 truss.

22 We're doing a 14-inch parallel chord 
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1 truss dense pack with fiberglass there, as well.

2 MR. SANTANA: Okay. I think I'm starting 

3 to come around a little bit, little by little.

4 MR. SCHNEIDER: Okay. 

5 MR. SANTANA: So, what's the height at 

6 the heel? Or what's the height of the truss 

7 above the exterior wall?

8 MR. SCHNEIDER: Fourteen inches.

9 MR. SANTANA: Okay. Fourteen inches. 

10 So, yeah, I would agree with you that if you had 

11 a truss that had 14 inches at its minimum 

12 dimension, you can get an installed R38 or R49 in 

13 there. I'd agree that that is the case.

14 But I will state that, at least with my 

15 experience with the product that we make, the 

16 only product that we make that has a 14-inch-tall 

17 truss at the heel is the Santa Fe product in the 

18 Southwest, where -- and it's a whole different --

19 you know, it's at the parapet wall.

20 But, you know, everything else that we do 

21 has -- it's a ranch-style house. So it has a 

22 gabled truss. And I think that's what Dave was 
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1 trying to say, is that, you know, if you change 

2 the construction of the truss so that you 

3 increase the height of the heel, that might be 

4 what you have to do to get this installed R value 

5 in the roof.

6 And I think the position we were taking 

7 is that that's going to have additional costs and 

8 shipping height concerns and the other stuff we 

9 were talking about.

10 MR. SCHNEIDER: Manny, this shows a one11 and-a-half 12 cathedralized ceiling on the 

12 inside. And I don't know if that's a two-and-a13 half 12 on the outside. Our roof system --

14 MR. SANTANA: It's a three -- yeah.

15 MR. SCHNEIDER: Three 12?

16 MR. SANTANA: Yeah.

17 MR. SCHNEIDER: So just to give you an 

18 idea, you know, I'm in the Northeast. We have 

19 13.5 feet, we need to travel down the road. And 

20 we're meeting the 13.5-foot height. We have a 

21 two-and-a-half 12 cathedralized space on the 

22 interior, from 7.5 feet at the aegis, 2.5 at the 
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1 ridge, a very comfortable space that feels like a 

2 big volume, even a steeper cathedralized space 

3 than shown here in the picture.

4 And we have the same two-and-a-half 12 

5 pitch on the outside, which is pretty darn close 

6 to the 3.3 shown here. And I'll go back to what 

7 Mark has said over and over again, which is we're 

8 trying to make housing for people making $25,000 

9 a year more affordable.

10 Having ice damming issues and heat loss

11 at the eaves as a result of getting an additional 

12 one-12 pitch on the exterior of the roof doesn't 

13 seem to make sense to me or meet the intent of 

14 that goal, if that's what we're doing here.

15 MR. SANTANA: Right. I follow you, and I 

16 understand it. I think, you know -- well, I'm 

17 glad that you explained that because it makes 

18 sense that if you increase the size of the truss, 

19 you're going to have more free space.

20 But, you know, unfortunately, when I 

21 start my discussions, it's always with base HUD 

22 code, not what can be done. We can do a lot of 
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1 stuff. But, you know, the way it's going to be 

2 most cost effective is if we can modify the 

3 existing product as little as possible, but gain 

4 the most energy efficiency from it.

5 So, you know, and if we can't, that's one 

6 of the things that we need to illustrate, because 

7 in Texas, where, if you look at the data that I 

8 think HUD provided, that state is responsible for 

9 20 percent of all the HUD shipments last year, 

10 you're going to find that the vast majority of 

11 the product looks like what we have on the screen 

12 and won't have the 14-inch heel.

13 So we can do that, yeah. Yeah, we can do 

14 that. But there's going to be costs. And it's 

15 going to be a pretty drastic change.

16 MR. RAMIREZ: So, I guess tapping into 

17 the manufacturers' expertise --

18 MR. SCHNEIDER: I guess I'm just --

19 MR. RAMIREZ: Hold on a second, Peter.

20 Let me just ask this question of the 

21 manufacturers. So, just using your expertise and 

22 your years of experience, you're saying that to 
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1 make those adjustments to the structure, to get 

2 in that higher R value, would make it cost 

3 ineffective?

4 MR. SANTANA: There's a chance for that, 

5 yeah. I can't say that it won't. But it's going 

6 to be -- it's not just the cost of the materials. 

7 You have to -- you know, increased height is 

8 going to have an effect of wind pressures. So 

9 that's going to have an effect on your lateral 

10 resisting system.

11 You know, that can mean -- well, at a 

12 minimum, it's going to mean redesign of that 

13 manufacturer's entire product line. That 

14 includes floor plan, since the middles -- it can 

15 affect the strength of sheer walls. It can 

16 affect some floor plans, you know, because they 

17 can have a lot of window space. It could affect 

18 sheer walls.

19 It can all be done. But changing the 

20 exterior dimensions of something can have a big 

21 impact.

22 MR. RAMIREZ: Domino effect.
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1 MR. SANTANA: Yeah.

2 MR. SCHNEIDER: I'm just not 

3 understanding how the exterior dimensions are 

4 getting changed here. I mean, in terms of the 

5 cathedralized -- I'm not sure what exterior 

6 dimensions are getting changed that would be 

7 outside of business-as-usual.

8 Because if we're talking about an eight9 foot wall, we're talking about a seven-and-a-half 

10 foot wall and taking that height and putting it 

11 into an eave and the raised heel insulation 

12 depth.

13 MR. SANTANA: Right. Well, the heel 

14 depth is the issue. If you go from 5 inches to 

15 14, that will change the way that wind sees the 

16 exterior of the house. And that has an impact on 

17 everything else, structurally speaking.

18 MR. SCHNEIDER: I'd like -- instead of --

19 I mean, that seems, Manny -- I apologize, but 

20 that just seems like sort of a subjective 

21 statement there. I mean, I'd like to see the 

22 numbers to show why that's not -- A, that it 
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1 wouldn't still be cost effective, and B, why that 

2 wouldn't work.

3 Again, we're talking about the same 

4 surface area. And we're talking about the way 

5 that truss system attaches to the vertical wall 

6 at that length.

7 MR. TOMPOS: Manny, if you don't change 

8 this pitch of the roof, because basically what 

9 he's saying is we drop this down to about here so 

10 we have a six-foot -- or I'm sorry, seven-six 

11 ceiling height. This all becomes your wall. So 

12 I'm not changing my -- I don't think you're going 

13 to change your structural loads on your --

14 MR. LUBLINER: Reducing your wall area. 

15 Reducing the cost to the wall.

16 (Cross-talk.)

17 MR. SANTANA: It's changed a little bit 

18 because --

19 MR. TOMPOS: You're going to increase the 

20 cost to your truss.

21 MR. SANTANA: It might be a wash if you 

22 keep the overall height the same. Yeah, that 
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1 might be a wash. But it's still going to have a 

2 little bit of an effect, because although your 

3 wall height is shorter, right?

4 I don't want to get into the weeds. But 

5 everything above the diaphragm gets added into 

6 the diaphragm. So if you have a five-inch heel, 

7 five inches of wind pressure is going to go 

8 through your diaphragm. If you have a 14-inch 

9 heel, 14 inches is going through your diaphragm.

10 If you have a 30-inch heel, all of that 

11 goes into the -- the wall gets split in half. 

12 You know? So if you reduce the wall, you still 

13 split that in half. When the wind blows, half 

14 the load goes up, half the load goes down. All 

15 the load that hits the heel goes into the 

16 diaphragm.

17 So it's not -- I mean, it might be pretty 

18 close, but it won't be an exact wash.

19 MR. TOMPOS: I do have a question for 

20 Peter. You know, if I come down six inches, I'm 

21 going to increase my heel height to 11.5 inches. 

22 But to get a full R --
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1 MR. SANTANA: R49?

2 MR. LUBLINER: No. 38 we're talking 

3 about.

4 MR. TOMPOS: R38? Well, you're going to 

5 need about 15 inches.

6 MR. SANTANA: At what density?

7 (Cross-talk.)

8 MR. SCHNEIDER: No, no, no. You know, if 

9 I could -- Johns Manville's Climate Pro, which is 

10 the blown-in fiberglass insulation, is R4.3 per 

11 inch. So there's no reason to have any more than 

12 11 inches there to get R49.

13 And then if we're talking R38, we're 

14 talking about even a less gap there and plenty of 

15 room for venting.

16 MR. RAMIREZ: Okay. Hold on a second. 

17 Let's make sure that everyone is on the same page 

18 here.

19 (Pause.)

20 MR. SANTANA: At 4.3 per inches it ceases 

21 as the stuff that we blow. We're blowing stuff 

22 --
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1 (Cross-talk.)

2 MR. TOMPOS: Right. I mean, that's my 

3 point. Typical fiberglass blown insulation, 

4 based on the calculations I've seen, give either 

5 a 2.6 or a 2.7 per inch. What Peter is talking 

6 about is a -- this is a different product than 

7 what the industry is using.

8 MR. MENDLEN: Worse than about 4 per 

9 inch, that over 4.

10 MALE VOICE: Four per inch?

11 MR. MENDLEN: I'm just looking at the 

12 table -- says for 10 inches, you have 38.

13 MR. SCHNEIDER: I'd be fairly interested 

14 in why there's such a drastic difference for 

15 blown fiberglass that has enhanced PF tested 

16 rating of 4.3 and what the blown-in fiberglass is 

17 that the industry has. This is an R value of 

18 half of what Johns Manville and -- that can go

19 across every single large fiberglass insulation 

20 manufacturer has a blown-in fiberglass product 

21 that's R4.3 or 4.1 per inch.

22 MR. SANTANA: But rigid board gives you 
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1 what? R5 per inch? And that's rigid board --

2 MR. LUBLINER: R7?

3 MR. MENDLEN: No. 4.2.

4 MR. TOMPOS: I'm telling you that the 

5 heat loss calcs that we're using right now in the 

6 industry are using 2.6 and 2.7. So, if maybe the 

7 industry has been using the wrong numbers all 

8 along, we don't even have this conversation 

9 because we're doing a lot better than we thought 

10 we were.

11 (Laughter.)

12 MR. EZZO: This is Mark Ezzo.

13 I think what Peter is talking about is 

14 not what we see off the shelf from Johns Manville 

15 or Owens Corning or anybody that sells blown 

16 fiberglass, because all those blown fiberglass 

17 charts --

18 MR. RAMIREZ: Mark, I'm sorry. Hold on a 

19 second.

20 MR. EZZO: They're not based on --

21 MR. RAMIREZ: Mark, I'm sorry. Hold on 

22 one second. I just want to make sure everyone is 
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1 on the same page.

2 MR. EZZO: Sorry.

3 MR. RAMIREZ: Could you start all over, 

4 Mark?

5 MR. LUBLINER: He wants you to start 

6 again, Mark.

7 MR. EZZO: Yeah. The JM blown 

8 fiberglass, Climate Pro, if you go on their 

9 website, you'll find it's around 3 R per inch. 

10 And that's not dense pack. And I think what 

11 Peter is talking about is different than what 

12 typical manufacturers are using.

13 Most manufacturers, and I don't want to 

14 speak for all because I don't know. But I don't 

15 think most of us are dense-packing insulation. 

16 We're blowing it to just the regular recommended, 

17 whether it's Johns Manville or Owens Corning or 

18 whoever making blown fiberglass, we're just 

19 blowing to the typical off-the-shelf standard. 

20 We're not dense-packing.

21 And I think that's what Peter -- I think 

22 that's where you're getting 4.3 per inch, because 
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1 like Dave Tompos said, I know the bags that we

2 get from JM, they don't hit 4.3 per inch. And I 

3 think if you go to the --

4 MR. SCHNEIDER: We're just putting it in 

5 at the rate it --

6 MR. EZZO: Go ahead.

7 MR. SCHNEIDER: 1.8 pounds per -- yeah, I 

8 was just going to say, we're putting it in at 1.8 

9 pounds per cubic foot, which tested to the FTM

10 is R4.3 for Johns Manville's Climate Pro. The 

11 877, I believe it is, with Owens Corning, is 

12 exactly the same rating. So --

13 MR. EZZO: Okay. You're talking about a 

14 density that's twice what we normally do. Our 

15 densities are more about half of what you're 

16 talking about.

17 MR. SCHNEIDER: Okay. 

18 MR. EZZO: I think that's where the 

19 disconnect is. I think we're talking about --

20 when we say -- when Dave Tompos and I say 3 R per 

21 inch, we're not talking about dense pack.

22 MR. SCHNEIDER: That's fine. But let's 
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1 just -- whatever the R value is of the material 

2 that you're using, I'd like to return to, I think 

3 the key approach is to go to a seven-and-a-half4 foot wall because our homeowners don't care if 

5 it's eight or seven-and-a-half if you have a nice 

6 cathedralized space that goes to eight-and-a-half 

7 feet.

8 And we can have a much larger raised-heel 

9 truss regardless of what material we're using 

10 there. We're getting a higher R value in that 

11 11-inch heel, let's call it, as opposed to a 

12 five-and-a-half-inch heel. 

13 And it would appear there would be no 

14 cost penalty to achieve this, short of maybe just 

15 a different truss design and wall height.

16 MR. EZZO: Yeah, the other comment I'd 

17 like to make on just the geometry we're looking 

18 at here is, we're looking at a single-wide home. 

19 If you take that same concept of your parallel 

20 chord truss that's a 2.5 and 12 pitch, that 13-6 

21 shipping height goes to 14-6. And multi-section 

22 homes are, I think, more of the volume in the 
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1 industry than singles.

2 (Pause.)

3 MR. EZZO: So, I mean, we've got to 

4 address multi-section homes, too. We've got to 

5 address multi-section homes, too, not just 

6 single-wides.

7 MR. LUBLINER: Mark, doesn't the multi8 section home have a larger percentage of space 

9 where you can get the full insulation in?

10 MR. EZZO: Oh, yeah, definitely.

11 MR. LUBLINER: Okay. Thanks.

12 MR. EZZO: Yeah. My comment was more 

13 about shipping height.

14 MR. SANTANA: You know, one thing that 

15 stood by me the first time, but if you have a 

16 parallel chord truss, how do you drain the roof?

17 (Pause.) 

18 MR. EZZO: Manny, what do you mean by 

19 "drain the roof"?

20 MR. SANTANA: Well, when it rains, where 

21 does the water go?

22 MR. TOMPOS: It's still sloped, Manny.
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1 MR. SANTANA: How much?

2 MR. TOMPOS: Well, it can't be less than 

3 2-12.

4 MR. SCHNEIDER: Two-and-a-half 12.

5 MR. SANTANA: Two-and-a-half 12. Okay.

6 MR. EZZO: I think it's still peaked, 

7 Manny.

8 MR. SANTANA: Okay, thanks.

9 MR. EZZO: It's still got a peak on it, 

10 doesn't it, Peter?

11 MR. SANTANA: Yeah, it still has a peak, 

12 yeah.

13 MR. SCHNEIDER: Yeah. Yeah, yeah. 

14 Parallel chord truss. It's parallel. The two, 

15 the top chord and the bottom chord are parallel. 

16 So you're two-and-a-half 12 inside, you're two17 and-a-half 12 outside.

18 And if you happen to be delivering your 

19 home to a place where you don't have to meet the 

20 13-foot fixed requirement, you could have even a 

21 steeper pitch than that when you're going to 14-8 

22 or the other height requirements in the Southern 
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1 sphere.

2 MR. RAMIREZ: So, is the reason that all 

3 this is going on to see if R38 is truly feasible 

4 in the ceiling? Is that why we're having this 

5 discussion?

6 MR. SANTANA: This is Manny with Cavco.

7 The reason why this whole thing was 

8 brought up is to give everybody an idea as to the 

9 existing constraints in the majority of the 

10 industry when it comes to size and room available 

11 for insulation.

12 And that you know, if -- you know, it's 

13 one thing to say, "I want R38 in the ceiling" or 

14 "I want R49 in the ceiling." And it's another 

15 thing to know that, in order to achieve that, you 

16 might not be able to do that with standard 

17 construction today. You're going to have to 

18 change some things.

19 MR. RAMIREZ: Okay. 

20 MR. SCHNEIDER: This is Peter.

21 And yeah, I mean, I think I heard from 

22 minutes ago, maybe from Manny, that, you know, 
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1 this is why we can't achieve R38. And I just

2 wanted to note that I think we do need to rethink

3 the way these are designed and constructed.

4 You know, I think the belly and the 

5 manufacturing of that whole system is a bit 

6 flawed in regards to how it comes together. And 

7 that's why it's been such a challenge to 

8 determine whether the belly space is conditioned 

9 or unconditioned.

10 And you know, the limitations that 

11 manufacturers are suggesting with regards to R 

12 value in the cap are a result of, you know, just 

13 going with the standard eight-foot wall height, 

14 and not thinking about dropping that wall height, 

15 which will have, I think, no compromise on the 

16 interior volume and only improve the actual 

17 envelope and durability of that home.

18 MR. RAMIREZ: All right. Let me get 

19 David and Manny.

20 MR. TOMPOS: Did you call me?

21 MR. RAMIREZ: Yeah. I'm sorry. That was 

22 Mike. Mike?
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1 MR. LUBLINER: I live in a triple-section 

2 home. It's got a vaulted ceiling throughout, and 

3 it's got a seven-and-a-half-foot end wall, and 

4 it's just fine. But that's a triple. But, and 

5 you haven't experienced in a single.

6 The other comment I make is when I do go 

7 to retailers around the country, I always ask 

8 Emanuel Levy, I do see advertising of R38 as an 

9 option. And I'm wondering, if this is so new, 

10 how are they getting it now?

11 MR. TOMPOS: Well, I can -- again, it's 

12 not impossible. It just costs more money. I 

13 want to make sure that we capture that.

14 MR. LUBLINER: Good.

15 MR. TOMPOS: You know, I've got some 

16 manufacturers, too, that their market is nine17 foot side walls. So, you know, I mean, that's 

18 what they're able to sell. You know, you go into 

19 some of the Northern regions, that's what the 

20 consumers expect, at least in the Midwest, 

21 because, you know, my --

22 MR. LUBLINER: Would that be the entry-
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1 level consumer?

2 MR. TOMPOS: Well, again, I don't know if 

3 that's the -- probably not, you know. So, again, 

4 if the consumer is willing to pay for it, it is 

5 possible. I'm not saying that we need to make 

6 sure we can do everything for a nine-foot side 

7 wall.

8 I'm just saying there is some -- they're 

9 going to have to change their designs because of 

10 what we're requiring. And I just want to make 

11 sure that that is looked at by DOE to make sure 

12 we're not, you know, that we're including that 

13 additional cost into some of these life cycle 

14 cost analyses.

15 MR. RAMIREZ: Do you have those costs?

16 MR. TOMPOS: I don't. Because I'm not a 

17 manufacturer. So I don't know what the 

18 percentages are. I'm just telling you that I 

19 think that it's going to change some of the 

20 manufacturers' ways that they have to build these 

21 homes. And I want to make sure we capture that 

22 cost.
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1 But, no. That would -- I mean, Manny or 

2 Mark would have to help them with some of that.

3 MS. DICKENS: This is Ishbel.

4 Can we extrapolate out from what it does 

5 cost to do the nine-foot walls? Because that 

6 much obviously also costs more to subtract that 

7 from what it therefore costs to do the seven-and8 a-half foot walls. Is that too simplistic?

9 MR. TOMPOS: I'd like to know what the 

10 difference between the dense-packed -- if I can 

11 get an R4 per inch --

12 MR. LUBLINER: Change your model. Put in 

13 4.5.

14 MR. TOMPOS: We could do that. I can't 

15 do it right now because I don't have a laptop. 

16 But I mean, I will look at that and how much 

17 difference that makes. But I don't know if -- I 

18 don't think Emanuel Levy maybe did get this 

19 information.

20 But it would be interesting to me to see, 

21 okay, to achieve some of these things, we have to 

22 go to a dense pack. And if we can get over an 
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1 R4, that's going to solve, I think, a lot of the 

2 problems, especially if the cost is relatively, 

3 you know, reasonable.

4 MR. RAMIREZ: To get to that higher dense 

5 pack, is that a different material or is that 

6 just a different process?

7 MR. LEVY: I can answer that. Emanuel.

8 In fact, the R38 example we showed at the 

9 cost table assumed that the eaves were dense

10 packed because we needed to get an R30 R value at 

11 the eave. So we've assumed that they're dense 

12 packed.

13 And that's something that's doable. And 

14 we've done it before with some test homes. But 

15 dense-packing the roof is not a big stumbling 

16 block.

17 MR. LUBLINER: I say we're ELMO.

18 MR. SANTANA: We've talked about design 

19 elements or, you know, construction elements that 

20 the plant's going to have to do. And, you know, 

21 insulating pipes and ceiling openings and stuff 

22 like that, and all that stuff, when everything is 
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1 said and done, you're not going to be able to 

2 see, and the customer won't really be able to see 

3 the difference. And that's fine. You know, 

4 that's reasonable. We can do all of that.

5 If you start to talk about changing the 

6 geometry of the house, you know, there are plants 

7 that only build eight-foot walls, right?

8 If we're saying just drop the side wall 

9 height down and nobody's going to care, you know, 

10 I think that's unreasonable to think that you can 

11 -- you know, for an industry that's always trying 

12 to play catch-up and always -- you know, in some 

13 circles, manufactured housing is almost taboo.

14 And so we're trying to gain equality with 

15 stick-built in terms of construction. And so we 

16 say manufactured houses now are going to have 

17 seven-foot-wall standard with a taller -- I mean, 

18 what's that going to do to the market? 

19 I'd like to see what retailers think 

20 that's going to do to their business. You know, 

21 if we have plants that are going to nine-foot 

22 walls flat and eight-foot walls flat because --
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1 and it's all in trying to compete with what 

2 stick-built is doing, we're going to take a huge 

3 step back if we think we're going to offset a 

4 shorter wall height with more insulation at the 

5 heel.

6 MR. RAMIREZ: Manny, did I understand, 

7 though, that -- I'm sorry. Emanuel, did I 

8 understand that you could currently pack in an 

9 R38 without changing the structure?

10 MR. LEVY: You can put a -- well, let's 

11 distinguish what we're talking about in terms of 

12 the maximum insulation level, which you can get 

13 well above a 38 or 49, or even 60. That's in the 

14 field there in the middle of the house, as 

15 opposed to what you can achieve at the eave.

16 When we did our analysis, we wanted to 

17 get an R30 at the eave for the 38 in the field 

18 case, the only way to achieve that was to dense19 pack what the insulation that's in the eave area 

20 at a heel height of seven-and-a-half inches. But

21 go ahead.

22 MR. RAMIREZ: And what did that produce, 
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1 dense-packing in that area, as far as the R 

2 value?

3 MR. LEVY: Well, it allowed you to get a 

4 much higher overall -- or a higher. I wouldn't 

5 say much higher -- a higher overall R value and 

6 therefore a lower U value for the same area.

7 But in dense-packing, you're putting a 

8 lot more material into that area that's dense 

9 packed, so it's costing you some money. And that 

10 cost was included in our estimate.

11 MR. RAMIREZ: Okay. So that costing has 

12 already been submitted.

13 MR. SANTANA: Right. Emanuel, but I 

14 think he was asking what R value do you get at 

15 that restricted height area? Because that isn't 

16 R38. You know, what you do is -- so you pack in 

17 as much as you can in the restricted area. You 

18 account for the restricted area. And then you 

19 blow more insulation.

20 And as Michael said, if you have a 

21 double-wide or a triple-wide, you have a lot more 

22 area that's unrestrained that you can actually 
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1 put more insulation versus what's restricted on 

2 the eaves.

3 So then, you do a calculation to say 

4 what's your U value in the brook? You don't say 

5 what's the U value there? Because that might not

6 be R30. This might be R49. And overall, you 

7 say, "Okay, this is R38."

8 MR. RAMIREZ: And so, if it's overall --

9 MR. SANTANA: Right. It depends what 

10 we're talking about. You know, and I think if 

11 Peter is saying we need to -- or if members are 

12 saying we need to have R38 uniform throughout the 

13 roof, that's going to be a problem.

14 If you say we're going to need R38 in the 

15 roof, we'll figure out how to do it. 

16 Manufacturers do that now. But there's a --

17 (Cross-talk.)

18 MR. RAMIREZ: Let me get David and Peter.

19 MR. TOMPOS: I just would point out that 

20 I don't think the IRC requires you to have an R38 

21 throughout the roof.

22 MR. SCHNEIDER: This is Peter --
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1 MR. TOMPOS: So, we're not going that 

2 far.

3 MR. SANTANA: That's what Peter is 

4 saying, right, that it's R16 and --

5 MR. TOMPOS: But he's getting an R30. 

6 IRC requires you can go down to an R30 over the 

7 eaves.

8 MR. SCHNEIDER: Right. And this is 

9 Peter.

10 And Manny and other working group 

11 members, I mean, the idea here is that, looking 

12 at what the overall average R value is of this 

13 roof assembly, you guys can come up to any 

14 Northern climate that gets regular snowfall, and 

15 you go to manufacturing housing lots, private or 

16 leased land.

17 And everybody is out shoveling off their 

18 roof, because the ice damming is so bad that they 

19 all get water infiltration and compromise their 

20 building's durability, as well as the R value of 

21 that insulation that's wet after the first 

22 snowstorm if they aren't out there with roof 
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1 rinks or standing up on their roofs shoveling off 

2 the snow.

3 So, this is about getting the proper 

4 insulation value over the exterior wall where 

5 there's the most heat loss. We need to resolve 

6 that issue. And I find it hard to believe that 

7 we're trying to serve the lowest-income sector 

8 and we're concerned about seven-and-a-half versus 

9 eight-foot ceiling heights, when I'm talking 

10 about having even a deeper pitch cathedralized 

11 space.

12 I can just say anecdotally that over the 

13 last month I've had over probably 600-700 people 

14 tour our mobile home replacement unit in 

15 Burlington, Vermont. Every single person that's 

16 come into that unit can't believe how the space 

17 feels and how big it feels compared to what they 

18 anticipated. So, and that's with a seven-and-a19 half-foot ceiling and eight-and-a-half foot ridge 

20 with a two-and-a-half 12 pitch on the inside and 

21 outside.

22 MR. JACKSON: Michael?
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1 MR. LUBLINER: Yeah. I think we've 

2 thoroughly discussed the thermodynamic issue and 

3 resolved that.

4 But I do want to bring up the cost 

5 savings to the consumer from avoiding ice dams in 

6 Northern climates. We have a similar experience 

7 with a program in Montana and northern 

8 Washington.

9 So I would like to ask either the SAA 

10 program that HUD runs if they're willing to share 

11 that information with DOE, as to how many 

12 thousands of ice dam complaints nationally, or 

13 maybe it's hundreds, or maybe it's not even that 

14 many, they get every year. And look at what the 

15 cost to repair those ice dams are.

16 Manufacturers have some of that 

17 information as well because of the warranties 

18 associated with the project.

19 I think that our group agreed that 

20 durability was a factor we wanted to consider 

21 here. We have some very compelling reasons 

22 thermodynamically that we can do it. The costs 
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1 already assume that. And I think the ice 

2 damming, avoiding ice damming is, anecdotally and

3 probably quantifiable, a significant reason that 

4 the consumer would want the better insulation at 

5 the eaves. Thank you.

6 MR. TOMPOS: A question for Manny. You 

7 know, if we raise the heel height to seven-and-a8 half inches, that only gives me six-and-a-half 

9 inches to put insulation. We still aren't 

10 achieving an R30 over that wall. Is that -- so 

11 your costs don't take into account that we may 

12 have to get to an R30. I mean, this is a 

13 conversation. The IRC requires an R30 over that 

14 edge.

15 MR. LUBLINER: It is what it is.

16 MR. TOMPOS: So, well, if we get to go by 

17 the KISS program, it is what it is. But --

18 MR. LUBLINER: After making all the 

19 attempts to do it as well as possible.

20 MR. TOMPOS: Okay. But even at a seven21 and-a-half heel height, which we don't do now, so 

22 what I'm understanding is that cost is included. 
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1 At some point we're going to have to decide what 

2 that minimum value is and what other cost 

3 implications there are to getting to that, unless 

4 we're going to say it is what it is.

5 MR. LUBLINER: When I said "it is what it 

6 is," what I was saying is you attempt to use the 

7 highest density insulation that you can, which 

8 seems that -- and maybe we'll have a little issue 

9 with some homes that you won't get the full R30 

10 at the eave. And that's why I would say we can 

11 work on this as a unique thing that isn't -- that 

12 because of transport, and make potentially an 

13 exception for certain situations where that 

14 occurs.

15 But I don't think it is what it is at the 

16 2.6 density. And I don't think we costed that 

17 out.

18 MR. TOMPOS: Apparently, we didn't. I 

19 wasn't aware of that.

20 MR. RAMIREZ: So, I think just to try to 

21 capture what I think are a couple of the concerns 

22 here is that you're trying to get the R38 in as 
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1 many places as possible, if not all of them. But 

2 I understand that there may be some restrictions 

3 by the wall where the eave is tighter.

4 And I think that the concern on the 

5 manufacturing side is that, if the standard says 

6 R38, and by the eaves it does not, we don't have 

7 R38, am I going to get in trouble? Right. And 

8 so, if so, do I have to then figure out ways to 

9 get R38 in that area?

10 But what I'm hearing is that there may be 

11 a way to say that, "Hey, let's get R38 in the 

12 most places possible with a few exceptions." And 

13 we could deal with those exceptions. And then I 

14 would ask, how? What is the verbiage that we 

15 would need in order to look at, right?

16 David?

17 MR. TOMPOS: No, I'll let Mark. I'll 

18 pass.

19 MR. RAMIREZ: Okay. Mark?

20 MR. WEISS: Somebody correct me if I'm 

21 wrong. Are we talking about redesigning every 

22 HUD code home to address this, potentially? 
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1 Manny?

2 MR. LUBLINER: Every one?

3 MR. WEISS: That's what I'm asking.

4 (Cross-talk.)

5 MR. MENDLEN: Yeah, but just the 14-wides 

6 and smaller.

7 MR. WEISS: Just what?

8 MR. MENDLEN: Fourteen-wides and smaller, 

9 it looks like.

10 MR. WEISS: Okay. 

11 MR. TOMPOS: No. I mean, we have 5.5 

12 inch heel life on -- 2.5 inch on some, on 

13 everything. So what we're talking about, and 

14 maybe Manny can help us, is, was your cost 

15 assuming that we have to redesign and retest 

16 every truss in the industry?

17 MR. SANTANA: No. No, no. 

18 MR. TOMPOS: But don't we have to do that 

19 if we change the heel height on everything?

20 MR. SANTANA: If you change the truss 

21 design from what it is, you're going to have to 

22 redesign.
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1 MR. TOMPOS: Okay.

2 MR. WEISS: And just to finish the 

3 thought, to me, that's ridiculous. Okay? You 

4 know, Vermont -- I've calculated. Vermont is 2-

5 10th of 1 percent of the manufactured housing 

6 market in 2014-2013. I realize there are other 

7 states with cold climates. But the majority of 

8 our production is going into warmer climates.

9 And to start talking about redesigning 

10 all these homes with the market implications that 

11 Manny mentioned before just seems to me to be an 

12 absurd stretch for what we're doing here.

13 MR. LUBLINER: You know, I'm having deja 

14 vous because when we discussed the wind 

15 standards, and then HUD upgraded it, I heard the 

16 same argument. And after the wind standards were 

17 adopted, we didn't lose the industry. We didn't 

18 change the market share significantly.

19 And we ended up with more durable houses 

20 that made this industry's recognition of a 

21 product that can make it through a hurricane, 

22 recognized that by the insurance companies, the 
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1 banks.

2 And so I'm hearing deja vous, Mark. I 

3 understand what you're saying. I'm not disputing 

4 that there isn't a cost associated with 

5 reengineering the trusses. But I think that 

6 change is something that the only people that 

7 like change are babies with lousy diapers. At 

8 some point, you accept change because it's the 

9 best thing for the consumer.

10 MR. WEISS: Well, and you know, I just --

11 but I don't think you have a comparable argument 

12 from wind standards to what we're talking about 

13 here.

14 MR. LUBLINER: Okay. 

15 MR. WEISS: You have legitimate concerns, 

16 issues with wind damage --

17 (Cross-talk.)

18 MR. WEISS: Well, excuse me. Let me 

19 finish.

20 You had specific issues with wind, and 

21 you had consumer issues, consumer problems. What 

22 we're talking about here, again, I'll go back to 
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1 the AHS information, okay? Operating costs for 

2 manufactured homes equal to in the case of 

3 electricity site-built homes, less than other 

4 fuel types, site-built homes.

5 I have not heard, you know, in relation 

6 to this statute and the process we're talking 

7 about, a great consumer outcry that there's this 

8 deficiency that is a problem and they need to be 

9 changed through drastic measures.

10 So I think you're talking, you know, 

11 oranges-to-apples, Mike, I'm sorry, in this 

12 instance.

13 MR. RAMIREZ: Let me get Lowell, then 

14 Peter.

15 MR. UNGAR: I'm confused on two counts. 

16 One is, there were a couple of references to 

17 redesign, and I'm not quite sure what that means. 

18 I mean, this is a standard. It's my 

19 understanding that very little manufactured 

20 housing meets the standard or is as good in terms 

21 of efficiency as IECC 2015.

22 So, there would be some changes required. 
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1 But that doesn't necessarily mean a whole 

2 redesign of each model.

3 In terms of the latter, I thought the 

4 discussion we were just having was about 

5 cathedral ceilings, which I gather are more 

6 popular, but are still a small, relatively small 

7 fraction of the market. And was this past 

8 discussion about all homes with flat ceilings as 

9 well? Or -- I mean, I thought that was --

10 MR. TOMPOS: Yeah. I mean, it's going to 

11 affect all homes.

12 MR. UNGAR: So I guess, I mean, we 

13 started yesterday at the beginning of yesterday 

14 with a detailed presentation of the cost in order 

15 to get up to different levels of insulation. I 

16 mean, that's -- those were from industry.

17 I mean, you know, we have not vetted 

18 those outside the manufactured housing industry, 

19 but that was my understanding of the presentation 

20 from the manufactured housing industry of their 

21 best estimate of the cost to meet these.

22 And so, are you arguing that those costs, 
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1 which we went over in some detail yesterday 

2 morning, are completely misrepresentative of what 

3 it would cost to meet those levels?

4 MR. RAMIREZ: David?

5 MR. TOMPOS: Well, I wasn't on the 

6 subcommittee. But I mean, I think some new 

7 information came to light. Because there is a 

8 provision in the IRC that says you have to have a 

9 certain R value over the eave. Correct?

10 MALE VOICE: Yes.

11 MR. TOMPOS: And you can't get that with 

12 the trusses that are being sold to the industry 

13 right now. And if we have to go to a seven-and14 a-half or a -- you know, I think Vermont 

15 suggested a 14-inch heel height, you're talking 

16 about redesigning -- I mean, there's going to 

17 have to -- we're going to have to go to the truss 

18 manufacturers. They have to redesign the truss. 

19 Then we have to test the truss because we 

20 test 99 percent of the trusses in the industry. 

21 And I'm just asking. I don't know. Maybe 

22 Emanuel did include that cost.
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1 MR. UNGAR: So, the issue is we're not 

2 talking about the overall R value of the ceiling 

3 insulation? You're concerned about a separate 

4 provision that requires a certain --

5 MR. TOMPOS: Correct.

6 MR. UNGAR: And this is a mandatory 

7 provision?

8 MR. TOMPOS: In the IRC, yes.

9 And I have a conflict here, because if 

10 you change all the designs, and I'm going to have 

11 to review all those, so I'm going to make a lot 

12 of money off this.

13 MR. UNGAR: I'm sorry. You're also --

14 MR. TOMPOS: Maybe I shouldn't be 

15 arguing.

16 MR. UNGAR: I'm sorry. You're also 

17 saying that IRC, you don't mean -- are you 

18 talking about the IECC or a separate version of 

19 the IRSM?

20 MR. TOMPOS: It is in the -- somebody 

21 that knows the code better than me.

22 MR. LACEY: Yes, it's the same thing.
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1 MR. TOMPOS: Same in both codes, okay.

2 (Cross-talk.)

3 MR. UNGAR: So, we're arguing about a 

4 mandatory provision in the IECC, which presumably 

5 Manny's subcommittee looked at. And is that an 

6 unresolved issue under that subcommittee?

7 MR. SANTANA: It's not mandatory.

8 MR. LACEY: No. Let me clarify. I just 

9 -- I want to maybe clarify where this R30 comes 

10 from, or at least where I think it comes from, if 

11 I could.

12 The prescriptive attic or ceiling 

13 insulation requirements that are laid out in the 

14 IECC prescriptive path range from an R30 to an 

15 R49, depending on the climate zone.

16 Now, the IECC prescriptive path has some 

17 exceptions that play into this. One of them is 

18 if the ceiling has an attic space and if the 

19 requirement is R38, so that would apply to 

20 climates IECC -- every climate zone except for 

21 basically the most southern Miami climate zone.

22 If the requirement is R38, you're 
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1 permitted to go down to R30 as long as the 

2 uncompressed insulation over the eave is at least 

3 an R30. So it gives you kind of an exception, I 

4 mean, a lower insulation requirement, as long as 

5 you have the right kind of truss out there.

6 And then, it's similar for --

7 MR. UNGAR: And, sorry. That's -- so 

8 where the overall requirement is for an R38, you 

9 don't have to meet the overall requirement --

10 MR. LACEY: The whole thing could be R30 

11 as long as it extended out to the eaves.

12 MR. UNGAR: To the eaves?

13 MR. LACEY: Uh-huh.

14 MR. UNGAR: So there's two options. You 

15 could either meet the R38 overall.

16 MR. LACEY: Right.

17 MR. UNGAR: Or you could meet the R30 

18 over the eaves?

19 MR. LACEY: Yes. And it's important to 

20 remember, too, that this is just one of the 

21 options. But you could also do a U factor 

22 alternative, which would allow you to trade it 
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1 off and to do other things other than redesigning 

2 the whole, you know, roof maybe. There are 

3 other means of making up, you know, an equivalent 

4 level of overall UA.

5 And so, I think the confusion -- I think 

6 the confusion is coming from the fact that there 

7 is a carve-out in here that allows you to go down 

8 to R30 as long as the R30 is all the way out to 

9 the ends. But that's just an exception to the 

10 prescriptive path.

11 You could put R5 in there if you wanted 

12 to as long as you made up for the energy losses 

13 somewhere else if we're incorporating all the 

14 different paths in the IECC.

15 Am I explaining that correctly?

16 MR. WEISS: Yeah.

17 MR. TOMPOS: Yeah. And again, before I 

18 can tell you if we can or can't do it, I need to 

19 know where we fall on the U values. And I don't 

20 think -- we've been talking more about 

21 prescriptive path. And you know, I've got to put 

22 it in an R38. But I don't -- I haven't seen -- I 
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1 don't know where those U values are going to 

2 fall.

3 MR. LACEY: Yeah. And it may be that if 

4 you build to the prescriptive, you would have to 

5 do the roof a certain way. But if you didn't 

6 want to do the roof that way, you could use the 

7 UA or the performance or whatever compliance 

8 options --

9 (Cross-talk.)

10 MR. RAMIREZ: So then, does this have to 

11 be taken care of in your report?

12 MR. SANTANA: No, I don't think so 

13 because this isn't one of the mandatory -- you 

14 know, the mandatory sections don't get into the 

15 compliance paths. So, what was that?

16 MR. LUBLINER: Why are we talking about 

17 it? It's not mandatory.

18 MR. TOMPOS: Because if we want to have a 

19 prescriptive path, which I thought that was your

20 proposal, Michael, we're going to have to -- I 

21 think we have to address this.

22 MR. LUBLINER: Yeah. We have to address 
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1 it if and when we run into that situation if it's 

2 legitimate. After you dense-packed it and you 

3 dealt with that, if it's still a problem, we can 

4 change it from R30 to whatever it is.

5 (Cross-talk.)

6 MR. SANTANA: Well, the whole thing 

7 started because --

8 MR. TOMPOS: Make it R25 and I think 

9 we're okay.

10 (Laughter.)

11 MALE VOICE: That makes sense.

12 MR. SANTANA: Dave was just providing the 

13 restrictions of the construction. And I think 

14 now it's been very well explained.

15 MR. RAMIREZ: Very well discussed? Okay. 

16 (Laughter.)

17 MR. RAMIREZ: Mark?

18 MR. WEISS: Eric, thank you. I 

19 appreciate the explanation. This just kind of 

20 goes back to something I mentioned more or less 

21 in passing yesterday when we first started 

22 talking about costs.
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1 And that is, I don't know why DOE -- I 

2 wish Joe was here to -- DOE hasn't or doesn't 

3 just build, commission the building of homes to 

4 meet these various requirements, and then you can 

5 really see what the cost is based on the outfit 

6 of a going concern.

7 You get a large company, small company, 

8 medium company, and just build some of these 

9 things. And you're not talking about necessarily 

10 a long period of time to do it. And see what all 

11 this looks like, you know.

12 I'm all for theoretical discussion. But, 

13 you know, some facts on the ground might help.

14 MR. RAMIREZ: Okay. Michael?

15 MR. LUBLINER: So, I said before that I 

16 go out into factories, and I see R38s sold as an 

17 option currently. How are they doing it? It's 

18 your plant. Plants that you represent, other 

19 plants, how are they doing it?

20 MR. EZZO: Michael, this is Mark Ezzo. 

21 I'll answer that.

22 MR. LUBLINER: Thanks, Mark.
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1 MR. EZZO: So, the insulation folks that 

2 we buy from -- and we buy from some of the 

3 biggest suppliers in the country. We buy a lot 

4 from JM, right? They give us these bag charts. 

5 And it says, if you want to put R38 in the roof,

6 and the ceiling is 13 feet 2 inches wide, and 

7 it's 68 feet long, and if you want to hit R38, 

8 you've got to put in 18.4 bags.

9 And I'll tell you that today, for the 

10 most part, it may not be 100 percent, but a huge 

11 majority of our rafter profiles, we can fit 18 

12 bags in and hit R38. Okay? That's on paper. 

13 That's according to the Johns Manville chart that 

14 says, if you put 18 bags in at a ceiling that 

15 size, you're going to hit R38, okay?

16 Now, JM doesn't take into consideration a 

17 lot of geometry and heel heights and roof slopes 

18 and ceiling slopes. They just say, if you put 

19 this much insulation in the roof, you're going to 

20 meet our tabulated R value. And that's what we 

21 do, and that's what everybody in the industry 

22 does. Okay?
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1 So, we tell consumers they're getting --

2 they order an R38 roof. And that's what's in our 

3 option package. And that's what's in our sales 

4 literature. And that's what we're doing.

5 MR. LUBLINER: Thanks, Mark.

6 MR. EZZO: Now, to Dave Tompos's point, 

7 when we run an energy calculation to comply with 

8 the HUD code, right, heat loss calc, we're taking 

9 into consideration all that truss geometry and 

10 coming up with a U value of all the components. 

11 And I know I'm telling you stuff you already 

12 know.

13 And when we do that, the net U value that 

14 comes out of that roof or ceiling, because of the 

15 geometry, it doesn't always equate to a true R38. 

16 Okay? It may be something a little bit less than 

17 that based on that truss geometry. But we're 

18 still putting in all the prescribed insulation 

19 amount that Johns Manville tells us to put in the 

20 roof. Okay?

21 So, I mean, all that said, I understand 

22 that, you know, we're taking a 20-year leap in 
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1 energy standards. So, I mean, to me it's natural 

2 that we're going to run into situations like 

3 we're looking at here on the screen, where in the 

4 coldest climates those profiles are probably not 

5 going to work in a lot of cases.

6 For one thing, you can't get 18 bags of 

7 insulation in that roof that I'm looking at 

8 there. It's just physically impossible. So 

9 there's going to be situations like this that's 

10 like we're looking at that, even if you try to do 

11 the UA tradeoff or even if you try to go 

12 prescriptive or even if you do overall U value, 

13 we're still going to have situations where that 

14 geometry just flat-out doesn't work and we're 

15 going to have to do, you know, one of several 

16 things.

17 Lower wall heights. Lower ceiling 

18 pitches. Raise roof pitches. Increase heel 

19 heights. A combination of those things -- I 

20 mean, we're going to have to do something to make 

21 it work.

22 Does that answer the question?
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1 MR. LUBLINER: It totally answers my 

2 question. Totally answers my question. Thank 

3 you very much.

4 (Pause.) 

5 MR. RAMIREZ: What do we need to do with 

6 this information?

7 MR. SANTANA: Internalize it. It might 

8 come out later on, to sections of the code.

9 (Cross-out.)

10 MR. TOMPOS: As we get into the specifics 

11 on the prescriptive methods, I think we're going 

12 to have to look at this again.

13 MR. RAMIREZ: So, does everyone go with 

14 moving on then, with respect to --

15 MR. WEISS: We'll go on into Manny's

16 area? I just didn't hear what you said.

17 MR. RAMIREZ: Oh. Yes. He was saying 

18 that we're going to have to deal with it later 

19 when we're talking about different compliance 

20 paths.

21 MR. SANTANA: Because we haven't even 

22 started talking about how we're going to comply.
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1 MR. WEISS: Yeah. Yeah.

2 MR. SANTANA: You know? So we've got to 

3 keep this in mind, just internalize it.

4 MR. RAMIREZ: Which I would like to do 

5 sometime today. We'll see if we can get there. 

6 Everyone's smiling at me like, "Oh. It's a 

7 landmine." But let's see.

8 All right, so good to move on?

9 (Pause.) 

10 MR. RAMIREZ: Then the next one is Manny.

11 MR. SANTANA: Okay. Can we get a break 

12 before this?

13 MR. RAMIREZ: Let's do that. Thank you. 

14 Let's take a 10-minute break, and then we'll come 

15 back at 2:30.

16 (Recess from 2:19 p.m. until 2:35 p.m.)

17 MR. RAMIREZ: All right. So, Manny is 

18 going to go next. And what we did was, Mark had 

19 the good idea -- thank you -- for continuing the 

20 same format that we had last time, when we were 

21 discussing some of these items as far as, if 

22 there's a consensus agreement, any comments on 
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1 the cost or savings impact, and then whether this 

2 is a current practice or not. All right? So 

3 those are some of the things that we had 

4 discussed last time.

5 So, with that, Manny, I'd like to turn it 

6 over to you to guide the discussion here.

7 MR. SANTANA: Okay. So, this 

8 subcommittee was focused on identifying the parts 

9 of the IECC that are required as mandatory, and 

10 then go through and recommend whether or not, 

11 Dave, this should be added to the MH standard or 

12 not.

13 And we went through the easiest at the 

14 last meeting. And so now we're going through the 

15 items that required some more consideration and 

16 that may not get accepted as is, although we did 

17 come to a determination that several of them may 

18 be accepted as is, or we recommend they could be 

19 accepted as is.

20 So -- and again, speaking to the idea of 

21 poor concepts, you know, some of these issues, we 

22 can accept in principle, but didn't want to --
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1 couldn't spend the time to come up with any kind

2 of language for them. So, you know, you might 

3 see that in here, where we just -- you know, we 

4 accept the concept in principle, but don't know 

5 exactly how it should read.

6 With that, I think the best thing to do 

7 is to just go in order. I may jump around a

8 little bit if we come across an item that may be 

9 time consuming.

10 So, if everybody has a copy of the IECC, 

11 and you go over to section R401.3, and that's on 

12 page R29, R401.3 --

13 MR. RAMIREZ: Give folks just a second 

14 there.

15 MR. LUBLINER: Are there extra copies of 

16 the IECC around?

17 MR. RAMIREZ: Emily, do you know where 

18 those books are at?

19 MR. LUBLINER: I didn't get one.

20 (Pause.)

21 MR. LUBLINER: I had to buy mine, but I 

22 didn't --
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1 (Cross-talk.)

2 MALE VOICE: We can share.

3 MR. LACEY: I can look on.

4 MR. RAMIREZ: We can share, yeah, yeah.

5 MR. LUBLINER: Thank you.

6 (Pause.) 

7 MR. SANTANA: So, R401.3 deals with the 

8 certificate. And, you know, Ted, if you can put 

9 up the suggested -- what everybody suggested, not 

10 language, but -- okay. 

11 When it comes to the certificate, and if 

12 you could scroll down a little bit --

13 (Pause.)

14 MR. SANTANA: You know, the IECC has a 

15 requirement to install a certificate that lists 

16 several items which would duplicate the 

17 certificate requirements currently in the HUD 

18 code.

19 So, without getting into, or without 

20 knowing how it's going to be implemented or 

21 enforced and without wanting to get into that, 

22 the committee recommends that DOE refer to the 
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1 HUD code requirements for what's currently 

2 required in their certificates, but make sure and 

3 include fenestration U values and SHGC values 

4 which currently aren't required by the HUD code.

5 So that's the recommendation there.

6 (Pause.)

7 MR. SANTANA: I'll open it up to 

8 discussion.

9 MR. RAMIREZ: Yeah. Questions?

10 Mark?

11 MR. WEISS: Manny, could you be a little 

12 bit more specific and say "information for 

13 fenestration U values and SHGC" -- are you 

14 talking about general information or information 

15 for that particular unit?

16 MR. SANTANA: Well, okay. The 

17 requirement in the IECC, one of the things that 

18 it requires is that the manufacturer have a label 

19 where you list the U values for your windows and 

20 the solar heat gain coefficient for the window.

21 And the reason why we added that 

22 specifically is because that item isn't included 
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1 in the HUD current requirements, and we think 

2 it's a good idea.

3 MR. WEISS: So it's the data for that 

4 home?

5 MR. SANTANA: Yeah, for that particular 

6 home.

7 MR. WEISS: That's what I figured.

8 MR. LACEY: Windows that are NFRC labeled 

9 will have that in big numbers right on the label.

10 (Cross-talk.)

11 MR. LACEY: That's why you should put it 

12 on the certificate, yeah.

13 MR. UNGAR: I had a couple of questions

14 about that. When you looked at it, I mean, did 

15 you decide that the other things that are on the 

16 IECC's certificate are already included on the 

17 HUD code?

18 MR. SANTANA: Most of them are. One of 

19 the ones that -- one of the items that isn't is 

20 the efficiencies of appliances. And one of the 

21 things that HUD's data plate requires is that you 

22 list the appliance. You know, so you list the 
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1 model, you list the appliance. You don't list 

2 the efficiencies.

3 And we wouldn't include that as a 

4 recommended; I guess you could suggest that. But 

5 we didn't really see the benefit of it. You 

6 know, the U values for the fenestration and the 

7 solar heat gain value for the fenestration, we 

8 could see the value in that. But the efficiency 

9 on the appliances, you know, didn't really find 

10 that to be essential.

11 MR. RAMIREZ: Michael?

12 MR. LUBLINER: I really like providing 

13 more information on that label for a number of 

14 reasons. For the consumer to shop around. 

15 They're in a lot. Look at what they're getting 

16 for their price and given the market and given 

17 the consumer choice. But also, we find that a 

18 lot of lenders, as we are starting to recognize 

19 energy ratings, like third-party folks, provide 

20 preferable financing.

21 So, the more information that's readily 

22 available means that the rater doesn't have to 
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1 spend a lot of time figuring things out and can 

2 cost-effectively rate the home and might help 

3 those homeowners, second-homeowners or whoever, 

4 or utility program that wants to verify that this 

5 home is going to meet their standards.

6 So I think this is a really good thing. 

7 I think as far as the appliances go, if it's new, 

8 you've got the energy guide label. But once that 

9 home is sold, that energy guide label kind of 

10 isn't there anymore. So you kind of lose that. 

11 But I think it's appropriate that the energy 

12 raters can go look at the appliance and figure 

13 out what the rating is.

14 But this is a good thing. I think it's 

15 transparency, it's consumer choice. It's better 

16 information for the heating contractor to 

17 calculate the size of the air conditioner after 

18 market if there's a need for that. So I think we 

19 did good on that one.

20 MR. RAMIREZ: Let me see a show of thumbs 

21 if everyone is okay with the committee 

22 recommendation.
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1 MR. UNGAR: Sorry. I have one more thing 

2 to ask before.

3 MR. RAMIREZ: Go ahead. Yeah.

4 MR. UNGAR: You know, on that it seems to 

5 me that the appliance information might be useful

6 for programs, but I don't feel really strongly 

7 about it.

8 I'm more wondering, Robin in his 

9 presentation last time made a strong pitch for 

10 energy use estimates on labels. And I don't 

11 know, I'm curious both whether you considered 

12 that, and then you know, I guess, if particularly 

13 if Robin, given his strong -- has any comment on 

14 that.

15 Because it would seem to me that this, if 

16 we were to do it, this would be, I assume, where 

17 it would be included. So I just wanted to flag 

18 that as, that seems to me that that would be the 

19 issue here.

20 MR. ROY: Okay. Then I have to say 

21 something.

22 (Laughter.)
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1 MR. RAMIREZ: Go ahead.

2 MR. ROY: Robin.

3 In the context of having different 

4 product types, it seemed particularly useful to 

5 make it easier for consumers to understand what 

6 they might be buying or what they might be 

7 trading off.

8 In that case, it seemed very useful to 

9 have something which is particularly 

10 understandable to consumers. And some of the 

11 stuff isn't really very useful anyway.

12 FTC labels like I put up on the screen a 

13 couple of weeks ago show how much money you're 

14 spending at currently projected prices and where 

15 this particular unit fits within the spectrum of 

16 homes, typical stuff you see for refrigerators, 

17 for example.

18 Dollars are, I think, helpful both to 

19 consumers, the first buyers, subsequent buyers, 

20 and perhaps will help twig with some of the 

21 raters. I don't know. I suspect raters are 

22 sophisticated enough to not need that, but it's 
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1 always useful to have that to push a 

2 conversation.

3 I wouldn't be proposing it here if you 

4 have a single product type, particularly. I 

5 wouldn't object to it. I'd like to see it. I 

6 think it's helpful for folks to kind of 

7 understand. But they won't be trading off 

8 between nearly so much as they would in a two9 product-type world.

10 Does that make sense?

11 MR. SCHNEIDER: This is Peter, from

12 Efficiency Vermont.

13 MR. RAMIREZ: Yeah. Go ahead, Peter.

14 MR. SCHNEIDER: I was just going to say, 

15 in Vermont, you know, our MLS listing is an 

16 example as the home energy rating index, any 

17 other certifications that have been earned with 

18 regards to ENERGY STAR or Energy Code Plus.

19 Where I think that labeling is going to 

20 be the most important is with regards to 

21 appraisers. And right now, in our units, we have 

22 an energy light bulb that has the home energy 
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1 rating index for the homes and the -- yeah.

2 And so I think that having a label in 

3 here which no -- this is the code that the home 

4 has achieved, whether it's achieved ENERGY STAR 

5 as well, but provides compliance, just will help 

6 the appraiser identify this home and provides 

7 value over the costs that make other homes that 

8 are sold or that have met a lesser code that may 

9 not carry the ENERGY STAR label.

10 MR. RAMIREZ: David?

11 MR. TOMPOS: I think some type of an 

12 energy rating would be a good idea. I think it 

13 can be done when the manufacturer does their heat 

14 loss calc. So I don't think there would be much 

15 additional expense.

16 However, I am opposed to the idea of 

17 giving a dollar amount. Because this industry, 

18 for whatever reason, the consumers like to sue 

19 the manufacturer. And if we put a dollar amount

20 on appliances, you can't really relate that to 

21 anything because your energy bill is added up 

22 among a lot of things.
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1 So now if I have a dollar amount that 

2 says, "You're going to spend $100 a month on this 

3 house," but if I've got six kids in the house and 

4 I'm leaving the windows open and the air 

5 conditioning on 60, and I'm spending $200, you 

6 know, a month, I'm going to go sue that 

7 manufacturer because they lied to me about what I 

8 was going to spend on this house.

9 So, if we come up with a rating that's 

10 like a HERS rating, is zero to 100 or whatever it 

11 is, I can live with that. But I would be opposed 

12 to some type of a dollar amount.

13 MR. ROY: This is Robin.

14 That kind of means you're saying that 

15 it's less transparent to a consumer. And that 

16 makes it positive. I hear what you're saying 

17 with that.

18 My qualifier for it -- and I take the 

19 point that one might, a buyer might end up 

20 spending a lot more and has some dissatisfaction. 

21 But I think in all of those, even in the 

22 appliance world, there is -- it's qualified, 
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1 saying "in typical use" and "in typical 

2 circumstances."

3 And I think it's appropriate to have that 

4 kind of language. And if you have six kids and 

5 you don't get to this, it's going to be 

6 different. Where do we go with that?

7 MR. RAMIREZ: Mark, and then Emanuel. 

8 I'm sorry, Manny.

9 MR. WEISS: I'll go beyond Dave. I mean, 

10 even a rating that's calculated by the 

11 manufacturer is litigation bait. I mean, when 

12 you're talking about fenestration U values and 

13 you're getting that number from the manufacturer,

14 or SHGC also, you're just passing through 

15 information you get from the manufacturer.

16 Somebody sues you, you say, "Hey, over 

17 there." But once you start making calculations 

18 and dollar values like Dave was talking about, 

19 it's Katie-bar-the-door. I mean, there's all 

20 sorts of potential for problems there.

21 MR. RAMIREZ: All right. Manny?

22 MR. WEISS: I mean, I know what you're 
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1 trying to accomplish. But there's blowback from 

2 it.

3 MR. RAMIREZ: Let me get Manny, and then 

4 we'll see if there's anyone on line.

5 MR. SANTANA: You know, one of the ways 

6 that we were able to get through the section was 

7 to try to keep as narrow a scope as we were 

8 comfortable with. And although I see the 

9 benefits to having an energy rating for the house 

10 or an energy usage for the house, I don't think 

11 that that's the same as the certificate that's 

12 required in the IECC.

13 You know, it's in addition to that. So, 

14 you know, I would suggest that we close this 

15 issue off before -- and this energy use label is 

16 probably going to be a separate issue altogether. 

17 All the information probably wouldn't be on the 

18 same label.

19 You know, the reason why we made this 

20 suggestion is so that we can try to contain the 

21 information on one sticker.

22 MR. RAMIREZ: Ishbel?
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1 MS. DICKENS: May I just suggest that we 

2 put energy label on the parking lot then, so that 

3 we don't forget about it?

4 MR. RAMIREZ: Eric?

5 MR. LACEY: I was just going to back up 

6 what Manny said. You know, we've kind of -- we 

7 have this fundamental choice. Do we start with 

8 the HUD label and add something to it? Or do we 

9 start with the IECC certificate and try and add 

10 the HUD stuff to it?

11 And we took the approach of starting with 

12 the HUD label that already goes on these homes, 

13 said, what are a couple of things we could add to 

14 this to get basically the same information out 

15 there? Right or wrong, that's kind of the 

16 approach we took.

17 MR. RAMIREZ: So, Ted started an 

18 electronic parking lot and threw in the energy 

19 labels in there.

20 Lowell?

21 MR. UNGAR: So, as I understand that, for 

22 energy ratings, there was also the suggestion 
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1 just if it's ENERGY STAR home, to put that one. 

2 And I don't know what it could also do based for 

3 UO value, not all homes -- we haven't discussed 

4 compliance paths. But it's not clear that all 

5 homes will have a calculated UO value.

6 But if that was part of the calculation, 

7 it would seem to me that those two things could 

8 easily be added there. They're set information. 

9 It's not -- I don't see those as particularly 

10 litigation bait, and would be helpful then for 

11 appraisals or for future programs.

12 MR. EZZO: This is Mark Ezzo.

13 MR. UNGAR: Or ENERGY STAR, whatever --

14 (Cross-talk.)

15 MR. EZZO: Don't those already come with 

16 their own labels?

17 MR. UNGAR: Yeah, but separately labeled, 

18 that's fine.

19 (Cross-talk.)

20 MR. UNGAR: If there's a separate label 

21 on the home, then I withdraw it, separate 

22 certification.
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1 MR. RAMIREZ: Okay. Mark, what was your 

2 question?

3 MR. EZZO: It wasn't a question; it was a 

4 statement. ENERGY STAR homes already come with 

5 their own labels.

6 MR. TOMPOS: Yep.

7 MR. LUTER: This is Rob. I've got a 

8 comment if I can sneak it in?

9 MR. RAMIREZ: Yeah.

10 MR. LUTER: Rob Luter with Lippert.

11 I would be very cautious about putting 

12 anything on the label that is not objective and 

13 supportable, you know. About two to three ALMA 

14 (phonetic) meetings ago, we had a very nice 

15 person from the FTC come in and give us a lecture 

16 on how it was verboten to make claims about 

17 percentage of energy saved if someone bought our 

18 fenestration or potential dollars saved.

19 In fact, the FTC has brought suit against 

20 parties for making just the kind of claims that I 

21 think we're contemplating putting on a label.

22 MR. WEISS: That's an excellent point. 
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1 Also, there could be concerns with state-level 

2 enforcement as well regarding false claims.

3 MR. LUTER: No. I've just always found 

4 that if one -- I think it's a good idea to put 

5 some sort of rating on this label. The more 

6 useful information for the consumer, the better.

7 But I wouldn't want it to be misleading 

8 or at all subjective or something that had to be 

9 qualified. Because the consumer's just not going 

10 to understand.

11 MR. RAMIREZ: So, let me understand, 

12 though. I think what's being recommended by the 

13 subcommittee is the U value. Is that --

14 MR. LACEY: Yeah. Just to be clear, Rob, 

15 you're not opposing listing the labeled 

16 fenestration U values and SHGC's. You're talking 

17 about the issue of a rating system or making 

18 claims about the dollars or percentage energy 

19 efficiency, right?

20 MR. LUTER: That's correct, Eric.

21 MR. LACEY: Okay. 

22 MR. LUTER: I think it's a good idea to 
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1 make supportable claims using objective measures. 

2 In fact, we do that on all fenestration as it's 

3 delivered. It's labeled with the NFRC certified 

4 U values, solar heat gain, air leakage, 

5 condensation rating, in some cases.

6 And I don't -- I'm just sharing that 

7 regarding the fenestration. But if there's going 

8 to be a rating plate on the home, I think it's 

9 important that that feature only objective data 

10 that can be supported, and not potential savings 

11 or, you know, dollars-a-month or what-have-you.

12 MR. RAMIREZ: So let me clarify it then 

13 with the subcommittee. That is what you're 

14 suggesting, correct?

15 MR. LACEY: Yes. We parked the other 

16 issue for now, right?

17 MR. RAMIREZ: On the energy label?

18 MR. LACEY: The labeling. 

19 MR. RAMIREZ: Yeah, yeah, yeah.

20 MR. LUBLINER: And since we put this in 

21 the parking lot, could I make a suggestion? 

22 Because I understand DOE has a labeling rating 
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1 program already. And what I'm hearing from Rob 

2 is that the FTC has some concerns. And maybe I'm 

3 hearing this wrong.

4 But I would recommend that whatever we

5 do, we have liaison with the Federal Trades 

6 Commission to make sure that it's appropriate. 

7 And I'd make that recommendation to DOE legal 

8 counsel and to Joe.

9 MR. LUTER: Michael, I believe you are 

10 hearing me correctly. It was a real head11 scratcher for us when we sat through a 

12 presentation telling us exactly what not to do. 

13 And we brought up the ENERGY STAR site, and they 

14 were doing the exact same thing that we were just 

15 told not to do.

16 Now, maybe it's because we're 

17 fenestration people and not well liked; I don't 

18 know.

19 (Laughter.)

20 MR. LUTER: Sarcasm intended.

21 MR. LUBLINER: I kind of attribute it to 

22 silos in Washington, D.C., to tell you the truth.
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1 MS. VAIDYANATHAN: This is Kavita

2 Vaidyanathan, DOE legal counsel.

3 We have some questions about labeling. 

4 And we do have some authority on labeling, but 

5 not all the authority. FTC does have authority 

6 over labeling. So we will be talking to them to 

7 see what authority we have for this type of 

8 labeling before we can move forward with it.

9 MR. RAMIREZ: All right. Then, what was 

10 suggested by the subcommittee, I think there was 

11 one little amendment to that, is -- does that 

12 work for the group here? There it is.

13 All right. Let me see a show of thumbs 

14 for ones okay with that.

15 (Pause.)

16 MR. RAMIREZ: Yeah, Mark?

17 MR. ROY: I can't believe it. He's got 

18 his thumb up.

19 (Laughter.)

20 MR. WEISS: Hey, hey!

21 FEMALE VOICE: Can we take a picture of 

22 this, Mark?
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1 MR. WEISS: Aw, come on. I've had my 

2 thumb up, what, at least 60 percent of the time.

3 (Laughter.)

4 MR. WEISS: Anyway, just a comment that I 

5 have to make. My thumbs up is subject to what I 

6 said last week, and I forget exactly how or what 

7 I said. But the gist of it was, the thumbs up is 

8 with respect to the recommendation subject to 

9 cost analysis, something along those lines.

10 MR. RAMIREZ: Okay. Thank you.

11 So, any thumbs down on the phone?

12 (Pause.)

13 MR. RAMIREZ: Okay. Then that one has 

14 unanimous support.

15 Next one?

16 MR. SANTANA: Okay. The next one is on 

17 page R33, and it's a grouping of items. It 

18 encompasses 402.4 all the way through 402.4.4. 

19 And don't know if you want to, you know -- we'll 

20 take them as they go. You might not be able to 

21 vote on the first one until we get through them 

22 all because one references some of the other 
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1 ones. But we'll just go in order.

2 On page R33 of your IECC, R402.4, Air 

3 Leakage. And this here, we suggested that it 

4 just go through as it is. You know, the only 

5 thing that it says is that your thermal envelope 

6 shall comply with other sanctions and that 

7 however you seal this cylinder, materials will 

8 allow for differential expansion. And we didn't 

9 have an issue with that.

10 MR. WEISS: Manny, it sounds like 

11 basically just an introduction to the sections 

12 that follow, right?

13 MR. SANTANA: Right.

14 MR. WEISS: And I have a question for 

15 Dave, or this goes -- I hope it doesn't. But 

16 perhaps, does this go back to the argument we had 

17 previously? Is there any problem with the term 

18 "building thermal envelope" and then the 

19 definition, understand what that means? Because 

20 if you have a problem with that, then you're 

21 going to have a problem, even if it's just an 

22 intro.
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1 MR. TOMPOS: Well, I don't think it's 

2 "thermal envelope" that we were having problems 

3 with. It's "pressure envelope."

4 MR. WEISS: Okay.

5 MR. TOMPOS: So I'm okay with this.

6 MR. WEISS: Thanks.

7 MR. TOMPOS: And we're just talking about 

8 402.4?

9 MALE VOICE: At this point.

10 MR. TOMPOS: Or all the subsections?

11 MR. SANTANA: 402.4, but we're going to 

12 get into all the subsections one at a time.

13 MR. TOMPOS: Oh, one at a time?

14 (Chorus of "Yeah.")

15 MR. SANTANA: Yeah, so we might have to 

16 go through them all before we can come back and 

17 vote on 402.4, because you might not be 

18 comfortable with what 402.1 through 402.4.4 

19 contain.

20 MR. TOMPOS: Okay. 

21 MR. WEISS: But there's no controversy 

22 about what they mean by "building thermal 
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1 envelope"?

2 MR. SANTANA: We'll define -- it's 

3 defined in Chapter 2.

4 MR. WEISS: Okay. Great.

5 MR. RAMIREZ: Okay. So, any questions on 

6 that one?

7 (Pause.)

8 MR. RAMIREZ: We may later, but as of 

9 right now, everyone understand that?

10 Okay. So, let's go on with the next one.

11 MR. SANTANA: Okay. The recommendation 

12 for 402.4.1 is the same. You know, we recommend 

13 that that one be adopted as is, didn't find 

14 anything wrong with it.

15 (Pause.)

16 MR. SANTANA: Okay. And that one also 

17 references other sections. So we want to keep 

18 that in mind.

19 Now, 402.4.1.1, that deals with 

20 installation. The only thing we wanted to strike 

21 was the reference to the code official or 

22 approved third party, as that gets into, you 
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1 know. Now, this references the table, which is

2 down the line as well. But we didn't find 

3 anything else wrong with that.

4 402.4.1.2, that deals with testing of air 

5 leakage. And so we pondered on that one. 

6 Highlighted the entire section, and it says that 

7 it would -- we deferred to the Emanuel proposal

8 and all of the discussion that that is going to 

9 require.

10 MR. TOMPOS: Didn't we vote?

11 MR. LACEY: Yeah.

12 MR. TOMPOS: We were going to have 

13 descriptives? So can we -- we're basically 

14 striking all the testing, correct?

15 MR. LACEY: Yeah. I think we can delete 

16 this whole thing now, don't you?

17 MR. SANTANA: Yeah.

18 MR. WEISS: We're striking that?

19 MALE VOICE: yeah.

20 MR. SANTANA: So then, as we strike 

21 things, the sections that reference them are 

22 going to have to be updated. That goes without 
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1 saying.

2 Okay. So, 402.4.2 is Fireplaces. So you 

3 might want to change that.

4 MR. RAMIREZ: I'm sorry. So one of the 

5 quick amendments is under 402.4.1, where it 

6 references 402.4.1.2. That could be deleted 

7 then?

8 MR. SANTANA: Well, it will be updated, 

9 yeah.

10 MR. BANTLE: Just strike that?

11 MR. RAMIREZ: Yeah.

12 MR. SANTANA: Okay. 

13 MR. RAMIREZ: Right?

14 MR. SANTANA: Right.

15 MR. RAMIREZ: Okay. 

16 MR. LACEY: It's probably just editorial 

17 stuff.

18 MR. RAMIREZ: Okay. Yeah. Let's skip 

19 that then, yeah.

20 All right. Go ahead.

21 MR. SANTANA: Okay. 402.4.2, it's on the 

22 same page. And this one deals with the tight-
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1 fitting doors or dampers on wood-burning 

2 appliances, or wood-burning fireplaces. And we 

3 struck the first part of it because the HUD code 

4 references the same thing.

5 The only difference between the HUD code 

6 and this section is the year of the standard. 

7 And I don't know if we want to get into the ins 

8 and outs of UO 127. I haven't read either. So I 

9 couldn't comment on it.

10 The only section we retained was the one 

11 that's outside of the HUD code, and it only 

12 affects fireplaces that you build out of masonry, 

13 which I don't know are a big segment of 

14 production.

15 (Pause.)

16 MR. ROY: Zero, right?

17 MR. SANTANA: I think so. But if we do, 

18 then how do you put a door in there?

19 (Laughter.)

20 MR. WEISS: We're checking on something.

21 MR. RAMIREZ: Mark, yes. Sorry.

22 MR. WEISS: We're checking on something. 
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1 I might have a question.

2 MR. RAMIREZ: Okay. 

3 MR. WEISS: I'm not sure yet.

4 MR. RAMIREZ: Okay. 

5 MR. SANTANA: Okay. So then --

6 MR. RAMIREZ: Hold on a second. Just one 

7 second.

8 MR. SANTANA: Okay. 

9 (Pause.)

10 MR. SANTANA: Oh, by the way, so the 

11 language that's below that is an excerpt from the 

12 HUD code that will show what's --

13 MR. RAMIREZ: Yeah, Mark.

14 (Cross-talk.)

15 MR. WEISS: Manny, the term "tight16 fitting door," I mean, is this language here in 

17 black, is that in the IECC? Or did you put that 

18 together?

19 MR. SANTANA: That's verbatim out of the 

20 IECC.

21 MR. WEISS: Okay.

22 MR. SANTANA: Right. They use the strike 
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1 underline format.

2 MR. WEISS: Okay. 

3 MR. SANTANA: So anything struck is --

4 well, anything underlined is added.

5 MR. WEISS: Okay. That wasn't the 

6 question, but thanks.

7 "Tight-fitting doors," is that defined 

8 anywhere here? Or is it recognized as a term of 

9 art?

10 MR. SANTANA: We got into that a little 

11 bit.

12 MR. WEISS: Okay. 

13 MR. SANTANA: And, but to narrow the 

14 scope again, what we decided is that, since we 

15 didn't expect masonry fireplaces to be very much 

16 of an issue, we decided to just let it go.

17 MR. WEISS: I'm sorry, Rick. Did you 

18 have something?

19 MR. MENDLEN: They don't use masonry 

20 fireplaces.

21 MR. WEISS: We don't use them?

22 MR. MENDLEN: Yeah.
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1 MR. WEISS: So why are we talking about 

2 them?

3 (Cross-talk.)

4 MR. LUBLINER: If a client wanted to 

5 order and the manufacturers want to build it, 

6 it's got to have a standard.

7 MR. WEISS: I don't want to hold up 

8 progress in the world. But just make a note, I 

9 mean, "tight-fitting doors," what does that mean? 

10 You know, again, you have to comply with this, on 

11 criminal penalty if you don't. And even if 

12 there's two of them in the country. You know? 

13 So what's a tight-fitting door? That's all.

14 (Cross-talk.)

15 MR. SANTANA: You know, I guess --

16 MR. ROY: It's something to be avoided, 

17 according to this.

18 (Laughter.)

19 MR. ROY: You only put in a tight-fitting 

20 door on a masonry fireplace.

21 (Cross-talk.)

22 MR. RAMIREZ: Hold on a second, folks.
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1 (Laughter.)

2 MR. RAMIREZ: All right. So --

3 MR. MENDLEN: It has to be listed and 

4 labeled. That's the answer.

5 (Pause.)

6 MR. RAMIREZ: All right. Move on?

7 MR. ROY: You're suggesting something, G, 

8 in place of what's there?

9 MR. SANTANA: No, no, no, no. G was for 

10 reference.

11 (Cross-talk.)

12 MR. ROY: It's already been covered.

13 MR. SANTANA: Yeah, it's already covered. 

14 So this G is -- so if you say, "I don't believe 

15 Manny. He's a liar." So this is what the HUD 

16 code --

17 MR. RAMIREZ: Mark, you know, I think 

18 that might be relevant. I don't know if that was 

19 quite clear before. But it's referencing the HUD 

20 code, and all Manny did was cut and paste it for 

21 our purposes just so that way we could see what 

22 does that reference.
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1 MR. SANTANA: Right. We're not adding 

2 anything.

3 MR. RAMIREZ: So, the suggestion isn't to 

4 add that verbiage in there that's in the black. 

5 It's just referencing the HUD code. That is the 

6 HUD code reference that's in the document.

7 MR. WEISS: I'm not sure we're saying the 

8 same thing. I mean, I understand that's part of 

9 the black sentence there, is part of the IECC. 

10 I'm just asking, is there a definition somewhere 

11 in the IECC or UO 907 of what a "tight-fitting 

12 door" is so somebody doing this knows how to 

13 comport their conduct with the law? That's all.

14 MR. SANTANA: We didn't find "tight15 fitting" in the IECC.

16 MR. WEISS: Okay. 

17 MR. SANTANA: Don't know about the UO, 

18 though.

19 MR. WEISS: Okay. I'll put it down. If 

20 I can find it on the internet, I'll see what it 

21 says. 201, UO 907.

22 MR. SANTANA: Okay. 402.4.3, on the same 
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1 page, it's R33. This one deals with fenestration 

2 air leakage. And we kind of touched on this 

3 earlier today. And the suggestion is to strike 

4 the entire section. And the reasoning is HUD has 

5 specific requirements that deal with the force 

6 required to open an egress window.

7 And so, if you meet those requirements, 

8 you can only tighten it up to a certain level. 

9 So if you comply with 402.4.3 and tighten it up 

10 even further, you might not comply with the 

11 egress end, but you're in the HUD code. 

12 (Pause.)

13 MR. RAMIREZ: Okay. Next?

14 MR. SANTANA: Okay. 402.4.4, we didn't 

15 resolve this one. And it's not because it was so 

16 complex. It was we didn't reach a discussion on 

17 this one because there is a portion of the HUD 

18 code that deals with appliances in rooms, or 

19 rooms that contain reverberating appliances, and 

20 we just didn't have the time to do the research 

21 to find out how they compare.

22 So we don't have a recommendation, don't 
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1 know if what's in the HUD code mirrors this, it's 

2 less than this, or exceeds this. I don't know 

3 how we could put a placeholder on it. But there 

4 is a chance that the requirements are parallel or 

5 overlap. And so, you know, DOE would have to 

6 compare them both, I think.

7 MR. RAMIREZ: So you just need more time 

8 for that one?

9 MR. SANTANA: Yeah. We needed more time 

10 for that one. Ran out of time.

11 MR. RAMIREZ: Okay.

12 MR. SANTANA: So that concludes this 

13 block of sections of related sections.

14 MR. RAMIREZ: Okay. So, let me ask the 

15 group, are you okay with adopting these 

16 recommendations?

17 (Pause.)

18 MR. RAMIREZ: Again, in the context of 

19 seeing it all, similar to the way we were doing 

20 the other ones, right?

21 So, let me see a show of thumbs if we're 

22 okay with these recommendations.
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1 (Pause.)

2 MR. RAMIREZ: Anyone on the phone, your 

3 thumbs down?

4 All right. So that one's unanimous as 

5 well, or that block, rather.

6 (Pause.)

7 MR. SANTANA: Okay. So now we're on 

8 section R402.5, which is also on page R33. And 

9 that deals with maximum fenestration U factors 

10 and solar heat gain coefficients.

11 Are you going to explain this one, Eric?

12 MR. LACEY: Yeah. I can explain this.

13 This is a kind of a tradeoff count that 

14 applies when you use one of the tradeoff options 

15 in the IECC. You built to the prescriptive path. 

16 You have to meet whatever the window requirements 

17 are that are specified.

18 But if you use the UA tradeoff path of 

19 the performance path, you can trade the windows 

20 up a certain amount, but it kind of draws a hard 

21 line. It says, "Okay, you can't put in terrible 

22 windows. As much as you trade off, you can't go 
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1 beyond these limits."

2 And so, this is one area, you know, at 

3 least when we were looking through the code, I 

4 thought, you know, if there's an area where I 

5 think we might be able to do a little better than 

6 the IECC, it would be in a tradeoff cap. Because 

7 based on what I saw from the fenestration 

8 offerings in the paper that Emanuel handed out, I 

9 think in most cases, you know, the manufacturers 

10 aren't going to bump up against these caps.

11 So what it says, basically, is that in 

12 the Northern two HUD climate zones, climate zone 

13 2 and 3, there is a cap on the amount of U factor 

14 tradeoff for the window. U factor, obviously, 

15 being the most important factor in those climate 

16 zones.

17 If the base requirement is at 32, then 

18 the 40 is -- still gives you quite a bit of 

19 tradeoff leeway there if you wanted to get the 

20 efficiency somewhere else still.

21 And then in the Southern two climate 

22 zones, climate zones 1 and 2, where there would 
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1 be an SHGC requirement, you know, if the SHGC is 

2 a 25 or a 33 or whatever we land on that, you 

3 know, a 40 would be the outer limit for 

4 tradeoffs.

5 And just to make sure, you know, the 

6 window, which is typically the weakest part of 

7 the law, isn't gobbling up tons of energy. So 

8 that's the idea here.

9 And again, you know, we could play with 

10 the numbers a little bit. But I thought this is 

11 an area where I think you could do better than 

12 the IECC. The IECC's tradeoff caps are pretty 

13 loose. And I don't think this would really 

14 impact the manufacturer all that much.

15 MR. RAMIREZ: Any questions?

16 David?

17 MR. TOMPOS: Are we basically saying that 

18 we're eliminating all the windows with a U value 

19 of 0.40 or higher?

20 MR. LACEY: No. It's an area weighted 

21 average. And so, if you put in a piece of 

22 decorative glass or something that, you know, is 
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1 higher than that, then on average your windows 

2 would need to be a 40 or lower on U factor.

3 MR. TOMPOS: But I wouldn't be able to 

4 put in vinyl framed clear dual glazing 

5 everywhere, because in here it says that the U 

6 value is 0.49.

7 MR. LACEY: That particular window, yeah. 

8 You'd need to use something better than that.

9 MR. TOMPOS: Okay. 

10 MR. LACEY: And in those two climate 

11 zones, that's climate zone 2 and 3 of the 

12 northern part of the country. See, there 

13 currently isn't a cap on climate zone 1. So if 

14 you wanted to put in the -- I wouldn't put them 

15 in, but if you put in the dual-pane clear in 

16 climate zone 1, so there's two parts to this. 

17 There's the U factor cap and the SHGC cap.

18 And the U factor cap doesn't apply to the 

19 southernmost climate zone. That's the way it is 

20 in the IECC. We could add that in there if you 

21 decided you wanted to have good windows in every 

22 climate zone, which I think would be a good idea. 
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1 But for now, climate zone 1 doesn't have that U 

2 factor limitation on it, on tradeoffs.

3 MR. SANTANA: So, you know, and again, 

4 this is a section -- well, this is one of the 

5 sections where we accepted it in principle. So 

6 we accepted the concept, you know. There's 

7 should be a cap. We like the idea for there to 

8 be a cap on the windows so if you choose a 

9 performance cap, where you calculate your -- say, 

10 your total U not for the house as a whole, you 

11 could have great insulation, horrible windows, 

12 and still pass, theoretically.

13 So this puts a cap on that. And the 

14 suggestion is that we accept it in principle, we 

15 accept the concept. But the language, the 

16 values, the zones, you know, we don't know if 

17 we're going to end up with a UA path or not. It 

18 might just be a prescriptive path and a U not --

19 we don't know. I mean, REScheck, we probably 

20 can't reference to REScheck. But, you know, 

21 conceptually, we thought it was a good idea.

22 MR. RAMIREZ: Mark?
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1 MR. TOMPOS: I think what's confusing me 

2 is that you've got, this is SHGC saying UA 

3 REScheck or UO. Is that the right language?

4 MR. LACEY: Yeah. The idea was, in the 

5 IECC, it applies to basically the UA path on the 

6 performance path. But I don't know if we're 

7 going to end up with a performance path or a UO 

8 or a REScheck option in the end.

9 So, all of those have, I think have or 

10 should have an SHGC requirement. And so that's 

11 kind of in there as a placeholder for, you know, 

12 this trade-up cap, applies wherever you have a 

13 tradeoff option, you know?

14 MR. UNGAR: But is there a tradeoff if 

15 you do a UA or a UO option? Is SHGC traded off? 

16 I thought I was hearing those.

17 MR. LACEY: In a straight-up UA or UO, 

18 no. I think that that's what we been talking 

19 about. Even the UO would have an SHGC 

20 requirement. Whether you can trade that off, I 

21 don't know. It will depend on what our final 

22 package looks like.
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1 (Cross-talk.)

2 MR. RAMIREZ: Let me get Mark, and then 

3 David.

4 MR. UNGAR: All right. If there is a 

5 tradeoff, then we would expand it?

6 MR. LACEY: Yeah.

7 MR. UNGAR: Yeah. It might be this, or 

8 no need for it.

9 MR. LACEY: We might not need it.

10 MR. UNGAR: Okay. 

11 MR. RAMIREZ: Mark, then David.

12 MR. WEISS: I don't know if it makes a 

13 question or just seemed to me like we have a lot 

14 here that's contingent. And maybe the thing to 

15 do with this is just table it until we can get 

16 some other, further development in these issues.

17 I don't know. Just, you're dependent on 

18 zones, you're dependent on, you know, what was 

19 the other thing? Anyway, dependent on a couple 

20 of things.

21 MR. RAMIREZ: David?

22 MR. TOMPOS: Well, I think zones really 
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1 are the only one, and we can expand that later if 

2 we decide we're going to have multiple zones.

3 Rob Luter, one of the windows 

4 manufacturers, was involved with this. And if he 

5 doesn't see a problem in supplying the industry, 

6 I have no problem going above the IECC.

7 MR. SANTANA: Well, he wasn't involved 

8 with this.

9 MR. LACEY: Rob wasn't on this particular 

10 call.

11 MR. SANTANA: Right.

12 MR. TOMPOS: Well, then, maybe we need to 

13 ask that question.

14 MR. LACEY: We generally got it, but --

15 (Cross-talk.)

16 MR. LACEY: But I don't know what you 

17 think --

18 MR. SANTANA: But if I can pull back a 

19 little bit, conceptually speaking, without 

20 worrying about the exact values and content, the 

21 concept, does that seem sound?

22 MR. RAMIREZ: Does the concept? The 
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1 question is, does the concept seem sound?

2 (Pause.)

3 (Cross-talk.)

4 MS. STARKEY: I'd like to know what Rob 

5 thinks, Rob Luter.

6 MR. LUTER: Yeah. If I understand this, 

7 what you're saying is that in the event you 

8 choose to use tradeoffs, in this case, better

9 insulation in exchange for lousy windows -- even 

10 though I don't make any lousy windows --

11 (Laughter.)

12 MR. LUTER: We'll use that argument, that 

13 you won't be able to use any windows with a U

14 value lousier than 0.40 in climate zone 2 through 

15 3. And I'm fine with that. This really doesn't 

16 present any issues.

17 I think that, if I recollect the values 

18 that we saw earlier, just going to a dual19 insulated window within a vinyl frame, even with 

20 clear glass, it's going to get us a little better 

21 than that. Perhaps not. Maybe it will take low22 E. But in those climate zones, it's probably 
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1 justified.

2 MR. RAMIREZ: So, either way, though, 

3 we're probably going to have to come back to this 

4 one because we have not yet identified the 

5 climate zones.

6 MR. HAGERMAN: Yeah, but you can do --

7 (Cross-talk.)

8 MALE VOICE: What would you suggest at 

9 that point, Javier?

10 MR. HAGERMAN: Joe Hagerman, DOE.

11 Even if we don't come up with, do we use 

12 the HUD climate zones or the other climate zones, 

13 they easily map. So let's go ahead and vote on 

14 this, conceptually, and then start putting some 

15 values. I mean, it's very easy to disentangle 

16 the climate zone, whichever decision the group 

17 ultimately decides.

18 MR. RAMIREZ: So is the group okay with 

19 this one? Let's see a show of thumbs.

20 (Pause.)

21 MR. RAMIREZ: Any thumbs down on the 

22 phone?
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1 All right. Then we have unanimous 

2 approval on that one.

3 MR. SANTANA: Should we add that it's 

4 conceptual?

5 MR. RAMIREZ: Yeah.

6 MR. SANTANA: To your approval.

7 MR. RAMIREZ: Yeah.

8 MR. LACEY: Once we get the compliance 

9 down.

10 MR. SANTANA: Okay. Next item on the 

11 agenda is the table.

12 MR. RAMIREZ: I'm sorry. We need 

13 compliance paths and zones.

14 MR. SANTANA: And values.

15 MR. RAMIREZ: And values.

16 (Pause.)

17 MR. RAMIREZ: But the formula is sound.

18 MR. SANTANA: Right.

19 MR. RAMIREZ: Okay.

20 (Pause.)

21 MR. SANTANA: So we're going to skip the 

22 table for now, just because I think we can double 
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1 back and take care of some of the easier ones 

2 first.

3 Section R403.1.2. That one's on page 

4 R35. And it is Heat Pump Supplementary Heat.

5 (Pause.)

6 MR. SANTANA: And you might want to open 

7 up the PDF.

8 (Pause.)

9 MR. SANTANA: Okay. We think this can go 

10 through as is. You know, we didn't have an issue 

11 with it.

12 MR. RAMIREZ: Any discussion on that one? 

13 Mark?

14 MR. WEISS: Is this representing this in 

15 practice?

16 MR. SANTANA: I don't know that it does, 

17 just because we don't purchase heat pumps, you 

18 know. Is this in practice? I don't know that it 

19 is. But I don't know that it's not.

20 MR. LUBLINER: I could provide some 

21 feedback. So what the problem is is that 

22 sometimes consumers will fiddle with their 
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1 thermostats. And like it will be in setback 

2 mode, and then all of a sudden, in the morning it 

3 will kick in to -- and instead of going into heat 

4 pump mode, it goes straight into electric 

5 resistance. So the heat pump is running like a 

6 furnace.

7 So that's what it was about. So that, 

8 yeah, to answer your question, yes, it's pretty 

9 standard in site-built that either the thermostat 

10 or the heat pump itself has a lock-out that keeps 

11 it from operating above a certain -- strip keeps 

12 it operating above a certain temperature.

13 Except if there's emergency heat need or 

14 if there's defrost. And what we find is that 

15 that's an incredibly cost-effective way of making 

16 your heat pump perform like a heat pump. Our 

17 utility programs can sanitize that, and our state 

18 code requires that lock-out in our setup 

19 inspections in heat pumps.

20 MR. WEISS: Okay. Yeah. And thank you. 

21 The question was, though, is it existing practice 

22 on HUD code homes at this point? I guess the 
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1 answer is we don't know at this point. So.

2 MR. SANTANA: Not sure.

3 MR. HAGERMAN: I think if you buy any 

4 modern heat pump, with emergency supplemental 

5 heat, it's going to have that, unless you just 

6 cobbled it together yourself.

7 (Laughter.)

8 MR. RAMIREZ: All right. So let me see a 

9 show of thumbs if we're okay with that 

10 recommendation.

11 (Pause.)

12 MR. RAMIREZ: All right. Any thumbs down 

13 on the phone?

14 All right. We have unanimous on that one 

15 as well.

16 MR. SANTANA: Okay. Section 403.3.3, on 

17 page R35, we pondered on this one as well, 

18 because it deals with duct testing. And that was 

19 going to be a -- we might have already handled 

20 that yesterday. But it was going to be dependent 

21 on, almost on the Emanuel proposal.

22 So then the suggestion is to strike that 
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1 and we'll fix it with whatever we come up with.

2 MR. WEISS: Say again, Manny? I'm sorry.

3 MR. SANTANA: That we deferred to the 

4 Emanuel proposal for that one.

5 MR. RAMIREZ: Is everyone okay with that? 

6 Let me see a show of thumbs.

7 (Pause.) 

8 MR. RAMIREZ: Okay. Any thumbs down?

9 (Pause.)

10 MR. RAMIREZ: All right. Then that one's 

11 unanimous. And that's unanimous on the 

12 recommendation.

13 All right. Next?

14 MR. SANTANA: Next up, 403.5.1, also on 

15 page R35, and it comes over to R36 a little bit, 

16 but it's on your screen. It deals with heated 

17 water circulation and temperature maintenance 

18 systems. So, for those of you that are concerned 

19 whether you're getting cold water in the shower, 

20 this is for you.

21 (Laughter.)

22 MR. RAMIREZ: This is the David section?
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1 MR. SANTANA: Yeah. You want to --

2 MR. TOMPOS: This is my proposal right 

3 here.

4 (Laughter.)

5 MR. SANTANA: So again, we didn't have an 

6 issue with it. We don't think that -- well, I 

7 don't think that there's a lot of manufactured 

8 homes using this feature. And if they are, they 

9 should probably adhere to this, you know.

10 MR. RAMIREZ: Mark?

11 MR. WEISS: The technical aspects of it 

12 are fine. But I'm just looking at this section, 

13 the line up from the bottom, it says, 

14 "Temperature sensors in the heat pump should be 

15 accessible." What does that mean? And I'm 

16 asking for a specific reason.

17 MR. RAMIREZ: Do you want to state the 

18 reason? That might help apply to the context.

19 MR. WEISS: Yeah. The reason is there is 

20 a whole separate area in standards and 

21 regulations of accessibility in terms of disabled 

22 persons. And sometimes, language like this is 
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1 seized on to mean something it's not necessarily 

2 intended to mean.

3 MR. RAMIREZ: Okay. Yes.

4 MR. WEISS: I assume this means 

5 accessible for repair, consumer, whatever.

6 MR. RAMIREZ: Yeah, accessible for 

7 repair. Yeah. Yeah, you don't --

8 MR. EZZO: Hey, Mark, this is Mark Ezzo.

9 Yeah, there is an actually a definition 

10 in the IECC that says "accessible," and it says, 

11 "admitting close approach as a result of not 

12 being guarded by locked doors, elevation, or 

13 other effective means."

14 MR. WEISS: Okay.

15 MR. EZZO: But I think what Manny is 

16 saying is right. It's just for -- it's for 

17 repair.

18 MR. WEISS: Okay. Okay, well, if there's 

19 a definition, I'll take a look at it and I'll get 

20 back to you on it.

21 MR. RAMIREZ: Okay. As far as accepting 

22 the recommendation --
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1 MR. SANTANA: Well, we can't just accept 

2 it as is, because it encompasses the next two 

3 sections as well.

4 MR. RAMIREZ: Okay. So let's hear the 

5 next two then.

6 MR. SANTANA: Well, the next two, we 

7 didn't have any recommendations for those either 

8 other than to accept them as they were. So 

9 they're part of the same system, a system that 

10 isn't in great use. We didn't have a problem 

11 with it.

12 MR. RAMIREZ: So, the recommendation is 

13 to accept as is 403.5.1, 403.5.1.1, and 

14 403.5.1.2.

15 MR. SANTANA: Correct.

16 MR. RAMIREZ: Let me see a show of thumbs 

17 if the working group is okay with that 

18 recommendation.

19 (Pause.) 

20 MR. RAMIREZ: Okay. Anyone with their 

21 thumbs down on the phone?

22 (Pause.)
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1 MR. RAMIREZ: All right. Then that one 

2 is unanimous as well.

3 MR. RAMIREZ: Okay. What else, Manny?

4 MR. SANTANA: Okay. So now we're going 

5 to jump over to section R404.1.1. That's on page 

6 R37.

7 (Pause.)

8 MR. SANTANA: This has to do -- this is 

9 Lighting Equipment. I guess I thought it was 

10 just lighting equipment for a pilot light for, 

11 say, a water heater. But I guess it also applies 

12 to if you have gas lamps in your house, or gas 

13 lights in your house. You can't have a pilot 

14 light that burns all day long. You've got to 

15 have another kind of ignition system.

16 MR. ROY: Fortunate to keep the horse 

17 warm.

18 (Laughter.)

19 MR. SANTANA: Yeah. Exactly.

20 MR. UNGAR: This is only for new homes. 

21 If you have any heat lights in this century in

22 manufactured homes.
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1 MR. SANTANA: Then you're okay. You're 

2 exempt. If you're a forward-thinking individual 

3 with gas lights, this is what you have to do.

4 (Cross-talk.)

5 MR. SANTANA: So anyway, yeah. We're 

6 proposing that it be adopted as is.

7 MR. RAMIREZ: Okay. Questions?

8 All right. Let's see a show of thumbs if 

9 you're okay with that recommendation.

10 (Pause.)

11 MR. RAMIREZ: Anyone on the phone with 

12 your thumbs down?

13 (Pause.)

14 MR. RAMIREZ: And the steamroller is 

15 sparking up. I didn't see any thumbs down. So 

16 we're good.

17 All right. Now what?

18 MR. SANTANA: Okay. So now I think the 

19 steamroller is going to come to a halt for a 

20 minute.

21 (Laughter.)

22 MR. SANTANA: We're going back to table 
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1 402.4.1.1.

2 MR. RAMIREZ: Okay. 

3 MR. SANTANA: And this table is the air 

4 barrier and insulation installation table. And 

5 it has a lot of provisions to it. And the 

6 majority of the provisions are because we believe 

7 the element wasn't written with manufactured 

8 housing in mind, you know, because of the 

9 different construction practices.

10 So the first one is, when you get to 

11 walls -- and this again, it's in the strike and 

12 underline format. So anything that has a strike13 through is currently part of the IECC, and we're 

14 suggesting that it be removed. Anything that's 

15 underlined is an addition. So it's currently not 

16 part of the IECC.

17 So looking at walls, the first line is a 

18 strike-through that reads, "The junction of the 

19 foundation sill plate shall be sealed." And the 

20 reason why we're suggesting that removed is 

21 because the -- in manufactured housing, every 

22 manufactured house has a floor, whereas this was 
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1 written with the intention that your sill plate, 

2 or the first piece of wood that sits on the 

3 foundation of the slab, constitutes the bottom of 

4 a wall.

5 So they seal that, whereas in 

6 manufactured housing, the interface you're 

7 concerned with is the bottom of the wall and the 

8 top of the floor.

9 And the next line is for the top of the 

10 wall and the bottom of the ceiling. You know, 

11 there aren't any walls per se, and so then we 

12 added, "The junction of the bottom plate and the 

13 floor along the exterior walls shall be sealed" 

14 just because we wanted to capture what the 

15 junction of the foundation and the sill plate was 

16 trying to convey.

17 So, in essence, we're requiring that the 

18 bottom of the wall where it meets the floor be 

19 sealed and the top of the wall where it meets the 

20 ceiling be sealed.

21 MR. RAMIREZ: I hope that's the 

22 controversial part.
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1 MR. SANTANA: No. No, that's --

2 MR. RAMIREZ: It doesn't sound too bad.

3 (Laughter.)

4 MR. SANTANA: I'm going to keep going 

5 unless somebody pipes up.

6 MR. RAMIREZ: Okay.

7 MR. WEISS: So that's existing practice?

8 MR. SANTANA: No. No, it's not existing 

9 practice. I wouldn't say it's existing practice, 

10 because the HUD code currently says that you have 

11 all your joints designed to resist air 

12 infiltration. It doesn't say you have to seal 

13 them.

14 MR. WEISS: Okay. So it's construction 

15 versus performance?

16 MR. SANTANA: Right. Performance. And 

17 so, say you could have a joint where you overlap 

18 the siding, and some people may say, "Well, that 

19 restricts air infiltration." But it's not 

20 sealed.

21 MR. WEISS: Thank you.

22 MR. RAMIREZ: Okay. 
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1 MR. SANTANA: Okay. So, over to the 

2 right, "Cavities within the stud bay called by 

3 blocking" -- you know, I'll read what the IECC 

4 first said. "Cavities within corners and headers 

5 a frame walls shall be insulated by completely 

6 fitting the cavity with a material having a 

7 thermal resistance of R3."

8 And the reason for that is, in stick9 built conventional construction, the corners have 

10 a lay-flat, or they have a stud which is faced 

11 the other way so they can be fastened to the wall 

12 that runs on the other plane. So we call those 

13 lay-flats in the industry.

14 So what they're trying to get at is 

15 they're trying to make sure that where you have 

16 less depth than the entire stud bay, you fill 

17 that. Or to give you another scenario, where you 

18 have -- in stick-built construction, your headers 

19 may not have, they may not be the same depth or 

20 the same thickness as the wall.

21 In conventional manufactured 

22 constructions, manufacturers add shims in between 
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1 the headers to make the depth the same, or the 

2 thickness the same, whereas in stick-built, you 

3 could have a gap.

4 You know, so the recommended language 

5 here just makes it a little bit clearer as to 

6 what cavities we're talking about. So it reads, 

7 "Cavities within a stud bay caused by blocking 

8 lay-flats or headers of exterior walls shall be 

9 insulated by completely filling the cavity with 

10 a" -- so it essentially gives you the same thing, 

11 only we believe it does it in a way where it's 

12 easier to understand.

13 (Pause.)

14 MR. SANTANA: All right. Moving on, the 

15 one underneath that -- scroll up a little bit --

16 read, "Exterior thermal envelope insulation for 

17 framed walls shall be installed in substantial 

18 contact in continuous alignment with the air 

19 barrier." And that's where we touched on that 

20 earlier.

21 The subcommittee thought it was a good 

22 idea to strike that, because most two-by -- well, 
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1 most stud bays are filled with insulation anyway. 

2 And the whole substantial contact with continuous 

3 alignment of the air barrier, you know, as we all 

4 heard earlier today, some people say the air 

5 barrier's on the outside, air barrier's on the 

6 inside.

7 You know, we didn't see the benefit to 

8 adding to that confusion. And I don't want to 

9 speak for anybody.

10 Go ahead, Mike.

11 MR. LUBLINER: I just want to make it 

12 clear, because I have seen two-by-six walls in 

13 the Northwest starting to show up with R11 in the 

14 walls. Do you -- and I don't personally believe 

15 that the FTC reading is valid for that, when you 

16 have a big air gap like that, particularly if 

17 you're not caulking things that we said, you 

18 know, to caulk, depending on the air barrier.

19 So, my question would be, if we eliminate 

20 this, are we allowing a manufacturer to continue 

21 to do that? Build a two-by-six wall and put R11 

22 in it so that there's a big gap in the wall, so 
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1 that you don't have -- you haven't filled it?

2 I don't know if it applies here, but I 

3 thought it may. And so I wanted to ask you for 

4 your kind of clarification.

5 MR. SANTANA: I think that you could have 

6 that in a scenario where you have a two-by-six 

7 wall with R11.

8 MR. LUBLINER: You know, don't ask me why 

9 they do it, Mark.

10 (Laughter.)

11 MR. WEISS: Why would anybody do that?

12 MR. LUBLINER: They're doing it.

13 MR. SANTANA: You know, you've got 

14 requirements to seal penetrations, you know, in 

15 the air barrier that it had before.

16 MR. LUBLINER: So, I guess my concern is 

17 that I don't think that's a very cost-effective 

18 thing to do. If you're going to frame out the 

19 wall, you might as well fill it. And I want to 

20 make sure that excluding this doesn't continue to 

21 allow that to happen.

22 MR. LACEY: I'm not sure that this 
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1 specific requirement would fix that scenario. 

2 But maybe we can have something in there if you 

3 think that's important to fill the cavity. This 

4 one, I think, just addresses the issue --

5 MR. LUBLINER: At least the walls. Have 

6 you seen any of that in preapproved?

7 MR. TOMPOS: I have not seen that. If 

8 they do the six-inch wall, they're putting in at 

9 least an R19.

10 (Cross-talk.)

11 MR. LUBLINER: I mean, I was really 

12 surprised when I saw it show up in Idaho.

13 MR. TOMPOS: I mean, the question again 

14 comes to, where's the air barrier?

15 MR. WEISS: Large fries at McDonald's; is 

16 this size back?

17 (Laughter.)

18 MR. LUBLINER: Right. I just say hello 

19 to MoneyBites. If you still meet the minimum UO.

20 MR. RAMIREZ: So, how would that have to 

21 be modified in order to take care of that?

22 MR. LUBLINER: If you leave it in --
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1 MR. RAMIREZ: David?

2 MR. TOMPOS: I think with the additional 

3 R values that we're going to require, I don't 

4 think they're going to be able to do it.

5 MR. RAMIREZ: Okay. 

6 MR. TOMPOS: I mean, I guess you could 

7 have a situation in the South where you'd have a 

8 six-inch wall and still put in an R11. I just, I 

9 don't know why anybody would do that.

10 MR. HAGERMAN: It says up there right 

11 now, "Walls shall be insulated by completely 

12 filling the cavity."

13 MR. SANTANA: Right. But these are 

14 cavities caused by blocking or headers or 

15 something else, corners. It isn't saying all 

16 cavities.

17 MR. HAGERMAN: Why don't we just repeat 

18 that? Why don't we just say "All cavities shall 

19 be insulated completely"? "Cavities within a 

20 stud bay," blah-blah-blah.

21 MR. SANTANA: You know, and they can 

22 occur -- okay, if you're in the South or you're 
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1 in a high-winds area, you could -- you know, that 

2 may necessitate two-by-six framing, right? But 

3 not necessarily necessitate anything greater than 

4 R11 insulation.

5 You know, so the question is, do we want 

6 to have R19 insulation be mandated even if the 

7 climate zone doesn't require it?

8 MR. LUBLINER: So you're saying that 

9 people will build the two-by-six wall in Southern 

10 zones where there's -- because they get better 

11 structural integrity out of the wall?

12 MR. SANTANA: Yeah. Because of the wind 

13 zone.

14 MR. LUBLINER: Okay. That's good to 

15 note.

16 My feeling is if you built the two-by-six 

17 wall, as long as the WUfi model shows it's 

18 acceptable in the hot, humid climates -- because 

19 what I would want to do is make sure that hot, 

20 humid air can't get into that gap and get right 

21 behind the vinyl drywall and condense when the 

22 air conditioner is on.
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1 MR. SANTANA: You know, the problem that 

2 I have with substantial contact and continuously 

3 with the air barrier is, how do you -- you know, 

4 these things are going to go down the road 

5 hundreds of miles, right, through bumps and wind 

6 and, you know, who-knows-what else.

7 So, how do you then prove that the thing 

8 is in substantial contact when it arrives? If 

9 somebody opens up a hole in the wall to see if 

10 that's in substantial contact after going 1,000 

11 miles and it isn't, what happens?

12 You know, and so taking that into 

13 consideration, how important is it to have 

14 substantial contact with it continuously?

15 MR. LUBLINER: I think the ENERGY STAR 

16 program requires it. But I mean, like I said, if 

17 it's a moisture reason and it's hot, then I was 

18 responding to your point. And it's interesting 

19 to note that, you know, there's actually 

20 structural benefit in the high-wind zones.

21 MR. SANTANA: Yeah. And the thing to 

22 state my concerns in a more general fashion is, I 
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1 am generally against having requirements that you 

2 can't verify or that it's hard to -- you know, 

3 it's going to be hard to verify and prove that 

4 it's so. It's going to be a perpetual issue. 

5 You can't prove that it's in a substantial 

6 contact.

7 MR. LUBLINER: Yeah. Generally, what we 

8 do is a blower test with an infrared scan. And 

9 it would show up if it's a question. Now, open 

10 up the cavity and see if it's true.

11 MR. SANTANA: See, I don't want to do 

12 that.

13 (Laughter.)

14 MR. RAMIREZ: David?

15 MR. TOMPOS: Manny, you talked about the 

16 cost, reducing the SKU numbers in a manufacturing 

17 plant.

18 Wouldn't you -- typically you're going to 

19 be -- well, maybe all of the homes that you build 

20 are, I would assume that you've got some two-by21 fours and two-by-sixes. Are you going to have to 

22 all go to two-by-sixes and then put in R21 in all 
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1 of the walls?

2 I don't see the advantage. I guess what 

3 I'm saying is, why wouldn't we want to fill the 

4 cavity? Can't you just put less insulation in 

5 the roof cavity?

6 MR. SANTANA: You could.

7 MR. TOMPOS: So it may solve some 

8 transportation problems.

9 MR. SANTANA: I mean, so that's a good 

10 question to ask. You know, on the one hand, 

11 somebody could comply with R11 in the walls. You 

12 know, the two-by-sixes is required by another 

13 unrelated issue, right?

14 So what we're asking is if, do they have 

15 to fill the cavity just to maintain the 

16 substantial contact? You know, what is the 

17 benefit versus the cost? I'm not saying -- I 

18 know manufacturers do. So the question is, do we 

19 have enough reasons to tell them they can't do 

20 that anymore? You know, if the unit --

21 MR. EZZO: Hey, Manny, it's Mark.

22 MR. SANTANA: Yeah.
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1 MR. EZZO: Would it be better to say 

2 "Exterior thermal envelope insulation shall 

3 completely fill the cavity," period? And forget 

4 about mentioning "substantial contact"?

5 MR. SANTANA: You could say that. You 

6 could say that. But then you're still -- you 

7 know, as long as we recognize that we're going to 

8 be requiring R19 in anything built with two-by9 six walls. And as long as that's what we 

10 understand we're doing --

11 MR. HAGERMAN: As long as the 

12 manufacturers take that into account when they do 

13 their UO calculation, right?

14 MR. SANTANA: Yeah.

15 MR. LACEY: Get credit for it.

16 MR. HAGERMAN: And they'll get credit for 

17 it, so you won't have to put it so much -- I 

18 mean, the end cost to the consumer is probably a 

19 wash.

20 MR. SANTANA: How do you mean that?

21 MR. HAGERMAN: Meaning because you could 

22 reduce the insulation that's in the ceiling, 
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1 right?

2 MR. SANTANA: Oh, okay.

3 MR. HAGERMAN: I mean, net out, you're 

4 not buying more insulation because of that 

5 requirement, right?

6 MR. SANTANA: Maybe. Maybe not.

7 MR. RAMIREZ: Mark, can you repeat the 

8 change there?

9 MR. EZZO: Yeah. Where the red font has 

10 all the strike-through where it starts to say, 

11 "Exterior thermal envelope insulation for framed 

12 walls"?

13 MR. RAMIREZ: Yeah.

14 MR. EZZO: Take out "in substantial 

15 contact and continuous alignment with the air 

16 barrier," and insert -- let's see, "Exterior 

17 thermal envelope insulation for framed walls 

18 shall completely fill the cavity."

19 MR. SANTANA: You know, wouldn't it be 

20 easier -- this is Manny with Cavco.

21 Wouldn't it be easier to just eliminate 

22 all of that and say, "Exterior walls shall have 
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1 the cavities filled with insulation"?

2 MR. HAGERMAN: No. "Shall completely 

3 fill the cavity."

4 MR. SANTANA: I mean, why? We're worried 

5 about the blocks and the lay-flats and the 

6 headers.

7 MR. LACEY: I do think there -- if I 

8 could throw something in there. The reason why 

9 this language was added was because it wasn't 

10 getting filled. They were filling the cavity, 

11 but not the header.

12 And so, would it be okay to add -- you 

13 know, to leave that language that you've got in 

14 the bottom there. I think that covers most of 

15 it. But to say, "including within stud bays 

16 caused by blocking lay-flats or headers," or 

17 something like that? Or including -- just so 

18 that those sections are not being left out.

19 Because that was a problem. Everybody 

20 understood that the stud cavity needed to be 

21 filled. Nobody understood that it included that 

22 little section at the top.
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1 MR. SANTANA: So then, you do that and 

2 then strike everything above it?

3 MR. LACEY: Right. Yes.

4 MR. RAMIREZ: Mark?

5 MR. WEISS: This is for Eric. And I hope 

6 I'm framing this right.

7 Don't other provisions of the IECC 

8 already address what you have to put in the 

9 exterior walls or framing walls?

10 MR. LACEY: There are requirements for 

11 how much insulation you put in, generally.

12 MR. WEISS: Right.

13 MR. LACEY: But if you get in a tradeoff 

14 scenario, you may not be filling that whole 

15 cavity, and then you run into other issues. So 

16 this just says --

17 MR. WEISS: Does that undermine the 

18 tradeoff?

19 MR. LACEY: What's that?

20 MR. WEISS: Does this undermine the 

21 tradeoff in some way?

22 MR. LACEY: No.
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1 MR. TOMPOS: No. You can take --

2 MR. LACEY: Because you get full credit 

3 for whatever is in the wall.

4 MR. SANTANA: It will undermine the 

5 tradeoff with walls, because now you can't trade 

6 off the walls. You have to fill it to capacity.

7 MR. WEISS: So, isn't that a problem?

8 MR. LACEY: If your wall is already 

9 required to be six inches thick for requirements 

10 outside the energy code, you're kind of stuck 

11 with that.

12 And I think what we're saying here is, if 

13 it's already going to be that much thicker, fill 

14 that with insulation. And then you can take the 

15 insulation from somewhere else. You don't have 

16 to put as much in in the attic, for example.

17 So I tend to agree that it's probably a 

18 net wash to the consumer.

19 MR. HAGERMAN: But this is good building 

20 science.

21 MR. KESSLER: This is Bert, Palm Harbor. 

22 MR. RAMIREZ: Yes.
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1 MR. KESSLER: Have you guys thought about 

2 if somebody, if a manufacturer decided to use 

3 spray foam? Now we're making -- we're forcing 

4 the manufacturer to completely fill that cavity 

5 with spray foam?

6 MS. DICKENS: Good point. No.

7 (Chorus of "No.")

8 MR. KESSLER: I don't think that was the 

9 intent. I think the way this was written 

10 originally, as Manny had it, was just fine. And 

11 keep in mind, too, that the requirements for that 

12 insulation to be in substantial contact with the 

13 air barrier is to prevent air movement or air 

14 flow. So, that's why that's there.

15 If you keep an air space between the air 

16 barrier and the insulation, and the insulation is 

17 air permeable, you get air flow. And that's what 

18 you're trying to prevent by keeping it in 

19 substantial contact with the air barrier.

20 MR. RAMIREZ: David?

21 MR. TOMPOS: Okay. Bert is making a 

22 really good point. Can we say something about 
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1 the type of insulation? Because I think it's bad 

2 building practice to not fill it if we're using a 

3 batt or a type of insulation that will allow 

4 convection of the air in there.

5 So, but he's right. If we use a closed 

6 cell foam, we shouldn't have to do this.

7 MR. RAMIREZ: So do we need a separate 

8 line for foam insulation?

9 MR. LUBLINER: Just do an exception for 

10 closed-cell foam.

11 Is it closed-cell foam, or are there 

12 other -- are you talking about just closed-cell, 

13 Bert?

14 MR. KESSLER: No. I'm talking about any 

15 foam.

16 MR. LUBLINER: So, let's just say 

17 exception for foam.

18 MR. WEISS: Why don't we just go back to 

19 what we had?

20 MR. KESSLER: I don't think we need to 

21 have an exception. Why can't I -- and the reason 

22 for using some two-by-six construction with R11 
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1 and R13 insulation is because the green building 

2 is getting more and more popular.

3 Manny mentioned the fact that in high4 wind areas you might be able to get by with two5 by-sixes at 24 on center, versus the, you know, 

6 16. Or, you know, even double two-by-fours, 

7 which some people are doing. And you should not 

8 be limited by the code to not be able to do that.

9 MS. DICKENS: That's a good point.

10 MR. KESSLER: Install the insulation 

11 correctly, and as it's supposed to, and there's 

12 no problem.

13 MR. LUBLINER: I wouldn't disagree with 

14 being -- I don't want to -- my recommendation was 

15 focused on non-foam insulation products. I 

16 totally agree. If there's -- I don't want to 

17 limit your ability to put foam in there if it's

18 going to provide the listed R value.

19 No, I think that's good. And that's why 

20 I proposed the exception. But I'm not 

21 comfortable with a two-by-six wall where there's 

22 five of us in there, if the testing for that R 
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1 value has been based on a two-by-four wall.

2 Maybe we should just get some 

3 clarification from the FTC or the manufacturers 

4 of the batt insulation as to whether they accept 

5 stating that R values are -- to get some clarity 

6 as to whether they feel that their R value 

7 represented is consistent when it's in a two-by8 six cavity with a two-inch gap.

9 And if they say that's okay, then I'm 

10 okay with it. But I know that when I do infrared 

11 scans, you can tell it's an R11 wall.

12 MR. HAGERMAN: This is Joe Hagerman, DOE.

13 MR. LUBLINER: And this is a minor 

14 detail.

15 MR. HAGERMAN: It is a minor detail. But 

16 what is wrong with just having the exception for 

17 spray foam insulations? Seems like that 

18 addresses the concern and then --

19 (Cross-talk.)

20 MR. LACEY: Can you just say what the 

21 exception --

22 MR. SANTANA: What if something new comes 
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1 up?

2 MR. HAGERMAN: Yeah. Exactly.

3 MR. SANTANA: Foam -- I don't know.

4 MR. LACEY: Could you just say instead, 

5 at the beginning of the suggestion, "air 

6 permeable exterior thermal envelope insulation"?

7 MR. HAGERMAN: You can do that.

8 MR. LACEY: I'd be concerned with adding 

9 in a word like "exception." What are you 

10 excepting them from?

11 MR. SANTANA: Okay. 

12 MR. LUBLINER: That's fine. That's fine. 

13 That's fine.

14 Fiberglass batts, or --

15 MR. LACEY: It's not everything.

16 MR. LUBLINER: Air permeable, that's 

17 fine.

18 (Pause.) 

19 MR. LUBLINER: You know, this is a small 

20 percentage of the homes. So maybe we need to 

21 move on on this one and do the investigation with 

22 the window -- I mean, with the insulation 
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1 manufacturers?

2 (Cross-talk.)

3 MR. RAMIREZ: Mark.

4 MR. WEISS: Just again, I'm more 

5 comfortable with the original suggestion from the 

6 committee. Anytime you put an exception into a 

7 regulation or something, again it becomes an 

8 invitation for problems.

9 And the more narrow you make that 

10 exception, as Manny just said, the more you're 

11 limiting that technological advancement and, you 

12 know, different methods that could satisfy the 

13 requirement and potentially lower costs. It 

14 constrains innovation.

15 MR. RAMIREZ: I think the suggestion that 

16 Eric just had addresses those concerns you just 

17 brought up by saying that "air permeable exterior 

18 thermal envelope," right?

19 MR. LACEY: That's right.

20 MR. WEISS: To me, that sounded narrower. 

21 But that could be right.

22 MS. DICKENS: So, I just came up with a 
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1 phrase that connect the two so we don't have to 

2 choose one or the other. So, at the end of the 

3 first -- the black, three per inch minimum, just 

4 say, "bearing in mind that air permeable exterior 

5 thermal envelope insulation for framed walls 

6 shall completely fill the cavity." So you can 

7 just connect them both, and we can have the whole 

8 combined sentence.

9 Does that work for people?

10 MR. WEISS: No.

11 (Cross-talk.)

12 MR. KESSLER: This is Bert. I just --

13 I'm Bert.

14 MR. RAMIREZ: Who is on the line?

15 MR. KESSLER: Bert.

16 Yeah, I was just going to mention the 

17 fact that when the insulation is air permeable, 

18 it doesn't matter whether it's filling the cavity 

19 or not. If you're putting something on the 

20 exterior surface that's also air permeable, then 

21 in fact it would probably be better if you did 

22 have a bit of air space.
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1 But again, I think we need to look at the 

2 thermodynamics and see what happens when we do 

3 this. And as far as the R value is concerned 

4 that is certified, we all calculate the U for the 

5 framing members separately. But whether it's 

6 full depth of the framing or not, the R value is 

7 not affected by it.

8 MR. RAMIREZ: All right. So, what do you 

9 all want to do? Do you want to gauge the level 

10 of consensus on that suggestion there and see 

11 where we're at as far as consensus or not?

12 Let's try that. The part that's 

13 highlighted, and you need to move it a little. 

14 There you go. Give you a second to read that, 

15 and then I'm going to ask for where you're at.

16 (Pause.)

17 MR. RAMIREZ: Okay. Are you okay with 

18 that verbiage? Let's see a show of thumbs.

19 (Pause.)

20 MR. RAMIREZ: Okay. And then anyone on 

21 line thumbs down?

22 MR. KESSLER: A no vote for me. This is 
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1 Bert.

2 MR. RAMIREZ: Okay. Then, we'll note 

3 that Bert was a no. And then the rest of the 

4 committee was okay. And okay, either thumbs up 

5 or sideways, right?

6 (Pause.)

7 MR. SANTANA: So, all the stuff above 

8 that is kaput, right?

9 MR. RAMIREZ: Correct. It's just the 

10 part that was shaded. That's the way I 

11 understand that.

12 So, we'll strike that right now.

13 (Pause.)

14 MR. RAMIREZ: Okay. 

15 MR. SANTANA: Okay. Should we vote on 

16 the other part of the wall section?

17 MR. RAMIREZ: On the air barrier 

18 criteria?

19 MR. SANTANA: Yeah.

20 MR. RAMIREZ: All right. So, left of 

21 what we just approved, how does that look to 

22 everyone? Is everyone okay with that? Let me 
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1 see a show of thumbs if you're okay with that 

2 part.

3 (Pause.)

4 MR. RAMIREZ: Okay. Michael, I saw your 

5 thumb down. Do you want to comment on that?

6 MR. LUBLINER: No. I guess I'm okay with 

7 that. I'm going to do one of these.

8 MR. RAMIREZ: Sideways. Okay.

9 Is anyone on the phone thumbs down on 

10 that section?

11 (Pause.)

12 MR. RAMIREZ: All right. Then that one 

13 is unanimous.

14 And I thought we were going to go through 

15 all of these, and I think we are. But I don't 

16 think we talked about the first two general 

17 requirements.

18 MR. SANTANA: Okay. Right. We didn't 

19 have any changes to the first two.

20 MR. RAMIREZ: All right. So, are those 

21 okay to keep as is then? Let me see a show of 

22 thumbs if you're okay with keeping those as is.
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1 (Pause.)

2 MR. RAMIREZ: Joe, you have a question?

3 MR. HAGERMAN: I just have a question. 

4 Do you have somewhere in here that the -- and 

5 this could be completely obvious, that the 

6 insulation has to be installed per the insulation 

7 manufacturer's recommendations?

8 MR. LUBLINER: I think HUD code requires 

9 that.

10 Does it, Rick?

11 MR. MENDLEN: Um-hm. I don't think 

12 there's anything specific about that.

13 MR. RAMIREZ: I'm sorry?

14 MR. MENDLEN: I don't think there's 

15 anything specific about that below a 12.

16 (Inaudible conversation.)

17 MR. SANTANA: Well, all manufacturers 

18 usually have it. I mean, in general, the HUD 

19 code requires all manufacturers' insulation 

20 instructions to be --

21 MALE VOICE: Exactly.

22 MR. HAGERMAN: Because I think that some 
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1 of these issues are going to be taken care of by 

2 the insulation installation instructions.

3 MR. SANTANA: Yes. 

4 MR. LACEY: And we actually approved that 

5 language earlier today at R402.4.1.1. It says,

6 "The components of the building or model shall be 

7 installed according to the manufacturer's 

8 instructions and this criteria."

9 MR. HAGERMAN: And this criteria.

10 MR. LACEY: Yeah.

11 MR. HAGERMAN: All right. Thank you. 

12 Sorry. I must have missed that one.

13 MR. RAMIREZ: You approved it; don't 

14 worry about it.

15 MR. LUBLINER: It's a very important 

16 issue.

17 MR. RAMIREZ: All right. So then, was 

18 there anyone on the phone that was objectionable 

19 to those first two as far as general requirements 

20 in ceiling-slash-attic?

21 (Pause.)

22 MR. RAMIREZ: Okay. Then those two are 
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1 unanimously as is.

2 All right. So, and then I see windows, 

3 skylights, and doors, and rim joists. Those are 

4 as is as well?

5 MR. SANTANA: Right. We have made them 

6 trilogies.

7 MR. RAMIREZ: Any questions or concerns 

8 with that one?

9 (Pause.)

10 MR. RAMIREZ: All right. Let me see a 

11 show of thumbs if we're okay with keeping those 

12 as is.

13 (Pause.)

14 MR. RAMIREZ: Any objections on the 

15 phone?

16 (Pause.)

17 MR. RAMIREZ: Okay. Those are good.

18 All right. This one would take some 

19 explaining, on floors.

20 MR. SANTANA: Okay. On floors, yes. So, 

21 floors, the component includes including above 

22 garage and cantilevered floors. And so we just 
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1 struck that because this applies to all floor 

2 models.

3 I don't know if you want to vote on that 

4 or not.

5 MR. RAMIREZ: Yeah. Any questions on 

6 that one?

7 (Pause.)

8 MR. RAMIREZ: Let me see a show of thumbs 

9 if you're okay with the recommendation.

10 (Pause.)

11 MR. RAMIREZ: Any thumbs down on the 

12 phone?

13 (Pause.)

14 MR. RAMIREZ: All right. That's 

15 unanimous as well.

16 MR. SANTANA: You know, and I'd like to 

17 skip floors for now, because other ones are easy.

18 (Laughter.)

19 MR. SANTANA: If you don't mind. So I 

20 can go down to crawl space walls. 

21 Crawl space walls, we struck the whole 

22 thing because they don't apply to -- you know, 
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1 it's outside the scope of manufactured homes 

2 construction. We just struck the entire line, 

3 the entire row.

4 Do you want to have a vote on that?

5 MR. RAMIREZ: For crawl space walls?

6 MR. SANTANA: Yeah.

7 MR. RAMIREZ: Let's see s show of thumbs 

8 if you're okay with the elimination of that one.

9 (Pause.)

10 MR. RAMIREZ: Okay. Anyone on the phone 

11 objectionable?

12 Okay. That one's unanimous.

13 MR. SANTANA: Okay. Shafts and 

14 penetrations. The air barrier criteria. It 

15 originally read, "Duct shafts, utility 

16 penetrations, and flue shafts opening to exterior 

17 or unconditioned space shall be sealed." And we 

18 thought it was easier to just say, "Duct shafts, 

19 utility penetrations, and flue shafts that 

20 penetrate the air barrier shall be sealed."

21 And I think that's consistent with what 

22 we said earlier today about sealing penetration.
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1 MR. RAMIREZ: Mark?

2 MR. WEISS: Is that current practice, 

3 Manny, or is that something that is new here?

4 MR. SANTANA: It's new. It would be new, 

5 yeah.

6 MR. RAMIREZ: All right. Let's see a 

7 show of thumbs if you're okay with the 

8 recommendation.

9 (Pause.)

10 MR. HAGERMAN: Joe Hagerman, DOE.

11 It's new, but we do take into account in 

12 the life cycle costs per our earlier discussions.

13 MR. SANTANA: Yeah, we're considering it. 

14 Yeah, it's in the costs, yeah.

15 MR. RAMIREZ: Okay. And then, anyone on 

16 the phone with a thumbs down?

17 (Pause.)

18 MR. RAMIREZ: Okay. That's unanimous as 

19 well.

20 MR. SANTANA: Okay. The following items, 

21 narrow cavities, we didn't have any issues with 

22 it.
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1 MR. RAMIREZ: So, as is?

2 MR. SANTANA: As is.

3 MR. RAMIREZ: I'll give folks a second to 

4 take a look at that.

5 (Pause.)

6 MR. RAMIREZ: Yeah?

7 MR. TOMPOS: Question. Manny, help me. 

8 Is that saying -- let's say we have a panel box 

9 on the exterior wall -- that we don't need to 

10 meet the full depth of insulation?

11 Okay. I have what's covered in the HUD 

12 code under thermal shorts.

13 MR. SANTANA: Okay. I think that would, 

14 that's for if you have an offset stud in a wall, 

15 you have, say, maybe a six-inch cavity, you can't 

16 get your batting to stuff it in there. You know? 

17 You can't just fold it over and stuff it in there 

18 however you want. You have to cut it to fit the 

19 width and place it.

20 (Pause.)

21 MR. SANTANA: Correct me if I'm wrong, 

22 anybody.
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1 MR. LACEY: Yeah.

2 MR. HAGERMAN: Joe Hagerman, DOE.

3 If it would help, maybe you say "narrow 

4 width cavities."

5 MR. TOMPOS: No, that's fine. I can live 

6 with that.

7 MR. SANTANA: It's a little repetitive.

8 MR. HAGERMAN: Right. Yes. 

9 MR. SANTANA: Because you go up to the 

10 wall section where it says you need to fill 

11 everything.

12 MR. HAGERMAN: Right.

13 MR. SANTANA: You know, this one just 

14 gives you more -- you know, it's a little 

15 repetitive.

16 MR. TOMPOS: It's repetitive. It says I 

17 can't shove it in there; I've got to cut it.

18 MR. SANTANA: You've got to cut it.

19 MR. TOMPOS: So I don't have any gaps in 

20 there.

21 MR. HAGERMAN: You weren't doing that 

22 anyway, though, right?
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1 MR. TOMPOS: No. We cut everything. It 

2 fits perfectly.

3 (Laughter.)

4 MR. RAMIREZ: Mark.

5 MR. WEISS: Manny or somebody, give me a 

6 read on what "readily conforms" means.

7 MR. TOMPOS: Yeah, that held me up, too. 

8 That's strange language.

9 MR. SANTANA: Okay. The way that I 

10 understand it is, you know, okay, so everybody --

11 "Batting in narrow cavities shall be cut to fit, 

12 or narrow cavities shall be filled by insulation 

13 that, on installation, readily confirms to the 

14 available cavity space."

15 You know, so you either cut the batt to 

16 fit it, or if say you don't have a batt, you're 

17 going in your wall, by the time it's installed 

18 it's going to conform to the space. You know? 

19 If you're using blown or foam.

20 MR. HAGERMAN: You could say "readily 

21 fills the available cavity space."

22 MR. SANTANA: Yeah.
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1 MR. WEISS: You don't want stuff hanging 

2 out.

3 (Cross-talk.)

4 MR. TOMPOS: You don't want air gaps.

5 MR. WEISS: Exactly. Corners you're 

6 trying to avoid. And if there are problems --

7 MR. RAMIREZ: I'm sorry?

8 MR. UNGAR: I'm not sure why we would 

9 change that language.

10 (Cross-talk.)

11 MR. TOMPOS: I agree.

12 MR. UNGAR: My preference is leave the 

13 language in the IECC unless there's a reason to 

14 change it. And this is a case where, you know --

15 MR. WEISS: Yeah. I mean, it's a 

16 concern, but I can see positives and negatives to 

17 it.

18 MR. RAMIREZ: Michael?

19 MR. LUBLINER: I have a question about 

20 this. So, sometimes we have the vaulted ceiling21 type. Do you have to cut the rake? Because batt 

22 comes in rectangles. Now all of a sudden, you're 
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1 having to cut an angle up there.

2 And quite often, what we'll see is that 

3 they're cutting the angles by hand. There's no 

4 jig or anything. And so, sometimes, there is 

5 like kind of a gap, you know, in the wall, with 

6 no insulation right at that break, right at that 

7 intersection there.

8 And I think this helps to clarify that 

9 that needs to be -- you know, it needs to be done

10 with readily conformed batting so that you don't 

11 have that void in the insulation. I think it 

12 just helps to give attention to detail on that, 

13 for an MP to have that to be able to point that 

14 out.

15 MR. RAMIREZ: All right. Let's see a 

16 show of thumbs if everyone is okay with that.

17 (Pause.)

18 MR. RAMIREZ: Any objections on the 

19 phone?

20 All right. That's unanimous as well.

21 Next one?

22 MR. SANTANA: Okay. Garage separation. 
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1 That one was easy. We don't build garages. So 

2 then it's outside scope.

3 MR. RAMIREZ: All right. So let's see a 

4 show of thumbs if you're okay with eliminating 

5 that one.

6 (Pause.)

7 MR. RAMIREZ: Any objections?

8 MR. TOMPOS: I want that on the record --

9 MR. MENDLEN: Garages.

10 (Laughter.)

11 MR. WEISS: Other people build them.

12 MR. RAMIREZ: So that one is unanimous.

13 Next?

14 MR. SANTANA: Next is recessed lights. 

15 And I had a little bit of an issue with this 

16 because I don't know that our current recessed 

17 lights are IC rated or air tight. I don't know 

18 what they cost. So this is a potential cost 

19 consideration. But, you know, outside of that we 

20 didn't see any issues. And that was my own 

21 issue. I don't know if it was a committee issue.

22 MR. RAMIREZ: Yeah.
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1 MR. LUBLINER: So, my observation is 

2 that, next to P-traps, a lot of those recessed 

3 lights are the next big leak, after you've done 

4 everything correctly. I guess, is there -- what 

5 is the assumption? I would assume that the cost 

6 of the air sealing included the cost of some way 

7 of addressing that, whether it's buying an IC can 

8 or covering it with something that's 

9 nonpermeable.

10 MR. HAGERMAN: I would assume that, too, 

11 but we can relook at it.

12 MR. WEISS: How?

13 MR. LUBLINER: You just buy one that 

14 says, "proved by the Washington State energy 

15 code." Actually, we're the state that started 

16 it. Now it's the national one now, the I-codes. 

17 There's listing on it. You know that, because 

18 you need to do it for modular, right?

19 MR. TOMPOS: As far as the IC rating?

20 MR. ROY: The IC rating.

21 MR. TOMPOS: I mean, we don't do that now 

22 in the HUD code.
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1 MR. LUBLINER: But you do it in modular?

2 MR. TOMPOS: Well, I don't know where 

3 this provision -- I can't remember when this 

4 provision started.

5 MR. LUBLINER: I was just going to ask 

6 you, do you know what the products are?

7 MR. TOMPOS: No, we don't do it --

8 (Laughter and cross-talk.)

9 MR. HAGERMAN: It was in '09 or -- well.

10 (Inaudible conversation.)

11 MR. TOMPOS: Yeah, that's -- so, yeah. 

12 If we're building modulars and that is all

13 resolved, we do that. So eventually, all modular 

14 guys are going to have to go to this anyway.

15 MR. HAGERMAN: Right.

16 MR. TOMPOS: The point I wanted to make 

17 was, you know, we talked earlier about meeting 

18 that five air changes. We aren't doing this now, 

19 but we're, on average, pretty much meeting the 

20 five air changes. That provision right there 

21 will make a huge difference in the air changes. 

22 Because that is a big area of air leakage in most 
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1 homes.

2 MR. RAMIREZ: Okay. So, we have Manny 

3 for 15 minutes. So I want to try and get through 

4 as much as we can while Manny is here.

5 So let me see a show of thumbs if we're 

6 okay with that recommendation.

7 (Pause.)

8 MR. RAMIREZ: We're thumbing that 

9 recommendation on the lights, the recessed 

10 lights, the recessed lighting.

11 (Pause.)

12 MR. RAMIREZ: Okay. Anyone objectionable 

13 on the phone?

14 All right. Unanimous.

15 Next one?

16 MR. SANTANA: Okay. Plumbing and wiring. 

17 Plumbing and wiring, this is one of my pet 

18 peeves. It currently calls out for, "Batt 

19 insulation shall be cut neatly to fit around 

20 wiring and plumbing in exterior walls or 

21 installations that, on installation, readily 

22 conforms to available space and shall expand 
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1 behind piping and wiring."

2 You know, I think, one, that it's a 

3 little redundant, because we have other sections 

4 that call for the cavity to be full and the 

5 requirement to neatly cut around wiring and 

6 plumbing. I don't know that we get the benefit 

7 from that for the trouble we have or the 

8 potential cost.

9 MR. RAMIREZ: So, the recommendation is 

10 to exclude it?

11 MR. SANTANA: Exclude it.

12 MR. RAMIREZ: Any questions? Yeah.

13 MR. LUBLINER: I want to ask Emanuel, 

14 because I know in our ENERGY STAR homes program, 

15 if there is a wire going horizontally, an 

16 electrical wire, we make sure that that wire 

17 isn't compressing the insulation. And that's in 

18 ENERGY STAR.

19 So I'm just wondering -- and to actually, 

20 you know, peel the insulation and put the wire 

21 between didn't represent a lot of effort. But 

22 I'm just wondering if that's something you're 
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1 finding in your ENERGY STAR program, whether or 

2 not there's a problem here with, say, the costs 

3 or the -- what is the practice in your ENERGY 

4 STAR program, I guess is the question, Emanuel, 

5 on this one? Is this something that you require 

6 in ENERGY STAR?

7 MR. LEVY: I can say we expect that it 

8 won't be compressing the insulation. But as to 

9 whether it's a question, Mike, as to whether it's 

10 cost or whether it's a requirement?

11 MR. LUBLINER: No, I'm just wondering if 

12 this is practice that you're doing in ENERGY STAR 

13 right now. The cost is a separate thing I should 

14 have kept -- that we can talk about that after we 

15 answer the first question.

16 MR. LEVY: Yes. The wiring should not be 

17 compressing the insulation.

18 MR. LUBLINER: So this step provides more 

19 specificity to the quality assurance plan. 

20 That's why I wanted to leave it in.

21 MR. SANTANA: Yeah.

22 MR. ROY: I have a quick one.
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1 MR. RAMIREZ: Yeah, Robin.

2 MR. ROY: Do you have a one- or two3 sentence explanation as to why this provision is 

4 less suitable in the manufactured housing world 

5 than it is in the site-built world?

6 MR. SANTANA: No. I think it's -- well, 

7 for conservative -- I don't think the site-built 

8 world has the same level of inspection 

9 requirement, or in practice, right, that general 

10 manufactured housing world does, as far as 

11 scrutiny goes.

12 You know, so that is why. So just 

13 because you have the same requirement in both 

14 worlds doesn't mean you have the same level of 

15 enforcement and subsequent recall potential, you 

16 know, corrective action potential.

17 MR. ROY: Right.

18 MR. SANTANA: So that's the reason why I 

19 don't -- you know, in my mind, the compression 

20 caused on insulation by wire doesn't necessitate 

21 the level of attention that this is going to 

22 dictate.
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1 MR. LUBLINER: I guess that's where we 

2 disagree.

3 MR. SANTANA: Yeah. That's where we 

4 disagree. The only thing I think we don't see 

5 eye to eye on.

6 MR. LUBLINER: That's cool.

7 MR. RAMIREZ: Joe?

8 MR. HAGERMAN: So is there a compromise 

9 position here, that we can just say, "Batt 

10 insulation shall be installed such that the wire 

11 does not compress it"? Is it the word "neatly" 

12 that bothers you?

13 MR. SANTANA: No. It's that you need to 

14 just cut around it. You know, you need to cut 

15 around boxes. You need to cut around pipes. You 

16 need to cut around -- where I think the 

17 compression, when you take the area, right, why 

18 can't the loss from that compressed insulation be 

19 accounted for in the calculation? You know, why 

20 can't that loss --

21 You know, on the one hand, we're saying, 

22 you know, if you're building a two-by-six wall 
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1 where R11 insulation is going to work, we say 

2 it's just good practice to fill the void, right? 

3 To just fill the entire cavity.

4 So, on the one hand, we're saying, you 

5 know, put more insulation in. But on the other 

6 hand, we can account for some compression. You 

7 know? So that would be a way, that would be a 

8 tradeoff that, if you can quantify the losses, 

9 right, that are generated by compressing 

10 insulation, trade that off with something else. 

11 Can you have something, deep cut somewhere else?

12 MR. HAGERMAN: So then, so my follow-up 

13 question is, does Emanuel's seven, you know, 

14 prescriptive measures for envelope leakage take 

15 this into account? Or would that impact this at 

16 all? Do you remember? I don't have that in 

17 front of me.

18 MR. SANTANA: The leakage?

19 MR. HAGERMAN: Does it talk about --

20 MR. SANTANA: I don't think leakage has 

21 anything to do with it.

22 MR. HAGERMAN: Because, I mean, you're 
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1 going to be held to --

2 MR. RAMIREZ: Right there, it's separated 

3 there.

4 MR. HAGERMAN: -- achieving this.

5 MR. SANTANA: If you use that account.

6 (Pause.)

7 MR. SANTANA: Because, you know, it's one 

8 thing for us to sit here and, you know, spend the 

9 time that we're spending. But these, the 

10 products that we generate, are going to live for 

11 a long time. And it's going to have to be dealt 

12 with by everybody in the industry for a long

13 time.

14 And I just don't want to set us up for a 

15 perpetual failure, you know, or for a mode of 

16 failure.

17 MR. HAGERMAN: So, do you know, if you 

18 look up the installation instructions for batt 

19 insulation, what they say? As the insulation 

20 goes around wiring and plumbing, do you know what 

21 they say?

22 MR. SANTANA: I think they require you to 
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1 cut around. Yeah. They require you to cut 

2 around.

3 And I'm thinking the losses are 

4 negligible, or can at least be accounted for.

5 MR. LUBLINER: So this is where I'm 

6 coming from. We see so much wiring in exterior 

7 walls, because code mandates a switch in every 

8 room, and every so many feet there's another 

9 recept. And so, all of those areas are getting, 

10 without that attention, are getting compressed.

11 Now, if that's being calculated in the 

12 quality assurance plan, I sure don't know about 

13 it, or in the UO. So I'm just saying, rather 

14 than make it really complicated and go back to 

15 the void thing, just do it the way the 

16 manufacturer says it should be done.

17 Now, if it costs more, we should look at 

18 the implications of that.

19 MR. HAGERMAN: Well, it seems like if the 

20 insulation installation instructions -- that's so 

21 complicated -- from the manufacturers say you do 

22 it, you need to do it, then we sort of don't even 
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1 need the provision anyway; you've got to do it.

2 I mean, whether you've been doing it or 

3 not, that's between you and somebody else, right?

4 (Cross-talk.)

5 MR. LUBLINER: And this gets back to the 

6 ability of the IBEA (phonetic) to have the 

7 specifics and say, "Hey, it says specifically

8 this needs to be." That was my concern. It 

9 gives more guidance to the quality assurance 

10 plan, which includes the DAPEA (phonetic), the 

11 IPEA, HUD, all the players.

12 MR. HAGERMAN: I can say this provision, 

13 this row in its entirety, is sort of like an 

14 exception, because it just calls out batt 

15 insulation, right?

16 MR. SANTANA: Um-hm.

17 MR. HAGERMAN: So if we just want to say 

18 "Plumbing and wiring, all insulation shall be 

19 installed per the manufacturer's installation 

20 instructions" to take into account only on 

21 electrical wiring, and just move on, it seems 

22 like that's a --
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1 MR. SANTANA: Well, yeah. I mean, we 

2 approved that section already.

3 MR. WEISS: Well, keep the strike. 

4 You're fine.

5 MR. ROY: Is that a way of winking and 

6 nodding but not actually doing this?

7 MR. HAGERMAN: No. That's a winking and 

8 nodding that, if a manufacturer of insulation has 

9 done the study that says, "If you don't do that," 

10 but it's so equivalent, then we're fine with it, 

11 right? But the burden is on the manufacturer of 

12 the insulation. They would get sued by FTC 

13 because this actually has a deduction in the 

14 insulation values.

15 MR. LUBLINER: I guess my point is --

16 MR. HAGERMAN: You don't buy that?

17 MR. SANTANA: No, that makes sense. Joe, 

18 my point would be --

19 MR. LUBLINER: ENERGY STAR best practice 

20 also does that. And so, I just feel this is one 

21 that we run into a discussion in the QA in the 

22 factory. Is this required or not?
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1 MR. HAGERMAN: It sounds like all 

2 installation instructions for batt insulation 

3 require you to do this. So why they haven't been 

4 doing it altogether means they haven't been 

5 installing insulation --

6 MR. LUBLINER: And I don't want to go 

7 there. So I'm saying, if we make it explicit, 

8 then we don't have that problem.

9 MR. RAMIREZ: Why? Why don't you want to 

10 go there?

11 The only reason I'm asking this is that 

12 it kind of goes back to a lot of stuff that we 

13 do, is why do you want to fight this? Or go over 

14 the same road twice?

15 MR. LUBLINER: Why I don't want to go 

16 there is because then it suggests that everything 

17 that they've been building is out of compliance 

18 with that procedure. And I don't know that to be 

19 the case.

20 But what I just heard was the 

21 manufacturers' installation instructions requires 

22 you to cut around it. I was just pointing out, 
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1 ENERGY STAR does, too. If ENERGY STAR is a 

2 voluntary program, but I think that's best 

3 practice, and there's reasons for it.

4 But I think it's getting back to what I 

5 originally said. The more specific detailing 

6 about air sealing, the better the quality 

7 assurance plan can evaluate whether it's 

8 acceptable or not. And this is where Manny and I 

9 disagree, is that I think that that's a very 

10 important thing in overall because of the amount 

11 of wiring and plumbing, wiring particularly, in 

12 exterior walls.

13 I mean, on a single-section home, it 

14 could be a large percentage. And I haven't seen 

15 any calculations that look at it.

16 MR. SANTANA: Well, you know, why can't 

17 you account -- I'm sorry. Who's next?

18 MR. RAMIREZ: Let's get David real quick.

19 MR. TOMPOS: Well, I just pulled up an 

20 installation instruction. And what we're talking 

21 about is the grading of the instructions. And 

22 what it says in here is that when grading is 
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1 necessary, that you recommend -- it recommends 

2 that you use the RESNET grading quality.

3 So I'm not -- I'd have to do a little 

4 more research to find out if there are 

5 installation instructions that say you cut around 

6 wires. But I don't think it's in there. I think 

7 it's like this, where it says, "Well, if it's 

8 required, if there's a grading requirement, you 

9 go and use the RESNET system." So I don't think 

10 we're violating manufacturers' instructions on 

11 all homes right now.

12 MR. LUBLINER: Again, regardless, I just 

13 think it's a good practice or something we run 

14 into difficulty interpreting.

15 MR. HAGERMAN: And so, Johns Manville's 

16 installation instructions for insulation says, 

17 "Insulating around electrical wiring and walling. 

18 When electrical wiring passes through a 

19 subcavity, split the insulation with a utility 

20 knife" --

21 MR. LUBLINER: Bingo.

22 MR. HAGERMAN: -- "and fit half in front 
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1 of and half behind the wire," blah-blah-blah.

2 MR. SANTANA: And so, what I was saying 

3 is the HUD code currently allows you to take into 

4 account voids or areas that have compression, you 

5 know. And you're penalized for that in your U 

6 value calculations. So why wouldn't that be an 

7 option? 

8 What I'm against is making it a mandatory 

9 provision where it has to be done 100 percent of 

10 the time. If there's a way you can quantify it 

11 and account for it, why not have that option? 

12 Why not have that bit of --

13 MR. HAGERMAN: Well, that sounds like an 

14 exception for installing it not per the 

15 installation instructions.

16 MR. LUBLINER: That's exactly what that 

17 is.

18 MR. SANTANA: There are exceptions for 

19 installing materials all over the place, you 

20 know? It depends. If you can -- you know, we 

21 have letters from manufacturers on all sorts of 

22 products when you ask them for a specific 
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1 scenario and they write you a letter. So that 

2 wouldn't be an option if you have this.

3 MR. HAGERMAN: No, absolutely it wouldn't 

4 be an option. If this line was just struck, 

5 because it's actually not even new --

6 MR. SANTANA: Right.

7 MR. HAGERMAN: If we just said, you know, 

8 just as a reminder here, "Install your 

9 installation per the manufacturers' 

10 instructions," it's incumbent on the manufacturer 

11 with the FTC to say, "If you don't cut it, then 

12 it's equivalent," right?

13 MR. SANTANA: Exactly. Right, right.

14 So say that Johns Manville --

15 MR. HAGERMAN: So the burden is on them, 

16 right?

17 MR. SANTANA: Right.

18 MR. HAGERMAN: I don't think you'll ever 

19 get them to say that.

20 MR. SANTANA: That might be the case.

21 MR. RAMIREZ: Unless Manny is willing to 

22 concede on this, my suggestion is that we end it 
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1 here for this thing. Because I want to be 

2 respectful of his time that he's been working on 

3 this hard on this stuff, along with Eric and some 

4 of the other committee members, right? And he 

5 needs to catch a flight. And I think he did give 

6 us as much time as possible.

7 MR. HAGERMAN: Absolutely. Joe Hagerman, 

8 DOE.

9 We really appreciate this work. And this 

10 is good work.

11 MR. RAMIREZ: Yeah. Yeah.

12 MR. ROY: Two thumbs up.

13 MR. HAGERMAN: Yeah, two thumbs up. And, 

14 you know, I agree with it being struck. I don't 

15 think that --

16 MR. SANTANA: Make an executive decision.

17 (Laughter.)

18 MR. HAGERMAN: Yeah. I'll vote on it 

19 being struck.

20 MR. RAMIREZ: All right. Well, let's 

21 gauge the consensus of it being struck. Let me 

22 check the level of consensus.
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1 MR. ROY: Is it being captured in the 

2 calculation in the U value for walls?

3 MR. LUBLINER: Yeah. As long as it's in 

4 the calculation --

5 MR. HAGERMAN: No, no, no. Hold on. 

6 Time out here.

7 So we assume with all the calculations 

8 and the simulations that you install the products 

9 like the manufacturers say you do. So our 

10 simulation would show that you're cutting for 

11 wire.

12 MR. RAMIREZ: Mark?

13 MR. HAGERMAN: If they don't do that, you 

14 know, they're not installing it per the 

15 manufacturer's installation instructions.

16 MR. LUBLINER: Could I get a sense, maybe 

17 I'll change my vote --

18 MR. HAGERMAN: Do you not follow that?

19 MR. ROY: I follow that. But it's not a 

20 satisfying answer. That's what I thought he 

21 would say, and it's not a pleasing one.

22 MR. HAGERMAN: That's the reality, 
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1 though.

2 MR. ROY: I'm reading from the industry, 

3 too. I get that, too.

4 MR. RAMIREZ: Michael?

5 MR. LUBLINER: Yeah. I was just wondering 

6 what Mark from Clayton or the other manufacturers 

7 think about this. Do they consider the 

8 compression around the wiring in the exterior 

9 walls in their void calculation? Or not?

10 MR. HAGERMAN: I think HUD allows that, 

11 right, Manny, 1 percent?

12 MR. SANTANA: I know.

13 MR. LUBLINER: But just because HUD 

14 allows something now, we're sitting here to 

15 evaluate whether what HUD allows that's been 

16 around for -- that compression void thing has 

17 been around since '76.

18 MR. MENDLEN: I've got to say something.

19 MR. LUBLINER: Sorry, Rick.

20 MR. MENDLEN: It's in the standards. But 

21 what isn't in the standards, Joe, is it has to 

22 comply with the insulation manufacturers' 
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1 instructions. Be careful about whose 

2 instructions you're talking about.

3 MR. HAGERMAN: Right.

4 MR. MENDLEN: What's in the code talks 

5 about the manufacturers' instructions, not the 

6 insulation manufacturers' instructions. It's 

7 different.

8 MR. HAGERMAN: I would assume that the 

9 manufacturers of insulation are manufacturers, 

10 right? Just like GE makes refrigerators, right?

11 MR. LUBLINER: Well, maybe we should --

12 MR. HAGERMAN: You have to install that 

13 correctly.

14 MR. LUBLINER: Maybe we should recommend 

15 the HUD at that --

16 MR. UNGAR: I've been hearing something 

17 different. You're saying the manufacturers' 

18 instructions. You're talking about, the home 

19 manufacturer is not in the HUD code a requirement 

20 that the components be installed?

21 MR. MENDLEN: The insulation 

22 manufacturers' instructions is not specifically 
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1 referenced in our standards.

2 MR. HAGERMAN: But we did reference that 

3 earlier today.

4 (Cross-talk.)

5 MR. MENDLEN: But you talked about 

6 manufacturers' instructions, Joe. Which 

7 manufacturer are you talking about? Home or 

8 insulation?

9 MR. HAGERMAN: So we've said, we've 

10 already voted that R402.4.1, insulation, the 

11 components of the building thermal envelope as 

12 listed in table blah-blah-blah shall be installed 

13 in accordance to the manufacturer's instructions. 

14 Those manufacturers' instructions are the 

15 manufacturers of the building thermal envelope 

16 components.

17 MR. LUBLINER: So we just change the HUD 

18 code to represent that.

19 MR. HAGERMAN: Okay. All right.

20 MR. LUBLINER: I mean, you have to talk 

21 to HUD about that.

22 MR. HAGERMAN: You have to install the 
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1 insulation per the manufacturers' instructions, 

2 the people that make the insulation.

3 MR. RAMIREZ: So, let me see a show of 

4 thumbs again for striking --

5 MALE VOICE: No, no, no.

6 (Simultaneous conversation.)

7 MR. RAMIREZ: That's 402.4.1, the first 

8 page of Manny's document.

9 So, again, let me see a show of thumbs 

10 for striking -- I'm trying to find it -- the 

11 plumbing and wiring section of this chart.

12 (Pause.)

13 MR. RAMIREZ: Any thumbs down on the 

14 phone?

15 Okay. No thumbs down. That one is 

16 unanimous.

17 MR. WEISS: For the strike, correct?

18 MR. RAMIREZ: For striking.

19 Okay. Again, Manny, thank you very much.

20 Let me suggest this. Are you guys okay 

21 with a quick five-minute one function here? And 

22 then we'll come back and then see -- we'll 
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1 discuss as a group how you want to use the 

2 remaining 40 minutes that we have. Okay?

3 So, a quick five-minute break.

4 (Recess from 4:20 until 4:29 p.m.)

5 MR. RAMIREZ: All right. We're still 

6 missing a few bodies. While we're getting the 

7 group back together, I want to offer an 

8 opportunity for public comment. And then let's 

9 see what time that takes, or not, and then we can 

10 see what we have remaining and see how to fill it 

11 properly.

12 So, Rick, I believe that you are the only 

13 member of the public present. Would you like to 

14 make any comments?

15 MR. MENDLEN: I will defer my comments 

16 for the day and let the committee continue to do 

17 its work.

18 MR. RAMIREZ: Okay, great.

19 Then I'll ask the committee here. You 

20 know what? 

21 MR. WEISS: Javier.

22 (Inaudible conversation.)
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1 MR. WEISS: Javier, I just want to say 

2 one thing for the sake of consistency, as I make 

3 this point at just about every MHCC meeting, 

4 where I'm considered a member of the public.

5 And that is, I just have a problem with 

6 referring to HUD, our regulatory agency, as "a 

7 member of the public." I understand the process 

8 we have here, but you know, they're not just Joe 

9 Shmo from the public.

10 MR. RAMIREZ: Right.

11 MR. WEISS: You know, they have a direct 

12 interest in this proceeding.

13 MR. RAMIREZ: Right.

14 MR. WEISS: And I appreciate you giving 

15 Rick the opportunity to comment when he feels 

16 it's appropriate. But again, I just have a 

17 problem with that terminology.

18 MR. RAMIREZ: Yeah, I understand that. 

19 And Rick has been very compliant with the rules 

20 that this committee has set up, and also very 

21 helpful with giving us information offline and 

22 online. So we do appreciate that, Rick.
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1 It's a formality. I hope that everyone 

2 understands that.

3 MR. MENDLEN: I understand it.

4 Thank you, Mark.

5 MR. WEISS: I'll cite this next time I'm 

6 called upon, right?

7 MR. RAMIREZ: Yeah.

8 (Laughter.)

9 MR. RAMIREZ: Okay. So, we have about 30 

10 minutes left. And I'm looking at this. I want 

11 to see if we could -- I'm going to defer on the 

12 affordability report right now. I think that 

13 that's still probably a bit premature for the 

14 affordability report, which we get to it at the 

15 next meeting.

16 But as far as action items go, that kind 

17 of goes to the multiple product types, which 

18 leaves climate zones and compliance paths.

19 Can this group make a decision on either 

20 one of those with the remaining time that we 

21 have? Has there been enough data thrown out 

22 there, say, for the climate zones, to adopt 
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1 either -- and correct me if I'm wrong. We're 

2 talking about either HUD or IECC. I don't think 

3 we're getting creative here and trying to create 

4 our own type of climate zone structure. Is that 

5 accurate?

6 MR. ROY: This is Robin.

7 I think it's accurate. But if the IECC, 

8 it may be a subset of those or a combination of 

9 those. We would treat them all the same. I can 

10 imagine of the eight IECC zones, ending up with 

11 three that happen to be just a different 

12 geographies than the HUD. It's imaginable.

13 It could be all eight. But then several 

14 of them would be identical. I can picture that.

15 MR. WEISS: I mean, I just see it as such 

16 an important issue that to address it at the end 

17 of a meeting, for me, I just don't think it 

18 works.

19 MR. RAMIREZ: And that's why I'm asking.

20 MALE VOICE: I agree.

21 MR. RAMIREZ: We have 30 -- a little over 

22 30 minutes. Is that enough time to address 
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1 either one of those issues?

2 MR. LUBLINER: So, since the first 

3 meeting, I've been trying to get a sense of the 

4 feeling of the group about, should we just leave 

5 the HUD climate zones the way they are? And I've 

6 been one that's been a advocate for doing that, 

7 not going to the IECC climate zones, because I 

8 think it's a bigger burden in the industry and 

9 it's harder -- it may be more difficult.

10 But I'm willing to hear arguments as to 

11 why we should make it more climate zones.

12 I feel like a place like California, 

13 where this could really be an issue, because it's 

14 just very diversified climates, that they will 

15 probably during public comment decide whether or 

16 not they think this is adequate or not, and they 

17 will tell us, "Well, wait a minute. We're 

18 California."

19 But anyway, so, Robin, that's kind of my 

20 thought. So I'm wondering, is it useful at all 

21 in getting a sense from the group how far off we 

22 are on the issue of climate zones?
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1 MR. RAMIREZ: Okay. And, Lois, you had a 

2 comment?

3 MS. STARKEY: I'd like to hear from the 

4 rest of the group, and then I will.

5 MR. RAMIREZ: Okay. I saw perfectly a 

6 hand. Is that you, Mark?

7 MR. WEISS: Yeah. I'm probably the wrong 

8 one to be saying this. Part of the problem we're 

9 going to have here is Manny's not here. And, you 

10 know, I think he would have some important input.

11 But I don't know if the analysis works, 

12 Mike's analysis works, because the HUD zones are 

13 more, are broader, okay? You have three zones 

14 versus, what is it, eight in the IECC. And 

15 you're making the requirements more prescriptive 

16 if nothing else, probably more costly as well.

17 By applying those higher requirements 

18 over potentially broader areas, aren't you 

19 increasing the cost of the burden rather than 

20 having more targeted areas? I don't know. I'm 

21 just raising this.

22 MR. LUBLINER: So, Mark, my feeling is if 
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1 the industry wants the IECC climate zones, I'm 

2 fully supportive of it. I just want to know what 

3 the industry wants, you know.

4 (Laughter.)

5 MR. ROY: This is Robin.

6 I hear your view, Mark, about this one. 

7 I take a look at some of the numbers on the 

8 incremental home costs that they've whipped up. 

9 And I can see that they seem to correlate with 

10 some of the -- you can find some places where it 

11 looks like, "Gosh, Phoenix or Houston should not 

12 be here. We should not be treating it as HUD 

13 zone 2." You can easily see, well, it works 

14 better in an IECC definition.

15 I don't know the answer, but I was kind 

16 of keen to see what the costs, and the cost 

17 effectiveness, would guide us to do. And we're 

18 just getting to that now. So I think it is 

19 premature. We won't solve it today. But we're 

20 getting the numbers that will allow us to do it.

21 MR. WEISS: Yeah, not being a technical 

22 person or any of that, the question just occurs 
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1 to me, you know.

2 MR. ROY: Me, too.

3 MR. RAMIREZ: All right. I'm sorry. 

4 Eric, then Lowell.

5 MR. LACEY: You know, I'm not sure 

6 whether you will come down on the climate zones. 

7 And I think I'm fine with either. I see the 

8 value in either of them.

9 The IECC has nominally eight climate 

10 zones. But if you look at insulation 

11 requirements, there's kind of three different 

12 insulation requirements that applied in groups of 

13 climate zones. And window requirements, there 

14 are essentially three window requirements that 

15 apply to three groups of climate zones.

16 And so, what I like about the Luby 

17 prescriptive proposal is that it sort of took, on 

18 balance, you know, levels that were equivalent, 

19 or in some cases kind of the better requirements 

20 of those climate zones. If you were to package 

21 the climate zones from eight packages into three, 

22 it picked reasonably efficient levels for each of 
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1 those climate zones.

2 So I think, if you keep that in mind, you 

3 know, whether we end up with three or eight 

4 climate zones, or some other number, as long as 

5 we're keeping an eye on those groupings of 

6 efficiency levels for the components, I think 

7 we'll be okay.

8 But, you know, I'm interested in hearing 

9 from the manufacturers on how that would affect 

10 them to have maybe more climate zones.

11 MR. LUBLINER: That's what I'm waiting to 

12 hear from the manufacturers, or Emanuel, because 

13 he's looked into this pretty extensively.

14 MR. LACEY: Yeah.

15 MR. LUBLINER: I don't think we're ready 

16 for a vote today. I was just trying to get a 

17 sense of the group. I agree with Robin.

18 MR. LEVY: Javier?

19 MR. RAMIREZ: Yeah.

20 MR. LEVY: Hi, this is Emanuel. Can I 

21 weigh in here?

22 MR. RAMIREZ: Yeah. Please, please.
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1 MR. LEVY: Javier, did you get the email 

2 I sent?

3 MR. RAMIREZ: Let me check.

4 (Pause.)

5 MR. RAMIREZ: Yeah. We'll pull it up 

6 here in just a second. I see it. It did come 

7 through.

8 (Pause.)

9 MR. RAMIREZ: While Ted takes a minute, 

10 because I know how my Outlook is just brutally 

11 slow to open, are there any of the other 

12 manufacturers that want to chime in as far as 

13 just initial perceptions on the climate zones?

14 MR. KESSLER: This is Bert from Palm 

15 Harbor.

16 I think the consensus among manufacturers 

17 is to keep it simple, like we have it. I'm going 

18 to go out on a limb and some of my brethren will 

19 probably hate me. But I think we should look at 

20 making at least a couple of changes, just looking 

21 at the map. If you look at the Texas panhandle, 

22 I think perhaps that line in the sand could be 
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1 redrawn and kind of follow a little bit more of 

2 what the IECC folks show.

3 Just because, you know, we can design a 

4 house for Amarillo, Texas, to climate zone 1 and 

5 design a house for, you know, down around -- for 

6 thermal zone 1, but there's a huge difference.

7 The other thing that I believe is part of 

8 an issue relating to the thermal zones is 

9 equipment sizing, because that gets a little bit 

10 more diluted. So that's all I'm going to say 

11 about that.

12 MR. RAMIREZ: So if I could try to sum 

13 that up, basically what you're saying is that 

14 there's a comfort in keeping what you have. But 

15 there may be a good argument to restructure that 

16 a bit.

17 MR. KESSLER: Yeah. And especially for 

18 Texas. And I think somebody brought up Arizona. 

19 You know, I think we could streamline 

20 efficiencies a little bit more if we went away 

21 from just following state lines.

22 And I know that was a big deal back in 
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1 '94 when we changed the wind standards. But I 

2 think everybody is used to it. And I think it's 

3 manageable.

4 MR. RAMIREZ: Okay. Thank you.

5 MR. KESSLER: Lois?

6 MS. STARKEY: Yes.

7 MR. KESSLER: You got any comments?

8 MS. STARKEY: No. We talked about this. 

9 You know, we've been talking about this as a 

10 group most recently in the last couple of years. 

11 So I think it's worth putting it on the table, 

12 because I think you can get some tradeoffs if you 

13 added at least one other zone.

14 MR. RAMIREZ: Okay. Emanuel, do you want 

15 to walk us through what we're looking at?

16 MR. EZZO: Can I make a comment? This is 

17 Mark, Clayton.

18 MR. RAMIREZ: Yeah.

19 MR. EZZO: My vote or my preference would 

20 be to keep the three HUD zone boundaries as they 

21 are. And I completely recognize and agree with 

22 the logic that Bert just expressed. I mean, it 
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1 makes perfect sense.

2 But I also am concerned about the 

3 complexity of changing the boundaries, not only 

4 for manufacturers, but for the retail world. 

5 It's going to cause a lot of confusion for them

6 if we change the boundaries. 

7 You've got to keep in mind that not 

8 everything we build is customer sold. Our 

9 industry deals with a lot of stock homes, a lot 

10 of retailers carrying inventory. A lot of those 

11 retailers are in areas that hit multiple zones. 

12 So my preference would be that we keep the 

13 boundaries the way they are.

14 And then couple that with, like Mike 

15 Lubliner's approach, where he took what I thought 

16 was a pretty practical stab at putting together 

17 as a thermal requirement by zone, you know, 

18 prescriptive approach, that I know we haven't 

19 gotten through that yet and I hope we do in more 

20 detail.

21 But it really makes sense to me the way 

22 he broke it down between 1, 2, and 3 in terms of 
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1 what's required for insulation in the cavities, 

2 the thermal performance of the window 

3 requirements, and all those kinds of things.

4 So that's my input for what I think the 

5 boundaries ought to be, going forward. Thanks.

6 MR. LUBLINER: Thanks, Mark.

7 MR. RAMIREZ: All right. Emanuel, you 

8 want to walk us through what we're looking at?

9 MR. LEVY: Yeah. This is -- and all the 

10 comments leading up to this were very good 

11 because it will be very helpful.

12 This is the mapping of the results from 

13 our analysis of U values, with the various zones. 

14 And you see what you're looking at is two maps 

15 overlaid. The thick line you'll recognize is 

16 carving out the three HUD zones. So, Texas over 

17 to Georgia and down to Florida, or South Carolina 

18 down to Florida, is zone 1. And the middle area 

19 there is zone 2, and the northern zone is zone 3.

20 And you can see how what this means in 

21 terms of the consistency of the U values. And I 

22 think what Mark was saying just now about keeping 
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1 them where they are makes some sense, or that's 

2 reflected somewhat in the U values in that, if 

3 you look at zone 2, for example, all the way 

4 across there -- now, there are exceptions, as 085 

5 and there's 059. But generally, that whole band 

6 is around 067.

7 So just for U value matching up to the 

8 IECC, you can pretty much soft focus on that area 

9 and say, "Okay. Zone 2 should be about 067. 

10 Let's develop a prescriptive package from that." 

11 And you can now look at the South and see it's 

12 somewhere between 067 and 085. In the North, you 

13 can see that it ranges anywhere from 067 down to 

14 051.

15 And also, you see on the table there's 

16 the LCC range. And I've just picked two. I've 

17 bracketed that with kind of a high-low set of 

18 assumptions. And you can see that, in zone 1, 

19 those U values tend to -- some of them are cost 

20 effective, some of them are not cost effective. 

21 They're pretty much straddled. So the overall 

22 impression is that that range there is within the 
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1 band of what you'd expect, without much change.

2 Same thing, less so, in zone 2, and zone 

3 3, probably, there's some opportunity there to 

4 make things a little bit more stringent.

5 But I just threw this map out there to 

6 kind of get the debate going so you can see what 

7 the ramification would be in terms of overlying 

8 the two zones and what it really means in terms 

9 of the use of all zoning.

10 MR. RAMIREZ: Great. Thank you. It 

11 looks very useful. And I just forwarded it on to 

12 the complete work group.

13 Mark?

14 MR. WEISS: Question. Maybe I'm missing 

15 something. Why is the brown shaded area, both 

16 the brown shaded area and the yellow shaded area 

17 0.067?

18 MR. LEVY: Same prescriptive requirements 

19 in the IECC.

20 MR. WEISS: Why are they shaded 

21 differently then?

22 MR. LEVY: Because they're different 
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1 zones. They're called out as different zones by 

2 the IECC.

3 MR. WEISS: But the same requirement?

4 MR. LEVY: The same requirement.

5 MR. UNGAR: In 2015 IECC.

6 MR. WEISS: Oh, okay. Okay. All right. 

7 Thanks.

8 MR. RAMIREZ: Yeah, Eric?

9 MR. LACEY: This is Eric. And just to be 

10 clear, you aren't including any of the cost or 

11 benefits of a lower SHGC in the fenestration, 

12 right? This is just a use of O calculation?

13 MR. LEVY: We used the lower solar heat 

14 gain coefficient, but we picked a window that 

15 gave you that value. And that helped to trade 

16 off against the rest of the envelope. So it does 

17 include the glazing. It does include the solar 

18 heat gain coefficient in here, in the package.

19 But what you're looking at is use of O 

20 values. And the use of O values, of course, are 

21 only reflective of what U values are in a 

22 component.
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1 MR. LACEY: So I guess you use the SHGC 

2 in your cost effectiveness, but that won't be 

3 reflected in the use of O values that are on this 

4 page?

5 MR. LEVY: I think I just said it the 

6 opposite way. The first thing is the cost 

7 effectiveness is just using the tool that NCI 

8 developed. The U values here are developed from 

9 the packages that were on the chart that we 

10 talked about yesterday, which included the solar 

11 heat gain coefficient windows, the windows with a 

12 lower solar heat gain coefficient.

13 MR. HAGERMAN: This is Joe Hagerman, DOE.

14 So I think he used -- all your packages 

15 had the same solar heat gain coefficient, which 

16 says 0.33.

17 MR. LEVY: That's right.

18 MR. HAGERMAN: Okay. 

19 MR. LEVY: Right.

20 MR. HAGERMAN: So I think the number that 

21 you're showing here reflect your single-section 

22 home from the chart that he provided us 
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1 yesterday.

2 MR. LEVY: Right.

3 MR. HAGERMAN: The proposed prescriptive 

4 packages.

5 MR. LEVY: That's right. Now, we can go 

6 in and tweak those. It might impact these 

7 numbers a little bit.

8 MR. HAGERMAN: And just to be clear, too, 

9 you did two analysis periods here, one 10 and one 

10 30? And on the 10-year, you did not include 

11 residual value, and in the 30, you included 

12 residual value. Is that right?

13 MR. LEVY: Right. Right. And of course, 

14 we discussed -- you can throw in any set of 

15 assumptions in here and come up with your LCC 

16 range.

17 MR. HAGERMAN: Yeah, just to be clear, 

18 that's backwards of what we talked about 

19 yesterday. We talked yesterday about 10 years 

20 with residual value and 30 years without residual 

21 value. So is that a typo?

22 MR. LEVY: No. You know, this was -- I 
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1 characterize this as a quick and dirty just to 

2 get some numbers out, just to be able to have a 

3 visual display of this information so we could 

4 have a discussion about how to make decisions in 

5 that climate zone.

6 MR. HAGERMAN: Okay. 

7 MR. LEVY: This is not a final -- this is 

8 not a recommendation. This is not a proposal.

9 MR. HAGERMAN: Right.

10 MR. LEVY: This is just a way, a proposed 

11 way to get at that discussion.

12 MR. RAMIREZ: And so I guess I sent that 

13 out without that clarification. I just forwarded 

14 it. Just so everyone, when you get that, don't 

15 get worked up on any numbers.

16 MR. HAGERMAN: Joe Hagerman, DOE.

17 Just to be clear, I think once you put in 

18 10 years with residual value, your LCC range 

19 where you're showing negative 105, negative 1068 

20 and 263, are going to be less severely negative.

21 MR. LEVY: Right, right. Actually, both 

22 numbers, you get in a little closer --
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1 MR. HAGERMAN: To zero.

2 MR. LEVY: From what you've said, Joe. 

3 But you're right.

4 MR. HAGERMAN: Okay. 

5 MR. LEVY: The U value, that won't affect 

6 the U value range.

7 MR. HAGERMAN: That's right.

8 MR. LEVY: But the tweaks in the window 

9 might affect the U value range a little bit.

10 MR. RAMIREZ: Any other questions on this 

11 one?

12 (Pause.)

13 MR. RAMIREZ: So, we have about 10 

14 minutes left. And I'd like to take a few minutes 

15 to at least start the outline of a proposed 

16 agenda for the next meeting, where we continue 

17 with the 2015 IECC scope report that Manny had 

18 put together for us.

19 And then, I think on that affordability 

20 report, that's going to the question of multiple 

21 product types, which there may be some benefit to 

22 holding that conversation off for a little bit to 
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1 see if that's something that we actually are 

2 seriously considering, or -- Robin?

3 MR. ROY: I think it's worth holding off 

4 till we see a few more of the numbers to see 

5 whether it's something that we actually need.

6 MR. RAMIREZ: Right.

7 MR. ROY: If we find that in the first 

8 buyer's perspective and in the full life cycle 

9 cost perspective there's an overlap in the energy 

10 efficiency levels, then there's no reason to do 

11 something that separates them.

12 MR. RAMIREZ: Okay.

13 MR. ROY: To have two product types. So 

14 we should take a look at some numbers first.

15 MR. RAMIREZ: Okay. Joe?

16 MR. HAGERMAN: So I'm just -- so we're 

17 meeting next week, right? And isn't it next 

18 week?

19 MS. DICKENS: Yes, it's next Wednesday 

20 and Thursday, right?

21 MR. HAGERMAN: Yeah, next Wednesday and 

22 Thursday. So, just like let's talk turkey and 
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1 let's do a reality check real quick.

2 So, usually I'll walk away with a ton of 

3 homework. And today it seems like I'm not 

4 getting very much homework. I'm going to have 

5 PNNL relook at the U values, right, for the 

6 packages that Emanuel gave us, just to see how 

7 the savings numbers differs. We talked about 

8 that yesterday, right?

9 Matthew will correct the life cycle tool, 

10 where we saw some errors or there were some price 

11 discrepancies, you know, per the discussion on 

12 everything we voted on with the price or the 

13 costs.

14 What else do we need here? I mean, you 

15 know, next week when we meet, how does the

16 situation change between now and next week to 

17 make this group get closer to a decision? Right? 

18 Let's just talk turkey about that, right?

19 MR. ROY: This is Robin.

20 In my estimation, it changes a lot. We 

21 had a few things which will change the life cycle 

22 costs and the first buyer perspective costs of 
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1 effectiveness analyses. So much of what we're 

2 discussing hinges on what those numbers show us, 

3 I think.

4 I didn't even have that much time to 

5 reflect on what we received on Friday, before 

6 today. We'll have plenty of time, I'm presuming. 

7 Matthew, how long before you send that out? In 

8 advance, I would hope, by more than the previous 

9 day.

10 If it is, then we'll be able to actually 

11 have a conversation about some of the numbers 

12 that we see in there. We should have some idea 

13 of whether we think some of them are sensible 

14 already, from the discussion we've had over the 

15 last couple of days. But we need to see the 

16 numbers coming through as well.

17 MR. HAGERMAN: Let's just say that all 

18 the DOE stuff will get done by Thursday close of 

19 business. We'll send it out to you Thursday 

20 close of business.

21 MR. ROY: Thursday next week or this 

22 week?
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1 (Laughter.)

2 MR. HAGERMAN: This week.

3 MR. ROY: Sorry. Can we strike that from 

4 the record?

5 MR. HAGERMAN: And do you also think it 

6 would be helpful if we showed -- so we're doing 

7 two things right now. We're going to update the 

8 life cycle tool. We're going to give you the new 

9 runs, those two things.

10 Would it be helpful for us to add a 

11 third? And that is revise the chart that Emanuel 

12 sent out and show you that graphic with the new 

13 numbers in it for the single and the double? I 

14 thought it was pretty helpful. Is that something 

15 you would like to see, as well?

16 MR. RAMIREZ: I've seen some heads bob, 

17 so yes.

18 MR. HAGERMAN: So we'll do that, too. So 

19 there's three things. Update the life cycle, new 

20 PNNL runs so we can get the correct numbers, and 

21 then take Emanuel's climate zone chart and update 

22 it. Right? So we can be responsible for getting 
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1 all that to you Thursday, close of business. GC 

2 will agree to approve what we send very quickly. 

3 So.

4 MR. UNGAR: One question on that. The 

5 one thing I've heard a lot of discussion on 

6 yesterday was on the windows costs. And I don't 

7 know how to handle that dispute. And we can 

8 either go ahead, recognizing that some people 

9 think the costs on that portion will be 

10 considerably -- I mean, not just a small amount, 

11 but a lot lower.

12 Or I suppose we could do -- we could ask 

13 for a new set of numbers from a new evidence and 

14 run another set of, you know, calculations based 

15 on two different sets.

16 I just -- that's one thing that seemed to 

17 me like it might be material.

18 MR. HAGERMAN: I forgot to say, too, that 

19 when we got Emanuel's cost data from the 

20 industry, I asked Navigant to compare those costs 

21 with just publicly available data sources just to 

22 make sure there weren't any discrepancies, just 
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1 as a course of good measure, not that we don't 

2 trust the manufacturers or anything.

3 So they've been doing that RSMeans 

4 evaluation. They didn't get it done by time to 

5 share it with anybody. But we're also doing that 

6 site analysis, too. And once they get that 

7 RSMeans calculation, we can share that as well.

8 MR. WEISS: From part of the industry.

9 MR. HAGERMAN: For part of the --

10 MR. WEISS: From part.

11 MR. HAGERMAN: Yeah.

12 (Cross-talk.)

13 MR. HAGERMAN: All of the information 

14 that's been publicly provided by this group.

15 MR. BARBOUR: Joe, on the RSMeans, is 

16 that part of Navigant? It's not an apples-to17 apples?

18 MR. HAGERMAN: Right. Yeah. We should 

19 say that, because --

20 MR. BARBOUR: Actually, I don't know how 

21 useful it's going to be. I'm just going to 

22 preface it by saying that.
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1 MR. HAGERMAN: To me, it's a gut check, 

2 right? It's like, hey, we've got these numbers. 

3 Let's just do a first-order, does it kind of --

4 is it in the same ballpark? But, obviously, 

5 RSMeans does not have a volume from manufactured 

6 housing. And you are right. It's not apples-to7 apples.

8 But you guys are smart guys.

9 MR. BARBOUR: But it's going to --

10 MR. HAGERMAN: You guys are smart guys.

11 MR. BARBOUR: But it's not --

12 MALE VOICE: You guys are smart guys. 

13 You all figure it out.

14 (Laughter.)

15 MR. RAMIREZ: Let's get Michael, then 

16 Eric, Mark, Lois.

17 MR. LUBLINER: A couple of meetings ago, 

18 I suggested that you might want to go and talk 

19 with the associations like NAIMA. And now that 

20 we know what the markups are and we have the 

21 retail costs, you might want to go back to NAIMA 

22 and just confirm with them that, is it two cents 
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1 per R? Or one cent? Or for high density, low 

2 density? That would be very useful for me to 

3 understand.

4 Now, again, not that I'm questioning the 

5 manufacturers' costs. But this is a third-party 

6 independent way of assessing things that might 

7 help with perception. Thanks.

8 MR. HAGERMAN: We have reached out. We 

9 just haven't heard back.

10 MR. LUBLINER: Okay. Thanks.

11 MR. RAMIREZ: Eric?

12 MR. HAGERMAN: And we welcome other 

13 members to reach out to other sources, too. I 

14 mean, any data that you can provide us helps all 

15 of us.

16 MR. RAMIREZ: But the sooner you get it, 

17 the sooner it can be plugged in and then out to 

18 you all for review. So.

19 Eric? Mark, and then Lois.

20 MR. WEISS: I was just going to ask, when 

21 Navigant does that analysis, just indicate what 

22 public sources you're looking at. Thank you.
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1 MR. RAMIREZ: Thank you.

2 Lois?

3 MS. STARKEY: I'd like to suggest that 

4 once we get the information from DOE, that 

5 perhaps I can get with Emanuel and the 

6 manufacturers and we can take this and put it 

7 into another straw man, based on everything that 

8 we've talked about that would include zones, U 

9 values, you know, prescriptive requirements, duct 

10 leakage, all of the components --

11 MR. RAMIREZ: You're talking about a full 

12 package?

13 MS. STARKEY: -- of a package, a draft 

14 term sheet, very draft, just to throw out. 

15 Because I think we just need something on the 

16 table that we can just mark up. Not with any, 

17 you know, this is our proposal, just something 

18 that we can --

19 MR. RAMIREZ: That's what a straw man, 

20 technically, is.

21 MS. STARKEY: Yeah. Yeah.

22 MR. HAGERMAN: I think we're at the third 
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1 step of grieving. We're at the third phase.

2 (Laughter.)

3 MR. HAGERMAN: So we welcome whatever 

4 materials the members can produce to help, you 

5 know, move that conversation along. I mean, 

6 we're very thankful of ya'll's time, your 

7 participation, your comments, all the data you 

8 have provided, the discussion. We're very 

9 thankful for all of that, right?

10 And we think we're at the cusp here of 

11 closing it out and getting to a term sheet. But, 

12 you know, at the end of next week we'll 

13 reevaluate whether or not we need the meeting in 

14 Golden.

15 MS. DICKENS: So don't book your flights 

16 yet. Is that what you're saying?

17 MR. HAGERMAN: I wouldn't necessarily 

18 book your flight yet because, I mean, if we get 

19 to the end of next week and, you know, we're not 

20 there, I'm sort of thinking we need to just go 

21 back to ASRAC and say, you know, we did our best, 

22 we just couldn't get there.
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1 MS. DICKENS: Okay. 

2 MR. HAGERMAN: So, I mean, that's my 

3 personal opinion, and I think that -- you know, I 

4 don't want to -- I'm very conscious of your time 

5 and your effort. I don't want to necessarily 

6 waste your time. And if we just have a couple of 

7 more meetings, are we going to get to closure? 

8 You know, I'm a little bit unknown at this point 

9 in time.

10 MR. RAMIREZ: So, my interpretation is 

11 we're beyond the wish list, right? And let's --

12 so, Lois, when you're working with Emanuel, put 

13 something out there that -- and I think there has 

14 been enough dialog, right, where you kind of have 

15 an idea of where the poisoned pills are, and see 

16 if we can't get close to hitting that target, 

17 with no ownership, right, no wing tips.

18 MS. STARKEY: Emanuel, does that sound 

19 good to you?

20 MR. LEVY: Yeah.

21 MR. RAMIREZ: Great. Great. Okay.

22 And then, there may be a procedural 
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1 question. Good? Okay. 

2 MR. HAGERMAN: So, just so -- Kavita just 

3 asked me if we got the extension. John Cymbalsky 

4 has been out. It's my understanding he's asked 

5 the ASRAC members for extension, and I've seen a 

6 lot of them pull back saying, "Yes, I don't see a 

7 problem there." But I'll reconfirm that we did 

8 get the extension.

9 And when we do get the extension 

10 formally, we have to quickly put out our Federal 

11 Register notes. So you'll see all that 

12 materialize within, you know, the next couple of 

13 days.

14 MR. RAMIREZ: So, just to recap, it looks 

15 like we're going to be getting some additional 

16 reports. We'll get them by Thursday of next 

17 week. And then --

18 MR. HAGERMAN: This week. Thursday of 

19 this week.

20 (Cross-talk.)

21 MR. RAMIREZ: I'm sorry. Thursday of 

22 this week. Robin's rubbing off on me, sitting 
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1 too close to him.

2 (Laughter.)

3 MR. RAMIREZ: And then, once we get those 

4 reports, then Lois and Emanuel and the 

5 manufacturers are going to get together and try 

6 to put together a straw men.

7 We will also continue with the 2015 IECC 

8 report that Manny has. But you all have that 

9 one, right? You kind of have a feel for how 

10 that's going so you could use that when you're 

11 developing the straw man.

12 And then, next week, we're going to have 

13 to start making some decisions, right? Climate 

14 zones, compliance paths, and then analyzing the 

15 straw man.

16 MR. HAGERMAN: I would just like to put 

17 on the table, too, I think you framed it up 

18 correctly. Next week, we have to make some 

19 decisions. And the decisions, in my mind, are 

20 one of two things. One is, everything you just 

21 said in terms of finding a term sheet, and-or the 

22 decision whether or not we need to continue as a 
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1 group. Right? Whether we think that one 

2 additional meeting will get us to closure or not, 

3 right? And that's just the decision we're going 

4 to have to make as a group.

5 MR. RAMIREZ: Okay. So we'll make sure 

6 that we incorporate time for that in the agenda 

7 to have that discussion and not just 30 minutes 

8 at the end of the day.

9 MR. LEVY: Javier, can I just throw one 

10 certainly unpopular suggestion? We have a 

11 meeting scheduled for October 1-2, correct?

12 MR. RAMIREZ: Yeah. That's the one for 

13 next week.

14 MR. LEVY: That's the one next week. You 

15 know, it's unfortunate we don't have that the 

16 8th, one week later than that, you know, so 

17 there's two weeks between now and then, and 

18 another two weeks before then and the Golden 

19 meeting.

20 Because I think what we need by the next 

21 meeting, the next step together is something 

22 pretty complete in order to be sure that Golden 
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1 is going to close things out. It's not possible 

2 to move that meeting date, is it?

3 MR. LUBLINER: Not for me.

4 MR. LACEY: It's not for me.

5 MR. HAGERMAN: But also, I think, you

6 know, unfortunately, I think it is what it is, 

7 and I think it's good that we continue. And then 

8 next week, if we need another meeting, we can do 

9 it. We can try to schedule 11R or something like 

10 that. I just think we've got to keep on. I 

11 mean, I think that, unfortunately, you've got two 

12 weeks of work to do in a week, just like we did.

13 (Pause.)

14 MR. RAMIREZ: I think maybe at this point 

15 it might be --

16 MR. HAGERMAN: I think you're really 

17 close, though, Emanuel, to be honest with you. I 

18 think that, you know, the working group members 

19 outside of us have done just a really good job of 

20 getting together and working. And what we've 

21 seen in the discussions today, even though 

22 they've been painful, right? I mean, I think 
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1 we're seeing some positive direction. I think we 

2 can see a horizon now, right?

3 I would think. I mean, I don't think 

4 we're far off. I mean, nobody really said too 

5 much complaining when we looked at the life cycle 

6 and looked at the numbers and the savings. I 

7 mean, sure, we have some problems in a couple of 

8 climate zones, but I feel like we're in the 

9 ballpark, right?

10 MR. RAMIREZ: Logistically, I think that 

11 it has been a heavy lift. And, Emanuel, I know 

12 that you've been putting in a lot of time and 

13 resources into the research, and Lois, as well, 

14 and quite a few other committee members have 

15 really been putting in a lot of time and effort.

16 And I understand that next week seems 

17 awfully tight. For where we're at, 

18 unfortunately, it probably does seem like we're 

19 going to have to do a little bit more homework 

20 and just try to push it and make this final push 

21 and see if it does, if we can get an agreement or 

22 if it makes sense to meet that last time.
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1 But I think to try to rearrange 

2 everyone's schedules at this last minute for next 

3 week, I think would be a challenge.

4 MR. LEVY: I certainly appreciate that. 

5 Unfortunately, I can't physically be there; I'll 

6 be in California. But I will be calling in.

7 You know, you're right. We'll do what we 

8 can do. And if we don't get it done, we'll still 

9 have those decisions we need to make and perhaps 

10 have another one-day meeting, or whatever is 

11 required before the Golden meeting. Yes. Sounds 

12 fine.

13 MR. RAMIREZ: All right. Anything else 

14 before we close out?

15 MS. DICKENS: Well, I'm hoping I won't 

16 see you in Golden, because I'm hoping we'll be 

17 done by then.

18 (Laughter.)

19 MR. RAMIREZ: Okay. Yeah, we did the 

20 public comment when you were gone. We wanted to 

21 see how much time we were going to have.

22 MR. LUBLINER: I just want to thank the 
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1 facilitators and all the people that have been 

2 making this ship float here, everybody, including 

3 the team. I mean, I've been in a lot of public 

4 consensus standards meetings and stuff. And 

5 they're grueling. But I think you guys, I'm 

6 impressed with the quality of the turnaround and 

7 the quality of the dialog. So, thank you.

8 MR. RAMIREZ: Yeah, it's been a real team 

9 effort. So, thank you, everyone.

10 All right. We'll see you all next week, 

11 or hear you next week, depending.

12 (Proceedings adjourned at 5:03 p.m.)

13

14

15

16

17

18

19

20

21

22
413 

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