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 U.S. DEPARTMENT OF ENERGY

 + + + + +

 MANUFACTURED HOUSING WORKING GROUP

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 PUBLIC MEETING

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 WEDNESDAY

 OCTOBER 1, 2014

 + + + + +

 The Public Meeting met in Room 6097,

950 L'Enfant Plaza, S.W., Washington, D.C., at

9:00 a.m., Eileen Hoffman and Javier Ramirez,

Meeting Facilitators, presiding.

PRESENT

EILEEN HOFFMAN, Federal Mediation and 

 Conciliation Service, Facilitator

JAVIER RAMIREZ, Federal Mediation and 

 Conciliation Service, Facilitator

TED BANTLE, Federal Mediation and 

 Conciliation Service, Facilitator

JOHN CASKEY, National Electrical 

 Manufacturer's Association

KEITH DENNIS, National Rural Electric 

 Cooperative Association*

ISHBEL DICKENS, National Manufactured Home 

 Owners Association*

SCOTT DRAKE, East Kentucky Power 

 Cooperative*

MARK EZZO, Clayton Homes, Inc.*

JOSEPH HAGERMAN, U.S. Department of Energy

RICHARD HANGER, Housing Technology and 

 Standards*

BERT KESSLER, Palm Harbor Homes, Inc.*
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ERIC LACEY, Responsible Energy Codes 

 Alliance

MICHAEL EMANUEL LEVY, Systems Building 

 Research Alliance*

MICHAEL LUBLINER, Washington State 

 University Extension Energy Program*

ROBERT LUTER, Lippert Components, Inc.*

RICHARD POTTS, Virginia Department of 

 Housing and Community Development

ROBIN ROY, Natural Resource Defense Council

MANUEL SANTANA, Cavco Industries*

PETER SCHNEIDER, Efficiency Vermont*

LOIS STARKEY, Manufactured Housing Institute

DAVID TOMPOS, NTA, Inc.

LOWELL UNGAR, American Council for an 

 Energy-Efficient Economy

MICHAEL WADE, Cavalier Home Builders*

MARK WEISS, Manufactured Housing Association 

ALSO PRESENT

EDWARD BARBOUR, Navigant

MICHAEL JENSEN, Office of General Council, 

 U.S. Department of Energy

RICK MENDLEN, Department of Housing and

 Urban and Urban Development

KAVITA VAIDYANATHAN, Office of General 

 Counsel, Department of Energy

MATTHEW WALKER, Navigant

*present via teleconference
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 TABLE OF CONTENTS

 Page

Welcome and Introduction

 Eileen Hoffman . . . . . . . . . . . 4

 Javier Ramirez . . . . . . . . . . . 6

Opening Remarks

 Javier Ramirez . . . . . . . . . . . 7

 John Caskey. . . . . . . . . . . . . 8

Agenda Review

 Javier Ramirez . . . . . . . . . . .13

2015 IECC Subcommittee Recommendations

 Manuel Santana . . . . . . . . . . .15

Straw Man

 Emanuel Levy . . . . . . . . . . . 129

Public Comment . . . . . . . . . . . . . . . 325
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1 P-R-O-C-E-E-D-I-N-G-S

2 (9:04 a.m.)

3 MS. HOFFMAN: Good morning. I'm

4 Eileen Barkas Hoffman, one of your co5 facilitators for the Manufactured Housing

6 Working Group Negotiated Rulemaking.

7 My colleague, Javier Ramirez, and

8 Ted Bantle. We have got a lot to do today and

9 tomorrow and I think the first way to get

10 started is to see first, introduce who is in

11 the room and then who is on line. So, can we

12 start with you, Joe?

13 MR. HAGERMAN: Joe Hagerman, DOE.

14 MR. LACEY: Eric Lacey, Responsible

15 Energy Codes Alliance.

16 MS. STARKEY: Lois Starkey, the

17 Manufactured Housing Institute.

18 MR. UNGAR: Lowell Ungar, American

19 Council for an Energy-Efficient Economy.

20 MR. POTTS: Richard Potts, Virginia

21 Department of Housing and Community

22 Development.
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1 MR. WEISS: Mark Weiss, Manufactured

2 Housing Association for Regulatory Reform.

3 MR. TOMPOS: David Tompos, NTA.

4 MR. BANTLE: Ted Bantle, FMCS.

5 MR. CASKEY: John Caskey, NEMA.

6 MR. ROY: Robin Roy, Natural

7 Resources Defense Council.

8 MR. WALKER: Matthew Walker,

9 Navigant.

10 MR. BARBOUR: Ed Barbour, Navigant.

11 MS. VAIDYANATHAN: Kavita

12 Vaidyanathan, DOE General Counsel's Office.

13 MR. RAMIREZ: And Javier Ramirez

14 with Federal Mediation and Conciliation

15 Service.

16 MS. HOFFMAN: Great, thank you. 

17 Now, I would like to read who is on the line. 

18 And if anyone else is there, let us know.

19 Ishbel Dickens, National

20 Manufactured Home Owners Association; Scott

21 Drake, East Kentucky Power Cooperative; Mark

22 Ezzo, Clayton Homes; Richard Hanger, Housing
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1 Technology Standards; Rob Luter, Lippert

2 Components; Manny Santana, Cavco Industries;

3 and Michael Wade, Cavalier Home Builders.

4 Have we missed anyone who is online

5 who is a delegate member?

6 MR. LEVY: Emanuel Levy, SBRA.

7 MS. HOFFMAN: Oh, thank you. 

8 Emanuel Levy, okay.

9 Let's now hear who are audience

10 public participants.

11 MR. MENDLEN: Rick Mendlen, HUD.

12 MS. HOFFMAN: Anyone on the line who

13 is from the public?

14 Okay, so we have got a busy day. 

15 Eileen Hoffman again from FMCS. I am one of

16 your co-facilitators. And basically, first we

17 will just see if there are any housekeeping

18 comments.

19 MR. RAMIREZ: Yes, I have just a

20 couple. One of them, I just ask you to be

21 careful with the cords. There is quite a few

22 of them that are around the table there. So,
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1 make sure you don't trip over any of those.

2 We were asked that if you could

3 provide, Debby, the lady that was at the door

4 making sure that we could all get in, if you

5 could provide her a card, she likes to keep

6 record of everyone that was here.

7 And then make sure that you state

8 your name for Cameron, our court reporter, for

9 today before you make any comments.

10 And folks that are online, if you

11 could please just mute your phones until you

12 want to say something just to help minimize

13 any potential feedback.

14 Okay, those are the housekeeping.

15 MS. HOFFMAN: Okay, great. Any

16 opening remarks from any of the Working Group

17 members?

18 MR. LEVY: This is Emanuel. Your

19 signal is going in and out. I am just

20 wondering if it is me or other people on the

21 line that are having the same difficulty.

22 MR. MENDLEN: This is Rick. I am
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1 having the same issue.

2 MR. HANGER: This is Rob. I'm only

3 experiencing when Javier is talking. There is

4 some static associated with his signal. But

5 others that are speaking, I don't have the

6 same.

7 MR. RAMIREZ: Okay, we are going to

8 check the connections here because we are all

9 squeaking. And I will just make sure that I

10 speak up with I talk. Was that any better?

11 MR. LEVY: That's static free for

12 me.

13 MR. LUTER: That's better.

14 MR. RAMIREZ: Okay. All right,

15 thanks.

16 MS. HOFFMAN: Okay, so everyone,

17 hopefully, can hear us and hear themselves. 

18 Yes, John Caskey?

19 MR. CASKEY: This is John Caskey at

20 NEMA and also the ASRAC representative. Can

21 you hear me okay on the phone?

22 MR. LEVY: Yes.
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1 MR. MENDLEN: Yes.

2 MR. CASKEY: Okay, I just wanted to

3 give a quick update. One piece of information

4 is that at the last meeting that I attended,

5 basically I think the Working Group concluded

6 that they weren't going to get all the work

7 done on the original schedule of October

8 first, which is today. So, I had filed with

9 the ASRAC, the other ASRAC members to get

10 basically an extension until November 1. So,

11 we did that, I think, earlier this week and we

12 did get that extension for your work, final

13 recommendations to be due by November 1. So,

14 there was unanimity in the ASRAC members to

15 grant you that extension.

16 But, at the same time, still some

17 concern relative to trying to get things

18 wrapped up. I mean so you have these two day

19 meetings. You have it penciled in for Denver

20 in mid-October, I think like the 23rd and 24th

21 but November 1 is still a month away,

22 essentially. 
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1 So, in preparation for today's

2 meeting, I looked through some of the analysis

3 that is done and there is a huge amount of

4 analysis done. I think it is all very good. 

5 I think you are getting a lot of good

6 information that, otherwise, wouldn't have

7 been collected and assessed without doing the

8 negotiated rulemaking. But at the same time,

9 I went through my notes from our first

10 meeting, talking about the Department of

11 Energy ground rules relative to the negotiated

12 rulemaking and then also, the proposed

13 framework for developing term sheets and some

14 other information that was provided there.

15 So, from my perspective, it seems

16 like you have been given what you need to do

17 sort of on a silver platter here in terms of

18 the proposed framework for developing the term

19 sheet and some other guidelines. So,

20 basically I think we are in sort of the 11th

21 hour and you need to start putting sort of pen

22 to paper in order to figure out exactly what
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1 you do want in the term sheet and, hopefully,

2 what you want above and beyond the status quo,

3 as we know of it today.

4 So, anyway, I urge you to work, do

5 the best you can over the next few days. I am

6 going to be in and out a little bit but if I

7 can be of any help, let me know. But

8 otherwise, again, I urge you and sort of

9 challenge you to try and get some rough ideas

10 out even today or early tomorrow that you can

11 start working on that you would consider,

12 essentially, a draft that we could turn over

13 to DOE for them to do their massaging to

14 actually turn it into a rulemaking document.

15 So, I don't know if Joseph has

16 anything more to add to what I have said. But

17 again, it is a golden opportunity for you to

18 really lead the industry and lead the

19 manufactured housing energy efficiency

20 requirements. I urge you to roll up your

21 sleeves and get the job done.

22 MR. HAGERMAN: So, this is Joe
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1 Hagerman, DOE. I will second those comments

2 and just say I have been seeing a lot of back

3 and forth with all the analysis and the

4 discussion. I think we are going to have an

5 incredibly productive two days. I think that

6 we will get, hopefully we will get 85, 90

7 percent of the way over the next two days. 

8 And then we will talk about the three weeks

9 in-between and see if we need Denver or not.

10 But I am encouraged. I think this

11 group, we have come a long ways. It seems

12 every time we get asked to do an analysis,

13 when we run the analysis, it only moves to the

14 second decimal place on the annual energy

15 savings. So, that means, I think that means

16 to everybody that we have kind of hit the

17 sweet spot. Right? And we should just settle

18 on that and codify the sweet spot and write

19 the term sheet. But I agree with your

20 comments that I don't think we could have

21 gotten to this level of detail without this

22 consensus group and these meetings. This has
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1 been extremely productive for the Department

2 and, I hope, for the industry as a whole.

3 MS. HOFFMAN: Yes, and we, as

4 facilitators, want to compliment the hard work

5 of all of the members. You have taken your

6 job very seriously and, hopefully, you will

7 have a successful outcome.

8 Are there any other comments before

9 we get started?

10 Okay, then the next order of

11 business and the agenda is on the board behind

12 you and also online on the computer, we will

13 hear from Manny Santana on the 2015 IECC

14 scope.

15 MR. RAMIREZ: Yes, and Manny, before

16 I have you pick up where we left off last

17 time, let me review the entire agenda, and

18 then we will come back.

19 MS. HOFFMAN: Okay.

20 MR. RAMIREZ: So, we are going to

21 have Manny -- if you remember, we fell a

22 little short being able to get through the
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1 entire list to get put together. And if there

2 is any updates, that would be great.

3 So, we are dealing with that. Then,

4 we are going to ask Matthew to run through,

5 briefly, the latest LCC scenario that he ran

6 and make sure that we understand that. And I

7 believe that was some of the information that

8 Emanuel had used to draft the straw man that

9 he is going to walk through.

10 I am hoping that, kind of to Joe's

11 point and John's, is that let's assume that

12 what Emanuel is presenting is acceptable. 

13 Right? And let me finish this thought here. 

14 That it is acceptable and where is the harper

15 with the document. Where are the points that

16 you think that we need to address and let's

17 try to focus our attention on those specific

18 areas, instead of trying to tear apart the

19 whole document and analyze the entire

20 document. Let's find those areas where there

21 is harper and have discussion on that.

22 I'm assuming that we might take the
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1 rest of the day looking through that and

2 seeing if we can't reach some type of

3 consensus. And if not, then we have tomorrow

4 set aside to continue that discussion, as well

5 as any subcommittee reports.

6 We also want to see if we can take

7 some action items on the climate zones, the

8 compliance pass, if needed, and any other

9 items that we can finalize.

10 So, is there any question, as far as

11 what we have put together for the agenda?

12 Okay, then Manny, are you prepared

13 to finish walking us through your document? 

14 We only had a little bit left, unless you made

15 some revisions.

16 MR. SANTANA: I don't have any

17 additions but the few items that are left are

18 the ones that we didn't come to a consensus

19 on.

20 This is Manny with Cavco, by the

21 way. I apologize.

22 So, what I recall is that we left
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1 off on Table 402.4.1.1.

2 MR. RAMIREZ: Okay, let's give

3 everyone a second to find that document, if

4 they need to.

5 MR. HAGERMAN: Here are some copies

6 from last week.

7 MR. RAMIREZ: Does anyone need one?

8 MR. LUBLINER: I have an extra copy

9 of the IECC, if somebody wants to look on.

10 MR. RAMIREZ: Does anybody else need

11 a book?

12 Okay, Manny, I think we are good.

13 MR. SANTANA: Okay, now just to

14 recap, we got through all the way to the rim

15 joists. So, if you can scroll down a little

16 bit. Right there.

17 So, we skipped the floor. We went

18 through the crawlspace and we got through the

19 plumbing and the wiring. So, now we are back

20 at the floor.

21 So, the thing about the floor, the

22 floor, the criteria column is the addition of
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1 the sentence at the bottom where they serve as

2 an air barrier. And that is where we left

3 off.

4 And the issue that circulates around

5 this is due to the fact that manufactured

6 homes have a different type of construction

7 when it comes to the floor that you don't see

8 in stick-built with the bottom board, which is

9 a sheet that manufacturers have in-between the

10 floor joists and insulation and the frame

11 below. And so that is unique to manufactured

12 housing. And because of that, the definition

13 of an air barrier at the floor interface is

14 not the same between MH and stick-built.

15 And the committee thought that

16 because of that, the way that the air barrier

17 is considered at the floor should be

18 different.

19 MR. RAMIREZ: Are there any

20 questions on that one?

21 MR. LUBLINER: This is Mike

22 Lubliner.
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1 MR. RAMIREZ: Okay. Yes, we hear

2 you Mike.

3 MR. LUBLINER: Yes, I guess this is

4 where we disagree. My feeling is that the

5 bottom board, if it is being considered the

6 air barrier, it may be providing some air

7 resistance but the primary air barrier in

8 manufactured homes is the floor. And that is

9 why we caulk the penetrations in the floor.

10 And the floor can be relied on as a

11 pressure barrier. And if you don't rely on

12 the floor as a pressure barrier, my experience

13 is that the bottom board, over the life of the

14 home, will be compromised in a way that it

15 will not provide the pressure resistance

16 necessary.

17 And so, I don't understand why some

18 of the people on the committee that are saying

19 that the bottom board is the pressure barrier

20 and others on the committee are saying it is

21 the floor. But my feeling is is the floor and

22 that is the way have designed things. I think
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1 I sent a quality assurance manual out for

2 manufactured housing that shows air sealing,

3 all the penetrations in the floor. We talked

4 about air sealing penetrations in the floor. 

5 And again, if we are sealing the floor, then

6 why isn't that the primary barrier?

7 I don't see a difference between

8 site-built homes here and manufactured homes. 

9 They both have insulation in the floor. The

10 belly blanket is there for a rodent barrier. 

11 And it is true that there is some gap, there

12 is a little void between the underside of the

13 decking and the belly insulation. And that is

14 acceptable, as long as the rim joist has been

15 insulated to the I-beam and packed with

16 insulation, as some of the details I have sent

17 note.

18 So, my feeling is it is going to be

19 hard to get through this one because we

20 disagree, fundamentally, I believe, on what

21 the bottom board is serving as. I believe it

22 is the pressure boundaries, the floor, and the
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1 bottom board is the rodent barrier.

2 MR. RAMIREZ: Okay, Richard?

3 MR. POTTS: Richard Potts. So, we

4 talked about this at the last meeting quite a

5 bit. So, can we get a chance to maybe

6 rebuttal and if not, do a temperature test or

7 just vote on it, just to move ahead?

8 MR. RAMIREZ: Sure.

9 MR. POTTS: Like Mike said, I don't

10 think people's views are going to change or

11 one side is going to convince the other that

12 -- I mean maybe there is some people stuck in

13 the middle but I think a lot of people have

14 made up their minds as far as what they feel

15 that barrier is.

16 MR. RAMIREZ: David?

17 MR. TOMPOS: Yes, I agree. I think

18 the last time we talked about sealing of the

19 floor, and if we go through those prescriptive

20 methods that we, I think, already agreed to,

21 the floor is going to be the pressure. You

22 know we are also going to have this additional
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1 bottom board that is, in addition, going to be

2 also helpful. But the primary air barrier --

3 you know I don't even know if we need this

4 section here because we already addressed it

5 in the prescriptive sealing requirements.

6 MR. RAMIREZ: Well, which section

7 are you --

8 MR. TOMPOS: The floor line here,

9 this whole --

10 MR. HAGERMAN: Joe Hagerman, DOE. 

11 Luby, would it help if -- I am kind of

12 remembering things like David. I think that

13 we already said that the floor, all the

14 penetrations in the floor are going to be

15 sealed in the air sealing stuff that we talked

16 about.

17 Would it be suitable for you, and

18 here is just a straw man here, if we reiterate

19 in this section that the floor is sealed,

20 period, and then just say the air barrier

21 shall be installed at any exposed edge of

22 insulation, period?
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1 So, just kind of call back to the

2 proper sealing techniques that we have on the

3 floor system, just to reiterate them here?

4 MR. LUBLINER: Yes, so I would

5 suggest the way it should be the floor is the

6 primary pressure barrier. The belly board or

7 rodent barrier is a secondary pressure barrier

8 that cannot be relied on as the primary

9 pressure barrier.

10 MR. HAGERMAN: This is Joe Hagerman,

11 DOE. I think he is saying that the floor is

12 the primary -- I would say a properly sealed

13 floor is the primary pressure barrier.

14 MR. RAMIREZ: And then Lowell?

15 MR. UNGAR: Yes, can I ask what is

16 the practical difference this makes? This

17 seems to have deleted all criteria from this. 

18 Given that we have a separate requirement on

19 sealing of the floor, it is not clear to me

20 what the effect is of declaring the air

21 barrier.

22 MR. RAMIREZ: Michael, do you have a
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1 response to that one?

2 MR. LUBLINER: Yes, so you know

3 where you are supposed to be sealing. The

4 primary air barrier is what it is you are

5 supposed to be sealing.

6 So, that is why I say the belly may

7 serve as an air barrier but the primary air

8 barrier is the sealed floor. And you can

9 reference the penetrations that should be

10 sealed in somewhere else but it is already

11 provided prescriptively by Emanuel Levy.

12 Anyway, but my feeling is we can

13 either add something about the floor as the

14 primary and note that the belly may serve as

15 an additional air barrier. I am comfortable

16 with that but that is about as comfortable as

17 I am, given my adamant feeling about this, in

18 terms of building science. 

19 MR. RAMIREZ: Manny, --

20 MR. LUBLINER: Isn't the primary -- 

21 MR. RAMIREZ: Manny or --

22 MR. LUBLINER: I'm going to shut up.
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1 MR. RAMIREZ: -- what do you think

2 of that?

3 MR. SANTANA: Manny here with Cavco. 

4 You know I know that it was just last week,

5 but I've already forgotten. Now, didn't we

6 agree last week that we were going to seal all

7 penetrations along the floor? I agree with

8 Lowell, that we might be getting -- I think

9 any language here might just complicate the

10 issue. You know, I don't know if Navigant or

11 if Matthew has the ability to pull up the

12 document from last week, but there are details

13 there that I would like to pull up on the

14 screen. And I think that will illustrate to

15 everybody that the potential issue involved in

16 identifying what is the air barrier, primary

17 air barrier, secondary air barrier and so on. 

18 Can you look at the last page?

19 So, if you go to the last page and

20 you see the detail on the bottom, there is

21 Figure 4.8. And you see the squiggly lines is

22 the insulation. This is how a typical floor
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1 is built. And so there is a sheet that goes,

2 that follows the line of the insulation

3 underneath the floor. So, you are going to

4 have a problem if you seal the floor and you

5 don't seal the bottom board. Because if air

6 can get into the bottom board and get on top

7 over the insulation, then the insulation is no

8 good, even if the floor is sealed.

9 So, there is an issue with not

10 sealing the bottom board and there is an issue

11 with not sealing the floor.

12 So, rather than getting into

13 primary, secondary, rather than getting into

14 even identify what the air barrier is at the

15 floor, we have already decided or we have

16 already agreed to seal penetration in the

17 floor. Why don't we just pull back a little

18 bit and look at it from a more general

19 perspective and say at the floor, penetrations

20 at the floor should be sealed? And then just

21 leave it.

22 MR. RAMIREZ: So, you are saying
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1 that we can modify that. What do you think of

2 that, Michael?

3 MR. LUBLINER: I think that the

4 reason that we are caulking the floor is

5 because it is the primary air barrier and we

6 don't need to talk about the belly at all. We

7 can just say the floor is the primary air

8 barrier and that all the penetrations that we

9 reference need to be sealed. That is my

10 feeling.

11 As far as the insulation in the

12 floor, there was some information sent out

13 that showed that if the floor is, in

14 effective, that little hole area between the

15 I-beams where the insulation doesn't come in

16 full contact with the decking, as you can see

17 there, that is okay. And so, that is what is

18 happening now and is okay. And when we

19 insulate the floor to a higher level, we are

20 going to end up dense packing between the I21 beam and the rim and it is going to limit the

22 air infiltration that Manny was talking about.
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1 Again, all they are doing with this

2 belly board is stapling it to the rim joists. 

3 So, there is no way that -- I mean if air

4 wants to get it, the air is going to get in

5 through the rim joist. The more insulation up

6 there, the more it is going to limit that air

7 that is getting in through these staples in

8 the rim joists from impacting the temperature

9 in that belly space.

10 So, I don't know. It is true that

11 is an issue. It is an issue now. It is going

12 to be an issue in the future, which is why I

13 explicitly suggested that the area between the

14 I-beams, the insulation goes down under the

15 truss and doesn't need to -- it can be

16 exempted from being in full contact with the

17 floor because you have a good air barrier in

18 the floor and you have a reasonable secondary 

19 air barrier with the insulation and the belly

20 blanket and the packed insulation in the

21 joists.

22 So, again, if we are going to be
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1 sealing the floor, then that is going to be

2 the primary air barrier.

3 So, I guess, at this point, that is

4 how I feel. I can vote negative on it, if

5 others feel -- or we can just move on and

6 leave this as one for DOE to look into is my

7 feeling.

8 MR. RAMIREZ: The problem is --

9 MR. HAGERMAN: So, Luby, again, I

10 think Manny gave us a suggestion that, and

11 everybody in the room was kind of nodding

12 their heads yes, that we just have the

13 language that penetrations at the floor should

14 be sealed and maybe a friendly amendment to

15 use a parenthesis that says penetrations at

16 the floor should be sealed as the floor

17 becomes the primary air barrier -- sorry --

18 pressure barrier. And then it seems like we

19 might have closure on that.

20 MR. WADE: Joe, can you hear me?

21 MR. HAGERMAN: Yes.

22 MR. WADE: This is Michael Wade with
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1 Cavalier. I wanted to add one more comment

2 that may be of value to the manufacturers and

3 this, actually, is in support of Mike's

4 argument there.

5 You know, historically, we as

6 manufacturers typically in our design packages

7 or basket manuals, as we fondly call them, we

8 a lot of times have had notations that

9 actually would allow either the bottom board

10 or the floor to be the pressure envelope. 

11 However, as the industry has historically used

12 the bottom board, it has kind of left us

13 subjective over our kind of open, susceptible,

14 however you want to put it to easy write-ups

15 by the EPF, of state IBPS, whoever, when we

16 have little cuts or tears in the bottom

17 boards, which Luby is pretty accurate on, it

18 is inevitably going to happen.

19 So, maybe a positive for us in the

20 industry if we do view the floor as the

21 pressure envelope and declare that in our

22 design packages, then we do have a cut or tear
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1 in the bottom board, then that, in essence,

2 would no longer be a write-up. So, that is

3 something to consider.

4 MR. RAMIREZ: David?

5 MR. TOMPOS: Michael, I don't think

6 that is going to get you out of a write-up. 

7 You are still going to have rodent protection

8 that you will have to deal with. So, I am

9 still going to write you up when you tear your

10 bottom board.

11 (Laughter.)

12 MR. WADE: We always can count on

13 you, David.

14 MR. RAMIREZ: So, one question I

15 have -- sorry. Is someone on the line?

16 MS. DICKENS: This is Ishbel. I

17 just wanted to, before you take the vote,

18 should the "should" be "shall?"

19 MR. RAMIREZ: So, do we strike

20 number one and the opening paragraph and is it

21 just number two or do we need that opening

22 sentence as well?
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1 MR. LUTER: This is Rob. Well, you

2 have stricken it now but I have been wondering

3 what the relevance of that opening sentence

4 was.

5 MR. RAMIREZ: Well, I'm going to

6 hold you on that because it looks like we are

7 going to strike that. 

8 MR. LUTER: Okay.

9 MR. RAMIREZ: So, it may be

10 irrelevant.

11 So, let me see a show of thumbs if

12 everyone is okay with number two.

13 MR. UNGAR: I realize this is picky 

14 but air barrier is a defined term in IECC and

15 I don't think pressure barrier is. Is air

16 barrier or pressure barrier the right term?

17 MR. HAGERMAN: Well, if we want to

18 use pressure barrier, we can get Navigant to

19 define pressure barrier.

20 MR. UNGAR: And it is not critical. 

21 I'm just saying they are different and I am

22 just asking.
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1 MR. HAGERMAN: It seems like

2 Michael's made them different in his

3 explanation of the two different layers.

4 MR. UNGAR: Okay, I withdraw if that

5 is the case.

6 MR. RAMIREZ: So, let me see a show

7 of thumbs if you are okay with number two. 

8 Can you read that for us?

9 MR. BANTLE: Yes. Number two --

10 this is Ted Bantle -- penetrations at the

11 floor shall be sealed. And then in

12 parentheses, as the floor becomes the primary

13 pressure barrier, end parentheses.

14 MR. KESSLER: This is Bert, Palm

15 Harbor.

16 MR. BANTLE: Yes, Bert?

17 MR. KESSLER: Yes, I would like to

18 make one recommendation and change the term

19 floor perhaps to floor decking. Because when

20 I see the term floor, to me, that means all

21 the framing and the decking, whatever is part

22 of that component.
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1 MR. LUBLINER: Michael Lubliner

2 agrees with Bert.

3 MR. KESSLER: No! Really?

4 MR. HAGERMAN: Joe Hagerman, DOE. I

5 think you should say penetrations through the

6 floor decking shall be sealed, parentheses, as

7 the floor becomes the primary pressure

8 barrier, end parentheses, period.

9 MR. RAMIREZ: And then we can vote

10 on it. Because I think this issue took us an

11 hour last time and we didn't closure to it. 

12 It has taken 15 minutes here, let's just be

13 done with it.

14 (Simultaneous speaking.)

15 MR. SANTANA: I think that --

16 MR. RAMIREZ: Hold on a second

17 Manny.

18 MR. SANTANA: Okay.

19 MR. RAMIREZ: I'm sorry. Okay, go

20 ahead, Manny.

21 MR. SANTANA: The parentheses, it

22 doesn't add anything to the statement and
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1 introduces a new term that we don't currently

2 have. I think we can do without it.

3 MR. RAMIREZ: David?

4 MR. LUBLINER: I'm going to agree

5 with Manny but for a little different reason.

6 I think it modifies the first portion of the

7 sentence and implies that penetration shall

8 only be sealed as the floor becomes the

9 primary pressure barrier. And I think our

10 conversation has been one where we don't have

11 any choice. The floor is the primary pressure

12 barrier.

13 MR. RAMIREZ: David?

14 MR. TOMPOS: There is a definition

15 in the --

16 MR. LUBLINER: It is a grammatical

17 issue.

18 MR. TOMPOS: -- 3280 for pressure

19 envelope. It says pressure envelope means the

20 primary air barrier surrounding the living

21 space that serves to limit air leakage. So,

22 I don't know if we want to call it -- I know
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1 we keep saying pressure barrier but that code

2 does call it a pressure envelope.

3 MR. LEVY: Right but doesn't exist

4 in the IECC currently.

5 MR. RAMIREZ: You say it does or it

6 does not?

7 Let me get Mark Weiss. Hold on a

8 second, Michael. Go ahead.

9 MR. WEISS: Just a general point

10 that makes it obvious. To the maximum extent

11 possible, we should have consistency with what

12 we are doing. The part already defines that

13 that has been the existing practice. We

14 should continue to follow that definition and

15 not start modifying it, if at all possible.

16 MR. RAMIREZ: Michael?

17 MR. LUBLINER: Yes, I referenced

18 this definition 3280.502 and it defines

19 pressure envelope. And when reading this,

20 that is how I conclude that it is the floor

21 that is the pressure envelope.

22 And so I think that we are talking
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1 about the I Code but I think the definition in

2 the HUD Code of the pressure envelope is a

3 relevant one and is referencing the floor.

4 MR. WEISS: It is not only relevant,

5 it is binding right now.

6 MR. LUBLINER: Yes, I believe there

7 could be things that could be changed but this

8 one I don't think we want to change because it

9 is correct, in my opinion. It references

10 correctly the pressure envelope definition,

11 which is why are doing the floor.

12 But I think we are getting the round

13 and round on this one. I don't know if I am

14 going to change on this or others that are. 

15 We might want to just hold it and move on. I

16 don't know that it drives a lot of stuff, if

17 we have agreed already to sealing all those

18 points in the floor.

19 MR. HAGERMAN: So, I think everybody

20 agrees. I think we are comfortable giving a

21 thumbs, I mean with taking a vote here. And

22 I would say the only reason I added the
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1 parentheses was to kind of get Michael

2 comfortable with us recognizing the primary

3 pressure barrier, which is now the primary

4 pressure envelope.

5 MR. LUBLINER: Yes, I am

6 comfortable.

7 MR. CASKEY: John Caskey. Do we

8 want to change that word where it says

9 pressure barrier?

10 MR. HAGERMAN: I think you want to

11 change that to pressure envelope.

12 MS. HOFFMAN: So you want to read it

13 again and make sure it is --

14 (Simultaneous speaking.)

15 MR. RAMIREZ: Okay, so we are going

16 to, as soon as Ted is done with this last

17 edit, then we will read it and then check for

18 consensus.

19 Ted, would you mind reading that for

20 us?

21 MR. BANTLE: Penetrations through

22 the floor decking shall be sealed as the floor
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1 becomes the primary pressure envelope. And

2 then we just reference the code. I don't know

3 if that would be included or not.

4 MR. HAGERMAN: You just referenced

5 the 3280.502 as the definition of the pressure

6 envelope.

7 MR. RAMIREZ: Okay, just a

8 procedural thing. Cameron, are you good?

9 COURT REPORTER: Could I just remind

10 the people who are speaking online to

11 introduce themselves before they speak? I am

12 having trouble tracking who is who.

13 MR. RAMIREZ: Yes, Cameron is not

14 familiar with all of our voices yet.

15 Mark?

16 MR. WEISS: Just a question for

17 clarification for the technical folks, I

18 guess. If you are going to say primary

19 pressure envelope, is there some other

20 pressure envelope that we are going to be

21 identifying? So, why say primary? Primary

22 implies there is something that is secondary.
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1 MR. RAMIREZ: I think that was the

2 definition. I think that is how it is

3 defined.

4 MR. WEISS: And I there is further

5 explanation in IECC, that's fine.

6 MR. RAMIREZ: David is checking

7 right now.

8 MR. TOMPOS: It is not in the IECC. 

9 I would recommend that we just strike it.

10 MR. RAMIREZ: Strike primary?

11 MR. TOMPOS: Yes.

12 MR. UNGAR: The definition of

13 pressure envelope says primary air barrier.

14 MR. HAGERMAN: It is just redundant.

15 MR. LUBLINER: This is Mike

16 Lubliner. It is redundant.

17 MR. RAMIREZ: Okay, great. All

18 right, so let's see a show of thumbs if we are

19 okay with what is up on the screen there for

20 number two. Any thumbs down online? Okay,

21 then we have unanimous consensus on that one.

22 Okay, yes, Manny.
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1 MS. HOFFMAN: Manny, go on.

2 MR. SANTANA: Okay, Manny with

3 Cavco. So, over to the right on that same row

4 on the floor, over the right, that insulation

5 installation criterion, the subcommittee

6 recommended striking the entire section. It

7 had to do with the insulation being in contact

8 with the decking. And the reason for the

9 strikethrough is if you can see from the chart

10 that was up there previously, current

11 insulation installation practice of the floor

12 doesn't always have insulation in contact with

13 underside of the decking in the belly area.

14 And even if you put insulation

15 there, you are always going to have insulation

16 that follow the contours of the belly board

17 and comes underneath the decking. So, unless

18 you want to prohibit that, in almost every

19 case, you are almost never going to have all

20 the insulation up in contact with decking.

21 MR. RAMIREZ: Okay, any questions on

22 that recommendation?
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1 MR. LUBLINER: Mike Lubliner.

2 MR. RAMIREZ: Yes, Michael?

3 MR. LUBLINER: Yes, I think that

4 what we want to do is we want to exempt the

5 requirement for underside contact with the

6 insulation with the subfloor decking between

7 the I-beams. But I think it is crucial that

8 we have underfloor contact from the I-beam to

9 the rim joists. And I sent off the quality

10 assurance manuals that we use that have

11 section drawings that explicitly detail all

12 those out with different floor insulation

13 systems. But you have to have the rim joists

14 full, at least the floor joists full from the

15 rim to the I-beam is doable with the

16 insulation levels we are talking about. You

17 can pack that. That will also help limit the

18 air infiltration concern that was expressed

19 because the air goes through the nails if it

20 is packed up to all the belly board and could

21 go right through that gap, if there is a gap

22 from the joists to the I-beam and then really
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1 screw up the insulation performance, which we

2 want to avoid.

3 So, I am suggesting this is okay if

4 it is only limited to the space between the I5 beams, I am okay with this language.

6 So, you can do it by leaving the

7 language the way it is and say exception,

8 insulation installed between the I-beams and

9 under the crossover duct.

10 MR. RAMIREZ: David?

11 MR. TOMPOS: Well, first of all, I

12 don't think there is any way with the amount

13 of insulation that we are putting in that we

14 are not going to be in contact. But my

15 question for Michael would be, are you

16 suggesting that we -- how are we going to

17 handle perimeter ducts? Because typically

18 that insulation is under the duct and not in

19 contact with the floor decking.

20 You mentioned the crossover duct. 

21 But we also have been using other perimeter

22 ducts that go out into that outrigger section. 
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1 So, we need to address that.

2 MR. LUBLINER: This is Mike

3 Lubliner.

4 Yes, I think that the exception, it

5 is wherever you have -- if you have those

6 perimeter ducts, you are going to have

7 compression of the insulation there. And you

8 are right, you may not have the coverage right

9 underneath the decking for directly over the

10 ducts. And I think that is just part of that

11 insulation compression analysis that you have

12 to do for the floor. And I am okay with that,

13 obviously, not being in contact for that.

14 So, that could be another exception,

15 insulation between the crossover duct and I16 beam and insulation displaced by --

17 MR. TOMPOS: Ductwork.

18 MR. LUBLINER: What do you call it? 

19 Yes, by ductwork. Does that work for you,

20 Dave?

21 (Simultaneously speaking.)

22 MR. TOMPOS: I think that will work,
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1 unless there is any other manufacturer that

2 foresee another concern or issue that I am not

3 thinking of.

4 MR. KESSLER: Well, this is Bert,

5 Palm Harbor. 

6 If we want to list all of the

7 exceptions, we had better add plumbing to it

8 as well.

9 MR. TOMPOS: You know I am wondering

10 if we really are -- if these even needs to be

11 addressed. You know we are talking about a

12 five and a half-inch space. And I don't think

13 we are talking, I would have to look at the

14 last numbers, but are we looking anywhere at

15 anything less than an R-22? I mean we are

16 fully packing this to the point where I don't

17 think we are going to have -- I don't think we

18 are going to be able to not be in contact with

19 the floor.

20 So, my question is, are we making an

21 issue that maybe not be really an issue?

22 MR. LUBLINER: This is Mike
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1 Lubliner. To the extent if you are adapting

2 it, I certainly have a question about it. I

3 think that Bert is right, plumbing could also

4 fall into getting in the way of the coverage. 

5 But I can't think of anything really other

6 than the ductwork and the plumbing that would. 

7 So, I am comfortable with the exceptions here

8 and I think it does make it more explicit so

9 that there is no question between the quality

10 assurance folks on what is exempt and what is

11 not when it comes to floor coverage.

12 So, I am okay with it. I think it

13 helps provide more specificity to the quality

14 assurance plan.

15 MR. HAGERMAN: Joe Hagerman, DOE. 

16 So, I think we are un-striking the first part

17 of the sentence. Is that correct?

18 MR. SANTANA: Manny with Cavco. 

19 Before we do that, I would like to see what it

20 looks like on the existing suggestion without

21 the exception.

22 MR. HAGERMAN: Joe Hagerman, DOE. 
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1 The problem is we have, it seems like we would

2 need some criteria for the floor insulation

3 installation. Right? It seems like you would

4 have to -- where you have this table, it seems

5 like all the cells should be filled out,

6 unless we have just deleted a whole entire

7 row. Right?

8 Also, we don't have any criterial

9 for the insulation of the floor installation. 

10 That's a mouthful.

11 MR. UNGAR: This is Lowell. I would

12 just add it looks to me like we currently have

13 down to R13 for the floors in some regions. 

14 So, in answer to your question, yes, I do

15 think we have much less than R22 in some

16 areas.

17 MR. TOMPOS: That still would be --

18 MR. SANTANA: You know I agree but I

19 think that the insulation criteria should be

20 similar to walls so that there is no voids in

21 the floor.

22 And really the only thing that I
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1 think was an issue in the floor section was

2 the requirement that the insulation be in

3 contact with the decking. That is the only

4 item that derailed the train, so to speak.

5 MR. RAMIREZ: And so, Manny, what

6 concerns would you have in having that

7 language in there?

8 MR. SANTANA: Well, you know the

9 language that was in the IECC currently didn't

10 really talk about anything other than contact

11 with the decking, as you can see.

12 MR. HAGERMAN: Right. Joe Hagerman,

13 DOE. So if we just kept the first part of

14 that struck out sentence that said floor

15 framing cavity insulation shall be installed

16 to maintain permanent contact with the

17 underside of the floor decking -- subfloor

18 decking with the following exceptions, which

19 is insulation between the crossover duct,

20 comma, I believe comma, the chassis girder

21 beam, comma, and insulation displaced by

22 ductwork and plumbing.
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1 MR. SANTANA: You know okay, so I

2 would edit that a little bit. Rather than --

3 this section here for floors was really the

4 only concern was contact with the decking,

5 when I think the concern should be insulating

6 every cavity in the floor. You know, so

7 rather than saying floor trimming, cavity

8 insulation. So, how about floor trimming

9 cavity shall be fully insulated and void of

10 voids with the exception of and then you have

11 the exception there.

12 MR. HAGERMAN: Okay.

13 MR. SANTANA: Because as they have

14 said it, the insulation, you know these floors

15 are typically built with two by sixes or two

16 by eights when the floors get bigger. With

17 the insulation that we are calling out, they

18 are going to be jam-packed outboard of the I19 beams. So, I don't think that is a concern.

20 And I think it is almost a secondary

21 requirement to say everything is going to be

22 in contact with the decking when what you
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1 really want is to have every cavity insulated.

2 MR. RAMIREZ: Mark?

3 MR. KESSLER: This is Bert, Palm

4 Harbor. 

5 Mike Lubliner, your concern for that

6 area outside the I-beams to be completely

7 filled is so that the rim joist is completely

8 insulated?

9 MR. LUBLINER: Yes, that is one of

10 the requirements that you get the rim joists

11 completely insulated. When we go on quality

12 assurance checks in the factory, you are

13 walking around at the floors and if you see an

14 exposed rim joist, you know they haven't done

15 the floor insulation correctly. It needs to

16 cover that.

17 And as has been noted is if you have

18 a two by six or a two by eight, you are going

19 to adjust the belly insulation relative to

20 that floor insulation and you are going to run

21 a bat insulation or blown insulation in the

22 floor so you can then pack that space from the
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1 I-beam to the rim joist. And so there is full

2 coverage at the decking there.

3 And the exception that I am talking

4 about comes at the I-beam to the next I-beam,

5 where we are not asking you to fill the whole

6 belly, we are just wanting to make sure that

7 the insulation is allowed to not be in contact

8 with the underfloor of the decking in that

9 area.

10 I don't know if that answered your

11 question. I am comfortable with the language

12 that is being proposed here.

13 MR. KESSLER: Well, the only reason

14 I brought it up because I think it is pretty

15 common practice to treat the exposed vertical

16 area of the rim rail as if it were a wall. 

17 And I know we have in our package a

18 requirement that if the floor insulation is

19 not as deep as the floor framing itself, and

20 you install it back around your rim rail with

21 the same R value as what is in the wall.

22 MR. RAMIREZ: Mark?
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1 MR. WEISS: This is a different

2 point. So, if there is any further

3 conversation that you want to finish out.

4 MR. RAMIREZ: Michael, are you good

5 with that?

6 MR. LUBLINER: Yes. I mean if you

7 call it -- I call it the wall insulation on

8 the vertical. But what I am saying is is that 

9 floor contact, the exception of floor contact

10 should only be allowed between the I-beams. 

11 That is how we have been doing it for years. 

12 We fill in the I-beam. If it is a two by six,

13 you can get up to R21 in there. If it is a

14 two by eight, you can get R25. And that is

15 what you do and you fill it. It goes across

16 the I-beam and down. Those drawings that we

17 set out, we want to the show those to the

18 group at some point. I think many of them

19 have probably seen our program drawings.

20 But I guess I am good with what the

21 language is here right now. And I would

22 interpret this as what I said.
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1 MR. RAMIREZ: All right. I want to

2 see because it seems like we are going in

3 circles, at least to me it does. It sounds

4 like we are okay. But David -- 

5 MR. TOMPOS: The more I look at it,

6 I am a little concerned that we aren't okay. 

7 Now, we are changing it not just to be in

8 contact but we are saying that it has to be

9 fully insulated. So, let's say I have a wider

10 unit, a 16-wide and we are using two by eight

11 floor joists in the southern regions where I

12 may only require an R13, based on what Michael

13 is saying, we need to put an R25 in there.

14 So, we are doing a lot more here

15 than just saying that it needs to be in

16 contact with the floor decking. We are saying 

17 it needs to be fully insulated. 

18 MR. HAGERMAN: But if we just struck

19 out the word fully there. Of course it has to

20 be insulated per whatever your U value

21 calculation is. Right?

22 MR. TOMPOS: Right.
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1 MR. HAGERMAN: It is just the word

2 fully there.

3 MR. TOMPOS: And then I have some

4 concerns on how do you maintain that contact

5 with that floor decking? I mean typically, it

6 is a blanket that is put in and then they cut

7 it so that it does fit up into those areas. 

8 But gravity has a tendency to pull things

9 down.

10 MR. RAMIREZ: Mark.

11 MR. WEISS: Well, David's comment

12 kind of leads into what I was going to talk

13 about. Mark Weiss MHARR. 

14 My concern is with the word

15 permanent. Because if you fit this into

16 something that is a HUD's enforcement

17 mechanism, you have something called subpart

18 I that has no time limitations on it. And

19 permanent really could be permanent. I could

20 be 30 years down the road somebody comes in

21 and complains hey, this is not making contact,

22 whatever. You have to go through a whole
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1 investigation as to what happened over the

2 last X number of years.

3 So, any indication of the word

4 permanent is of great concern.

5 MR. RAMIREZ: David.

6 MR. TOMPOS: I guess this is a

7 question for Michael. The purpose of being in

8 contact and you talked about dense packing,

9 the whole purpose here is to stop air flow. 

10 And we also have other provisions that we

11 added in the sealing of the rim joists in the

12 floor, in the different contact areas that

13 should prevent any air movement in that area.

14 Are we being redundant here? If you

15 read the article that I sent out by Joe

16 Lstiburek, that basically explains that the

17 reason why the whole provision was put in in

18 the first place was because, in a typical

19 home, you have a crawlspace. There is nothing

20 to stop the air from circulating under those

21 floor cavities. In through that bat

22 insulation, you get a convection going on
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1 there. But since we have the bottom board and

2 we are sealing the rim joists the way we are,

3 I am just wondering if we are trying to solve

4 a problem that may not be there. It may not

5 be as critical as some of the other provisions

6 that we have added.

7 MR. SANTANA: Manny with Cavco. I

8 think that Mark and Dave have shared exactly

9 what I think the problem is with this thing is

10 we are going to introduce a mandatory

11 requirement into the standard that it could be

12 nearly impossible for us to verify. We can

13 verify at the plant when it was installed but

14 we would have to get through those compression

15 process and these homes sometimes travel a

16 thousand miles before they get to where they

17 get to.

18 And so as Mark pointed out, we have,

19 there is a penalty structure for the industry

20 that typically is currently and it is commonly

21 used. And for the benefit that you are going

22 to gain from having permanent contact with
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1 decking, for a product that is wrapped in a

2 bag, which is different from say a

3 conventional stick-built, which is just it is

4 a raised floor on a crawlspace, I don't think

5 we get the benefit from it.

6 In addition to that, we have some

7 issues with the nomenclature trying to define

8 the exception as being in-between the I-beams. 

9 You know the crossover duct is a good point of

10 reference because they can be anywhere. And

11 main chassis girder beam isn't a term that is

12 commonly used. So, we need to work on that

13 language as well.

14 MR. RAMIREZ: Okay, Mark.

15 MR. WEISS: Yes, to raise a totally

16 self-serving point based on what I said last

17 week at the last meeting, the point I made

18 also shows the inevitable relationship between

19 what you put in a standard and enforcement

20 aspects of it. The enforcement costs will be

21 related to that standard. You know I was

22 trying to say last time, you can't separate
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1 it.

2 MR. RAMIREZ: Okay. Now, Manny, I

3 think I have heard two different things from

4 you. One of them is that adding this language

5 in here may create additional compliance issue

6 that may not be necessary and which I thought

7 you were leaning toward striking it but then

8 you also suggested clarifying some of the

9 verbiage.

10 MR. SANTANA: I can provide a

11 suggestion to the language, if you want to

12 hear it.

13 MR. RAMIREZ: Okay. Yes, please.

14 MR. SANTANA: So, I suggest the

15 language should read floor framing cavities

16 shall be insulated and then strike the

17 maintain permanent contact with the underside 

18 of the subfloor decking. All floor framing

19 cavities shall be insulated. And then from to

20 to the decking, strike that, and then with the

21 following exceptions.

22 So, just strike from the word to to
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1 decking. 

2 And then with the following

3 exceptions: insulation between the I-beams

4 and strike the crossover duct and strike the

5 main chassis girder beam and add insulation

6 between the I-beams on the single section.

7 MR. EZZO: This is Mark Ezzo. Say

8 per section instead of saying on single

9 section.

10 MR. SANTANA: Okay. And the reason

11 for that is that we don't want somebody to

12 take an I-beam on one half and go to the I13 beam on another half and say well this is the

14 area between the I-beams and we have to --

15 What this will do, this says, to

16 Joe's point earlier, it requires that cavities

17 be insulated. And to Mike's point, it only

18 allows it to not insulate the individual

19 cavity when you are in-between the I-beams,

20 which constitutes the barrier.

21 MR. HAGERMAN: All right.

22 MR. RAMIREZ: How does that look to
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1 everyone? David.

2 MR. TOMPOS: Aren't we saying that

3 we don't have to insulate those? We are

4 insulating those cavities. We are saying our

5 exception is we don't have to insulate between

6 the I-beams but we are insulating between the 

7 I-beams. We are putting a blanket in there. 

8 We are just not --

9 MR. SANTANA: But not in the

10 cavities. So, unless you want to say all four

11 framing cavity bays. Because the difference

12 is the blanket insulation that insulates the

13 whole area and the insulation that insulates

14 in-between the framing members.

15 MR. LUTER: This is Rob at Lippert. 

16 Could you use language that speaks to the

17 insulation being within the cavity as opposed

18 to over it? All four framing cavities shall

19 contain insulation with the following

20 exceptions and those exceptions would be those

21 where the insulation was outboard of the

22 cavity itself?
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1 I don't know that that is the right

2 language but that is what I'm -- because to

3 Manny's point, you are not going to be able to

4 fill that center cavity if you have got a

5 blanket over the top of it.

6 MR. RAMIREZ: So, could you

7 highlight that second on, Ted? So, how does

8 that look to everyone, the one that is

9 highlighted? Can you read it, Ted?

10 MR. BANTLE: Let me just simplify

11 this a little.

12 Okay. All floor framing cavities

13 shall contain insulation with the following

14 exceptions: insulation between the I-beams

15 first section and insulation displaced by

16 ductwork and plumbing.

17 MR. LUBLINER: This is Mike

18 Lubliner. I will vote against this.

19 MR. RAMIREZ: What is the issue?

20 MR. LUBLINER: If you have want to

21 get rid of the -- yes, the things I have been

22 saying all along. I think the cavity should
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1 be packed with insulation. I don't think you

2 should be able to allow for an R13 to sit in

3 the belly below the floor joist and have a

4 little piece of R13 in the rim and say that

5 that is effectively insulating that floor. 

6 What I think that you are going to need to

7 have at least four feet of insulation there to

8 help limit air infiltration coming in through

9 the spaces between the staples on the rim

10 joist of the belly board. This goes right

11 around, horizontally right into your ductwork

12 in the middle of the belly board.

13 I don't see with this code change,

14 at least my understanding would be is that we

15 should always require that space to be fully

16 insulated, regardless of when the floor

17 insulation says R13 in your tradeoffs.

18 That is my own feeling and I am

19 going to vote against it and I will let the

20 group do what they are going to do.

21 MR. LUTER: Rob with Lippert. Mike,

22 are you concerned more about air infiltration
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1 or thermal performance?

2 MR. LUBLINER: I'm concerned about

3 both and I am also concerned that the thermal

4 analysis of the floor U value with that in

5 place like that, because of the air

6 infiltration, you are not going to get the U

7 value you think you are going to get. It is

8 going to bypass at that point. And I think

9 that it is a good thing to have floor coverage

10 like the I code says, where you can do it. 

11 And to do it here means you need to use the

12 depth of the insulation or fasten it like they

13 do in the site-built home with string. In a

14 site-built home, they go through many, many

15 ranks to get that thing covered up by using a

16 string on the I joist. Instead, we have a

17 belly closure that can help.

18 But if it is only R13 down there,

19 you are going to need to figure out a way to

20 attach it. Maybe this is a good thing. Maybe

21 they will keep people from just doing R13

22 bellies. I think that the belly needs to be
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1 insulated fully from the rim to the I joist in

2 any climate zone. But that is my own personal

3 opinion and like I said, I don't think I am

4 going to be changing on this one. So, you

5 guys can decide what you want to do and put me

6 down as an exception.

7 MR. RAMIREZ: Any other comments?

8 MR. LEVY: Yes, this is Emanuel

9 Levy. Can you hear me?

10 MS. HOFFMAN: Yes.

11 MR. LEVY: I'm not sure what this

12 section is the way it is written right now. 

13 It just basically says the floor cavity should

14 be insulated. And you can't comply with the

15 thermal provisions of the standards, the other

16 parts without insulating the floor.

17 So, I am not sure what this

18 discussion really adds.

19 MR. EZZO: This is Mark Ezzo. I

20 agree that this started out with only talking

21 about connection if the insulation to the

22 underside of the decking and this thing has
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1 morphed into how to install insulation in the

2 floor.

3 And like Emanuel said, I agree that

4 all the other sections of the code, whether

5 you do a prescriptive path or a performance

6 path, you have to insulate and you have to

7 prove that you are meeting certain R-values

8 and/or U values. So, I don't see the value in

9 all this language at all.

10 MR. RAMIREZ: Mark.

11 MR. WEISS: Mark Weiss. Question

12 for Mark Ezzo. Are the exceptions we are

13 talking about here addressed somewhere else? 

14 Because I mean, the only value might be in

15 keeping the exceptions. I don't know.

16 MR. EZZO: Mark, I don't know that

17 you can meet the insulation requirements -- I

18 guess I am saying that wrong.

19 I think we use those exceptions when

20 we are designing the floor insulation, whether

21 it be prescriptive or using calculated U

22 values. So, if you have got compression and
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1 you have got areas where a cavity isn't

2 completely full, you have to account for that

3 in the U value of your floor.

4 So, again, I think to Emanuel's

5 point, I mean I would strike the whole

6 section. And Mike Lubliner, aren't we --

7 maybe I am missing this but at the rim, aren't

8 we required to fully insulate the full

9 vertical height of the rim anyway?

10 MR. LUBLINER: My understanding is

11 that is what we see in the plants right now is

12 a piece of R11 or R19 insulation covering the

13 rim. They put it in in addition to the belly

14 to try to prevent some lateral heat loss and

15 thermal bridging.

16 I am good with eliminating the whole

17 section.

18 MR. RAMIREZ: You know what, folks? 

19 This is consensus and this is how it works. 

20 You have to allow for the discussion so that

21 way when you get somewhere, you understand how

22 you got there. 
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1 So, let's go ahead and put the

2 strikethrough on it and let's take a vote. 

3 All right?

4 MS. HOFFMAN: A vote and then take a

5 break.

6 MR. RAMIREZ: Yes, we will do this

7 and then we will take a quick ten-minute

8 break.

9 So, let's see if you are okay with

10 striking the entire section. Let's see a show

11 of thumbs. Okay. Any thumbs down online?

12 Okay, then with that, then it is

13 unanimous.

14 Let's take a ten-minute break and

15 when we come back, Manny, if we could have you

16 continue with what is left in here, that would

17 be great.

18 MS. HOFFMAN: All right, thank you. 

19 Thank you, all.

20 (Whereupon, the above-entitled

21 matter went off the record at 10:12 a.m. and

22 resumed at 10:25 a.m.)
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1 MS. HOFFMAN: All right, we are back

2 from the break. And everybody on? Okay.

3 Well, we reached consensus on one

4 item there. Manny, do you want to continue? 

5 I think there are just a few more left. Is

6 that right? This is Eileen Hoffman.

7 MR. SANTANA: That is correct.

8 MS. HOFFMAN: Good, keep going.

9 MR. SANTANA: So, we went through

10 the -- we are down to -- okay. I guess we

11 should discuss the items that we haven't --

12 even the ones that we suggested remain the

13 same. 

14 So, shower, tub on exterior walls. 

15 We are talking about that entire row. And the

16 subcommittee recommended that we leave this as

17 it is with no changes.

18 MR. RAMIREZ: Okay, any questions or

19 is that a quick vote?

20 Let's see a show of thumbs if you

21 are okay with the recommendation from the

22 committee to keep it as it is. Any thumbs
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1 down online?

2 Okay, that was unanimous.

3 MR. SANTANA: Can we scroll up a

4 little bit? I want to make sure we didn't

5 skip anything.

6 MR. RAMIREZ: So, Ted was doing a

7 fast scroll but I think what Ted is looking

8 for is just to make sure that everything that

9 is altered has a consensus by it. And Ted is

10 --

11 MR. BANTLE: Yes, it appears to be.

12 MR. RAMIREZ: Okay.

13 (Simultaneous speaking.)

14 MR. SANTANA: On the same page. 

15 Okay, so electrical/phone box on exterior

16 walls. The current IECC we had a sentence

17 that was struck and a sentence that was added. 

18 The sentence struck is air sealed boxes shall

19 be installed. And the sentence added is that

20 the air barrier shall be sealed around the box

21 or the box penetration. And this deals with

22 how the air barrier being compromised around
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1 electrical/phone boxes on the exterior wall.

2 MS. HOFFMAN: Is there any

3 discussion?

4 MR. RAMIREZ: Let's see a show of

5 thumbs if you are okay with the recommendation

6 by the committee. Any thumbs down online?

7 Okay, then that one is unanimous as

8 well. Next.

9 MR. SANTANA: Next row, HVAC

10 register boots. And the subcommittee

11 recommends that this go through unaltered.

12 MR. RAMIREZ: All right. Any

13 questions on that one?

14 Can I see a show of thumbs if you

15 are okay with the recommendation from the

16 committee to keep it as it? Okay, online any

17 thumbs down?

18 All right, that one is unanimous as

19 well.

20 And I believe this is the last one,

21 right? The chart was a little compressed. 

22 So, I just wanted to make sure that this was
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1 the last point. Manny, is this the last one?

2 MR. SANTANA: Well, it is the last

3 point in the table but there was also a

4 Footnote A that we had a recommendation on.

5 MR. RAMIREZ: Okay. So, let's do

6 this one and then we will go to the footnote.

7 MR. BANTLE: Manny, this is Ted. 

8 Should that Footnote A be on the same document

9 with the table?

10 MR. SANTANA: Yes.

11 MR. BANTLE: Okay.

12 MR. SANTANA: Yes, only that it

13 wasn't part of the table citation on the same

14 page.

15 MR. BANTLE: Okay, I will do that.

16 MR. SANTANA: Well, the last row

17 deals with sprinklers. Sprinklers are outside

18 of the current HUD Code. And for that reason, 

19 our subcommittee votes to strike the entire

20 row.

21 MR. RAMIREZ: Okay. So, is there a

22 comment online?
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1 MR. LUBLINER: Mike Lubliner. I

2 agree that sprinklers aren't very common but

3 if they were in the home, shouldn't they be

4 sealed? 

5 MR. SANTANA: And to that point,

6 Mike, this is Manny again, if sprinklers are

7 installed, as we all know that they are, in

8 some cases, then they would just follow the

9 penetration of the air barrier.

10 MR. LUBLINER: Okay, I am good with

11 that. Thank you. Mike Lubliner.

12 MR. RAMIREZ: So, let's see a show

13 of thumbs if we are okay with the

14 recommendation of the committee. Anyone

15 online with your thumbs down?

16 Then, that one is approved

17 unanimously.

18 And then my hesitation is that

19 occasionally I am not seeing thumbs. And I

20 just want to remind everybody if you are

21 opposed you need to have your thumbs down,

22 otherwise you are okay with it. So, just a
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1 reminder there.

2 Okay, now can you go to the

3 footnote?

4 MR. SANTANA: Okay, so the footnote

5 deals with a standard that deals with the log

6 walls. And I am a relative newbie to the

7 industry. I have only been here ten years but

8 I haven't seen a house with log walls built

9 actually yet. I don't think it applies.

10 We decided to strike it for those

11 reasons.

12 MR. RAMIREZ: Any questions on that? 

13 Okay, let's see a show of thumbs if you are

14 okay with the recommendation. Okay, anyone

15 online with your thumbs down?

16 Okay, then that was unanimous as

17 well.

18 Manny, is there anything else that

19 your committee wants to address?

20 MR. SANTANA: Yes, we had a few

21 other items that weren't addressed during last

22 week's meeting. By any chance, do you have
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1 the list that I sent out?

2 MR. RAMIREZ: The email?

3 MR. SANTANA: The email, right. I

4 think we got through the heat pumps. Actually

5 we got through 403.5.1. I'm showing we got

6 through 403.5.1.1 as well as 403.5.1.32

7 because they were all a group. 

8 MR. LACEY: So, Manny, this is Eric

9 Lacey. I have the list that you handed off to

10 me that has all of your checkmarks on it. And

11 it looks like the only two that don't have

12 checkmarks are R403.6 and R403.7.

13 MR. SANTANA: Right.

14 MR. RAMIREZ: You know what, Manny? 

15 Could you hold on for a second? We are going

16 to make copies so that way everyone has it and

17 I am going to see if I can find the email.

18 MR. SANTANA: Okay.

19 MR. RAMIREZ: So we will just take a

20 brief break to do that.

21 (Whereupon, the above-entitled

22 matter went off the record at 10:32 a.m. and
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1 resumed at 10:34 a.m.)

2 MR. RAMIREZ: Okay, Manny?

3 MR. SANTANA: Yes.

4 MR. RAMIREZ: We are going to put

5 the screen back up here and let me know if

6 this is the chart that you are referencing. 

7 Is that it?

8 MR. SANTANA: That is it, yes.

9 We have gone through all of the

10 sections except for the two highlighted ones

11 on the previous screen. So, we have gone

12 through everything except R403.6 and R403.7.

13 MR. RAMIREZ: Okay, so why don't we 

14 take 403.6 first? Do you want to walk us

15 through that?

16 MR. SANTANA: Well, let me back up,

17 though. There was another one that we didn't

18 get to and that one was R402.4.4. We have

19 three sections left.

20 MR. RAMIREZ: Okay, so that 402.4.4

21 is a little bit further up.

22 MR. SANTANA: Right. So 402.4.4 is,
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1 if you are set with that, it is on page R33 of

2 the IECC. And it is a section that deals with

3 rooms containing fuel-burning appliances. And

4 we didn't resolve it because we didn't get to

5 it. And part of the reason why we didn't get

6 to it is because we didn't have the full

7 language because there is a standard of the

8 HUD Code or there is a section of the HUD Code

9 that deals with a very similar subject and it

10 would have taken research to see how they both

11 compared and how they contrasted. And we

12 didn't have time to do that at the last

13 meeting and this one came pretty quickly.

14 So, we have no recommendations,

15 either. I don't know if this is something

16 that we just tell DOE that we think is

17 important and for them to look at or us go and

18 see what is currently there and what this

19 actually requires.

20 MR. SANTANA: Any discussion on

21 that?

22 MR. UNGAR: I just think it would
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1 not be a priority for the full group that if

2 there is time, the subcommittee should go back

3 and consider this. If not, leave it for DOE.

4 MS. HOFFMAN: So, your suggestion is

5 either consider it later or have DOE deal with

6 it.

7 MR. RAMIREZ: So, let's ask the

8 group. Is it something that you are okay with

9 letting DOE handle? Let's see a show of

10 thumbs if you are okay with that. And online,

11 is there any issue with that, any thumbs down?

12 MR. RAMIREZ: Okay.

13 MS. HOFFMAN: Okay, so it goes to

14 DOE.

15 MR. RAMIREZ: Yes, 402.4.4 will be

16 handled by DOE.

17 Okay, 403.6.

18 MR. SANTANA: Okay, 403.6 is on page

19 R36 of your IECC.

20 MR. HAGERMAN: So, this is Joe

21 Hagerman. Just real quick while we are on

22 that last one, just let me go ahead and say
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1 it. Any manufacturers have any information

2 pertaining to that 402.4.4 or its effects on

3 indoor air quality, we would love to have any

4 information or separate comments.

5 And we will ask that question, too,

6 obviously, once you come up with the term

7 sheet and we write the actual NOPR, we will

8 put a question in there that specifically asks

9 for more information.

10 MR. RAMIREZ: And so, let me just

11 pick on this a little bit in the sense that

12 Lois or Emanuel, is that something that you

13 could look into to see if there is information

14 on that?

15 MS. STARKEY: Sure.

16 MR. RAMIREZ: Okay, great. Thank

17 you. 

18 Okay, 403.6.

19 MR. SANTANA: Okay, 403.6 is on page

20 R36 and it deals with mechanical ventilation. 

21 And it is a little strange because the

22 subcommittee suggested that we accept in
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1 principle but illustrated the need to consider 

2 cost impact of fan efficacy requirements.

3 And the reason why I said that it is

4 tricky is because the only section that is

5 mandatory if 403.6. There is a 403.6.1, which 

6 throws you to a mechanical ventilation system

7 fan efficacy. And I think what the

8 subcommittee had accepted in principle was the

9 need to have ventilation fan efficacy.

10 The current HUD Code has whole house

11 ventilation requirements. The IECC doesn't

12 give you any specific mechanical ventilation

13 requirements. And to my knowledge, you need

14 the IRC or the IMC when you have natural

15 ventilation.

16 So, and now I want to speak for the

17 group. I don't want to speak out of turn but

18 my understanding of what the group is

19 suggesting is that we accept in principle the

20 need for mechanical ventilation fan efficacy,

21 not so much the requirements for mechanical

22 ventilation.
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1 MR. RAMIREZ: All right. So, is the

2 part for the mechanical ventilation, 403.6.1,

3 is that something that you are suggesting

4 similar to letting DOE handle that piece?

5 MR. LUTER: This is Rob from

6 Lippert. I would like to chime in on that if

7 I could, please.

8 While on the surface it might seem

9 that assigning minimum efficiencies to HVAC

10 equipment and mechanical fans is a good idea,

11 I think there is going to be unintended

12 consequences with respect to bathroom fans and

13 range hoods in that the electronically

14 commutated motor-type product or the

15 efficiencies on watts per cfm are going to

16 completely eliminate an entire class of

17 products that has been historically used in

18 HUD Code homes. And those are products that

19 utilize shaded pole electric motors and

20 backwardly inclined impellers.

21 Not to get too far into the weeds,

22 these are extremely efficient, cost-efficient,
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1 I should say, means of moving the air. These

2 are products that are off for the majority of

3 time. And while one could argue that

4 increased efficiency is a good thing, the

5 amount of increased efficiency you are going

6 to get for the low amount of operating time,

7 I think, is going to prove to be a pretty

8 tough payback when you consider the cost of

9 these much more sophisticated products.

10 I don't have a dog in this fight. I

11 used to be in that industry so, I am aware of

12 the ins and outs in this. I just thought I

13 would throw that out and see if the group

14 would want to act on this.

15 MR. RAMIREZ: Eric?

16 MR. LACEY: So, this is Eric. Rob,

17 are you suggesting that maybe a couple more

18 categories of products be added to the fan

19 efficacy table? I mean, I gathered that for

20 the types of fans that are normally included

21 in these categories in the table, are there

22 any issues with the efficacy requirements? Is
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1 it just a matter of adding two or three more

2 categories for the types of fans being used

3 that they say are efficient or are you

4 suggesting eliminating it?

5 MR. LUTER: Well, the issue is that

6 the -- and this won't be a problem with the

7 class of homes that, for example, Mike

8 Lubliner is very familiar with, the northwest. 

9 In fact, I think BTA has been mandating this

10 kind of efficacy for a while. We used to run

11 into it up there in terms of not only

12 efficiency at the zone level but the

13 demographic that is going to be mostly

14 effected are the entry level homes, let's say

15 in the southeast and the southwest, where they

16 are using a bathroom that costs under $10 and

17 they are going to need to change to a bathroom 

18 fan that costs over $40, perhaps over $50. 

19 I'm not sure exactly where the market is right

20 now with that on the wholesale level but it is

21 a completely different animal.

22 I don't have a great solution. I
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1 mean we could add less efficient products to

2 this table. We could just say no, the table

3 is fine as is. I just want to make sure that

4 the group is aware that efficacy in this case,

5 means significant costs. It is not the

6 difference between a light bulb that costs

7 $1.39 and $8. It is the difference between a

8 bathroom fan that costs under $10 versus one

9 that costs $50 or a range hood that costs $25

10 today that is going to cost $150. It is just

11 the reality of that class of air mover.

12 They are nice products. Don't get

13 me wrong but the costs are quite a bit higher

14 than current.

15 MR. LUBLINER: This is Mike

16 Lubliner.

17 MR. RAMIREZ: Yes, Michael?

18 MR. LUBLINER: Rob is right. To get

19 a better, you are going to be changing the

20 type of exhaust fans, motors, getting a more

21 energy efficient motor that over the life of

22 these fans will be, I believe, very cost
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1 effective. They are generally ENERGY STAR

2 rated. But we haven't done a cost3 effectiveness analysis of this. It could be

4 done.

5 I would suggest that there is more

6 important reason for the requirement for the

7 better, more expensive fans and that is my

8 personal experience and published research in

9 international engineering journals and my

10 presentations and NIST presentations from

11 scientists at the Consensus Committee has all

12 been suggesting that when you measure the flow

13 rate of these cheap fart fans, these $10 fans,

14 you are not achieving the minimum flow

15 requirements stated in the HUD Code.

16 The HUD Code says 50 cfm for a bath

17 fan and it says 100 cfm for the kitchen. I

18 have repeatedly measured these at 25 cfm. I

19 have raised this issue with the HUD Consensus

20 Committee. I believe there is a working task

21 group of the Consensus Committee that is going

22 to be addressing this. This is also discussed
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1 in GAO's report to HUD. And that report, I

2 would really encourage folks to read because

3 it says testing of performance evaluation

4 could ensure better safe indoor air quality. 

5 And part of what they were talking about is

6 that nobody measures the flow rates of bath

7 fans in this industry, evidently, except for

8 me. And when I do it, I get half the flow.

9 So, we need a better bath fan, not

10 only for energy efficiency but so that it

11 addresses purging the bathroom of moisture and

12 reducing the associated mold or other problems

13 with the underperforming out of spec current

14 practice.

15 I would like to suggest that we

16 table this, leave this to DOE to talk about. 

17 I would also point out that the Uniform

18 Mechanical Codes, these codes reference ASHRAE

19 60.22 and the Manufacturer Construction

20 Consensus Committee recently approved the use

21 of ASHRAE 60.22 as an approach to meeting the

22 criteria for ventilation and they also have
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1 the current HUD ventilation criteria. But I

2 really do believe that this would be a

3 positive change and well worth the money both

4 from an energy and a mold avoidance

5 standpoint. Thank you.

6 Sorry for rambling.

7 MR. LUTER: Rob from Lippert. Just

8 one more comment. I will agree with Michael

9 that the majority of the products that are out

10 there right now do not deliver to the exterior

11 of the home their rated capacity. This is an

12 issue I have been working on since the mid13 '90s as well.

14 The issue is that the rating system

15 used by the Home Ventilating Institute bears

16 no resemblance at all to a real world

17 application. So, in that respect, I think a

18 hard look at this is a good idea.

19 MR. RAMIREZ: Mark --

20 MR. LUBLINER: Rob, this is Mike

21 Lubliner again. Can I follow up on that?

22 From what I understand the HVI
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1 specifications have two listings for pressure

2 drop. A 0.1 inches of water, which is rarely,

3 rarely achieved when you duct it and put a cap

4 on it. They also have a 0.25 inches of water

5 column.

6 And I think what has been happening

7 and the reason that we have some of these low

8 flows is we have been trying to size these

9 fans and assuming we had 0.1, when we really

10 have about 0.25 or worse, depending on the run

11 and the Ls and the restriction of the flex

12 being used. Just a point of clarification.

13 MR. LUTER: No, I appreciate that,

14 Mike. I wasn't aware of the quarter-inch

15 water column issue. I have been out of the

16 air-moving industry for a little while. And

17 when I was in it, it was just a tenth of an

18 inch of water column. 

19 But again, I think it is something

20 that we ought to get a closer look at but

21 going in, understand the cost ramifications.

22 MR. LUBLINER: Absolutely, there are
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1 cost ramifications.

2 MR. RAMIREZ: Let me get Mark and

3 then Lois.

4 MR. WEISS: First I have a question

5 if somebody could answer it. Looking at the

6 section when it says that meets the

7 requirements of these two codes as applicable

8 or with other approved means of ventilation. 

9 Could somebody just talk about what other

10 approved means of ventilation is, and who does

11 the approving, and on what basis?

12 MR. RAMIREZ: Richard, do you have

13 an answer?

14 MR. POTTS: This is Richard Potts. 

15 That is just referring to billing official or

16 to jurisdiction who approves the plan. So,

17 that is more geared towards your building

18 locality where there is a prescriptive method

19 but it gives the building official some kind

20 of flexibility to approve some sort of method

21 for testing. So, I don't know if that is

22 really applicable to our situation of
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1 adapting.

2 MR. WEISS: Okay, thanks. I just

3 have a problem with just leaving this out of

4 what we are doing and just delegating it to

5 DOE. I think we need to work at this with

6 respect to costs and also with respect to the

7 technical aspects of it, particularly since

8 you are making the home tighter and potential

9 collateral impacts from that.

10 I really wouldn't be comfortable

11 just separating this part out of what we are

12 doing.

13 MR. RAMIREZ: Okay, Lois.

14 MS. STARKEY: Lois Starkey, MHI. 

15 This issue is very near and dear to the

16 Consensus Committee and to HUD's authority

17 right now because of the GAO Report of

18 November of 2011. And the committee has just

19 met. They are working on this. I would

20 recommend that we ask DOE to consult with HUD

21 and the consensus committee and work on this

22 issue, which is a very important issue to air
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1 tightness, to indoor air quality and something

2 that is already being worked on and

3 professional people are working on this.

4 MR. WEISS: Mark Weiss. I have no

5 problem with that because it will be fully

6 vetted within that process.

7 MR. RAMIREZ: Any suggestion?

8 MR. HAGERMAN: We can always take it

9 under advisement.

10 MR. RAMIREZ: Okay. So, then, the

11 question is to have DOE handle this

12 consultation with HUD and the Consensus

13 Committee.

14 MR. EZZO: This is Mark Ezzo. Can

15 we strike the language, though, as it is

16 written where it says reference the

17 International Residential Code? Because I am

18 looking at the IRC right now and it is pretty

19 cumbersome. And considering the HUD Code

20 already has whole house mechanical ventilation

21 requirements, pretty detailed out, by the way. 

22 I think everybody knows that.
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1 I mean to me, my suggestion would be

2 we keep what HUD has got and strike this

3 mechanical ventilation section, other than the

4 comments that people made before about the fan

5 efficacy needing to be evaluated further. But

6 if we want to go with what Lois and Mark

7 suggested, I'm fine with that. But I think,

8 in addition to making that statement, we

9 should strike what it says here, so there is

10 no confusion about possibly maintaining this

11 reference to the IRC.

12 MS. DICKENS: This is Ishbel from

13 the Manufactured Home Owners Association. I

14 would not support removing that language. We

15 are going to not really deal with this in the

16 Department of Energy Working Group but doing

17 to deal with it at the MHCC, then I don't

18 think there is any reason to change the

19 language here at all. I just ask that we

20 leave it the way it is, especially if DOE is

21 taking it under advisement because I think the

22 air ventilation thing has been a huge issue.
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1 And the DOE report speaks to it very

2 clearly. It is something that HUD should have

3 been dealing with a long time ago and the fact

4 that we still haven't got a final rule on that

5 really concerns me.

6 So, I would like to just leave the

7 language as is and hopefully the HUD process

8 -- as Lois says, there's a group that is

9 looking at it right now, hopefully will come

10 out with the final language on that when we

11 meet in December. But I don't want to mess

12 with this language until HUD has a final rule

13 on it.

14 MR. RAMIREZ: Let's get --

15 MR. SCHNEIDER: This is Peter from

16 Efficiency Vermont and I agree with that.

17 MS. HOFFMAN: Who is this?

18 MR. RAMIREZ: Peter.

19 MS. HOFFMAN: Oh, okay.

20 MR. RAMIREZ: Okay, let me get Mark

21 and then Lois again.

22 MS. HOFFMAN: Also, has anyone else
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1 joined us? Peter Schneider, just? Okay.

2 MR. WEISS: Yes, I agree with Mark. 

3 I think leaving it potentially could trump

4 whatever happens within the MHCC, essentially

5 prejudge the outcome. So, I would want to

6 take it out.

7 MR. RAMIREZ: Okay, Lois.

8 MS. STARKEY: I guess maybe we could

9 just have it -- I was thinking that we are not

10 going to act on, I don't think, at least that

11 is not my recommendation, that we act on and

12 affirmatively including that provision, that

13 we table it or make some notation.

14 So, whether we leave it in or out,

15 we are going to make it clear, I think, or I

16 would like to recommend that we make it clear

17 that this group hasn't taken a position on

18 that and that we would like DOE and HUD to

19 consult, so it doesn't really matter whether

20 we leave it in or out, as long as we make it

21 clear that we are not taking a position on

22 that provision.
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1 MR. WEISS: Mark Weiss, MAHRR. I

2 wouldn't have any problem with leaving the

3 category and not leaving the title and simply

4 making the notation the issue will be

5 addressed pursuant to consultation between DOE

6 and HUD by the Manufactured Housing Consensus

7 Committee.

8 MR. RAMIREZ: Okay, Michael.

9 MR. LUBLINER: Mike Lubliner. Yes,

10 I kind of agree with Mark and agree with

11 Ishbel and everybody. But I do think we could

12 do this by just saying, inserting where there

13 is a ventilation that meets the requirements

14 of, and leave what is in there now but also

15 include HUD's Manufactured Housing

16 Construction Safety Standards. If we include

17 that in there, we are okay because then DOE

18 can look at all of those and decide. And by

19 including the Manufactured Housing

20 Construction Safety Standards, I think what we

21 will end up with is the opportunity to use

22 either the existing ventilation standards and
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1 the HUD Code or 60.22, which is referenced in

2 the Residential Code as well.

3 So, I just suggesting inserting

4 Federal Manufactured Housing Construction

5 Safety Standards and then I am okay with the

6 reference to the Consensus Committee stuff

7 that was suggested. Maybe that is a

8 compromise to get between Mark and Ishbel.

9 MR. RAMIREZ: Okay, so that --

10 MS. DICKENS: I would accept that as

11 well.

12 MR. SANTANA: Manny with Cavco. I

13 think that we might be confusing the issue

14 here and, you know, there is two issues that

15 I understand are being discussed. One deals

16 with indoor air quality and the other one

17 deals with fan efficacy. One of those issues

18 is within our charter and the other one is

19 not.

20 So you know the indoor air quality

21 issue I think is the one muddying this stuff

22 up. And what the subcommittee presented and
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1 agreed to in principle was to look at fan

2 efficacy within the field of energy. And that

3 is what we are concerned with.

4 You know the other issue whether HUD

5 is doing it or whether the GOA report is going

6 to make us do it or whether it is two I

7 referenced in the IRC, what the IRC says, what

8 the IMC -- we don't need that to carve out.

9 The only thing that I think is

10 within our purview here is the energy

11 consideration of the fans themselves and how

12 those should be considered.

13 MR. RAMIREZ: Okay, so does everyone

14 agree with that that the air quality issues

15 are out of scope?

16 MR. HAGERMAN: So, I think -- Joe

17 Hagerman, DOE -- we have always been concerned

18 about the efficiency of the mechanical

19 ventilation system and its impact on indoor

20 air quality. So, I really like this. I

21 really encourage this group if you just want

22 to punt it down the field, that's fine. We
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1 are going to ask in the rule for more

2 information about efficiency of the mechanical

3 system and its impact on indoor air quality

4 because we don't have good visibility into

5 that issue.

6 Obviously, we have good

7 understanding of the fan efficiencies and how

8 to get the mechanical ventilation system

9 efficient. We just don't know the impact it

10 would have in this sector and the whole indoor

11 air quality issue that we know that the

12 industry has deal with previously.

13 So, that is why I would like this

14 group to, you know, if I had my preference, I

15 would have you kind of discuss it and come up

16 with some resolution to these two issues

17 because they are sort of linked, to give us

18 some more guidance. Does that make sense?

19 MR. CASKEY: Well, this is John

20 Caskey at NEMA and I agree with that whole

21 heartedly. That I mean as we are trying to

22 improve energy efficiency and reduce
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1 infiltration, certainly it is a lot easier to

2 get a manufactured housing sort of air tight

3 or almost air tight than a conventional home. 

4 So, I certainly think it is important for this

5 group to at least touch on it or to ask that

6 some other agency investigate it more fully to

7 make sure that you are covering your bases. 

8 I would hate for some sort of mold problem or

9 something like that to develop as a result of

10 trying to move forward with energy efficiency.

11 MR. RAMIREZ: Mark?

12 MR. WEISS: Without necessarily

13 taking a position on what Joe said without

14 looking at it further, it doesn't change the

15 discussion about -- well, that doesn't change

16 my concerns that I said before and that is,

17 just punting this issue effectively to DOE

18 without having looked at it and assessed it

19 either here or via the MHCC. This is

20 potentially a significant issue both with

21 respect to the home itself and with respect to

22 cost. And I just don't see how you come to
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1 any kind of a final, legitimate recommendation

2 without having this factored into it.

3 MR. RAMIREZ: Lois and then --

4 MR. LUBLINER: This is Mike

5 Lubliner.

6 MR. RAMIREZ: Yes, Michael.

7 MR. LUBLINER: You know I think that

8 my position is that I am pretty confident that

9 the exhaust fans now are only putting out

10 typically half of the minimum requirements for

11 the existing HUD Code home.

12 So, my logic is that that needs to

13 be fixed, regardless of what is going on. To

14 fix that, you are going to need better

15 performing fans like the fans that we are

16 talking about that absolutely will have that

17 better efficacy that will actually move the 50

18 cfm out of the bathroom with the current

19 ducting configuration or the 100 out of the

20 kitchen.

21 So, I would argue that if these

22 requirements aren't being made, they should be
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1 made for health and safety and mold. And if

2 they are made, it is a moot point because you

3 will get fans that have the higher efficacy. 

4 MR. RAMIREZ: Eric.

5 MR. LUBLINER: And I kind of feel

6 like DOE can take this information, talk with

7 ASHRAE Standard 60.22, talk with NIST who did

8 the research on healthy houses for

9 manufactured homes and tested, talk with the

10 experts within their national labs and come

11 back and look at whether or not this should be

12 a requirement, regardless of whether it saves

13 any energy.

14 And if that is the case, then I

15 think the incremental cost is zero because

16 this is something that is long overdue and

17 those costs shouldn't be part of Energy Code.

18 Anyway, that is all I can say on it

19 right now. I have done a lot of work in this

20 area. I think that the consensus committee is

21 moving into a dialogue that will recognize

22 this as a needed change to make sure that they
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1 are meeting the HUD standard they are already

2 building to. Thank you.

3 MR. RAMIREZ: Eric.

4 MR. LACEY: This is Eric. I mean I

5 am not a mechanical engineer. Luby

6 understands this much better than I do and

7 actually he said most of what I was going to

8 say.

9 I would just say that I don't think

10 it is fair to compare a fan that is currently

11 being installed that is not doing the job with

12 one that would do the job and would be more

13 efficient. I think going from $10 to whatever

14 it is going to be, $40, is probably an unfair

15 comparison and I don't think we should pull

16 out the individual cost effectiveness of an

17 item like that, especially where the current

18 fans, as I am hearing, are not doing the job

19 adequately.

20 I am still kind of hung up on the

21 table. The IECC membership decided that these

22 values were reasonable, per cfm is a
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1 reasonable efficiency levels. And I haven't

2 heard anyone suggest that those are not cost

3 effective or not reasonable. So, while I

4 understand that HUD is going to continue, I am

5 hearing HUD is going to continue to move

6 forward on getting effective ventilation

7 standards, I would like to make sure that we

8 are recommending some kind of efficacy level

9 to DOE, whether it is these numbers here or

10 whether somebody has something else to

11 suggest. They were put here for a reason. I

12 assume they were cost-effective in the stick13 built home world.

14 So, I think the two are going to be

15 linked like Luby said and I wouldn't

16 completely get rid of the efficacy

17 requirements.

18 MR. RAMIREZ: Okay. Joe, did you

19 have something? Okay.

20 MR. HAGERMAN: Sorry.

21 MR. RAMIREZ: All right. So, I am

22 hearing that this is something that the group
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1 may need to deal with. And so the question I

2 have for you is is that something that we

3 could take care of through discussion right

4 now or is it something that might be better

5 handled by the subcommittee?

6 MR. SANTANA: This is Manny with

7 Cavco. You know I think this issue here has

8 got a lot of angles to it. And there is a lot

9 of information that is lacking from the

10 discussion here, one of which is what exactly

11 does HUD require. What exactly does the IRC

12 require? Because there is a difference

13 between what is in the IRC and the IMC and

14 would then state specific requirements.

15 To my knowledge to me, the 2012 IRC

16 and IMC did not mandate mechanical ventilation

17 unless you don't have enough natural

18 ventilation. The California State Code, that

19 does require mechanical ventilation and I

20 think Oregon's might as well. So, I think

21 that this issue has got to be dealt with at a

22 subcommittee because there is too much -- you
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1 need to do a lot of research and there is too

2 much for us to go through right now to come to

3 a decision based on factual information in

4 this venue.

5 Then you get into the other issue of

6 on the one hand you have air quality, which is

7 important. On the other hand, you have energy

8 usage. Well, how can you say that well, we

9 are going to take -- we are concerned about

10 the house being too hot, so, we need to

11 provide mechanical means to exhaust air and

12 then let makeup air come in through gaps but

13 that is going to be eliminating. This is

14 unconditioned air which is just going to have

15 be conditioned. It could be moist.

16 And so there a lot of issues here

17 that have to be discussed. And I don't think

18 we are going to get anywhere here.

19 MR. RAMIREZ: All right. So, Manny,

20 you are suggesting that it be deferred to a

21 subcommittee. There was also Lois had 

22 mentioned that this is currently being
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1 investigated by HUD and the Consensus

2 Committee. Do you defer to them or do we have

3 our own subcommittee?

4 MR. HAGERMAN: I think we need to

5 form our own subcommittee because you need to

6 --

7 MR. SANTANA: Yes, we need our own.

8 MR. HAGERMAN: I think we need to

9 create our own and I hate to put David Tompos

10 on the spot but I think he has done a good

11 deal of indoor air quality testing. And I

12 assume that you all are manufactured housing

13 experts.

14 Is there something that you could

15 maybe form a subcommittee around to give us

16 some understanding of it?

17 MR. TOMPOS: Well, what kind of

18 scope are you looking for? I mean we have

19 done the test. We can do the testing.

20 MR. HAGERMAN: We are looking, I

21 think the scope is we are looking to help and

22 how this committee deals with 403.6 and 403.7.
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1 MR. HAGERMAN: I mean my personal

2 opinion is I think we should we all use ENERGY

3 STAR fans but I am going to get a lot of push

4 back from the industry because I do think air

5 quality is extremely important.

6 I would need some help --

7 MR. LUBLINER: Joe, this is Mike

8 Lubliner.

9 MR. RAMIREZ: Yes, Michael.

10 MR. LUBLINER: I support, Dave, if

11 you want to volunteer. I would do it as well

12 if he didn't want to. But I would certainly

13 support him on the committee helping him. I

14 just do a back of the envelope calculation. 

15 Basically, the cheap fart fans or the $5, $10

16 fart fans, they are putting out about 50 watts

17 when they run. And the fan efficacy we are

18 looking at here is putting out 20 watts. So,

19 we are talking about a differential 30 watts

20 per fan.

21 Now, assuming two bathroom and a

22 kitchen fan are running with that differential
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1 30 watt savings, it is 90 watts a day if it is

2 on for an hour. Assuming that they will be on

3 for say a couple of hours in the morning,

4 maybe an hour in the evening, if we say three

5 hours and you do the calculation at a dime a

6 kilowatt hour, the fan, the additional fan not

7 only is it quieter and reliable and moving the

8 air necessary to meet the current minimum code

9 but, just on the energy savings alone of the

10 ENERGY STAR fans, as Dave puts it, we are

11 talking about a payback that is within the

12 life of the fan.

13 So, I think our committee can look

14 into this and both look at the implications

15 for air quality, as well as the cost16 effectiveness of the fan. I should also point

17 out that the energy that the fan creates when

18 it is running leaves the house. So, it is not

19 going back into heating the house at all. And

20 I think that that means it is going to be a

21 good option for a cost-effective improvement

22 that will also compliment improving air
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1 quality and meeting current HUD standards. 

2 Thank you.

3 MR. RAMIREZ: Now, I heard Joe make

4 a recommendation for a subcommittee for 402.6

5 and 402.7 because they are related.

6 MR. SANTANA: They are not related.

7 MR. RAMIREZ: All right. And is a

8 subcommittee of David Tompos and Michael

9 Lubliner, is that enough, with you all getting

10 the folks that you need externally for that?

11 Is that big enough to make it to that?

12 MR. LUTER: I would happy to

13 participate. This is Rob.

14 MR. TOMPOS: It would be nice to

15 have a manufacturer in that group, just so we

16 can potentially get to their suppliers. I

17 mean we are going to need costs on fans.

18 MR. EZZO: Dave, this Mark Ezzo. I

19 will help.

20 MR. LUBLINER: Great. Mike

21 Lubliner, too, I can bring, since I am on the

22 ASHRAE 60.22 committee, I can bring the 60.22
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1 chairman, if we need him and the then industry

2 folks from that committee to a discussion and

3 have them provide information as well. I

4 think we can get it. I think we have a good

5 group to resolve this and it is an important

6 issue, I think, everybody agrees.

7 MR. RAMIREZ: Okay, so I am showing

8 as the fan subcommittee as David Tompos, as

9 the chair. And then Michael Lubliner, Rob

10 Luter, and Mark Ezzo.

11 MR. JENSEN: I have a quick comment,

12 Mike Jensen from DOE.

13 (Simultaneous speaking.)

14 MR. RAMIREZ: Okay, Manny, I will

15 add you in there.

16 MR. JENSEN: DOE over the past

17 couple of years -- 

18 MR. RAMIREZ: Say your name.

19 MR. JENSEN: Sorry, this is Michael

20 Jensen from DOE, general counsel. We have

21 been looking into this issue for a couple of

22 years now. And I think one of my asks for the
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1 subcommittee is just to also maybe not just

2 consider this as the fan issue but also

3 determine the impacts of natural air

4 infiltration, based on prior versions of the

5 HUD Code, the current version of the IECC and

6 determine just what impact natural air

7 infiltration has determining overall indoor

8 air quality vis-a-vis mechanical ventilation.

9 MS. HOFFMAN: Can you serve as a

10 consultant to the committee?

11 MR. JENSEN: I am technically

12 supporting Joe here.

13 MS. HOFFMAN: He can? Okay, through

14 Joe.

15 MR. HAGERMAN: But he will provide 

16 -- whatever we collected before we can provide

17 to them.

18 MS. HOFFMAN: Okay.

19 MR. JENSEN: We have a lot of

20 information about indoor air quality, the

21 relationship between natural infiltration,

22 mechanical ventilation and tightening of the
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1 thermal envelope. So, I would just like the

2 committee or the subcommittee to consider

3 those three variables in their deliberations.

4 MR. HAGERMAN: Right. This is Joe

5 Hagerman with DOE just to reiterate what

6 Michael just said was you know is the

7 relationship between R43.6, R43.7, and then

8 also indoor air quality. It is the balance of

9 those three things.

10 There is not a section in any code

11 that really specifically says indoor air

12 quality but it is the elephant in the room.

13 MR. SANTANA: Manny with Cavco. I

14 don't think 403.7 is germane to this

15 discussion.

16 MR. HAGERMAN: Well, I think we are

17 worried about the efficiency of the whole

18 house ventilation and equipment.

19 MR. SANTANA: Okay, so I think you

20 mean 403.6.1.

21 MR. HAGERMAN: Oh, yes, I do. Yes,

22 I do.
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1 MR. SANTANA: Yes.

2 MR. JENSEN: And specifically, just

3 to clarify where I am coming from there, prior

4 versions of the HUD Code and also prior

5 interpretations from ASHRAE on 62.2 at least

6 beg the question as to whether natural air

7 infiltration should be considered in

8 determining overall, vis-a-vis mechanical

9 ventilation in determining indoor air quality.

10 So, I think that there are three

11 different variables that need to be considered

12 equally here.

13 MS. HOFFMAN: What were the

14 variables once again?

15 MR. JENSEN: Natural air

16 infiltration, mechanical ventilation and

17 tightening the building thermal envelope.

18 MS. HOFFMAN: Okay. Now,

19 realistically, can the subcommittee come back

20 with something in time for our next meeting?

21 MR. HAGERMAN: Absolutely is the

22 answer.
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1 MS. HOFFMAN: Thank you, Joe. 

2 Right, absolutely. Let the record show --

3 MR. HAGERMAN: Don't as the

4 question.

5 MS. HOFFMAN: Unless you have the

6 answer, which is absolutely.

7 MR. HAGERMAN: That's right.

8 MS. HOFFMAN: Good.

9 MR. RAMIREZ: All right, then allow

10 this to be handled by the subcommittee. Then

11 that takes care of 403.6. Well, that's being

12 handled so we don't have to bring back a

13 recommendation, right to the main group here?

14 And then that leaves 403.7. Manny?

15 MR. SANTANA: Okay, 403.7 is on page

16 R36. This section deals with equipment sizing

17 and efficiency rating. It is a mandatory

18 section and it basically requires it refers to

19 equipment to be sized using Manual S and it is

20 required that the load be calculated using

21 Manual J.

22 And the subcommittee, well, they
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1 would have come to a determination on this and

2 it is a big issue. The suggestion is move it

3 to the parking lot for further discussion.

4 MR. RAMIREZ: All right.

5 MR. SANTANA: You know part of the

6 reason -- I will give you some of the

7 background. The reasons why we thought the

8 issue was bigger than just the subcommittee

9 itself is because of the contrast with the way

10 this is currently handled by the industry. 

11 You know, the industry currently doesn't size

12 -- well, it doesn't typically provide cooling

13 equipment and it only provides heating

14 equipment. And it doesn't use Manual J to

15 size it.

16 As we discussed in previous

17 discussions, we just account for manufacturers

18 have two or three per the sizes that they buy. 

19 And based on the heat loss calculations, those

20 are just put in with thermal and they think it

21 is going to work fast but they are not exactly

22 sized per the manual.
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1 And then Manual J isn't used because

2 the PNNL methodology, which is spelled out in

3 the HUD Code, that one is used.

4 MR. HAGERMAN: So, this is Joe

5 Hagerman, DOE. Did that, I understand, I

6 think it is a Patel document, the Patel

7 document that is referenced in the HUD Code,

8 didn't that predate Manual J?

9 MR. SANTANA: I don't know.

10 MR. LUBLINER: This is Mike

11 Lubliner. I think that the document was 94. 

12 And I can't recall when the Manual J person

13 Hank Rutkowski first did it.

14 I did talk with Glenn Hourahan this

15 week, who is the Director of Research for

16 ACCA. I am on the Manual S committee, which

17 uses Manual J. The Manual J is the heat loss

18 calculation for the house, the room to room

19 heat loss. Manual S then uses Manual J to

20 size the equipment, any equipment, HVAC

21 equipment. Then Manual D is used to size the

22 duct work if there is forced air ducting
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1 heated system. So, that is the ACCA manuals.

2 When you Glenn and I, when we looked

3 at the HUD Code, his observation was holy

4 moly, this is a thousand BTUs per -- no,

5 excuse me. I think it was twice what would be

6 required if you used Manual J. It should be

7 something like 500 BTUs per ton. And instead

8 of 500 BTUs per square foot, instead when he

9 looked at it, the current is about 1,000 BTUs

10 per square foot.

11 So, anyway you look at it, I think

12 that we need to really reinvestigate how the

13 current sizing is being done -- my

14 understanding it hasn't changed since the '70s

15 -- and really seriously consider using Manual

16 J or a simplified version of Manual J like

17 just upping it from the cfm per ton, come up

18 with a factor like that. 

19 But I do think that conforming to

20 ACCA sizing criteria is what the HVAC industry

21 knows that that is generally the ANSI standard

22 and they are the ones that are going to be
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1 bringing after-market equipment in. And I

2 think conforming to that standard for that

3 equipment that goes into the factory is

4 useful.

5 But it will require that they

6 engineer it more like some of the modular

7 homes that they build that they have to meet

8 the Manual S, Manual J, Manual D criteria for

9 it.

10 MR. HAGERMAN: So, Joe Hagerman, DOE

11 again. Is there a reason why Manual J would

12 not apply to these homes when they apply to

13 all other buildings from the manufacturers?

14 I mean, it is just a -- it is

15 developed by ASHRAE that is physics-based and

16 the laws of physics apply to manufactured

17 housing.

18 MS. HOFFMAN: Thank you.

19 MR. HAGERMAN: Although, David

20 Tompos just shook his head no, they don't.

21 MR. WEISS: Mark Weiss. I point out

22 the laws of economics also apply. If you
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1 increase the price too much, you lose

2 purchasers.

3 MR. HAGERMAN: Right but I think in

4 this case you would actually reduce the size

5 of equipment. So, you actually would see the

6 opposite of that.

7 MR. RAMIREZ: Let me get Eric.

8 MR. LACEY: Yes, Mark, this

9 addresses your point. These are cost savings

10 we are talking about here that I think are

11 being overlooked. And I know we had this

12 discussion. We started this discussion

13 before. And there are kind of two sides of it

14 here. One side is looking at what is commonly

15 installed at the plant, which is, I guess, the

16 heating unit and whether those could be more

17 appropriately sized and that would have some

18 direct cost impacts on the manufacturers, some

19 savings, I should say, impacts on

20 manufacturers.

21 And I think those would be

22 recommended and maybe you don't get all the
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1 way down to the size that you need but if you

2 could reduce it a little bit and allow the

3 units the function as they are designed, then

4 there would be not only some cost savings from

5 the manufacturer but also for the home owner

6 because those get replaced every 10 to 15

7 years and replacing a smaller unit is going to 

8 cost less every 10 to 15 years.

9 The other side of this is the air

10 conditioning, which I understand is not

11 typically installed by the manufacturer but we

12 expect will be installed at some point down

13 the line in most units. 

14 And there is not, I think there is

15 not enough direction given to the homeowner

16 and to the eventual contractor or whoever is

17 going to be installing this unit to tell them

18 this is the size of the unit that belongs in

19 this home. And we have to figure out a way to

20 provide a clearer signal to whoever is going

21 to be installing that. And it may be

22 installed as soon as the unit is sited or when
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1 it goes to the retailer. I'm not sure at what

2 point but I think it happens pretty quickly. 

3 Can we provide guidance if we can't

4 provide a single number for how they should be

5 sized? Because the same issues applied here

6 only rather than the cost being kind of split

7 or the savings being split between the

8 manufacturer and the homeowner, all of the

9 savings would go to the homeowner here. If

10 you have got a smaller air conditioning unit,

11 it is going to run more efficiently, it is

12 going to last longer and it is going to cost

13 less, and replacing the unit is going to cost

14 less.

15 So, this seems to be sort of an

16 untapped source of energy and cost savings. 

17 And if we can't require the ACCA manuals and

18 can't be that specific with it at the plant,

19 can we give a recommendation or provide a

20 chart or a map or something that would give

21 the ultimate installer some better guidance on

22 sizing? That is my rant.
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1 I think I would get another

2 mechanical engineer. I don't understand the

3 specifics but in the stick-built world, this

4 is a huge energy savings issues and cost

5 savings issue.

6 MR. HAGERMAN: I mean the question

7 is still on the table why Manual J and why

8 Manual S here wouldn't apply to manufactured

9 housing. It seems like you all have to do,

10 the manufacturers have to do this for the

11 Modular Code already. Right? So, I mean you

12 know how to follow the manuals.

13 So, is this something that we should

14 just take a vote on right now?

15 MR. RAMIREZ: That is what is going

16 through my head. I mean if that is what you

17 are talking about, it would have be basically

18 you are accepting Manual S and Manual J are

19 fine. What would be the problem with that?

20 MR. TOMPOS: I'm not familiar enough

21 with those manuals but aren't there a

22 provision in there that we have to pick an
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1 actual location, an address and orientation to

2 be able to do those calculations or is that

3 not the case?

4 MR. HAGERMAN: Well, that may be the

5 case but you would have to -- that may or may

6 not be the case but if don't install the unit

7 when you ship it from the factor, you would

8 just push that down to whoever is installing

9 the unit. Right? You would require in your

10 -- 

11 MR. SANTANA: Many from Cavco here.

12 MR. RAMIREZ: Yes, Manny?

13 MR. SANTANA: If I can speak. If I

14 can ask Joe's question as well as I can.

15 You know to the point of how modular

16 manufacturers do it now, in my experience most

17 modular manufacturers run the REScheck. So,

18 they don't do a Manual J, they just run the

19 REScheck. 

20 And I think the question is valid

21 how do we know that Manual J isn't appropriate

22 for HUD Code. But before we answer that, how
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1 do we know that the way we currently do the

2 heat loss count is inadequate? You know I

3 think we should answer that one first.

4 MR. HAGERMAN: I'm just going back

5 to what the statute said that said use the

6 2015 IECC as the basis. So, that is how I

7 come to why would Manual J and Manual S not

8 work.

9 And I believe that -- and I can walk

10 down the hall and ask the team that does the

11 REScheck, I'm pretty sure REScheck runs a

12 Manual J calculation in the background.

13 MR. SANTANA: Yes.

14 MR. HAGERMAN: So, when you do do,

15 when you do complete REScheck, you are

16 effectively doing a Manual J and a Manual S. 

17 It is just way easier to use that software. 

18 But I can verify that over the lunch break and

19 get that answer back to everybody.

20 MR. SANTANA: Yes, because what I

21 don't know, you know I am familiar with the

22 HUD's heat loss calculation and I am familiar
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1 with the Manual J calculation but not in2 depth. But I have never really done a

3 comparison of evidence. I know that the PNNL

4 count was tailor made in that sense for the

5 HUD Code. And I would be concerned, I would

6 like to see how they contrast first, just to

7 make sure we are not going to introduce any

8 issues unwittingly.

9 MR. RAMIREZ: Okay. So, do we need

10 that information that Joe could get between

11 now and after lunch?

12 MR. HAGERMAN: And I can ask. This

13 is Joe Hagerman, DOE. I can ask PNNL over

14 email. They could probably give me a quick

15 answer on the difference between the two and

16 what the recommendation would be, which would

17 probably be wise to do.

18 MR. RAMIREZ: All right, well then

19 let's go ahead and table this. Can you do

20 that at lunch?

21 MR. HAGERMAN: I can do that. I

22 mean they have to respond. I don't know how
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1 quickly they are going to respond.

2 MR. RAMIREZ: Okay, so I guess we

3 will table it for after lunch or sometime

4 tomorrow.

5 Who is on the phone?

6 MR. LUBLINER: This is Mike

7 Lubliner.

8 MR. RAMIREZ: Okay, Michael.

9 MR. LUBLINER: Yes, Just want to

10 point out that they do a worst case scenario

11 when they don't know what the orientation of

12 the home is. They will get like a large

13 subdivision and some of the homes will be in

14 different directions. So, often they will do

15 a worst-case scenario for the sizing and that

16 is something that could be done here as well

17 since we don't know necessarily the

18 orientation of the home when it is finally

19 set.

20 I support Joe getting more

21 information from PNNL on this.

22 MR. RAMIREZ: Okay.
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1 MR. LUBLINER: I think it is going

2 to come down to probably halving the rule from

3 1000 to 500 in the sizing of the per square

4 foot, BTUs per square foot but we will see.

5 MR. RAMIREZ: Okay, Mike. So, we

6 will table that until Joe has the numbers from

7 PNNL.

8 Manny, is there anything else that

9 you have for us?

10 MR. SANTANA: No, that concludes the

11 recommendations by the subcommittee.

12 MR. RAMIREZ: All right. Again, I

13 want to thank you Manny and the subcommittee

14 for doing all that work and those product

15 tests that you undertook there. So, thank

16 you.

17 MS. HOFFMAN: Yes, and who were the

18 members of the committee again?

19 MR. SANTANA: It was Mark Ezzo,

20 Eric, Bert, Luby, and Mark Weiss.

21 MS. HOFFMAN: Okay, we especially

22 want to thank you all.
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1 MR. RAMIREZ: All right. Then, I

2 think it is 11:30. Do we want to go ahead

3 and break for lunch early? Then that way when

4 we come back we could get into Emanuel Levy's

5 straw man, instead of starting for half an

6 hour and breaking?

7 Okay, great. So, let's go ahead and

8 do that and we will start back up at 12:30.

9 MR. HAGERMAN: Emanuel, you know we

10 put on the agenda for Matthew to discuss his

11 LCC for 15 to 20 minutes before you talk. Do

12 you think that is necessary or do you think it

13 is easier just to dive into your proposal?

14 MR. LEVY: I actually took some of

15 his data and I embedded it into the proposal. 

16 We can come back to -- we could do that. I'm

17 not sure it would help in the beginning. It

18 may help coming back to it later.

19 MR. HAGERMAN: So, let's do that. 

20 Let's go ahead and just go with Emanuel first

21 and then we will revisit whether we need to

22 talk to --
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1 MR. RAMIREZ: When we get back, you

2 can fill in any holes.

3 MR. HAGERMAN: Just everybody, and

4 maybe Emanuel when you present your proposal,

5 maybe if you could just at the very beginning

6 talk through how you incorporated Matthew's

7 LCC analysis in the PNNL energy analysis just

8 so everybody feels comfortable with the inputs

9 that you started with.

10 MR. LEVY: I will.

11 MR. RAMIREZ: Okay, great. Thank

12 you.

13 MS. HOFFMAN: So, we will see you at

14 12:30.

15 (Whereupon, the above-entitled

16 matter went off the record at 11:29 a.m. and

17 resumed at 12:31 p.m.)

18 MS. HOFFMAN: We're back online,

19 ready for Emanuel.

20 MR. RAMIREZ: Yes, what I would ask

21 -- let me ask. Emanuel, are you ready to go?

22 MR. LEVY: Yes.
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1 MS. HOFFMAN: I think he said yes.

2 MR. RAMIREZ: Oh, I'm sorry. I

3 didn't hear him.

4 MS. HOFFMAN: Did you say yes?

5 MR. LEVY: I said yes.

6 MR. RAMIREZ: Okay, great. And so

7 before you get started, I would just ask to

8 allow Emanuel to go through the report here

9 and then we can come back and ask any

10 clarification questions. And then we can try

11 to focus on discussion on any areas that may

12 be what I will call heartburn, instead of

13 trying to analyze the entire chart.

14 Also with the idea that we have done

15 a few of these runs now and I think Joe made

16 the point earlier that it seems like the

17 needle isn't moving very much. So, we might

18 have found the area, the neighborhood that we

19 need to be in.

20 So with that, Emanuel, whenever you

21 are ready, go ahead and get started. 

22 MR. LEVY: Okay. Can you hear me
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1 all right?

2 MR. RAMIREZ: Yes. Yes, we can.

3 MR. LEVY: Okay. So, I spent the

4 last few days since the last meeting looking

5 at the question of what the thermal

6 requirements might be in the mapping strategy

7 and number of related issues. And I kind of

8 said to myself, the goal had five parts to it. 

9 One was to develop the methodology for

10 identifying the thermal envelope targets, and

11 in other words saying that the Uo values that

12 the industry used to are based initially on

13 the 2015 IECC. So the first primary goal is

14 to come up with a set of performance targets. 

15 Uo value performance targets.

16 Secondly, I wanted to try to suggest 

17 a way to resolve the mapping strategy, based

18 upon the three-zone HUD maps but reflecting

19 the variations and the characteristics of the

20 IECC map, which is an eight-zone map, and have

21 those two overlay and resolve the differences

22 between those.
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1 Then I wanted to test the results,

2 based upon the life cycle cost information

3 that we had and, as Javier mentioned worked

4 back and forth a little bit with Matthew and

5 I will talk a little bit about how his results

6 came into impact what I did and modify the Uo

7 results that I had initially based upon the

8 LCC results.

9 I wanted to consider more fully and

10 broadly the affordability criterion beyond

11 life cycle cost. Manny, you will see how that

12 figures into what I am going to suggest.

13 And lastly, I wanted to, based upon

14 the results of this now, this articulated

15 prescriptive alternative path that is quote,

16 unquote equivalent from an energy standpoint

17 to the overall U value and Uo value results so

18 that we have at least two paths for compliance

19 that are mathematically, or at least from an

20 energy consumption standpoint, equivalent.

21 So, those are the five goals that I

22 set out to try to achieve. And I will make
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1 some caveats because there is a bit of math

2 here. I got involved into a procedure that

3 involved a bunch of different calculations

4 that I will go through very quickly. I have

5 noticed that there are some tweaks that I am

6 going to want to make predicated on the

7 feedback from the working group on what is

8 here. So, there are some areas of math which

9 I am going to go back and revise but they

10 probably don't have a substantial impact, at

11 least I don't think, on their results but

12 there are probably some math issues here to be

13 dealt with.

14 And I also made some decisions on a

15 number of assumptions that will be subject to

16 the base. That is, I picked up on some issues

17 that needed some decision-making. I made a

18 decision on those but they are certainly

19 debatable and I will point those out as I go

20 through.

21 So, before I get into the

22 presentations, are there any questions about
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1 what my goal is or what I was trying to

2 achieve here?

3 MR. RAMIREZ: I think you are good

4 to go.

5 MR. LEVY: Okay, good. So, open the

6 screen. This is a little analysis that I will

7 come back to but I wanted to explain right up8 front.

9 Typically in the past when we have

10 been involved in these kinds of standard11 setting issues with Energy, we have used what

12 is called a marginal approach, which is to

13 look at each individual measure that is

14 available for consideration and individual

15 measures, R22 in the ceiling, for example, and

16 look at the relative cost benefit of each

17 measure individual and look at them relative

18 to each other. And this is important for a

19 couple of reasons. One of which is it tells

20 you what the relative merits are of doing

21 certain things. And the way I have put this

22 table together is I have simply listed, and if
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1 you just scroll down to the bottom of the

2 table just to get a sense, to make sense of

3 what we are talking about here.

4 I have listed out here all of the

5 options we are considering. And for each

6 option, if you scroll back up anywhere in the

7 table, it doesn't really matter, you will

8 notice that I have looked at each of the

9 measures that are possible on a marginal

10 basis, that is, I have said that R22 ceiling

11 is our baseline. And the question is, is R30

12 cost-effective. And the way you would look at

13 that is you look at the cost, which is in the

14 fourth column there and you see the difference

15 in cost between the 30 and 22, which is

16 $409.30. So, you have the differential in

17 cost and that is for the single section

18 analysis data from a double section which is

19 right next door.

20 So, you have the incremental change,

21 we have discussed this at the last meeting,

22 going from level to level. And you also have
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1 the difference in the U value, which is in the

2 second column in which you go from in the 22

3 case, 0.061 to the 0.045 in the 30 case. So

4 you see what the change in the U value is. 

5 You see what the change in cost is.

6 And the U value, it is important to

7 understand is proportional to the energy use,

8 not perfectly proportional but a pretty good

9 flier for what the relationship is. So the

10 lower the U value, generally the lower the

11 energy use. This is a location independent

12 conduct that is going from 0.061 to 0.045 is

13 going to reduce energy use in a certain

14 proportion and that is going to reduce energy

15 use by more than going from 0.061 to 0.050,

16 for example.

17 The amount of exact reduction in

18 energy use is going to be a functional

19 location, obviously, in weather conditions and

20 a bunch of other things. But what I set out

21 to do is just look at the change in U value,

22 relative to the change in cost because that
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1 gave me a sense of how much bang I was getting

2 for each buck I was spending for that measure.

3 And then I created in the last four

4 columns, three of the last four columns, a

5 ratio of those figures. I took the delta U,

6 the difference in the U value from 22 to 30

7 and the delta dollars, going from 22 to 30,

8 and divided one by the other to give me a

9 ratio. And this ratio, in the case of the

10 single section homes is 036; in the case of

11 the double section is 032; average, simple

12 average are 034. That means that that ratio

13 gives me a sense of what kind of value I am

14 getting for that change from 22 to 30.

15 The change of 30 to 38 costs a

16 little bit less but it has less of an impact

17 in U value. So, the ratio is less. What that

18 means is there is lesser value in going from

19 30 to 38 then there was going from 22 to 30.

20 So, the value in going through this

21 exercise is you can develop these ratios for

22 each of the measures that you are thinking
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1 about. And once you have all of those average

2 figures, 034, 021, 015, and you do that for

3 all your measures, you can start to prioritize

4 all of the measures that you have available to

5 you and decide which ones are going to give

6 you the best value.

7 And if you were going through a life

8 cycle cost analysis, you would add them in

9 that order, that sequence column, the last

10 column there. You would start to add your

11 measures in that order, until you reach the

12 point in which one more measure gave you

13 negative value. And you have to do this by

14 location to know at what point you reach that

15 point.

16 So, you can see that the first thing

17 you would do, and if you would stop right

18 there in the table, the first thing you would

19 do in this whole list is you would go to the

20 baseline of R11 floor and R13 floor. That is

21 the most cost-effective item on the list. So,

22 that is going to give you the best bang for
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1 the buck. That is going to have the best life

2 cycle cost relationship. That is the thing

3 you are going to do first.

4 There is a little more interest to

5 this than I am kind of getting into here but

6 generally, that is the approach that you would

7 use for doing this. If we had a lot more

8 resources and a lot more time, we would go

9 through this exercise and then implement these

10 things for a whole bunch of different

11 locations than PNL and NCI would do tens of

12 thousands of runs and we would have excellent

13 data on which to base our analysis and that is

14 how we would come up with our numbers. Or at

15 least that is one way we can come up with our

16 numbers.

17 But I did this as a starting point

18 because I wanted to get a feeling for what are

19 the things that we have in our packages that

20 are giving us value and what things are not

21 giving us value.

22 So, that is the context. I will
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1 come back to the stable in a few minutes to

2 explain how it fits in. Are there any

3 questions about the table?

4 MR. UNGAR: Yes, before you leave

5 the table, Emanuel, this is Lowell. I

6 understand what you said and it makes sense to

7 me, at least as a rough metric. What I didn't

8 understand was the math when I tried to look. 

9 If you go to the top of the table, what I

10 tried to, for 22 and ceiling -- I'm sorry --

11 for 30 and ceiling I get a difference of 0.16

12 in total U and a difference of $400,000,000.30

13 for delta dollar sign. And when I divide one

14 by the other, I don't actually get 0.036. So,

15 I am confused as to the math you are doing

16 there.

17 MR. LEVY: Well, the exact math flow

18 is you subtract the U from the U, the dollar

19 from the dollar, and you multiply it by the

20 square footage of that component area.

21 MR. UNGAR: Oh.

22 MR. LEVY: So, you have to multiply
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1 it by the ceiling area overlay.

2 (Simultaneous speaking.)

3 MR. UNGAR: But the Uo is not the --

4 it won't do that for you.

5 MR. LEVY: That is not the U value.

6 MR. UNGAR: Total U times ceiling

7 times the area.

8 MR. LEVY: Yes.

9 MR. UNGAR: Thanks.

10 MR. RAMIREZ: And that area number

11 is not on the chart?

12 MR. LEVY: It is not on the chart

13 and I can provide it but you have that -- that

14 is the base condition that we looked at last

15 time. I'm not sure I included that but we

16 have handed that out to the committee before. 

17 It is about 1,068 square feet, I think for the

18 single section and a little bit less for the

19 double section, something in that range.

20 MR. HAGERMAN: Joe Hagerman, DOE. I

21 think the note where he says psf there, per

22 square foot, that is where he calls that out.
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1 But I have a question for you,

2 Emanuel, real quick. What climate is this one

3 example run at?

4 MR. LEVY: This is climate5 independent, Joe. It had to do with the U

6 value of the component. The only thing we are

7 looking for here is what change in U value --

8 let's first of all let's agree to a great

9 extent this is not perfect, that the U value

10 is proportional energy use, not perfect

11 because there is a pull on the cooling side. 

12 It is not exactly the way things work but it

13 is a pretty good flier for putting these

14 things in order was my main goal.

15 U value is independent acquiring. 

16 So, I am not actually looking at energy use

17 here but as a metric that will give me a

18 proportional relationship of energy use that

19 is consistent across all of the measures.

20 MR. UNGAR: Okay, you have answered

21 me. I'm crystal clear now on what this is.

22 MR. RAMIREZ: Emanuel, hold on one
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1 quick second. Could the folks that are

2 online, if you are not contributing something

3 at the moment, could you mute your phones,

4 please? 

5 MR. LUBLINER: This is Mike

6 Lubliner.

7 MR. RAMIREZ: Yes, Michael?

8 MR. LUBLINER: This looks good,

9 Emanuel. I had a couple of questions on the

10 assumptions that are going into the costs, the

11 incremental costs data. Is there somewhere

12 that that is documented? For example, like

13 for the ceiling options, going from R22 to

14 R30, are we talking about just the material,

15 the extra R8 material or is this all of a

16 sudden requiring that you now have baffles, or

17 is it requiring that you change your trusses? 

18 Are those details documented somewhere so we

19 can review those at some point?

20 MR. LEVY: Yes. So, the question

21 Mike had is there backup substantiation for

22 these costs and any U values, for that matter. 
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1 That was provided, Mike, in the last meeting,

2 if you remember those extensive tables we had

3 each of the components and a description of

4 what went into each component level. We

5 provided those at the last meeting.

6 MR. LUBLINER: So, then I will just

7 ask specifically, at what point do you start

8 throwing baffling costs in it, R30 or R38? Or

9 are they not included for the ceiling options?

10 MR. LEVY: You know, the full list

11 of all the measures were included and we can

12 dig into those, if you like. But let me go

13 through this presentation first because in the

14 context of this, that is kind of a detail.

15 MR. LUBLINER: I was trying to --

16 very good. Thank you.

17 MR. RAMIREZ: Let's get quick

18 questions from Mark and Eric and then I would

19 really like for him to get through it.

20 MR. WEISS: I'm sorry. Just very

21 quickly. Emanuel, Mark Weiss, MHA. Can you

22 just remind me the dollar numbers you have
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1 reflected up there? Is that just material

2 costs or does that include labor and overhead? 

3 I know you factored in the markup for retail. 

4 I remember that from last time.

5 MR. LEVY: Yes, so the markup to

6 retail should include everything, Mark,

7 including labor.

8 MR. WEISS: Okay, thank you.

9 MR. HAGERMAN: I think we defined

10 that earlier as the total cost to the

11 consumer. The all-in costs.

12 MR. LEVY: Correct.

13 MR. WEISS: Thanks, I appreciate it.

14 MR. RAMIREZ: Does that take care of

15 your question, Eric?

16 MR. LACEY: No. This is Eric from

17 RECA. You know I am going to ask this and I

18 probably already know the answer but you

19 didn't include in any of these calculations

20 the impact of solar gain. This is just a U

21 factor calculation.

22 MR. LEVY: That's right.
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1 MR. LACEY: Okay.

2 MR. LEVY: And that, Eric, is really

3 one of the things I am alluding to about U

4 value not being a perfect metric to use.

5 MR. LACEY: Okay.

6 MR. LEVY: It gets a little bit more

7 multi-dimensional when you start considering

8 solar heat gain. And there are some other

9 things like that.

10 But when you see how I am using this

11 later on, you will recognize that it is not

12 that critical and we are spending actually

13 more time on it, probably, than it deserves in

14 the context of the overall presentation. But

15 yes, this is not a perfect measure. It is

16 just one way to begin to look at the analysis.

17 MR. RAMIREZ: Okay. So with that,

18 go ahead and continue.

19 MR. LEVY: Okay, so let's go to page

20 two. At page two, can we reduce that? Yes,

21 great. Okay, this you have seen before. 

22 Again, this was handed out last week. This is
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1 taking the table in I guess it is 402.1.1 in

2 the IECC standard and transposing the R value

3 label, the equivalent construction for

4 manufactured housing. So, this is pretty much

5 the table right out of IECC with equivalents

6 for each of the insulation levels, with the

7 exception that we set the room maximum at 38

8 because it was impossible to get to 49, follow

9 the rules in the IECC. So, that is the one

10 change you will see in this table, that we

11 only go to 38 in the ceiling. And that

12 particularly is for zones 4 through 8, which

13 would have been 49. So, those have been set

14 to 38.

15 But this is a table that you saw

16 last week. And again, I am sharing this table

17 because it is where I started with my

18 analysis. And you can see on the far right

19 the column that says Uo value. That is the

20 corresponding Uo value that we calculated for

21 those packages that they would be implemented

22 for manufactured housing.
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1 Okay, we will come back to this

2 table in a few minutes, so don't worry about

3 the specifics. All right, keep going. Go to

4 three.

5 All right, also here you see the map

6 which we looked at last week in which we have

7 overlaid the HUD zones with the IECC zones. 

8 And there is a couple of things to look at on

9 this, which is, of course, if they don't

10 exactly match up but there is some coherence

11 among the zones. As you would expect, it is

12 not perfect. There is some -- if we start

13 with a premise and again, this is the premise

14 that we can debate as to whether it is

15 something we want to stay with or not, that we

16 want our final standard to be used in the HUD

17 3 HUD zones.

18 This is the dark line, the bold line

19 you see running the map shows the distinction

20 of each of the zones and the specific

21 requirements that they have to meet today. 

22 So, HUD 1, which is a federal location, takes
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1 us over to South Carolina, has a current Uo

2 value requirement at 116, 2 is 096, which is

3 that band you see going across the country in

4 northern zone, in Zone 3.

5 And if you look at how they cohere

6 with the IECC zones, you will notice a couple

7 of things that are rather important in terms

8 of what I will be talking about next. In

9 particular, in HUD Zone 1, HUD Zone 1 has in

10 it parts of IECC Zones 1, 2, 3, and 4; 1 is

11 the Miami area, 2 is the red area, 3 is the

12 brown area, 4 is the yellow area. But what

13 you will notice is that HUD Zone 1

14 predominately 2 and 3, the red and brown

15 areas. So, where virtually all the homes are

16 going in Zone 1 is either in what corresponds

17 to IECC Zones 2 and 3. That should be pretty

18 evident, just graphically from what is up

19 there.

20 By the same token, if you look at

21 HUD Zone 2, it primarily consists of 3 and 4

22 and a little bit of 5, which is the brown, the
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1 yellow, and the green. So, that will give you

2 a sense of what are the prominent overlaps

3 between the zones. And in HUD 3, you get a

4 real mix going anywhere from 4 up to in the

5 newer 7, 7/8. So, keep that in mind as we go

6 to the next slide. Any questions on that?

7 Okay, now, things get a little bit

8 hairy here. What I try to do is then map this

9 in terms of dollars. The first column are the

10 IECC Zones. The second third and fourth

11 column are corresponding overlaps with the HUD

12 Zone. So, what I mean exactly is that if you

13 look at HUD Zone 1, which is that second

14 column, you will notice that the corresponding 

15 intersection with IECC Zone 1 and 4 are gray

16 areas and the corresponding intersection of

17 HUD Zone 1 and 2 and 3 of IECC is emphasized

18 with black with a white 1 in the middle of it. 

19 What that means is that there is a profound

20 overlap between HUD Zone 1 and IECC 2 and 3

21 and only a modest overlap or a small overlap

22 with 1 and 4. Is that clear for everyone? 
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1 This is what I mean in terms of the overlap of

2 the zones.

3 By the same token, you will that for

4 2 and 3 I have also mapped the overlaps with

5 the profound overlaps are and where the more

6 modest overlaps are.

7 Okay, having done that, I then went

8 back to the dollars. And I said okay just for

9 the profound overlaps because we have to come

10 up with a methodology that is somewhat simple

11 and straightforward, just for the profound

12 overlaps what the costs impact.

13 So, the cost of going from a house

14 that is in HUD Zone 1 to the requirements in

15 IECC Zone 2 is $2,000.46. See that

16 intersection? So, basically the same pattern

17 is followed in the next three columns. That

18 number that the cursor is on right now, the

19 $2,000.46, that is the cost of going from HUD

20 1 to IECC Zone 2. That is why it is in that

21 box.

22 So, I have just mapped out, dollar-
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1 wise, where the profound overlaps are between

2 zones and what the cost impact is of going

3 from HUD up to the IECC requirements. Is

4 everyone following that? Okay.

5 Now, if you will just go up a little

6 bit on this page, okay. Coming back to the

7 issue about affordability and other metrics

8 that define affordability. I also wanted to

9 consider what the impact was on cost. And I

10 know this has been an issue that we have

11 debated and discussed at some length, so I

12 took a shot at it, at trying to evaluate how

13 we might work that information and looked at

14 the single section, average cost nationwide of

15 single section home which is $42,200, which is

16 that number at the top of the table. So,

17 $42,200 is the average cost of the single

18 section in the country. And I set as a rule,

19 and of course this was my take on it, I am not 

20 going to allow the cost of the package,

21 whatever the cost of reaching the package that

22 is going to be in the standard to be more than
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1 five percent increase over the cost of the

2 home and that is why I took five percent of

3 $42,200 and ended up with $21,010.

4 So, I set as a rule, and of course,

5 this is a debatable that the cost of the

6 package could not be more than $21,010. And

7 then I went back into the table and wherever

8 there was a number that was larger than

9 $21,010, I grayed out that cell. So, just

10 where the cursor is, the $2,750 dropped out to

11 those $3,000 figures. So, follow through the

12 rest of the tables.

13 And I said okay, those are too much. 

14 I am just going to focus on where the costs

15 are less met and what the corresponding U sub

16 o values are from the prior table on page two

17 and those are the ones that are now listed in

18 the columns that you can see the cursor on

19 right now.

20 So, the $2,046 corresponds to a U

21 sub o value, IECC Uo value of 0.085. For the

22 two figures that are below $21,010 in Zone 2,
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1 they are both 0.067 and for the two that are

2 in 3 are 0.067 and 0.059.

3 Just to finish out this page, if you

4 scroll down a bit, do the same thing for

5 double section home, same thinking. And then

6 what I did is I simply took the Uo values from

7 each of the HUD zones and I came up with a

8 simple average down at the bottom, those are

9 the U sub o values that I landed on as the

10 average for those recommended U sub o's for

11 those zones before what are called

12 adjustments. And I will talk about

13 adjustments in a second. So, let me just stop

14 there and see if I completely confused

15 everybody.

16 Are there any questions?

17 MR. RAMIREZ: Looks like you are

18 good.

19 MR. LEVY: Mike Lubliner has got a

20 question or a comment, I guess.

21 MR. RAMIREZ: Go ahead, Michael.

22 MR. LUBLINER: It seems like that
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1 that five percent is an arbitrary number. I

2 think that the methodology is excellent. I

3 like what you have done. I understand what

4 you have done. But it seems like -- where do

5 we get the five percent from? 

6 It seems like what I was thinking we

7 were doing here is going through and I

8 understand this is a straw man and the five

9 percent is what is driving the straw man. I

10 thought what we were going to be doing is

11 looking at the IECC, which I think you have

12 done, as is, look at the costs and then

13 determine whether or not they are lowest life

14 cycle costs. In other words, the package is

15 cost-effective because the life cycle costs as

16 a whole are lower than the current practice.

17 So, the five percent seems to take

18 us off the path of that approach. And I am

19 interested in seeing how it comes out. So,

20 just an observation there and a question. How

21 did you come up with the five percent,

22 Emanuel?
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1 MR. LEVY: As I said in the

2 beginning, I picked a number that I thought,

3 intuitively. It would be great to get,

4 particularly, the input of the committee that

5 is dealing with these kinds of metrics as to

6 what they set. But yes, it is a separate

7 issue from life cycle costs. It is a second

8 consideration.

9 It is acknowledging the fact that

10 life cycle costs may not come up with figures

11 that in the end are necessarily affordable. 

12 So, I try to bring in, by interjecting this

13 cap on the total possible cost of the package. 

14 You know that the level of pain, if you will,

15 that the customer is willing to endure in the

16 energy package.

17 I try to inject some idea of -- you

18 know one other considerations that might be

19 worth to table, without ignoring the life

20 cycle costs, I will come back to, by the way,

21 I will come back to life cycle costs later on

22 and talk about how that might come into play. 
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1 But yes, it is a separate item. The five

2 percent was kind of more of an experiential

3 consideration than anything else but that is

4 certainly something that should be open for

5 debate and discussion.

6 MR. RAMIREZ: Robin.

7 MR. ROY: This is Robin. Thanks,

8 Emanuel. This is all very helpful.

9 I guess to sort of follow-up on

10 Luby's five percent question, I have to say I

11 have been thinking about affordability in

12 terms of for all the buyers in the homes, so

13 that is like a 30-year life cycle cost of this

14 product. And the other perspective that I

15 found to be needful in my own thinking about

16 it and kind of get a handle on affordability

17 is the perspective of the first buyer. And

18 for that, we are looking what is the average. 

19 Ten years. What is the resale recapture. We

20 have some numbers for that. So, I quite like

21 the types of economic analysis that Navigant

22 has been putting together to look at those two
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1 different perspectives; first buyer's

2 perspective, all owners' perspective over

3 time.

4 I see what you are doing with the

5 five percent. It is a simplification and it

6 is handy for it. I just think maybe it is

7 something that draws me in. I much more

8 interested in that first buyer's perspective

9 by a great deal.

10 MR. LUBLINER: This is Mike Lubliner

11 and I didn't hear anything. That was a bunch

12 of echo on my end. I think it was Robin that

13 was talking.

14 MR. RAMIREZ: Yes, you want to give

15 him the headline version?

16 MR. ROY: I'm not sure that is going

17 to change anything. How am I going to do

18 that?

19 MR. RAMIREZ: Did Emanuel hear? 

20 Emanuel did you hear it?

21 MR. LEVY: I heard most of it.

22 MR. ROY: Okay. Luby, can you hear
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1 this? I'm afraid it will not help to say it

2 again.

3 MR. RAMIREZ: Luby, how is the sound

4 now?

5 MR. LUBLINER: Still echoes. 

6 Somebody must have their -- is not muting that

7 is on the phone.

8 MR. ROY: Well I shall do a one and

9 a half minute echo because that is about how

10 long ago I said this the first time. Sorry,

11 that was a stupid joke for the people in the

12 room and not for the folks out there who are

13 suffering through bad IT.

14 My view -- I appreciate what you are

15 doing, Emanuel, and it is very helpful in

16 simplifying and trying to come up with some

17 numbers. But from my perspective, I have been

18 trying to understand what is a meaningful

19 affordability metric. And I quite like the

20 approach that is reflected in the Navigant

21 economic analyses, which is looking at two

22 different types of cost-effectiveness. One,
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1 the cost-effectiveness from the perspective of

2 all buyers over the life of the product, so

3 the 30-year perspective. And the other

4 perspective, which is from the first buyer's

5 financial perspective.

6 So, I think they have been using ten

7 years. We seem to have come to rely on that

8 was not a bad number to use. Ten years and

9 some kind of resale or recapture properly

10 discounted. To me, it is more meaningful than

11 just the first cost. That is really what that

12 first buyer is going to be facing. It is

13 really what is going to be a more defensible

14 definition of cost effectiveness than the five

15 percent.

16 The first buyer's perspective sounds

17 like a very good definition of cost

18 effectiveness that I think that DOE could

19 support.

20 MR. RAMIREZ: All right. Well,

21 let's hear what else -- I'm sorry. Michael,

22 were you able to hear that?
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1 Maybe not. Emanuel, were you able

2 to hear that?

3 MR. LACEY: Yes, I could hear it

4 perfectly.

5 MR. KESSLER: This is Bert. For

6 what it is worth, I heard just fine.

7 MR. RAMIREZ: Okay, thanks, Bert. 

8 Lowell, you had something?

9 MR. UNGAR: Yes, there are two

10 things, one in response to Robin. Another

11 affordability metric, it seems to me one that

12 has been used in the codes world is a cash

13 flow analysis. If the buyer is effectively

14 paying a down payment upfront and getting each

15 month a little bit more back in energy than

16 they are presumably paying on their mortgage,

17 how long does it take for the energy savings

18 to pay back what they put into the down

19 payment? So, how long is it until they come

20 out ahead on a cash flow basis? That might be

21 one more way of looking at the affordability.

22 What I really wanted, actually, was
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1 a question to Emanuel. If we take a five

2 percent cap, which I also have some problems

3 with, why wouldn't we just apply a five

4 percent cap? What you are doing is looking at

5 a bunch of numbers, taking those which are

6 five percent or less, and then averaging all

7 of those that are five percent or less.

8 If we were putting a cap, I would

9 think we would go up to the five percent limit

10 and just use the whatever package, whatever

11 efficiency we can get that is within that five

12 percent cap.

13 MR. LEVY: Yes, we can do that. 

14 That would be easy enough to do. For example,

15 in IECC's Zone 6, in the single sections where

16 it is grayed out, if the cap is $2,100, we can

17 see how much conservation or how much

18 efficiency we can buy for $2,100 and what Uo

19 value that gives us. And that would modify

20 the results somewhat. I don't know exactly

21 how much.

22 And if we took the cap away
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1 entirely, by the way, and just included

2 everything where there is a profound

3 intersection of zones, if that methodology is

4 acceptable, again, it will change the results

5 somewhat. I don't think it will change them

6 dramatically but it will change them somewhat. 

7 And we could look at all of those.

8 MR. RAMIREZ: Mark and then Eric.

9 MR. WEISS: Emanuel, just again, I

10 apologize, remind me. The cost you are using

11 is the average cost. That is the cash price,

12 correct?

13 MR. LEVY: That is correct.

14 MR. WEISS: Okay, thank you.

15 MR. RAMIREZ: Eric.

16 MR. LACEY: Emanuel, it is Eric. I

17 hate to pile on on your five percent. I

18 realize it is kind of a simplification but one

19 thing that is not reflected here if I am

20 understanding this is the amount of energy

21 saved from one zone to the next. It may be

22 that in some of these grayed out zones, there
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1 is a significant amount of energy being saved,

2 even though it goes beyond the five percent. 

3 There is not an accounting for that in this

4 particular table, right?

5 MR. LEVY: You are asking if you

6 exclude, for example, the Zone 7 and you say

7 that there is no -- let me just make sure I

8 understand what you are saying. We have not

9 included the Zone 7 and Uo value calculation. 

10 You can see that the average for the zone

11 right now is 0.061 for Zone 3. That is an

12 aggregate of all the numbers above.

13 If you go back up to the table on

14 page two, you will notice that if we add in 6

15 and 7 that adds in 0.053 and 0.051 or 0.056

16 and 0.050, depending on where you are. So,

17 what I am saying is, when you add those into

18 the mix, it will bring down the Uo value.

19 MR. LACEY: Yes, I guess that is

20 what --

21 MR. LEVY: It won't bring it down

22 dramatically. It is probably in the -- we are
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1 probably talking about two thousandths of a

2 difference in the Uo value.

3 MR. LACEY: That is part of what I

4 am asking. I guess going back to the Navigant

5 spreadsheet, Climate Zone 6 and especially 7

6 and 8 were highly cost-effective at the 20.15

7 IECC levels, if I remember that right.

8 MR. LEVY: Yes.

9 MR. LACEY: You know so yes, and

10 they cost more than five percent but on an

11 energy savings standpoint and from a payback

12 perspective, they were more cost-effective

13 than Climate Zones 2 and 3, for example, which

14 may come under the five percent cap that you

15 put here but may have a longer payback.

16 I just wanted to make sure I am

17 understanding. There is this simplification

18 here.

19 MR. LEVY: Yes, I mean I don't know

20 if I should get into this now but the Navigant 

21 life cycle cost analysis looks at the total

22 package, I think as was mentioned earlier, in
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1 going from, in this case, HUD package 3 up to

2 4, or 5, 6 and 7. So, each one of those is

3 looked at individually and, of course, the

4 fact that you have a big jump from current HUD

5 Zone 3 to what is in 7 or 6, 7, and 8 is just

6 a reflection of the fact that that is a huge

7 jump in energy efficiency from the baseline.

8 My point is we can include that but

9 in a practical matter in terms of impact and

10 U sub o value, it is probably only going to

11 change it by, when you average it all together

12 -- remember you are creating a zone, a Zone 3,

13 HUD Zone 3 which includes all of, includes

14 parts of 4, 5, 6, 7, and 8, mostly 4 and 5 and

15 6.

16 So, you have a huge zone in which

17 you are averaging things. And so those have

18 a lot of cost effectiveness to them but they

19 don't change the average U sub o value that

20 much. I guess that is the bottom line.

21 MR. LACEY: Okay.

22 MR. ROY: Emanuel, supposing you
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1 used the HUD Zones and mush together all these

2 things, including some which are extremely

3 cost-effective and some which are not, which

4 is one the challenges with the HUD Zone being

5 so spread across from the warm parts of

6 Virginia to the coldest, bitterest of the

7 nation's rural 48. It's one of the challenges

8 with it.

9 MR. LEVY: I couldn't have said it

10 better, Robin. That is exactly what I am

11 trying to.

12 MR. RAMIREZ: Okay to move on?

13 MR. LEVY: Yes.

14 MR. RAMIREZ: Does anybody have a

15 follow-up here?

16 MR. LACEY: Yes, this is Eric. I

17 hate to belabor this because again, I know

18 this is simplified. What you are including

19 here is the cost of getting to a specific U

20 sub o. And by including the Climate Zone 7

21 and 8, you are right, the U sub o numbers may

22 not change all that much but the payback
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1 numbers may change significantly because there

2 is a lot more energy used in those climate

3 zones. Two houses could have the same U sub

4 o but there is a lot more energy used to heat

5 in Climate Zones 7 and 8 than there is in 4

6 and 5. You know, obviously, this table isn't

7 going to address that. But I just -- maybe I

8 was a little uncomfortable with the level of

9 simplification here but I understand why you

10 are looking at the five percent.

11 MR. ROY: To say it differently, a

12 person's winter wardrobe in Tidewater,

13 Virginia is probably different than a person's

14 winter wardrobe in Bismarck, North Dakota. 

15 I'm just guessing but certainly is. 

16 MR. LACEY: You get your money's

17 worth out of it in North Dakota.

18 MR. RAMIREZ: Yes, I remember

19 correctly, the group also said that we were

20 going to look at the life cycle cost for ten

21 years and thirty years. So, if those are

22 going to be the runs the data is going to do.
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1 So, at some point if we need to look

2 at how do these numbers plug into those life

3 cycle costs, then that is something that

4 Matthew can hook up the computer later and we

5 can take a look at those. Okay?

6 So, prescriptive?

7 MR. LEVY: Not quite yet.

8 MR. RAMIREZ: Okay.

9 MR. LEVY: I wasn't done and I

10 wanted to create a little bit more

11 controversy.

12 MR. RAMIREZ: Okay, go ahead.

13 MR. LEVY: All right, so let's go to

14 page five. To the panel, I have to say,

15 interject my view on the whole life cycle cost

16 base because I have a slightly different

17 perspective on it. 

18 I think what Navigant has done is

19 really very valuable. It has given us a sense

20 of just how cost-effective certain things can

21 be under various economic conditions. But it

22 wasn't helpful in one respect in terms of
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1 doing this analysis because what I really

2 wanted to do and why I did the analysis on the

3 first page is understand what the marginal

4 benefits were. And what Navigant has done is

5 looked at the whole package of measures. 

6 So, when we say together that going

7 from HUD Zone 3 to IECC Zone 7 is really cost8 effective, almost regardless of what your

9 economic conditions are, we are looking at the

10 value of the whole package. And not

11 concerning the fact that the first couple of

12 things that have been added to the package

13 might be contributing in a disproportionate

14 way to the overall benefit that is figured in

15 the life cycle cost benefit.

16 So, the question I ask is,

17 specifically, if we can scroll up just a

18 little bit, I said okay, given what we have

19 seen, what I have discussed so far -- sorry. 

20 Scroll down a bit. Given what we have seen

21 thus far, in terms of the analysis, the

22 question I ask is if you look at the
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1 individual measures and now that we have a

2 package of measures, if we look at the

3 individual measures, particularly R38 in the

4 ceiling in Zones 2, 3, and 4, is that measure

5 really cost-effective relative to R30? 

6 And the reason I ask that question,

7 if you go all the way back to page one at this

8 point, the reason I asked whether 38 was cost

9 effective than an individual measures was if

10 you look at that relative sequence here, the

11 38 change has a sequence value of 15. It is

12 very low on the priority scale. Very bad

13 relative to other things. Very bad in terms

14 of payback.

15 So, I really wanted to understand

16 whether for those specific climates whether

17 going from 30 to 38 made sense.

18 And so then if you now go down to

19 page six, I asked Matthew to specifically run

20 that case to see whether -- to me, this is

21 where the tire meets the road -- whether R38

22 in place of 30 makes sense. And the figures
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1 that are -- sorry. It should say incremental

2 savings in the second column there. 

3 So, for these four locations, these

4 are the IECC Zones 2 and 4, two different

5 locations in each, the savings for a single

6 section home going from 30 to 38 was $4 a

7 year, as I interpreted it, $5 a year for the

8 2B, 11 and 11. You can see what the

9 incremental savings, it should say, is and you

10 can see what the cost is. And then you can

11 also see what the simple payback is.

12 So, in the best case, unless I

13 misinterpreted these numbers, which is always

14 possible, in the best case you get a simple

15 payback of 12 years, in the worst case, almost

16 90 years, which to me is very suspect in terms

17 of whether that is a viable cost-effective

18 measure. And this to me is the real use of

19 life cycle cost analysis, not to find the

20 total life cycle cost benefit in which you can

21 make almost anything look good, but to look at

22 those things that are on the margin and say
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1 from a customer standpoint, does it make

2 sense, once you are in R30 to invest in an

3 additional R8. And if these are the numbers,

4 one would have to say it doesn't make any

5 sense.

6 So, if you move back up to the page

7 five, I asked that question about three

8 different measures and of course you can go

9 farther into this analysis. And I said based

10 upon these results, I can't justify 38 in 2,

11 3, and 4.

12 So, on this table, I took those -- I

13 am sure we are going to have come comments

14 after this. So, I took the 38 out of those

15 three zones and I put in R30 because 38 was

16 just simply not cost-effective. And if we

17 stand behind cost-effective criterion, this is

18 the conclusion we have to come to, I think.

19 Before you make comments, let me

20 just go down to the next slide after this one

21 right here. I followed the same methodology,

22 made the changes for the R values that I
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1 indicated. And you can see after these

2 adjustments what the U values become, Uo

3 values, 0.085, 0.069, and 0.062, which is

4 about an increase, again, a modest increase of

5 0.002 over the other factors.

6 You can see that even changing some

7 of these assumptions were interjecting some of

8 this different way of thinking about the

9 economic balances has a modest impact in the

10 U sub o value.

11 Let me stop there and face the

12 consequences.

13 MR. RAMIREZ: Okay, Robin.

14 MR. ROY: Emanuel, I think this is

15 very helpful. It is actually -- you wanted

16 controversy? This is controversy.

17 This is a question that has been

18 kind of weighing on me as well when it came to

19 38. I have also wondered about some of the

20 wall insulation in the milder climates. I'm

21 not talking about 5, 6, 7 but these milder

22 climates it seemed like it may be spending
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1 more than you are getting value for. So, this

2 is very helpful in understanding that and I

3 have to say I am not terribly surprised but I

4 generally like the approach that you have

5 taken. That is my controversial reply.

6 MR. RAMIREZ: Mark.

7 MR. WEISS: Emanuel, Mark Weiss,

8 MHAR. Is there any new and empirical data

9 reflected in this analysis that was not

10 included in the first one that you did? Or is

11 this effectively a refinement of the empirical

12 data you had previously?

13 MR. LEVY: You mean on the page

14 above, Mark?

15 MR. WEISS: In any of it.

16 MR. LEVY: Are you talking about

17 from the last meeting or from just the yearly

18 presentation?

19 MR. WEISS: From the last meeting.

20 MR. LEVY: So, this analysis

21 embodies the cost and the U values that were

22 presented at the last meeting.
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1 MR. WEISS: Okay, so it is a

2 refinement.

3 MR. LEVY: Well, this was my taking

4 that information and from that developing a

5 recommended set of Uo values of performance

6 path and what the thinking was that led up to

7 that. And predicating on keeping with the HUD

8 Zones as they are today.

9 MR. WEISS: Okay, that answers my

10 question. Thank you.

11 MR. RAMIREZ: Eric.

12 MR. LACEY: Emanuel, it is Eric. 

13 First, a question. I am comparing your Uo

14 value analysis before adjustments, page four,

15 and the one that we are looking at, page

16 seven, and the average costs haven't changed

17 between the two. Is that a mistake or are

18 those supposed to be the same?

19 MR. WEISS: That is a mistake. I

20 didn't readjust. When I went down to 30, I

21 didn't readjust that cost.

22 MR. LACEY: Okay. I mean, I assumed
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1 that some of those might go from gray to

2 black. Maybe not. They might get closer.

3 MR. LEVY: That's right. Well, not

4 so much the gray to black but where there is

5 black it might go -- I'm sorry. The numbers

6 maybe go from gray to black and that is what

7 I meant earlier, Eric, when I said the math

8 needs some tweaking. I started seeing those

9 things as I went back through this.

10 I don't think those will make a

11 substantial change but there needs to be some

12 revisiting of the math throughout the entire

13 analysis, actually.

14 MR. LACEY: Okay. I guess maybe a 

15 --

16 MR. RAMIREZ: Hold on a second. 

17 Eric has another comment.

18 MR. LACEY: I wasn't going to throw

19 my controversial comment in. I didn't think

20 Robin's was all that controversial.

21 MR. ROY: Well, it will be just not

22 with Emanuel.
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1 (Laughter.)

2 MR. LACEY: I guess I am not a huge

3 fan of picking individual increments and

4 pitting them one against the other in terms of

5 cost-effectiveness and so on because so much

6 of this depends on the assumptions that are

7 made in the life cycle cost analysis and I

8 have been messing around with it and very

9 minor tweaks in these assumptions completely

10 change the outlook on the back end. 

11 And so I get what you are trying to

12 do and it may be that there are some measures

13 that are so radically cost ineffective that it

14 makes sense to change those, especially in

15 light of our requirement to make it

16 affordable.

17 On the other hand, I hate to see us

18 dragged down into a measure versus measure

19 analysis on every single thing. I think

20 trying to find the absolute most single cost21 effective level for every single component. 

22 Because I think with a few tweaks in the
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1 assumptions, those can completely change.

2 MR. LEVY: Eric, I agree with you

3 except I was a little surprised looking at the

4 38 to 30 change that that was so cost5 ineffective, you would have to have a pretty

6 big difference in your assumptions to make up

7 the difference.

8 So, I agree that when things are on

9 the cusp, you have to really be diligent about

10 your evaluation. And that, of course, goes

11 true for even when you look at the whole

12 package. As I was seeing from the Navigant

13 analysis, changing your assumption on the

14 period of analysis does change things

15 dramatically. This is what we live with when

16 we buy into life cycle cost.

17 MR. RAMIREZ: All right, let's get

18 Michael and then Lowell.

19 MR. LUBLINER: Yes, I guess I

20 thought we were dealing with first cost

21 affordability by doing the 10-year analysis

22 and then we were looking at the 30-year for
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1 the overall mission.

2 So, I kind of see this as a little

3 bit of mission creep but I understand the

4 exercise and I think it is a useful one to

5 look at the marginal individual cost6 effectiveness of measures. However, I

7 fundamentally disagree with this approach for

8 setting codes.

9 I, basically, have been

10 indoctrinated from building America into a

11 systems engineering approach to designing

12 energy efficient homes, where you get savings

13 from the first measure and that savings, the

14 energy savings gets applied to other measures

15 which aren't necessarily as cost-effective,

16 but as a whole, the whole package still meets

17 the lowest life cycle cost compared to the

18 package you were looking at as the baseline.

19 So, I got a fundamental problem

20 based on assistance engineering approach to

21 analysis. And I kind of think that we have

22 this affordability of the 10-year and this is
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1 just a different angle. And I think the five

2 percent is real arbitrary and maybe seen as

3 capricious when people from the IECC look at

4 this and say well what is the five percent. 

5 Where do get that? Why are you doing

6 incremental? Who cares what the increment is

7 if the overall package is in the best interest

8 of the consumer?

9 The consumer doesn't see the savings

10 of the incremental measures. They see the

11 savings of the whole house.

12 So, I am feeling like this is a

13 little mission creep from what we -- and we

14 discussed this for a few hours a couple of

15 meetings ago. I like the fact that you

16 presented it. We can see which are marginal

17 areas but I don't believe that we should be

18 reducing these because of a five percent

19 assumption.

20 I think the other point is is that

21 if you do a five percent assumption, you end

22 up with losers, real big losers, people that
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1 buy these home in cash or conventional

2 mortgages. And those people are going to lose

3 measures that to them are very cost-effective.

4 So this whole thing, the least

5 common denominator of affordability as first

6 cost and then cherry picking it down to

7 individual measures isn't my approach. That

8 is not something that I can buy into.

9 Thank you.

10 MR. RAMIREZ: All right. And the

11 way I look at that is it was just a metric to

12 look at, at least at this point.

13 But let me get Lowell, Joe, and then

14 David.

15 MR. UNGAR: Yes, I could nitpick

16 both assumptions and the math but I am also

17 not sure that the conclusions would change. 

18 But I did have two questions. One is the

19 incremental savings, is that based on a PNNL

20 run that just changed the ceiling insulation

21 level and whatever the other assumption

22 separately changed the other assumptions you
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1 were looking at?

2 MR. LEVY: Yes. Yes, that was a

3 PNNL run of just that case, changing from 30

4 to 38.

5 MR. HAGERMAN: Let me interject -- 

6 this is Jose Hagerman from DOE -- just real

7 quick. That assumption was modeled by PNNL

8 and we have put everything that PNNL can model

9 into the latest version of Matthew's life

10 cycle tool that he can present right after you

11 are done with this so you can see how things

12 rack and stack.

13 And it is true, I think in my

14 opinion it is true what Emanuel said about

15 going from a 38 to a 34 or a 30 ceiling

16 insulation. It looks like it is more cost

17 effective to go with a lesser ceiling

18 insulation because the annual energy numbers

19 don't really move that much coming from a 34

20 to a 38 or a 30 to 38, which we can see here. 

21 That statement, you can arrive at

22 that conclusion not by -- I mean you can
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1 arrive at that conclusion the same way that

2 Emanuel did in this packet, but you could also

3 arrive at that conclusion by just looking at

4 the life cycle analysis and seeing things

5 change.

6 MR. UNGAR: The life cycle analysis

7 --

8 MR. HAGERMAN: Right.

9 MR. UNGAR: -- and that separate

10 line.

11 MR. HAGERMAN: That's right.

12 (Simultaneous speaking.)

13 MR. HAGERMAN: Which we will see. 

14 It was shook out to you late yesterday just

15 because it has taken a lot of time to get

16 together everything but we can show that right

17 after this discussion.

18 MR. UNGAR: My other question was, I

19 mean I understand IECC does not necessarily do

20 cost-effectiveness analysis. So, whether you

21 think this result has something to do

22 specifically with manufactured homes, that
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1 they are different from stick-built homes or

2 is it just that your suspicion as for these

3 climate zones R38 insulation just isn't cost

4 effective?

5 MR. LEVY: I'm not sure what the

6 question is, Lowell.

7 MR. UNGAR: My question is is this

8 analysis where you are showing there is not

9 much savings for a somewhat expensive measure,

10 does this have to do with something regarding

11 manufactured homes? Is it different from

12 stick-built homes? Or if you do this analysis

13 on stick-built homes, would you get the same

14 result?

15 MR. LEVY: Well, you might get

16 different results with stick-built homes. I'm

17 not sure about that. This is a result

18 specific to manufactured homes because we used

19 an R38 and how it would be constructed to the

20 manufactured housing setting, what the

21 exceptions would be for an R38 ceiling and

22 what the cost would be for that matter for a
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1 site-built home is likely to be different and

2 I'm not sure how different.

3 MR. UNGAR: So, you are not sure for

4 the cost or the savings whether this is

5 something particular to manufactured homes.

6 MR. LEVY: Right. This is --

7 MR. UNGAR: I understand the

8 analysis was only for manufactured homes. 

9 What I don't understand is whether there is

10 some unique characteristic of manufactured

11 homes that is causing this result.

12 MR. LEVY: Well, you know, I do want

13 to reinforce what you said to begin with which

14 is there is no proof that the IECC standard is

15 cost-effective either. I think they are

16 saying that the IECC standard is based upon

17 cost-effectiveness might be going a little too

18 far, too.

19 MR. UNGAR: I did not say it.

20 MR. HAGERMAN: Can I just make a

21 suggestion here? I don't know if this is

22 going to answer your question, Lowell, but let
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1 me just go back to the latest life cycle

2 analysis when you went from the 38 to the

3 lower levels, that change did turn, which were

4 three climate zones that were red turn those

5 three into two blacks and then we are always

6 double digit negative and I think San

7 Francisco, which has higher energy prices and

8 a more moderate climate.

9 So, I mean that is one way of

10 looking at it. Which I encourage if we can

11 get to some resolution on that, maybe it would

12 be helpful for you to balance everything that

13 Emanuel is going through right here, which is

14 all really good. In my opinion, it is going

15 to kind of arrive us all at the same place.

16 And then the life cycle tool that we have been

17 looking at consistently, if we kind of rectify

18 those two, I think we can get some closures on

19 this.

20 MR. RAMIREZ: Okay, Joe did you have

21 a question?

22 MR. HAGERMAN: Yes, Manny can go
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1 first.

2 MR. RAMIREZ: Okay, go ahead, Manny.

3 MR. SANTANA: Yes, I think that we

4 might be getting a little too bogged down on

5 the five percent. You know Emanuel stated

6 that it was arbitrary to start with. And what

7 have we, that five percent turns into ten

8 percent or altogether and just hit a dollar

9 amount increase. I think what is important to

10 consider here is the methodology and what

11 results we are going to get. On the index, we

12 have got a couple of items that we need to

13 address. Going through this procedure is

14 going to get us U values. It is going to get

15 us climate zones potentially. And it is going

16 to get us a prescriptive package.

17 We can go through, you know, I think

18 the message and the approach is sound. We can

19 all see where the numbers are coming from. 

20 You know whether the five percent is too much,

21 I guess to assume, we go through this kind of

22 with group zones, come up with a package, run
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1 that through the analysis and see how that

2 turns out. But I think the approach is

3 fantastic.

4 MR. RAMIREZ: Okay, let me get Joe

5 and then David.

6 MR. HAGERMAN: I just have two

7 questions. First of all, I see that what you

8 do is you do a single section, U sub o and

9 then a double section U sub o and then you

10 get, I guess a composite U sub o, which is in

11 the box, the black box that is at the bottom. 

12 Right? I am on page four. 

13 Is there any reason that the

14 standard couldn't have different U sub o's for

15 singles and doubles?

16 MR. LEVY: I think that's probably a

17 question more for the manufacturers.

18 MR. HAGERMAN: I mean I wouldn't

19 think you would -- how does the code treat

20 that right now? Is there just one? Because

21 there is a big difference.

22 MR. MENDLEN: One value.
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1 MR. HAGERMAN: There is only value? 

2 Okay, that is interesting because they are

3 geometrically different.

4 And then the second question is so

5 in the column 3, HUD Zone 3, you have lumped

6 in Zone 4 and 5. And then column 2, HUD Zone

7 2, you have lumped in 3 and 4. So, IECC Zone 

8 4 gets kind of double-counted there. Right?

9 It impacts HUD Climate Zone 3 just

10 as it impacts HUD Climate Zone 2. Right?

11 MR. LEVY: That's right.

12 MR. HAGERMAN: There is a big

13 difference between a 0.067 and a 0.059 and a

14 0.066 and 0.056. Right?

15 MR. LEVY: Yes. If you go back to

16 the map, you will see the problem is obvious.

17 MR. HAGERMAN: Yes, those damn state

18 lines.

19 MR. WEISS: It's obvious but thanks

20 for pointing it out.

21 MR. RAMIREZ: David?

22 MR. LUBLINER: This is Mike
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1 Lubliner.

2 MR. RAMIREZ: Hold on a second,

3 Michael, let's let David go again and then

4 you.

5 MR. LUBLINER: Very good.

6 MR. TOMPOS: Well, I just wanted to

7 -- you know I can agree that cost8 effectiveness can be looked at by a life cycle

9 analysis, full life cycle whether it is 30

10 years or ten years. I think that defines

11 cost-effectiveness of certain measures. If we

12 came to an agreement that that ten years is

13 affordability, I would like to change my vote.

14 You know I think affordability is

15 going to come down to that first cost. I

16 don't think, unless something changed that I

17 don't know about, banks don't loan money based

18 on what your cash flow is or how much money

19 you are going to save on your energy

20 efficiency. It comes down to debt to income

21 ratio. I mean, is there anybody here that

22 disagrees with that?
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1 MR. HAGERMAN: It is cash flow. 

2 That is the definition of cash flow. Debt to

3 income is cash flow.

4 MR. TOMPOS: But the banks will only

5 give you so much money. So, whatever my

6 income is, I can only spend so much on a

7 house.

8 So, I think the five percent is

9 completely relevant. Even if you tell me we

10 are going say I have got a five-year payback

11 on something that is going to save me all

12 kinds of money but it is going to raise the

13 price of a $30,000 house by $10,000, I don't

14 think that is affordable anymore to somebody

15 that could only afford a $30,000 house.

16 So, I just want to make sure that

17 there is a big difference between cost or

18 energy effectiveness or cost-effectiveness and

19 affordability.

20 MR. RAMIREZ: Let me get Michael and

21 then Mark and then Robin. Michael.

22 MR. LUBLINER: Okay, this question
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1 is for Emanuel. What is in the roof cost

2 between 38 and 30? It gets back to my

3 original question earlier.

4 Because I am looking at it when you

5 blow insulation into a roof, there is material

6 costs and there is labor costs. The more you

7 have to blow the more time in the factory it

8 takes. So, there are those costs but there

9 other costs that I have been hearing thrown

10 out but I am trying to confirm which they

11 apply to, which of these cases.

12 So, for R22, I am assuming there is

13 no baffle of the insulation. So, you don't

14 have a cost associated with the baffling but

15 when you get up to R30, is that where you put

16 in the baffling or is it a 38 and is that why

17 your costs seem to be higher than just

18 materials cost? 

19 And then the second question is are

20 any of the changes from 30 to 38 associated

21 with an assumption of a different type of

22 truss or a structural change?
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1 My understanding from kind of what I 

2 proposed in the KISS Luby thing was that they

3 were already going to be baffling at R30 and

4 there was no structural change. So, it was

5 just the R8 that is being added. It is loose

6 fill insulation and it just blows my mind that

7 once you have got the filling and this is the

8 last time you are ever going to be able to put

9 insulation in and you are not blowing it in to

10 the full 38, when a person in a climate zone

11 comes in to weatherize that home, they are

12 going to blow it to 38. So, why don't we just

13 do it right the first time if the overall

14 package, and this is still a big if, I want to

15 see if the overall package is still a lower

16 life cycle cost than the base case.

17 But could you kind of get into the

18 details on the baffling or the frame change? 

19 What is driving these costs? They seem

20 somewhat higher than what I see for certain

21 applications, just based on material, but I am

22 not a manufacturer. I don't know what is
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1 going into them. And maybe you can document

2 that or show me where that is documented so

3 you can take this offline.

4 MR. RAMIREZ: I thought these were

5 the cost numbers that were already provided

6 and reviewed. Matthew, is that accurate?

7 Matthew is shaking his head yes.

8 MR. LUBLINER: I never got my

9 question answered on the baffle and the

10 framing. Are those involved in these costs

11 changes?

12 MR. RAMIREZ: Emanuel, do you have

13 --

14 MR. LEVY: Can I take a shot at

15 that?

16 MR. RAMIREZ: Please.

17 MR. LEVY: You are absolutely right,

18 Javier. We discussed these last week in some

19 detail. And as I mentioned, the 22, the 30,

20 and the 38 are different constructions. They

21 all have different DLI trusses. They have

22 different trusses. We costed out the trusses
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1 and there is about 80 trusses, I think in the

2 multi-section. We costed out the cost of the

3 incremental cost of the trusses, of the

4 insulation, and the other materials like

5 baffles, which baffles are actually a very

6 small piece of the cost, what the cost

7 differences were there.

8 Most of the cost difference, much of

9 the cost difference, I wouldn't say most,

10 relates to the change in the trusses. And

11 that is because what we did is we took an R22

12 case and we said what can the industry build

13 today with an R22, and what can they build

14 today with an R30, and what can they build

15 today with an R38. And we went to the cost

16 differences between those cases, not what it

17 would be nice to build if they were building

18 an R22 but what they are building today. And

19 the information that we used came from the

20 survey.

21 So, we predicated all our decisions

22 about what went into that roof, in each of the
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1 construction measures, predicated on what

2 information we got back from the industry and

3 we costed that out and that is what the costs

4 are based upon. And the details were provided

5 at the last meeting.

6 MR. LUBLINER: Thank you. Yes, I

7 guess I misunderstood or I definitely did. My

8 understanding is when a manufacturer

9 advertises R38 right now for ENERGY STAR, they

10 don't have to put in a different truss. Is

11 that the case? So, why are we putting a

12 different truss in here for 38? 

13 MR. LEVY: We are not putting in a

14 different truss. Of course in the

15 marketplace, there are a lot of people today

16 building well above the HUD Code for various

17 reasons, whether it is ENERGY STAR or anything

18 else. But we did it just to reiterate what

19 our thinking was is that we took what 

20 manufacturers are building today minimally to

21 each of the levels. And then we looked at the

22 cost differences between those. We didn't
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1 look at some -- we couldn't pick some

2 arbitrary heel height that might be used. We

3 picked one that was likely to be used if you

4 are going to try to minimize cost.

5 MR. LUBLINER: So, let me just

6 clarify this and I will shut up because I am

7 not there. So, if we have a 5.5-inch heel

8 height and we are advertising the home as R22

9 in the ceiling, somebody comes in and they

10 want an R38 in the ceiling, are you having to

11 change that heel height or anything, --

12 MR. LEVY: Yes.

13 MR. LUBLINER: -- or is it just

14 blowing more insulation in?

15 MR. LEVY: I am having to change the 

16 heel height to 7.5 inches if they are getting

17 up to R38.

18 MR. LUBLINER: Yes, if they are not

19 square in the fundamental differences between

20 that and what we had proposed, which is to

21 allow that taper to take effect and leave it

22 as is.
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1 Yes, I don't -- when I see a

2 manufacturer and they offer that option, they

3 are not changing the heel height. They are

4 leaving it at 5.5 and advertising it at 38. 

5 I guess you are using a higher density.

6 MR. LEVY: Michael, you may be

7 talking about a manufacturer or five

8 manufacturers in the northwest but we couldn't

9 start picking arbitrary values. We had to

10 pick values that were predicated on real

11 minimum construction for each of the levels,

12 with some rationale behind it.

13 MR. LUBLINER: I agree.

14 MR. LEVY: I'm not saying that --

15 MR. LUBLINER: Yes, I agree,

16 Emanuel. I am not going there. I just wanted

17 to be clear that my understanding is that the

18 majority of roof trusses in this industry

19 right now have a 5.5 heel. And my

20 understanding was that to go from an R22 with

21 that 5.5 heel who advertised R38 does not

22 require a higher heel truss. It requires
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1 higher density of insulation.

2 So, that is kind of where I am

3 differing from your definition, which then

4 brings in much higher costs with your

5 definition, which then justifies, supposedly,

6 this individual measure as not cost-effective

7 and as a grounds for throwing it out.

8 So, I am having some issues with

9 this but thank you.

10 MR. RAMIREZ: Michael, so we are

11 going to move on. Mark, you are next and then

12 Robin.

13 MR. WEISS: Well, I just wanted to

14 follow on to what Dave was saying and that is,

15 if you look at, with respect to the five

16 percent, if you look at this cost increase in

17 terms of percentage of the income of the

18 purchaser, while I have been waiting here, I

19 have been furiously looking for my AHS cost

20 data for owners, which I couldn't find, but I

21 believe the median value was something like

22 $26,000. It is $22,000 for renters. And you
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1 look at these cost increases in terms of

2 percentage of the income of these folks. You

3 know $4,000, you are talking 15 or 16 percent;

4 $2,000, even you are looking at 8 percent. 

5 So, I mean these are substantial chunks of

6 money for folks looking to purchase and

7 finance these homes even beyond five percent.

8 MR. RAMIREZ: Robin.

9 MR. ROY: Robin Roy. To David and

10 to Mark's point, we are really sensitive to

11 this first buyer's perspective and this

12 affordability question. No question about it.

13 What has driven me in moving towards

14 a first buyer's perspective and it could be

15 along Lowell's line with a simple payback with

16 the first buyer, is that the Congress didn't

17 actually ask for us to look at -- ask the

18 Secretary of Energy to weigh in on

19 affordability. Now, that may be implied in

20 some way but it was specific for the Secretary

21 to choose a level starting with IECC 2015 and

22 moving up or down from there, based on cost-
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1 effectiveness. They didn't define this life

2 cycle cost, which one could reasonably

3 interpret as the impact on all of the owners

4 of a home over its life and also on purchase

5 price.

6 It is hard to imagine that they were

7 really asking to minimize purchase price

8 because then you might actually be removing

9 insulation from it. Right? You might be

10 making something which is simply siding and no

11 insulation. That would reduce purchase price. 

12 That cannot remotely do what Congress was

13 intending. So, we could put even more people

14 into even more houses by removing insulation. 

15 I cannot imagine that that is the perspective

16 that we want.

17 I am very interested in that first

18 buyer's perspective. I understand it. I just

19 think it would be very hard to defend a five

20 percent. I am trying to think of what would

21 be the language in the Secretary's

22 determination that would stand up. Otherwise,
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1 you would have to be removing insulation,

2 putting all electric resistance in. That is

3 the cheapest way to go on everything. You

4 would just, you would have single pane

5 aluminum windows everywhere. It just can't

6 be. I can't think of any way you can

7 construct that as what Congress' intent was.

8 MR. RAMIREZ: David.

9 MR. TOMPOS: We're not reducing the

10 cost. I mean are improving energy efficiency

11 here by a huge jump. We are just trying to

12 keep it so that people can afford to get in

13 the home. If they can't get into the home at

14 all, they save nothing. So, right there you

15 are stopping any type of potential energy

16 saving, period. Your life cycle cost is, I

17 mean your benefit is zero. 

18 So, we want to average it out and

19 look at the people that can't afford these

20 homes now. I do think Congress would look at

21 it that way. You know if they are going to

22 stay in the rentals, I mean I have seen some
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1 rentals. They are not energy efficiency. The

2 homes are out there, the 30-year-old

3 buildings. That is where they are going to

4 live if they can't get into new housing that

5 is going to be more energy efficient. And we

6 are not saying that we can't add any cost to

7 this. It just means it would be something

8 that is reasonable so that that person with a

9 $20,000 to $30,000 income can still go to the

10 bank and allow them to borrow some money so

11 they can get into the home. That is my

12 biggest concern.

13 And I don't know exactly what

14 Congress' intent was here but I can't believe

15 it isn't to help people get into homes. I

16 think that is still the American dream. 

17 Right?

18 MR. ROY: It is part of it. It

19 could be 16 to 20 instead of 20 to 24, if you

20 pulled out the insulation on a first price

21 basis.

22 MR. TOMPOS: I just find it very
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1 hard to understand how you could possibly --

2 MR. RAMIREZ: Let me get Lois and

3 then Mark.

4 MS. STARKEY: Yes, I think there is

5 enough leeway in the Act and in what the

6 appropriators have said for the last three

7 years, that we do need to balance those first

8 costs.

9 Yes, I think that the Department of

10 Energy's goal is to save over 30 years to look

11 at those energy savings. But I think there is

12 a recognition by Congress that there are

13 different congressional goals, different

14 federal goals about housing and affordability.

15 So, I think there is enough leeway

16 to balance. And I totally agree we are not

17 talking about -- I don't think there is any,

18 at least from MHR's perspective, we are not

19 talking about minimizing those first costs as

20 the number one be-all. Clearly, we don't want

21 to keep people out of housing and then avoid

22 the -- do away with the goal of putting people
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1 in energy efficient housing.

2 MR. RAMIREZ: Okay, let me get Mark

3 and then Lowell.

4 MR. WEISS: Well, no one was

5 suggesting that we want to retreat in terms of

6 providing energy efficiency from what we have

7 now. But if you look at ISA, it says, goes

8 with the IECC, except in cases in which the

9 Secretary finds that the code is not cost10 effective based and keep it on the relevant

11 line here, based on the impact on the impact

12 of the code no the purchase price of

13 manufactured housing and on total life cycle

14 constructing and operating costs.

15 And what I have said from the start

16 is that I am not saying the life cycle

17 construction and operating costs are

18 irrelevant, obviously, they are in the

19 statute. I am just saying from our

20 perspective as an organization, impact on the

21 purchase price of the home to the consumer has

22 to be a primary, if not the primary
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1 consideration because you get to a point where

2 you are pricing significant people out of the

3 market. And federal law specifically

4 recognizes manufactured housing as affordable

5 housing. And a balance between these two

6 factors is already written into the law, in

7 the regulatory law, federal law that HUD

8 follows.

9 So, there is some balancing there. 

10 But from our perspective, first cost impact,

11 as we have been calling it, needs to be

12 primary.

13 MS. HOFFMAN: After Michael, I think

14 we want to hear also all of Emanuel's

15 presentation. There is more, isn't there?

16 MR. RAMIREZ: Is there more Emanuel?

17 MR. LEVY: Just a couple more

18 slides, yes.

19 MR. RAMIREZ: Oh.

20 MS. HOFFMAN: Okay, so I think that

21 would be good. 

22 MR. RAMIREZ: Actually Lowell was
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1 first. Lowell, Michael, and then we will

2 finish up the presentation.

3 MR. UNGAR: I am happy to get into

4 detailed pricing and legislative language,

5 that is something I do but I will forego for

6 now because it is not clear to me whether it

7 would be significant or not.

8 If we are going to argue over like

9 the five percent cost cap, I would just

10 suggest that we, one, apply it as a cost cap. 

11 At the moment the analysis is averaging

12 numbers that are within that cap. So, if the

13 concern is a five percent cost cap, let's look

14 at a five percent cost cap and see what those

15 numbers are.

16 And secondly, we haven't really

17 talked about climate zones and such. But if

18 we are going to go with Uo values with the HUD

19 climate zones, then let's look at the mapping

20 of 2015 IECC onto what the Uo values will look

21 like for the HUD climate zones. And then

22 let's look at what the Uo values would be
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1 under a five percent cost cap for the HUD

2 climate zones.

3 I think they are not -- I mean there

4 may be one or two cases where they are

5 slightly different and we would have to argue

6 about it but I think in a lot of cases in fact

7 there is not going to be a difference.

8 So, if that is the criterion, I

9 would suggest we go to where the standard and

10 that we will be pretty close.

11 MR. RAMIREZ: Okay. Because at some

12 point, instead of arguing what it is that we

13 are supposed to be doing, I thought that the

14 numbers -- we were pretty close in some of

15 these numbers, the majority of them, actually. 

16 So, instead of getting bogged down

17 on some of the mission, let's see if we can

18 look at the actual numbers and reach some

19 agreements.

20 Michael and then Emanuel.

21 MR. LUBLINER: Yes, thank you. So,

22 I guess the question I have is if we are going
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1 to be dealing with first cost affordability

2 beyond this ten-year analysis, which I think

3 we are doing an adequate job just doing the

4 ten-year first home buyer analysis, but if we

5 are going to go ahead and do this, I guess my

6 question is so what is the percentage or what

7 is the number of homes -- clearly, there is

8 going to be an increase in the cost of a first

9 cost in these homes. And say if there are

10 60,000 homes a year being built out there and

11 the cost is going to go up, what is the

12 acceptable number of home buyers at the low

13 end with the marginal credit scores who are

14 buying chattel mortgage financing? How many

15 of these are we going to lose out of 60,000 a

16 year?

17 And you know I think that that is

18 the kind of information that needs to be

19 discussed, if you want to go in that

20 direction. Personally, I think the ten-year

21 analysis does this but so -- this is a

22 question for Mark Weiss. Can we lose no
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1 customers on the entry level, then, to justify

2 this or is it a thousand customers out of

3 60,000? Is it 2,000? Where is the data? 

4 That is what I think we need if we are going

5 to go down that trek and I don't think we need

6 to go down that trek. I think we do an

7 adequate job with the ten-year analysis.

8 MR. HAGERMAN: Can I just add to

9 that real quick? One thing that Lois gave us

10 early on was the average sales price of

11 manufactured housing and the number of

12 shipments over like the last five years. 

13 There is like a MHI fact sheet.

14 And one thing that is pretty

15 interesting in there and that is why I think

16 this is sort of confusing is, when the average

17 price goes up, the industry looks to ship

18 more. I don't know, just as a heads up, your

19 data shows the average price goes up, the

20 shipments increase. Right?

21 So, this argument that if we raise

22 the price a little bit, you know, and there is
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1 going to be units taken out of market is

2 actually not validated by the five-year

3 historical data that you provided.

4 So, just something to keep in mind. 

5 It is like one of the correlation things that

6 if you just look at the data, I'm not sure you

7 can really derive what I said but you can if

8 you want to because I just did.

9 (Laughter.)

10 MR. HAGERMAN: But just something to

11 keep in the back of your mind.

12 MR. RAMIREZ: Yes, so I want to let

13 Emanuel finish his presentation.

14 MS. HOFFMAN: Yes, let him finish.

15 MR. RAMIREZ: So, Emanuel, you are

16 up.

17 MR. LEVY: Okay. We can go to the

18 next slide. It is less controversial. Slide,

19 I guess, eight. Yes.

20 So, this is just a quick indication

21 of if we arrive at Uo values like we saw in

22 the last table, what percentage of improvement
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1 that is over the current HUD, this is just for

2 your reference, see that we are talking about

3 just the thermal portions. We are not talking

4 about the other pieces of the standard that we

5 have been talking about. It is anywhere from

6 22 to 28 percent, depending on the zone. 

7 There is nothing magical about this but it is

8 an appreciable increase but just as a

9 reference point.

10 And if we go to the next slide just

11 to finish up here, this would be one typical,

12 again, looking at the far right column, this 

13 U sub o value, this would be one package, one

14 potential prescriptive package equivalent. 

15 Remember my original point that I wanted to

16 try to come up with two paths that were equal

17 in terms of their energy impact. So, I used

18 the U sub o to come up with a package for each

19 of the three HUD zones. And this is one

20 package that there is nothing sacrosanct about

21 these individual combination of measures but

22 just to give you a sense of what might be
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1 built in each one of the zones as a result of

2 those U sub o values.

3 And that concludes.

4 MR. RAMIREZ: Any questions, Mark?

5 MR. WEISS: Nothing.

6 MR. HAGERMAN: I was just going to

7 ask you what you were thinking about.

8 So, Mark Ezzo, do you have a

9 question on the phone?

10 MR. EZZO: Yes, thanks, Joe. So,

11 Emanuel, slide eight is easily understood. No

12 problem with that. We have the suggestion for

13 the three new Uo numbers, one for zone and

14 they approved it.

15 As for running a performance path,

16 right, where the manufacturer runs the

17 calculation and comes up with those numbers. 

18 And so they would have the freedom to use any

19 combination of insulations and window grades

20 that they want under that. Correct?

21 MR. LEVY: That's right.

22 MR. EZZO: Okay, so that is what I
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1 think most of us refer to as a performance

2 method or performance path.

3 And then the next slide, if you will

4 go up, Javier, or down. Excuse me, down. 

5 This one is a prescriptive approach, correct? 

6 Meaning, that you are not necessarily running

7 calculations. You are following those

8 prescriptive R values in the cavities and then

9 you are following the prescriptive window U

10 value and heat gain coefficient numbers. 

11 Correct?

12 MR. LEVY: Yes, I think you are

13 point out part of what is missing from this

14 table, which would be added later, our set of

15 rules about how you use this information. But

16 yes.

17 MR. EZZO: Yes, so I guess that is

18 kind of where I was going with the whole

19 thing. 

20 So, underneath this prescriptive

21 table, would there be some footnotes that gave

22 things like maximum glazing allowance or is
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1 this prescriptive proposal unlimited glass? 

2 I guess that is my main question.

3 MR. LEVY: Yes, I think generally

4 the way this is done, it is done this way in

5 the IECC and most other standards, is when you

6 have a prescriptive alternative like this, you

7 have to set aside a bunch of rules on how this

8 is used to make sure that in using the

9 prescriptive path, you don't inadvertently

10 consume more energy than what is applied in

11 the performance path.

12 So, you would have to set some

13 limits on things like window area. If you are

14 going to -- and for potentially other things,

15 to make sure that this package is used

16 correctly.

17 MR. EZZO: Okay, thank you.

18 MR. RAMIREZ: Joe.

19 MR. HAGERMAN: So, I am just going

20 to ask, Ted, can you scroll up to that? Right

21 there.

22 So, just to ask this question again
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1 because I asked it a second ago. Is there any

2 reason why we can't have different U sub o

3 values for single and double wide? I mean a

4 single section and a double section look

5 different. They act different. EnergyPlus,

6 when we run the simulations, the numbers are

7 different. Is there any reason why we can't

8 recognize that they are different and provide

9 different values?

10 MS. STARKEY: Anybody, any of my

11 members there on the phone?

12 MR. EZZO: Yes, Joe, this is Mark

13 Ezzo. I will try and answer that.

14 At first blush, I would kind of

15 disagree with that you are saying and only

16 because the differences we are seeing are

17 based on the geometries of the assumptions we

18 made, meaning a 14 by 66 compared to a 28 by

19 56. But in reality, I can make a double wide

20 or a two-section home smaller in size and

21 shape and make those numbers come up a whole

22 lot different, even when compared to a single
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1 section.

2 So, I am not so sure I think that is

3 the right path to go down. But I will say

4 that it would be simple to do. I mean there

5 would be no problem, I don't think, for any

6 manufacturer if we had two sets of Uo numbers,

7 one for a single section and one for multi8 section.

9 MR. HAGERMAN: Okay, the only reason

10 I brought it up was because when I redo some

11 math on Emanuel's page seven, as an example,

12 I come up with a single section home with a U

13 value of 0.086, rather than 0.085. Just can

14 you scroll that down?

15 So, I think the averaging actually

16 sort of penalizes the single section homes and

17 makes it a little bit more difficult for them

18 to meet.

19 MR. EZZO: You know and maybe it

20 makes sense to do it that way because the

21 single section home is, I think everybody

22 would agree is the more affordable, --
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1 MR. HAGERMAN: Right, that is what I

2 am getting at.

3 MR. EZZO: -- a more affordability4 sensitive product. So yes, if we had a little

5 bit easier Uo numbers to hit on the singles

6 than the doubles, it might make sense.

7 MR. HAGERMAN: It is just something

8 to consider. 

9 MR. RAMIREZ: Let me get David and

10 then Mark.

11 MR. HAGERMAN: Hold on. It doesn't 

12 seem like for me, in years of manufacturing,

13 Mark, that you would have a hard time

14 understanding two different tables. I mean

15 you never are halfway through building a

16 single section and all of a sudden say we have

17 to make it a double. Right? I mean I don't

18 think that has ever happened.

19 MR. EZZO: That is correct. Like I

20 said, if we had two sets of numbers, I don't

21 see any struggle for a manufacturer to do it

22 that way.
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1 MR. HAGERMAN: Okay.

2 MR. LUBLINER: This is Mike

3 Lubliner.

4 MR. HAGERMAN: Hold on, Mike. You

5 have got to get in the queue.

6 MR. RAMIREZ: Yes, hold on, Mike. 

7 We have got David, Mark, and then you.

8 MR. LUBLINER: Okay, thanks.

9 MR. TOMPOS: Well, I'm just curious. 

10 Are we getting into the weeds a little bit

11 here? Because we talked about whether it is

12 0.085 or 0.086, that needle is barely moving,

13 isn't it? I mean or am I wrong?

14 MR. HAGERMAN: To be honest with

15 you, the last run -- so, the groups has always

16 been asking me to do simulations. And they

17 asked me for a set and we give you the

18 results. And then the next week they ask for

19 me to do another set. And the results change

20 the first go-round five percent. And then

21 they change two percent. And now they are

22 changing a half percent or actually so
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1 negligible.

2 So, again, I think we are in that

3 sweet spot. We just need to all agree that

4 hey, we are in the sweet spot and let's start

5 picking numbers and just vote.

6 MR. TOMPOS: Well that is -- we are

7 arguing over affordability and all this other

8 stuff, but at the end of the day, these

9 numbers are -- I think could make everybody

10 happy. Can't they?

11 MR. HAGERMAN: I think so. I think

12 it is much easier, to be honest with you, I

13 appreciate all of the work that Emanuel has

14 done consistently through the whole thing but

15 it is sort of much easier for me to pick

16 numbers off of the LCC because we have been so

17 used to seeing that.

18 We can plug these numbers into it

19 and see how they rack and stack. But I can

20 tell you on the last numbers that Emanuel

21 asked us to simulate, which was the reduction

22 in the ceiling, those were the same costs in
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1 the proposal make all the zones that are

2 negative positive. So, it seems like we are

3 there in my mind. And you can see the up4 front costs.

5 And that is why also something that

6 Matthew has done is he has given you a little

7 cheat sheet here, this little two-pager. And

8 he will present it to everybody on the phone

9 right after we get back from a break. But

10 this gives you the annual energy costs that a

11 homeowner would see from the HUD baseline to

12 the newest proposals that you have asked us to

13 simulate.

14 So, when we say it costs somebody

15 $2,000 more to buy the house, well, that is

16 true but in one climate zone, 6B, they are

17 getting $700 of savings per year just by the

18 reduction in their utility bills. So, you

19 have got to keep all that in mind.

20 That is why it is much easier to

21 kind of see all that play out in what I think

22 is Matthew's spreadsheet and Emanuel's
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1 presentation. But I appreciate, Emanuel,

2 everything you have done here.

3 MR. RAMIREZ: I will tell you, we

4 see this dynamic quite a bit in bargaining

5 where the parties are a lot closer than they

6 actually realize and they just continue

7 talking, I guess, is the mediator word. They

8 keep talking.

9 But let's go ahead and get Mark,

10 Michael, and then let's take a break and then

11 we will get Matthew's computer hooked up and

12 we will pull those life cycle numbers.

13 MR. WEISS: I would like to

14 recognize Rick. I may or may not have a

15 further comment when he is finished.

16 MR. RAMIREZ: Rick?

17 MR. MENDLEN: Okay, thank you, Mark. 

18 Joe, this is just to point out that there are

19 other geometries. There are triple wides,

20 quads even, two stories. I mean I think the

21 uniform singular value serves us well and just

22 as David said, the tweaking the thing by 0.001
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1 or something like that is not going to make a

2 significant difference in the outcome of what

3 factors they are going to use for insulation

4 and window values. So, that is my comment.

5 MR. RAMIREZ: Thank you.

6 MR. WEISS: Thanks, Rick. I will

7 follow up a little bit.

8 MR. KESSLER: This is Bert.

9 MR. RAMIREZ: Just a second, Bert. 

10 I will get you in the queue.

11 MR. WALKER: Part of the basis for

12 the affordability of manufactured housing

13 under the HUD Code has been standardization of

14 uniformity. And while I understand what you

15 are saying, Joe, it is kind of like the

16 reaction that I have gotten from some of my

17 folks to what Robin has been talking about

18 with the high level and the low level. And

19 that is, while it is logical, unfortunately

20 when you start applying that in practice, it

21 just winds up making things more complicated

22 and, therefore, more costly. So,
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1 standardization and uniformity are important

2 within the context that we are addressing.

3 MR. HAGERMAN: My only comment was

4 that I was trying to loosen the requirements

5 for singles but if everybody is comfortable

6 with them being more rigorous, hey, more

7 energy savings.

8 MR. RAMIREZ: All right, Michael and

9 Bert.

10 MR. LUBLINER: Yes, I have got some

11 data from the northwest regarding the

12 distribution of homes. You know out of 27,877

13 homes that have been built in the northwest

14 since 2004, 1,500 of them were single section,

15 almost 20,000 were double section, 6,000 were

16 triple section, and as Rick points out, we

17 have 200 quads.

18 So, we are real interested in the

19 multi-section. And if the affordability issue

20 really is focused on the singlewides and if we

21 could have a separate Uo value that maybe

22 addresses some of Emanuel's concerns after
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1 running it and seeing whether it is justified

2 from the life cycle cost, maybe that is the

3 win-win in terms of trying to come up with a

4 way of addressing affordability. It would

5 tweak it a little bit for the single section

6 homes.

7 My logic there is that I think by

8 the time you set up a multi-section home, it

9 costs thousands and thousands of dollars more,

10 so that the homeowner who is really in that

11 affordability gap is probably tending to buy

12 the single section.

13 So, if we could just align any

14 adjustments, again, I don't think there should

15 be adjustments if it got a total package. But

16 if we had to negotiate, I think maybe coming

17 up with a separate Uo for those single section

18 homes would be a compromise. Thank you.

19 MR. RAMIREZ: Yes, I will have you

20 hold onto that. Let's see what those LCC

21 numbers look like and see if we need to pull

22 that out a little bit later.
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1 Let's get Bert and then we will take

2 a break. Bert?

3 MR. KESSLER: Yes, I agree with what

4 Rick Mendlen said. We do have a variety of

5 floor plan arrangements and if you really stop

6 and think about it, unless there would be

7 significant difference in the Uo, all

8 construction is pretty well fixed. The

9 insulation is pretty well fixed. The windows

10 and doors is fixed. There is nothing much we

11 can do. That only leaves the ceiling

12 insulation and only then if the manufacturer

13 uses blown, where we can control the height. 

14 So, I don't think it is worth it.

15 MR. RAMIREZ: Okay, thank you. You

16 wall want ten or fifteen minutes?

17 MS. HOFFMAN: Let us know.

18 MR. RAMIREZ: Ten minutes. All

19 right, there you go.

20 MS. HOFFMAN: Matthew will set up

21 his computer. So, look for our life cycle

22 costs.
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1 (Whereupon, the above-entitled

2 matter went off the record at 2:09 p.m. and

3 resumed at 2:21 p.m.)

4 MS. HOFFMAN: Okay, we're back. 

5 This is Eileen Hoffman. Everybody online, I

6 hope? And we're back from our break. Thank

7 you.

8 MR. WALKER: Okay. Hi, everybody. 

9 I'm Matthew Walker from Navigant. 

10 What we're going to go over is a

11 couple of the handouts that we have here in

12 the room and I have it up on the screen. And

13 then also the LCC model itself.

14 I think what I'm going to do is

15 start here with this annual heating and

16 cooling cost handout because I think it segues

17 the best from what Emanuel was discussing.

18 So where I want to start is the

19 labels of these three columns, or really these

20 four columns.

21 So we have the HUD code, that's the

22 baseline. Then if you go all the way -- I'm
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1 going to go all the way to the right where

2 that cursor is. That's the 2015 IECC using

3 the mapping of components that Emanuel and the

4 manufacturers put together. We looked at that

5 last week.

6 And then as you move back towards

7 the HUD code I have revision 1. And just to

8 kind of review what was in that particular

9 package, revision 1 is the revised ceiling

10 insulation. So we changed zones 2 through 3

11 from R38 to R34. So only zones 2 through 3

12 change between the rightmost column and

13 revision 1.

14 And then you move to revision 2 and

15 revision 2 includes changes to zones 2A and B,

16 4A and B, and 6A and B. And those are the

17 zones that are in this table. And the changes

18 there were from -- in zones 2 and 4 it was

19 ceiling insulation down to R30.

20 MR. MENDLEN: Say that again.

21 MR. WALKER: Zones 2 and 4 moving

22 from revision 1 to revision 2, the ceiling
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1 insulation changed to R30, R30 in revision 2.

2 And then zone 6 we moved from an R20

3 plus 5 sheathing to just an R21 high-density

4 blanket when you move from revision 1 to

5 revision 2.

6 MR. HAGERMAN: Joe Hagerman, DOE. I

7 have a quick question. 

8 Your HUD code baseline there that

9 you're showing is which version of the HUD

10 code baseline? Because there was some -- you

11 might want to just remind people of the

12 baseline.

13 MR. WALKER: Right, that's what --

14 so, last week when we met the HUD code

15 baseline that we were presenting was based on

16 the energy usage of PNNL's original mapping.

17 What we have here on the screen now

18 is based on the mapping of components that

19 Emanuel Levy and the manufacturing group put

20 together. That's the new HUD code set of

21 components.

22 And you can see the specific noted
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1 particulars on the PNNL/EUI spreadsheet that

2 was also sent around yesterday and has been

3 sent around in each iteration of the LCC.

4 MR. HAGERMAN: So, Joe Hagerman,

5 DOE, again. I think it's good then that we

6 heard from the manufacturers that the original

7 baseline wasn't exactly correct. 

8 So, now the HUD code baseline we're

9 using is the one that you said is more

10 representative of your industry. 

11 MR. HAGERMAN: Right. And along the

12 same lines the 2015 IECC manufacturer Levy

13 column was on the rightmost side last week did

14 not have updated energy use values. This week

15 has the energy use values that are associated

16 with the particular mapping provided by

17 manufacturers and Levy. 

18 So everything is all up to date. 

19 Everything matches those labels at the top

20 with the HUD code being the particular one

21 that was revised by manufacturers.

22 Okay, so that's what we're looking
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1 at. And, I mean Emanuel has really already

2 talked about what's happening here in this

3 table, but I just wanted to share with

4 everyone again what these numbers mean in case

5 you look at them again later.

6 These are annual heating and cooling

7 costs. So you can calculate the change in

8 annual heating and cooling costs by

9 subtracting one of these three IECC levels

10 from the HUD code.

11 So, for example, if we just look at

12 2A from the HUD code the total is 892. You go

13 to the 2015 IECC, you get $634 in annual

14 heating and cooling costs.

15 Then when we went down to revision 1

16 we changed the ceiling from R38 to R34. So,

17 revision 1 uses a little bit more energy

18 relative to the 2015 IECC run. 

19 But like we've been saying it's a

20 really small change. It uses $3 more energy

21 but it saves a bunch of money by not having to

22 use the R38 ceiling cost.
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1 And then similarly, moving down to

2 revision 2, that goes down to an R30 ceiling. 

3 The delta in energy cost is $4, $641 minus

4 $637. But again, you save a lot of money by

5 not having to install the more insulative

6 ceiling. 

7 So that's the table represents. Are

8 there any questions on this before we?

9 MR. TOMPOS: Okay, so this is what

10 we're arguing about? The difference between

11 this and this. Ten dollars a year?

12 MR. HAGERMAN: Actually, it's a

13 little bit worse than that. We're actually

14 arguing over the sum of this. This -- like

15 you were just pointing out the heating.

16 MR. TOMPOS: Okay.

17 MR. HAGERMAN: But yes, you're

18 right.

19 MR. TOMPOS: Why are we still here?

20 MR. HAGERMAN: We need to pick these

21 levels and get out of here.

22 MR. RAMIREZ: I want to go to that
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1 question, though. I mean, for the most part

2 are these numbers acceptable? 

3 And that's kind of what I was

4 talking about before where is there a

5 heartburn area? Is there a spot or two that's

6 really just the, you know, we really need to

7 look at these specific areas. Otherwise, as

8 a package --

9 MR. ROY: Hang on, these are energy

10 costs, right? So the heartburn area is on how

11 much you have to spend to get -- put that

12 table on.

13 MR. TOMPOS: Right, but isn't this

14 what Emanuel just went through? 

15 MR. ROY: No.

16 MR. TOMPOS: Oh, this is not what he

17 went through.

18 MR. ROY: No.

19 MR. TOMPOS: Oh, okay.

20 MR. HAGERMAN: Those represent the

21 last runs that he asked us to do which you're

22 about to see.
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1 Like I said before, the last runs

2 that he asked us to run basically went from

3 the R34 route to the R30. And then other

4 small little change, right? But we kept the

5 costs the same. 

6 And so that's what Matthew should

7 alt-tab over to right now and show you the

8 lifecycle simulations of that. 

9 Before that change there were three

10 red climate zones. Now there's just one red

11 climate zone by like a double digit, right? 

12 And that's San Francisco. So one of the

13 hardest climates to do stuff in.

14 MR. WALKER: Right. So that other

15 table showed really small differences in

16 energy cost, but like Robin was saying there's

17 a big difference in the cost to install those

18 different measures.

19 So what I've done here on this

20 sheet, this is not the LCC model itself, but

21 just for ease of presentation I copied down

22 the LCC savings associated with these three
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1 different levels. 

2 These are actually inverted from the

3 table you were just looking at so watch out

4 for that. 

5 This is the original 2015 IECC. 

6 Moving to the right, revision 1. And then on

7 the far right, revision 2.

8 MS. HOFFMAN: Do we have copies of

9 that or no?

10 MR. WALKER: You do not have a copy

11 of this.

12 MS. HOFFMAN: Okay. So you may have

13 to read it for those of us who are technically

14 challenged.

15 MR. WALKER: All right. So this

16 table has the total LCC savings for the three

17 versions of the 2015 IECC that we've been

18 looking at over the past week.

19 So in the first column here 2015

20 IECC manufacturer Levy. Single section home

21 using a 10-year analysis period with

22 residuals. That's got everything. 
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1 We have three zones that have

2 negative lifecycle cost which means the

3 customer doesn't save money relative to the

4 HUD code.

5 MR. HAGERMAN: Joe Hagerman again. 

6 Just to remind everybody, this is 10-year with

7 residual recapture.

8 MR. ROY: So this is not LCC. This

9 is first buyer, like 10-year perspective.

10 MR. HAGERMAN: Yes.

11 MR. ROY: And that may be the too

12 long 10 years, but in that case it is more of

13 a proxy for first buyers.

14 MR. WALKER: That's right. Ten

15 year.

16 MR. ROY: Not LCC.

17 MR. HAGERMAN: Ten year with a

18 recapture.

19 MR. WALKER: Ten-year ownership cost

20 with recapture. 

21 So then what happened with revision

22 2 was that in these gray highlighted cells we
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1 moved from an R38 ceiling to an R34 ceiling.

2 And so you see in each of those that

3 the lifecycle cost savings had increased. So

4 in the case of Houston it went from -137 to

5 -9. It increased but it's still slightly

6 negative.

7 In the case of San Francisco you

8 went from -$48 to a positive $76. Just with

9 that one change from R38 ceiling to R34

10 ceiling.

11 And then you can see that all the

12 other zones are unchanged. For example,

13 Albuquerque is $671, also $671.

14 And then I'll just complete -- I'll

15 talk about the last column and then I'll open

16 it up for questions.

17 Revision 2 follows the changes that

18 Emanuel Levy had requested and sort of

19 discussed recently. So, his changes affected

20 zones 2A and B, 4A and 4B, and 6A and 6B.

21 And so you can see zone 2A Houston

22 goes from a -$9 with an R34 ceiling to a
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1 positive $109 when you have an R30 ceiling. 

2 That was the only thing that changes between

3 these two scenarios for that particular zone.

4 And the other gray cells showed the

5 other zones that change between revision 1 and

6 revision 2. So that's single section. I have

7 double section below, but if anyone wants to

8 talk about single section I'll give you a

9 chance.

10 MR. EZZO: It's Mark Ezzo. Can I

11 ask a question?

12 MR. WALKER: Sure.

13 MR. EZZO: So the far right column

14 that's Levy revision 2, is that representative

15 of Emanuel's latest presentation, slides 8 and

16 9 so to speak that we just finished up? Those

17 numbers represent those recommendations that

18 he had? At the very bottom.

19 MR. WALKER: I'm looking to 8 and 9.

20 MR. EZZO: There you go. Is that

21 what we're looking at there in Levy revision

22 2?
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1 MR. WALKER: So, Mark, I guess I can

2 answer that. The answer is no. The LCC

3 results are specific to the Uo or specific to

4 the component package associated with an IECC

5 zone. But what we have here on slide 9 is a

6 particular aggregation of the IECC zones into

7 a HUD zone.

8 No is kind of an extreme answer. 

9 The results are related to each other and the

10 results here in my LCC spreadsheet perhaps

11 could be averaged.

12 MR. ROY: You're 10-year

13 cost-effectiveness. It's not the LCC. 

14 MR. WALKER: Ten-year

15 cost-effectiveness.

16 MR. HAGERMAN: Could you pull up --

17 Joe Hagerman, DOE -- could you pull up a

18 little quickly the component U values for the

19 IECC revision 2? Just give people just a

20 little second to do this.

21 MR. WALKER: I'm just going to

22 scroll down to one that is affected and I'm
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1 going to highlight what we should look at.

2 So when I've highlighted the zone

3 2A, the component mapping for revisions 1 and

4 2 and here, I'll just get all three.

5 MR. SANTANA: Manny here, Cavco. So

6 how do the values that you get now if you

7 compare with slide 5 in Emanuel's

8 presentation? Aren't they one and the same?

9 MR. WALKER: I think this is one and

10 the same. I don't remember width adjustments

11 and four adjustments meant. 

12 MR. SANTANA: Well, the four

13 adjustments was the four that you rated -- you

14 went from 38 to 30.

15 MR. WALKER: Right.

16 MR. SANTANA: Because this is all a

17 big progression. And I think slide 8 that

18 Mark Ezzo brought up earlier I think was what

19 -- how Emanuel took the results of this table

20 and grouped them into the three zones. They

21 should be roughly equivalent to.

22 MR. WALKER: Yes, that was what I
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1 was trying to say at the end, I think. 

2 They're roughly equivalent, but it's not an

3 LCC specific to a HUD climate zone, or a

4 10-year operating cost relative to the

5 purchase price analysis.

6 MR. HAGERMAN: So, if you just do a

7 quick little comparison, if you pull them up,

8 like a single section for a HUD zone 1 would

9 be 0.087. And as Emanuel proposed it would be

10 0.085. And then for a double section HUD zone

11 1 would be 0.084 and he's proposed 0.085.

12 And then for a single section HUD

13 zone 2 would be a 0.07. He's proposed a

14 0.069. And for a double section it would be

15 0.068. He's presented a 0.069. 

16 And then finally the last HUD zone

17 kind of gets confusing of course. Matthew's

18 analysis says a single section should be 0.059

19 and 0.051. And Emanuel's presented 0.062 and

20 for a double section would be 0.056 and 0.050. 

21 And again, Emanuel's presented 0.062.

22 MR. LEVY: Hey Joe, this is Emanuel.
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1 MR. HAGERMAN: Yes.

2 MR. LEVY: I'm not sure what you

3 said is exactly correct.

4 If you look back at page 5 which

5 Manny was just referring to I think those are

6 the specific conditions that map with that.

7 The combined U value is something

8 else, comes from outside of the analysis. But

9 I think what Matthew ran is exactly what's in

10 Table 5.

11 MR. HAGERMAN: Right. And if you

12 just group something like IECC climate zone 1

13 and IECC climate zone 2 which is roughly

14 equivalent to I think HUD climate zone 1 those

15 numbers don't change. You still get a Uo

16 value of 0.087, right?

17 MR. LEVY: That's right. That's

18 right.

19 MR. HAGERMAN: And there seems to be

20 some natural divisions that occur. Like IECC

21 zone 1 and IECC zone 2 look like they're

22 pretty, you know, they group together. And
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1 IECC 3 and IECC 4 look to group together. And

2 then 5 and 6 group together. And then 7 and

3 8 kind of are out there.

4 And that kind of works across both

5 singles and doubles. I mean, obviously the Uo

6 values change which I think everybody should

7 consider having different numbers for singles

8 and doubles. But I think that's a dead horse

9 around here.

10 MR. RAMIREZ: All right. What other

11 questions do you have on this?

12 So, if we're going to pull up the

13 costing information, are those areas that we

14 need to tweak in order to try to make this

15 thing acceptable? 

16 MR. LACEY: Are you asking are there

17 additional areas?

18 MR. RAMIREZ: I'm sorry?

19 MS. STARKEY: What date?

20 MR. RAMIREZ: So, we're looking at

21 -- because it seemed like how much is this

22 going to cost seems to be the part that
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1 everyone is looking at.

2 And everyone seemed to be okay with

3 the savings piece. And just the overall cost

4 on here. But what does that compute to as far

5 as the overall dollars. And if so, if it's

6 out of a range that is acceptable where do we

7 need to tweak it to make it acceptable. Is

8 that where we're at?

9 MS. STARKEY: I guess I have a

10 question. Where we're at. I mean, we have a

11 proposal on the table for a set of U values,

12 and a climate zone, and a prescriptive path.

13 And it sounds like that we've come

14 to some sort of fair consensus that the

15 analysis compares to this 10-year look that we

16 just did.

17 So, then it would make sense to look

18 at what the costs might be if we were to

19 agree, and I think that was the purpose of

20 proposing something. 

21 And then we could say, okay, well, I

22 don't like 062, let's go to, you know, and
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1 then look at the cost.

2 But I think we need to say is this

3 approach that Emanuel has taken, regardless of

4 how he got there, three zones, these U values,

5 this prescriptive path, does that make sense,

6 or does it not.

7 And what we were trying to come to

8 is some proposed standard.

9 MR. ROY: Could you make another

10 chart? I don't know how hard it is for you to

11 do it. This is Robin.

12 And it would bridge A-C and A-B. 

13 Let's move onto -- if we want to move onto

14 maybe Rev 2. Because I thought those were

15 always interesting opportunities for reducing

16 cost that didn't seem very productive. So

17 have that combed.

18 Change the heading of it to make it

19 correct. So it's a total 10-year

20 cost-effectiveness. But also have the total

21 30-year lifecycle cost-effectiveness column. 

22 And a third column, the cash out. Purchase
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1 price for it.

2 And then a fourth column would be

3 maybe the U value for each of those things. 

4 And then SHGC at some point would be good too. 

5 Do you see what I'm saying?

6 MS. STARKEY: Yes. How long would

7 it take you to do that?

8 MR. ROY: Cash out is a 10-year

9 prospective, 30-year prospective and a U

10 value. That would be really helpful I

11 suspect.

12 And we can see if we want to combine

13 some of those, modify some up and down. I

14 think we could all talk clearly to it.

15 MR. HAGERMAN: Can you step aside

16 maybe and quickly run through that? And maybe

17 we can continue the conversation. You can use

18 Bob's if you want to sit down.

19 MR. WALKER: Or I can just pass the

20 control of the screen back to Ted. He can

21 stay here.

22 MR. HAGERMAN: That would be good.
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1 MR. WALKER: Emily, can we?

2 MS. HOFFMAN: Before he goes though

3 is there something else you'd like on this

4 chart?

5 MR. RAMIREZ: Let's get Mark and

6 then Eric.

7 MR. WEISS: And I apologize again,

8 not being a technical person. But you asked

9 about tweaking these numbers. Do all these

10 numbers ultimately go back to the PNNL model

11 that we've been talking about since the first

12 meeting which Joe has characterized is based

13 on laws of the physics?

14 MR. WALKER: That's right. The

15 energy simulations, yes. Annual energy.

16 MR. WEISS: Okay. But no one has

17 ever looked at this in terms of an actual home

18 under actual conditions operating under these

19 standards.

20 You know, I don't think you were

21 here, Joe, when I mentioned this last week. 

22 Given the time that's been invested in this
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1 it's -- I just don't understand why from the

2 start DOE just doesn't commission some of

3 these homes built to the IECC. 

4 And admittedly 2015 just came out,

5 but to see what the actual numbers and actual

6 operation look like.

7 I mean, I don't know what needs to

8 be tweaked on this model. I mean, I didn't

9 put it together. God only knows. But it's

10 all based on model.

11 MR. HAGERMAN: We did commission

12 homes, they just were energy simulations. And

13 that energy simulation software has been

14 recognized I think by all the --

15 MR. WEISS: I'm not arguing with

16 that. 

17 MR. HAGERMAN: It seems to be pretty

18 well --

19 MR. RAMIREZ: Lois, you want to

20 respond to that?

21 MS. STARKEY: Yes. I just -- and

22 Emanuel, you may speak to this because you're
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1 intimately involved in it, but SBRA in joint

2 partnership with DOE is actually -- and

3 Tennessee Valley Authority is actually

4 building some homes.

5 I'm not sure if it's to the 2015

6 IECC, but it's super energy efficient. It's

7 the gold standard of what DOE is -- 

8 MR. HAGERMAN: Building America.

9 MS. STARKEY: Yes, and what --

10 you've got a super energy efficient home. So

11 we will have some data on how manufactured

12 homes perform.

13 But it's only in one zone, only in

14 one climate zone. I mean, you know, I just --

15 I'm not sure what value just building more

16 homes that would be model homes. People

17 really wouldn't necessarily be living in them. 

18 And I think to Joe's point we've

19 got, you know, data and models --

20 MR. HAGERMAN: Energy Plus has been

21 validated too, I guess.

22 MS. STARKEY: Yes, it's Energy Plus. 
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1

2 MR. LUBLINER: This is Mike

3 Lubliner.

4 MR. RAMIREZ: Hold on a second,

5 Michael. Eric, you've been patient. Let me

6 get Eric, then you, Michael.

7 MR. LACEY: Before we send Matthew

8 away I do want to have a conversation about

9 SHGC. Because I think we're going to be

10 getting more runs. That's one area that gives

11 me heartburn in the current prescriptive path. 

12 Because I think we can do a little bit more

13 cost-effectively on the solar heat gain of the

14 windows, and we could be more consistent with

15 the 2015 IECC.

16 Emanuel's done some great work on

17 the U factors of the various components in

18 comparing them, but he's left the SHGC the

19 same in every climate zone. 

20 I think if we drive that down a

21 little bit lower where it is in the 2015 IECC

22 to 025 SHGC I think you'll turn then Miami
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1 from red to black, first of all. 

2 And I think the energy savings and

3 some other factors that come into this will be

4 beneficial. 

5 I'm wondering if we should have that

6 discussion now or at some later point. 

7 Because I did have some discussions with

8 people in the window industry and have some

9 information to share.

10 MR. HAGERMAN: So, Joe Hagerman,

11 DOE. Could you really quickly remind us, by

12 changing the solar heat gain coefficients on

13 the glass what the incremental cost increase

14 would be in both the single and the double

15 section? 

16 And then we can just keep the energy

17 numbers the same and just put the cost data in

18 there and see how it racks and stacks?

19 So there we recognize the cost

20 increase but not the savings.

21 MR. LACEY: Recognizing that the

22 savings would probably increase.
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1 MR. HAGERMAN: Right.

2 MR. LACEY: Okay.

3 MR. HAGERMAN: Let's just see what

4 the cost impact. 

5 Because last time really, to be

6 honest with you, when we monkeyed around with

7 the numbers, or when we -- I shouldn't say it

8 that way. Take that back. That's not a

9 technical term.

10 When we redid the simulations we

11 didn't really see a huge energy impact. We

12 saw the hugest impact just on the cost, right?

13 MR. LACEY: Yes.

14 MR. HAGERMAN: So I don't think, you

15 know.

16 MR. LACEY: I'll run through a few

17 reasons why I think that was probably the

18 case.

19 First, as I pointed out last time,

20 the costs that we were presented with, I

21 thought they were conservative, very

22 conservative. They were certainly a lot
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1 higher than the windows being sold for the

2 stick-built home market.

3 And I realize there are some

4 differences. And when I reached out to people

5 in the fenestration industry you can't just

6 take a window off the shelf at Home Depot and

7 put it in a manufactured home.

8 Now, their opinion was the costs

9 would not increase all that much to get -- to

10 comply. It certainly wouldn't double in price

11 as the numbers showed here.

12 And recognize that these numbers

13 also show kind of upgrade by upgrade costs

14 rather than looking at the window costs as if

15 you're producing the same window for the whole

16 country, or just two windows for the whole

17 country, not special ordering each incremental

18 improvement the costs would obviously come

19 down. That's what we've seen in the

20 stick-built home market.

21 So, I had a conversation with Rob

22 and I chatted with Emanuel on this.
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1 One thing I was going to suggest. 

2 Rather than aim for the very, very best window

3 that's spec'd on -- there was a handout that

4 was handed out last time that showed kind of

5 the incremental steps and cost for going

6 single-pane to double-pane, to double-pane

7 low-E, rather than driving that all the way to

8 what I'd like to see which is a 3.0 U factor

9 2.5 SHGC window, why don't we just focus on

10 starting where Emanuel is.

11 He's got basically two windows for

12 the whole country. The HUD climate zone 1 and

13 2 has a U factor of 3.5 and an SHGC of 3.3,

14 and HUD climate zone 3 has a U factor of 3.2

15 and the same SHGC of 3.3.

16 What I'm going to suggest is if in

17 the HUD climate zone if we can drive the SHGC

18 down to a 2.5 the incremental cost difference

19 is somewhere around 70 or 80 cents a square

20 foot which I don't think is a lot. That's

21 obviously not going as far as we could go with

22 the efficiency, it's just going kind of one
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1 level change.

2 But this accomplishes a few things. 

3 One, it will maintain consistency with the

4 2015 IECC in all climate zones. It would

5 bring out -- in addition to the energy and

6 cost benefits you would reduce electric peaks.

7 Depending on the orientation of the

8 home which is another thing we should talk

9 about you get some real energy savings and

10 comfort improvement.

11 One thing that the PNNL model is it

12 assumes an equal amount of glazing on all

13 sides of the unit. And from the designs I've

14 looked at, especially single lines, that's not

15 the case.

16 Most of the glazing is on two sides,

17 the long sides. Right? 

18 And so if you rotate that house from

19 a good orientation which would be a

20 north-south to a bad orientation which would

21 be east-west the impact of the solar gain is

22 going to be huge on your air conditioning
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1 loads.

2 So, I'm going to suggest going with

3 the 2015 IECC numbers for SHGC if we could

4 figure out the air conditioning sizing that

5 would save you on -- you could downsize the

6 air conditioning too like we discussed

7 earlier.

8 I'd like to see how that falls out. 

9 I think it's going to be cost-effective at

10 least in HUD climate zone 1 if not in HUD

11 climate zone 2 as well.

12 MR. HAGERMAN: We should point out

13 too -- Joe Hagerman with DOE again -- that

14 this model does not assume any cost for the

15 downsizing of equipment. 

16 MR. LACEY: Right.

17 MR. HAGERMAN: So we did not model

18 that credit into the current cost numbers that

19 you see up there.

20 MR. LUBLINER: This is Mike

21 Lubliner.

22 MR. RAMIREZ: Thank you. All right,
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1 Michael.

2 MR. LUBLINER: I think that there's

3 a mistake if you don't take credit for the

4 downsized air conditioner that the consumer

5 would have.

6 And I think if you take the credit

7 for the downsized air conditioner and used

8 what Eric's proposed you're going to get a

9 better solar heat gain coefficient with a good

10 lifecycle cost in climate zone 1.

11 If we're doing some horse trading

12 you're going to get rid of the 38 in the roof

13 in climate zone 1, I certainly think you need

14 to trade back in the better solar heat gain

15 coefficient.

16 Having said that I still have real

17 issues with assuming that we need to change

18 the frame of a truss to get an R38. And

19 that's what's driving that cost and pushing us

20 into Levy's revision 2 proposal. 

21 So those are my feelings here on

22 that. Thank you.
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1 Oh, one last thing. In regards to

2 Mark's comments about validation of computer

3 modeling, we have taken random samples of

4 thousands of homes that were built under

5 energy efficient manufactured homes program

6 and have done measurements and billing

7 analysis, and have concluded that the models

8 that we used, the E-Plus models which are

9 fundamentally like EnergyPlus do a really good

10 job of predicting energy use.

11 Although there is a wide standard

12 deviation, that tends to happen. That's out

13 of our control and that's occupant behavior.

14 One thing that we do see though is

15 that a lot of these people, particularly the

16 licensing, the affordable people that get the

17 entry-level house, they can't afford to keep

18 the heat at 70 or 68 degrees. 

19 They turn the heat off when they

20 leave, the electric furnace, the 15 kWh

21 furnace. They come back. And we see that

22 practice results in durability and moisture
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1 problems.

2 So I think that it's easy to say,

3 you know, we don't know how well this model

4 predicts. 

5 I think we, at least in the

6 Northwest are comfortable using these models

7 as is DOE. And the only problem is behavior. 

8 And you would save less energy because people

9 are using a setback and turning the heat off

10 for long periods of time, that's generally

11 driven by their licensing nature, inability to

12 pay utility bills.

13 So I think we're good on the energy

14 savings side. But I do have some issues, as

15 I said, on the ceiling costs assumptions. And

16 I do support that solar heat gain compromise

17 for a better solar heat gain, or at least look

18 at the analysis and see how it compares for

19 climate zone 1. I think that's going to be

20 huge.

21 The other thing is the R38 and the

22 lid in climate zone 1 did not take into
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1 account the impact that an R38 has versus an

2 R30 on the duct thermal distribution

3 efficiency.

4 If there are ducts in the attic

5 which there are in those climate zones very

6 often, then the energy savings associated with

7 going to 38 is going to be much higher because

8 there's less duct losses. Because more of

9 that duct insulation is covering -- the

10 ceiling insulation is covering the ducts. 

11 So that's -- sorry for these

12 nuances, technical, nerdy stuff, but that's

13 all I have to say. Thank you.

14 MS. HOFFMAN: Quick question for

15 Matthew. It's Eileen Hoffman. Can you in

16 your columns also do SHGC? Can that be done?

17 MR. HAGERMAN: You can model the

18 costs but not the energy effects quickly.

19 MR. LACEY: You'd rather not have

20 one without the other.

21 MR. HAGERMAN: You can have one,

22 just can't have the other.
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1 MR. RAMIREZ: That's for PNNL,

2 right?

3 MR. HAGERMAN: Right.

4 MR. RAMIREZ: So, at least we get

5 that in there and see how --

6 MR. HAGERMAN: That's why I said if

7 you just look at just this front cost first

8 you can see.

9 MR. RAMIREZ: Well, let me ask you,

10 is that something that they could do

11 overnight?

12 MR. LACEY: I don't know if that's

13 going to be that helpful to add just the cost

14 without the energy savings.

15 MR. RAMIREZ: Well, I'm asking if

16 PNNL could broaden their savings overnight.

17 MR. HAGERMAN: If it adds $300 of

18 cost then no. 

19 MR. LACEY: It's going to be $90 and

20 $153.

21 MR. HAGERMAN: So the worst case

22 would be --
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1 MR. LACEY: The double-wide would be

2 --

3 MR. HAGERMAN: One forty. So, okay. 

4 It's not going to make anything negative other

5 than --

6 MR. RAMIREZ: Is that all right,

7 Eric? Just looking at the cost for now, and

8 then we can see if we can get the savings from

9 PNNL overnight?

10 MR. LACEY: Yes, that's fine. And

11 I'd recommend looking at the worst case

12 scenario on SHGC when they calculate that,

13 rather than the average with the glazing area

14 distributed on all four sides.

15 MR. RAMIREZ: Okay. Mark? I'm

16 sorry, Emanuel. Let me get Mark and then I'll

17 get you.

18 MR. WEISS: Just to recognize Rick.

19 MR. MENDLEN: Thank you. At one of

20 the fall meetings we had discussion about the

21 SHGC coefficients. And the fact that going

22 down to the level of 0.25 would possibly
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1 impact the ability to produce an egress window

2 that meets the current requirements of the HUD

3 standards.

4 And I'd like to remind everybody

5 that what I suggested was doing some sort of

6 weighting or averaging to make sure that

7 egress windows at least would be capable of

8 meeting our current requirements without -- as

9 they currently are for safety considerations.

10 MR. LUBLINER: This is Mike

11 Lubliner.

12 MR. RAMIREZ: Michael, hold on. Let

13 Eric address that.

14 MR. LACEY: I was just going to

15 respond that I hear you. The issue, the SHGC

16 won't affect egress. The air leakage number

17 might. And we had already decided at a

18 previous meeting we were going to eliminate

19 the air leakage requirement on the windows

20 that applies specifically to them. So unless

21 somebody wants to correct me I don't think

22 SHGC will affect the egress. That is
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1 important and I don't think this will change

2 that.

3 MR. ROY: Egress is about the frame. 

4 SHGC is about the glass.

5 MR. LACEY: Is about the glass.

6 MR. ROY: The glass unit inside a

7 frame.

8 MR. LACEY: Yes.

9 MR. ROY: It will be strange.

10 MR. LACEY: It's not affected by the

11 air leakage.

12 MR. LUTER: This is Rob Luter. Eric

13 is correct. SHGC will have no impact on force

14 of operation, but the air leakage that we

15 proposed adopting would have. 

16 At the end of the day though we

17 elected to keep the current HUD air leakage in

18 place. So that shouldn't affect egress.

19 MR. RAMIREZ: All right. Emanuel,

20 you had something?

21 MR. LEVY: Yes. I just wanted a

22 word of caution. I agree with Eric that it
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1 would be worthwhile to do a little more

2 investigation of the glazing options.

3 The cost of going down to 0.25 is

4 about $100 per single section and $150 for a

5 double section.

6 But in doing the modeling, and he

7 touched on this earlier, there are a number of

8 variables that have to be considered.

9 Because you can easily make

10 assumptions that are in favor of -- very

11 favorable to the reduction in solar heat gain

12 coefficient. 

13 For example, orientation, Eric

14 talked about bad versus good orientation for

15 solar heat gain coefficient makes a huge

16 difference in -- makes the difference between

17 cost-effective and not cost-effective.

18 But there are other things like

19 shading. If there's another house within 10

20 feet of the house that gets the glass that's

21 being shaded by it, and therefore the solar

22 heat gain coefficient is of less value.
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1 And by the same token, if people

2 have window shades pulled down the solar heat

3 gain coefficient is of less value.

4 If they set up their thermostats

5 during the day while they're out of the house

6 the solar heat gain coefficient has less

7 value.

8 So, it's not -- it shouldn't be

9 simplified and we should look at the full

10 range of variables here. Recognize that the

11 actual use conditions may, in fact, make the

12 option less cost-effective. But it certainly

13 is worth looking at.

14 MR. DENNIS: Can you hear me?

15 MR. RAMIREZ: Yes, go ahead,

16 Michael.

17 MR. DENNIS: This is Keith Dennis. 

18 Can you hear me?

19 MR. RAMIREZ: Yes, go ahead, Keith.

20 MR. DENNIS: I just wanted to make a

21 point earlier. I've been on the phone but

22 I've been having trouble getting my hand
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1 heard.

2 I think that the cost-effective and

3 affordability conversation is great, and I

4 think that the conversation is great.

5 One thing that I was thinking about

6 is some studies that we've done on kind of

7 looking at the cost approaching the

8 cost-effectiveness.

9 And generally this is just a rule of

10 thumb we have, but when you're going up in

11 energy savings the first 50 percent of your

12 savings is going to cost you about 25 percent. 

13 The next 25 percent is going to cost you about

14 25 percent. 

15 Wait -- the first 50 percent is

16 going to cost you 25 percent. The next 25

17 percent is going to cost you about 25 percent. 

18 The next 25 percent is going to cost you about

19 50 percent. So you start getting more

20 expensive as you go towards the level that

21 you're reaching generally. But that may not

22 happen here.
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1 But one of the things I'm concerned

2 about is step increases right at the end of

3 cost-effectiveness. 

4 And it sounds like this graded thing

5 might be one of those kind of issues where it

6 is cost-effective but it's a big step

7 increase. So, you're not getting the bang for

8 the buck that you do earlier on in that

9 analysis.

10 Does that make sense?

11 So, just generally I think we need a

12 construct like 10-year payback. But when you

13 think keeping added-on rate at the end that

14 costs a lot more and it's kind of marginal,

15 that's where I get a little bit nervous.

16 MR. RAMIREZ: All right. Let me get

17 Michael, Lowell and then Eric. 

18 MR. LUBLINER: Well, first comment,

19 back to Rick's comment is my understanding is

20 the solar heat gain coefficient has nothing to

21 do with egress of windows.

22 And I think also for HUD's benefit I
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1 would take a strong look at what HUD has for

2 the way of its current egress and its

3 differences with site-built I-codes.

4 I think you'll find that some of the

5 egress requirements in the HUD code are based

6 on very old assumptions, but we don't need to

7 get into that now.

8 As far as the solar heat gain

9 coefficient if we're talking about less than

10 a buck a square foot we should certainly do

11 the run and see where it's at.

12 And again, I'm very concerned about

13 assumptions that are made, as Emanuel said. 

14 My philosophy is to use the worst case

15 assumption for orientation. This is generally

16 what's done. 

17 So if we want to, right now we're

18 using an average. But I would say we look at

19 the lifecycle cost assumption of this better

20 solar heat gain coefficient and assume worst

21 case and see where it comes out.

22 That would be a conservative way to
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1 do it so those people that are in a park and

2 they have some sort of limitations in

3 orientation, those aren't getting screwed

4 because they didn't get a better solar heat

5 gain coefficient.

6 That's all I have to say on that. 

7 Thank you.

8 MR. RAMIREZ: Okay. So can Matthew

9 start working on his stuff while we continue

10 this discussion? 

11 MS. HOFFMAN: Are we all clear what

12 we've asked Matthew to do? Are you clear?

13 MR. RAMIREZ: That's the question.

14 MS. HOFFMAN: This mission, should

15 you accept it.

16 MR. HAGERMAN: Would it be that

17 difficult to show us with the cost?

18 MR. WALKER: I can do what I've been

19 asked very quickly.

20 MR. HAGERMAN: Okay. And then can

21 you show us the same but with the solar heat

22 gain already costed in there, but not the
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1 energy savings? Would that be more difficult?

2 MR. WALKER: Can we pick one? Do

3 you want to pick?

4 MR. HAGERMAN: Yes. I think we only

5 care about 1A, 2A, 2B.

6 MR. WALKER: Okay.

7 MR. HAGERMAN: And 3(a).

8 MR. LACEY: Well, it would be

9 climate zones 1 and 2 which would go through,

10 basically through IECC climate zone 4.

11 MR. HAGERMAN: Three and four.

12 MR. LACEY: Yes, if I'm reading that

13 right.

14 MR. WALKER: I can do that too.

15 MR. LACEY: I mean, all you're doing

16 is adding $90.35 to a single and $153.03 to a

17 double according to the numbers here. I'm

18 just using the numbers we got from Emanuel. 

19 MR. HAGERMAN: Just see if you can

20 do that. We'll see you in 10 minutes.

21 (Laughter)

22 MS. HOFFMAN: Thank you.
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1 MR. RAMIREZ: While Matthew's doing

2 that, Lowell, you're next.

3 MR. UNGAR: It's still not clear to

4 me how much influence the lifecycle cost,

5 either the 10-year or 30-year, has on folks.

6 I do think for SHGC the assumptions

7 may be it sounds like are critical. That

8 would be my guess too. 

9 So, simply to say that the run isn't

10 very helpful unless we all agree on the

11 assumptions. I'm not sure we're all going to

12 agree on the assumptions. So I'm not quite

13 sure -- unless we spend an hour discussing

14 them I'm not sure we can deal with them.

15 I did want to throw in a couple of

16 other things to the extent we're going to take

17 about lifecycle cost calculations.

18 One is that I think these runs are

19 assuming air leakage rates which were not what

20 we -- consistent with what we agreed to in the

21 last meeting. 

22 So if we're in zones 3 and above it
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1 looks to me like it has the envelope air

2 leakage of three. And I don't think anybody

3 thinks that will be the average given what

4 we're talking about as a standard for air

5 leakage.

6 It also has duct leakage of four and

7 I'm not sure if that's -- for real homes if

8 that's consistent with what we were talking

9 about with the heater. And I think those

10 might have a significant effect on the results

11 for the other measures. 

12 That is, if you have a lot more air

13 leakage then some other measures will have

14 more of an impact on energy savings. 

15 I'll also note that for zone 3 the

16 ceiling assumption doesn't look the same and

17 what was in Emanuel's chart. So I'm not sure

18 they're exactly the same although I assume

19 it's pretty close to Rev 2, but not just

20 exactly the same.

21 And then I'll note if we're talking

22 about lifecycle cost the other thing that I
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1 think is potentially significant is while we

2 have taxes on the homes the mortgage interest

3 is tax deductible for those who pay taxes and

4 itemize deductions, which for those who have

5 mortgages is usually a lot.

6 And that would have -- lower the

7 effective interest rate. And it also I think

8 would have a somewhat significant -- again,

9 where we're talking about the margin for these

10 balancing costs and savings, if it's just a

11 little bit red or a little bit black I think

12 that might make a difference.

13 There's a number of other ones, so. 

14 Oh, the one other one I'll mention

15 because that's for Miami if we care about zone

16 1 which it's not clear to me -- for HUD zones

17 I don't think we care about Miami.

18 But if we care about Miami the mix

19 of equipment for HVAC equipment is a national

20 mix. I think the regional mix is quite

21 different and would give quite different

22 results.
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1 MR. RAMIREZ: Okay. Eric, did you

2 have something?

3 MR. LACEY: No. I agree with what

4 would be said about the reasons behind worst

5 case. 

6 I guess maybe I will follow up a

7 little bit. I think it was Keith Dennis that

8 was commenting on whether the costs were worth

9 it.

10 And I'd point out that if this can

11 result -- if lower SHGC results and lower air

12 conditioning loads, that'll have a significant

13 impact on heat and electrical demand and

14 environmental impact associated with that,

15 especially out in rural parts of the country. 

16 And so I think there's a huge value that's not

17 accounted for in the PNNL runs.

18 As long as we're considering whether

19 there might be a tree shading it nearby we

20 also need to consider the other potential

21 impacts that maybe aren't being tallied up in

22 the PNNL spreadsheet.
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1 MR. DENNIS: Can I add one comment? 

2 My comment was actually from earlier and I

3 just kind of came in on this.

4 MS. HOFFMAN: This is Keith?

5 MR. DENNIS: When we were talking

6 about affordability -- yes, this is Keith. 

7 Sorry.

8 When we were talking about

9 cost-effectiveness and affordability I wanted

10 to throw out there what I would view as kind

11 of my philosophy looking at it.

12 I mean, I think that we need to look

13 at -- and that's started at the time I was

14 trying to -- I'd been on the phone.

15 We're trying to get a look at it --

16 or I know we have to look at it in the

17 construct. But I like this 10-year, 30-year,

18 you know, as a rule of thumb.

19 But again, one key is to kind of

20 approach that boundary to add a little step

21 apart. That's where I think we need to have

22 some leeway in order to make people like me
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1 comfortable. I don't know if there are other

2 people. I know there were -- rules of thumbs

3 are good but if it's not practical and at the

4 very end you're adding this cost to get that

5 last couple percentage, or that last bit

6 that's cost-effective, I think that that just

7 doesn't make sense for the buyer.

8 I don't know if the solar heat gain

9 one is one of them. I'm saying if we can

10 different things like that at inception I'm

11 more comfortable with kind of sticking to the

12 guidelines of lifecycle cost. I know that

13 we've had a discussion about affordability. 

14 I think that's kind of where I fall. 

15 So that just happened to fall in

16 this conversation because I had my hand raised

17 earlier, but it didn't come up. So, and we do

18 like, obviously, people having reductions are

19 huge for us. So if that's what comes out in

20 the analysis we'd love to know that and it

21 would be important to have because people have

22 just a real problem.
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1 MR. RAMIREZ: Okay. Lois?

2 MS. STARKEY: I'd just like some

3 clarification as to where we're going with

4 this. Because it sounds like we -- are we

5 back to four zones or five zones, and

6 different U values than are proposed here? I

7 mean, with the exception of a few tweaks.

8 I'd like to see us kind of come to

9 terms with some parameters of a standard. I

10 mean.

11 MR. RAMIREZ: And I think that with

12 the U values we might have to play with that

13 a little bit, right?

14 But as far as the climate zones, how

15 does everyone feel about the three climate

16 zones?

17 MR. ROY: I think 6 and 7 stick out. 

18 They look weird. They just don't do it for

19 me.

20 HUD zone 3 going from the Tidewater

21 Virginia and Las Vegas to the Canadian border

22 is weird.
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1 MR. HAGERMAN: If you just look at

2 Emanuel's page 5, this is -- I kind of went

3 over this before. If you look at the Uo

4 values there's some natural divisions in my

5 mind, right?

6 You can group IECC climate zone 1

7 and 2, then you can group 3 and 4, then you

8 can group 5 and 6, and then you can group 7

9 and 8, right?

10 MR. ROY: Eight is the last one?

11 MR. HAGERMAN: Yes, 8 would be the

12 last group.

13 (Simultaneous speaking)

14 MR. SANTANA: I don't think we can

15 get into the discussion on the zones until we

16 establish U values first. You know, the

17 establishment of the U value is what's going

18 to allow you to lump things into zones.

19 MR. HAGERMAN: Well, so Manny, in my

20 mind, you know, the -- so in my mind the U

21 values that Emanuel has presented on page 5

22 don't really differ from what he's shown us on
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1 page 8. 

2 But the ones on page 5 are kind of

3 better justified by the 10-year look, 10-year

4 with recapture.

5 So I mean, I guess the question is

6 to the manufacturers is how palatable are

7 these U values that are on page 5.

8 MS. HOFFMAN: Well, could we stick

9 to the last two zones?

10 MR. HAGERMAN: Let's just stick with

11 -- let's just part the climate zone situation,

12 just however the Uo values with the current

13 presented IECC climate zones. I mean, do they

14 seem --

15 MR. SANTANA: So, just where I'm

16 standing I think the U values on page 5 in my

17 mind are justifiable.

18 I think the approach of how you got

19 to the --

20 MS. HOFFMAN: Oh, we can't hear you.

21 MR. SANTANA: I'm sorry, how am I

22 now?
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1 MS. HOFFMAN: Yes. If you could

2 repeat.

3 MR. SANTANA: Which part, the whole

4 thing?

5 MS. HOFFMAN: Yes, start from the

6 beginning.

7 MR. SANTANA: Okay. What I was

8 saying is I think just from my perspective is

9 that the U values on slide 5 are justifiable.

10 I can see where they come from. I

11 can see what incremental benefit they have and

12 I don't have an issue with them.

13 But just the fact that there's too

14 many of them. I try to group them into

15 chunks.

16 MR. HAGERMAN: Yes. So, Joe

17 Hagerman, DOE. I think they group themselves

18 in chunks, right? Just those natural

19 divisions of climate zone 1 and 2, and 3 and

20 4, and 5 and 6, and then 7 and 8.

21 MR. SANTANA: You know -- this is

22 Manny -- when you look at the map there's only
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1 a few areas that really are not consistent

2 with grouping. But the country as a whole I

3 think lends itself to being grouped.

4 MS. HOFFMAN: And Manny, what kind

5 of grouping are you proposing?

6 MR. SANTANA: Well, I like the idea

7 of the three zones. You know, I actually

8 don't have a problem with what Emanuel did. 

9 You know, he might have gone too far by adding

10 single sections with double sections. But I

11 think we can take another look at his proposal

12 here and before we just put it aside.

13 As we can see, after Emanuel was

14 done presenting Matthew came up and he gave

15 lifecycle numbers for the packages that

16 Emanuel's method determined. 

17 MR. HAGERMAN: Well, just to be

18 clear, I think he gave the 10-year look with

19 residual of the packages that are on page 5 of

20 Emanuel's document.

21 MR. SANTANA: Right.

22 MR. RAMIREZ: So, what I'm hearing
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1 though is that the possibility of looking at

2 creating your own climate zones here, right? 

3 Where not necessarily HUD or 2015 IECC, it's

4 a combination of some of these 2015 IECC

5 zones. 

6 And according to the U values that

7 are in Manny's chart I think at least 1 and 2

8 would be one zone, 3 and 4 would be another,

9 4 and 5 would be another. Is that that I'm

10 hearing?

11 MR. ROY: I would say something. 

12 This is Robin. I wouldn't say it's creating

13 -- if you want an IECC-based definition you

14 wouldn't be creating these zones. You would

15 just be giving one number for two zones. IECC

16 zones 1 and 2 would have the same numbers. 

17 It's not creating anything new.

18 MS. HOFFMAN: Oh, I see. So in a

19 sense you're lumping them so that it's easier

20 to administer.

21 MR. ROY: Well, the numbers which

22 show up on page 5 are already identical for 1
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1 and 2, and they're identical for 3 and 4, and

2 they're identical for 5 and 6, and they're

3 identical for 7 and 8. So, it seems like it's

4 naturally grouped into four zones.

5 I could imagine dropping one of

6 those. But which one would it be?

7 MS. STARKEY: Just for the sake of

8 discussion, you know, it's what, the two

9 Dakotas, Minnesota and Michigan. 

10 MR. HAGERMAN: How many units are

11 sold up in those zones?

12 MR. SANTANA: This is Manny. What's

13 captured -- you know, the thing to notice. 

14 These numbers only reflect the U values from

15 the packages, but they're not weighted at all. 

16 So when you go into grouping zones

17 and you say, well, grouping 0.051 and 0.59, I

18 don't feel really comfortable with that. 

19 But you know, you think of how many

20 units should go in there versus what's going

21 in this house, right, you might try to put a

22 little --
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1 MR. HAGERMAN: Well, we need that

2 data. I think everybody here is reasonable

3 people, we just need some data to support the

4 decisions that we're all going to have to vote

5 on, right?

6 MR. EZZO: This is Mark Ezzo. I

7 agree with what you said, Manny. I think

8 that's -- to me, that's the way I read what

9 Emanuel did. He went from what we were

10 looking at on page 5, right, that has all the

11 zones.

12 And to your point, Manny, about how

13 it looks like 1 and 2 are together, 3 and 4

14 are together, 5 and 6 are together, and you've

15 got 7 and 8 kind of out there on its own. 

16 And the fact that 7 and 8 is such a

17 low number of units shipped per year, that's

18 why I like what Emanuel did with page 8 where

19 he took the page 5 and he simplified it down

20 into Uo numbers that would work in the three

21 current HUD code climate zones. 

22 MR. ROY: Mark, this is Robin. As I
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1 understand page 7, what Emanuel combined was

2 really for HUD zone 1 he combined IECC zones

3 2 and 3. Yes, 1 is in there too, but it's

4 negligible.

5 MR. EZZO: Yes.

6 MR. ROY: So it's 2 and 3.

7 MR. EZZO: I agree.

8 MR. ROY: Which are 0.67 and 0.85

9 which are so substantially different. 

10 MR. EZZO: Well, but when you --

11 okay.

12 MR. ROY: It's combining IECC zones

13 2 and 3. That's the heart of the HUD zone 1. 

14 It's 2 and 3. And 2 and 3 are very different

15 U values. IECC 2 and 3 are 0.067 and 0.085,

16 right? Is that not right? They're very, very

17 different. That's part of the challenge of

18 the way the HUD zones are drawn. It goes

19 different places.

20 I mean, HUD zone 1 -- am I not

21 right?

22 MR. UNGAR: Sorry, I think Robin is
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1 looking at the -- page 2, the prescriptive

2 requirements before the adjustments, not after

3 adjustments. At IECC zones 2 and 3 for

4 single-wide. My understanding.

5 MR. ROY: Yes.

6 MR. LACEY: Page 2 has that on the

7 far right column. You're looking at the map. 

8 It says the same thing.

9 MR. UNGAR: The map would be the

10 same. But it's before adjustments, not after

11 adjustments.

12 MR. ROY: Oh, I see. So 0.087 and

13 0.07. So that's a big gap. It's like a 24

14 percent gap. That's big. 

15 It's just a funny design, HUD zone

16 1. Actually, HUD zone 3 is a funny design

17 too. And while you're at it 2 is kind of

18 strange as well. Las Vegas the Tidewater

19 Virginia and the northern border of the

20 country. It's all funny. That's all zone 3.

21 MR. EZZO: This is Mark again. Yes,

22 and I think where you look at Matthew's LCC
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1 numbers to me that's where it all sort of kind

2 of comes to a conclusion that makes some

3 sense.

4 Because I'm looking at the far right

5 column where we have most of the numbers in

6 the black. And I think those were based on

7 Emanuel's page 5. Correct me if I'm wrong.

8 MR. ROY: Right, that's correct.

9 MR. EZZO: So I think we're getting

10 close. I think we're getting close, but I

11 think what we need to do now is somehow pare

12 down his page 5 that has all those different

13 zones into three. 

14 Because didn't we all I guess

15 tentatively agree that we want to end up with

16 three zones when this is all over?

17 MR. RAMIREZ: I don't know. I think

18 it was the discussion of whether it be the HUD

19 3 zones, or the 2015, or something other I

20 think is even we'll put them up there. I

21 mean, this may be the other.

22 MR. HAGERMAN: This is Joe Hagerman. 
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1 Just real quick.

2 I mean, I sort of agree with you,

3 Mark. It just seems like the numbers on the

4 Uo values on page 5 of Emanuel's sheet

5 naturally get us down to more than -- I mean,

6 sorry, less than the eight climate zones of

7 IECC. So I think we can agree with Matt just

8 on how the numbers kind of naturally group

9 themselves. It gives you four.

10 Now, let's take off the easiest one

11 first, right? Or let's talk through the

12 easiest one first.

13 IECC climate zone 7 and 8 I think

14 deals with -- all these states are grouped

15 together, Michigan, Montana, shoot, I don't

16 know all my acronyms, North Dakota --

17 MS. HOFFMAN: South Dakota.

18 MR. HAGERMAN: Minnesota.

19 MR. UNGAR: This is Lowell. Are we

20 okay with, you know, whether it's three or

21 four zones, but zones that are not by state,

22 but by county if I recall. 
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1 I can't tell whether this is -- it

2 seems to me that you get a much better result

3 if we can do a better, you know, map these

4 zones the way that we're talking about. 

5 But I guess I haven't heard from

6 industry if that's a -- given that you're

7 going to get zones that make more sense you're

8 going to get a standard which is better

9 attuned to each location. Is that an okay

10 result?

11 You can then deal with these maps

12 which are not by state.

13 MR. EZZO: Lowell, I weighed in last

14 time when we had that discussion and I

15 expressed concern over changing the current

16 HUD code boundaries.

17 Because a lot of HUD code shipments

18 are for inventory and stock. And retailers

19 that inventory a lot don't -- they don't

20 necessarily know where those homes are going

21 to go. So the more complicated we make with

22 the boundaries the harder it's going to make
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1 for them.

2 Now, I'm not saying that it can't be

3 done because like other people have mentioned

4 in the modular world where we're dealing with

5 the by-county boundaries that are in the IECC.

6 But typically in the modular world

7 just about every home sold is a retail-sold

8 home. They're not inventorying modular homes

9 for the most part. So in that world there's

10 quite a bit of inventory and stock.

11 MR. HAGERMAN: Let me just close out

12 one thing. So I just wanted a statement of

13 fact.

14 If you look at the 2013 shipment

15 data in climate zones 7 and 8 it's roughly 4

16 to 5 percent of all shipments. So you need to

17 decide whether it needs to be its climate zone

18 or not. 

19 This is from the HUD data. And you

20 can run the numbers yourself. You have to

21 kind of make a judgment about Michigan so I

22 just took half of the number.
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1 MR. UNGAR: This is Lowell. Again,

2 if you use the HUD zones you're going to have

3 a standard in Las Vegas that is probably more

4 attuned to Wisconsin. Right? I mean, that's

5 the price you pay.

6 I'm not saying we can't do it. 

7 Personally I can support either one. I just

8 don't want complaints about why we have a

9 standard that doesn't work for Las Vegas.

10 If you really want HUD zones, okay,

11 let's work with it. But then accept that the

12 zones have to be then attuned to where most of

13 the sales are.

14 MR. RAMIREZ: Is somebody trying to

15 talk online? Oh, okay.

16 So, am I hearing then the

17 possibility of 1 and 2 combined as one zone,

18 3 and 4 as one zone, and then 5, 6, 7 and 8 as

19 another?

20 MR. HAGERMAN: That looks sensible

21 to me.

22 MR. LACEY: I just have a question
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1 from the HUD veterans in the room and on the

2 phone. 

3 Are the HUD zones used for anything

4 other than the energy standard? I mean, are

5 there other things that go by HUD zones 1, 2

6 and 3, or is it just for the energy efficiency

7 requirements?

8 (Simultaneous speaking)

9 MR. RAMIREZ: The folks that are

10 online, if you're not going to talk at that

11 moment if you could mute we'd appreciate that.

12 MR. LACEY: It just seems like it

13 would be easier. I mean, I don't have a real

14 dog in the fight. I do think it would be

15 better if you could get a little more

16 accurate. And I tend to agree with lining up

17 with the IECC, especially if you're already

18 building the other homes --

19 MR. HAGERMAN: Can I ask --

20 MR. LACEY: -- the modular homes to

21 the IECC map. If there are other things

22 attached to the HUD climate zone map it might
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1 be more challenging, but it sounds like this

2 is only used for energy efficiency so it might

3 be a little easier to tweak it.

4 MR. HAGERMAN: Can I ask another

5 question? This is certainly slightly inverse

6 of what Eric just said.

7 So, since there -- I think Rick just

8 said there's three other maps that are in the

9 --

10 MR. MENDLEN: There's three maps

11 total.

12 MR. HAGERMAN: Three maps total, all

13 right. So the three maps total in the HUD. 

14 There might be four now? There are four?

15 MR. MENDLEN: There's a -- I forgot

16 about the HUD wind zone map. There's a wind

17 zone map, a roof zone map, a thermal zone map

18 and then a hot and humid zone map.

19 MR. HAGERMAN: Okay, so all those

20 maps, do they divide up all those maps by

21 state boundaries? Or are there some maps that

22 are divided up by other factors?
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1 MR. MENDLEN: The wind map is done

2 by counties. The roof map is also done by

3 counties.

4 MR. HAGERMAN: So there's no real --

5 MR. MENDLEN: -- today I was curious

6 about the zones. These are the three same

7 zones that we had in 1975 when I had to work

8 out all this without a 21-person panel to help

9 me.

10 (Laughter)

11 MR. HAGERMAN: So this seems like

12 there's precedent then that we don't actually

13 have to draw these things by the state

14 boundaries. Is that correct? If all the

15 other maps in the HUD book doesn't go by state

16 boundaries why are we bound to state

17 boundaries here?

18 MR. ROY: This is Robin. That's

19 very interesting that they're making --

20 because the wind is a big deal for safety,

21 right? So, the manufacturers must be fairly

22 attuned to this location issue. I don't know
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1 how they deal with it with the retailers

2 sitting in the middle and not sure where their

3 products are going. It's interesting. I

4 guess it's harder.

5 MR. RAMIREZ: So when you say this

6 is harder, the combining of IECC.

7 MR. HAGERMAN: It seems like we

8 should just draw our own boundaries according

9 to IECC by just grouping 1 and 2 together and

10 draw the map, and then grouping 3 and 4 and

11 draw the map, and then grouping 5 and 6 and

12 draw the map. And I think 7 and 8 are still

13 on the table since it's only 4 percent of the

14 shipments and the U factor difference is just

15 0.008, you know. But that's for you all to

16 decide.

17 MR. MENDLEN: Also, don't forget

18 Alaska.

19 MR. HAGERMAN: Oh okay, and Alaska.

20 MR. ROY: That's 8, right?

21 MR. RAMIREZ: Let me gauge the level

22 of consensus on that. So, I'm going to check
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1 the level of consensus for three zones, one

2 combining 1 and 2 of the IECC as one, 3 and 4

3 as another, 5, 6, 7 and 8 as a third. And

4 we'll see a show of gloves of how you feel as

5 far as those zones.

6 MR. HAGERMAN: Do we need some more

7 conversation from the manufacturers? I mean,

8 I'd like to really hear from them.

9 I'm not trying to be insensitive to

10 Mark's concerns, but I just think that we need

11 to recognize that the other maps aren't drawn

12 by these state lines and just have a

13 discussion about it.

14 I clearly understand that there's a

15 need to educate everybody, the home-buyers,

16 the dealers, everybody on the changes that

17 we're going to present in this new standard. 

18 So I agree that there's some education that

19 the DOE needs to help pay for to help the

20 industry understand how these standards are

21 going to impact their product and to sell

22 their product. 
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1 But notwithstanding that could you

2 tell us more about if we had to redraw this

3 map the impacts?

4 MR. RAMIREZ: Richard, you had a

5 comment?

6 MR. HAGERMAN: I think Mark was

7 trying to talk.

8 MR. RAMIREZ: Mark?

9 MR. EZZO: I was going to say that

10 the other maps that Rick Mendlen was referring

11 to, the humid and fringe, it does follow the

12 county line. And the wind follows county

13 line.

14 Those are isolated to a fairly small

15 part of the country. I mean, for instance,

16 the wind zones as you guys know, everybody

17 knows is basically Gulf Coast and up the South

18 Atlantic. So it's not hitting the entire

19 country obviously. 

20 It's something that people have

21 gotten used to and it's not that cumbersome.

22 And the roof map is similar. If you
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1 look at the roof map it largely goes by state

2 boundary. There are some exceptions though

3 obviously. But it's a fairly simple map to

4 follow as well.

5 And I'm probably being selfish here

6 because I represent a lot of plants and a

7 whole lot of retailers.

8 And I went out to them and asked

9 them the question about the climate zone

10 boundaries, current HUD code versus what's in

11 the IECC. 

12 So I got an awful lot of feedback. 

13 And it's relatively unanimous. So that's

14 where my vote on this is coming from.

15 From a technical standpoint it makes

16 sense to change the boundaries from what we

17 currently use to something more in line with

18 the IECC boundaries. I understand the

19 argument for that completely from a technical

20 standpoint.

21 But I'm just looking at it from

22 logistics, from inventory, stock units, like
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1 I said. 

2 And then I'm also kind of wondering

3 how much more accuracy are we really going to

4 get if we change these boundaries from where

5 they're at today. 

6 So anyway, that's my two cents on

7 it.

8 MR. HAGERMAN: So, Mark. Can I ask

9 you just a quick follow-up question? When you

10 asked your -- so that's very helpful. It's

11 very good to get that information.

12 When you asked your dealers and your

13 manufacturers about the impacts of changing

14 the climate zones did you ask, like would they

15 have frustration if we changed the climate

16 zones and let's say just maintained state

17 boundaries? Or are they just against

18 completely changing any of the zones? Do you

19 follow that?

20 MR. EZZO: Yes, that's a good

21 question, Joe. And I didn't ask it that way. 

22 But I think I've got a pretty high level of
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1 confidence that I can say they would prefer no

2 change, obviously. 

3 MR. HAGERMAN: Right.

4 MR. EZZO: But if we were going to

5 change, if you could keep it on state

6 boundaries I think most of them would say they

7 would prefer that if we could do that.

8 MR. HAGERMAN: Okay. That's

9 helpful.

10 MR. EZZO: Where it gets challenging

11 is if you look at the map what happens today

12 with a lot of the retailers that ship in from

13 multiple zones is a lot of them ship into two

14 zones. 

15 And so what they'll typically do is

16 just stock worst case because they don't know

17 where the home's going. 

18 And today stocking a worst case -- I

19 shouldn't say worst case, but most restrictive

20 energy standard is not a huge leap. 

21 But going forward I think that's

22 going to be a little bit more of a challenge
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1 for a retailer, say, in, I don't know, in one

2 of the areas where their distribution radius

3 covers multiple zones.

4 MR. HAGERMAN: So, Joe Hagerman

5 again. It just strikes me like Texas is a

6 really hard state to deal with, right? 

7 MR. EZZO: Yes.

8 MR. HAGERMAN: Where it would

9 naturally fall under, well, the panhandle

10 would fall under IECC 2 which has a U value

11 for a single-wide of 0.087. And the rest of

12 the state would be climate zone 3 which would

13 be a 0.07.

14 MR. EZZO: Right.

15 MR. HAGERMAN: So, okay.

16 MR. RAMIREZ: Yes, Rich?

17 MR. POTTS: Richard Potts. Just on

18 the stocking of worst case or most energy

19 efficient home within that zone kind of drives

20 home the affordability point.

21 The example of Tidewater Virginia

22 where I'm from potentially paying just as much
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1 energy efficiency-wise when they might not

2 have to as a home up in the northern portion

3 of the country. 

4 I don't know what that cost

5 difference would be, but when you compare it

6 to the IECC zones it might be fairly drastic.

7 So I like Joe's approach. And then

8 maybe as a compromise even including the 7 and

9 8 within the upper range.

10 But I understand. I see all the

11 island climate zones up there and how that

12 might present a logistical problem for the

13 manufacturers. So I understand that. But it

14 makes sense to me to group them just where

15 they fall, where it makes the most sense.

16 MR. HAGERMAN: So, can I ask the

17 question? So if Mark or -- so thank you,

18 those are important comments, Richard.

19 What would be worst case if you're

20 looking at Texas?

21 MR. EZZO: Yes. So I think what

22 we're talking about is grouping IECC 1 and 2
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1 into Texas, correct?

2 MR. HAGERMAN: Well, that's -- yes. 

3 How do we group IECC 1 and 2 as a group and

4 IECC 3 and 4 across these states in some

5 logical fashion where it's equitable to

6 everybody, right?

7 Because it looks like Mississippi

8 and Alabama and Georgia are sort of getting

9 disenfranchised because they're in HUD climate

10 zone 1 when they probably should be in -- I'm

11 sorry. HUD climate zone 1 but yet they should

12 be in IECC climate zone 3, right?

13 MR. EZZO: Yes.

14 MR. LUBLINER: This is Mike

15 Lubliner.

16 MR. RAMIREZ: Yes, Michael.

17 MR. LUBLINER: I really, really have

18 a hard time with combining IECC 3 and 4. The

19 Northwest is building 60 percent of its homes

20 right now, well current practice homes and the

21 Energy Star homes to 0.059 throughout the

22 States of Oregon and Washington.
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1 I don't think you can split that

2 state into two climate zones without our

3 clients, the northwest utilities who have

4 invested hundreds of millions of dollars

5 really screaming. I don't think that's

6 equitable at all based on the uniqueness of

7 the fact that we have 50 percent cash and of

8 the other 50 percent, 90 percent are loans

9 with conventional mortgages. We're 90 percent

10 electric furnace.

11 When you start looking at all these

12 things their heads are going to explode if

13 they get lumped in a climate zone that's less

14 than what they have now. So that's a

15 deal-breaker for my client, I believe. 

16 MR. SANTANA: The fact that even so

17 -- Manny with Cavco, I -- two statements here. 

18 One, in response to Michael's

19 statement here. If your customers are

20 currently building to a 0.059 in Oregon which

21 is currently an 0.079 and you met that I don't

22 see how, you know, grouping it in two zones
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1 matters. You can still build to 0.059.

2 (Simultaneous Speaking)

3 MR. LUBLINER: -- can't. 

4 MR. SANTANA: The thing I wanted to

5 say is I want to make sure we all understand,

6 we're not just talking about changing

7 boundaries of the zones in the sense of --

8 take, for example, Texas which is responsible

9 for 24 percent of the industry's production. 

10 Say we split that state in half and

11 part of it is going to be the new HUD zone 1

12 with a U value of 0.085 or thereabouts, and

13 the other half is going to be HUD zone 2 with

14 a new U value of 0.067.

15 So that's a new U value of 0.067 or

16 thereabouts when they're used to building

17 0.116. It's going to be a very drastic change

18 for the folks in that state. We're going to

19 want to make sure all the costs and the

20 lifecycle costs and all that stuff is well

21 vetted if we're going to take that approach.

22 You know, where we're talking about
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1 20 percent of the industry's production. 

2 MR. RAMIREZ: Michael --

3 MR. LUBLINER: This is Mike

4 Lubliner. I'd just like to follow up on that

5 for a second. I don't want to spend too much

6 time on this.

7 I'm just telling you, this is a

8 no-brainer. If we get -- if the new minimum

9 comes in for western Washington and western

10 Oregon, the minimum less than what the current

11 practice is now the manufacturers are going to

12 have an unlevel playing field that's even

13 worse. And we're going to see less efficiency

14 because it's going to be driven to the bottom

15 of the barrel.

16 I really do believe that you need to

17 include the States of Oregon, Washington and

18 probably northern California in the coldest

19 HUD climate zone. 

20 Again, I won't support -- anything

21 less than that is not something I don't think

22 my clients are going to support.
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1 MR. RAMIREZ: Let's get Mark and

2 then Lois.

3 MR. WEISS: Two things. As I

4 mentioned previously there's inherent tension

5 between trying to fine-tune -- the potential

6 benefits of fine-tuning this to a greater

7 degree than it already is. 

8 Like Richard was referring to,

9 having Las Vegas and then Tidewater Virginia

10 in the same zone versus staying with a system

11 that permits standardization, uniformity to

12 the greatest degree possible which also drives

13 affordability.

14 So, I do know what Joe is saying and

15 I mean, my preference sitting here right now

16 would be to maintain three zones based on

17 state lines rather than county lines. When

18 you start splitting states that's a problem in

19 and of itself, particularly when you get the

20 smaller manufacturers who are serving a

21 smaller customer area.

22 MR. RAMIREZ: Lois?
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1 MS. STARKEY: I would need to go

2 back to my members if we were going to start

3 splitting zones by counties or other than

4 state boundaries. I just don't feel

5 comfortable with that right now, but maybe if

6 we could demonstrate the costs and the

7 benefits, the costs and if those U values

8 change maybe that would be something else.

9 But I don't feel real comfortable. 

10 I could see arguing for four zones, but again

11 that would have to be by states.

12 MR. HAGERMAN: I mean, you can --

13 Joe Hagerman, DOE -- you can see the color

14 code problem in front of us.

15 MS. STARKEY: Yes.

16 MR. HAGERMAN: It's kind of like,

17 you know, for sure pull the line up to capture

18 Virginia and all those yellow states up there. 

19

20 And then what do we do about the big

21 discrepancy in Texas. And then -- I need to

22 brush up on all my states.
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1 MR. RAMIREZ: I just, I'm hearing

2 the talk about the state lines. 

3 MR. HAGERMAN: Basically you're

4 going to drive everybody that's in HUD climate

5 zone 1 to, you know, 0.087, right? Or 0.070. 

6 I'm sorry, 0.070.

7 MR. RAMIREZ: There aren't clean

8 lines right now.

9 MR. HAGERMAN: 0.068.

10 MR. LACEY: At least the IECC lines

11 are based on climate data. I mean, as opposed

12 to just state lines.

13 MS. HOFFMAN: But the HUD code --

14 just excuse me, the three zones, were they by

15 state or by county?

16 MS. STARKEY: By state.

17 MS. HOFFMAN: Oh they were by state. 

18 Okay. So they were by state.

19 MR. HAGERMAN: Could you ever

20 conceive of allowing the manufacturer to

21 choose and then just label the product whether

22 or not it met the IECC version of the zones,
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1 or some modified HUD code version of the

2 zones? Would that make any sense? As long as

3 there's a label.

4 MR. EZZO: Joe, this is Mark Ezzo. 

5 I think that would be complicated for retail

6 world who -- from multiple manufacturers. 

7 Their head would spin.

8 MR. HAGERMAN: Okay.

9 MR. LUTER: This is Rob at Lippert. 

10 I think that would present some challenges on

11 the manufacturing side too as far as getting

12 the right label on the right product. 

13 MR. HAGERMAN: I'm happy to hear a

14 suggestion. 

15 MR. RAMIREZ: If you're really

16 talking about state lines are you saying the

17 current three HUD zones? Or is there a

18 different map?

19 MR. ROY: This is Robin. Actually,

20 maybe the good thing is, Lois, if you'd go

21 back and talk to your members and caucus with

22 them separately and see just how painful and
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1 costly and possible it would be to follow

2 three zones that are based on weather

3 conditions.

4 I understand how this is along state

5 lines and it is complicated, but there may be

6 something you guys can talk more freely

7 amongst yourselves and get back. I think that

8 could be useful.

9 MS. STARKEY: Yes. We've had lots

10 of discussions about it and they keep coming

11 back to the state boundaries. 

12 So I think if there's value in the

13 cost-effectiveness issue definitely I think,

14 you know, if they can say oh well geez, it's

15 going to cost me less to sell these homes in

16 this zone versus if we go to some other U

17 value or -- I'm happy to do that.

18 MR. HAGERMAN: Let me just say too. 

19 So, maybe Lois and Mark could go back to both

20 of your all's members.

21 And then also maybe we could sort of

22 park the discussion for now about the climate
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1 zones. And what we can move back to is what

2 Matthew is working on so we can at least give

3 you when you go back to your members, give

4 them a map that has the updated U values that

5 we sort of all agree on after seeing the

6 10-year -- not the LCC, the 10-year plus

7 residual analysis.

8 Because at least we can move this

9 map forward a little bit more of getting some

10 revised numbers up there.

11 MS. HOFFMAN: You may recall -- this

12 is Eileen -- one of our earliest meetings we

13 talked about climate zones. And people said

14 well, let's wait and see the numbers and see

15 if it makes a difference in how it can be

16 clustered. 

17 So, maybe -- but talking to your

18 members makes a lot of sense to get a feel for

19 it. Because if it's not --

20 MR. LUBLINER: This is Mike

21 Lubliner.

22 MS. HOFFMAN: Yes?
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1 MR. LUBLINER: This is Mike

2 Lubliner. That's exactly why I've been trying

3 to encourage this group to talk about this

4 earlier.

5 At this late date dropping this down

6 on the table and saying that, you know, again

7 back to the Northwest scenario, that we're

8 going to de-rate the savings in eastern

9 Washington versus western Washington. 

10 It's a non-starter with my client

11 groups that have worked with the industry in

12 partnership to produce this product at a very

13 high level. 

14 This will smack in the face of our

15 market transformation venture and our ability

16 to achieve the utility goals of the Federal

17 Northwest Power Planning Act. 

18 I do believe that the sooner we do

19 the analysis, the technical analysis, and if

20 it shows that a particular climate zone has a

21 lower lifecycle cost than the minimum HUD base

22 now that's what we should be going off of.
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1 But to suggest that we're going to

2 start making these -- gerrymandering or

3 whatever at this late date is really of

4 concern to me. And I think it will be to my

5 client as well.

6 (Simultaneous speaking)

7 MS. HOFFMAN: This was never -- just

8 to correct just one thing though. The

9 meetings I've been in this has always been out

10 there. We hadn't ever firmly decided it. So

11 it's -- just to set the record straight.

12 MR. ROY: Mike, this is Robin. One

13 thing I'm wondering, you're saying that if

14 anything comes back for Oregon, for example,

15 that's less than 0.059 it's a complete

16 nonstarter? Am I hearing you properly?

17 MR. LUBLINER: Absolutely. If we

18 don't get a regional Northwest

19 Power/Bonneville service area, one number that

20 works that's at least what we're at now with

21 our programs which is about 0.059 we're going

22 to have a hard time. 
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1 We're going to have utilities

2 looking at all kinds of alternatives, carrots

3 and sticks. And I think the client will be --

4 I think we're good with what we have. 

5 But now all of a sudden you start

6 splitting it out so a dealer that's in eastern

7 Washington shipping to western Washington has

8 to meet an 0.067 as opposed to an 0.059. Yes,

9 heads are going to explode, I think, in my

10 region. I'm just telling you what's going to

11 happen.

12 MR. ROY: I just want to clarify

13 because all I can say to that, I don't think

14 we're ever going to get to an 0.059 for

15 western Oregon. I just can't imagine we would

16 go there.

17 But if that's what the expectation

18 was that's problematic from the start. I

19 think.

20 (Simultaneous speaking) 

21 MR. LUBLINER: -- talking about was

22 0.061.
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1 MR. ROY: So, a question for Joe. 

2 Is it also possible to help with Lois and her

3 members, and Mark and his members to draw a

4 new map that is color-coded in three zones? 

5 That's combining IECC 1 and 2, combining 3 and

6 4, combining 5, 6, 7 and 8? It's a lot nicer

7 to have three colors than the whatever there. 

8 This is confusing. Just to help with their

9 conversation.

10 MR. HAGERMAN: Let me repeat what I

11 think I heard you say. So, make a colored map

12 that has four zones and just draw IECC 1 and

13 2 and color it the same. And then 3 and 4

14 color it the same. And 5 and 6 color it the

15 same. And 7 and 8. Okay.

16 MR. ROY: Five, six, seven and

17 Alaska, I guess that's what you used to do?

18 MR. HAGERMAN: Well, you need to

19 decide. I mean, it's 5, 6, 7. There's 5 and

20 6, and then there's 7 and 8.

21 MR. ROY: You told me that 4 percent

22 shipment to zone 7, that kind of -- I was over
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1 it. But maybe if others are not.

2 I was hoping to have something

3 that's simpler and easier for them to discuss

4 in front of them, something like that.

5 MR. LACEY: Those three climate

6 zones would make sense. I would just go and

7 lump in. Alaska has the same requirements as

8 Minnesota anyway.

9 MR. HAGERMAN: Can we go ahead and

10 vote to lump in IECC 5, 6, 7 and 8 as one

11 zone? For the purposes of a map.

12 MR. LACEY: All right. I'll do that

13 for the purpose of the map.

14 MR. RAMIREZ: As far as timing goes

15 when could you get that out?

16 MR. HAGERMAN: I'll ask. I mean

17 Navigant could easily do that tonight.

18 MR. RAMIREZ: Okay. Yes, because

19 I'm looking at this and trying to figure out

20 -- I understand there's some discussions that

21 need to be had. Is that going to happen

22 tonight? Is that something that we are going
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1 to try and reach some type of conclusion by

2 tomorrow?

3 MR. HAGERMAN: I think they have to

4 go back to their membership.

5 MS. HOFFMAN: We have to go back.

6 MR. HAGERMAN: We can re-present it

7 tomorrow. So we can just kind of talk over it

8 one more time just so you can see all the new

9 colors up there.

10 MS. HOFFMAN: Because you could do

11 it two maps, one with the colors with these

12 and one with states and see how that would be.

13 MR. ROY: You have to define the

14 states if you're going to say that.

15 MR. HAGERMAN: We can't say the

16 states. We'll just color those zones.

17 MR. RAMIREZ: And then are we also

18 --

19 MR. LUBLINER: This is Mike Lubliner

20 again.

21 MR. RAMIREZ: Go ahead, Michael.

22 MR. LUBLINER: Yes, I'd like to also
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1 see climate zone 4 lumped in with 5 and 6. 

2 I'd also like to see that map. 

3 MR. HAGERMAN: So, let me just make

4 sure I'm hearing you correctly. 

5 So, a second map that groups IECC 1

6 and 2 together, then leaves 3 by itself, and

7 then lumps in 4, 5, 6, 7 and 8?

8 MR. LUBLINER: Yes.

9 MR. HAGERMAN: Okay.

10 MR. SANTANA: Manny with Cavco. How

11 -- if a U value for zone 4 is the same as a U

12 value for zone 3 why would you lump in zone 4

13 in with 5, 6, 7 and 8, but leave zone 3 alone? 

14 Going off of that logic you might as

15 well just have a zone from the middle Texas on

16 up through 5, 6 and 7. That doesn't make

17 sense.

18 MR. RAMIREZ: I'll tell you what. 

19 Instead of getting into that today we'll run

20 it.

21 MS. HOFFMAN: Run two maps.

22 MR. LACEY: I'll run two maps. It's
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1 easy.

2 MR. UNGAR: We can run two maps. If

3 I might suggest while it's counter to my

4 interest I think that I think in that if we

5 went with these zones that the solution to

6 Luby's problem might be to take the western

7 parts of Oregon and Washington and just add

8 them into the third zone. Rather than keep

9 them all in zone 4, in IECC zone 4, we could

10 just take western Oregon and Washington and

11 move them.

12 MR. LUBLINER: I would accept that

13 and I think our retailers out here would also

14 appreciate that as will our utility grid and

15 their lawyers.

16 MR. RAMIREZ: So using basically the

17 line of the IECC as that.

18 MR. HAGERMAN: So why don't we do

19 this. Mike Lubliner, since I'm not sure I

20 follow exactly everything that you all are

21 talking about. 

22 Could you just draw up the map that
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1 you're asking to see? And then maybe send it

2 to --

3 MR. LUBLINER: I can give it to you. 

4 Right now you've got --

5 MR. HAGERMAN: I think if you could

6 just send it to Navigant then they could

7 colorize it and make it professional looking.

8 MS. HOFFMAN: Why don't you email

9 them?

10 MR. LUBLINER: Basically all I'm

11 saying is the yellow in Washington and Oregon

12 should be green.

13 MR. HAGERMAN: Okay. You follow

14 that, guys?

15 MR. ROY: This is Robin. Can I also

16 ask Lois and Mark when you're consulting your

17 members, because you do have manufacturers in

18 the yellow areas of Washington and Oregon,

19 what they would -- if it's really fine with

20 them. It's fine. 

21 I mean, you decide what you want in

22 terms of these maps. But you've got members
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1 out there, not just retailers.

2 MR. TOMPOS: We're making that all

3 green because? I mean, the IECC says this is

4 what it is, but we're saying we need to make

5 it higher than the IECC because Mike Lubliner

6 likes it that way?

7 MR. RAMIREZ: We're not making

8 anything. All we're doing is making a map.

9 MS. HOFFMAN: We're making a map. 

10 We're not doing anything.

11 MR. TOMPOS: Okay, okay.

12 MR. LUBLINER: It's not because I

13 like it, though I do like it. It's because

14 it's cost-effective. That's why we do it. It

15 has a lower lifecycle cost than the minimum

16 HUD code. That's why we do it.

17 MR. RAMIREZ: Mark?

18 MR. SANTANA: This won't prohibit

19 you from doing anything. The U knot for that

20 zone is currently 0.079. If Oregon is split

21 in half with half being 0.067 and the other

22 half being 0.059 per the current IECC map, and
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1 you moved everything to 0.059, you won't have

2 any issues. You can send that 0.059 out

3 anywhere you have the ability. I don't

4 understand why there's such an issue.

5 MR. RAMIREZ: All right, well we'll

6 --

7 MS. HOFFMAN: We'll deal with this

8 later.

9 MR. RAMIREZ: Yes, when we're trying

10 to actually finalize the map. Mark?

11 MR. WEISS: Just to recognize Rick.

12 MR. MENDLEN: Thank you. I just

13 thought it might be useful to tell you that

14 when we did the three-zone map umpteen years

15 ago, almost 40 now, we had to make some

16 compromises in order to keep the boundaries

17 along state lines because that's where the

18 comments took us in terms of U values and

19 everything else.

20 And I don't know whether or not, you

21 know, Joe your problem with splitting Texas as

22 an example which is probably the best
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1 four-star example we've got up there into --

2 maybe you take the most conservative approach

3 in some cases in order to make everything work

4 out along state lines.

5 Because some compromises are going

6 to have to be made in order for this map to

7 finally be acceptable to all parties. To make

8 it work along state lines you are going to

9 have to make compromises. There's just no two

10 ways about it. That's my two cents' worth.

11 MR. RAMIREZ: Okay. Is there -- can

12 we make any type of agreement on the U values

13 or prescriptive paths without knowing the

14 zones? Or is that something that can be

15 agreed to independently? 

16 MR. UNGAR: We could at least get

17 notional. I mean, there might be fine

18 gradations of how you translate from one set

19 of zones to the other. But we could at least

20 discuss whether we're basically okay with the

21 set of U values for the IECC zone. The

22 assumption we'll translate that if we don't. 
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1 MR. HAGERMAN: So, I have just a

2 housekeeping question for everybody. Would it

3 be helpful if we kind of took the public

4 comment right now and try to finish up? It's

5 4 o'clock already. 

6 Let Matthew go do all the work that

7 he needs to do and just send us out PDFs maybe

8 like in an hour from now with everything that

9 you're asking for.

10 And then come back tomorrow morning

11 bright and early and restart the discussion?

12 I just worry that if we move

13 immediately to the new tables that Matthew is

14 going to present we're not going to really get

15 anywhere in the next hour. But we'd probably

16 get a long way if we start going over it

17 tomorrow morning.

18 Does that sound sort of agreeable to

19 everybody?

20 MR. LUTER: This is Rob at Lippert. 

21 Joe, we had some introductory comments this

22 morning that kind of chided us on not being
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1 further along, about being handed a

2 methodology on a silver platter, and concerns

3 that we aren't going to get this done in time.

4 I'd like to suggest that we perhaps

5 move off of this topic and do something else

6 so we can be productive for the remaining hour

7 of the scheduled meeting time. 

8 You know, if we're really behind the

9 eight ball we don't need to leave early every

10 day.

11 MR. RAMIREZ: Do you have a

12 suggestion on where to go?

13 MR. LUTER: I do not, sir.

14 MR. EZZO: This is Mark Ezzo. I

15 liked what somebody I heard suggest. Can we

16 maybe come to consensus on the prescriptive? 

17 I mean, we've got Emanuel's page 5

18 which breaks it down prescriptive by all of

19 the IECC zones. And I realize we can't jump

20 to his page 8 where he has it lumped into

21 three zones because we don't know our climate

22 zones yet. 
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1 But can't we agree on page 5 that

2 that looks like an agreeable prescriptive

3 path? And then figure out tomorrow how we

4 want to draw the boundaries.

5 MR. RAMIREZ: Eric?

6 MR. LACEY: Other than the SHGC,

7 yes, that's kind of an open question for me. 

8 Because the glazing SHGC, I mean, from my

9 perspective everything else in there looks

10 like a decent compromise.

11 MR. RAMIREZ: How does it look to

12 everyone else? Again with the exception of

13 the glazing. Mark?

14 MR. EZZO: This is Mark. Go ahead,

15 I'm sorry.

16 MR. WEISS: No, let Mark.

17 MR. RAMIREZ: Go ahead, Mark.

18 MR. EZZO: I was going to say this

19 is a big chunk of work here. And it's a huge

20 part of the term paper. 

21 And so I think if we can get beyond

22 this, or at least get some kind of general
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1 tentative consensus on it I think we're going

2 to make a whole lot of headway into coming to

3 where we need to be.

4 MR. RAMIREZ: Do you want to check

5 the level of consensus on this? Setting aside

6 the SHGC numbers.

7 MR. EZZO: I would, yes.

8 MR. RAMIREZ: Mark?

9 MR. WEISS: What's the question? 

10 What's the consensus on? This is separate

11 from cost?

12 MR. RAMIREZ: Yes, that these are

13 the prescriptive --

14 MR. WEISS: These values.

15 MR. UNGAR: The standards would be

16 based on these values.

17 MR. WEISS: These values. Separated

18 from cost. Related to each.

19 MR. HAGERMAN: So, Joe Hagerman. 

20 Not to interject, but Matthew is done with the

21 tables and I think we can go ahead and present

22 those if you want to see them.
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1 MR. RAMIREZ: We might be able to

2 get consensus on some of this stuff over here. 

3 And that's where we're -- we're just about to

4 gauge the level of consensus excluding SHGC on

5 the chart here. 

6 So, let me see a show of thumbs

7 excluding SHGC if these numbers are

8 acceptable. 

9 (Show of thumbs)

10 MR. RAMIREZ: And on the phone are

11 there any thumbs down?

12 MR. LUBLINER: Yes. Lubliner's

13 thumbs down unless you're going to get me my

14 climate zones here.

15 MR. RAMIREZ: No, no, I'm sorry. 

16 We're not -- this is -- so there's two columns

17 that need to be excluded then. I apologize. 

18 The climate zone column and the SHGC. We're

19 not trying to lock in the climate zones right

20 now.

21 MR. HAGERMAN: So, just to be clear. 

22 You're trying to -- you're asking for a vote
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1 on what? On the Uo values and the climate

2 zones? That column that says --

3 MS. HOFFMAN: Not the climate zones.

4 MR. HAGERMAN: Well, the -- you're

5 asking for the Uo value column right there. 

6 And that's against the climate zones over

7 here. 

8 MR. RAMIREZ: We're looking at the

9 prescriptive numbers that are --

10 MR. HAGERMAN: And the prescriptive

11 numbers.

12 MR. RAMIREZ: The prescriptive

13 numbers that are in there. With the exception

14 of SHGC. 

15 (Simultaneous speaking) 

16 MR. ROY: -- R38 in subzone not yet

17 identified but probably 5, IECC 5.

18 MR. WEISS: I mean, I don't know how

19 much value it has. I don't think you can

20 divorce the values from the cost aspects of

21 it. I mean, I'm not going to vote no, but I

22 just don't know how much value it has.
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1 MR. HAGERMAN: What Matthew has is

2 this whole table with the cost data, right? 

3 And so whether we vote for it here, or we

4 switched over and look at his chart real quick

5 and vote for it, it'll be voting on the same

6 thing, you'll just have a little bit more

7 comfort because you can see the cost numbers

8 over the 10-year. Which is not LCC, but it's

9 the 10-year look.

10 MR. WEISS: He's got the LCC too,

11 doesn't he?

12 MR. HAGERMAN: Yes, he has LCC too.

13 That's the -- what he's hiding right

14 now is just the solar heat gain coefficient

15 added numbers which turned a few -- obviously

16 a few of the climate zones negative because we

17 don't take into account the energy impacts. 

18 MS. DICKENS: This is Ishbel Dickens

19 from NMHOA What does the column "Down Payment

20 and Fees" refer to?

21 MR. WALKER: So, the down payment

22 and fees refers to the 20 percent down payment
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1 on a mobile home -- or on the manufactured

2 house. And the financing data associated with

3 establishing that loan which I think are

4 assumed at 1 percent.

5 MS. DICKENS: Okay, will this take

6 into account whether it's a chattel loan or

7 ARM mortgage?

8 MR. WALKER: That is correct because

9 the down payment on both of those types is 20

10 percent and the fees are assumed to be the

11 same.

12 MR. ROY: What does column AK refer

13 to?

14 MR. WALKER: Column AK is the total

15 cost of purchasing this home over the 10-year

16 period. So, it's the down payment and fees

17 plus 10 years of mortgage payments discounted

18 to the future including the residual resale

19 value that you get when you sell the home on

20 the 10th year.

21 MR. UNGAR: So for lifecycle cost

22 would be column AK plus either KI or AJ,
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1 whichever way you're doing it.

2 MR. WALKER: Right.

3 MR. UNGAR: I'm sorry, your 10-year

4 costs. So it would be the 10-year cost, this

5 10-year total "lifecycle" would be AI plus AK. 

6 Is that? 

7 No, that's obviously not true. No,

8 AI must be the total lifecycle number. 

9 MR. WALKER: Sorry. So it already

10 includes AK.

11 MR. ROY: This is Robin. When you

12 asked for the home cost.

13 MR. WALKER: I don't remember

14 exactly. 

15 MR. ROY: I really meant just the

16 purchase price. The incremental purchase

17 price, not the total cost of putting energy

18 plus buying the home over 10 years.

19 Is that the purchase price increase?

20 MR. WALKER: Do you want me to just

21 give you that number too?

22 MR. ROY: It's not helpful. I want
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1 to know how much they pay, not how much they

2 save after 10 years.

3 (Simultaneous speaking) 

4 MR. HAGERMAN: I think he just wants

5 the up-front cost. 

6 MR. ROY: How much more are we

7 asking somebody to pay right now.

8 MR. HAGERMAN: Ten-year cost of

9 ownership, 30-year.

10 MR. WALKER: So year zero is down

11 payment and fees is what they have to put down

12 on the table. 

13 I'm going to pull out the total

14 incremental cost of those energy efficiency

15 components. 

16 MR. UNGAR: The down payment and

17 fees you said was a total of 21 percent of the

18 initial cost. So, multiply it by four point

19 something, you'll get the total incremental

20 cost.

21 MR. WALKER: I'll try not to make

22 any assumptions. There's enough space for
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1 that. So this is total incremental heating

2 cost. 

3 Let me just make sure that I pulled

4 off the single section price. I did, okay. 

5 MR. ROY: So that's the part that

6 we're asking somebody to swallow in order to

7 get some savings.

8 For example, in Miami, we're asking

9 somebody in Miami just spend $2,300 more up

10 front, however they finance it, and after 10

11 years they would have recovered all but $51 of

12 it. They'd be negative by $51.

13 MR. HAGERMAN: That's correct, but

14 we haven't factored in the reduction credit to

15 sizing. So let's just keep that in mind.

16 MR. EZZO: That's right. They would

17 save about $500 on the air conditioner size.

18 MR. HAGERMAN: Right. They'd save

19 some money.

20 MR. EZZO: An order of magnitude

21 more than the $51 savings. Deficit.

22 MR. LUBLINER: This is Mike
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1 Lubliner. I had one other comment I'd like to

2 make.

3 And that's we had noted that a large

4 percentage of people buy with cash. And I

5 don't see -- I know that Stacy's group was

6 going to look into that. But I don't see any

7 attempt here to factor in cash purchases into

8 this analysis.

9 So, I think that because the cash

10 purchases aren't factored in, and because

11 we're not taking credit for the downsized

12 heating equipment as a result of the higher

13 efficiency measures that we're looking real

14 good.

15 MR. RAMIREZ: Mark, you had a

16 question?

17 MR. WEISS: Yes, the EEM cost they

18 just put up, that's based on the information

19 that Emanuel came up with?

20 MR. WALKER: Correct.

21 MR. HAGERMAN: If you remember our

22 previous conversation there were some measures
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1 in that package that we thought that the

2 number was conservative, right? Like the air

3 ceiling, the duct ceilings. We didn't change

4 those numbers. So there was -- we took the

5 higher of those numbers. I think that's

6 pretty conservative.

7 MR. LUBLINER: I thought we agreed

8 to get rid of the duct ceiling costs. They're

9 still in there is what you're saying, Joe?

10 MR. HAGERMAN: I believe they're

11 still in there. Yes, they're still in there. 

12 So these costs are conservative.

13 MR. LUBLINER: So, there's duct

14 ceiling costs as well which make it even more

15 conservative. And then we value engineer the

16 testing for the envelope out of this.

17 I mean, I don't know, we've bent

18 over backwards to make all these first-cost

19 adjustments. And I'm concerned that the

20 consumer who has cash that wants to buy a home

21 off a lot is not getting the full benefit of

22 this exercise.
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1 MR. HAGERMAN: Mark, you had a

2 question?

3 MR. WEISS: A comment. And

4 actually, as I indicated last week I think

5 there are at least two reasons why the first

6 cost might be underestimated.

7 And that is because particularly

8 smaller manufacturers purchasing supplies in

9 smaller volume, they're not going to get the

10 level of discounts and considerations that

11 larger manufacturers would.

12 Also, as I mentioned last time this

13 number necessarily reflects only cost labor

14 and retail market. It does not reflect

15 enforcement and testing cost, regulatory

16 compliance costs that are also part of the

17 overall impact on the consumer.

18 So, therefore I think that the

19 numbers are probably understated to some

20 degree.

21 MR. RAMIREZ: Any other questions or

22 comments on this? 
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1 MR. LUBLINER: This is Mike Lubliner

2 one more time. I'm sorry.

3 I do also believe that you're able

4 to achieve an R38 in the ceiling without the

5 cost that Emanuel's put in for higher trusses. 

6 And so again, the adjustments that

7 Emanuel made to the ceiling were based on

8 costs that I'm having some issues thinking

9 that this is probably not a cost that's going

10 to be incurred very often. Maybe for a few

11 designs, but very often it's not going to be

12 incurred. And it's driving everything.

13 I'm more than open to exploring a

14 dual Uo value or something for single-section

15 homes to deal with affordability.

16 I'll make the case that if somebody

17 can afford a multi-section home and they can

18 afford the setup, the additional thousands of

19 dollars in setup of the multi-section home,

20 that maybe they are not that type of consumer. 

21 And that really maybe we should be

22 working on -- if we try to give something,
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1 maybe it's the single-section homes where we

2 can give a little.

3 But everything that Mark says is

4 right. There's things that we haven't

5 considered on the other side. 

6 I'm just worried about the things

7 that I think aren't being considered. And I'm

8 going to continue to point them out. That's

9 why I have some discomfort.

10 I do think that the lifecycle cost

11 analysis here is really positive for

12 everything. And I think it would be whether

13 we used the IECC or Emanuel's modification of

14 the IECC. Thank you.

15 MR. HAGERMAN: So just one other

16 statement on the cost. 

17 MR. WADE: This is Michael Wade.

18 MR. HAGERMAN: Michael Wade, you go

19 first.

20 MR. WADE: Thank you, Joe. I've got

21 a question for Lubliner.

22 On the $500 that you're talking
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1 about for tonnage, are you talking about on a

2 heat pump or are you talking about an air

3 conditioning system?

4 MR. LUBLINER: Heat pump and an air

5 conditioner are virtually the same thing, just

6 a reversing valve. 

7 MR. WADE: That's correct.

8 MR. LUBLINER: So, basically, Mike,

9 what I'm thinking is probably if you look at

10 those sizing tables that will be these data

11 for your industry, the little cards that show

12 sizing.

13 MR. WADE: Correct.

14 MR. LUBLINER: And you go down those

15 tables, I think it gives you a half a ton

16 credit for low-E windows, right?

17 MR. WADE: I believe you're correct.

18 MR. LUBLINER: And then I'm saying

19 that with all the other measures that you're

20 improving on the home, the insulation and --

21 that you're going to end up with something

22 higher than that. 
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1 So I would suspect it's at least at

2 a minimum a half a ton of credits which is

3 probably $400 if you did some sort of a means

4 calculation, or you talked to people, HVAC

5 guys.

6 And then there's going to maybe be

7 another half a ton on the other. So we're

8 talking about -- when I talked to the HVAC

9 guy, he said boy, you're sizing these things

10 at thousands -- at 500 per and it should be

11 1,000. So in other words, we're over-sizing

12 them now but we're not getting credit for it. 

13 And I don't worry about doing it

14 now. But I do think it's legitimate that if

15 somebody is buying this efficient home, their

16 heating contractor is going to -- if they do

17 size it correctly and we get the sizing right

18 it's going to save a half a ton to a ton.

19 And that's a cost that I think is

20 real and should be considered. I know that

21 when we do the Building America program, it's

22 gospel. You reduce the shell and that affords
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1 you the ability to pay for more conservation. 

2 And that's what the client wants,

3 it's the package. They don't care about the

4 individual things.

5 Ignoring the HVAC savings, and I

6 would like to see the analysis done with at

7 least $400 of HVAC savings --

8 MR. HAGERMAN: So, just real quick,

9 just so we can move along a little bit. I

10 think all we need to see is $51, right, to

11 make the one red positive.

12 So, again, Mike, I sort of agree

13 with you but I think we're really, really

14 close here with everybody.

15 Let me just say one thing about

16 Mark. Mark did bring up a good question about

17 the cost. 

18 And when we took receipt of the cost

19 Mark asked Navigant just to do some quick spot

20 checks with publicly available data so they

21 pulled up the RSMeans. And we compared the

22 costs that were submitted in some areas -- not
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1 across the whole table, but just some random

2 areas -- to retail costs that are published

3 annually by the RSMeans company. Is that a

4 company, I guess? Whoever RSMeans is.

5 And the numbers that were reported

6 were consistently 15 to 20 percent lower in

7 all the categories that we pulled from from

8 the retail costs.

9 So, we felt pretty comfortable that

10 it represents an average of the industry. We

11 didn't see anything kind of glaring there.

12 Now, if it came back half retail or

13 even more than that, then I think we would

14 have some problems. Or if it came back more

15 than retail. So we feel like that's a good

16 kind of average of the whole industry.

17 But if your members, if your small

18 manufacturers can provide us cost data, or

19 review the cost data that was submitted we'd

20 be happy to hear from them.

21 So, I guess the question is now, I

22 mean now that we have this data up here, can
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1 we kind of do a vote on the Uo values and the

2 climate zones that are presented here? Which

3 I think are similar to the ones that are on

4 page 5.

5 MR. RAMIREZ: They are, aren't they?

6 MR. HAGERMAN: They should be.

7 MR. RAMIREZ: Yes.

8 MR. HAGERMAN: Page 5 averages them. 

9 So the page 5 only has basically seven zones

10 and here there's a lot more zones. Because we

11 go to 1A, 2A, 2B, 3A, 3B, 3C. So there's

12 obviously, there's some averaging here. 

13 MR. WALKER: They're somewhat

14 different numbers. Let me speak to that. The

15 Uo values that are here on the table on the

16 screen are what PNNL calculated based on the

17 runs they did. 

18 It does seem to diverge by a few

19 decimal places from what Emanuel had

20 calculated.

21 MR. ROY: I'm looking at -- the

22 single? The single for IECC 5, 0.059. What
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1 happened? That's an 8 percent difference

2 maybe? 0.063 to 0.059.

3 MR. WALKER: And 6 is the same.

4 MR. ROY: They seem really

5 different.

6 MR. WALKER: Yes. Zone 6 is the

7 same as 5 for Emanuel's calculation. 

8 MR. UNGAR: Is this -- are these

9 supposed to be for revision 2?

10 MR. WALKER: These are for revision

11 2. I mean, some of the differences, it's a

12 little bit hard for me to estimate but it

13 could be different assumptions in framing, or

14 door U values. 

15 I mean, one thing I can do here is I

16 can plug in the numbers that Emanuel put

17 together. I think we could -- and then I'll

18 figure out why there are differences. And

19 we'll have to talk to Emanuel also.

20 MR. HAGERMAN: We're just looking at

21 the raw data. We're looking at the same raw

22 data. So we don't understand the
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1 discrepancies either.

2 MR. WALKER: And I'm looking --

3 (Simultaneous speaking) 

4 MR. ROY: -- manufacturers just have

5 a sense of why it seems to have such different

6 U values which is -- but I understand what

7 you've got here. This is all readable when

8 it's all broken out. Because this I get.

9 MS. HOFFMAN: So, you're going to

10 speak to Emanuel and reconcile figures?

11 MR. HAGERMAN: It's just a

12 different. Like zone 4 is different here. 

13 It's more aggressive on that sheet. Salem is

14 0.0063. Here it's 0.0067. There seems to be

15 some discrepancies.

16 MR. RAMIREZ: Could it be that

17 they're in different areas of the zones and

18 maybe fuel costs? Could it be things like

19 that?

20 MR. EZZO: There's an IECC exception

21 in marine climates for zone 5 and 4 that might

22 be the problem. There's a 5 except marine and
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1 then there's a -- so that might be where the

2 discrepancy is. It gets back to the map. 

3 MR. HAGERMAN: Emanuel, do you have

4 any ideas?

5 MR. LEVY: I'd just be guessing. It

6 could be the windows because we assumed a

7 fairly constant U value for the window. I'm

8 not sure what PNNL did.

9 But I'm just guessing. It won't

10 take that long to figure out the difference.

11 MR. RAMIREZ: So, it sounds like we

12 need to know what those differences are before

13 we actually pull the trigger on it. 

14 And is that something that we could

15 have for tomorrow morning?

16 MR. WALKER: We'll initiate the

17 question. There's potential. 

18 MR. HAGERMAN: We're cautiously

19 optimistic that there will be an answer

20 tomorrow morning.

21 MS. HOFFMAN: Okay.

22 MR. HAGERMAN: I did get an answer
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1 about the Manual J, which we can cover that in

2 a second. But let's finish this up first.

3 MR. RAMIREZ: Well, what else do we

4 need to know on this thing?

5 MR. WALKER: There is the SHGC item

6 that Eric had asked about. Are we ready to

7 look at that?

8 MR. RAMIREZ: Sure.

9 MR. WALKER: Okay. 

10 MR. RAMIREZ: Unless we're going to

11 have -- I don't know if we're going to have

12 costing numbers on that.

13 MR. HAGERMAN: Well, we have cost

14 numbers of energy impact numbers. But you can

15 see the costing numbers.

16 MR. LUBLINER: This is Mike

17 Lubliner. So am I clear in understanding that

18 we are not going to be looking at cash

19 purchases as part of the analysis, nor are we

20 going to be looking at the savings from the

21 downsizing of the HVAC system analysis?

22 Nor are we going to be looking at
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1 30-year cost of home ownership, just the

2 10-year that we're going to be looking at.

3 Am I correct that we're not going to

4 look at any of these variables?

5 MR. UNGAR: All right. So, for -- I

6 mean it looks a little bit -- for cash I think

7 it makes very little difference unless you

8 assume depending on what discount rate you

9 assume.

10 Right now the discount rate is

11 assumed to be the same as the interest rate. 

12 And so cash if you take a blended value of the

13 discount rates will look very similar to these

14 analyses. 

15 Three-year we have so people can

16 look at it. And downsizing is not included. 

17 And again, people it seems to me -- I mean,

18 we're told that it's some hundreds of dollars

19 that should be for downsizing that will

20 adjust. I guess it's a question of which

21 zones it would apply to.

22 But again it's not clear. I haven't
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1 heard anybody say that their vote yet up or

2 down on the standard depends on the LCC

3 analysis. 

4 If that $51 makes a difference we

5 could discuss all these factors. But it's not

6 clear to me whether it does.

7 MR. RAMIREZ: I mean that -- I don't

8 know if it -- I don't see how it really would,

9 right? I mean, if everything but the one is

10 in the black, and knowing that there is give

11 or take a little bit here on these numbers, is

12 that a big enough discrepancy that's going to

13 derail this?

14 MR. HAGERMAN: That's the point why

15 I wanted to go ahead and factor in the cost of

16 the solar heat gain coefficients. Is because

17 the zones that are already in the black,

18 they're going to stay in the black. And the

19 zone that's in the red is just going to stay

20 in the red, right?

21 But in the best professional

22 judgment the one zone that would benefit the
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1 most from it would be the zone that's in the

2 red. So you would assume the savings. So you

3 can assume that you're going to get some

4 return on that money.

5 And then take in addition the sizing

6 credit that's not factored in here. You know,

7 in my professional judgment that's going to

8 turn to black. I think that's a reasonable

9 assumption to make, right? 

10 But there's other engineers in the

11 room. They could speak to that too.

12 MR. LUBLINER: I agree with Joe. 

13 COURT REPORTER: I'm sorry, who was

14 that?

15 MR. HAGERMAN: That's Lubliner,

16 Michael Lubliner. 

17 MR. LUBLINER: I believe that Joe is

18 right, it's a reasonable engineering

19 assumption to make.

20 MR. RAMIREZ: Lowell?

21 MR. UNGAR: This is Lowell. And the

22 other one that would make a difference is if
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1 Mike is right that you can get R38 insulation

2 without changing the truss, that would mean

3 that for those -- particularly in zone 4 where

4 the ceiling insulation was dialed back

5 actually below IECC 2006 levels that there

6 would be no reason, you know, you wouldn't

7 need to -- you would no longer justify pushing

8 that back.

9 I don't know whether that's -- this

10 is a technical question. I don't know whether

11 there's an easy way of resolving it or not. 

12 But it may, you know, I guess I can

13 live probably with it if we're really talking

14 about the ceiling insulation in one zone. But

15 it is tough to swallow.

16 MR. HAGERMAN: Well, let's remember

17 though that the reduction in the insulation

18 had a very minimal impact on the annual energy

19 consumption, but a huge impact on the cost,

20 right? So it was more of a cost increase than

21 any energy impact. 

22 MR. UNGAR: Yes, because if Mike is
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1 right then you wouldn't have a large -- it

2 would be a small cost increase rather than --

3 MR. HAGERMAN: But you'd still have

4 small energy impact. So it's like, you know,

5 is it worth it, right?

6 MR. UNGAR: Yes. You know.

7 MR. HAGERMAN: I think if anything

8 the flip side of saying that is you could say,

9 well, the costs are maybe overstated for the

10 roof insulation, right?

11 So, again, the numbers that are

12 black here, you'd believe that you'd be a

13 little bit more positive in the black.

14 MR. RAMIREZ: Let's get Lois and

15 David.

16 MS. STARKEY: I just -- on the roof

17 truss issue. I just think we need to take

18 sort of, you know, we did a lot of work to get

19 some real data and some real numbers from at

20 least a few manufacturers. And I think we

21 should take that. 

22 I mean, we're not looking at
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1 theoreticals. We're not looking at, well,

2 this is what a couple of manufacturers in the

3 Northwest do. 

4 I mean, I just -- I think we need to

5 stick with the assumptions about what you need

6 to do to put R38 in the ceiling.

7 MR. HAGERMAN: Agreed. And when you

8 do look at -- everything is black when we do,

9 right?

10 MS. STARKEY: Yes. Exactly.

11 MR. TOMPOS: My comment was along

12 the same lines. I mean, we're assuming

13 everybody is using a 5.5 inch truss heel. We

14 still have manufacturers using a 3.5 inch

15 truss heel. So there is going to be some

16 change to those trusses.

17 MR. LUBLINER: A good thing to have,

18 right?

19 MR. TOMPOS: No, it could also be

20 for the 4 inch.

21 MR. LUBLINER: Not for the --

22 MR. UNGAR: The baseline here is
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1 2.5.

2 MR. LUBLINER: This is my

3 understanding and then I'll shut up. The

4 majority of the trusses in the United States

5 have a 5.5 inch heel. Technically, if you

6 have a 5.5 inch heel you can get R38 without

7 changing the truss. Am I wrong on those two

8 assertions?

9 MR. EZZO: Yes, you are.

10 (Laughter)

11 MR. MENDLEN: We don't have specific

12 data about various trusses. I think that that

13 would be an NTA, a larger step, actually.

14 But there's a variety of truss size

15 that go from probably a 2.5 inch heel up to

16 7.5 inch. What the average is I couldn't tell

17 you.

18 MR. HAGERMAN: So just real quick, I

19 don't think it really changes the numbers

20 though. I mean the numbers are the numbers. 

21 They're still going to be positive, right?

22 MR. TOMPOS: That was my point. I
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1 don't know why we're arguing a whole side of

2 this. Let's forget about the trusses.

3 MR. GALLAGHER: In terms of time

4 it's almost, what is it, 4:30. I think we

5 have a public comment period.

6 MR. HAGERMAN: Well, let's just go

7 ahead and tee up what we're going to see

8 tomorrow. 

9 I think we're close to getting a

10 vote on this if we just can double-check the

11 U values to make sure there's not some

12 translation issues. And so we can hopefully

13 get that settled between now and tomorrow

14 morning. 

15 So hopefully we can show you the

16 same chart tomorrow morning first thing with

17 the updated Uo values. And then I'd hope that

18 we could take a vote on it. Is that?

19 MS. STARKEY: On the prescriptive

20 path.

21 MR. HAGERMAN: On the performance

22 path. Uo.
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1 MR. RAMIREZ: And we might even have

2 the SHGC numbers in there, correct? 

3 MR. HAGERMAN: We're not going to

4 have the energy runs by tomorrow.

5 MR. TOMPOS: Were the U values the

6 ones that matched?

7 MR. HAGERMAN: That's what we have

8 to understand. We have to understand why

9 there's a discrepancy.

10 MS. HOFFMAN: They're going to

11 reconcile that. So maps tomorrow?

12 MR. HAGERMAN: Right. And then

13 we'll hopefully get maps tomorrow. Matthew's

14 going to have a busy night.

15 MS. HOFFMAN: Yes.

16 MR. RAMIREZ: Okay, so then we'll do

17 that. And then we'll see if there's any

18 additional committee reports.

19 And we won't be able to take action

20 on the climate zones because we're going to

21 have -- you need some time to talk to your

22 clients on that, right?
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1 MR. LACEY: One more issue to throw

2 out there. Brace yourselves. We're talking

3 about two compliance options - a prescriptive

4 path and a Uo performance path.

5 Do we want to explore a simplified,

6 like a Ua path that we'd plug into REScheck? 

7 Or are we just going to allow the Uo

8 to kind of be the starting assumptions for a

9 Ua calculation? Does that make sense?

10 A prescriptive path in the IECC has

11 very limited, you know, tradeoff capabilities. 

12 Now, if you set your prescriptive

13 levels someplace that everybody can agree on

14 then that's fine.

15 But if you wanted a little more

16 flexibility here and there without doing a

17 full-blown performance path there are some

18 means of trading those off. 

19 We don't have to decide right now. 

20 I just thought I would put it out there.

21 MS. HOFFMAN: Put it out on the

22 table.
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1 MR. LACEY: Yes, think about it over

2 night. If you want another compliance option

3 -- we already had that discussion earlier. We

4 were only talking about the two. 

5 MR. RAMIREZ: We have that on there

6 for compliance.

7 MS. HOFFMAN: And would you be ready

8 to address it in greater detail?

9 MR. LACEY: Yes. I don't know if we

10 need one, I just wanted to throw that out.

11 MS. HOFFMAN: Just so everyone knows.

12 MR. HAGERMAN: Let's also tomorrow,

13 let's go through the list of the other items

14 that the group wants to present to ASRAC. 

15 It's outside the term sheets. Because I'm

16 afraid that we're going to lose some of those.

17 And if memory serves me, the most

18 important one to the group is the continuing

19 this committee hopefully in the New Year,

20 hopefully not two weeks from now, to discuss

21 compliance and enforcement, right? Because I

22 think you want that recommendation. 
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1 And we've heard a couple of times

2 people saying that they used the REScheck. 

3 And so if there's a recommendation that the

4 Department needs to modify REScheck to make it

5 easier for the manufactured housing or to

6 address manufactured housing we'd be happy to

7 put that in for a recommendation too. 

8 So whatever you can think about that

9 needs to go in those recommendations we should

10 at least start capturing those because they

11 need to be part of the term sheet, or an

12 appendix to the term sheet.

13 MS. HOFFMAN: Tomorrow we'll also

14 talk about logistics for the next meeting

15 because it's not for a year. It will be in

16 Colorado.

17 MR. HAGERMAN: If we need it, right?

18 MS. HOFFMAN: If we need it, right.

19 MR. HAGERMAN: So far it sounds like

20 we're going to need it because you're not

21 going to have consensus on the climate zones. 

22 MR. LUTER: For those of us that
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1 already have tickets let's hope we need it.

2 MS. HOFFMAN: Well Rob, if we left

3 out earlier we would definitely need it.

4 MR. HAGERMAN: Yes, Rob.

5 MS. HOFFMAN: I'm teasing.

6 MR. LUTER: My bad.

7 (Laughter)

8 MR. RAMIREZ: Public comment.

9 MR. MENDLEN: I'll make a comment. 

10 The first one is, Joe, I would caution you to

11 remove natural infiltration from the

12 evaluations that Dave's committees got to deal

13 with on fan efficacy and ventilation. 

14 Simply because there are variations

15 between when you test a factory versus when

16 you test a site because the home has been

17 transported and some of the stiffness has come

18 out of the unit when it's -- and you go

19 through the setup process also that removes

20 additional stiffness.

21 So there really -- in all the

22 different conditions that you have to test in
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Neal R. Gross and Co., Inc.

1 to make sure that you've got proper

2 assumptions for natural air infiltration.

3 So my suggestion to you if you

4 really want to get through this by the 23rd or

5 24th is to remove that part, give Dave a break

6 and his committee a break and just have them

7 focus on the fan efficacy.

8 MR. HAGERMAN: I've got high hopes

9 for David's group to solve it all. So we

10 won't have to solve it.

11 MR. MENDLEN: Because I think if you

12 wait for that you'll miss your deadline.

13 I guess I can echo what several

14 others have said today also about needing to

15 balance cost-effectiveness with the energy

16 improvements versus affordability. 

17 We have to obviously under our

18 statute deal primarily with affordability as

19 well as balancing that against all the various

20 safety, durability and quality issues that go

21 along with our statute as well.

22 So I just remind you that that's
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Neal R. Gross and Co., Inc.

1 going to be important when it gets to HUD

2 eventually. 

3 And then again I've made this

4 statement. Now Rob's finally here so I can

5 make it to him.

6 By uniformity, you've heard that

7 before today as well. If you decide to go

8 single-wide, multiple-wide, don't have two

9 levels because it's going to complicate

10 enforcement dramatically.

11 You've already heard that adding

12 just one level for each of the three zones, or

13 for four zones, or how many zones you work out

14 of is better and will avoid I think

15 significant enforcement problems in the

16 future. That's my comment for today. Thank

17 you.

18 MR. RAMIREZ: Okay. Any other

19 workgroup comments? 

20 MR. LUBLINER: This is Mike Lubliner. 

21 I just had a quick question. Are you speaking

22 as HUD or are you speaking as an individual?
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1 MR. MENDLEN: On that last point, on

2 enforcement I'm speaking for HUD. 

3 MR. LUBLINER: Thank you.

4 MR. MENDLEN: And I'm also -- I

5 think I'm speaking for all those individuals. 

6 I'm not here as an individual. I'm here

7 representing HUD.

8 MR. RAMIREZ: Then we'll see you all

9 tomorrow at 9 o'clock. 

10 MR. HAGERMAN: Same place tomorrow. 

11 I appreciate all your all's hard work and your

12 time and your comments. This has been very

13 helpful, this whole endeavor and I think that

14 I feel like we're really close. 

15 I look up at that chart and even

16 when we factor in the stuff that we can't

17 really account for a lot of it's black, or

18 most of it's black. 

19 MS. HOFFMAN: Okay, well have a good

20 evening, really. See you tomorrow.

21 (Whereupon, the above-entitled

22 matter went off the record at 4:36 p.m.)
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believe 14:7 19:20

19:21 36:6 47:20

69:20 82:22 83:20

85:2 122:9 179:17

198:21 202:14

304:15 306:16

313:18 337:10

339:3 341:17

352:17 354:12

bellies 62:22

belly 19:10,13 22:6

23:6,14 26:6 27:2

27:9,19 40:13,16

41:20 49:19 50:6

61:3,10,12 62:17

62:22 65:13

belongs 118:18

beneficial 250:4

benefit 55:21 56:5

132:16 168:14,15

170:20 201:17

267:22 280:11

337:21 351:22

benefits 168:4

254:6 307:6 308:7

bent 337:17

Bert 1:22 32:14,16

33:2 44:4 45:3

49:3 125:20 159:5

159:7 222:8,9

223:9 225:1,2

best 11:5 136:6,22

137:1 170:12,14

179:7 226:17

253:2 323:22

351:21

better 8:10,13 44:7

82:19 83:7 84:4,9

98:14,17 100:6

102:4 119:21

165:10 256:9,14

258:17 268:19

269:4 279:3 289:2

289:3,8 292:15

364:14

beyond 11:2

130:10 162:2

199:7 208:2

327:21

big 107:11 113:2

164:4 177:6

179:22 187:21

188:12 190:17

192:14 233:17

239:17 267:6

286:13,14 294:20

308:20 327:19

351:12

bigger 48:16 113:8

biggest 202:12

billing 87:15 257:6

bills 220:18 258:12

binding 36:5

Bismarck 166:14

bit 11:6 15:14

16:16 20:5 25:18

48:2 68:4 74:21

77:11 82:13 118:2

130:4,5 131:1

135:16 139:18

144:6 147:22

148:7 150:6 152:4

159:15 167:10

168:18,20 178:3

209:22 216:17

217:5 218:10

221:4 222:7 224:5

224:22 230:17

231:13 249:12,21

267:15 273:11,11

274:7 276:5

277:13 290:10

300:22 312:9

331:6 343:9

346:12 350:6

351:11 354:13

bitterest 165:6

black 148:18 175:2

175:4,5,6 187:11

250:1 273:11

287:6 351:10,17

351:18 352:8

354:12,13 355:8

365:17,18

blacks 185:5

blanket 19:10

27:20 53:6 59:7

59:12 60:5 228:4

blended 350:12

blow 191:5,7

192:12

blowing 192:9

196:14

blown 49:21 225:13

blows 192:6

blush 215:14

board 13:11 17:8

18:5,13,19 19:21

20:1 21:1 22:6

25:5,6,10 27:2

29:9,12 30:1,10

40:16 41:20 55:1

61:10,12

boards 29:17

Bob's 245:18

bogged 186:4

207:16

bold 146:18

book 16:11 294:15

boots 69:10

border 277:21

286:19

borrow 202:10

bottom 17:1,8 18:5

18:13,19 19:21

20:1 21:1 24:20

25:5,6,10 29:9,12

29:16 30:1,10

55:1 133:1 152:8

164:20 187:11

237:18 306:14

bound 294:16

boundaries 19:22

289:16,22 290:5

293:21 294:14,16

294:17 295:8

298:10,16,18

299:4,17 300:6

305:7 308:4

311:11 323:16

327:4

boundary 275:20

298:2

box 68:15,20,21

149:21 187:11,11

boxes 68:18 69:1

boy 342:9

Brace 359:2

break 66:5,8,14

67:2 73:20 122:18

126:3 220:9

221:10 225:2

226:6 363:5,6

breaking 126:6

breaks 326:18

bridge 244:12

bridging 65:15

brief 73:20

briefly 14:5

bright 325:11

bring 107:21,22

112:12 154:12

162:18,21 254:5

343:16

bringing 116:1

brings 198:4

broaden 260:16

broadly 130:10

broken 347:8

brought 50:14

216:10 239:18

brown 147:12,14

147:22

brush 308:22

BTA 81:9

BTUs 115:4,7,8,9

125:4

buck 135:2 137:1

267:8 268:10

build 116:7 194:12

194:13,14,17

305:1

Builders 2:9 6:3

building 2:2 23:18

87:17,19 100:2

111:17 178:10

194:17,18 195:16

195:20 217:15

248:4,8,15 292:18

303:19 304:20

305:16 342:21

buildings 116:13

202:3

built 25:1 48:15

72:8 101:13

208:10 212:1

223:13 247:3

257:4

bulb 82:6

bunch 131:3

134:20 137:10

156:11 160:5

214:7 230:21

business 13:11

busy 6:14 358:14

buy 113:18 160:18

177:16 180:1,8

220:15 224:11

336:4 337:20

buyer 155:17

158:12 159:13

199:16 208:4

235:9 276:7

buyer's 156:1,8

158:4,16 199:11

199:14 200:18

buyers 155:12

158:2 208:12

235:13

buying 208:14

333:18 342:15

by-county 290:5

bypass 62:8

C

calculate 230:7

261:12

calculated 64:21

112:20 145:20

345:16,20

calculation 52:21

105:14 106:5
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calculations 113:19

121:2 131:3

143:19 213:7

271:17

California 102:18

306:18

call 22:1 29:7 34:22

35:2 43:18 51:7,7

128:12

called 53:17 132:12

152:11

calling 48:17

205:11

calls 139:22

Cameron 7:8 38:8

38:13

Canadian 277:21

cap 86:3 154:13

160:2,4,8,12,16

160:22 163:14

206:9,10,12,13,14

207:1

capabilities 359:11

capable 262:7

capacity 85:11

capricious 179:3

capture 308:17

captured 283:13

capturing 361:10

card 7:5

cards 341:11

care 102:3 112:11

143:14 270:5

273:15,17,18

343:3

careful 6:21

cares 179:6

Carolina 147:1

carrots 315:2

carve 95:8

case 32:5 40:19

82:4 99:14 117:4

121:3,5,6 124:10

134:3,3 135:9,10

164:1 169:20

170:12,14,15

181:3 192:16

194:12 195:11

230:4 235:12

236:4,7 251:18

254:15 260:21

261:11 268:14,21

274:5 300:16,18

300:19 301:18

302:19 339:16

cases 71:8 191:11

194:16 204:8

207:4,6 324:3

cash 159:12,20

161:11 180:1

189:18 190:1,2,3

244:22 245:8

304:7 336:4,7,9

337:20 349:18

350:6,12

Caskey 1:16 3:8

5:5,5 8:18,19,19

9:2 37:7,7 96:19

96:20

categories 80:18,21

81:2 344:7

category 93:3

caucus 310:21

caulk 18:9

caulking 26:4

causing 184:11

caution 263:22

362:10

cautiously 348:18

Cavalier 2:9 6:3

29:1

Cavco 2:6 6:2

15:20 24:3 40:3

45:18 55:7 94:12

102:7 110:13

121:11 239:5

304:17 319:10

caveats 131:1

cavities 54:21

57:15,19 58:16

59:4,10,18 60:12

213:8

cavity 47:15 48:6,7

48:9 49:1 58:19

59:11,17,22 60:4

60:22 63:13 65:1

ceiling 132:15

133:10 138:10,11

139:1,6 141:13

142:9 145:11

169:4 180:20

181:15,17 183:21

196:9,10 219:22

225:11 227:9,19

227:22 230:16,22

231:2,6 236:1,1,9

236:10,22 237:1

258:15 259:10

272:16 337:3,8,14

339:4,7 353:4,14

355:6

ceilings 337:3

cell 151:9

cells 46:5 235:22

237:4

center 60:4

cents 253:19 299:6

324:10

certain 64:7 132:21

134:13 167:20

189:11 192:20

certainly 45:2 97:1

97:4 105:12

131:18 155:4

166:15 251:22

252:10 256:13

265:12 268:10

293:5

cfm 79:15 83:16,17

83:18 98:18

100:22 115:17

chair 108:9

chairman 108:1

challenge 11:9

285:17 300:22

challenged 234:14

challenges 165:4,7

310:10

challenging 293:1

300:10

chance 20:5 72:22

237:9

change 20:10 32:18

36:8,14 37:8,11

61:13 81:17 85:3

90:18 97:14,15

99:22 133:20

134:4,5,21,22

135:14,15 140:7

141:17 145:10

156:17 161:4,5,6

164:11,19 165:22

166:1 169:11

175:11 176:10,14

177:1,4,14 180:17

182:5 185:3

189:13 191:22

192:4,18 194:10

196:11,15 218:19

218:21 227:12

230:7,20 233:4,9

236:9 237:5

241:15 242:6

244:18 254:1

256:17 263:1

298:16 299:4

300:2,5 305:17

308:8 337:3

355:16

changed 36:7

115:14 174:16

180:20,22 189:16

227:10 228:1

230:16 299:15

changes 67:17

171:22 191:20

193:11 227:15,17

236:17,19 237:2

296:16 356:19

changing 52:7 63:4

82:19 172:6

177:13 181:3

197:3 218:22

250:12 289:15

299:13,18 305:6

353:2 356:7

characteristic

184:10

characteristics

129:19

characterized

246:12

chart 40:9 69:21

74:6 119:20

128:13 139:11,12

244:10 246:4

272:17 282:7

329:5 331:4

357:16 365:15

charter 94:18

chassis 47:20 56:11

58:5

chatted 252:22

chattel 208:14

332:6

cheap 83:13 105:15

cheapest 201:3

cheat 220:7

check 8:8 37:17

295:22 328:4

checking 39:6

checkmarks 73:10

73:12

checks 49:12

343:20

cherry 180:6

chided 325:22

chime 79:6

choice 34:11

choose 199:21

309:21

chunk 327:19

chunks 199:5

280:15,18

circles 52:3

circulates 17:4

circulating 54:20

citation 70:13

clarification 38:17

86:12 128:10

277:3
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clarify 111:3 196:6

315:12

clarifying 57:8

class 79:16 81:7

82:11

Clayton 1:20 5:22

clean 309:7

clear 22:19 92:15

92:16,21 140:21

148:22 197:17

206:6 269:11,12

271:3 273:16

281:18 329:21

349:17 350:22

351:6

clearer 118:20

clearly 91:2 203:20

208:7 245:14

296:14

client 304:15

313:10 314:5

315:3 343:2

clients 304:3

306:22 358:22

climate 15:7 63:2

140:2,4 163:5,13

165:20 166:2,5

183:3 185:4,8

186:15 188:9,10

192:10 206:17,19

206:21 207:2

220:16 233:10,11

240:3 241:12,13

241:14 243:12

248:14 249:19

253:12,14,17

254:4 255:10,11

256:10,13 258:19

258:22 259:5

270:9,10 277:14

277:15 278:6

279:11,13 280:19

282:2 284:21

288:6,13 290:15

290:17 292:22

298:9 299:14,15

301:12 302:11

303:9,11,12 304:2

304:13 306:19

309:4,11 311:22

312:13 313:20

317:5 319:1

326:21 329:14,18

329:19 330:1,3,6

331:16 345:2

358:20 361:21

climates 169:16

172:20,22 233:13

347:21

close 207:10,14

272:19 287:10,10

290:11 343:14

357:9 365:14

closer 86:20 175:2

221:5

closure 28:19 33:11

62:17

closures 185:18

clustered 312:16

co-facilitators 6:16

Coast 297:17

code 35:1 36:1,2

38:2 61:13 62:10

64:4 70:18 75:8,8

78:10 79:18 83:15

83:16 89:17,19

94:1,2 98:11

99:17 102:18

106:8 109:5

110:10 111:4

114:3,7 115:3

120:11 121:22

123:5 187:19

195:16 204:9,12

222:13 226:21

227:7 228:8,10,14

228:20 229:8,20

230:10,12 235:4

268:5 284:21

289:16,17 298:10

308:14 309:13

310:1 322:16

codes 2:1 4:15

84:18,18 87:7

159:12 178:8

codify 12:18

coefficient 213:10

256:9,15 264:12

264:15,22 265:3,6

267:20 268:9,20

269:5 331:14

coefficients 250:12

261:21 351:16

cohere 147:5

coherence 146:10

coldest 165:6

306:18

collateral 88:9

colleague 4:7

collected 10:7

109:16

color 308:13

316:13,14,14

318:16

color-coded 316:4

Colorado 361:16

colored 316:11

colorize 321:7

colors 316:7 318:9

318:11

column 16:22 86:5

86:15,18 133:14

134:2 136:9,10

145:19 148:9,11

148:14 170:2

188:5,6 211:12

227:12 229:13

234:19 236:15

237:13 244:21,22

245:2 286:7 287:5

329:18 330:2,5

331:19 332:12,14

332:22

columns 135:4,4

149:17 151:18

226:19,20 259:16

329:16

combed 244:17

combination

211:21 212:19

282:4

combine 245:12

combined 241:7

285:1,2 291:17

combining 285:12

295:6 296:2

303:18 316:5,5,6

come 12:11 13:18

15:18 26:15 66:15

77:6 91:9 96:15

97:22 99:10 103:2

103:12 111:19

113:1 115:17

122:7 125:2 126:4

126:16 128:9

129:14 132:7

137:14,15 138:1

146:1 149:9

153:21 154:10,20

154:21,22 157:16

158:7 159:19

163:14 171:13,18

186:22 189:15

211:16,18 215:21

216:12 224:3

243:13 244:7

250:3 252:18

257:21 276:17

277:8 280:10

325:10 326:16

362:17

comes 17:7 40:17

45:11 50:4 53:20

153:19 189:20

192:11 196:9

212:17 241:8

268:21 276:19

287:2 306:9

314:14

comfort 254:10

331:7

comfortable 23:15

23:16 36:20 37:2

37:6 45:7 50:11

88:10 127:8 223:5

258:6 276:1,11

283:18 308:5,9

344:9

coming 61:8 111:3

126:18 150:6

181:19 186:19

224:16 298:14

311:10 328:2

comma 47:20,20,21

comment 3:19 29:1

53:11 70:22 85:8

108:11 152:20

175:17,19 221:15

222:4 223:3

267:18,19 275:1,2

297:5 325:4 336:1

338:3 355:11

357:5 362:8,9

364:16

commenting 274:8

comments 6:18 7:9

12:1,20 13:8 63:7

77:4 90:4 171:13

171:19 257:2

302:18 323:18

325:21 338:22

364:19 365:12

commission 247:2

247:11

committee 17:15

18:18,20 67:22

69:6,16 71:14

72:19 83:11,20,21

84:20 88:16,18,21

89:13 93:7 94:6

99:20 104:2,22

105:13 106:13

107:22 108:2

109:10 110:2

114:16 125:18

139:16 154:4

358:18 360:19

363:6

committees 362:12

common 50:15

71:2 180:5

commonly 55:20

56:12 117:14

Community 2:5

4:21
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Page 372

commutated 79:14

company 344:3,4

compare 100:10

239:7 302:5

compared 75:11

178:17 215:18,22

343:21

compares 243:15

258:18

comparing 174:13

249:18

comparison 100:15

123:3 240:7

complains 53:21

complaints 291:8

complete 122:15

236:14 314:15

completely 49:6,7

49:11 65:2 79:16

81:21 101:16

152:14 176:9

177:1 190:9

298:19 299:18

compliance 15:8

57:5 130:18

338:16 359:3

360:2,6,21

complicate 24:9

364:9

complicated

222:21 289:21

310:5 311:5

compliment 13:4

106:22

comply 63:14

252:10

component 32:22

138:20 140:6

142:4 176:21

238:4,18 239:3

components 2:4

6:2 142:3 227:3

228:18,21 249:17

334:15

composite 187:10

compressed 69:21

compression 43:7

43:11 55:14 64:22

compromise 94:8

224:18 258:16

302:8 327:10

compromised

18:14 68:22

compromises

323:16 324:5,9

compute 243:4

computer 13:12

167:4 221:11

225:21 257:2

conceive 309:20

concern 9:17 41:18

44:2 48:4,5,19

49:5 53:14 54:4

202:12 206:13

289:15 314:4

concerned 52:6

61:22 62:2,3 95:3

95:17 103:9 123:5

267:1 268:12

337:19

concerning 168:11

concerns 47:6 53:4

91:5 97:16 223:22

296:10 326:2

Conciliation 1:14

1:15,16 5:14

conclude 35:20

concluded 9:5

257:7

concludes 125:10

212:3

conclusion 171:18

181:22 182:1,3

287:2 318:1

conclusions 180:17

condition 139:14

conditioned 103:15

conditioner 256:4

256:7 335:17

341:5

conditioning

118:10 119:10

254:22 255:4,6

274:12 341:3

conditions 134:19

167:21 168:9

241:6 246:18

265:11 311:3

362:22

conduct 134:12

confidence 300:1

confident 98:8

configuration

98:19

confirm 191:10

conforming 115:19

116:2

confused 138:15

152:14

confusing 94:13

209:16 240:17

316:8

confusion 90:10

Congress 199:16

200:12 201:7,20

202:14 203:12

congressional

203:13

connection 63:21

connections 8:8

consensus 12:22

15:3,18 37:18

39:21 65:19 67:3

68:9 83:11,19,21

84:20 88:16,21

89:12 93:6 94:6

99:20 104:1

243:14 295:22

296:1 326:16

328:1,5,10 329:2

329:4 361:21

consequences

79:12 172:12

conservation

160:17 343:1

conservative

251:21,22 268:22

324:2 337:2,6,12

337:15

consider 11:11

30:3 76:3,5 78:1

80:8 109:2 110:2

115:15 130:9

150:9 186:10

217:8 242:7

274:20

consideration

95:11 132:14

154:8 155:3 205:1

considerations

154:18 262:9

338:10

considered 17:17

18:5 95:12 111:7

111:11 264:8

340:5,7 342:20

considering 89:19

133:5 144:7

274:18

consistency 35:11

254:3

consistent 140:19

249:14 271:20

272:8 281:1

consistently 185:17

219:14 344:6

consists 147:21

constant 348:7

constitutes 58:20

construct 201:7

267:12 275:17

constructed 183:19

constructing

204:14

construction 17:6

84:19 93:16,20

94:4 145:3 195:1

197:11 204:17

225:8

constructions

193:20

consult 88:20 92:19

consultant 109:10

consultation 89:12

93:5

consulting 321:16

consume 214:10

consumer 143:11

179:8,9 204:21

256:4 337:20

338:17 339:20

consumption

130:20 353:19

contact 26:16

27:16 40:7,12,20

41:5,8 42:14,19

43:13 44:18 47:3

47:10,16 48:4,22

50:7 51:9,9 52:8

52:16 53:4,21

54:8,12 55:22

57:17

contain 59:19

60:13

containing 75:3

CONTENTS 3:1

context 137:22

142:14 144:14

223:2

continue 15:4

35:14 66:16 67:4

101:4,5 144:18

221:6 245:17

269:9 340:8

continuing 360:18

contours 40:16

contractor 118:16

342:16

contrast 113:9

123:6

contrasted 75:11

contributing 141:2

168:13

control 225:13

245:20 257:13

controversial 173:5

175:19,20 210:18

controversy 167:11

172:16,16

convection 54:22

conventional 56:3

97:3 180:1 304:9

conversation 34:10

51:3 245:17 249:8

252:21 266:3,4
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cooling 113:12

140:11 226:16

230:6,8,14

Cooperative 1:18

1:20 5:21

copied 233:21

copies 16:5 73:16

234:8

copy 16:8 234:10

cords 6:21

correct 36:9 45:17

67:7 143:12

161:12,13 212:20

213:5,11 217:19

229:7 241:3

244:19 262:21

263:13 287:7,8

294:14 303:1

314:8 332:8

335:13 336:20

341:7,13,17 350:3

358:2

correctly 36:10

49:15 166:19

214:16 319:4

342:17

correlation 210:5

corresponding

145:20 148:11,14

148:16 151:15

corresponds

147:16 151:20

cost 78:2 80:8

82:10,22 83:2

86:21 87:1 97:22

99:15 100:16

101:2 106:15

117:9,18 118:4,8

119:6,12,13,16

120:4 130:2,11

132:16 133:13,15

133:17 134:5,22

136:8 137:2

143:10 149:13,19

150:2,9,14,17,20

150:21 151:1,5

154:13 155:13

158:11,14,17

161:10,11 163:10

163:21 164:18

165:19 166:20

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252:13 253:4,22

266:6 267:5,14

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276:11,14 277:8

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kinds 132:10 154:5

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KISS 192:2

kitchen 83:17

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knot 322:19

know 5:18 11:3,7

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64:15,16 65:18

71:7 73:14 74:5

75:15 87:21 94:14

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113:11 114:9

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142:10 143:3,17

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300:16 301:1

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305:22 307:14

308:17 309:5

311:14 313:6

323:20,21 326:8

326:21 330:18,22

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348:12 349:4,11

351:8 352:6 353:6

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knowing 324:13

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knowledge 78:13

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knows 89:22

115:21 247:9

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kWh 257:20

L

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label 145:3 309:21

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labels 226:19

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labor 143:2,7 191:6

338:13

labs 99:10

Lacey 2:1 4:14,14

73:8,9 80:16

100:4 117:8

143:16 144:1,5

159:3 161:16

162:19 163:3,9

164:21 165:16

166:16 174:12,22

175:14,18 176:2

242:16 249:7

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317:5,12 319:22

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lacking 102:9

lady 7:3

landed 152:9

language 24:9

28:13 42:5,7 47:7

47:9 50:11 51:21

56:13 57:4,11,15

59:16 60:2 64:9

75:7 89:15 90:14

90:19 91:7,10,12

200:21 206:4

large 124:12 336:3

354:1

largely 298:1

larger 151:8

338:11 356:13

Las 277:21 286:18

291:3,9 307:9

lastly 130:13

late 182:14 313:5

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lateral 65:14

latest 14:5 181:9

185:1 237:15

Laughter 30:11

176:1 210:9

270:21 294:10

356:10 362:7

law 205:3,6,7,7

laws 116:16,22

246:13

lawyers 320:15

layers 32:3

LCC 14:5 126:11

127:7 130:8

219:16 224:20

226:13 229:3

233:20,22 234:16

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238:13 240:3

286:22 312:6

331:8,10,12 351:2

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licensing 257:16

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lid 258:22

life 18:13 82:21

106:12 130:2,11

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lifecycle 233:8

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244:21 256:10

268:19 271:4,17

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light 82:6 176:15

liked 326:15

likes 7:5 322:6

limit 26:21 27:6

34:21 41:17 61:8

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limitations 53:18

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limited 42:4 359:11

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line 4:11 5:17 6:12

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living 34:20 248:17

load 112:20

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location 121:1

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lock 329:19

log 72:5,8

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lot 4:8 10:5 12:2

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113:3 137:7,8

164:18 166:2,4

182:15 195:15

207:6 215:22

221:5 231:4

251:22 253:20

257:15 267:14

272:12 273:5

289:17,19 298:6,7

298:12 300:12,13

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328:2 337:21

345:10 354:18

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lots 311:9

love 77:3 276:20

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Lowell 2:8 4:18

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lowest 153:13

178:17

Ls 86:11

Lstiburek 54:16

Lubliner 2:3 16:8

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22:4 23:2,20,22

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34:16 35:17 36:6

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41:1,1,3 43:2,3,18

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51:6 60:17,18,20

62:2 65:6,10 71:1

71:1,10,11 81:8

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85:21 86:22 93:9

93:9 98:4,5,7 99:5

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Luter 2:4 6:1 8:13

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MAHRR 93:1

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53:4 57:17 254:3

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maintained 299:16

maintaining 90:10

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mapping 129:6,17

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318:11 319:21,22

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margin 170:22

273:9

marginal 132:12

133:9 168:3 178:5

179:16 208:13

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marine 347:21,22

Mark 1:20 2:9 5:1

5:21 35:7 38:15

49:2 50:22 53:10

53:13 55:8,18

56:14 58:7 63:19

64:10,11,12,16

85:19 87:2 89:4

89:14 90:6 91:20

92:2 93:1,10 94:8

97:11 107:18

108:10 116:21

117:8 125:19,20

142:18,21 143:6

161:8 173:6,7,14

190:21 198:11

203:3 204:2

208:22 212:4,8

215:12 217:10,13

218:7 221:9,17

237:10 238:1

239:18 246:5

261:15,16 284:6

284:22 286:21

288:3 297:6,8

299:8 302:17

307:1 310:4

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321:16 322:17

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Mark's 199:10

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market 81:19

205:3 210:1 252:2

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marketplace

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markup 143:3,5

massaging 11:13

match 146:10

matched 358:6

matches 229:19

material 141:14,15

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192:21

materials 191:18

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math 131:1,8,12

138:8,15,17 175:7

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mathematically

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Matt 288:7

matter 66:21 73:22

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133:7 141:22

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Matthew 2:15 5:8

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220:6 225:20

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Matthew's 127:6

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maximum 35:10

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27:3 36:21 44:15

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65:5 80:19 82:1

90:1 96:21 100:4

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107:17 110:20

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120:16 123:22

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163:19 173:13

174:22 181:22

182:19 185:9

187:18 189:21

199:5 201:10,17

201:22 207:3

215:3 216:4

217:14,17 218:13

221:20 230:1,4

232:1 242:5

243:10 247:7,8

248:14 270:15

275:12 277:7,10

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meaningful 157:18

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means 12:15,15

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80:1 82:5 87:8,10

103:11 106:20

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202:7 235:2 342:3

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222:13 223:1

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standpoint 85:5

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293:21 294:13,15

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298:1 299:16

300:5 301:6,12

304:2 305:10,18

307:17 308:4

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100:21 120:7

123:19 124:3

125:6 132:22

133:2,7 136:18

138:3,5,9 145:1,5

145:10,15,16

146:2 150:16

151:7,16 154:19

162:4,13 166:6

171:12 210:22

213:14,21 227:17

230:3 231:7

232:12 233:15

234:3,16 239:19

241:10 243:11

295:13 313:6

331:2 334:12

344:1 345:15

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217:14 325:13

328:21 341:10,15

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take 14:22 15:6

30:17 58:12 66:2

66:4,7,14 73:19

74:14 89:8 92:6

99:6 102:3 103:9

120:14 143:14

150:19 153:17

159:17 160:1

167:5 193:3,14

196:21 221:10

225:1 245:7 251:8

252:6 256:3,6

258:22 268:1

271:16 281:11

288:10 305:8,21

320:6,10 324:2

331:17 332:5

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351:11 352:5

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152:12 154:22

236:15 237:8

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288:11 291:15

292:10 297:7

309:2 310:21

311:6 313:3 318:7

346:19 358:21

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218:11 230:2

264:14 312:13

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26:22 35:22 41:16

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63:20 64:13 67:15

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120:17 133:3

141:14 147:8

156:13 163:1

172:21 173:16

197:7 199:3

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211:5 221:7,8

222:17 232:4

246:11 268:9

272:4,8,21 273:9

275:5,8 289:4

302:22 305:6,22

310:16 312:17

315:21 320:21

340:22 341:1,2

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359:2 360:4

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170:16 176:4

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221:17 222:5

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226:6 255:22

256:22 259:13

261:19 269:7

270:22 302:17

323:12 340:14,20

364:16 365:3

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188:19 212:10

218:8 222:6

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111:17 113:20

129:5,10 211:3

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thermostats 265:4

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46:22 55:9 62:9

62:15,20 63:22

80:4 90:22 95:9

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140:6 152:4

161:19 176:19

180:4 192:2 209:9

209:14 213:19

219:14 221:22

237:2 242:15

253:1 254:8,11

257:1,14 258:21

266:5 267:4

272:22 280:4

283:13 286:8

290:12 305:4

310:20 314:8,13

331:6 341:5

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132:21 134:20

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140:12,14 144:3,9

146:8 147:7 148:7

159:10 164:17

165:2 167:20

168:12 169:13

170:22 175:9

177:8,14 181:11

182:4 210:5

213:22 214:13,14

222:21 245:3

254:2 264:18

267:1 271:16

276:10 278:18

292:5,21 294:13

304:12 307:3

340:4,6 342:9

343:4 347:18

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10:4,5,20 12:4,5

12:10,15,20 14:16

16:12 18:22 20:10

20:13,17,20 21:12

22:11 24:1,8,14

26:1,3 28:10 30:5

31:15 33:5,10,15

34:2,6,9 35:22

36:1,8,12,19,20

37:10 39:1,2 41:3

41:7 42:12 43:4

43:10,22 44:12,17

44:17 45:3,5,8,12

45:16 46:15,19

47:1 48:5,19,20

50:14 51:18 55:8

55:9 56:4 57:3

60:22 61:1,6 62:7

62:8,22 63:3

64:19 65:4 67:5

68:7 72:9 73:4

75:16,22 78:7

79:11 80:7 81:9

85:17 86:6,19

88:5 89:22 90:7

90:18,21 92:3,10

92:15 93:11,20

94:13,21 95:9,16

97:4 98:7 99:15

99:20 100:9,13,15

101:14 102:7,20

102:20 103:17

104:4,8,10,21

105:2,4 106:13,20

108:4,4,6,22

110:14,16,19

111:10 113:20

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118:14 119:2

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122:3 125:1 126:2

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156:6,12 158:6,18

160:9 161:5

163:22 167:18

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175:10,19 176:19

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179:1,20 181:13

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185:6,18 186:3,9

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187:19 189:10,14

189:16 190:8,14

194:1 200:19,20

201:6,20 202:16

203:4,9,11,15,17

205:13,20 207:3,6

208:2,17,20 209:4

209:5,6,15 213:1

213:12 214:3

216:2,5,15,21

217:18 219:2,9,11

219:11 220:21

221:20 224:7,14

224:16 225:6,14

226:14,16 229:5

239:9,17,18 240:1

241:5,9,14 242:6

242:8 243:19

244:2 245:14

246:20 247:14

248:18 249:9,12

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262:21 263:1
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244:22 296:3

320:8

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17:15 57:6 80:12

113:7 153:10

154:2 177:20

193:4 207:13

244:14 251:21

323:13 337:1,7

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thousands 137:12

224:9,9 257:4

339:18 342:10

thousandths 163:1

three 12:8 74:19

81:1 106:4 110:3

110:9 111:10

113:18 135:4

146:4 149:17

171:7,15 185:4,5

203:6 211:19

212:13 226:19

230:9 233:9,22

234:16 235:1

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270:11 272:2

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293:12,13 294:6

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309:14 310:17

311:2 316:4,7

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Three-year 350:15

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323:14

throw 80:13 175:18

271:15 275:10

359:1 360:10

throwing 142:8

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throws 78:6

thumb 266:10

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36:21 39:18,20

66:11,11 67:20,22

69:5,6,14,17

71:13,15,19,21

72:13,15 76:10,11

276:2 329:6,9,11

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tickets 362:1

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277:20 286:18

301:21 307:9

tight 97:2,3

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111:17

tighter 88:8

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time 9:16 10:8

12:12 13:17 20:18

33:11 53:18 56:22

75:12 76:2 80:3,6

91:3 111:20 137:8

139:15 143:4

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191:7 192:8,13

217:13 224:8

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275:13 289:14

303:18 306:6

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34:14,18 39:8,11

42:11 43:17,22

44:9 46:17 52:5

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59:2 104:9,17

107:8,14 108:8

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189:6 190:4 201:9

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230:12 234:16

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transported 362:17

transposing 145:2

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tree 274:19

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169:4 170:4

171:10 188:6,7,10

227:10,11,14,15

227:18,21,22

228:1,5 231:2

234:7 235:22

236:17 237:6,14

237:22 238:19

239:4 240:13

241:13,21 244:14

253:13 255:11

256:20 270:9

272:19 278:7

280:19 282:7,16

283:1 284:13

285:3,6,13,14,14

285:15 286:1,3,6

286:17 291:17

292:5 295:9 296:2

301:10 302:22

303:3 305:13

316:5,13 319:6

346:9,11

2,000 209:3

2.5 253:9,18 356:1

356:15

2:09 226:2

2:21 226:3

20 105:18 126:11

202:19,19 306:1

331:22 332:9

344:6

20,000 223:15

20.15 163:6

200 223:17

2004 223:14

2006 353:5

2011 88:18

2012 102:15

2013 290:14

2014 1:7

2015 3:13 13:13

122:6 129:13

199:21 206:20

227:2 229:12

230:13,18 234:5

234:17,19 247:4

248:5 249:15,21

254:4 255:3 282:3

282:4 287:19

21 334:17

21-person 294:8

22 133:15 134:2

135:6,7,14,19

138:10 193:19

211:6

23rd 9:20 363:4

24 202:19 286:13

305:9

24th 9:20 363:5

25 83:18 266:12,13

266:14,16,16,17

266:18

27,877 223:12

28 211:6 215:18

2A 227:15 230:12

236:20,21 239:3

270:5 345:11

2B 170:8 270:5

345:11

3

3 146:17 147:4,10

147:11,14,17,21

148:3,17,20 149:4

152:2 162:11

163:13 164:1,5,12

164:13 168:7

169:4 171:11

188:5,5,7,9

227:10,11 242:1

253:14 271:22

272:15 277:20

278:7 280:19

282:8 283:1

284:13 285:3,6,13

285:14,14,15

286:3,16,20

287:19 291:18

292:6 295:10

296:2 301:12

303:4,12,18 316:5

316:13 319:6,12

319:13

3(a) 270:7

3.0 253:8

3.2 253:14

3.3 253:13,15

3.5 253:13 355:14

30 53:20 105:19

106:1 133:15

134:3 135:6,7,14

135:15,19,19

138:11 169:17,22

170:6 174:20

177:4 181:3,15,20

189:9 191:2,20

193:19 203:10

239:14

30-year 155:13

158:3 177:22

244:21 245:9

271:5 275:17

334:9 350:1

30-year-old 202:2

325 3:19

3280 34:18

3280.502 35:18

38:5

34 181:15,19

38 135:15,19 145:7

145:11,14 169:8

169:11,17 170:6

171:10,14,15

172:19 177:4

181:4,15,20,20

185:2 191:2,16,20

192:10,12 193:20

195:12 197:4

239:14 256:12

259:7

3A 345:11

3B 345:11

3C 345:11

4

4 3:3 145:12 147:10

147:12,21 148:4

148:15,22 164:2

164:14,14 166:5

169:4 170:4

171:11 188:6,7,8

227:18,21 242:1

270:10 278:7

280:20 282:8,9

283:1 284:13

290:15 291:18

295:10,13 296:2

303:4,18 316:6,13

316:21 319:1,7,11

319:12 320:9,9
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 410

325:5 347:12,21

353:3 355:20

4.8 24:21

4:30 357:4

4:36 365:22

40 323:15

402.1.1 145:1

402.4.1.1 16:1

402.4.4 74:20,22

76:15 77:2

402.6 107:4

402.7 107:5

403.5.1 73:5

403.5.1.1 73:6

403.5.1.32 73:6

403.6 74:14 76:17

76:18 77:18,19

78:5 104:22

112:11

403.6.1 78:5 79:2

110:20

403.7 104:22

110:14 112:14,15

48 165:7

49 145:8,13

4A 227:16 236:20

4B 236:20

5

5 147:22 164:2,14

164:14 166:6

172:21 188:6

228:3 239:7 241:4

241:10 242:2

278:2,8,21 279:2

279:7,16 280:9,20

281:19 282:9,22

283:2 284:10,14

284:19 287:7,12

288:4 290:16

291:18 295:11

296:3 316:6,14,19

316:19 317:10

319:1,7,13,16

326:17 327:1

330:17,17 345:4,8

345:9,22 346:7

347:21,22

5.5 197:4,19,21

355:13 356:5,6

5.5-inch 196:7

50 83:16 98:17

105:16 266:11,15

266:19 304:7,8

500 115:7,8 125:3

342:10

56 215:19

6

6 3:4 160:15 162:14

163:5 164:2,5,14

164:15 172:21

228:2 242:2

277:17 278:8

280:20 283:2

284:14 291:18

295:11 296:3

316:6,14,19,20

317:10 319:1,7,13

319:16 346:3,6

6,000 223:15

60 303:19

60,000 208:10,15

209:3

60.22 84:19,21 94:1

99:7 107:22,22

6097 1:10

62.2 111:5

66 215:18

68 257:18

6A 227:16 236:20

6B 220:16 236:20

7

7 3:7 148:5 162:6,9

162:15 163:5

164:2,5,5,14

165:20 166:5

168:7 172:21

242:2 277:17

278:8 280:20

283:3 284:15,16

285:1 288:13

290:15 291:18

295:12 296:3

302:8 316:6,15,19

316:20,22 317:10

319:7,13,16

7.5 196:16 356:16

7/8 148:5

70 253:19 257:18

70s 115:14

8

8 3:8 145:12 163:6

164:5,14 165:21

166:5 199:4

237:15,19 239:17

242:3 278:9,11

279:1 280:20

283:3 284:15,16

284:18 288:13

290:15 291:18

295:12,20 296:3

302:9 316:6,15,20

317:10 319:7,13

326:20 346:1

80 194:1 253:19

85 12:6

892 230:12

9
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

411

Manufactured Housing Work Group

US DOE

10-01-14

Washington, DC