851 S.W. Sixth Avenue, Suite 1100 Steve Crow 503

- 222

- 5161 Portland, Oregon 97204

- 1348 Executive Director 800

- 452

- 5161 www.nwcouncil.org Fax: 503

- 820

- 2370 Bruce A. Measure
Chair

Montana Dick Wallace
Vice

- Chair Washington

Rhonda Whiting

Montana

W. Bill Booth
Idaho

James A. Yost
Idaho Tom Karier Washington

Melinda S. Eden Oregon

Joan M. Dukes Oregon

March 24 , 2010

Ms. Brenda Edward s US Departm ent of Energy Building Technologies Program, Mail Stop EE

- 2J Energy Efficiency Standards for Manufactured Housing

Reference Docket #: EE RE

- 2009

- BT

- BC

- 0021 1000 Independence Avenue, SW Washington, DC 20585

- 0121

Comments of the Northwest Power and Conservat ion Council on the Advanced Notice of Proposed Rulemaking Energy Efficiency Standards for Manufactured Housing

Reference Docket #: EERE

- 2009

- BT

- BC

- 0021

March 23 , 2010

The Northwest Power Planning Council (Council) is an interstate compact between the sta tes of Idaho, Montana, Oregon and Washington authorized by the Northwest Electric Power Planning

and Conservation Act of 1980 (PL 96

- 501). 1 The Council’s role is to ensure that the Northwest’s electric power system will provide adequate and reliable energy at the lowest economic and

environmental cost to its citizens. The Congress charged the Council with developing integrated electric power plans for the Northwest. These plans are to rely on cost

- effective conservation as their first priority resource. 2 T he Council appreciates the opportunity to comment on this important rulemaking. The Council has the followi ng comments on the Advanced Notice of Proposed Rulemaking published in the February 22, 2010 Federal Register

.

The Council recommends that the Depar tment of Energy (Department) employ the analytical framework it now uses to establish appliance standards under the National Appliance Energy Conservation Act (NECA) to derive the efficiency standards for new

manufactured homes

.

The Department has develo ped a methodological framework that permits it to analyze a wide array of potential efficiency improvements across a range of financial input assumptions for use in setting appliance efficiency standards under NECA

. This framework avoids having to select

s ingle values for assumptions (e.g., mortgage rate, energy cost, construction cost, etc.) which are

1 16 United States Code Chapter 12H (1994 & Supp. I 1995). Act of Dec. 5, 1980, 94 Stat. 2697. Public Law No. 96

- 501, S. 885.

2 Northwest Power Act, §4(e)(1 ), 94 Stat. 2705.known to vary over a broad range in order to derive either the initial cost of a more efficient

home or its cost over its complete life cycle. The primary vi rtue of this framework is that it permits decision

- makers and stakeholders to assess the “robustness” of a ny particular standard

level

. In the Council’s judgment, this framework is also applicable to the establishment of efficiency standards for new manufa ctured homes. 3

The remainder of our comments directly responds to several of the issues the Department on which the Department has specifically requested comment.

Issue 1

- Differences between site

- built and factory

- built construction techniques that m ay justify creating unique energy efficiency requirements for manufactured housing that are different from the requirements in the 2009 IECC.

Comment

- There are no intrinsic difference s between site

- built and factory

- built construc tion techniques that wo uld limit the abilit y of HUD Code home manufacturer s to attain the levels of efficiency called for in the 2009 IECC and beyond

. HUD Code manufacturing plants in the Pacific Northwest have built more than 100,000 manufactured homes that meet or exceed the efficiency levels required by the 2009 IECC since 1989. Under the current PNW Energy Star/EcoRated Home specifications, manufacturers must meet a performance standard equivalent to the reference prescriptive requirements shown in Table 1. The thermal perfo rmance requirements of this specification meet the 2009 IECC prescriptive standards for the Northwest

states.

Table 1

- Energy Star/EcoRated Home Specifications

Component Requirement
Ceiling R

- 40 Flat or vault

Walls R

- 21

Floor R

- 33

Windows U

- 0.32

H ot Water .93 EF
Duct Testing 6% Floor. Area Total @ 50Pa )
Lighting 50% CFLs

Issue 2

- Specific construction cost data on manufactured home measures affecting energy efficiency such as insulation levels including associated construction impacts, fene stration

3 Under the Northwest Electric Power Planning and Conservation Act (Act) the Council is charged with the promulgating Model Conservation Standards (MCS) for new residential construction. The MCS must be designed to achieve all regionally cost

- effective energy savings that are economically feasible for consumers. In order to fulfill its obligations under the Act the Council’s uses a methodology identical to that employed by the Department. For a more complete description of the Council’s a nalytical approach and input assumptions, see Appendix G of the 6 th

Northwest Power and Conservation Plan. Available at: http://www.nwcouncil.org/energy/powerplan/6/final/G_0210 10.pdf The analytical model used by the Council to compare the first cost and life cycle cost of alternative energy efficiency improvements for new manufactured house is available at: http:/ /www.nwcouncil.org/dropbox/MH_LCCModel.zip(windows, skylights and doors), duct design and insulation, and permanent lighting

, specifically

any information on an increase or decrease in first cost to the home purchaser of designing and constructing manufactured homes consistent with the cu rrent IECC.

Comment

- The Department should solicit cost data from bo th manufacturers and suppliers and adjust these with the appropriate manufacturer

- to

- dealer

- to

- consumer markups for overhead and profit. Cost data and markup from should assume that the measures are priced as part of the “base model” not as “optional upgrades.” Since 1989 when HUD Code manufacturers in the Northwest first began building to significantly higher levels of efficiency than called for my the

HUD standards they have developed approaches to improve both the cost

- efficiency and energy efficiency of their construction processes and designs. The Department should use cost data from

these manufactures or others across the country that regularly incorporate advanced levels of

efficie ncy in their design and production processes since their costs are more representative of the actual long

- term cost increases that will be experienced by consumers.

Cost data for HVAC equipment and appliances should be obtained from firms that supply the manufactured housing industry. These costs should be compared to those developed by the Department through its HVAC and appliance standards rulemaking processes to ensure consistency. 4

Table 2 below shows the incremental cost to consumers after both manu facturer and retailer markup used by the Council in its 6 th Northwest Power a nd Conservation Plan. These are cost were collected from surveying manufacturers in the region.

Table 2

- Incremental Cost of New Manufactured Home Residential Space Heating

Cons ervation Measures

Conservation Measure Incremental Installed Cost (2006$/sq.ft.)

Wall R19 Standard Framing Base

Wall R21 Standard Framing $0.17

Attic R19 Base

Attic R25 $0.10

Attic R30 $0.10

Attic R38 $0.15

Attic R49 $0.23

Vault R19 Base

Vault R 25 $0.10

Vault R30 $0.10

Vault R38 $0.15

Underfloor R22 Base

Underfloor R33 $0.18

Underfloor R44 $0.18

4 The Council notes that the Department has rulemakings either near completion or currently underway for water heating, dishwashers, clothes washers, dryers, refrigerators, central air conditioners, heat pumps a nd furnaces. Data from these rulemakings should be readily accessible to the development of manufactured home efficiency standards.Window Class 35 (U<0.35) Base

Window Class 30 (U<0.30) $0.89

Window Class 25 (U<0.25) $2.00

Exterior Door R5 $4.54

Issue 3

- Other economic parameters such as lending scenarios, interest rates, loan duration, energy costs, and recommended values and approaches for addressing financial considerations and life cycle costs.

Comment

- I f

, as recommended by the Council, the Department employs the analytical

framework used in it s appliance standards rulemakings it should develop a distribution of interest rates and loan duration reflective of the share of real and personal property loans so that “chattel”

loans are represented in proportion to thei r share of total sales market . Moreover, historical trends in the share of real vs. personal property loans should be used to forecast the share of

these loans in the future. If the share of cha ttel loans has been declining, the Department should recogniz e this in its analysis. Historical real estate mortgage rate and term data are readily available from the Federal Housing Finance Agency. 5

Issue 4

- Statistics associated with HVAC system and equipment type, window type, and insulation levels, provided in recently built new manufactured homes by state or region.

Comment

- The Council recommends that the Department solicit this information from the manufactured housing industry. The Council has information on both Energy Star and non

Energy Star manufactur ed homes sold in the Northwest. 6

Issue 5

- Energy and/or operational cost savings estimates and/or metered data associated with different energy options for manufactured housing design and construction.

Comment

- The Council recommends that the Departmen t use a simulation model with input assumptions that have been calibrated to metered or billing analysis data for space conditioning, water heating and lighting (since the IECC requires 50% CFL lighting). The model must be capable of simulating changes in thermal integrity as well as HVAC system efficiency improvements. It must also be able to deal with the interactive impacts of increased lighting efficiency and space conditioning. While the Council uses the SEEM model calibrated to billing history and met ered data, other models with similar capability could be used. However, in order to develop the database needed to implement the analytical framework recommended by the Council, the Department must select a model that is capable to creating thousands of al ternative “efficiency packages” for testing with a reasonable level of effort.

Issue 7

- The manner in which applicable climatic differences should be addressed through a singular energy standard addressing manufactured homes.

5 http://www.fhfa.gov/Default.aspx?Page=252

6 See reference 3 above for the link to an Excel spreadsheet containing this data.Comment

- The current HUD c ode establishes three climate zones for the entire c ountry while

the IECC sets forth eight zones. The Council recommends that the Department select locations in each of the IECC zones that represent their “boundary conditions,” (i.e., locations with TMY 3 weather data files with the minimum and maximum heating and cooling degree

- days within each zone). To the extent practicable, these locations should also be representative of the boundary

conditions of each of the three HUD code climate zones. The Depart ment’s economic analysis will then be able to ascertain whether the level of energy efficiency that appears cost

- effective for manufactured housing differs significantly between locations that fall within the same HUD

climate zone and those required by the IECC for comparable climates.

Issue 13

- Suggested sources, studies, and research results of other information considered relevant to DOE's effort to establish energy standards for manufactured housing.

Comment

- The Council is aware that in all reg ulatory proceedings of this nature that the benefits of proposed increases in energy efficiency must be weighed against the burden placed on consumers by the increased first cost of h igher efficiency requirements. Specifically, in the case

of manufactured housing, that higher prices lead to reduced sales. While this is generally the case, the Department should note that an analysis of the experience in the Northwest did not

show that cost increases associated with energ y efficiency decrease d sales of manuf actured homes. In fact, the Northwest experience documented in a peer

- reviewed paper found that more expensive, but more efficient manufactured homes tend ed to compete better against site built

homes and gain market share

. 7

Thank you for considering our comments on this important rulemaking.

Sincerely,

Tom Eckman Manager, Conservation Resources

7 See, Eckman, Tom How A Midlife Fling with "Trailer Trash" Changed the Market Transformation Strategy for Manufactured Housing in the Northwest . ACEEE 2002 Summer Study. American Council for an Energy Efficient Economy, Washington, DC. Available at: http://www.nwcouncil.org/dropbox/ACEEEpaper.doc