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 U.S. DEPARTMENT OF ENERGY

 + + + + +

 MANUFACTURED HOUSING WORKING GROUP

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 PUBLIC MEETING

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 THURSDAY

 AUGUST 21, 2014

 + + + + +

 The Public Meeting met in Room

8E-089, 1000 Independence Avenue, S.W.,

Washington, D.C., at 9:00 a.m, Eileen Hoffman, 

Meeting Facilitator, presiding.

PRESENT

EILEEN HOFFMAN, Meeting Facilitator, Federal 

 Mediation and Conciliation Service

TED BANTLE, Meeting Facilitator, Federal 

 Mediation and Conciliation Service

JOHN CASKEY, National Electric Manufacturers 

 Association

KEITH DENNIS, National Rural Electric

 Cooperative Association

ISHBEL DICKENS, National Manufactured Home 

 Owners Association *

SCOTT DRAKE, East Kentucky Power 

 Cooperative *

STACY EPPERSON, Next Step Network

MARK EZZO, Clayton Homes, Inc. *

RICHARD HANGER, Housing Technology and 

 Standards *

BERT KESSLER, Palm Harbor Homes, Inc. *

ERIC LACEY, Responsible Energy Codes

 Alliance
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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 *

JAVIER RAMIREZ, Meeting Facilitator, Federal 

 Mediation and Conciliation Service 

ROBIN ROY, Natural Resources Defense Council

MANUEL SANTANA, Cavco Industries

PETER SCHNEIDER, Efficiency Vermont *

DAVID TOMPOS, NTA, Inc.

MICHAEL WADE, Cavalier Home Builders *

MARK WEISS, Manufactured Housing Association 

 for Regulatory Reform

* Present via teleconference

ALSO PRESENT:

ED BARBOUR, Navigant Consulting

JANET FREIMUTH, Office of Conflict 

 Prevention and Resolution, U.S. 

 Department of Energy

JOSEPH HAGERMAN, Energy Efficiency and 

 Renewable Energy Office U.S. Department

 of Energy

JAMES MARTIN, Office of Manufactured Housing 

 Programs, U.S. Department of Housing 

 and Urban Development

PAM PONTILLO, Office of Conflict Prevention 

 and Resolution, U.S. Department of 

 Energy

DON SURRENA, National Association of 

 Homebuilders 

KANITA VAIDYANATHAN, Office of the General 

 Counsel, U.S. Department of Energy

MATTHEW WALKER, Navigant Consulting
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 C-O-N-T-E-N-T-S

Call to Order, Welcome, Introductions 6

and Housekeeping

 Eileen Hoffman

 Meeting Facilitator

Opening Remarks by Department of 11

Energy 

 Joe Hagerman

 Energy Efficiency and Renewable

 Energy Office

 U.S. Department of Energy

Opening Remarks by Working Group Members 14

 Michael Lubliner 14

 Stacy Epperson 15

 Mark Weiss 16

 Keith Dennis 16

 David Tompos 17

 Manny Santana 17

 Robin Roy 17

 John Caskey 18

 Emanuel Levy 18

 Eric Lacey 19

 Joe Hagerman 19

 U.S. Department of Energy

 Rob Luter 23

 Rick Hanger 23

Further Remarks and Agenda Overview 23

 Eileen Hoffman

 Meeting Facilitator

Department of Energy Presentations: 25

PNNL Analysis and LCC Activities

 Joe Hagerman

 Energy Efficiency and Renewable

 Energy Office

 U.S. Department of Energy
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 PNNL Analysis 26

Life-Cycle Cost Spreadsheet 90

 Matthew Walker

 Navigant Consulting

Additional Introductions 133

2015 IECC 134

 Eric Lacey

 Responsible Energy Codes

 Alliance

Framework 192

 Emanuel Levy

 Systems Building Research Alliance

Public Comment 365

Next Steps 380

Adjourn 392
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1 P-R-O-C-E-E-D-I-N-G-S

2 9:06 a.m.

3 MS. HOFFMAN: Good morning.

4 I am Eileen Barkas Hoffman, one of

5 the facilitators from FMCS, Federal Mediation

6 and Conciliation Service, for the DOE ASRAC

7 Manufactured Housing Working Group.

8 Welcome.

9 We have got two really packed

10 sessions to go through today and tomorrow.

11 First, let me introduce my

12 colleagues, and then, we will go around the

13 room.

14 MR. RAMIREZ: Hi. Javier Ramirez

15 out of the Chicago office.

16 MR. BANTLE: And I am Ted Bantle. 

17 I work in the Office of Alternative Dispute

18 Resolution with Eileen here out of D.C.

19 MS. HOFFMAN: And then, I would

20 just ask all of the Working Group members that

21 are here, and then, we will hear from the

22 folks doing it by remote, starting with
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1 Michael.

2 MEMBER LUBLINER: Michael

3 Lubliner, Washington State University,

4 Extension Energy Program.

5 MEMBER EPPERSON: Stacy Epperson,

6 Next Step Network.

7 MEMBER WEISS: Mark Weiss,

8 Manufactured Housing Association for

9 Regulatory Reform.

10 MEMBER DENNIS: Keith Dennis,

11 National Rural Electric Cooperative

12 Association.

13 MEMBER TOMPOS: David Tompos, NTA.

14 MEMBER ROY: Robin Roy, Natural

15 Resources Defense Council.

16 MEMBER CASKEY: John Caskey. I'm

17 on ASRAC, and I work for the National

18 Electrical Manufacturers Association.

19 MEMBER LEVY: Emanuel Levy,

20 Systems Building Research Alliance.

21 MEMBER LACEY: Eric Lacey,

22 Responsible Energy Codes Alliance.
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1 MR. HAGERMAN: Joe Hagerman, DOE.

2 MS. HOFFMAN: Okay. We would like

3 to hear from the folks in the back from DOE.

4 MS. VAIDYANATHAN: Kavita

5 Vaidyanathan, DOE General Counsel's Office.

6 MR. BARBOUR: Ed Barbour, Navigant

7 Consulting.

8 MS. HOFFMAN: Okay. We have one

9 person in the audience.

10 MS. PONTILLO: Hi. I'm Pam

11 Pontillo in the Office of Conflict Prevention

12 and Resolution at the Department of Energy.

13 Thank you.

14 MS. HOFFMAN: Right. Thank you.

15 And before we get into the formal

16 program, we want to hear who is on remote. 

17 First, who are the members and alternates, and

18 then, any of the public.

19 MR. RAMIREZ: And also, the folks

20 on the phone, please designate if you are a

21 voting member today.

22 MEMBER DICKENS: Good morning.
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1 This is Ishbel Dickens from the

2 National Manufactured Home Owners Association. 

3 I am a voting member, and it is still a little

4 dark here in Seattle.

5 MR. RAMIREZ: Thank you.

6 MEMBER HANGER: This is Rick

7 Hanger. I am with the State of Colorado,

8 Division of Housing. I am a voting member.

9 MEMBER EZZO: Mark Ezzo, Clayton

10 Homes, and I'm a voting member.

11 MEMBER LUTER: Good morning.

12 Rob Luter with Lippert Components,

13 also a voting member.

14 MEMBER SCHNEIDER: Peter

15 Schneider, Efficiency Vermont, a voting

16 member.

17 MEMBER WADE: Michael Wade,

18 Cavalier Homes, also a voting member.

19 MS. HOFFMAN: Is Scott Drake on

20 the line?

21 (No response.)

22 And let me just see. Bert
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1 Kessler?

2 (No response.)

3 Okay. And I think that's it. 

4 Okay. All right.

5 MR. HAGERMAN: This is Joe

6 Hagerman.

7 Here is who we have online. We

8 have Ishbel Dickens. We've got Scott Drake. 

9 We have Mark Ezzo, Richard Hanger, Bert

10 Kessler, Robert Luter, Richard Potts, Peter

11 Schneider, and Michael Wade.

12 And if we get anybody else online,

13 we will announce their names as well.

14 MR. RAMIREZ: Manny, can you go

15 ahead and turn your microphone on and

16 introduce yourself?

17 MEMBER SANTANA: Manny Santana,

18 Cavco Industries, Phoenix.

19 MS. HOFFMAN: Okay. Just a couple

20 of things we learned from the last time we

21 met. If you want to speak, an easy way is

22 just to put your name tent up. I think that
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1 is Robin Roy's idea. But, in any event, thank

2 you on that score.

3 Okay. All right. Well, welcome. 

4 And I would like to ask DOE to say a few

5 remarks, and we will, then, work through what

6 our agenda is.

7 MR. HAGERMAN: So, this is Joe

8 Hagerman, DOE.

9 I just want to thank everybody

10 again for taking the time out of their busy

11 lives to come here and discuss this consensus

12 process for manufactured housing.

13 We would really encourage that,

14 you know, there's been a lot of questions

15 asked by the group and we have done a lot of

16 analysis that we have shared with everyone. 

17 So, we think it is going to be a pretty

18 productive day, as we discuss the actual

19 standard-setting. So, we look forward to the

20 positive discussions that we have.

21 And I just wanted to ask, too,

22 maybe we could take a few minutes just to ask
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1 the members how they think the process has

2 been running thus far. If there is anything

3 that we need to do to get information quicker

4 to you or anything that you would like us to

5 do to help the conversation moving along, we

6 are very interested in hearing that.

7 I can say that we have gotten a

8 lot of questions from individual members. And

9 how we have been treating those thus far is,

10 if we get a question, we try to get an answer. 

11 And then, we send out the question and the

12 answer to everybody.

13 And we have realized that we need

14 to start keeping kind of a running FAQ, so

15 Frequently Asked Questions or questions that

16 get asked. And so, that is the docket. So,

17 in case you forget one in your inbox or you

18 want to see the total list of all the

19 questions that have been asked, we are going

20 to do that after this meeting. We are going

21 to start a running list of questions and

22 answers and post that to the docket.
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1 We have been pretty diligent about

2 posting everything.

3 Somebody's GPS is going off.

4 But we have been really good about

5 keeping all the dockets -- I mean, sorry --

6 all the files and the correspondence on the

7 docket. But if you do see that we have missed

8 something, please let us know. It is not our

9 intent to not post things to the document.

10 I believe that Energetics did send

11 out the docket URL to everybody. And so, you

12 should have that and you should be able to go

13 through it.

14 And I believe they posted the

15 transcripts yesterday. The transcripts, as

16 you read through them, there are some typos

17 and whatnot. And we erred on the side of

18 getting the transcript posted as quickly as

19 possible rather than going through and

20 cleaning up errors. So, a lot of times you

21 see acronyms, like the ICC is kind of missed

22 a couple of times, and the IECC is kind of
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1 missed a couple of times, but I think you can

2 figure it out.

3 Yes, the Wi-Fi password is

4 energy.wireless, all lowercase. And I think

5 it is behind you here, the sign behind you.

6 All right. So, if you have any

7 other questions for us, we would love to hear

8 some feedback from you guys on what we could

9 do better.

10 You know we are trying to be as

11 responsive as possible to you and trying to

12 make sure that we get the conversation rolling

13 and we get a consensus standard as quickly as

14 possible.

15 MS. HOFFMAN: I think it wouldn't

16 be a bad idea to go around the room and hear

17 how is the process working so far and, also,

18 if there is someone who is a Chair of a

19 subcommittee, if there is a report or how far

20 along you are on that.

21 Why don't we start with Michael?

22 MEMBER LUBLINER: The last meeting
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1 I was communicating via phone, so I didn't get

2 the benefits of interacting with people here

3 in person. But I thought from that

4 perspective the process went real well. I was

5 able to share my input, and I look forward to

6 doing it here again today.

7 MS. HOFFMAN: Now you have a

8 subcommittee.

9 MEMBER LUBLINER: Now, on the

10 subcommittee, since I have been on vacation

11 since the last meeting --

12 MS. HOFFMAN: Right.

13 MEMBER LUBLINER: -- I have done

14 nothing, but I have been reviewing some of the

15 work that some of the people on the

16 subcommittee like Emanuel have been crunching

17 out and others. So, I think that we are in a

18 good position today for some good discussions

19 in that area.

20 MS. HOFFMAN: Okay.

21 MEMBER EPPERSON: Hi. This is

22 Stacy Epperson.
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1 I think it is a thoughtful, good,

2 fair, and transparent process. I am the point

3 person for the Subcommittee on Finance, and we

4 met this week. We have been inventorying our

5 data. We have quite the list, quite the stack

6 of studies that we are reviewing.

7 Just a couple of highlights. You

8 know, we already have data on loan size and

9 interest rates and downpayments and FICO

10 scores. We have all that today that, if we

11 need to share that, we can. And we have

12 identified experts in the field we are going

13 to spend some time with.

14 Thank you.

15 MS. HOFFMAN: Thank you.

16 MEMBER WEISS: Mark Weiss.

17 I think we had a good exchange

18 last time and look forward to the same this

19 session.

20 MEMBER DENNIS: Keith Dennis.

21 I think it is going great. The

22 amount of information that has been coming
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1 quickly is great. Thanks.

2 MS. HOFFMAN: And you heard it was

3 Keith Dennis? Okay.

4 MEMBER DENNIS: Keith Dennis, yes.

5 MEMBER TOMPOS: Dave Tompos from

6 NTA.

7 I this, so far, so good. I think

8 the FAQs is a great idea. We have only had

9 one meeting. So, I think after today we will

10 have a lot more feedback for you.

11 MEMBER SANTANA: Manny with Cavco.

12 I think that the process has taken

13 the time that these things take. I think we

14 should all come to the realization that the 60

15 days at the end of September/October is fast

16 approaching, and we are going to struggle to

17 come up with a term sheet, I think, at this

18 pace, although I think this is the pace we

19 need to take.

20 MEMBER ROY: Rob Roy, NRDC.

21 I think it has been a great

22 process. Nobody has been shy. There are a
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1 lot of areas that are useful. Even though we

2 didn't get into the real substance of stuff

3 yet, I have no doubt we will continue to

4 debate these things intelligently.

5 And, Manny, I think we are going

6 to do a fine job in the end. We are really

7 going to see that finish line coming running.

8 (Laughter.)

9 MEMBER CASKEY: John Caskey, NEMA.

10 And I think the process is going

11 well, and I particularly think the last

12 session where you identified a lot of the

13 issues in the industry I think was very

14 important in trying to sift through all that. 

15 So, I am looking forward to good progress over

16 the next couple of days.

17 MEMBER LEVY: Emanuel Levy.

18 You will hear enough from me

19 later, but I think the process is going well

20 and I think the inputs have been very

21 constructive thus far. And I look forward to

22 a great meeting.
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1 MEMBER LACEY: Eric Lacey,

2 Responsible Energy Codes Alliance.

3 I found the spreadsheets from PNNL

4 to be very, very useful, and we worked on them

5 a little internally and kind of tested them

6 out, based on what we know about the codes, as

7 they are adopted for stick-built housing. And

8 I have checked in with a couple of our members

9 to see what kinds of innovative ideas they had

10 of how to get to some of these levels in

11 manufactured housing, and I think it is going

12 to spur some real innovation.

13 MR. HAGERMAN: Let me just add to

14 that. This is Joe Hagerman, DOE.

15 The PNNL team that we have set up

16 to do this fast turnaround analysis for us,

17 they have been doing a good job, I think, at

18 producing the type of materials that the

19 Working Group needs.

20 I do have to apologize. The first

21 issuance of the PNNL analysis had an error in

22 it that I didn't catch until they did the Uo
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1 calculator that Emanuel asked for, and then,

2 I caught the error and asked them to rerun all

3 the analysis again.

4 So, I apologize for that. If you

5 see anything in terms of errors or you think

6 something looks suspicious, then please flag

7 it and we can get the team to run down the

8 analysis or have a phone call with everybody. 

9 So, you know, we put that out there.

10 I can say that Robin Roy asked a

11 question of the analysis team to model a

12 manufactured home that meets the ENERGY STAR

13 requirement. And I was really hoping that I

14 would be able to able to present that today. 

15 But, in reviewing the data, I saw another

16 little problem or a potential problem that I

17 asked the team to hunt down. In one climate

18 zone the ENERGY STAR manufactured home was

19 using more energy than kind of the baseline

20 HUD home. So, that just didn't sound right to

21 me.

22 So, they are going to run that and
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1 present that document to us, hopefully by the

2 end of day tomorrow. We will be in

3 discussions by then. We will, hopefully, have

4 some added data.

5 And they are ready. They are

6 prepared and set up to do model runs to meet

7 the needs of the Working Group. So, if there

8 is something between today and tomorrow that

9 you want to see modeled, we can quickly model

10 that.

11 MS. HOFFMAN: Okay. Any of our

12 members on the remote want to mention

13 anything? Otherwise, we will get started. 

14 But, if you do, the question is, how is that

15 process going so far?

16 MR. RAMIREZ: We had one

17 additional member of the public come in the

18 back. Would you mind introducing yourself?

19 MR. SURRENA: Yes. I'm Don

20 Surrena from the National Association of Home

21 Builders.

22 MR. RAMIREZ: I'm sorry, could you
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1 approach the microphone? There are folks that

2 are online that need to hear as well. Thank

3 you.

4 MR. SURRENA: Don Surrena with the

5 National Association of Home Builders.

6 MR. RAMIREZ: Thank you.

7 MR. SURRENA: Thank you.

8 MS. HOFFMAN: All right. So,

9 thank you.

10 So, anyone on remote of our

11 members that would like to make any comments?

12 MEMBER LUTER: This is Rob Luter

13 at Lippert Components.

14 I would just like to echo some of

15 the other comments. I think the process is

16 going fairly well so far. There's a lot to

17 do. I think the candor expressed by everyone

18 so far is going to go a long way to getting us

19 where we need to go, and I appreciate that

20 from everybody.

21 MEMBER HANGER: This is Rick

22 Hanger out in Colorado.
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1 I do just appreciate the

2 information provided by PNNL. It is not

3 information I am able to get directly. So, it

4 is very helpful.

5 MS. HOFFMAN: Okay. Hearing no

6 more, we are going to get started.

7 First, we wanted to let you know

8 about the website to get all the information. 

9 We cobbled together our own summary of what

10 happened in the last two days of the meeting

11 as a draft. So, please look it over.

12 But the transcript really is the

13 official record. But, for those of you who

14 want the condensed version, we put together a

15 summary, and you are welcome to look at it. 

16 Since it is in draft, any comments or changes

17 would be most appreciated.

18 In terms of our format today, as I

19 said, you all, I think, have a copy of the

20 agenda, but it is pretty packed. We will be

21 hearing in a few minutes from DOE, from Joe

22 and from Research as well, on the PNNL
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1 analysis and LCC activities.

2 Then, we will be hearing from Eric

3 Lacey the 2015 IECC Code, and he will be going

4 through it with us step-by-step, I hope. 

5 Every word, yes.

6 (Laughter.)

7 The unexpurgated version, yes.

8 Then, we have a lunch break from

9 12:00 to 1:00.

10 1:00 to 2:00, continued discussion

11 of the 2015 IECC Codes.

12 And then, at 2:00, from 2:00 to

13 3:45, Emanuel Levy will have a framework

14 discussion. He also promises we may have some

15 slides to enhance that presentation.

16 Then, after break, we will have

17 comments from the Working Group and comments,

18 a especially-designed period from 4:30 to 5:00

19 for any comments from the public.

20 And then, our wrap-up. And then,

21 we have got a really busy day tomorrow as well

22 where we will be looking at more of the Mind
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1 Map that my colleague and wonderful co2 facilitator Javier Ramirez put together.

3 Because what we did the last two

4 days of the first meeting set was really to,

5 hopefully, define many, many of the topics

6 that we have to address for this draft rule.

7 And we will also hear any comments

8 about if there needs to be another Working

9 Group or how we are going to structure that,

10 and then, talk about next steps.

11 So, we have got a lot on our

12 plate. We have got a deadline. And, without

13 further ado, my colleagues, I am going to turn

14 it over to Joe.

15 Thank you.

16 MR. HAGERMAN: This is Joe

17 Hagerman, DOE.

18 Before I go into the PNNL

19 analysis, are there any opening comments that

20 the Working Group members would like to share

21 with us in terms of anything that they have

22 kind of realized? I know we asked you the
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1 question if you thought the process was going

2 well. All right, you have answered that

3 question. But do you have any opening

4 statements about the content in terms of

5 developing the standard that you would like to

6 make? You can say no. I am not trying to put

7 anybody on the spot here. But we would

8 welcome opening comments now.

9 (No response.)

10 Okay. All right. I didn't think

11 so.

12 All right. So, let's get started

13 with the PNNL analysis.

14 The people on the webinar can see

15 this? Okay.

16 And everybody should have, I

17 believe, a handout that has this information

18 on it.

19 And largely, I am going to walk

20 you through the two spreadsheets that were

21 generated in the last week, the last two

22 weeks. And I have made 10 copies of the
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1 spreadsheets here, and I will pass those

2 around. Ten copies is roughly the size of a

3 phone book. I know we have more than 10

4 people in the room. So, if you would like to

5 share these, we would encourage that.

6 I personally think that the

7 printouts are not as helpful as the actual

8 spreadsheet, right, because you can actually

9 drill down to the information you are looking

10 for. But, nevertheless, here's the

11 spreadsheets.

12 MEMBER LUTER: Joe, this is Rob,

13 Lippert.

14 Will these materials be available

15 electronically for those of us out in

16 cyberspace?

17 MR. HAGERMAN: That's right. So,

18 the documents I am going to cover thus far or

19 today is the spreadsheet, and then, you should

20 see the PowerPoint on the screen, if you are

21 signed into the webinar. And then, of course,

22 we will post after this meeting the PowerPoint
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1 and all the materials.

2 MEMBER LUTER: Out on the docket?

3 MR. HAGERMAN: Out on the docket.

4 MEMBER LUTER: Okay. Great. 

5 Thank you.

6 MR. HAGERMAN: I don't have a

7 problem with sending the PowerPoint right now

8 to the Working Group members, if you would

9 just like to have a copy of that. And we

10 could make that happen right now. So,

11 Jeremiah is going to do that.

12 MEMBER HANGER: This is Rick.

13 That would be great.

14 MR. HAGERMAN: Are there any more

15 questions on the phone before we get started?

16 (No response.)

17 All right. So, I just wanted to

18 kind of quickly walk over what the PNNL

19 analysis covers and how they generated it. 

20 And then, if you have specific questions about

21 assumptions or results, then we can write

22 those down and get the PNNL team to formally
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1 address those.

2 And so, of course, all the

3 analysis is predicated on some inputs, right?

4 Some there are some assumptions you have to

5 make, some inputs that you have to put into

6 the calculator or the EnergyPlus software

7 before they generate all these results.

8 And so, I really would appreciate

9 it if all the Working Group members, and the

10 manufacturers in particular, would look over

11 these assumptions and make sure that they are

12 consistent with the industry, what the

13 industry is doing and industry averages, and

14 whatnot, because, obviously, the inputs are

15 the principal parameters that are run in

16 EnergyPlus. So, if the inputs are wrong, of

17 course, the results are going to be wrong.

18 So, okay, the description of the

19 analysis. What PNNL did was they modeled two

20 manufactured homes, a single section,

21 singlewide, and a doublewide, a double

22 section. And the dimensions of those sections
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1 are listed. So, 14'x66' and a 28'x56'. So,

2 we are using those as a good representative

3 sample of the sizes of the manufactured homes.

4 They modeled four commonly-used

5 heating and fuel systems from electric

6 resistance to heat pumps, to natural gas

7 furnaces, to LPG furnaces, and also included

8 cooling equipment. And they used the minimum

9 appliance standards for those equipment. So,

10 they did not assume any high-efficiency

11 equipment.

12 All right. Next page. They

13 modeled each home in 15 locations,

14 representing the 15 climate zones as defined

15 by the IECC. And we made sure to use

16 locations that could be mapped to the three

17 HUD zones.

18 The five code scenarios, they also

19 ran it for five codes, with the HUD code as

20 the baseline, and then, 2006, 2009, 2012, and

21 2015 IECC, as we described earlier. And so,

22 this resulted in over 600 individual models
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1 being run, at which case they tallied the

2 results and gave you a summary in this

3 spreadsheet.

4 They did use the Building America

5 schedules, so the schedules of occupancy and

6 how many people are using the homes, how many

7 times they open the refrigerator, how many

8 times they open the door, et cetera, et

9 cetera, for the schedule and the loading.

10 And they modeled those results in

11 one-hour increments and, then, summed them up. 

12 So, it is not just a day analysis or a 15-

13 minute-interval analysis.

14 Any questions about that?

15 (No response.)

16 All I am trying to point out here

17 is there is a lot of data behind the tables

18 that you were presented.

19 So, next slide.

20 All right. So, for the purpose of

21 PNNL analysis, it is to estimate the energy

22 use and operating expenses. So, for this
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1 purpose, PNNL identified building parameters

2 at the component level, such as insulation for

3 walls, ceilings, and floors, window U-factors,

4 envelope leakage, lighting, and hot water pipe

5 insulation.

6 Next slide.

7 So, as we know, the HUD code, the

8 current HUD code doesn't break those

9 components out. They only prescribe an

10 overall U-factor. So, the overall U-factor

11 prescribed in the HUD code has been translated

12 into building component insulation values for

13 energy use for the analysis purpose.

14 Yes, Robin?

15 MR. RAMIREZ: Let's just take a

16 quick pause because we want to make sure that

17 this is the right version that is up here.

18 MR. HAGERMAN: So, I apologize. I

19 think the handouts have a slight typo. They

20 have "PNKL," the "kilowatt lab". It is

21 supposed to be "PNNL".

22 MEMBER ROY: While we are getting
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1 that sorted --

2 MR. HAGERMAN: Yes, why don't you 

3 ask your question?

4 MEMBER ROY: Robin Roy.

5 I have a question. On the

6 assumptions, like this all makes perfect

7 sense. One really major, I think perhaps

8 driving assumption on the both amenity for a

9 home and the energy use is the relative

10 glazing area. I think that is a big driver if

11 you change one of these. It would change a

12 lot with the energy use, and it has certainly

13 changed what it is like to live in one of

14 these.

15 Where did you get the assumptions

16 for that?

17 MR. HAGERMAN: Right. I can ask

18 them that question again just to confirm, but

19 I believe that they used information from a

20 previous RFI on how big that area is. I want

21 to think it was a comment that Michael

22 Lubliner submitted.
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1 Mike? Mike?

2 MEMBER LUBLINER: I am recalling I

3 saw something like 12 percent, but I have a

4 similar question. I would like to figure out

5 where the documentation is.

6 I know we in the Northwest have

7 run energy-efficiency programs and we track

8 the percent of glazing of the floor area. But

9 I have no idea if that is representative of

10 other areas of the country in non-energy

11 programs.

12 It would be an interesting to do a

13 parametric analysis to see what the impact

14 going from a minimum of 8 -- I don't think you

15 can go below 8 without egress issues -- to 12

16 is in terms of the implication on the Uo, if

17 that is something. I don't know how big of a

18 deal that is going to be.

19 But glazing area, depending on the

20 U-value of the glazing can have a lot of

21 effect in trading off other insulation values. 

22 So, that is appropriate.
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1 MEMBER TOMPOS: Dave Tompos from

2 NTA.

3 Eight is the minimum. I think you

4 are going to find in most homes 12 is going to

5 be probably what the minimum actually is. You

6 are not going to see a lot less than that.

7 MR. HAGERMAN: This is Joe

8 Hagerman, DOE.

9 So, this is a really important

10 issue. I will get an answer for what they

11 modeled here, but is there an "ask" for them

12 to do some analysis at lower levels, at higher

13 levels? Do the manufacturers want to comment

14 on what levels they should be modeling, what

15 assumptions? What is the input here that they

16 need to assume?

17 MEMBER LUBLINER: I would like to

18 see a parametric --

19 MR. HAGERMAN: Microphone, you've

20 got to do the microphone,.

21 MEMBER LUBLINER: I'm sorry again.

22 I would like to see a parametric
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1 analysis, if the group feels it is

2 appropriate, that would look at everything

3 from 8 percent up to 12, or at least do an 8

4 percent run and see if that is a big enough

5 tradeoff that we need to consider.

6 But, again, I don't know what the

7 distribution is. The average might be 12, but

8 that might mean that a bunch of them are at 13

9 and a bunch of them are down at 8, 9, or

10 something.

11 So, does the industry or does IBTS

12 or does HUD actually record that kind of

13 information? Maybe, then, it is just up to

14 the industry to share.

15 MEMBER TOMPOS: Dave Tompos.

16 I don't think we record it. I

17 mean, we check with every plan, that we look

18 at it. And again, I think you are going to

19 find that 12 is more the minimum than 8. You

20 know, if you want any windows in your home, 12

21 is going to be the minimum. So, maybe it

22 would be a good idea to see what the
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1 difference is if we go to the next percentage,

2 you know, 15 or maybe even a 20 percent.

3 MEMBER LUBLINER: Absolutely. 

4 Looking at maybe 8, 10, 12, and 14 would give

5 us a sense of, is this a big enough issue that

6 we need to worry about it in terms of the

7 ability to trade off with other measures? 

8 That is my biggest concern, not knowing what

9 that is.

10 MEMBER LACEY: Michael, this is

11 Eric Lacey.

12 If you look at the PNNL

13 spreadsheet that calculates the U sub o, you

14 can modify that. We did this internally and

15 started testing out just different glazing

16 areas. And it does have a huge impact on the

17 U sub o.

18 I mean, the U sub o assigns an

19 assembly area to all of the assemblies, the

20 ceiling, the wall, and everything, but the

21 glazing does make a big difference. They all

22 make a difference, but glazing makes a really
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1 big one.

2 And we found that turning up or

3 down that glazing area percentage in the

4 assumption can have a huge impact on the U sub

5 o. So, if you want, I would be happy to show

6 you how we monkeyed with the spreadsheet to

7 make that work.

8 MEMBER LUTER: This is Rob at

9 Lippert.

10 I would echo that sentiment and,

11 also, add that many of the assumptions made in

12 this analysis are represented to be at the HUD

13 code minimum. And this isn't at HUD code

14 minimum. It may be the more common

15 percentage, but I would like to at least see

16 the analysis at HUD code minimum 8 percent,

17 just to see how it shakes out.

18 MR. RAMIREZ: Eric, on your report

19 that you are going to be doing, is that

20 something that you could do on there?

21 (No audible response.)

22 Okay, perfect.
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1 MEMBER EZZO: This is Mark Ezzo at

2 Clayton Homes.

3 The 12 percent number that is

4 being used in a lot of these analyses I think

5 is an okay number to use. I mean, we see

6 glazing percentages, obviously, greater than

7 that. We also see glazing percentages a

8 little bit less than that.

9 And I think I heard somebody say

10 maybe the way to tackle it is to 10 percent,

11 12 percent, and 14 percent. To me, I think

12 that makes sense.

13 So, if we are looking at the

14 14'x66' model, for example, I think we used or

15 PNNL used the 111 square feet of glass in that

16 house at 12 percent, which that is an okay

17 number. But, I mean, we can tell you, we have

18 14'x66' homes that have less than that, and we

19 have 14'x66' homes that have a little bit more

20 than that.

21 So, I guess, in summary, I think

22 10 percent, 12 percent, and 14 are good
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1 numbers. Eight is probably a little bit of a

2 stretch on the low side. I am not saying that

3 there is not a home out there or homes out

4 there that have 8, but that is getting really

5 low.

6 And then, going over 14 I think is

7 also very infrequent. I mean, 14 percent

8 glazing on a 14'x66' is almost 130 square

9 feet, which is a lot of glass in a little

10 home.

11 MS. HOFFMAN: Okay. Thank you.

12 MEMBER ROY: Just one quick one. 

13 Robin Roy.

14 So, Mark, that is kind of what

15 drove my question in the first place. That

16 was very helpful, your comment.

17 I am just keen to see that the

18 result of this process is not that we drive

19 out the type of house that you guys find

20 really attractive and consumers find

21 attractive, like a 14 percent window home. As

22 long as you guys are comfortable with that and
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1 the manufacturers are comfortable with that,

2 that sounds good to me.

3 MEMBER LEVY: A couple of

4 questions or a couple of comments.

5 Emanuel Levy, Systems Building

6 Research Alliance.

7 The issue of window area relates

8 to a couple of things. One is, obviously, if

9 you have a target for Uo value and you have a

10 small home with a large window area, it is

11 going to be very difficult to comply. So,

12 that is going to be the worst-case analysis. 

13 It is not the 8 percent case. It is the

14 single section home that has a lot of glazing

15 area. That will be a real problem. So, I

16 think we should keep that in mind as we are

17 talking about this.

18 We did a survey years ago for

19 basically the same purpose, and PNNL did a

20 survey back in '92 -- I have it here -- that

21 talks a little bit about the basis of where

22 those numbers came from originally.
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1 And what you find is that the

2 amount of window area fluctuates. It depends

3 on the type of building. Single section and

4 multi-section will be different. But, also,

5 markets are different. Price point really

6 drives window area. The higher-priced homes

7 will tend to have more window areas, as you

8 expect. And so, you would find those in the

9 Northwest, and there are certain markets that

10 tend to have larger window areas. So, I don't

11 know to what extent we need to keep that in

12 mind as we are talking about this, too. The

13 areas in the South, which tend to be less

14 costly, tend to have a smaller window base. 

15 But, as Mark pointed out, there are plenty of

16 exceptions to that rule.

17 MR. HAGERMAN: So, just to close

18 this out, we need to sort of vote on what we

19 are doing here, what the PNNL analysis team is

20 going to do here for us.

21 You know, you were asking them to

22 do three runs of everything that they have
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1 run. So, you know, they have run 600

2 simulations here, and you want to see that at

3 10, 12, and 14 percent, is that correct? We

4 all agree to that? Does somebody want to see

5 8?

6 MEMBER LACEY: This is Eric.

7 I don't know if you need to rerun

8 everything. I mean, I think the information

9 is in the spreadsheet. You could just change

10 the assumptions in that spreadsheet, and it

11 will give you a calculated Uo. I mean, it may

12 not be quite as, yes, it may not be quite as

13 accurate, but that would be an easier way.

14 MR. HAGERMAN: I just need some

15 direction here.

16 MEMBER EZZO: This is Mark Ezzo at

17 Clayton.

18 The spreadsheet, though, it shows

19 a home that complies. And tell me if I am

20 saying this wrong. But, if you increase the

21 glazing area to 14 in order to comply with the

22 climate zone, whether it is IECC or HUD, it is
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1 going to have to adjust the cavity insulation

2 values and/or window U-value accordingly,

3 right?

4 MR. HAGERMAN: I believe so.

5 This is Joe Hagerman.

6 I believe so.

7 MEMBER EZZO: Okay. Okay.

8 MR. HAGERMAN: That's why I

9 believe they have to rerun this. Correct?

10 MS. HOFFMAN: So, are you asking

11 for a sense of the Committee to direct PNNL to

12 run it again for 8, 10, 12, and 14? They ran

13 12. So, for 8, 10, and 14?

14 MR. HAGERMAN: The question is, do

15 we have to run 8? That is the question.

16 MEMBER ROY: Robin Roy.

17 I am really interested in the 12

18 and 14, 12 being reasonable, and 14. Eight is

19 not going to be constraining. It is whether

20 we can make a home at 12 that is really the

21 issue or the 14. So, I don't think it is

22 worth any effort to go to 10 and the 8 that
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1 much. We know we can get there.

2 MEMBER TOMPOS: Dave Tompos.

3 We don't need the 8. You are not

4 going to find many down there, and it is not

5 going to make a difference because it is going

6 to be a better case.

7 MR. HAGERMAN: All right.

8 MEMBER LUBLINER: Mike Lubliner.

9 I would like to see the 10,

10 though, because we do see some of the

11 distribution of our homes, because they are

12 larger homes, that get down into the 10, like

13 as you were just discussing. So, maybe 10,

14 12, and 14 is appropriate.

15 MR. HAGERMAN: Could we do the

16 thumbs, 10, 12, 14?

17 All right.

18 MR. RAMIREZ: And 12 is done

19 already, right?

20 MR. HAGERMAN: That's right.

21 MR. RAMIREZ: So, it is just 10,

22 the new ones are 10 and 14.
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1 MS. HOFFMAN: Right.

2 MR. HAGERMAN: Thank you, Emanuel.

3 MS. HOFFMAN: And we should also

4 hear from our remote members.

5 MEMBER EZZO: Thumbs up. Mark

6 Ezzo.

7 MS. HOFFMAN: Okay. We are

8 assuming it is thumbs up.

9 MEMBER LUTER: Rob Luter. Thumbs

10 up.

11 MS. HOFFMAN: Okay.

12 MR. RAMIREZ: Yes, I guess for the

13 future, if your thumb is down --

14 MS. HOFFMAN: Let us know.

15 MR. RAMIREZ: -- let us know. 

16 Otherwise, we will just assume that you are

17 all right.

18 MS. HOFFMAN: But thank you. So,

19 you've got that.

20 MEMBER LUTER: Sure.

21 MS. HOFFMAN: Yes, Eric?

22 MEMBER LACEY: This is Eric.
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1 I have a question for the

2 manufacturers, and this is something I just

3 don't know. In stick-built homes you have

4 quite a bit of flexibility as to the

5 assembling areas, the amount of ceiling area

6 and wall area and everything. And I

7 understand it is going to be a lot more

8 limited. But in a U sub o calculation, you

9 have a base set of assumptions that is based

10 on not just glazing area, but ceiling area and

11 wall area and floor area.

12 Would it be fruitful at all or

13 would it make any difference to test out

14 different areas? Or is there just not that

15 much flexibility in the relative areas of the

16 assemblies? Does that make sense?

17 MEMBER TOMPOS: Dave Tompos.

18 That was the next thing I was

19 going to bring up before we rerun anything, is

20 to talk about some of the limitations that we

21 have.

22 In this analysis, for example,
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1 they are putting an R30 in a floor cavity in

2 some of the higher or northern zones. And

3 there just physically isn't enough room to put

4 an R30 in the floor cavities. Typically,

5 anything 14 wide and less is a 2x6 floor

6 system.

7 And the way these work is you have

8 a metal frame underneath that that helps

9 support it, and then, typically, what a

10 manufacturer does is they put an R11 blanket

11 down, and then, they have R11 bat that goes up

12 into each cavity. And that R11 blanket is

13 going to get compressed in certain areas,

14 because you have the I-beam that is going to

15 get compressed by that. And then, you can't

16 fit -- I think you are going to have a 7-inch

17 space to fit that R22 insulation. So, once

18 you compress that down to 5.5 inches, you end

19 up with about, it is less than 19. I think it

20 is 18.7, in that range.

21 So, those are a couple of things

22 that need to maybe get changed again in this
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1 analysis. I know in the northern zones you

2 have R22 in the current HUD code. That is the

3 insulation that they are putting in there. 

4 But, once it gets compressed, it goes down to

5 about an R18.7. And then, there is just

6 physically no way to get an -- I don't even

7 know if you can do it with foam, which we are

8 hopefully not talking about yet.

9 And even in the IECC, it talks

10 about the maximum value that you can put in. 

11 It calls out in the prescriptive method an

12 R30, but it says, when there are space

13 constraints, you do a minimum of R19. So,

14 even the IECC recognizes some space

15 constraints.

16 So, I think those are two areas

17 that we need to address when we rerun the

18 analysis. You are only going to get about an

19 R19.

20 Now you do have the area in the

21 middle part of the home that you can put more

22 insulation in, but you also have to remember
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1 that we have the supply ducts in that area. 

2 So, there is some compression there, too. But

3 you would be able to get a little more

4 insulation, but I still don't think you are

5 going to get it to an R30.

6 You also have the R30 in the

7 ceiling, which they did recognize there are

8 some constraints there, but there is also

9 going to be some truss configurations that I

10 think it is going to be very difficult to get

11 an R30 in some truss configurations, not to

12 mention cathedrals. It is never going to

13 happen in most cathedral homes. And I don't

14 want to limit construction types in homes.

15 So, those are my several concerns

16 that I think we need to talk about before we

17 rerun any analysis.

18 MEMBER LEVY: Yes, Dave brings up

19 a really important point. And that is that

20 the assumptions that are being used here for

21 the model prejudice the results. And not that

22 these aren't typical; I think they are. You
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1 can make a case for all the assumptions being

2 here. They are fairly typical. These are

3 typical single and multi-section homes where

4 the window area may be 12 or 11 percent, but

5 those aren't big differences.

6 But what Dave is talking about is,

7 if we had started with the assumption, for

8 example, that the ceiling was a cathedral

9 ceiling with a scissor truss, then the ability

10 to get higher insulation levels is really

11 pretty limited.

12 I am not sure it is necessary to

13 look at all those things, all the cases. I

14 think we can identify some sensitivity

15 analyses for specific locations to do that. 

16 But I think we should start putting together

17 a list of the things, like what Dave is

18 talking about, that might cause hardship for

19 anybody who is building a particular design

20 and evaluate those as sensitivity studies.

21 MEMBER EZZO: This is Mark Ezzo.

22 MR. HAGERMAN: This is Joe
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1 Hagerman, Mark.

2 MEMBER EZZO: Go ahead, Joe. Go

3 ahead.

4 MR. HAGERMAN: So, I agree. I

5 mean, this analysis and the inputs here,

6 strictly reading the code, right, they don't

7 have any kind of manufacturability lens over

8 these, right?

9 And we have no problem modeling

10 whatever you want to model. We just need to

11 know what those inputs are. And I don't know

12 if we want to put this not in the parking lot,

13 but if we want to make a list of these, start

14 making a list of these as changes to the

15 inputs, we can. And we just need to do that

16 and assign it to the labs to run the analysis

17 again.

18 So, Mark Weiss first, and then,

19 Mark Ezzo.

20 MEMBER EZZO: Okay.

21 MEMBER WEISS: Thanks, Joe.

22 I have sort of a macro-question
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1 related somewhat to the issue that David

2 raised. And that is, do the costs in this

3 modeling, do the costs include any collateral

4 impacts related to the changes? For example,

5 with respect to air exchange and costs of

6 dealing with impacts to that arising from what

7 you are doing here, if that makes sense?

8 MR. HAGERMAN: These are just

9 straight energy consumption costs. So, what

10 they do is they model the unit and they

11 simulate the unit being occupied for a year. 

12 And they get the annual energy consumption

13 that you would see at the meter. And then,

14 they multiply that by an EIA projection of

15 energy costs.

16 MEMBER WEISS: So, just to be

17 clear, collateral costs such as what I am

18 talking about.

19 MR. HAGERMAN: Right.

20 MEMBER WEISS: Potentially, others

21 are not part of this.

22 MR. HAGERMAN: Yes, it doesn't
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1 assume a cost in terms of price difference of

2 going from R19 bat wall to an R30, no. It

3 just shows you what the meter would see in

4 terms of what people are paying, their utility

5 bill.

6 Mark Ezzo, you had a question?

7 MEMBER EZZO: Yes. The U-values,

8 the component U-values for ceiling, floor, and

9 wall shown in these spreadsheets, I think what

10 it is going to all boil down to is we are

11 going to need to give I think DOE and PNNL

12 some information from the manufacturers' side

13 as to the real reality of those U-factors that

14 are assumed.

15 So, for instance, back to Dave

16 Tompos' point about our R30 in the floor, I am

17 looking on the spreadsheet and it shows the

18 corresponding U-value for that cavity is .034. 

19 So, I guess the question for us manufacturers

20 is, can we put R30 in a floor and get a

21 U-value of .034 with a 2x6 floor and

22 compressed insulation between the I-beam and
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1 the floor framing, and those kinds of things?

2 So, I mean, do we know where these

3 U-values came from? Are there assumptions,

4 are there designs that we can look at that

5 would allow us to determine whether or not we

6 can hit that .034?

7 The same thing with the ceiling, I

8 mean, are there ceiling profiles we could look

9 at for the different R-values for 30 and 38 to

10 see if we can hit those same U-values that are

11 shown in this chart?

12 MEMBER LEVY: Mark, on the

13 spreadsheet it is not apparent, but you can

14 look at the underlying analysis. It will show

15 you what the individual component U-values

16 are.

17 MR. HAGERMAN: That's Emanuel.

18 MEMBER EZZO: I see those, yes.

19 MR. HAGERMAN: Yes, so if you go

20 to Table 1, just quicky go to the handout that

21 I gave everybody, these are printouts from the

22 spreadsheets. And it is kind of hard to go
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1 through spreadsheets as a group, but here we

2 go.

3 If you go to Table 1-A, you see

4 the summary of the code requirements analyzed

5 for manufactured housing. So, you see the map

6 of the IECC climate zones, the HUD zones, and

7 then, what the building components, what the

8 performance specification of all the building

9 components are. And those are the inputs that

10 PNNL used to run their analysis.

11 Now, if you go to -- let's see,

12 where was the 30 in here -- yes, so if you go

13 to IECC Climate Zone 8, HUD Zone 3, you see an

14 R30 in the floor insulation R-values. And I

15 think what David Tompos is saying is that it

16 is not practical in the industry to achieve

17 that.

18 And so --

19 MEMBER EZZO: Right. And -- go

20 ahead.

21 MR. HAGERMAN: Yes, so, Mark, what

22 my suggestion would be is, if you or another,
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1 David or Emanuel, if somebody wants to come up

2 with a Working Group or a subcommittee that

3 annotates this list and says, you know, R30 is

4 impossible, R28 is the maximum or R20 is the

5 maximum we could possibly do for that climate

6 zone, just because of the assembly, I mean, we

7 need to start recording those kinds of

8 conversations and changing these inputs, so we

9 can redo the analysis for you guys.

10 MR. RAMIREZ: Let me ask the

11 group, though, that seems like for us to tie

12 down -- this is Javier -- for us to tie down

13 the time to do that, because it is somewhat

14 technical, is there a subcommittee group that

15 could do that, that could work on that and

16 make those changes, and get them to Joe, so

17 that we could run it?

18 MR. HAGERMAN: Yes.

19 MEMBER EZZO: This is Mark.

20 I think the answer is, yes, I

21 don't think that is really that cumbersome to

22 do.
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1 The spreadsheet I am looking at is

2 the one titled, "PNNL MH Uo Calculator". And

3 so, like, Joe, you were saying from the other

4 file. The one I am looking at, for Zones 7

5 and 8, this shows an R30 floor. The

6 corresponding U-factor is .034.

7 My whole point is, can we as an

8 industry, can manufacturers hit .034, or

9 something close to that, with an R30 floor,

10 based on the way we build them?

11 I think that is Dave Tompos' point

12 also. I mean, recognize you can't get full

13 R30 value out of the floor. I mean, we know

14 that. But really what it boils down to is the

15 U-factor. That is where the calculation comes

16 in. That 30, while it is important, it really

17 doesn't factor into the calculation. The

18 calculation uses the U-factor, which is the

19 assembly, the component, the floor component

20 U-value, right?

21 So, whether you put R20 or R40 in

22 a floor, you are going to come up with a
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1 U-factor that includes the geometry and

2 compression.

3 So, I guess, long story short, us

4 manufacturers, you know, me and Manny and Bert

5 and others, I think we just need to look at

6 these U-values and the R-values that are

7 associated to them, and come back to the

8 Committee and say, "Yes, we can do that" or

9 "No, we can't." Or we come back and say, to

10 put R30 in the floor, you need a 2x10 floor

11 framing.

12 MR. RAMIREZ: So, what timeframe

13 are you looking at on that? How long would it

14 take you to do that?

15 MEMBER EZZO: Well, we have all

16 that data already that we use. So, I don't

17 think it would take long to do at all.

18 MR. RAMIREZ: Okay. Manny?

19 MEMBER EZZO: Manny, do you want

20 to weigh-in?

21 MEMBER SANTANA: Yes. Manny with

22 Cavco.
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1 You know, as far as the

2 constraints of plank construction that have an

3 impact on this, I don't know if we need a

4 Working Group. I think we can just bring out

5 those realities right now. You know, they

6 aren't much.

7 You know, a typical floor

8 construction is 2x6 floor joists. Typically,

9 you have a blanket insulation in the floor, in

10 what we call the belly, which is in between

11 the I-beams, and then, bats on the outside,

12 although some plants do blankets underneath

13 the entire floor.

14 I can only speak to my experience,

15 but in my experience the blankets that are

16 available to our industry come in R7 and R11,

17 and that's it. So, when you need R22, you

18 just put two layers of R11. You know, we

19 don't buy R13. We buy some, but you don't buy

20 a whole lot. You know, there are very few

21 plants that buy R13 for the walls. You know,

22 it is mostly R11, R19. For an R19, as you
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1 know, you need to use 2x6 walls. There is R15

2 available, but it is a lot more expensive than

3 R11 or R19 even.

4 In the ceiling, the physical

5 constraints you have there are all ceilings

6 are built with pre-manufactured trusses. And

7 this truss has a predetermined height at the

8 heel, which is above the side walls. And so,

9 if that is only 5.5 inches, and you need an

10 inch for an air gap, then you only have 4.5

11 effective inches, right? And then, the rate

12 at which that area grows depends on the slope

13 of the ceiling.

14 And so, if you have a singlewide

15 that has a cathedral and you only have 12

16 inches or 18 inches at the ridge and you have

17 5.5 inches at the heel, that doesn't give you

18 a whole lot of room for adding insulation. 

19 So, that is what we have to work with here.

20 And Dave and Mark and everybody

21 made a really good point as to issues they had

22 with the analysis. I don't know how much it
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1 matters to conduct the analysis for the HUD

2 code units' usual actual insulation packages,

3 because I will give you an example.

4 On Table both 1 and 2 of the

5 spreadsheet, for Zone 1 or for Climate Zone

6 1A, the very first line, we are using 13 in

7 the wall, 30 in the ceiling, 30 in the floor. 

8 For that zone, a typical plant would use 14 in

9 the ceiling, 11 in the wall, and 11 in the

10 floor. So, I don't know if we need to model

11 that.

12 MR. RAMIREZ: Could you modify

13 that sheet, so we could give it to Joe? So,

14 that way, he could run that.

15 MEMBER SANTANA: Yes.

16 MR. RAMIREZ: Could you add those

17 numbers in the line there?

18 MS. HOFFMAN: Keith has been

19 trying to say something.

20 MEMBER DENNIS: Yes. Well, I just

21 want to clarify. So, we are talking about the

22 code. You are saying the code says 30. In
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1 reality, there's compressions and there's

2 trusses. So, you can't put 30 in.

3 Is it that, in impracticality, the

4 actual number is less, so it has to be modeled

5 less, but it still meets code if it is less

6 than 30? I guess I don't understand

7 completely the correlation between what we are

8 modeling and what is being put in, what is

9 code.

10 So, I see the code said 30 and 38,

11 but we are saying that 30 and 38 can't be done

12 in reality. So, currently, are they not

13 really meeting these codes or are we just

14 saying that, for modeling purposes, a 30

15 doesn't actually equal 30, so you should put

16 something lower in the model?

17 MEMBER SANTANA: Manny again.

18 So, when you say "code," you are

19 talking about the HUD code or the modeling for

20 the HUD code unit or the modeling for the

21 IECC?

22 MEMBER DENNIS: Yes, I mean, the
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1 ceiling goes up to 30. And somebody mentioned

2 30 in, say, Zone 6A for ceiling wasn't

3 necessarily achievable in the HUD code because

4 of trusses and cathedral ceilings. So, if

5 that is not possible, how do things meet, I

6 guess my question is, how do things meet HUD

7 code now?

8 And then, the floor, you know, it

9 is a 22 here, and I thought I heard you say

10 something along the lines of, while it says

11 22, in actuality, at a plant it would be less

12 than that.

13 So, like how do people meet the

14 codes if in practicality they can't already

15 meet the codes?

16 MEMBER SANTANA: Okay. I think

17 the answer to that is in the HUD code you have

18 to meet a minimum U-value for the entire

19 structure.

20 MEMBER DENNIS: Uh-hum.

21 MEMBER SANTANA: So, then, how you

22 meet that depends on your construction. But
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1 there are no minimum R-values for the floor,

2 the ceiling, or the roof. You just need to

3 meet the U-values.

4 MEMBER DENNIS: Oh, okay.

5 MEMBER SANTANA: Because of

6 performance, exactly.

7 MR. HAGERMAN: Right. This is Joe

8 Hagerman.

9 And that is a little bit of the

10 rub here, right? The rub is the IECC

11 specifies the component values. And so, we

12 are trying to go in between one code that does

13 the component values and the other code that

14 just does the raw U sub o, right?

15 MEMBER SANTANA: Right. Right. 

16 That is why the first analysis that came up

17 from DOE had the component U-values. And

18 then, there was a request to go and ask for

19 the total U-values, so that you can try to

20 compare apples and apples.

21 MR. HAGERMAN: Right. So, that is

22 the main rub here between the two codes,
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1 right? So, that is the one in Joe Hagerman's

2 personal opinion, not speaking for the

3 Department, that this Committee has to

4 resolve, right? Because it is very clear in

5 the legislation, you know, the target is the

6 2015 code which prescribes all the component

7 U-factors. So, that is the problem we have to

8 solve.

9 MR. RAMIREZ: Let's get Michael

10 and, then, David.

11 MEMBER LUBLINER: Okay. So, we

12 build, under our ENERGY STAR manufactured

13 homes programs, we probably build over 100,000

14 homes where we build something attempting to

15 get to R30 in the floor.

16 In the Northwest, some of the

17 homes are built with 2x8 as well as some of

18 the homes are 2x6. So, what I question is,

19 for the industry, what percentage of the homes

20 are 2x8 versus 2x6? But hold off on answering

21 that for a second.

22 When we have a 2x6, we basically
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1 use a number of different approaches to

2 getting the R30. We will put a layer of R11

3 blanket in, like is typically the case. And

4 then, they will put, from the rim to the

5 outrigger, an R21 bat or an R19 bat. If they

6 put an R19 bat in, the nominal insulation

7 level, if you account for no compression, is

8 R30.

9 I think that is a legitimate,

10 reasonable way to get R30, and we can talk

11 about the ramifications it has on the Uo value

12 in the calculation. But that, to me, would be

13 an appropriate way.

14 Another way that we have done it

15 over the years, some of the plants have done

16 it, is take three R11 belly blankets and

17 actually slice at each of the floor joists

18 back, so that the insulation, the belly

19 insulation, comes up.

20 The most important thing is

21 insulating the rim joist, so we don't have a

22 void at the rim joist that is a huge thermal 
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1 bridge, which is what we see all the time,

2 insulation coming down at that point, whether

3 we do it in the factory or with infrared

4 cameras. So, that is another approach, would

5 be to use multiple layers of belly insulation.

6 I think it would also be

7 appropriate, if the industry is transforming

8 to higher levels, to engage the insulation

9 manufacturers in producing higher-density

10 products for belly. I think that is a long11 term goal. I think Manny has articulated that

12 there are some limitations right now with what

13 they have.

14 But the whole issue of high

15 density, if we want to go to R15, you know, in

16 there or R21, our experience has been that you

17 can get the factory to do it.

18 The final way that they will do it

19 is they will put an R11 in the belly, and they

20 will blow loose fill all the way in, and they

21 will do it at a high density. And again, I am

22 talking about between the outrigger and the
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1 rim joist. From there, in the middle you are

2 open; you have got plenty of room. You meet

3 the stats.

4 So, we are talking about a portion

5 of the home for the homes that have 2x6. I

6 think that we could probably just accept that

7 there is some compression. And that belly

8 does pooch down, for lack of a better word,

9 pooch down between the I-beam and the rim

10 joist.

11 So, perhaps if you put an R11 down

12 there and you stick an R30, I mean an R21 in

13 there, you are getting equivalency to R30. 

14 That would be what I would look at for

15 challenging, and that based on 100,000 homes

16 built that way in the Northwest.

17 Thank you.

18 MR. RAMIREZ: David?

19 MEMBER TOMPOS: Dave Tompos.

20 The problem with trying to put an

21 R30 in there, you are going to end up with

22 about, depending on the space of that, you
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1 know, if you are using fiberglass, it is going

2 to be compressed at about 50 percent. And

3 when we do the calculations in HUD, we take

4 all that into account.

5 One of the numbers, the charts in

6 here, you basically, if that is a uniform

7 compression, you can only take 61 percent of

8 that actual R-value. So, we take all that

9 into consideration. The I-codes don't -- I

10 know you are supposed to, but they take an R19

11 and put it in the walls. Even though it does

12 compress in a 5.5-inch cavity, they say it is

13 good. We are a little more regulated and have

14 to meet what the code says.

15 The other point I wanted to make

16 was Mark Ezzo brought up the fact that, well,

17 we may have to go to a 2x10, 2x8 floor system. 

18 My concerns with that would be -- and I know

19 a lot of the manufacturers on this call, I

20 don't know if at all they extend into

21 Connecticut or Massachusetts -- we have some

22 travel height limitations of, in those two
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1 states I believe it is 13'6". And we may not

2 be able to add four inches to height to some

3 of these homes because you won't be able to

4 ship them at all. So, I don't want to limit

5 -- you know, Connecticut and Massachusetts

6 should still be able to buy manufactured

7 homes.

8 MEMBER SANTANA: Yes, just a

9 followup to a statement that Michael made. 

10 You know, I think it is important to identify

11 if on the analysis when we say R-values for

12 walls succeeding a floor, do we talk about

13 installed insulation or the assembly R-value? 

14 Because, you know, he said that you can

15 install R19 insulation, but, then, as a

16 component, you get R30 in the floor.

17 You know, now that is something

18 that needs to be, I guess, understood and

19 accepted. Because a lot of folks, you know,

20 we have to put a certificate of the installed

21 insulation, and it can't be for the assembly

22 or for the component. It has to be just for
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1 the installed insulation.

2 So, when we say R13 or R30 in the

3 floor, are we saying installed insulation or

4 are we saying what the assembly counts out at?

5 MS. HOFFMAN: Okay. Thank you.

6 Mark?

7 MEMBER WEISS: That's okay. I

8 have another general question. Let the

9 technical discussion play out a little bit.

10 MR. RAMIREZ: Well, I just thought

11 that that was, it seems like a key question

12 that we need to get answered there. And Eric

13 may have a response.

14 MEMBER LACEY: I can try to

15 clarify, Manny, that the R-value table that

16 the spreadsheet shows, those are nominal

17 R-values just for the component itself. So,

18 just the insulation R-value.

19 Behind that, I mean, it doesn't

20 tell you what the framing fraction is or any

21 of the other bridging effects or any of that. 

22 It is just kind of the component that you
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1 would buy off the shelf as an R30 or an R19,

2 or so on.

3 Whereas, the U-factor table is the

4 assembly U-factor that includes all of those

5 things, the framing members and everything. 

6 Does that clarify it?

7 MEMBER SANTANA: I saw that in the

8 calc, and I think that is the reason why I

9 brought it up in that. So, when the table has

10 R30, that means we have to install R30. So,

11 we are going to have a tough time physically

12 installing R30 into even 2x8 joists, if it is

13 installed in somebody's --

14 MEMBER LUBLINER: So, you have

15 factories that are doing that in the Northwest

16 right now, that nominal R-value of R30, by

17 putting a layer of R11 and, then, putting an

18 R19 in the joists. And there is some

19 compression at R11 that pooches out. It is

20 not a true R11. That would be accounted for

21 in the calculation with the overall U-value.

22 But when I was talking nominal,
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1 when I was looking at those tables, I was

2 assuming that an R34 would be a 2x6 with one

3 R11 belly and, then, R19. That was my

4 definition of it. And I think you can do that

5 at the factory.

6 MEMBER TOMPOS: Dave Tompos.

7 Michael, one of the things that

8 happens is you have a calculation that is a

9 minimum. Most manufacturers up in the Midwest

10 are exceeding that. So, you can put R50 in

11 the belly, if you want, but we don't really

12 have to do a calculation to show that that

13 meets anything.

14 So, they are meeting the minimum

15 U-value for that overall structure, and then,

16 you can blow in anything you want into the

17 belly. The problem is going to be when we are

18 required to meet an R30 and can't meet that

19 because you can't physically meet that with

20 the size limitations we have and taking

21 compression into effect.

22 MEMBER LUBLINER: So, I think it
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1 gets back to what the definition is. I am

2 talking about a nominal R30 from the I-beam to

3 the outrigger. That is where the issue is. 

4 And what I am suggesting is that, if that is

5 what we are talking about -- that is an R11 in

6 the belly that has got some compression, a

7 belly blanket with another R19 in the cavity

8 -- and if you add that up, that is a nominal

9 R30. And if you went to high-density, like

10 121, which is what we are using in the walls

11 instead of R19, then you would actually exceed

12 that.

13 So, I guess my question would be,

14 Emanuel, I know in the ENERGY STAR homes this

15 is where we are seeing this. Are you seeing

16 that approach to get to the R30 criteria in

17 the ENERGY STAR Homes Program around the

18 country?

19 MEMBER LEVY: Emanuel Levy.

20 I think the issue that is being

21 discussed here is that two different

22 manufacturers can install what some call R30
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1 and come up with two different U-values. And

2 that is the problem we are grappling with

3 here.

4 And I think one of the exercises

5 we are going to have to go through before this

6 is over is to come up with some consensus as

7 to what R30 equates to -- and this is coming

8 back to Mark's point earlier -- what R30

9 equates to as a nominal labeled R-value to a

10 U-value, to a component U-value.

11 Actually, later on in the

12 discussion, I have that as one of the slides

13 that I want to talk about. And I think one of

14 the things we are going to have to do before

15 our process is over is, as a group, have a

16 concurrence about what that is.

17 MR. RAMIREZ: When do we need to

18 do that? Do we need to do that -- is that

19 something that we should do right now?

20 MEMBER LEVY: I don't think we can

21 do it at this session.

22 MR. RAMIREZ: Okay.
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1 MEMBER LEVY: I think what I will

2 suggest later is that we go away, come back

3 with a proposal to put on the table that

4 people can react to, rather than try to debate

5 what the U-value is today.

6 MR. RAMIREZ: Got you. Okay.

7 MR. HAGERMAN: Joe Hagerman.

8 MEMBER KESSLER: This is Bert.

9 MR. HAGERMAN: Go ahead, Bert.

10 MEMBER KESSLER: Bert at Palm

11 Harbor.

12 I happen to have a spreadsheet

13 open right now that does floor U, and I have

14 an R19 bat with an R11 blanket, as Michael

15 suggested, with 2x6 floor joists at 16 on

16 center, 99.5-in I-beam spacing and 164-inch

17 floor bit. And the best U we can get is .042. 

18 But if I change that to a 2x8, it goes to

19 .040. If I go to a 2x10, it goes to .033.

20 Now, as I mentioned, the

21 components used are affected by a number of

22 things, not just floor joist size, but also
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1 I-beam spacing and floor width. But that just

2 gives you an idea of where we are at. We are

3 not even close to .031, I guess it was that

4 was used for the calculations.

5 MEMBER EZZO: .034.

6 MEMBER KESSLER: .034?

7 MR. RAMIREZ: Is there a value to

8 the group in seeing that spreadsheet?

9 MEMBER EZZO: This is Mark Ezzo at

10 Clayton.

11 Yes, Bert is echoing exactly what

12 I brought up initially, in that all this

13 analysis on the PNNL Uo calculator

14 spreadsheet, just for the example of R30, is

15 using a U component in the floor of .034. And

16 you can put a nominal R30 in the floor, but

17 you won't get .034 as the component U-value

18 for the floor.

19 So, where the calculation on this

20 PNNL document is saying that that works, in

21 reality, for us, if we ran that calculation,

22 it would not work.
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1 So, the point I was making is I

2 think we need to provide the DOE the numbers

3 like Bert just showed and say, "Here's the

4 real Uo number for a floor that we are coming

5 up with." Plug those numbers into these

6 tables and see what we come up with.

7 MEMBER LEVY: Mark and Bert, can

8 you get those numbers to Joe then?

9 MEMBER EZZO: Sure.

10 MR. HAGERMAN: Right. So, let's

11 just also not forget the goal here. I mean,

12 the goal is to see how we take what you are

13 doing today and get it closer to the 2015

14 IECC.

15 So, I do believe, Mark,

16 absolutely, we need to see what you are doing

17 today, and then, we need to have a discussion

18 on how we get to the 2015 and what just isn't

19 possible in the 2015, given how you

20 manufacture these units.

21 MEMBER EZZO: Right.

22 MR. HAGERMAN: Right.
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1 MEMBER EZZO: Let me ask one more

2 question. I hate to make this any more

3 complicated than it is, but in the 2015 IECC,

4 and in all previous versions of the Energy

5 Code, it gives you two options for thermal

6 compliance.

7 You know, one is you use a

8 prescriptive table that says put these

9 R-values and use this type of window in your

10 home, and there is no calculation required. 

11 Okay? That is the first table that comes up

12 in the residential section of the Energy Code.

13 So, it tells me, from looking at

14 Zone 7 and 8 for the 2015 Code, it says you

15 don't need to run any calculations. Just make

16 sure you use a window that has got .032. You

17 have got 49 on the roof, 38 in the floor, and

18 what in the wall? Twenty in the wall with an

19 R5 insulation wrap.

20 And then, there are footnotes that

21 say, in lieu of the 38 floor, I can fill the

22 full-depth cavity of R19, which is really
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1 helpful. That is one way to do it, and

2 there's no calculation. There is no U-factor. 

3 I am not having to do a component calculation

4 for the geometry in my truss or compression in

5 my floor. So, that is one method.

6 And then, the second method that

7 the IECC gives us is what we are talking about

8 here. And that is using U-factors for all

9 these components. And we haven't in this

10 Committee talked at all about the first

11 method.

12 So, I am just kind of throwing

13 that out there to the group, that there is

14 another way that this is being accomplished in

15 the IECC Code that we haven't talked about.

16 MS. HOFFMAN: Eric?

17 MEMBER LACEY: Yes, this is Eric

18 Lacey.

19 I am going to be talking in just a

20 little bit about the different compliance

21 options in the IECC and how they might match

22 up or not match up with what is going on at
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1 HUD. And I think I will answer some of those

2 questions that you have.

3 MEMBER EZZO: Okay. Cool. All

4 right.

5 MEMBER LACEY: Or you can ask them

6 again if I don't.

7 (Laughter.)

8 MS. HOFFMAN: No. Great.

9 And in terms of this discussion,

10 there was a question that Joe raised which

11 was, what kind of data or questions needed to

12 be answered in research. Is that something

13 that can be done now, which is what Javier was

14 asking? Could it be done by the end of the

15 day or by tomorrow in terms of our timeframe?

16 MR. RAMIREZ: One of them was I

17 heard that Manny was going to get them some

18 numbers and modify the list.

19 MS. HOFFMAN: Okay.

20 MR. RAMIREZ: And then, the other

21 thing, Mark and Bert were going to submit at

22 least the numbers that they have, I guess show
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1 what is the current place of what they can or

2 can't do.

3 But are there any additional

4 numbers?

5 MR. HAGERMAN: This is Joe

6 Hagerman, DOE.

7 Let me just recap on what I think

8 I am going to instruct the team to do because

9 it is very similar to what you just said.

10 MR. RAMIREZ: Okay.

11 MR. HAGERMAN: So, the first set

12 of analysis they are going to run is changing

13 the glazing area from 10 to 12 to 14. All

14 right? We discussed that and closed that one

15 out already.

16 The second analysis I think we are

17 asking them to run is Manny and potentially

18 some other people are going to give us what

19 the industry I believe is already

20 manufacturing component-by-component. 

21 Correct? And so, we will have that as the new

22 HUD baseline, as to what manufacturers are
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1 actually producing. Right?

2 We have not yet discussed what I

3 think we are all trying to drive to, which is,

4 how does that change to get to the 2015 IECC? 

5 We don't yet have a proposal of me doing any

6 analysis there.

7 I can say the team is doing

8 analysis right now for a question that Robin

9 Roy asked where they are modeling, just like

10 they have modeled here, an ENERGY STAR home,

11 which we should get that tomorrow, hopefully.

12 MS. HOFFMAN: And I wanted to ask

13 David and Manny, can you help give that data

14 then, those questions?

15 MR. RAMIREZ: What kind of

16 timeframe are you looking at on that? Is that

17 something that you can get them by the end of

18 today or is that a bit more intensive?

19 MEMBER SANTANA: I can get that by

20 the end of today.

21 MR. RAMIREZ: Excellent. Okay. 

22 Great.
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1 And then, Mark --

2 MEMBER SANTANA: But I will add --

3 this is Manny -- I will add that is only going

4 to come from one manufacturer.

5 MS. HOFFMAN: Right.

6 MEMBER SANTANA: You know, there

7 are different construction practices.

8 MS. HOFFMAN: So, also there are

9 some folks remotely. Was it Mark Ezzo? Oh,

10 so Emanuel will get to it.

11 MR. HAGERMAN: Yes, Emanuel says

12 he is going to get to this later.

13 MS. HOFFMAN: Okay.

14 MR. HAGERMAN: So, our discussion

15 right now might be trumpeted by --

16 MS. HOFFMAN: Okay.

17 MR. RAMIREZ: Yes, some of it I

18 know that it seemed like, I knew that Eric was

19 going to be getting to. I guess the question

20 I would have for you all, is that something

21 that we want to move on to?

22 Joe, did you have any other slides
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1 that you needed to show for today?

2 MR. HAGERMAN: So, I have a couple

3 more slides, but I think the conversation has

4 preempted these slides.

5 MR. RAMIREZ: Okay.

6 MR. HAGERMAN: So, everything that

7 we have discussed is past what is on the

8 screen here.

9 MR. RAMIREZ: Okay. Well, Mark

10 has been really patient, and I want to make

11 sure that I get there. I appreciate that

12 because it seems like they are on a roll here

13 with that conversation.

14 So, Mark?

15 MEMBER WEISS: Well, when I am

16 patient, it is probably because I have a

17 question I am not sure about.

18 MS. HOFFMAN: Oh.

19 MEMBER WEISS: It is safe to

20 assume that this modeling software we are

21 talking about here -- and you might have

22 addressed this last week to some extent. I
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1 mean, this was not developed specifically for

2 manufactured housing. Okay. What is it

3 developed for? Is this generic residential

4 single -- okay, what is it then?

5 MR. HAGERMAN: Yes, and I can get

6 you the background on EnergyPlus, the

7 calculator that is used here. It is a

8 physics-based model for any kind of building

9 simulation. So, it can do annual energy,

10 interval meter energy usage of a building. It

11 is referenced in just about every code as the

12 de facto energy modeling software. And I can

13 get you a cutsheet on what that means and

14 where it is referenced.

15 MR. RAMIREZ: Okay, Luby? Oh, I'm

16 sorry. Robin?

17 MEMBER ROY: Robin Roy.

18 It is just a clarifying question. 

19 The Uo spreadsheet that you sent out, which is

20 I think the core of what we are talking about

21 here, that it doesn't necessarily calculate

22 these San Louis values quite right.
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1 It is referencing another

2 spreadsheet, is that right, that we don't have

3 access to? It might be useful to see that

4 because I think what Bert is talking about and

5 what Mark Ezzo is talking about is their own

6 calculators that are trying to fill in the

7 role that is played by the floor calcs

8 spreadsheet, which is referenced by the Uo

9 spreadsheet. It would be very nice to have

10 that.

11 It might be even easier for Bert

12 and Mark Ezzo to riff off of that than to come

13 up with their own, have to supply their own

14 proprietary software for us to look at.

15 MR. HAGERMAN: Right. This is Joe

16 Hagerman.

17 Absolutely. I think there are

18 some hidden tabs here, just doing some

19 simple -- yes, but I don't know if you have

20 access to them or not. But I will get with

21 them and give you access to everything.

22 Yes, Emanuel says he can see them. 
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1 I think they are just doing calculations.

2 MR. RAMIREZ: Yes. So, Rob will

3 take a second and see if they are actually

4 there.

5 Mark?

6 MEMBER WEISS: Yes, and just to

7 follow up, the reason for asking that

8 question, the reason is, you know,

9 manufactured housing is a unique product. It

10 is different from other types of housing. It

11 is a unique product, and it serves a unique

12 function. So, that is why I am asking about

13 where this modeling comes from.

14 MR. HAGERMAN: No, and I

15 appreciate that question. The software that

16 we use is, like I said, a physics-based model. 

17 So, we still think the laws of physics apply

18 to manufactured housing.

19 MS. HOFFMAN: It might be a good

20 time to have a break, if we have come to a

21 conclusion for this part of the discussion,

22 because on our agenda I think we have that,
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1 yes.

2 MR. HAGERMAN: Well, we have not

3 gone over the life cycle.

4 MS. HOFFMAN: Oh, okay.

5 MR. HAGERMAN: So, remember, we

6 said in the last meeting that we were going to

7 put together a life-cycle cost spreadsheet. 

8 And so, Matthew from Navigant has been putting

9 that together for everybody.

10 MS. HOFFMAN: Oh.

11 MR. HAGERMAN: So, I wanted him to

12 stand up and kind of talk through what he has

13 been doing to put that spreadsheet together.

14 MS. HOFFMAN: Okay, fine.

15 MR. HAGERMAN: And hopefully, we

16 will get that spreadsheet possibly by next

17 week. It ties into the previous spreadsheets

18 you have seen.

19 So, Matthew?

20 MR. WALKER: Okay. So, my name is

21 Matthew Walker, and I work for Navigant

22 Consulting.
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1 I will be providing some of the

2 technical support on the life-cycle cost

3 analysis for this Working Group and for Joe.

4 So, we will try to be brief, but

5 this first slide gives an overview of what the

6 life-cycle cost analysis is all about. Life7 cycle cost represents the full cost of

8 ownership for a single consumer. So, it is

9 generally a summation of every monetary

10 payment that is made over the life of owning

11 that particular home.

12 The current analysis, the way I

13 have been developing it is that it focuses on

14 the incremental costs associated with adopting

15 the more efficient measures. It has the

16 advantage of us being able to avoid pricing

17 out carpet or sink fixtures and showers that

18 aren't affected by the energy efficiency

19 regulation. So, in the end, we have a life20 cycle cost savings associated with a

21 difference in the cost of operation of homes

22 of different efficiency.
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1 So, the green figure just gives a

2 general overview of the calculation,

3 algorithm. It is basically looking at the

4 first cost or the housing purchase relative to

5 the operating expenses or your energy costs

6 and potentially maintenance. And that is

7 something we can talk about. And then, both

8 of those components are brought down to a

9 present value, so that you can compare all of

10 those monetary payments on an apples-to-apples

11 basis.

12 Then, the figure on the right is

13 something that we saw last time, two weeks

14 ago. Emanuel drew it up on the board, and it

15 is the best explanation of how to interpret

16 the LCC results. So, I will just go through

17 it real quick again.

18 In the figure, we have life-cycle

19 cost on the vertical axis, and on the

20 horizontal axis, efficiencies. So, as you

21 move to the right, efficiency increases. As

22 you move to the right, energy use decreases
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1 and, also, your use of o is decreasing as we

2 move to the right.

3 So, you figure a HUD code as kind

4 of your starting point. And as you move to

5 the right, you are purchasing a more efficient

6 home. But, as represented by the green dot,

7 the energy cost savings are enough to offset

8 that investment in the more efficient home. 

9 And that continues down to the red point where

10 you have maximized your savings. But you can

11 actually continue past that point, and you can

12 continue buying more and more efficient homes. 

13 And there may be a few models, such as the

14 blue home, where you continue to save money,

15 just not as much as with that maximum savings

16 red home.

17 And then, you can actually push

18 the envelope so far that you shoot off the end

19 and you are off that purple dot where you have

20 sort of maxed-out; you have bought this space21 age home and there is just no way for the

22 operating cost savings to offset that
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1 investment. So, we would certainly say that

2 that purple home is not cost-effective

3 relative to the yellow starting point.

4 Are there any questions on this

5 slide before we keep going?

6 (No response.)

7 No?

8 And just an update on the status

9 of the model itself. Basically, calculations

10 are in place; the structure is in place. The

11 biggest thing that is missing is the cost data

12 associated with those aims, energy-efficiency

13 measures.

14 Mark?

15 MEMBER WEISS: If you could walk

16 me through how the analysis deals with someone

17 who is priced out of the market based on these

18 increased first costs, the increased cost to

19 purchase?

20 MR. WALKER: Right. And I can say

21 to that, real briefly, basically, the life22 cycle cost analysis doesn't address the
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1 concern you are speaking to. So, that would

2 be a separate layer, a separate layer to talk

3 about sort of that elasticity of demand of the

4 consumer that just is unable, is no longer

5 going to purchase based on a change in price.

6 I would say that there is a

7 component of affordability in the discount

8 rate that is selected for bringing those

9 future energy cost savings down to the present

10 level, but I realize it is not the full

11 picture that you are talking about.

12 MEMBER WEISS: Okay. Thanks.

13 MR. WALKER: Yes.

14 MEMBER TOMPOS: Dave Tompos from

15 NTA.

16 When we say "life cycle," is that

17 the entire life? What are you assuming is the

18 life of the home? And is that for every

19 homeowner? Are we assuming they own the home

20 for that length of time? Or are you assuming

21 like an average seven-year ownership?

22 MR. WALKER: Right. So, I mean,
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1 that is a great question. That is an

2 assumption that has to be decided on for this

3 analysis.

4 I mean, I will say, traditionally,

5 in sort of DOE's world in these times of

6 rulemakings, we might look at a period of

7 something like 30 years. We also might look

8 at a period of until the house falls apart and

9 is no longer usable. But this is a decision

10 that can be made, and it is an important

11 decision because it does affect that life12 cycle cost value and where you might fall on

13 this plot.

14 So, that is a decision that can be

15 made, and I think it may be something that

16 Emanuel reviews later with the framework for

17 the term sheet, and I also have a slide on it

18 coming up soon.

19 MR. HAGERMAN: This is Joe

20 Hagerman.

21 You know, all these models have

22 inputs, right, and assumptions. And that is
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1 one of the important assumptions and inputs

2 that the group here is going to have to decide

3 on, right, and talk to.

4 MEMBER LEVY: I have a question. 

5 Emanuel Levy.

6 Let me mention the 800-pound

7 gorilla in the room. When you discover that

8 the IECC 2015 does not lie on the cost curve,

9 is not the bottom point on the curve, and it

10 is not cost-effective, which we most generally

11 will discover that, or at least for some

12 cases --

13 MR. WALKER: Okay.

14 MEMBER LEVY: -- what is our

15 solution? You know, where do we go from

16 there?

17 MR. HAGERMAN: So, let me speak to

18 that. This is Joe Hagerman.

19 So, that is a great point. In the

20 ICC Code as developed through their own

21 process where people come and decide on what

22 the reasonable person should do when they
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1 build something, right, they do not run any

2 type of life-cycle analysis on those

3 provisions before they issue their code,

4 right.

5 So, absolutely, I think you are

6 right. I think that is the point where we

7 depart from meeting the 2015 code, and we

8 either ratchet things up or we ratchet things

9 down because of the results of the life cycle.

10 Does that make sense?

11 Because, remember, the statute

12 says meet the 2015 wherever you can, but not

13 when it is not cost-effective, right? It is

14 pretty clear.

15 That is one of the ongoing issues

16 that this group is going to have to decide,

17 right?

18 MEMBER LEVY: Yes, and I was

19 hoping you would go there, Joe, because I

20 think the question to the Committee really is,

21 when it is "less than," what does that mean in

22 terms of what we are recommending? And if it
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1 is "more than," is that appropriate? Is it

2 appropriate that we go beyond, this Committee

3 consider going beyond the 2015? To me, that

4 is one of the key questions that this

5 Committee is going to have to deal with today

6 or at some point in the near future.

7 MR. HAGERMAN: Okay. Luby?

8 MEMBER LUBLINER: Yes, a scoping

9 question on the life-cycle cost analysis.

10 Mike Lubliner here.

11 I work on the Manufactured Housing

12 Consensus Committee with some of my

13 counterparts here. And we had made some

14 proposals to the Committee to consider ENERGY

15 STAR appliances and ENERGY STAR HVAC and

16 ENERGY STAR lighting and water heating. Those

17 proposals were rejected by the Consensus

18 Committee with the justification that DOE was

19 going to be addressing that.

20 I just want to make it clear that

21 I am not seeing anything in those areas being

22 addressed by DOE now, whether that is good,
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1 bad, you know. So, my question really is,

2 will the life-cycle cost analysis consider

3 anything besides the shell measures, as we are

4 seeing so far?

5 MR. HAGERMAN: So, I believe Eric

6 is going to describe some different paths by

7 which you can meet code levels, right? I

8 would assume that one of those paths may take

9 into consideration higher-efficiency

10 appliances --

11 MEMBER LUBLINER: Okay, great.

12 MR. HAGERMAN: -- as potentially

13 like tradeoffs.

14 MEMBER LUBLINER: Excellent.

15 MR. HAGERMAN: That is how I would

16 imagine it being --

17 MEMBER LUBLINER: But this

18 particular analysis --

19 MR. HAGERMAN: This does not.

20 MEMBER LUBLINER: Does not. 

21 Thanks. It is just for clarification.

22 MR. HAGERMAN: It is going to
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1 assume the federal minimum appliances.

2 MEMBER LUBLINER: Right. And so,

3 then, a question for legal counsel would be,

4 does DOE have the authority beyond -- my

5 understanding is that the NAECA does not apply

6 to the federal government. It only applies to

7 States.

8 So, I would like to seek

9 clarification as to whether you have the

10 authority to do that at some point. And I

11 don't want to hold the process up or the ASRAC

12 up on that. I would just like to be clear on

13 that.

14 MR. HAGERMAN: All right. We will

15 look into that, but --

16 MEMBER LUBLINER: Thank you.

17 MR. HAGERMAN: -- I would bring

18 your question and your comments back up maybe

19 as Eric talks about what he is going to talk

20 about, because I believe there are alternative

21 paths to meeting the code that might address

22 your concerns.
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1 MEMBER LUBLINER: Excellent. 

2 Thank you.

3 MR. RAMIREZ: John?

4 MEMBER CASKEY: Yes, John Caskey,

5 NEMA.

6 So, I understand your simplified

7 model here and the purple dot that says that

8 doesn't appear cost-effective.

9 MR. WALKER: Sure.

10 MEMBER CASKEY: Where does the

11 projected age of the product itself or the

12 lifetime of the product fit into this? At

13 some point the payback could be so long or the

14 life-cycle cost, the value of the life-cycle

15 cost really could be out beyond the life of

16 the product itself. I mean, how do you take

17 that into account?

18 MR. WALKER: Well, I guess a

19 payback period can be calculated. So, that

20 would tell you the number of years it takes

21 for you to recoup that investment, and then,

22 after that, you would begin to realize those
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1 savings. And we can compare that to the

2 actual lifetime -- or I guess "lifetime" is

3 probably not the right word to use -- the

4 amount of time a consumer spends in that home,

5 to see whether or not we think those two

6 numbers work well together.

7 MEMBER CASKEY: Okay. Well, there

8 is both the average time that Consumer A

9 spends in a home, but, then, there is also at

10 some point the home itself may deteriorate to

11 the point of not being usable anymore. So, we

12 certainly don't want the simple payback to

13 stretch out beyond the lifetime of the product

14 itself.

15 MR. WALKER: Right. Yes, I think

16 you're right.

17 MR. HAGERMAN: This is Joe

18 Hagerman.

19 MEMBER CASKEY: So, I just want to

20 make sure that is taken into account. I mean,

21 looking at life-cycle cost is one thing, but

22 you also need to make sure you are not
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1 exceeding the lifetime of the product.

2 MR. HAGERMAN: This is Joe

3 Hagerman.

4 I agree with you, and I think that

5 some of the energy-efficiency measures are

6 going to have different lifetimes than the

7 other efficiency measures, right? And then,

8 we are looking at a grouping of efficiency

9 measures that have different lives to them.

10 So, we will have to weigh that. 

11 The group will have to weigh that as they

12 think through how they come up with the life

13 of each efficiency measure and, then, the life

14 of the house itself.

15 MR. WALKER: All right, I will

16 move on.

17 So, this next slide just gives an

18 overview of some of the financial parameters

19 that go into the calculation. And these are

20 really critical. We have already touched on

21 one, the analysis period or lifetime. Yes, so

22 it is very critical for calculating the
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1 tradeoffs between the first cost and the

2 operating expenses.

3 I won't go through all of them,

4 but I think a couple of them are interesting

5 or would be worth talking about.

6 So, the discount rate is a

7 representation of the time value of money or

8 the opportunity cost that the consumer has as

9 they weigh purchasing more efficient measures

10 versus paying off consumer debts, retirement

11 investments, perhaps even a mortgage itself.

12 So, that discount rate is used to

13 bring those future energy costs down to the

14 present-day value. It has the effect of sort

15 of, a larger discount rate has the effect of

16 diminishing the impact of future energy cost

17 savings.

18 So, then, the analysis period or

19 the lifetime of the product, that is the

20 amount of time over which the LCC calculation

21 is going to capture those operating expenses

22 or capture those energy cost savings. So,
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1 generally, a longer analysis period would

2 allow you to capture more savings and

3 potentially have a better opportunity of

4 offsetting those first costs.

5 Then, we have some kind of

6 standard items here: mortgage interest,

7 downpayments, taxes. I think I should just

8 hit the fuel escalation rate. That is

9 basically a forecast of how electricity or gas

10 prices are going to change over time, and that

11 allows the analysis to apply a more

12 appropriate cost value to energy expenditures

13 further out in the future rather than just

14 assuming the 2013 or current-year prices

15 persist.

16 So, all of these values here are

17 things that need to be agreed upon and

18 consensus would have to be reached.

19 Go ahead.

20 MEMBER WEISS: Mark Weiss, MHARR.

21 Based on your prior answer, I take

22 it that these parameters don't take into
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1 account what I would call the societal cost of

2 exclusion of significant numbers of lower3 income people from homeownership, the only

4 homeownership they can afford. Is that

5 correct?

6 MR. WALKER: That is correct.

7 MR. HAGERMAN: Hold on.

8 So, that is correct in this

9 analysis --

10 MR. WALKER: Right.

11 MR. HAGERMAN: -- but there is

12 other analysis that take that into

13 consideration, just like the previous

14 discussion on the Uo values don't take into

15 account your concern, right? But your concern

16 will be addressed in other analysis. Does

17 that make sense?

18 Yes, the analyses are siloed by

19 design, right?

20 MEMBER WEISS: Okay. That's fine. 

21 I will be waiting. Thanks.

22 MR. WALKER: Great. Well, I will
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1 move on.

2 MR. RAMIREZ: Do you have a

3 question? Okay.

4 MR. WALKER: So, then, just a

5 little bit more on the first cost. First

6 cost, I am using the term loosely here. It is

7 associated with the housing purchase. Now in

8 manufactured homes generally you have a loan

9 and you pay for that home over time. So, it

10 is not really first cost. It is costs

11 associated with the housing purchase. And

12 that is a category of costs that can be sort

13 of weighed against the savings that you get

14 from your energy cost savings.

15 So, the energy-efficiency measures

16 analyzed will need to be assigned costs. We

17 were just talking about that a couple of

18 minutes ago.

19 LCC calculates things on a retail20 level pricing rather than manufacturer costs. 

21 So, we have to be sure that those prices

22 represent what the end-use consumer is paying.
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1 And then, just two kind of

2 secondary-order type effects that could

3 potentially happen, these bottom two bullets. 

4 It is possible that the energy-efficiency

5 requirements could change the size

6 requirements of heating and cooling equipment,

7 which could come with some sort of savings. 

8 I think that could be a topic for discussion

9 at a later time, but it would be something

10 that would need to be decided upon.

11 And similarly, the energy12 efficiency requirements could change the

13 installation cost. I think that was something

14 that Dave was talking about earlier with

15 changing the height of the home and, then, no

16 longer being able, perhaps not even actually

17 being able to ship the home. But perhaps in

18 other cases you might have to pay extra money

19 for different permits or different safety

20 requirements to ship a different sized home.

21 So, these are all items that would

22 go into this first cost category. And all of
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1 these things are the things that the Working

2 Group will need to decide upon.

3 And I am finished.

4 Yes, Mark, do you have a question?

5 MEMBER WEISS: Yes, going back to

6 my earlier question, does this take into

7 account what I would call collateral impacts

8 of tightening the home related to air

9 exchange, condensation, moisture, those sorts

10 of issues?

11 MR. WALKER: Yes, it does. So,

12 when analyzing the cost of implementing some

13 sort of energy-efficiency measure, it needs to

14 capture every cost associated with the

15 installation of that new design. It is not

16 literally the piece of foam that you stick to

17 it. It is also the system effects that

18 sticking in that piece of insulation has.

19 So, I think that the things that

20 you were talking about would be captured by,

21 need to be captured by this analysis, yes.

22 MR. HAGERMAN: This is Joe
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1 Hagerman.

2 And likewise, I think as we talk

3 about energy-efficiency measures and all the

4 analysis that we are going to do, you need to

5 bring all those technical points up. I mean,

6 I don't think that this group is trying to

7 recommend an end-product that would do harm to

8 the people that live in the product, right? 

9 And that is why you all are here. You all are

10 experts in manufactured housing.

11 MEMBER LEVY: That was very good. 

12 Can we go back to the previous slide just a

13 second?

14 MR. WALKER: Sure.

15 MEMBER LEVY: There was a sense to

16 be studied, done about 10 years ago, but I

17 suspect there is also going to be -- 20 years

18 ago, right -- I suspect the results will be

19 the same. And it looked at what changing

20 these values, what impact it had on the

21 U-value. So, which of these things are

22 important and by what amount?
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1 For example, if within a

2 reasonable range of discount rate, your very

3 first item, that discount rate could change

4 the use of o-value, depending on what we

5 choose, by something like 20 percent, just by

6 deciding what, you know, for us to decide what

7 the discount rate is, one view might be

8 different than another, and that would change

9 the use of o-value by 20 percent. That is

10 probably one of the biggest impacts.

11 What is not up here is the

12 inflation rate, which is probably buried into

13 some of these other factors. If we brought

14 that out, that could also be an important

15 factor.

16 But there are a couple, like the

17 cost of the measures, even the property tax

18 rate, the fuel escalation rate, which are the

19 most important ones. And I am suggesting that

20 that is where we focus our attention when we

21 have discussion about what these values should

22 be.
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1 MR. WALKER: Great.

2 All right. So, I will move on to

3 the operating expenses. Operating expenses

4 are calculated on an annual basis. They are

5 discounted to the present year, so that they

6 can be balanced against the first cost.

7 The major operating expense is the

8 annual energy cost. That is what is being

9 affected by adopting different energy10 efficiency measures or different codes. And

11 that energy cost is calculated with the

12 EnergyPlus results along with these EIA fuel

13 cost pieces of data. So, electricity prices,

14 natural gas, propane.

15 And then, it is possible that

16 there could be maintenance costs associated

17 with the usage of different energy-efficient

18 measures. I think this is another place for

19 discussion. This may or may not be

20 applicable. That is certainly a topic that

21 the Working Group will need to agree upon

22 during this process.
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1 And this is my final slide on LCC. 

2 Some other assumptions. So, I guess when an

3 LCC is calculated, it is going to be

4 calculated on a very specific customer. It is

5 an analysis on an individual consumer. So,

6 that customer may have a very specific heating

7 and cooling equipment type, perhaps electric

8 resistance. They may use real estate rather

9 than personal property loans. They may have

10 purchased a single-section home versus a

11 multi-section. So, the LCC is calculated on

12 one particular set of those categories.

13 It can be interesting to aggregate

14 those categories. In order to do that, we

15 need to agree upon the percentage of customers

16 that use each of these types or that fall in

17 each of these categories. And that can

18 actually vary by climate zone, depending on

19 how much detail is necessary to specify some

20 of these things.

21 I think, in particular, the first

22 bullet has a lot of unknowns. I think there
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1 is better data available on the types of loans

2 currently being used as well as the single and

3 multi-section shipments.

4 But all of these will be important

5 pieces of data to collect and agree upon

6 during this process.

7 So, if there are any more

8 questions, we can talk about them here. 

9 Otherwise, I will hand the time back over to

10 somebody else.

11 (No response.)

12 All right. Well, thanks.

13 MEMBER CASKEY: Yes, John Caskey,

14 NEMA.

15 So, you are saying at some point

16 this group needs to agree upon those

17 percentages and different types of heating and

18 cooling systems and things like that. I mean,

19 do you have a proposal that you will offer the

20 group to say that, from your research, the

21 answer is "X" and just for this group to bless

22 it? Or how do you expect to proceed to get
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1 that answer?

2 MR. WALKER: I mean, I think that

3 is a possibility. I would kind of defer to

4 Joe on the direction that we take with that. 

5 But it is certainly something that we could

6 think about.

7 Joe?

8 MR. HAGERMAN: Yes, I think our

9 normal course of action would be to ask the

10 group first, right, for a proposal. And then,

11 absent a proposal, we would go get the

12 information however we could, right. If the

13 industry says, "Yes, this is the shipment data

14 and here's what we see going in the homes," we

15 would use that wherever possible, if we could

16 see the source of everything.

17 Does that make sense?

18 MEMBER CASKEY: It makes sense,

19 but each of the manufacturers may have a

20 different answer to that --

21 MR. HAGERMAN: Sure.

22 MEMBER CASKEY: -- question. And
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1 I have thought, you know, when I have had to

2 do other research on other issues, I have gone

3 to EIA data and gone to other industry data

4 and found it fairly easily. I just don't want

5 the group to waste too much time or get bogged

6 down --

7 MR. HAGERMAN: Yes.

8 MEMBER CASKEY: -- with everyone

9 providing their own numbers and, then, trying

10 to aggregate that, as opposed to somebody

11 independent doing the research and coming back

12 and say, "I think `X' percent of propane, `X'

13 percent of electric resistance, `X' percent or

14 `Y' percent or heat pumps," or whatever.

15 I mean, it is up to the group. If

16 the group is happy with providing that data

17 and helping arrive at that answer, that is

18 great. If they want you to provide a

19 proposal, then that is fine with me, too.

20 MR. HAGERMAN: Yes, I just want to

21 stress again that this is a consensus group

22 for you, for all the members, right? I mean,
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1 we are trying to get this group of people to

2 come to consensus on these standards, right? 

3 And DOE is here to help; we are just another

4 member at the table.

5 MR. RAMIREZ: One thing at least

6 that I am observing is that we have a lot of

7 technical people in the room, and I think the

8 little bit that I am observing already is that

9 it is easy to get bogged down by just certain

10 little components, right? And we are not, at

11 least the way I understand it, we are not

12 necessarily looking at and trying to go

13 component-by-component and trying to say that

14 this is exactly what we need to be doing. It

15 is in the context of an overall efficiency. 

16 Is that accurate? It is the overall

17 efficiency?

18 MR. HAGERMAN: So, you should wait

19 until Eric talks, I think.

20 (Laughter.)

21 MS. HOFFMAN: Okay. Yes.

22 MR. HAGERMAN: It is kind of a
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1 complex thing here, right?

2 MS. HOFFMAN: Yes.

3 MR. HAGERMAN: There is the

4 individual efficiency of each measure and

5 each --

6 MS. HOFFMAN: Measure, yes.

7 MR. RAMIREZ: Well, there's

8 minimums, but overall we need to hit a certain

9 mark.

10 MR. HAGERMAN: And then, there is

11 an evolvement.

12 MR. RAMIREZ: Okay.

13 MR. HAGERMAN: So, it is a go14 between the two.

15 MR. RAMIREZ: And it could be

16 daunting if you look at it. I don't know if

17 you ever heard the term "How do you eat an

18 elephant?" "One bite at a time." Right?

19 And I don't think that we are

20 going to be able to swallow this thing whole. 

21 And I think that is some of the portion we are

22 looking at that Emanuel is going to be walking
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1 through the solution later. And he started

2 off with a portion of it. Let's look at that.

3 And I think that goes to what you

4 are talking about, John, is that there is a

5 strawman. And I had to get really comfortable

6 with that term of strawman. I think of it

7 more like a straw house. We are going to get

8 to a beautiful home when we are done, right? 

9 That initial straw house, is it going to

10 easily be blown down? And that is okay,

11 right? That is the purpose of it.

12 The whole idea is to get something

13 out there. So, that way, we can say, all

14 right, this is a good place to start talking. 

15 Some of these pieces we could easily agree to,

16 but these other ones, fine, let's have a

17 discussion, right?

18 And then, we will revise it again. 

19 There is a stick house, right? And then, we

20 get to the beautiful manufactured house at the

21 end that everyone is happy with, right?

22 So, with that, are there any
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1 questions? Yes, go ahead.

2 MEMBER LUBLINER: So, I had a

3 question regarding the analysis. Could you go

4 back to the variables, that first slide? Yes.

5 So, in reality, what you have is a

6 distribution of each of these variables. You

7 have a distribution of people's discount

8 rates, maybe not the analysis period. You

9 have mortgage interest. The variables that

10 Emanuel was talking about are the most

11 important ones. There is a distribution.

12 I have seen from past abstract

13 analysis of appliances and things the way you

14 handle the distribution in the life-cycle cost

15 analysis is really important in terms of what

16 results you get. For example, do you just

17 take the average of each or do you provide

18 some sort of Monte Carlo, crystal-ball

19 analysis which I have seen used in the past

20 for standards?

21 What is the intent here? Are you

22 going to be doing just a simple averaging or
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1 are you going to be doing what has been done

2 by other standards where you take the

3 distribution of each of the inputs and see

4 what the implications are?

5 It can be very helpful in

6 determining where the winners and the losers

7 are in terms of affordable housing that you

8 don't get necessarily when you do the

9 averaging. So, it is a question, what is the

10 data that we are going to use in terms of the

11 analysis approach?

12 MR. WALKER: Right. Well, I mean,

13 I have presented primarily here today on the

14 average value approach. I sort of began to

15 allude to the idea or the notion of customers

16 having different impacts that are on that last

17 slide.

18 I think this is something where

19 the Working Group can provide some input as to

20 whether or not you would like for time to be

21 spent pursuing the Monte Carlo approach, which

22 is something that I am aware of.
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1 MEMBER LUBLINER: That would be my

2 personal preference because I think it shows

3 us more who the winners and the losers are,

4 and it might afford some problem-solving in

5 working things out.

6 MR. RAMIREZ: I'm a little

7 hesitant in asking this question because I

8 don't know how long the answer is. What is

9 the Monte Carlo approach?

10 MS. HOFFMAN: Winners and losers.

11 Go ahead.

12 MEMBER LUBLINER: So, I am not a

13 statistician, so correct me if I am wrong

14 here. But it is considering that all the

15 distribution of a variable, when you are

16 applying it to another variable, doing a life17 cycle cost, and understanding that it is not

18 just the average discount rate, but a

19 distribution of discount rates that are, then,

20 applied to the distribution of fuel types.

21 And so, it is a process that gets

22 you a better understanding of where the
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1 winners and the losers are. And it has been

2 historically used, as I understand, for the

3 setting of appliance efficiency standards by

4 ASRAC. So, I am wondering if you are using

5 the same protocols in this Committee as we

6 have historically.

7 MR. RAMIREZ: And I think the

8 answer is let us know, right?

9 (Laughter.)

10 We all need to be on the same page

11 on what we are doing. Okay.

12 MS. HOFFMAN: Yes, we have an

13 ASRAC member representative as well. So,

14 John, if you want to address it now or later?

15 MEMBER CASKEY: My look may appear

16 that I am a little bit dumbfounded, and I am. 

17 I mean, I agree that there is a spread of

18 answers for each of these terms that you are

19 talking about here. Certainly, the analysis

20 needs to take that spread into account. I

21 don't know that anybody here is prepared to

22 say what that spread looks like.
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1 I am expecting you guys to know

2 what that spread looks like on each of these

3 variables or do the research to figure out on

4 mortgage interest rates, you know, what the

5 range is and what the median is, and,

6 basically, give us some insights on, well,

7 gee, we find that all the low-income people

8 are paying the 9 percent interest rate. And

9 if you do that, then nobody can afford these

10 houses.

11 I mean, I think we need to know

12 those parameters, but I am not sure what more

13 guidance, as the ASRAC person on the group,

14 could tell you.

15 (Laughter.)

16 MS. HOFFMAN: Sorry to put you on

17 the spot, but thank you.

18 MEMBER CASKEY: Well, that's okay.

19 MR. RAMIREZ: Mark, Robin has been

20 patient, but is it on this topic here?

21 MEMBER WEISS: Yes, it is.

22 MR. RAMIREZ: Okay.
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1 MEMBER WEISS: I will let Robin go

2 first, though.

3 MEMBER ROY: Well, I have

4 something on two topics.

5 But, on the distribution, I think

6 it is very interesting, particularly for

7 manufactured housing. It is always

8 interesting in all the appliance and equipment

9 standard-setting processes to see if there are

10 some very large losers that are being

11 outweighed by very large winners, and a lot of

12 unaffected parties in the middle.

13 It helps, as a couple of folks

14 have said, it helps to think about, well, what

15 might we do a bit differently? How might we

16 target this better? So, it seems that if the

17 distribution is across different identifiable

18 populations, it is very useful.

19 I had a different question on the

20 heating fuel used. But this is such a

21 different topic. It fits within this. But I

22 think Mark has something which is germane to
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1 the distribution.

2 MR. RAMIREZ: We will come back to

3 that. Thank you.

4 MEMBER WEISS: Yes, thank you.

5 I just have a problem with

6 terminology like winners and losers. And my

7 concern here -- and I started to express this

8 last week, and I have a feeling I am going to

9 be saying this more today -- my concern is

10 this concern becomes a dry exercise in

11 technology and technical matters.

12 Let's be honest here. I mean,

13 manufactured housing is designated in federal

14 law as affordable housing. The mission is to

15 increase the availability of affordable

16 housing under federal law.

17 Let's be honest about what we are

18 doing here with these numbers and all this

19 terminology and all the technical data. We

20 are potentially talking about excluding people

21 from the only type of housing they can afford,

22 and that is mostly lower-income people. And
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1 we need to be cognizant of that at all times.

2 I have some data I brought with me

3 today. I mean, the average income for a

4 person owning, for a family owning a

5 manufactured home is $27,000 approximately. 

6 That is only a few thousand dollars over the

7 2014 poverty level. Okay?

8 We need to be cognizant that we

9 are affecting people here and we are

10 affecting, unfortunately, primarily lower11 income people, by increasing the cost

12 potentially of manufactured housing. And for

13 them, there is no alternative and there is no

14 life cycle.

15 MS. HOFFMAN: Okay.

16 MEMBER WEISS: So, I just want to

17 keep that human element in it.

18 MR. RAMIREZ: Thank you, Mark.

19 MEMBER DICKENS: May I add a

20 smaller -- this is Ishbel.

21 MR. RAMIREZ: I'm sorry, who is

22 this again? Oh, Ishbel.
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1 MEMBER DICKENS: Ishbel Dickens.

2 If I could add a comment, I want

3 to thank Mark for those comments. I have

4 these concerns as well. I think it is valued

5 on the average income of people purchasing

6 manufactured homes. We want to make sure that

7 we include as many people as possible.

8 But, Mark, I also want to make

9 sure that they are buying an energy-efficiency

10 home. And I don't think that that is the gold

11 standard here. I see that as something that

12 is workable and as sensible as possible. I

13 think a lot of the questions have to speak to

14 that. I am really concerned with the other

15 things here, but I want people to have energy16 efficiency homes. So, I am trying to look for

17 that compromise.

18 MS. HOFFMAN: I think you were

19 saying --

20 MEMBER SCHNEIDER: Could the phone

21 speaker restate that, please?

22 MS. HOFFMAN: Who's speaking,
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1 please?

2 MEMBER SCHNEIDER: It's Peter

3 Schneider from Efficiency Vermont.

4 I was just asking if you could

5 repeat what she said. I just couldn't

6 understand it.

7 MS. HOFFMAN: I got the impression

8 that Ishbel was saying that two factors are

9 being affordable, but also energy efficient to

10 keep it as you are operating the home. At

11 least that is what I heard. So, that there

12 are really two factors, to be able to purchase

13 it, but also to be able to keep it, which I

14 think that was what she was saying and has

15 said eloquently the last time as well.

16 MEMBER SCHNEIDER: This is Peter

17 Schneider from Efficiency Vermont, and there

18 is a bit of an echo. So, I apologize.

19 But I would echo what Ishbel said. 

20 At least in the Northeast the current HUD

21 homes are really continuing the cycle of

22 poverty for the homeowners due to high energy
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1 costs, durability issues, and I think indoor

2 air quality issues as well, from my

3 experience.

4 So, that's it.

5 MR. RAMIREZ: Thank you.

6 Robin?

7 MEMBER ROY: David, do you have

8 something on the distribution effects?

9 MEMBER TOMPOS: Well, there are

10 two conversational things here. If DOE could

11 just completely change the banking industry so

12 that they recognize energy efficiency, that

13 would make this a lot easier.

14 And my second point is to ask for

15 a break.

16 (Laughter.)

17 MS. HOFFMAN: Right. Thank you. 

18 I was about to suggest that.

19 May I suggest a 15-minute break?

20 Oh, Robin, do you want to do it

21 now or --

22 MEMBER ROY: Oh, it is quick. It
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1 is about the heating fuel.

2 MS. HOFFMAN: Okay.

3 MEMBER ROY: There was a table in

4 the PNNL analysis which laid out a set of

5 distributions across the climate zones and

6 across the types of heating fuel. It is Table

7 1-C.

8 And I was just curious about the

9 data. You used the microdata from the 2009

10 American Housing Survey. I was wondering what

11 kind of confidence you had that that reflected

12 both manufactured housing, as opposed to

13 general housing stock, and to new sales, as

14 opposed to the existing installs, which may or

15 may not be different.

16 MR. WALKER: I see you looking at

17 me. I will have to say that --

18 MEMBER ROY: Is this your stuff?

19 MR. WALKER: -- those assumptions

20 were done by PNNL, and I don't really have

21 knowledge of the underlying assumptions.

22 MR. HAGERMAN: This is Joe
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1 Hagerman, DOE.

2 So, I am not sure, you know, we

3 are going to trust this 2009 American Housing

4 Survey. That is our only kind of look into

5 that.

6 The manufacturers, you would

7 think, you would assume that they would know

8 more, especially since that is a good few

9 years old.

10 MS. HOFFMAN: Okay. I am going to

11 exercise my facilitator prerogative then and

12 suggest that we take a break.

13 (Whereupon, the foregoing matter

14 went off the record at 10:59 a.m. and went

15 back on the record at 11:18 a.m.)

16 MR. RAMIREZ: All right. We had

17 an additional member of the public, I guess,

18 join us. So, if you wouldn't mind, could you

19 introduce yourself before we get started here?

20 MR. MARTIN: Hi. I'm James Martin

21 with HUD's Office of Manufactured Housing

22 Programs.
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1 MR. RAMIREZ: Okay. Thank you,

2 Jim.

3 MS. FREIMUTH: I'm Janet Freimuth. 

4 I am from the DOE Office of Conflict

5 Prevention and Resolution.

6 MR. RAMIREZ: Thank you.

7 So, I think next on the agenda was

8 to have Eric go over the 2015 IECC stuff, and

9 he is going to send me a document here. Just

10 so the folks at home can see it as well, we

11 could put it on. Even though it is going to

12 be a quick reference, at least the folks at

13 home can see it or at their offices.

14 MEMBER LACEY: Okay. I am Eric

15 Lacey, Responsible Energy Codes Alliance.

16 Joe has asked me just to walk

17 through very briefly how the IECC works. I

18 know there are probably varying levels of

19 comfort with the International Energy

20 Conservation Code among this group. And so,

21 I was kind of struggling with how specific or

22 how general to make this discussion. And so,
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1 feel free, if you think this is too detailed

2 or not detailed enough, please stop me

3 throughout.

4 But I thought this was a really

5 important point or discussion to have because,

6 for whatever its reasons, Congress decided

7 that the starting point should be the latest

8 edition of the IECC. And rather than just

9 take the HUD baseline and apply a 10 percent

10 improvement, or whatever, they decided that

11 they wanted it to match as closely as feasible

12 and as cost-effective the IECC.

13 And so, I think some of the

14 questions that came up earlier were related to

15 this kind of clashing between two different

16 ways of calculating the energy efficiency of

17 a manufactured home. One way is based on the

18 use of o, which Emanuel Levy walked us

19 through, and I am going to talk a little more 

20 about that.

21 And the other way is the way IECC

22 calculates it now. And I would point out that
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1 the IECC used to use a U sub o calculation

2 several editions ago, but it got rid of it,

3 for a variety of reasons.

4 And so, I am going to walk you

5 through the different means of compliance

6 built into the IECC 2015 version and what

7 those elements are. I am hoping we will see

8 that maybe some things work for manufactured

9 housing; some things don't. But at least we

10 can all kind of understand how this works.

11 So, I created a handout, and I

12 have a bunch of copies, too, in case there

13 aren't enough there. Do you want these?

14 What this is is -- first, what

15 this isn't is this is not a recreation of the

16 code. It is not every detail, every

17 requirement that is in the code. It just a

18 really quick summary of what I see as the

19 three main compliance options that you

20 currently have in the IECC. And it is just to

21 kind of spur some discussion, and I think to

22 allow us to more effectively compare the IECC
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1 compliance options with the U sub o

2 calculation that most of you are probably more

3 familiar with.

4 And so, running underneath the

5 IECC is kind of assumed base-case home. All

6 of these compliance options are kind of

7 natural outgrowths of an assumed home. It is

8 just kind of a common, typical construction

9 home in different climate zones. So, it is

10 some differences according to the climate

11 zones.

12 And then, from there, from that

13 kind of baseline, there are a variety of ways

14 of showing that you are energy-equivalent to

15 that baseline. So, the process of developing

16 the IECC is kind of twofold. One is kind of

17 deciding what that baseline is going to be. 

18 And two is how many different options and

19 exceptions and methods can you use to get to

20 that kind of equivalent to that baseline. I

21 hope that makes sense.

22 So, there are three really key,
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1 main compliance options in the IECC and, then,

2 some suboptions within these. And so, first,

3 there is prescriptive. There's performance,

4 and there is the new Energy Rating Index. So,

5 I am going to kind of walk through these three

6 in turn.

7 First, the prescriptive path. And

8 this one I believe is by far the most --

9 prescriptive path or the different options

10 within the prescriptive path is by far the

11 most popular among builders. It is the

12 simplest option. It is also the least13 flexible option. So, I think it is very

14 commonly used, and I will walk you through it.

15 There are kind of three different

16 ways, at least three different ways, of

17 meeting the prescriptive path. The

18 prescriptive path is, first, the R-value table

19 is the one that we have been talking about

20 this morning.

21 This is designed to be sort of

22 like a recipe. If I am a builder and I have
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1 been building houses forever, I am going to

2 say, "Just tell me what the R-value of the

3 insulation needs to be, and I will put it in

4 the house. I will make this work." And so,

5 this is it. This is the recipe.

6 These are nominal R-values of the

7 components themselves. This is the R-value

8 that is printed on the insulation itself. For

9 windows, this is the U-factor that is on the

10 NFRC label.

11 And so, look, it's simple. It is

12 easy. These are kind of the baseline rules. 

13 And a lot of builders build this way. When

14 the R-values change or the U-factors change,

15 you change the things you are buying or in

16 some cases you change the design of the home. 

17 But this is kind of the fundamental baseline

18 set of requirements.

19 Now don't get too distracted by

20 the R-values. I know that maybe a 20 plus 5

21 or a 13 plus 10 -- I don't know how those work

22 in manufactured homes or some of the other
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1 R-values.

2 Leaving those aside for a minute,

3 this was kind of designed for a stick-built

4 home, and it is kind of the simplest, most

5 straightforward path, but also the least

6 flexible. If you wanted to put in Climate

7 Zone 1, for example, if you wanted to put R11

8 insulation in the walls, this wouldn't allow

9 you to do it on average.

10 Now, if you want to have more

11 flexibility, there are other options here. 

12 This is just the simplest.

13 The second option, scrolling down

14 here -- and I would also point out, too, that

15 it is not just the R-value table. There are

16 very specific instructions for the whole

17 assembly. There are some specific

18 instructions as to how to tighten the house. 

19 There are exceptions related to fenestration. 

20 You get a certain percentage of glazing area

21 that is exempt from these requirements.

22 There are other requirements like
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1 duct tightness and air leakage tightness and

2 testing, lighting requirements. And there are

3 certain mandatory requirements that you meet,

4 no matter what. But kind of the fundamental

5 is you start with this R-value table and these

6 are the thermal envelope requirements.

7 Well, if you want some more

8 flexibility, you go to a U-factor alternative. 

9 And this is a very similar to the R-value

10 table, except that rather than have the

11 nominal component R-values, these are the

12 assembly U-factors. The U-favor equivalent

13 table, rather than it just being the

14 insulating value of the piece of insulation,

15 it is the insulating value of the whole wall

16 or the whole window, the whole floor or the

17 whole ceiling.

18 And the advantage here is, as long

19 as the U-factor of the whole ceiling hits this

20 U-factor, it doesn't matter whether it is

21 varying, you know, thicker or thinner

22 insulation throughout. As long as the average
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1 U-factor is this, then you have some

2 flexibility.

3 So, let's say, for whatever

4 reason, you want to put R11 on one wall and

5 R20 on the other three walls. I don't know

6 why you would do that, but you would go by the

7 average assembly values for those four walls. 

8 And as long as it is no higher than these

9 U-factor numbers, you would comply.

10 And just like the R-value option,

11 there are requirements for window SHGC. There

12 are requirements for ducts, air leakage, duct

13 tightness, and so on, along with some

14 mandatory backstops. For example, on the

15 windows, you can't trade the windows all the

16 way down to nothing. If you live in Climate

17 Zone 5 through 8, up in the northern part of

18 the country, you couldn't put in a single19 pane, aluminum frame window. There are

20 certain backstops that don't allow you to go

21 too far, but relatively-few backstops there.

22 So, that is the equivalent U-factor table
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1 which is the R-value table with a little bit

2 more averaging flexibility built into it.

3 The third alternative here under

4 the prescriptive path is called the total UA. 

5 And those of you that are familiar with DOE's

6 REScheck program are probably very familiar

7 with this. In the total UA, I am going to try

8 to explain the difference between a total UA

9 and a U sub o calculation. Emanuel is going

10 to stop me if I get it wrong.

11 But this is the direction the IECC

12 has gone. They have kind of gone away from

13 the use of o for a few reasons and gone more

14 toward a UA path.

15 Well, the way the total UA

16 alternative is recall the average U-factors

17 that I just talked about. What the UA does is

18 it takes the U-factors times the area and

19 comes up with a number. So, you take the

20 U-factor times area of all the walls, and that

21 gives you a number. Then, the U-factor times

22 the area of all the attic, the U-factor times
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1 the area of all the floor, the U-factor times

2 the area of all the windows, and you take

3 those numbers and add them up, and that is a

4 UA number.

5 Now the U sub o is a little

6 different. The U sub o takes the U-factors of

7 everything in the house and boils them down to

8 a single number, a single, I guess, U sub o

9 number; whereas, the total UA, the way the

10 total UA works is you are comparing one model

11 home against a proposed home.

12 So, if I am calculating the UA for

13 a home that has 2,000 square feet of floor

14 area, then my baseline home has 2,000 square

15 feet of floor area. And so, then, you are

16 calculating your model home and the baseline

17 home have the same assembly areas; they just

18 may have different U-factors. And as long as

19 the total UA is no higher than what the model

20 home would require, it passes. I didn't do

21 that right.

22 MR. RAMIREZ: The total of U of o?
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1 MEMBER LACEY: UA. Let me see,

2 let me show you, I will show you a screen

3 capture I did of REScheck, which is the most

4 popular program. It is a free program DOE

5 produces that I think a lot of builders use.

6 And what you would do is -- let me

7 use the cursor here -- you put in the various

8 components of the building. You have ceiling,

9 floor, walls, and windows, basically. This is

10 how you come up with a thermal envelope.

11 And this is just a model that I

12 worked up. You put in what type of ceilings

13 and walls and windows, and so on, you use

14 here. And then, you put in the area of each

15 of those assemblies and, then, what your

16 insulation values are, whether it is an

17 R-value or a U-factor, and, then, your SHGC,

18 if it is the window.

19 And what this calculation does is

20 it multiplies the area times the U-factor,

21 actually, and comes up with a UA number. You

22 know, in this case it is a 56. And it adds up
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1 al those UA numbers. And the maximum UA that

2 would be allowed by the IECC for this

3 configuration of the home is 352. As long as

4 my number is lower than that, then I pass.

5 Now how is this different from U

6 sub o? I messed this up the first time. I am

7 going to try again. And then, Emanuel can

8 correct me if I am wrong.

9 I will use window area as an

10 example. In here, if I am designing a home

11 with 15 percent glazing area, that is my

12 proposed home, the model home, the baseline

13 home that I am being compared against would

14 have the exact same percentage of glazing

15 area. It would have 15 percent. If I decide

16 to put in 20 percent, my baseline home would

17 have 20 percent. If I decided to ratchet it

18 down to 8 percent, the baseline home would

19 have 8 percent.

20 What the UA does is it neutralizes

21 those decisions. It says we are not going to

22 let that impact whether you are above or below
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1 code. We are going to calculate the baseline

2 and your proposed home on the same set of

3 assumptions.

4 The Uo is a little different. The

5 U sub o, somewhere deep inside, is assuming a

6 base-case glazing area, and that stays the

7 same. Now it has been calculated into a total

8 U-factor number, but at the bottom of it there

9 is an assumed glazing area percentage.

10 And so, if I decide to put in a

11 lower glazing area percentage in my proposed

12 home, I would probably get a break on the

13 total U sub o number. And if I put in more

14 glazing area, I would have to come up with the

15 efficiency somewhere else. Is that fairly

16 accurate?

17 And the same would be true of any

18 other assembly area. We pick on glazing

19 because it is an obvious one. But if I design

20 a home with half of the ceiling area -- you

21 know, the ceiling might require R38 or R49 --

22 then I might get a break on my wall insulation
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1 and floor insulation, depending on what the

2 baseline was.

3 And if there are questions about

4 that -- I am afraid I have probably confused

5 this more than I needed to.

6 MEMBER LEVY: This is Emanuel.

7 Eric, that is a good explanation. 

8 I just wanted to add the point or one of the

9 points that I hear you making is that you can

10 get compliance with five different homes under

11 this UA procedure that have five different U

12 sub o values --

13 MEMBER LACEY: Yes.

14 MEMBER LEVY: -- for the same

15 location, the same climate, the same --

16 MEMBER LACEY: Yes, it is a

17 different way of calculating the energy

18 efficiency of the building. Now, you know, I

19 pointed to a weakness of the U sub o

20 calculation. And that is that a lot depends

21 on those assumed assembly areas. You know, if

22 you assume a high percentage of glazing, you
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1 get away with, I think, weaker walls, weaker

2 attic, and everything.

3 But, if you assume too low a

4 percentage of glazing, you have design

5 restrictions. You know, it is going to be

6 really hard to put in a 10 percent or 12 or 14

7 percent glazing if your U sub o is so low that

8 functionally you just can't put the glazing

9 in. And so, it is hard to find that sweet

10 spot in the U sub o, preserving energy

11 efficiency and allowing enough design

12 flexibility to build the homes that people are

13 going to buy.

14 The UA has its own weaknesses, and

15 I will be upfront about them. One of the

16 weaknesses of the UA and the criticism about

17 it often gets is, well, doesn't this mean you

18 could build a home with unlimited glazing? 

19 And that is the criticism of it.

20 In theory, you could. There are

21 other limiting factors. Windows cost more

22 than walls. And from a structural standpoint,
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1 you can't get away with a 100-percent glazed

2 home. That would be neat to see. And I

3 suspect that within manufactured housing there

4 are even more limitations as to the amount of

5 glazing area. You know, it has to at least

6 have a minimum of 8 percent, we heard. 

7 Getting beyond 14 or 16 percent may present

8 some structural challenges.

9 And so, if you adopted a UA

10 approach, that is the criticism of it, is that

11 it does neutralize the glazing area. But,

12 then, the upside of that is it allows a little

13 more design freedom and it takes out this kind

14 of built-in gap or credit based on glazing

15 area that you would find in the U sub o.

16 Are there other questions?

17 MEMBER LUBLINER: Eric?

18 MEMBER LACEY: Yes?

19 MEMBER LUBLINER: If I could just

20 clarify it, if you take the overall UA of 344

21 and you take the sum of the gross area column,

22 and you take 344 divided by the sum of the
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1 gross area of the column, you get the Uo,

2 right?

3 MEMBER LACEY: Yes, I think that's

4 right.

5 MEMBER LUBLINER: With the

6 exception of the crossover duct, which is

7 something we don't need to get into right now,

8 but it is something that I want to be clear,

9 when you do the analysis, if the crossover, if

10 it is in the belly, whether it is being

11 considered in the Uo.

12 MEMBER LACEY: Yes.

13 MEMBER LUBLINER: The other thing

14 I wanted to point out, that the reason we see

15 a lot of builders using the prescriptive

16 approach is so you don't have to be dealing

17 with someone adds another sliding glass door

18 to the product, you know, they don't have to

19 go back and redo the calcs. They just build

20 to this.

21 And are there limits on the

22 glazing area in the prescriptive approach?
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1 MEMBER LACEY: There's no limit on

2 glazing area, except that all the glazing has

3 to meet --

4 MEMBER LUBLINER: Meet a

5 certain --

6 MEMBER LACEY: -- meet a certain

7 U-factor and SHGC. And then, there are some

8 tradeoff maximums. You can't go completely

9 out.

10 MEMBER LUBLINER: Right, right. 

11 Sure.

12 MEMBER LACEY: And so, like I

13 said, there are a few maximums put in there

14 for sensitive areas like windows, air leakage,

15 and so on, where you just can't completely

16 trade these things off, if that makes sense.

17 MEMBER LUBLINER: Thank you.

18 It certainly, from my perspective

19 -- and I'm not a manufacturer -- would

20 simplify your ability, if you were able to

21 lock into a good prescriptive path that you

22 used a metric client base, it would greatly
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1 simplify that aspect of the special orders on

2 windows. And I don't know if that is a big

3 issue, but it came up in some experiences in

4 the Northwest.

5 Thank you.

6 MEMBER LACEY: Well, thank you,

7 and thanks for clarifying that.

8 Also, you will notice on this it

9 is not just all the U-factors. REScheck goes

10 through a number of other kind of checklists

11 and puts other requirements in there that are

12 required by the code. One of those is the

13 window SHGC, and the program actually kicks it

14 out if it is not compliant with some of these

15 other requirements.

16 I mentioned these earlier. You

17 have certain installation requirements for

18 insulation, some compression issues. You

19 know, those came up earlier. Your air barrier

20 has to be sealed. Or if you have an air

21 barrier, you have to seal the envelope to a

22 certain level. You have to have it tested for
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1 level of air leakage. You have duct

2 insulation, pipe insulation, a few other

3 requirements, and we can go through those.

4 I would assume that, as we are

5 coming up with a strawman, if the strawman

6 kind of starts with the 2015 IECC, we would

7 want to make sure we have a complete list of

8 all those items that the IECC would require

9 that might not be accounted for in a U sub o. 

10 You know, making sure that we at least start

11 there. And then, if any of them are just not

12 possible or don't work or are not applicable

13 to manufactured housing, you could cross those

14 off. But, as a starting place, I think it

15 would be useful to -- and I can help put this

16 list together, a list of the things the IECC

17 would require that are kind of outside of the

18 normal Uo calculation.

19 Are there any other questions?

20 Yes, Mark?

21 Oh, I'm sorry, it is the solar

22 heat gain coefficient, and it is a fraction of
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1 one. It is a measurement of the amount of

2 heat that is allowed to pass through the

3 window assembly, you know, in simplest terms.

4 And so, at .25, for example, in

5 this thing that I worked up here is basically

6 only a quarter of the sun's heat is allowed to

7 go through the window assembly; a .5 would be

8 half of the heat of the sun, you know.

9 And again, that is not accounted

10 for in the U sub o calculation, but in

11 performance paths, and certainly in the IECC,

12 that is a requirement that has been in there

13 for a long time.

14 Okay. Yes, Emanuel?

15 MEMBER LEVY: Yes, I just want to

16 make one point. And I am not sure how this is

17 going to bear on the discussion.

18 But there is a parallel between

19 what you have just outlined in the UA

20 procedure and what Matthew talked about with

21 the life-cycle cost analysis. Because Matthew

22 was talking about a marginal analysis where
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1 you look at each level of efficiency as a

2 marginal improvement. Going from R13, R19 in

3 the wall, for example, is a marginal

4 improvement to the wall. And you look at that

5 improvement and determine whether it is cost6 effective. Whether it is 1 square foot or 100

7 square feet doesn't matter. You are looking

8 at a per-square-foot cost-effectiveness of

9 improving from one level of efficiency to the

10 next.

11 So, this is kind of analogous to

12 that because it doesn't care how big each

13 component is. It looks at each component and

14 it looks at the improvement of each component

15 and keeps looks at those relative to each

16 other.

17 So, this is actually more

18 consistent with life-cycle cost way of

19 thinking. Do you use the UA type of analysis

20 rather than U sub o.

21 MEMBER LACEY: Yes. Yes, that is

22 a really good point. You are right, it is
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1 harder in a U sub o to determine what is cost2 effective because it depends on the choices

3 you make. But this would break it down more

4 by component. That is a really good point.

5 All right. So, I hope I have

6 thoroughly confused you on the prescriptive

7 paths. And maybe you are already familiar

8 with how these all work.

9 I will talk about the other two

10 paths here. The next one up is the

11 performance path. Now, again, this has been

12 in the IECC for quite a while.

13 I mentioned at the beginning

14 everything kind of goes back to a baseline

15 reference home. And then, all of these

16 compliance paths are outgrowths of that.

17 What the performance path does is

18 it takes kind of a model home, similar to what

19 the UA path did, with whatever size dimensions

20 and assembly dimensions that you plug into it,

21 and it creates a baseline. Well, this goes a

22 little bit further than the total UA. What
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1 the performance path does is it takes the

2 total UA in there and kind of fills in the

3 assumptions for your baseline home, but it

4 also has assumptions for other things,

5 assumptions for your duct leakage, air

6 leakage, and some of these other things. So,

7 you can't really trade off in the total UA

8 path some of your system requirements. Some

9 of these things, you really can't do it with

10 the UA, but the performance path allows you to

11 trade among these components.

12 The way it does it is it says, as

13 long as the annual energy cost of the building

14 that results is no higher than the annual

15 energy cost of the baseline home, you pass. 

16 And so, some builders like this path because

17 it provides a lot more flexibility. It takes

18 into consideration the orientation of the

19 home. That may be more difficult in the

20 manufactured home. In a stick-built home, how

21 you orient the house, what side you put the

22 windows on, can have a really big impact on
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1 energy use. That is not really captured in

2 the other simpler tradeoff paths, but it is by

3 the performance path. It is more of a whole

4 building analysis. And so, this is more

5 complicated, but more flexibility.

6 Similar to the other paths in the

7 IECC, again, there are a set of requirements

8 that you need to meet. There are mandatory

9 requirements in there and there are other

10 requirements that aren't included on the table

11 that I flashed up there.

12 Another interesting thing, since

13 we were talking about fenestration area, I

14 thought I would throw this up there. There is

15 yet another approach to fenestration area that

16 I think this group should consider.

17 The way the performance path

18 treats fenestration area is it says we assume

19 in the base case the fenestration area of 15

20 percent. Of you go above that, if your design

21 home has 20 percent glazing, you have to make

22 the home as efficient as a 15 percent glazed
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1 home would be. So, if you have to make up for

2 those savings if you go above 15 percent.

3 However, if you go below 15

4 percent, what you do is the assumed home

5 rachets that glazing area percentage down. 

6 And what this tried to address was, if you set

7 an assumption of 15 percent glazing area, if

8 you in your proposed home dropped the glazing

9 area by 2 percent or 3 percent, there was this

10 additional credit that was there, this

11 additional gap that was commonly used to

12 weaken the efficiency of other parts of the

13 envelope.

14 So, this is the approach the IECC

15 has taken since 2006. And that is, you have

16 this moving glazing area target. It is kind

17 of your baseline is 15 percent, and it is that

18 way -- if you go up to 100 percent glazing,

19 you are compared against the 15 percent glazed

20 home. If you go below that, then it follows

21 whatever you are proposing. This is another

22 way, like I said, another way of addressing
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1 that.

2 As I mentioned, you have some

3 mandatory backstops. You can't completely

4 trade away the windows. The air leakage has

5 to be at a certain level, and so on.

6 I mentioned earlier that REScheck

7 contains a total UA compliance path built into

8 it. REScheck is DOE software. REScheck also

9 has kind of a truncated version of the

10 performance path in there. It doesn't have

11 all of the assumptions and all of the

12 flexibility, but it is kind of a performance

13 light approach, and builders do like that.

14 I would also mention a change in

15 the IECC that happened in 2009 and is carried

16 into the 2012 and 2015 codes is in the

17 performance path there is no real credit for

18 putting in efficient equipment, appliances,

19 and other things.

20 And kind of the logic behind this

21 was some of you may be familiar with NAECA,

22 the National Appliance Efficiency and
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1 Conservation Act, is that right?

2 The federal government sets

3 efficiency levels for a listed number of

4 appliances, including heating and cooling and

5 water heating appliances that are used in

6 homes. And when the federal government sets

7 a minimum efficiency level, states are not

8 allowed to require anything better than that.

9 So, if I lived in the State of

10 Vermont and I thought, you know, we should

11 require condensing furnaces, 95 percent

12 efficient natural gas condensing furnaces, I

13 am not allowed to do that. The only thing I

14 can specify as a requirement in the code is

15 the federal minimum, which happens to be at 78

16 percent efficient furnace.

17 And so, this created an issue in

18 earlier versions of the IECC where anytime you

19 included that assumption in your base case,

20 the federal minimum assumption, if everybody

21 was already putting in 90-percent or 92-

22 percent-efficient furnaces and they were being
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1 compared against a 78-percent-efficient, there

2 was this big tradeoff gap, and the gap was

3 getting larger all the time.

4 And states weren't really allowed

5 to do anything about this. So, in 2009, the

6 equipment efficiency use was basically taken

7 out of that calculation to say we recognize

8 that, on average, much more efficient

9 equipment is being used. Rather than weaken

10 the overall efficiency of the performance

11 path, we are just going to remove that portion

12 from the calculation and remove that credit

13 from the calculation to make sure that the

14 rest of the building is still efficient.

15 I know this is a topic that was

16 hotly debated then, and it is still hotly

17 debated at the state level. But two-thirds of

18 the states have adopted a code that doesn't

19 allow equipment tradeoffs for single-family

20 homes for stick-built homes, and the code

21 currently doesn't allow it in the performance

22 path.
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1 Are there any questions about

2 that?

3 Yes, John?

4 MEMBER CASKEY: This is John

5 Caskey, NEMA.

6 I am still a little confused on

7 the first bullet. So, I sort of understand

8 part of it, but you said, thus, a proposed

9 home with 12 percent glazing is compared

10 against a standard reference home with 12

11 percent glazing. So, when that standard

12 reference home goes from the 15 percent to 12

13 percent, apparently, they are not being any

14 more lax on the other attributes in terms of

15 wall insulation or anything like that?

16 MEMBER LACEY: Right. Right.

17 MEMBER CASKEY: So, in essence,

18 this is better than the previous reference

19 standard at 15 percent. And it is sort of

20 like, if you want to do that, that is your

21 tough luck and you don't get any benefit for

22 doing that?
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1 MEMBER LACEY: Yes.

2 MEMBER CASKEY: Okay.

3 MEMBER LACEY: Yes. I mean, the

4 way this used to work on the performance path

5 is there was a fixed percentage. It used to

6 be 18 percent. In the pre-2006 code you had

7 an 18 percent glazing area. And if you built

8 a home for whatever reason, for cost reasons

9 or design reasons, a home at 15 percent

10 glazing, that gap between 15 and 18 percent,

11 which was your assumed home, was actually

12 quite a bit of tradeoff room. And it was

13 being used to trade efficiency in other parts

14 of the envelope.

15 Now some would argue, well, you

16 are getting the efficiency from somewhere,

17 whether it is through reducing the glazing

18 area or improving the windows. But the

19 thought here was that you make your decisions

20 on glazing area percentage based on a number

21 of other factors. And whatever percentage of

22 glazing you include in the home, the idea is
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1 to have an efficient home. And rather than

2 focus on setting that percentage at the right

3 percentage, they decided to just ratchet it

4 down if you went below 15 percent.

5 I hope I am doing that justice. 

6 Again, it is another topic that has had a lot

7 of debate and still gets debated. You know,

8 every cycle there are proposals that --

9 MEMBER CASKEY: Your description

10 makes sense; the logic in doing that doesn't

11 make sense to me, but that is the way it goes.

12 MEMBER LACEY: Yes. Okay.

13 MR. RAMIREZ: Keith?

14 MEMBER DENNIS: Keith Dennis.

15 You were describing the reason why

16 they excluded the appliances from this path

17 and mentioned kind of the interaction with

18 what the states were doing with clients'

19 standards and the interaction between state

20 and federal standards.

21 So, is my understanding correct

22 that, if you had a performance path, and you
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1 had a minimum requirement for a manufactured

2 house, it might come with, say, a certain type

3 of heating or cooling equipment. And then, a

4 state or, say, a utility would say, "We would

5 like to go above and beyond that with

6 appliances." And that is something that is

7 kind of the current practice or would be

8 allowed. And then, therefore, there would be

9 credit at that level.

10 I don't know if you would know

11 this, but from NAECA's perspective and from

12 compliance standard perspectives, are states

13 allowed to kind of ask for that higher level

14 or do they just have to incent it on a

15 voluntary basis? I know there are some

16 preemption concerns.

17 MEMBER LACEY: Yes, and I will

18 leave it DOE's attorneys to answer the

19 question that was raised earlier about whether

20 NAECA applies to manufactured housing.

21 MEMBER DENNIS: Uh-hum.

22 MEMBER LACEY: But how the states
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1 dealt with this, you know, in the statute it

2 is very specific. If you are going to include

3 any kind of equipment specification in your

4 code, it has to be specified at the federal

5 minimum level.

6 There have been a couple of cases

7 where states have tried or localities have

8 tried to say, you know what? We want all of

9 our furnaces to be 90 percent efficient. And

10 that gets kicked out. That is a violation of

11 the statute.

12 Now there are ways around this. 

13 States have figured out ways to sidestep

14 NAECA, and we can talk about some of those. 

15 But just outright specifying a higher16 efficiency piece of equipment is going to be

17 preempted and kicked out.

18 Does that answer your question?

19 MEMBER DENNIS: Well, I guess I

20 missed a little bit of the point on why

21 exactly that it was removed. You said it kind

22 of had some interplay between the states and
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1 the federal. And just if you could clarify it

2 a little bit, maybe I will get it the second

3 time.

4 MEMBER LACEY: Yes. So, I will

5 give you an example. In Wisconsin, a couple

6 of years ago there was a study run that showed

7 that 90 percent of the natural gas furnaces

8 being sold in Wisconsin were at least 90

9 percent efficient. So, 90 percent of them

10 were at least 90 percent efficient. And a

11 good percentage of those were 95 percent

12 efficient and above.

13 So, if you assume that 90 percent

14 of those furnaces in those homes are at 90

15 AFUE and better, and you compare that to what

16 would have been required in the code at 78

17 percent efficient, there is this huge gap

18 there.

19 Now, if Wisconsin or if any state

20 wants to move their energy code forward, they

21 are being hamstrung by having to include this

22 federal minimum standard in their code. So,
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1 one solution -- and we can debate about

2 whether it is -- I mean, it has been plenty

3 debated about whether it is the right or wrong

4 solution. One solution was to take that

5 calculation outs, to take that gap out by

6 removing the credit from the code.

7 Another solution might be to

8 rachet up the R-values that are required in

9 the building, up to a level where pro-energy10 efficiency people would be satisfied that you

11 just couldn't trade away the insulation levels

12 below an acceptable amount. But, then, I

13 think the prescriptive will look really

14 different from what it looks like right now. 

15 It might be kind of crazy.

16 So, the idea was, if the states

17 don't have control over this, to remove it

18 from the calculation. That is not to say that

19 it is anti-energy-efficiency. The equipment

20 is being put in for a variety of reasons. 

21 There are incentives. It is what the market

22 demands. And so, this seemed to be the most
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1 expedient way of taking care of that gap.

2 Okay. Go ahead. Mark had a

3 question.

4 MEMBER WEISS: No. No, not a

5 question, a point relating to this discussion

6 just now.

7 The HUD code standards are

8 preemptive. So, there is another issue here

9 of whether HUD winds up overlapping whatever

10 comes out of DOE. If that is essentially

11 parallel to the HUD code, then that becomes

12 preempted, whatever it is.

13 MEMBER LACEY: Yes, again, I would

14 defer that to DOE General Counsel to answer

15 those tricky questions anytime, and you don't

16 have to answer it now.

17 MS. VAIDYANATHAN: I am looking

18 into it. I am just understanding the issue

19 now. So, it is going to take me a little

20 while to get up-to-speed and get back to you

21 guys with an answer.

22 MEMBER LACEY: Okay.
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1 Robin?

2 MEMBER ROY: Yes, Robin Roy.

3 I think there were a couple of

4 states that figured out a way to effectively

5 require higher -- they didn't actually require

6 higher-performance heating equipment, but they

7 effectively did by having tradeoffs. In

8 particular, I think the State of Washington is

9 an example of it, but whatever.

10 Really, I don't think we need to

11 play that game. I look forward to seeing what

12 General Counsel says here.

13 Our counsel at NRDC came to the

14 view that there was no restriction on DOE from

15 putting a requirement for NAECA-covered

16 products. The preemption restrictions on

17 states don't apply to the federal government

18 on itself.

19 But that is our understanding. It

20 would be good to see what the General Counsel

21 says about it. That doesn't mean that we

22 should be putting the standards on equipment
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1 in this group or proposing them. It doesn't

2 mean we are prohibited from doing so.

3 I had a really different question

4 why I put this thing up for Eric. Back on,

5 for example, the first two tables you show

6 here --

7 MEMBER LACEY: Yes.

8 MEMBER ROY: -- we had this really

9 very interesting discussion earlier this

10 morning about some of the practical ability to

11 achieve assembly U-values based on -- well,

12 actually getting R30 out of an R30 bat or a

13 set of things you add up to it because of

14 compression, for example.

15 Is that explicitly considered in

16 IECC, some of those practical realities, or do

17 they still show up in site-built homes because

18 they have different dimensions or something?

19 MEMBER LACEY: Yes. The short

20 answer is yes. You probably couldn't get away

21 with compressing very much. There are

22 specific instructions on installation of
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1 insulation and the amount of compression, and

2 even the limitation as to how much it can be

3 compressed and still claim that R-value.

4 That is a real issue. I think the

5 example that was raised earlier of the belly

6 insulation is going to be an interesting one

7 to look into because something like that might

8 fail the UA alternative, and it may also fail

9 the R-value requirement in the State or in the

10 IECC, because there are those limitations on

11 compression. But it is addressed.

12 I mentioned there is a whole

13 series of other requirements that apply to

14 these things. So, it is not just a table. 

15 And that is one of those issues, is the amount

16 of compression that would be allowed in the

17 way it is constructed.

18 Does that sort of address --

19 MEMBER EZZO: This is Mark Ezzo.

20 Eric, can you hear me?

21 MR. RAMIREZ: Yes.

22 MEMBER LACEY: Yes.
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1 MEMBER EZZO: Eric, can you

2 elaborate on that a little bit, your comment

3 about the prescriptive table and the

4 limitations on compression? Because I don't

5 see anything written in the IECC that gives me

6 any guidelines, parameters, et cetera, on how

7 much insulation can be compressed. Where

8 would I find in the code where it tells me

9 what those limitations are?

10 MEMBER LACEY: Can I maybe circle

11 back with you afterwards on that, rather than

12 flip through my code book?

13 MEMBER EZZO: Oh, it is in the --

14 MEMBER LACEY: Yes, you do have

15 the air-barrier installation and insulation

16 installation table in there, which is going to

17 be one limitation.

18 MEMBER EZZO: Right.

19 MEMBER LACEY: And there are some

20 other restrictions on that. But can I give

21 you maybe some section numbers right after the

22 presentation?
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1 MEMBER EZZO: Sure.

2 MEMBER LACEY: Okay.

3 MR. RAMIREZ: Can you get that out

4 to everybody?

5 MEMBER LACEY: Yes, I can do that. 

6 Yes.

7 Are there any other questions? 

8 Okay.

9 MEMBER ROY: I have one. Also,

10 you said the prescriptive path has been the

11 primary means of compliance. Do you have a

12 sense of the breakdown between these two

13 different parts of this, options in the

14 descriptive path, which has been most heavily

15 relied on?

16 MEMBER LACEY: It is a good

17 question and it varies from state to state. 

18 I have heard anecdotally upwards of 80 percent

19 of builders in some states will use the

20 prescriptive path and I have heard in other

21 states a lot of them -- Florida, for example

22 -- a lot of them go the performance path.
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1 I don't have any hard data on how

2 this is nationally. I know DOE has released,

3 at least I have seen DOE numbers on the number

4 of REScheck runs that have been completed in

5 various states around the country, and the

6 numbers are actually quite big. The REScheck

7 is very widely used.

8 But, as far as a complete set of

9 numbers on what percentage is used in which

10 state, I wouldn't have that. I am not sure if

11 that is available.

12 I will say, anecdotally -- and NHP

13 might correct me if I'm wrong -- I think,

14 anecdotally, the prescriptive and totally

15 weight paths are the most popular means of

16 compliance on a national basis. But, anyway,

17 that is just based on what I hear going

18 through the states.

19 MEMBER LUBLINER: Yes, I concur. 

20 I think in the Northwest region the vast

21 majority of builders, particularly production

22 builders, have been using prescriptive
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1 approaches. And we worked with them to

2 develop a series of prescriptive paths that

3 work for them, and it provided simplicity. 

4 And that is what they liked about it. And it

5 provided consistency. So, every time somebody

6 added a window, they didn't have to go back

7 and redo their analysis. And it is something

8 that the industry should think about in terms

9 of whether it is a benefit as we look forward

10 on these options.

11 Thank you.

12 MEMBER LACEY: Okay.

13 MR. RAMIREZ: Emanuel?

14 MEMBER LEVY: Yes, Emanuel Levy.

15 Just a couple of other

16 perspectives on the question. First, it

17 probably depends on where you are in the

18 country.

19 MEMBER LACEY: Yes.

20 MEMBER LEVY: Because the more

21 severe the climate, the more stringent the

22 requirements, the more likely it is that
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1 alternatives will be considered.

2 And the other maybe more pertinent

3 question for this group is, and particularly

4 the manufacturers, since modular homes have to

5 meet the IECC, what percentage of those are

6 going through performance compliance? And I

7 would suspect it is a higher percentage than

8 site builders.

9 MEMBER LACEY: I don't know.

10 Do any of you want to answer?

11 MEMBER SANTANA: Yes. Manny with

12 Cavco.

13 We have plants that also build

14 modular homes which are built to conventional. 

15 And I don't know, I think 100 percent of those

16 homes do the REScheck. So, if we are going to

17 do prescriptive -- I don't think we do

18 prescriptive on any of them.

19 MEMBER LACEY: Now, just to

20 clarify, when you say you use REScheck,

21 REScheck has kind of two compliance options.

22 One is the total UA, which is kind of the
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1 default.

2 MEMBER SANTANA: Uh-hum, total UA

3 option.

4 MEMBER LACEY: Okay. And then,

5 the other is kind of a performance light.

6 MEMBER SANTANA: Right.

7 MEMBER LACEY: So, it is still --

8 MEMBER SANTANA: It is still a

9 total UA option.

10 MEMBER LACEY: Okay.

11 MEMBER SANTANA: And some of the

12 other manufacturers can also chime-in.

13 Does this excludes states like

14 California that have their own energy

15 requirements where REScheck won't work?

16 MEMBER LACEY: Yes.

17 MR. HAGERMAN: This is Joe

18 Hagerman, DOE.

19 I can say, to your question,

20 Robin, it is a question that we ask every time

21 we issue a code determination, which we have

22 to do after every IECC version that gets
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1 released and ASHRAE version. And it is always

2 a question that goes into our assumptions,

3 right, that we always ask for input on, and we

4 never get any input on.

5 Nobody is recording what path the

6 different builders are going down. There is

7 no information on that.

8 MEMBER ROY: Yes, I can imagine

9 the frustration, but I think, actually,

10 Emanuel's refinement of the question is really

11 very interesting.

12 And, Manny, your response is very

13 interesting, too. We don't really care about

14 these site owners. We care about what the

15 folks who are making the modulars are doing. 

16 And to the extent they represent the MH

17 industry, that is very, very interesting.

18 I would be curious, Mark, from

19 your membership, the extent to which -- it

20 would be great to take a poll of

21 manufacturers, housing manufacturers, and see

22 the extent to which they have familiarity with
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1 this REScheck UA approach. Because, if your

2 members can do it and if the other folks can

3 do it, boy, that might actually be simplifying

4 for you all. It is worth taking a look.

5 MEMBER EZZO: This is Mark Ezzo at

6 Clayton.

7 Robin, to answer your question, I

8 will echo what Manny said. Any modular home

9 we build we run REScheck and we use the UA

10 alternative, if that helps.

11 MEMBER LACEY: So, there is some

12 familiarity with the program out there,

13 probably better than me using it.

14 I saw a hand up out in the

15 audience. Don, did you want to offer

16 something? Is that appropriate? Okay. Yes. 

17 I thought maybe Don could clarify on the issue

18 of how many prescriptive, how many

19 performance --

20 MR. SURRENA: Don Surrena, NAHB.

21 It is my understanding that the

22 performance path is used more prescriptive in
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1 areas where it has become more complicated to

2 comply with the energy code.

3 I have just sent an email to our

4 Economics Department. They do the studies and

5 the surveys. And if I get that information

6 back, I will be glad to share it.

7 But it is my understanding from

8 answering questions on energy efficiency, it

9 is less prescriptive, more performance, on how

10 it is being handled because, as you had said

11 earlier, a lot of the options for compliance

12 have been narrowed. And that narrowing of

13 options has made the performance and the total

14 UA at times more adaptable or usable to be

15 able to comply.

16 An example of how the differences

17 in efficiencies or in window area, if in a

18 certain area it required a foundation

19 insulation of whatever, and that was hard in

20 that area to get builders to do, they could,

21 then, trade that off for their window area or

22 their equipment efficiency and comply. 
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1 Because those options are gone, they are now

2 going more to performance to get that done.

3 But if I have statistics that I

4 can share with you, I am more than glad to do

5 it. I may have overanswered your questions.

6 MEMBER LACEY: No, that's great.

7 MR. SURRENA: But thank you very

8 much.

9 MEMBER LACEY: Thanks, Don, and I

10 would really appreciate seeing the numbers on

11 prescriptive UA and performance because it

12 comes up a lot.

13 My perspective has always been

14 that a lot of the builders do use

15 prescriptive, but I include in prescriptive

16 the total UA. That is, I think, closer to a

17 prescriptive path than to total performance

18 where you might involve an energy rater or

19 something.

20 How am I doing on time? Are

21 people's stomachs grumbling? Because I can

22 talk about the ERI and kind of run through
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1 that quickly, and then, we can continue this

2 after lunch. I hate to stand in between us

3 and lunch.

4 MS. HOFFMAN: You are, though.

5 (Laughter.)

6 MEMBER LACEY: I know. It is my

7 favorite position on the speaking agenda.

8 MS. HOFFMAN: Why don't we do that

9 section, and then, we will adjourn and come

10 back and finish?

11 MEMBER LACEY: Okay.

12 MS. HOFFMAN: Okay.

13 MEMBER LACEY: Okay. I will run

14 through this. This is brand-new to the IECC

15 in 2015. If we had been talking about this a

16 couple of years ago, this wouldn't have

17 entered the discussion. But, because it is in

18 the latest edition of the IECC, I think the

19 group needs to consider this.

20 It is called the Energy Rating

21 Index. You may be familiar with the Home

22 Energy Rating System, HERS, that is a product
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1 of RESNET.

2 And what it is, it is a

3 performance-based approach that involves a lot

4 more assumptions than the IECC would normally

5 allow. I said earlier that everything is kind

6 of a natural outgrowth of the baseline home. 

7 All the other compliance options in the IECC

8 focus on the thermal envelope, the ducts, the

9 air leakage, and kind of that universe of

10 assumptions.

11 The Energy Rating Index includes

12 in that also heating, cooling, water-heating

13 equipment, appliances, lighting, and a few

14 other things, and calculates it a little

15 differently.

16 So, it is your baseline is much

17 broader and it involves a lot more things, but

18 there are still some critical backstops built

19 into this. So, the baseline for the Energy

20 Rating Index is an earlier version of the

21 IECC, the 2006 IECC. So, its baseline

22 assumption is actually a weaker version of the
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1 IECC, but had a few more tradeoffs and a few

2 more loopholes in it.

3 But it assumes that, if you build

4 a home to the 2006 IECC, you score 100 on this

5 scale. Now, when I say you build to the 2006

6 IECC, you are building to the federal minimum

7 equipment efficiencies. You are putting in a

8 non-ENERGY STAR refrigerator, a non-ENERGY

9 STAR clothes dryer, and all of your appliances

10 are basically the weakest that would be

11 permitted by law. And the 2006 IECC is your

12 thermal envelope baseline.

13 So, that is your scale, from zero

14 to 100, 100 being a 2006 IECC. Now you could

15 build a worse home, I guess, and the number

16 would be higher than 100, but kind of the

17 score is pegged to the 2006 IECC.

18 Now, when you do your calculation,

19 it is not based on the annual energy cost like

20 the performance path is in the IECC. It is

21 based on normalized, modified end-use loads,

22 a little different means of calculating this. 
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1 And it includes all the energy used in the

2 building, including your equipment, your

3 appliances, and so on, and your lighting.

4 Now the 2015 IECC Energy Rating

5 Index has specified the EIR score or,

6 basically, the HERS score that you need to

7 achieve to show compliance. So, in order to

8 be compliant with this version of the IECC,

9 the Energy Rating Index number would have to

10 be somewhere in the low fifties, depending on

11 your climate zone.

12 And the other key thing to mention

13 here is, aside from meeting these specific

14 numbers or better than these EIR numbers,

15 there are backstops built in here. The

16 thermal envelope can be no worse than the 2009

17 IECC. It is not all the way up to the 2012 or

18 2015 IECC, but it can't be any worse than the

19 2009. That kind of limits you as to trading

20 away the wall to R0, for example.

21 There are certain mandatory

22 requirements in the IECCs that have to be met. 
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1 Your window you factor in SHGC can't be traded

2 beyond a certain amount. There are caps on

3 that. Your air leakage can't be beyond a

4 certain level, and so on. And then, the

5 scores have to be about this level.

6 And so, this is by far the most

7 flexible option in the IECC. It is also the

8 most complicated. But, even within this

9 option, you have some limitations on the

10 amount of trading off.

11 Are there questions about the

12 Energy Rating Index?

13 (No response.)

14 I wanted to see -- I had a few

15 notes at the end, but we have probably covered

16 all these.

17 I guess, just to kind of sum-up

18 here, I will go over a couple of things. You

19 know, some of the things the IECC doesn't do,

20 it doesn't tell you how big or small the house

21 can be. It doesn't penalize you for a larger

22 or smaller home. It doesn't tell you what
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1 glazing area to have. It provides you a

2 variety of options that you can use to meet

3 the same baseline, that level of efficiency. 

4 And all of the compliance options are designed

5 to be roughly equivalent. They aren't going

6 to be perfectly equivalent because you can use

7 different tradeoffs and different options. 

8 The issue here is you do have a lot more

9 flexibility in here than you might have in

10 other systems.

11 And again, you have a list of

12 specific requirements that apply no matter how

13 you are building the home, under what

14 compliance option. And some of those I have

15 listed here.

16 And so, I guess I will leave it

17 there, and if there are questions, we could

18 answer them now or talk more after lunch. But

19 those are kind of the three main compliance

20 options in the IECC.

21 MS. HOFFMAN: Any questions now?

22 (No response.)
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1 Okay. Why don't we adjourn for

2 lunch, come back in an hour, and have the rest

3 of any questions on your presentation?

4 MEMBER LACEY: Yes.

5 MS. HOFFMAN: And then, go into

6 Emanuel's program. And hopefully, your slides

7 will arrive.

8 MEMBER LACEY: And just to kind of

9 close things out, I have another handout here

10 that shows the changes between the 2012 and

11 2015 IECCs. That came up a long time ago --

12 or a long time ago? -- a couple of weeks ago.

13 And I have my own notes on what

14 changed between those two codes. There is not

15 a lot, and especially not a lot that affects

16 manufactured housing. So, I will just hand it

17 around.

18 MR. RAMIREZ: Well, I will pass

19 those out at the door --

20 MEMBER LACEY: Okay.

21 MS. HOFFMAN: As you go to lunch.

22 MR. RAMIREZ: -- as you are going
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1 out. And that way, if you want to look at it

2 over lunch, you can do that.

3 MEMBER LACEY: This is not an

4 official list. These are my notes. They may

5 be wrong, but I tried to capture and I tried

6 to highlight those that might have an impact

7 on manufactured housing.

8 MR. HAGERMAN: So, just for

9 everybody playing along at home and on the

10 phone, we will come back, we will reconvene at

11 1:15 Eastern time.

12 MS. HOFFMAN: Right.

13 (Whereupon, the foregoing matter

14 went off the record for lunch at 12:13 p.m.

15 and went back on the record at 1:22 p.m.)

16 MS. HOFFMAN: First, we want to

17 ask if there are any questions for Eric. And

18 by the way, thank you for your presentation

19 for Eric Lacey.

20 If there isn't then I think we

21 should move ahead to Emanuel's presentation. 

22 We're looking forward to hearing the strawman. 
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1 Thank you.

2 MEMBER LUTER: One question for

3 Eric, please.

4 MR. RAMIREZ: Yes.

5 MEMBER LUTER: Rob at Lippert. I

6 had to step out of the call for awhile at

7 about 11 o'clock. Can you email me a copy of

8 your presentation? Or will that be added to

9 the docket?

10 MR. HAGERMAN: We can email you

11 right now the presentation he gave. And then

12 we also are going to add it to the docket, of

13 course.

14 MEMBER LUTER: That would be

15 great. Thank you.

16 MR. RAMIREZ: Okay, then with

17 that, Emanuel, do you want to come up here?

18 MEMBER LEVY: Thank you. Let me

19 just preface my comments by saying that the

20 intent of putting this presentation together

21 was to try to get our conversation focused on

22 at least from an initial draft standpoint what
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1 I thought might be the important issues that

2 we need to address as a committee to have all

3 the pieces of the term sheet that we need,

4 that are relevant to be on the term sheet.

5 So, what I -- and I also wanted to

6 suggest a structure for how we have our

7 conversation just going forward. So that we

8 not only get to all the items, but they're in

9 some kind of logical sequence that we can walk

10 through, and the first pieces affect the next

11 pieces, and so on and so forth. 

12 And it also ties into all the

13 other conversations we've had thus far about

14 life cycle and about the IECC standard and

15 what that's all about.

16 So this has been called a

17 strawman. It's one way to structure our

18 conversations. I'm going to walk through kind

19 of the overall concept. And please stop me

20 and comment at any point.

21 This basically embodies a certain

22 kind of thinking, but it's only really a
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1 starting point for discussion. I want to

2 bring up the issues in such a way that they

3 lead to some path to come to consensus and to

4 move onto the next issue.

5 So I started off by trying to come

6 up with a couple of points. Mark?

7 MEMBER WEISS: I'm sorry, I don't

8 mean to interrupt. But one question. Who put

9 the strawman together?

10 MEMBER LEVY: I did. 

11 MEMBER WEISS: Okay, thank you.

12 MEMBER LEVY: This comes from me

13 and it just reflects my views. And of course

14 there are other ways to structure this and

15 that's what we should be talking about too.

16 But I thought this was a starting

17 place and it was really intended to move us

18 forward to get the term sheet together

19 quickly.

20 So, I've started off by putting

21 together what I thought were a list of guiding

22 principles. The idea that this is not an
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1 exhaustive list by any means. It is a couple

2 of items that I thought were important. I

3 wanted to float them out there to start a

4 conversation.

5 And I have three points up here

6 which I'll go over in one second. But before

7 we do that let me just say that then I divided

8 the rest of the discussion up into specific

9 areas that we might focus on that each of

10 which would have a piece of the term sheet. 

11 And let me just mention those

12 quickly. And the idea is that we would

13 address each one of these areas individually,

14 that we would start off with a proposal on how

15 that section would be handled for discussion

16 and then we would together agree upon what

17 would be the meat of each of these sections.

18 And I divided up -- and again,

19 this comes somewhat from the Mind Map that we

20 worked on in the last session. It borrows a

21 lot of those pieces and reorganizes those into

22 some logical sequence. I thought it a logical
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1 sequence.

2 And the proposal here is that

3 there should be seven major topics that we

4 talk about over the course of the next

5 sessions leading up to the term sheet. 

6 All of these pieces would be

7 embodied maybe as separate sections in the

8 term sheet.

9 The first one is the thermal

10 requirements which brings into play the zone

11 map, the distribution of thermal requirements

12 across the country and how that divides up by

13 thermal zones.

14 The second -- and I'll be getting

15 into the first one as part of my presentation

16 today and start talking about some of the

17 specifics about that. We've already talked

18 about pieces of that thus far today.

19 The second is other economic

20 considerations. Coming back to a point you

21 made, Mark, earlier about what else comes into

22 play when we're thinking about the
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1 requirements that it go beyond life cycle

2 cost, or go beyond those things that are

3 easily quantifiable from the engineering

4 standpoint. What other economic

5 considerations bear on the thermal

6 requirements.

7 The third is additional energy

8 measures that are things like solar heat gain

9 coefficient or other factors that impact the

10 energy use but aren't maybe subject to --

11 aren't part of the thermal envelope and aren't

12 part of -- may not be subject to the life

13 cycle cost analysis.

14 The fourth is whole house

15 tightness and ventilation requirements. 

16 The fifth is duct system

17 tightness.

18 The sixth one is performance path

19 option which is just another way to comply

20 with the standard. 

21 And the last one is compliance and

22 verification, a topic I don't think we can not
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1 cover because this impacts the requirements

2 themselves and what the specifics are of the

3 requirements.

4 So we may, in discussing these, if

5 this is a format that everybody's comfortable

6 with following we may find ourselves jumping

7 around a little bit, coming down to certain

8 points and then jumping back and reconsidering

9 some of the earlier decisions.

10 When we get to whole house

11 tightness we might, for example, want to

12 reassess how we approached the thermal

13 envelope. So there are some interactions here

14 that we do have to take into consideration. 

15 But we follow this format generally and talk

16 back and forth as we saw fit.

17 So that's the overall concept. 

18 Mind if I stop there and see if there are

19 comments or questions?

20 MR. RAMIREZ: I want to make sure

21 that the group, first of all, if they're okay,

22 if they're comfortable with this guideline. 
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1 Understanding that we may need to jump around.

2 And secondly, do you understand

3 the broad topics? Do you need clarity on the

4 broad topics before we move on? Because I

5 believe you'll probably get into each one a

6 little bit, correct?

7 MEMBER LEVY: I will.

8 MR. RAMIREZ: So, before we move

9 on is there any clarity that you need on the

10 broad topics? Yes.

11 MEMBER CASKEY: John Caskey, NEMA. 

12 So where do the heating and cooling systems

13 and other things come into play? Are they

14 under one of these items?

15 MEMBER LEVY: Well, they might be

16 under several of these items. They're

17 embodied -- since we're not setting -- I guess

18 the premise here is that we're not going to

19 set requirements for the HVAC systems. We're

20 not going to suggest things that are beyond

21 NAECA requirements. 

22 MEMBER CASKEY: Okay.
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1 MEMBER LEVY: But those factors

2 play into the thermal requirements and other

3 elements of this. 

4 They're not listed here because

5 we're not setting requirements for that. 

6 We're not setting a term sheet for those

7 things.

8 MEMBER CASKEY: Okay. So the

9 other question relates -- thanks for that. 

10 The other question, like where you have

11 thermal requirements that can be an absolute

12 requirement where you may not have a comment

13 relative to the installation practices to

14 accomplish that. 

15 But then in dealing with like duct

16 system tightness it sounds like it's an

17 installation issue. 

18 So are you going to break out, you

19 know, the basic features versus the

20 installation guidelines or other sort of

21 installation issues?

22 MEMBER LEVY: No, that's a good
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1 point. And I haven't explicitly stated how

2 that works yet in here. 

3 But you're right, under each one

4 of these we have requirements in terms of what

5 the U-value requirement is. But also how that

6 materially gets installed. We should talk

7 about those in parallel I suspect.

8 The other option is to have

9 another category about installation quality or

10 --

11 MEMBER CASKEY: Okay.

12 MEMBER LEVY: That may be easier

13 to deal with, actually. 

14 MEMBER CASKEY: Yes, it seems like

15 going down the road it may be that you have

16 the actual requirements in one section, and

17 then maybe the installation recommendations or

18 guidelines or something like that would be

19 like a separate part of the document.

20 MEMBER LEVY: I think that's a

21 good addition. 

22 I mean, we should talk about
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1 installation quality as we're going through

2 these, keep notes of those, and then look to

3 incorporate those into an overall section

4 perhaps later on.

5 MEMBER CASKEY: Perfect. Thanks.

6 MEMBER SCHNEIDER: Just quickly. 

7 Peter Schneider from Efficiency Vermont.

8 I just keep coming back to

9 thinking about the comprehensive approach to

10 a better home. 

11 And just that if we're not talking

12 about where HVAC systems have come in regards

13 to, for instance, ductless mini-splits being

14 able to provide the cooling and heating needs

15 in these homes, heat pump water heaters,

16 offsetting cooling, dehumidification demands,

17 and also having all sorts of other benefits.

18 I'm just -- those can make a lot

19 of these other thermal requirements far more

20 cost-effective and easier to achieve, such as

21 getting ducts out of the envelope just as an

22 example. And so I feel like that should be
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1 part of the conversation and we shouldn't, you

2 know, ignore it.

3 MEMBER LEVY: Yes, that's a good

4 point. And the question, Peter, is where does

5 that come in. Again, does that come into each

6 one of these discussions and we'll figure out

7 how to handle it later? 

8 You know, when you're talking

9 about taking ducts out, that could be a

10 performance path discussion. It could be a

11 discussion under duct tightness, under the

12 duct tightness, or it could be up in the

13 thermal envelope.

14 Again, we could talk about changes

15 to this organization if there's better ways to

16 handle that, or we can just keep notes on that

17 as we go and figure out how to address that at

18 some point later. 

19 Do you have a specific thought

20 about that, Peter?

21 MEMBER SCHNEIDER: No, no, that

22 sounds great just to deal with it as we go
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1 along. I think it will make sense where those

2 fit in.

3 One other comment, and I think it

4 just came up a lot this morning was ultimately

5 all these restraints that the manufactured

6 housing industry keeps indicating in regards

7 to, you know, the heel on our truss is only

8 this tall, or our floor system is only this

9 deep.

10 And not only do I want to better

11 understand those constraints that they see

12 moving forward, but I also want to understand

13 why we can't think outside the box, and that

14 maybe some of the manufacturing practices and

15 strategies currently used are not ideal to

16 move forward with better homes in mind.

17 MR. RAMIREZ: Okay, thank you.

18 MEMBER LUBLINER: Yes, Mike

19 Lubliner. I just want to clarify too. Peter

20 was talking about water heating and heat pump

21 water heater technologies. 

22 And it's unclear to me if that's
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1 even the scope of our ASRAC rulemaking. And

2 if so, where would it fit here? That's kind

3 of in response to Peter.

4 And then I had a separate question

5 having to do with the labeling for the purpose

6 of the consumer, the energy efficiency level

7 of the home so the consumer can shop around

8 with a consistent yardstick.

9 And that also could tie into the

10 design of the HVAC, sizing of the HVAC system. 

11 So I'm wondering whether we're looking to

12 reassess the current way that HUD does their

13 data plate and reinvent in a way that's more

14 useful to both the heating contractor and the

15 consumer.

16 MEMBER LEVY: I guess there was a

17 couple of questions in there.

18 One of them had to do -- might be

19 covered under "Additional Energy Measures." 

20 But I think it would be good to get some

21 direction as to whether those things like hot

22 water heaters could be or should be part of
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1 this discussion. 

2 Joe, do we look to you for

3 guidance on that?

4 MR. HAGERMAN: No, you're not

5 setting me up. You brought this question up

6 at least three times now? Yes, three times

7 today. And general counsel is going to look

8 into it.

9 MEMBER LUBLINER: Again, this is

10 Mike Lubliner. For the labeling thing

11 compliance and verification might be an

12 appropriate area. But it does overlap with

13 all of them as you've noted, Emanuel.

14 MEMBER LEVY: Thank you. I'm

15 trying to get into the discussion here. This

16 is just one organization so we'll try to have

17 enough arms on the Christmas tree to hang all

18 our bulbs. Literally and figuratively.

19 Okay. So I want to try to get

20 controversial right away because we need to

21 come to some resolutions about where we stand

22 on some issues that will have a rippling
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1 effect through the discussions that we have.

2 So I put a couple of things up

3 here just to get the debate going. This is a

4 little bit different, I think, than the

5 version that's been passed around.

6 But I have three which I want to

7 suggest as guiding principles. This will help

8 us formulate what we're about in terms of what

9 direction we're moving in. I don't think we

10 have to spend a lot of time on this but I

11 wanted to just see the discussion by stating

12 a couple of things.

13 The first is that it's important

14 that cost and particularly life cycle cost be

15 taken into consideration. 

16 But my own view is, and this is

17 kind of an evolving view, is that we should

18 start our conversation assuming that this

19 industry, the manufactured housing industry,

20 should meet the thermal requirements of the

21 2015 IECC.

22 I recognize this is going to be --
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1 there should be a life cycle cost analysis

2 done that would supplement that, but that

3 would be the benchmark.

4 My own view is that that should

5 set the upper limit on energy efficiency and

6 the life cycle cost might be used to rein

7 those requirements back a bit. And I can

8 explain why I have that view. 

9 But that's my proposition to throw

10 out as a first kind of guiding principle. And

11 I think it's an important place for us to

12 start dialogue because I know there's

13 different views around the table on that

14 point.

15 MEMBER LACEY: This is Eric. I

16 generally agree with that. I think that's a

17 good approach.

18 There may be cases, I don't know

19 what they are. There may be cases where going

20 more efficient might be cost-effective. And

21 I think the statute kind of allows for that.

22 If we identify during this process
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1 that, wow, there's a little more room where we

2 can go cost-effectively and get more efficient

3 we should be open to that.

4 But I do agree with where you set

5 that up as kind of the starting point.

6 MEMBER LEVY: Louie?

7 MR. HAGERMAN: This is Joe

8 Hagerman, DOE.

9 My only comment to this principle,

10 I think it's a good starting principle. 

11 We're looking at the life cycle

12 costing for the entire building though, right? 

13 That's what you're saying? You're not doing

14 the life cycle costing of each measure because

15 obviously there's integrated effects that come

16 out.

17 MEMBER LEVY: I think the short

18 answer to that is life cycle cost on a

19 marginal basis. We may be talking about two

20 different things.

21 I'm specifically talking about the

22 thermal envelope. I think most of our focus
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1 thus far has been on the thermal envelope and

2 quantifying the costs and the benefits of

3 those measures. 

4 As opposed to tightening the ducts

5 or reducing the air filtration of the house

6 which is very difficult to quantify from a

7 cost standpoint. 

8 MR. HAGERMAN: So, what I'm trying

9 to convey is I think this group should come up

10 with energy efficiency measures as a package. 

11 We're going to do ducts here, we're going to

12 do insulation here, et cetera, et cetera. And

13 then run the life cycle of that package.

14 They shouldn't do the life cycle

15 of just each individual measure. Right?

16 MEMBER LEVY: Well, just to make

17 sure we're talking about the same thing. 

18 Matthew today gave a presentation. 

19 And on his presentation he showed a chart and

20 there were different points on a curve.

21 When you go from point to point

22 that's where the way you typically do life
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1 cycle cost analysis. 

2 MR. HAGERMAN: Degrees?

3 MEMBER LEVY: You're doing a

4 marginal analysis. You're looking at the next

5 point to see whether relative to the last

6 point it's cost-effective. So, if that's what

7 you're talking about I would agree with that.

8 MR. HAGERMAN: So it's packages

9 though of different measures. 

10 MEMBER LEVY: No. 

11 MR. HAGERMAN: Each point could be

12 packages of different measures. We're not

13 looking at 12 different life cycle --

14 MEMBER LEVY: Yes, you're right.

15 MR. HAGERMAN: Okay.

16 MEMBER LEVY: But a package --

17 what you're really looking at, I think, is a

18 difference in life cycle cost value between

19 package A and package B.

20 MR. HAGERMAN: That's right.

21 MEMBER LEVY: And that may be only

22 the change of one item in that package.
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1 MR. HAGERMAN: Could be. Could

2 be.

3 MR. RAMIREZ: So, let me ask the

4 group. Let me see a show of thumbs. Are you

5 okay with that?

6 (Show of thumbs)

7 MR. RAMIREZ: Okay, go ahead.

8 MEMBER ROY: I'd have a hard time

9 explaining to my members why we wouldn't even

10 consider going to ticket-adopting measures

11 which delivered a better result than IECC

12 2015.

13 I think, as Eric says, there may

14 be a couple of things that show up that turn

15 out to be crazily cost-effective.

16 And this is sort of saying we

17 won't exceed the 2015 requirements. And I

18 just don't know why.

19 MR. RAMIREZ: No, I think what

20 that's saying is as a starting point. 

21 However, as the discussion goes that may

22 happen. Is that?
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1 MEMBER ROY: That's not what that

2 sentence says.

3 MEMBER LEVY: No, Robin

4 interpreted exactly correctly.

5 MR. RAMIREZ: Okay.

6 MEMBER ROY: I just think as a

7 practical matter we won't find many cases that

8 we'd want to go beyond 2015 that make any

9 sense. 

10 But if something jumps out as

11 really attractive it would be very hard to

12 explain why we didn't pursue it.

13 I'd have to also say for something

14 going beyond 2015 was really something to be

15 attracted you'd wonder why it wasn't in the

16 2015. Folks worked really, really hard to

17 that end. 

18 I don't think it will help us in

19 anything. It will make it hard to explain

20 what our mission was.

21 MR. RAMIREZ: Mark?

22 MEMBER WEISS: You're calling for
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1 a show of thumbs, what, just on the 2015 part

2 of this? IECC 2015? Or the entirety?

3 MR. RAMIREZ: No, that first part

4 over there, that first part of the sentence,

5 right? Where it says, "To the extent that the

6 parties' impact of energy features covered by

7 the standard can be quantified in terms of

8 energy impacts and cost. Decisions should be

9 based on life cycle cost criteria but not

10 exceed the IECC 2015 requirements." That

11 sentence right there.

12 MEMBER WEISS: Unfortunately I

13 can't divorce that from the rest of it. So,

14 I'll have some comments on the entirety of it

15 in a moment.

16 MR. RAMIREZ: Okay. 

17 MEMBER CASKEY: So, just to make

18 sure I'm clear. So what I was looking for is

19 that when you offered this framework, you

20 know, moving towards this term sheet, I mean,

21 that's like our ultimate goal. That's what

22 we're trying to get to.
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1 And I understood that these

2 guiding principles would be related to -- that

3 would be like the introduction to this whole

4 term sheet that we would live by for this

5 whole process.

6 But then in the course of

7 answering a question you said well, really

8 we're just talking about -- and stuff like

9 that. 

10 I think when Joe asked a question

11 I think your answer related to, well, really

12 we're primarily talking about the envelope.

13 So I'm hoping that these guiding

14 principles would be generic for the whole

15 process and not just related to the envelope. 

16 Is that your understanding?

17 MEMBER LEVY: Yes, it's the whole

18 process. It may be that there's certain

19 things that we can't do life cycle cost

20 analysis on because certain parts of it can't

21 be quantified.

22 MEMBER CASKEY: Yes, that's fine.
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1 MEMBER LEVY: Yes, okay. 

2 MEMBER SCHNEIDER: This is Peter

3 Schneider from Efficiency Vermont. Just one

4 comment as an example.

5 In regards to exceeding IECC 2015

6 in two extreme climates, one being like New

7 Orleans, Baton Rouge area we evaluated sort of

8 a high-performance manufactured home down

9 there and the same up in Vermont.

10 But we found that ultimately we

11 did need to exceed IECC 2015 in a couple of

12 areas. And if we did we eliminated a

13 traditional HVAC system and we were able to go

14 with a ductless mini-split, significantly

15 reducing the complexity and cost of the

16 mechanical system and then also at the same

17 time increasing efficiency and allowing for a

18 much better thermal envelope as we removed all

19 those ducts from the system. So, again, that

20 comes back to this whole comprehensive

21 approach. 

22 And to ignore the advancements in
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1 mechanical systems these days and the benefits

2 of heat pumps is going to really skew this

3 life cycle cost analysis.

4 MR. RAMIREZ: Eric, you had

5 something?

6 MEMBER LACEY: Yes, I guess. I'm

7 a little confused because what you're showing

8 up there is not the same thing that I had in

9 front of me.

10 MEMBER LEVY: Yes, that's -- I

11 mentioned I changed that part.

12 MEMBER LACEY: Okay.

13 MEMBER LEVY: But mainly to get

14 this conversation going.

15 MEMBER LACEY: Yes. And I guess,

16 and I don't want to wordsmith it too much, but

17 I think I'd be more comfortable if it said

18 something like "starting with the 2015 IECC

19 requirements," or "based on" or something like

20 that. Rather than "not exceed." You know,

21 just to capture this idea.

22 And maybe it's only a couple of
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1 things. Maybe a few more efficient light

2 bulbs would be more cost-effective, or

3 something like that. It might not be very

4 many things or anything. But just to leave

5 that open. Anyway, I'll leave it there.

6 MS. HOFFMAN: So, just to clarify,

7 you're saying your modification would be

8 instead of saying not to exceed, to be based

9 on as a possibility. Which could allow going

10 farther or whatever. 

11 Okay, Manny had a comment. Oh,

12 okay.

13 MEMBER TOMPOS: I can go. Dave

14 Tompos.

15 I guess I have a little concern

16 about saying life cycle cost. We keep

17 bringing up this word "life cycle cost

18 analysis" but we haven't defined what that is

19 yet. 

20 So for me to agree to that it's

21 very difficult to do until you tell me if it's

22 30 years, 50 years, 5 years and what that
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1 involves. 

2 And then still keeping in mind

3 what we have, the second bullet point that we

4 aren't to yet, but that first cost.

5 To me it doesn't make a difference

6 if we go beyond 2015 or below it as long as we

7 all agree to what "affordable" is and define

8 that in this life cycle cost analysis. 

9 Because I have a concern that if

10 we can -- if you say it's 30 years and we can

11 show that we add $5,000 to the price of the

12 home and they get that paid back over that 30-

13 year period, you know. As Mark showed earlier

14 the average income is, what was it, $26,000? 

15 Somewhere in that range? Twenty-seven?

16 You add $5,000 to the price of

17 the house, they're never going to get in it in

18 the first place.

19 So, until we define what

20 affordability is or what that life cycle cost

21 analysis is it's hard to say, yes, we're going

22 to base our decisions on that.
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1 MR. RAMIREZ: Manny?

2 MEMBER SANTANA: Yes. Manny with

3 Cavco.

4 I think that saying that we can't

5 exceed the 2015 requirements is a moot point

6 because that's part of what DOE's mandate is,

7 that we go to the IECC unless a more stringent

8 standard is more cost-effective. 

9 So I understand that we have to

10 start somewhere and we have to have a cap of

11 sorts. So I think that statement is correct. 

12 But we might just want to add not to exceed

13 the 2015 requirements unless more cost14 effective. And then move onto the next point.

15 MR. RAMIREZ: The other

16 modification I was looking at was unless the

17 group by consensus agrees otherwise. Right? 

18 Unless the group by consensus agrees

19 otherwise. 

20 So if you all as a group say, yes,

21 in this area we do want to exceed the 2015

22 standard you all decide.
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1 MEMBER DENNIS: This might just be

2 like a clarification for my benefit, but

3 having been through the IECC process everyone

4 gets up there and testifies on all these

5 different hundreds of code proposals. And

6 things kind of get ad hoc thrown in and thrown

7 out. 

8 And when we're talking about

9 evaluating against that I guess is there --

10 we're just talking about that one life cycle

11 metric? 

12 I mean, it seems to me that there

13 may be places where you go above it in one

14 spot, below it in another spot and then -- are

15 we all agreeing that there's one metric by

16 which you exceed or don't exceed the IECC

17 metric?

18 Because I could see a lot of

19 places where we might tweak things up or down

20 on different components. And I don't know

21 that there is one metric that you said we

22 exceed it or not, unless you really define
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1 what that metric is.

2 And I don't know that there's any

3 real benefit to doing that. I mean, I guess

4 for life cycle cost you would just be -- you'd

5 have a variable that you're minimizing or

6 something.

7 So, maybe somebody could explain,

8 you know, what it means to not exceed IECC. 

9 Does that mean in total in one specific

10 metric, or is it on different components, or

11 what?

12 MEMBER LEVY: I think we would be

13 saying that that would be the framework that

14 we would be working from.

15 We might later on as we get into

16 the specifics decide on a specific item to go

17 in a different direction. 

18 But the concept here is that when

19 in doubt don't do anything more stringent than

20 the IECC 2015.

21 And let me just clarify one

22 comment that's been made about we should use
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1 life cycle cost if it's more -- the

2 requirements might be more than or less than

3 IECC. 

4 That's equivalent to saying let's

5 not use IECC where we can use life cycle cost. 

6 Right? Do we agree about that?

7 I mean, basically we're saying

8 anything that can be subject to life cycle

9 cost should be subject to life cycle cost and

10 IECC 2015 doesn't have any real meaning.

11 MS. VAIDYANATHAN: This is Kavita

12 Vaidyanathan of general counsel at DOE.

13 I mean, I understand what I think

14 the group is trying to do, but the statute

15 requires you, the group -- for DOE to base the

16 requirement on the 2015 IECC, and then to look

17 at life cycle cost.

18 So the standard shouldn't look at

19 life cycle cost in the first instance. You

20 should look at the 2015 IECC. And then if

21 it's not cost-effective, then you can change

22 the requirement. 
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1 So, I'm kind of -- I'm trying to

2 see if that's where you're going, or if you

3 guys are trying to flip the requirement and

4 look at life cycle cost in the first instance.

5 MEMBER LEVY: This is the problem

6 because IECC 2015 is not going to be the

7 bottom of that curve that Matthew showed. 

8 So, it really is, you know, it's a

9 misleading parallel. It's apples and oranges,

10 really.

11 You're either going towards IECC

12 2015 or you're doing a life cycle cost. 

13 They're two completely different items. The

14 fact that the statute put them together

15 doesn't mean that they belong together. 

16 They're really two different ideas.

17 2015 was a consensus standard

18 based upon a number of people sitting around

19 the room making a judgment without economic

20 criteria in front of them. 

21 We're trying to make a decision

22 about whether we should discard that and just
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1 base our entire analysis on life cycle cost

2 decision-making. 

3 MS. VAIDYANATHAN: Okay, so maybe

4 I don't understand. Can you not start with

5 the basis of 2015 and then show --

6 MEMBER LEVY: It doesn't really

7 matter. Ultimately Matthew will tell you it

8 doesn't matter where you start. You're

9 finding the minimum point. It doesn't matter

10 where you start on that curve, you're going to

11 find the minimum point.

12 And life cycle cost won't -- the

13 IECC 2015, that point, won't be even on that

14 curve probably in most cases. Because it has

15 a combination of measures some of which are

16 not cost-effective by definition. 

17 MS. HOFFMAN: Mark?

18 MEMBER WEISS: With all due

19 respect I have to disagree with OGC. The

20 statute says, "Except in cases in which the

21 Secretary finds that the Code" - meaning the

22 IECC 2015 - "is not cost-effective or a more
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1 stringent standard would be more cost2 effective based on the impact of the Code on

3 the purchase price of manufactured housing and

4 on total life cycle construction and operating

5 cost."

6 I think that constraint goes to

7 evaluating each and every aspect of this from

8 both perspectives, from purchase price impact

9 and life cycle cost impact. 

10 Otherwise, how are we going to

11 determine whether or not something other than

12 2015 IECC is more appropriate? I don't see

13 how you get around that analysis. 

14 Whether you start with 2015 makes

15 no difference to me. But everything involved

16 with that has to be analyzed from both

17 perspectives. 

18 Now, having said that and since

19 David kind of verged into it with his comments

20 my problem here is I can't divorce what you're

21 saying about 2015 as I indicated earlier,

22 IECC, from both of these statements, bullet
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1 item 1 and 2.

2 As will come as a surprise to no

3 one, in my view the first consideration has to

4 be purchase price impact and then life cycle

5 impact. Because again, for somebody who is

6 excluded from the market there is no life

7 cycle. 

8 So it concerns me when I see

9 language in here like tempered and if and when

10 it's demonstrated that such standards will

11 significantly reduce the -- I guess that means

12 the number of qualifying households.

13 You know, that effectively

14 requires somebody to prove a negative that,

15 you know, if you go forward and do some of

16 these things that it won't have an impact on

17 the number of people who can qualify. I just

18 think those two bullet items put the logic and

19 the economics backward.

20 And since the statute does not

21 indicate a preference for the order in which

22 these things are considered I think the
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1 logical thing to do and then the economically

2 realistic thing to do is to look at purchase

3 price impact and then temper that by life

4 cycle impact. So I would switch the order. 

5 And that's not just a wordsmithing

6 issue, that's a substantive issue.

7 MR. RAMIREZ: Let me ask the

8 group. Is it substantive in the sense that we

9 need to know this in order to get structure to

10 our conversation? Right?

11 I mean, is there a way through a

12 strawman that we can put something forward

13 knowing that we're going to be looking at the

14 2015 IECC, we're going to be looking at LCC,

15 we're going to be looking at cost.

16 And I say cost purposely, not just

17 the purchase price but also just to live in

18 the house.

19 We're going to be looking at all

20 that so all that stuff is going to be in our

21 minds as we're looking through this data.

22 Is it essential to nail this down
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1 in order to start having that discussion? To

2 look at a strawman?

3 MEMBER WEISS: I think we can look

4 at it in terms of --

5 MEMBER SCHNEIDER: This is Peter

6 Schneider from Efficiency Vermont.

7 MR. RAMIREZ: Peter, hold on one

8 second. Let Mark finish his comment.

9 MEMBER WEISS: I think we can

10 begin looking at concepts, but I think when

11 push comes to shove this issue has to be

12 resolved. 

13 Timing, you know, I just don't

14 want to get too far down the road where

15 commitments have been made, votes have been

16 taken, and then all of a sudden somebody comes

17 back and says oh yes, what about this. And I

18 don't want to be that person.

19 MR. RAMIREZ: You mean like the

20 cost.

21 MEMBER WEISS: Yes. I think

22 that's a fundamental aspect and fundamental
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1 issue involved here. 

2 And I think, you know, I don't

3 have a problem with looking at the other

4 elements of the strawman and talking about

5 them and so forth.

6 But I think one of the first

7 decisions that has to be made here is how we

8 are looking at these cost issues.

9 MEMBER ROY: I've got to say

10 Ishbel has been waiting to say something

11 apparently. I got an email from her. So, I

12 also have a comment but let her go if she's

13 available.

14 MR. RAMIREZ: Okay. Ishbel, are

15 you available?

16 MEMBER DICKENS: Can you hear me?

17 MR. RAMIREZ: Yes. You have to

18 mute your webinar, otherwise we're going to

19 get that feedback. 

20 MEMBER DICKENS: It was somebody

21 at your place.

22 MR. RAMIREZ: Can you mute her? 
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1 Or you could pick up the phone and try just

2 the phone versus the speaker phone. 

3 MEMBER DICKENS: Okay, can you

4 hear me now?

5 MR. RAMIREZ: Yes, that's better.

6 MEMBER DICKENS: All right. So

7 I'm hearing myself echoing but hopefully

8 you're just hearing me once. 

9 MR. RAMIREZ: Yes, no, it's much

10 better on this end.

11 MEMBER DICKENS: Okay. I think I

12 would agree with what Mark has been saying. 

13 It's been difficult to follow the conversation

14 while I've been dealing with the technical

15 problems.

16 But I think the sentence around

17 the intent is to provide a positive economic

18 return to homebuyers is paramount. 

19 There's no point in having

20 fabulously energy efficient homes if the

21 people that we're trying to serve aren't able

22 to purchase them.
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1 And I don't want to make that -- 

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

3 we're -- can you back up a little bit just

4 because we weren't able to hear you there,

5 those last few words.

6 I'll tell you what. Let's try --

7 Ishbel, if you could try a couple of different

8 things. 

9 Maybe, I don't know if there's a

10 way to pause the webinar, but let's get Peter. 

11 Peter has been waiting as well. Let's get

12 Peter while we try to work out some of those

13 technical issues. Peter, you there?

14 MEMBER SCHNEIDER: Yes, thanks. 

15 Okay, I was just sort of -- yes, I'm here. 

16 Can you hear me okay?

17 MR. RAMIREZ: Yes.

18 MEMBER SCHNEIDER: Okay. Yes, a

19 response to Mark in part, but just a comment

20 to the group.

21 I think that we can speak about

22 the purchase price over and over again and
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1 that we'll be pushing a lot of folks out of

2 the ability of purchasing one of these homes

3 with improvements.

4 But I think in reality that would

5 not be the case. As we're showing in Vermont

6 with an improved mobile home replacement,

7 while there is a higher initial cost we now

8 have lenders providing traditional financing,

9 lower down payments, better lending ratio.

10 And if we continue to just

11 consider the current lending market for a

12 typical HUD-compliant home again I think

13 that's a bit shortsighted.

14 So I think we need to think

15 outside of this box of this is, you know,

16 ultimately how these homes are considered. 

17 Whether it be private property loans with poor

18 terms and poor interest rates. 

19 But if we provide and develop a

20 standard that a product that is equivalent

21 with a typical stick-built home, say, meeting

22 IECC 2015, you know, hopefully we can
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1 collaborate with our lending partners and

2 begin to see far better terms that will allow

3 folks to get into homes that are at a higher

4 purchase price but that offer much lower

5 operating and maintenance costs. 

6 And hopefully we're creating homes

7 that don't depreciate in value moving forward

8 but actually will hold their value or even

9 appreciate because of the features we included

10 in this new code.

11 MR. RAMIREZ: Okay. Ishbel, you

12 want to try one more time? Okay.

13 So, Mark -- I have Mark, Luby and

14 Robin.

15 MEMBER ROY: I think we must

16 continue to refer to the purchase price

17 because it's right there in the act.

18 And in the end it's a lot like the

19 Supreme Court's understanding of pornography. 

20 We will have to see if we -- you know it when

21 you see it. And we may not know it as this

22 group what we want to put forward. 
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1 We don't have a way to define

2 what's the balance between the purchase price,

3 the life cycle cost, the financing ability

4 which relates to the life cycle cost. We

5 don't have a way to define what the proper

6 blending of those things in some abstract way.

7 Let's take a look at some numbers. 

8 Let's not drop any of these important pieces

9 of information off the analysis. There's no

10 reason to drop them off the analysis. It will

11 show up in the analysis you do. And when we

12 get back together in three weeks we'll have a

13 really good understanding of what kind of

14 tradeoffs we're talking about.

15 I think Peter's points are really

16 very, very interesting. 

17 Let's see what the numbers add up

18 to. I think, Mark, your concerns are really

19 well-founded.

20 So let's take a look at some

21 numbers. If we can figure out what the

22 pornography is then we'll be really happy in
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1 a few weeks. Is that a bad thing to say?

2 MR. RAMIREZ: No, and I think that

3 was my point is that we need to see something,

4 right? Okay. 

5 So let's go to Mark and then Luby

6 and then we'll try Ishbel again.

7 MEMBER WEISS: Two things. First,

8 in response to Peter. Look, I'm not a finance

9 person but as I understand it the dearth of

10 financing for manufactured housing is not

11 driven by a lack of energy efficiency

12 features. There are a lot of other things

13 involved with that.

14 I'd also, I'd like to recognize

15 Mr. Surrena. He had some things he wanted to

16 say. If I -- I believe I can recognize him

17 to? Okay, thank you.

18 MR. SURRENA: Thank you, Mark. 

19 Don Surrena, National Association of Home

20 Builders.

21 We're talking about manufactured

22 housing meeting the 2015 IECC. And for a
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1 doublewide house that can analogize and be

2 very similar.

3 But if you're looking to do the

4 same thing for a singlewide you've got design

5 constraints there that just won't work with

6 the 2015 IECC. 

7 Again, doublewides, they're more

8 conventional in size, in style and in

9 construction. But for singlewides I've heard

10 no conversation that set a different criteria

11 or an allowance for the singlewide. 

12 And I think if we get into this

13 too far you're going to have an issue with

14 singlewide manufacturers meeting the same

15 requirements that a doublewide would meet.

16 It in essence to me is going to

17 require two sets of criteria for you. And the

18 IECC, I've never heard it characterized as

19 being something that will add longevity to the

20 life cycle of a building, of a structure. It

21 will give you some efficiency, but it will not

22 add to the life and lower the maintenance cost
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1 for that. That just does not happen. Thank

2 you.

3 MR. RAMIREZ: Okay. Luby?

4 MEMBER LUBLINER: Mike Lubliner

5 here. I'd like to stick to what's in the act

6 in terms of evaluating all the measures and

7 seeing -- using life cycle cost principal once

8 we've agreed to what the inputs to the life

9 cycle cost analysis should be and the

10 procedure for evaluating those inputs.

11 So, the chips are going to fall

12 where they may, you know. Whether we want to

13 say the I-codes is a good starting point. 

14 We're going to find stuff that's below the I15 codes. 

16 We might find stuff that's above

17 the I-codes. For example, heat pump water

18 heaters might be cost-effective in the hot

19 South. And the I-codes is already looking at

20 water heating savings. This predicated on

21 some assumptions about what the authority DOE

22 has. But I'm just using that as an example.
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1 I think it's crazy to sit here and

2 speculate until we do the analysis.

3 To Dave's point, I think that we

4 need to buy into a life cycle cost procedure. 

5 You were more concerned about what the inputs

6 to that analysis was I thought, not the

7 procedure per se.

8 And then to Mark's points, I would

9 suggest that once we've done the analysis we

10 can look at where the cost-effective -- life

11 cycle cost-benefit that provides the maximum

12 benefit to the consumer.

13 And then we can look at the

14 demographics of the industry and determine

15 what percentage of people are priced out of

16 the market as a result of that. And then we

17 can tweak it if we think it's appropriate.

18 But what's going to happen in

19 actuality is we're going to find that if we

20 define, say, the affordable housing sector, X

21 percentage of the people in that sector are

22 going to benefit from higher energy standards
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1 and Y percentage aren't.

2 So, are we saying -- Emanuel, when

3 you say significantly reduce, does this mean

4 that every homeowner -- that no homeowner in

5 the United States when we change these

6 standards can change in terms of the

7 qualification? No, people are going -- at the

8 lower end some of them are going to fall out.

9 What we also have to analyze is

10 how many is the industry going to pick up as

11 a whole. 

12 What we've found in the Northwest

13 -- and we have published peer-reviewed

14 research that we would be happy to share, I

15 think I have shared it in my ANOPR comments --

16 is that when you produce a product with higher

17 insulation values you start to get buyers from

18 a higher market sector. And the actuality is

19 you may increase your sales in that sector.

20 And this is not a justification

21 for, you know, that we're going to be building

22 houses for richer people at the expense of
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1 poor people.

2 But we're going to recognize that

3 when we change this it doesn't work all in one

4 way, that we do get growth and I believe we

5 get growth in the market at the higher end.

6 And those homes at the higher end

7 are more profitable to the industry, they

8 produce less defaults by definition. And so

9 I think that it will be important that we look

10 at what Mark wants to do. But we need to look

11 at it holistically and look at all the impacts

12 it has on the market and the industry, not

13 just the affordable housing sector.

14 I'd also like to say that the

15 information that could come out of this could

16 help guide policy people at HUD and DOE to

17 help stopgap with incentive programs like the

18 millions of dollars they put into ENERGY STAR

19 for this industry. Perhaps we need to be

20 focusing on taking those resources and using

21 them in the affordable housing sector, and not

22 spreading them across.
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1 So I think there's ways of doing

2 this but we really have to start with the life

3 cycle cost analysis. 

4 So, to summarize. "Significant"

5 needs to be clarified. And I would say that

6 we don't stop at 2015. We see where the chips

7 fall. Thank you.

8 MR. RAMIREZ: Okay. Mark and then

9 Robin.

10 MEMBER WEISS: With all due

11 respect I think that formulation puts the cart

12 before the horse as I indicated earlier as to

13 the industry picking up demand.

14 You don't need a standard to pick

15 up upscale demand. If that demand were there

16 we'd have it now. People would pay for it. 

17 Nothing's stopping them from doing that now.

18 MR. RAMIREZ: Robin?

19 MEMBER ROY: Robin Roy, but I'm

20 channeling Ishbel and an email from her.

21 She just wants to highlight that

22 we need to ensure homes are affordable -- I
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1 think that's what Mark's been talking about

2 and a few of us -- while still providing

3 energy efficiencies. 

4 She likes what Peter is saying and

5 hopes that he can provide some good examples

6 of how the model works and is affordable for

7 low-income people.

8 And p.s., she says, this is so

9 frustrating and p.p.s., she does not reference

10 pornography. 

11 But I think that really is once

12 you get back to -- we don't need to go too far

13 down this. We need to get back to just going

14 onto the analysis we're going to have. Back

15 to your point.

16 MR. RAMIREZ: Well, you know, and

17 I really do want to get into the work that

18 you've done, that Emanuel has done.

19 And part of what I'm seeing

20 already as might be some difficulty is that

21 even though when you take this step by step

22 there is no just straight path. It's not
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1 going to be logical and linear, it's going to

2 be messy.

3 Do we need a strawman, right,

4 where it's just an initial shot of a full term

5 sheet so that we need to bounce around a

6 little bit. We have some content there that

7 we could reference.

8 And I don't think that, at least

9 some of the slides that I saw from earlier, I

10 don't think that singlewide and doublewide is

11 missed here. I saw something referenced in

12 there about doublewide.

13 So when we're doing this, if we

14 have to distinguish between single and double

15 we'll do that at that time, right. If there

16 is a distinction in a certain standard.

17 MS. HOFFMAN: Yes. It's Eileen. 

18 I just want to add that it sounds like we've

19 got a number of things. 

20 The charter that this working

21 group has is very tough which is really

22 looking at the 2015 IECC standards. Also
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1 looking at life cycle costs. Looking at a

2 number, a variety of things.

3 If you want to decide, those are

4 all of the things you've got to look at, what

5 goes into life cycle costs, how you will apply

6 the 2015 standards.

7 If we can get some general

8 understanding without perhaps weighting them

9 we can move onto seeing where the numbers go. 

10 I'm just throwing that out.

11 MR. RAMIREZ: Okay, let's go to

12 Robin and then back to Mark.

13 MEMBER ROY: I actually do think

14 we heard one approach to these standards

15 earlier this morning from Eric that does

16 relate to the difference between singles and

17 doubles and that has to do with this UA. 

18 It's an interesting approach. A

19 lot of familiarity in the industry. I'm

20 looking forward to hearing back from your

21 members, Mark, on their familiarity with it. 

22 But that actually directly
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1 addresses if we get the numbers for the

2 components right for the UA values then this

3 kind of all gets pretty nicely self-adjusting. 

4 Does that make sense to anybody? 

5 I actually think it works in a pretty good

6 way, but we can talk about that.

7 MR. RAMIREZ: All right. So, is

8 everyone okay then with not necessarily having

9 nailed down the guiding principles, right? As

10 long as we're looking at the numbers. 

11 We're keeping in mind all these

12 concepts anyway, right? We're keeping in mind

13 the IECC 2015 life cycle cost and just cost in

14 general, right? Purchase versus maintenance. 

15 Everyone is going to have that

16 stuff in their heads as we're going through. 

17 So do you want to pick it up from there?

18 MEMBER LEVY: Yes. You know, I'm

19 feeling pretty good, actually, about what

20 we've done so far, that we're on the right

21 topics and these are the ones that are drawing

22 out the discussion.
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1 The one thing I want to mention is

2 I think we're debating now whether to change

3 the first principle to take out the last part

4 of the first sentence entirely. That's what

5 the debate is about. 

6 Whether 2015 becomes the upper end

7 or not. Or we just go with life cycle cost

8 and see later how IECC '15 measures up. 

9 MS. HOFFMAN: No, no offense, but

10 I think the DOE general counsel is weighing in

11 the other way. I mean, that's what I've been

12 hearing.

13 MR. RAMIREZ: Yes, I think the one

14 thing that I saw some folks bobbing their

15 heads on was that unless the group by

16 consensus agrees otherwise, right? No?

17 MS. HOFFMAN: No. What I heard --

18 maybe -- this is your elephant, okay? What I

19 heard was on the -- but not to exceed the IECC

20 2015 requirements unless they're more cost21 effective. I heard that as a potential

22 amendment that Manny had suggested.
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1 Yes, no, it's all right, but it

2 could also be in our own mandate too. I mean,

3 would that work?

4 MEMBER DENNIS: Does anyone object

5 to going above IECC on certain types of things

6 if it's cost-effective? Or are people just

7 confident that's not going to happen? Then

8 what's the problem with putting it in there?

9 MEMBER LEVY: Go ahead. Is

10 somebody on the line?

11 MEMBER LUTER: Rob with Lippert. 

12 Just a couple of comments. 

13 Based on Mark's reading of the

14 statute, I mean, we're talking about what

15 words mean, what "significant" means, what

16 "affordable" means. 

17 The one constant that we know what

18 it means is the IECC 2015. This is what we're

19 tasked to start with. And as I understand the

20 statute in plain language it says base your

21 analysis on this, unless you can prove it's

22 not cost-effective. 
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1 Now, I think we're going to have

2 instances where it will be clear that it's not

3 cost-effective however we ultimately choose to

4 define cost-effectiveness. 

5 But we'll have perhaps some other

6 instances where we're surprised at how cost7 effective it is. And those will be the keys

8 for us to go farther.

9 We can't start with something more

10 stringent than the IECC because we don't know

11 what that is. We do know what the 2015 IECC

12 is though. And it's a benchmark. 

13 So, what I might suggest is that

14 that sentence be changed to something like,

15 "Decisions should be based on life cycle cost

16 and criteria based on the 2015 IECC," period. 

17 Then next sentence.

18 MS. VAIDYANATHAN: This is Kavita

19 Vaidyanathan of the DOE general counsel.

20 I just don't understand who you

21 can't just copy what's in the statute as your

22 guiding principle. And that would include
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1 purchase price which Mark Weiss is concerned

2 about and the total life cycle cost.

3 MS. HOFFMAN: So, do we have

4 consensus on the statute?

5 (Laughter)

6 MS. HOFFMAN: Manny, are you

7 teasing or you mean that?

8 MEMBER LEVY: That sounds good.

9 MS. VAIDYANATHAN: Okay.

10 MEMBER LEVY: And you can put up

11 there. No problem. We can all agree to it.

12 But as a practical matter it's not

13 a way forward. When Matthew or whoever is

14 going to do the analysis sits down and does

15 the analysis he's not even going to look at

16 2015.

17 What he's going to do is he's

18 going to create just what Joe was saying,

19 packages of measures that are cost-effective. 

20 He's going to create a curve, find out what

21 the bottom point is on the curve. 

22 And that point is going to
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1 represent a certain package of measures. It's

2 not going to be -- he never has to look at

3 2015 to get there. Never.

4 MR. HAGERMAN: So, this is Joe

5 Hagerman. I think it's the best starting

6 place that he would use.

7 So he's going to hear from

8 everybody here as we go through what energy

9 efficiency measures that the industry would

10 have to move to meet the 2015. And he would

11 go run those measures through his life cycle

12 cost analysis and get a cost. 

13 And then he'll give that back to

14 the group and the group's going to say, you

15 know, no, this doesn't work, or yes, this does

16 work.

17 So it's definitely a good starting

18 point. I mean, what other starting point

19 would you take?

20 MEMBER LEVY: Well, normally in

21 the way historically this has been done, it

22 was done in '92 and before that, when it was
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1 a life cycle cost-based analysis.

2 You start with the least efficient

3 point and you just keep adding conservation

4 measures in order of cost efficiency until you

5 reach that point at which adding another

6 measure will give you a negative benefit. And

7 that point, that point that you've established

8 becomes your target.

9 And the IECC 2015 is kind of a --

10 it's an arbitrary number relative to that

11 process. It's not even going to fall on the

12 curve because probably that package of

13 measures which we call 2015 was developed in

14 a different sphere entirely, includes a

15 package of measures which have nothing to do

16 with in many regards to manufactured housing,

17 and there's no reason to believe that all the

18 measures in that package would be cost19 effective.

20 So, it doesn't really enter into

21 the dialogue when you do a life cycle cost

22 analysis. It's a point you can look at, but
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1 it's not going to fall on the curve. That's

2 my view.

3 MR. HAGERMAN: That could be.

4 MEMBER LEVY: So, you don't start

5 there, you don't end there, you just -- you go

6 through your LCC analysis and you look at it

7 later and say, gee, 2015 is not cost8 effective. I think that's -- from my

9 experience that's the conclusion you'll come

10 to. So, putting IECC into the discussion just

11 confuses matters.

12 MR. RAMIREZ: I understand what

13 you're saying there. 

14 Could it be done the other way

15 though? So, if 2015 is so expensive, right,

16 where it's just not going to be efficient,

17 what if you work backwards from there?

18 MEMBER LEVY: But it's kind of --

19 it's an arbitrary point that has no bearing on

20 the whole concept of life cycle cost analysis. 

21 There's no basis for it.

22 MS. HOFFMAN: But Congress put it
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1 in the statute. So you might want to humor

2 them a little and follow it. And try out how

3 2015 would work. And if it doesn't work, then

4 you've got the rest of your analysis. I'm

5 just saying can't we proceed on two fronts.

6 MR. BARBOUR: This is Ed Barbour. 

7 As a practical matter what we'll do is we will

8 start with a package that meets the 2015 IECC. 

9 And then we'll go plus or minus off of that. 

10 And so we'll create the curves. 

11 We have to address the statute for DOE, or at

12 least that's what we were thinking. If you

13 guys tell us otherwise, that's fine.

14 But we were planning to create,

15 just like PNNL has done, create different

16 measures and meet the different levels of the

17 IECC from 2006 I believe up to 2015. So we'll

18 have that point as Emanuel says. 

19 I don't think anybody --

20 analytically we're not going to do anything

21 different whether we start at the end and add

22 incremental measures, or if we start at the
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1 2015 and work backwards and up.

2 MR. RAMIREZ: So there are going

3 to be overlays regardless of what we do.

4 MR. BARBOUR: Regardless what we

5 do we're going to have the same types of

6 analysis -- or let me rephrase that. Same

7 results and types of analysis. It's just one

8 package will be labeled 2015 IECC.

9 And whether it comes out cost10 effective or not, we'll see. So I think

11 everybody's sort of in agreement, actually. 

12 But, anyway.

13 MR. RAMIREZ: All right. Manny?

14 MEMBER SANTANA: Yes, this is

15 Manny with Cavco.

16 I feel like we're kind of going in

17 circles around here on the first sentence. 

18 You know, Emanuel on his own

19 initiative, he came up with four sheets of a

20 proposal. But it's just that, it's a proposed

21 framework to give us some direction and give

22 us a little push in the right direction.
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1 I suggest we let him just go

2 through it. Go through the whole thing in its

3 entirety. And then, you know, we might find

4 more important things to argue about a little

5 bit further.

6 MR. RAMIREZ: Thank you. Manny

7 pulled out the elbow there, right? All right. 

8 All right, you have the floor back and you can

9 start scrolling through.

10 MEMBER LEVY: Okay. So, there are

11 two more points up here. I think we've kind

12 of talked about the second point already. And

13 there's a discussion about how important this

14 should be.

15 It has to do with making sure that

16 we're not creating roadblocks to

17 affordability. Obviously I think there's some

18 concurrence in the room about that. How that

19 plays out we can talk about.

20 And there will be other topics. 

21 The third point in here is there will be other

22 topics that we'll talk about that we may not
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1 have conclusive information about but we will

2 try to as much as possible lean on peer3 reviewed scientific studies to substantiate

4 our points.

5 This is really an engineering

6 scientific endeavor that we're engaged in and

7 we're going to use the best research out there

8 to base our decisions on.

9 These are three points. There

10 probably can be 10 more. We may be adding

11 more as we go along.

12 So, given that we're doing a life

13 cycle cost analysis based -- starting with

14 IECC as the basis I wanted to identify what

15 the data needs were. And my proposal here is

16 that we would identify all the data needs. 

17 And we don't have all the data at

18 the moment. We would assign responsibility

19 for getting that data, some of that data. 

20 SBRA has volunteered to provide some of it. 

21 But we'll need quite a bit of data to help the

22 contractors do their work that is outlined.
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1 So I try to list here a couple of

2 things that are inputs. And I think we should

3 talk about each one of these even briefly as

4 we go along.

5 The first one is -- these are all

6 data inputs to the life cycle cost analysis

7 and related analysis.

8 So the first point is the thermal

9 requirements. I think that's been done

10 already by DOE and PNNL. There may be some

11 additional analysis that we talk about in

12 terms of just understanding what that

13 requirement is for the IECC. Not just 2015. 

14 Yes?

15 MR. HAGERMAN: So let me quickly

16 speak to that point. So I've already assigned

17 the window-to-wall ratio analysis to PNNL. 

18 They said they were going to try to get us a

19 result back by tomorrow. So we should be able

20 to resolve that very quickly.

21 MEMBER LEVY: The typical window

22 area. 
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1 MEMBER WEISS: Yes, the

2 abbreviation, LCC. Can you just specify?

3 MEMBER LEVY: Life cycle cost. 

4 Second point here is the cost for associated

5 building components. I don't know if you

6 pulled that up. There's a spreadsheet that

7 everybody has a copy of.

8 This addresses some of the

9 questions and comments and needs that were

10 discussed earlier today. And SBRA has

11 volunteered to provide some support in helping

12 do the analysis.

13 And this list of features might be

14 expanded. I think what we need is a pretty

15 clear understanding of how homes would be

16 built to get the various use of O-values that

17 are part of the analysis.

18 And what we're proposing is that

19 over the next couple of weeks we would

20 complete this table and any other data points

21 that need to be included in this table.

22 And that for each of the component
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1 U-values, and Matthew in particular can weigh

2 in on this, we would describe how those

3 components are built today on average by the

4 industry.

5 And the way we would do that is we

6 would put together a list of materials and

7 products that typically go into the

8 construction of each one of these U-values for

9 each component, send it back to the

10 manufacturers and have them verify that that

11 is what they would do, or if it isn't, what

12 variation they would have on that.

13 And provide back to you what that

14 final construction looks like for each one of

15 the U-values and what the cost is per square

16 foot of each of those constructions. It's a

17 little different than I think the query that

18 you sent out. 

19 But this is specific to making

20 sure it's clear how things are built and why

21 they are what they are, and what the cost is

22 that corresponds to those things. This seems
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1 to me to be the critical piece of information

2 you need to do the LCC analysis. Does that

3 make sense?

4 MEMBER SANTANA: Manny with Cavco. 

5 So, the U-values you have here for the

6 components, are those the same and what's in

7 the DOE analysis?

8 MR. HAGERMAN: Yes, I believe

9 those are copied from the 2015.

10 MEMBER LEVY: We copied the table

11 that PNNL had -- we copied the rows from the

12 table that PNNL had. And the same cities and

13 the same thermal zones.

14 MR. HAGERMAN: For units that

15 would meet 2015 IECC.

16 I have one question. So this

17 would be the average cost per square foot?

18 MEMBER LEVY: That's right. To

19 the customer.

20 MR. HAGERMAN: Could we not add

21 average and min and max? The two boundaries.

22 MEMBER LEVY: Yes. 
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1 MR. HAGERMAN: I mean, at some

2 point in time it would be nice to compare what

3 numbers get reported here to, say, some third

4 party source like RSMeans, as an example,

5 right?

6 MEMBER TOMPOS: Dave Tompos. So

7 are we expecting the manufacturers then to

8 come back and tell us that, hey, we can't

9 typically build a 0.034 floor system? Is that

10 our goal? I mean, that may be the results we

11 get back, correct?

12 MEMBER LEVY: It may be. I mean,

13 it may be that you have to build a 2 by 12

14 joist system and they would just weight it to

15 do that. 

16 And half the manufacturers might

17 come back and say we would never do it. If we

18 had to do it this is what it would cost. Yes.

19 MR. HAGERMAN: This is Joe

20 Hagerman from DOE. So, that's a great

21 question. 

22 And I think my recommendation
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1 would be you give us a cost to do it the way

2 to meet this IECC level, and then you flag

3 things and say we can build it like this but

4 we have to get shipping. Like you brought up

5 the Connecticut issue. So flag that and

6 recommend what the highest U-value would be

7 that you wouldn't meet that constraint, right? 

8 Does that make sense?

9 MR. RAMIREZ: That's an

10 alternative.

11 MEMBER TOMPOS: Dave Tompos again. 

12 My concern is we just may not get a

13 representation of people shipping to

14 Connecticut or Massachusetts. There's not a

15 lot of people that ship to those states. Or

16 at least I don't think any that are on this

17 committee. I know Manny doesn't.

18 MEMBER SCHNEIDER: I missed --

19 what is the constraint for Massachusetts?

20 MEMBER TOMPOS: They have a

21 shipping height constraint of 13'6. And the

22 concern is if we add an additional, you know,
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1 4 inches to the floor height that we could run

2 into that.

3 MR. HAGERMAN: Right. So, this is

4 Joe Hagerman with DOE again. 

5 MEMBER SCHNEIDER: Well, can I --

6 MR. HAGERMAN: I think if you just

7 -- Peter. Two seconds, Peter.

8 If you just flag that, right, and

9 then propose what a credible maximum value

10 would be to solve that. And we can have that

11 discussion. 

12 But it's hard to have the

13 discussion if you don't flag it and

14 everything. Peter?

15 MEMBER SCHNEIDER: This is Peter. 

16 I honestly think there needs to be a

17 subcommittee that is looking at the least-cost

18 path and the feasibility of achieving the IECC

19 2015 UA values. And really look at all these

20 different constraints that are being

21 suggested.

22 In Vermont we have the 13'6
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1 requirement here and we're delivering homes

2 with 10-inch floor joists and 14-inch parallel

3 chord trusses and achieving R60 rooms and R43

4 floor systems. 

5 So, you know, again it all comes

6 back to -- and we've got a 34-inch trailer. 

7 So it all comes back to reworking the

8 methodology in the plants. 

9 And maybe what's happening there,

10 while it may provide a constraint right now

11 needs to be changed to provide a better home.

12 MEMBER TOMPOS: Well, I'll just

13 comment to that. I mean, you can do that, but

14 now you're adding a hinged roof which involves

15 more cost, more setup time.

16 I mean, I'm all for it because I

17 get another four or five hundred dollars every

18 time I have to go out and inspect one of those

19 because it's not finished in the house. So

20 there's your additional cost that goes along

21 with that.

22 MEMBER SCHNEIDER: I just want to
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1 interrupt and just say there's no hinged

2 groove. This helm is done before it leaves

3 the factory. So it's a parallel chord truss,

4 the house is finished and we've got 7.5 to 8.5

5 foot cathedral ceilings. You know, with a

6 low-pitched roof, but it works just fine here

7 in Vermont so it's going to work just fine

8 anywhere else in the country.

9 MEMBER TOMPOS: Well, I think we'd

10 love to see those designs.

11 MR. RAMIREZ: Michael?

12 MEMBER LUBLINER: Yes, I think

13 that's why a subcommittee might be useful for

14 that discussion. I'd love to be involved in

15 that.

16 Where to start. Okay. I do think

17 that we really need to look at what you're

18 talking about, flagging those anomalies that

19 physically are technically challenging with

20 the existing processes you're using in the

21 factory.

22 You know, nobody likes change
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1 except babies with lousy diapers. We need to

2 think out of the box about what are the

3 systems and solutions here that maybe are

4 going to afford some change to your industry.

5 I don't believe that we're going

6 to need to go to a 10-inch floor to achieve

7 those. I'm doing math in my head going I

8 think that we see it in 2 by 8. I'd like to

9 know what percentage of your homes go out with

10 2 by 8. I'd like to know what the costs going

11 to 2 by 8 are and the constraint that you may

12 have in certain shipping.

13 I also think that when we get into

14 a problem and we flag these things like 2 by

15 6 floor joists that you're not going to get

16 the true R30, a nominal R30 but not the true

17 R30 from the eye to the rim joist, that we

18 adjust. 

19 We compensate for that and say,

20 okay, well, let's make an exception in the

21 standard for that. But I do think we really

22 need to get good cost data. 
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1 And I have some significant

2 concerns, Manny, about just going with retail

3 cost data. I'd like to see a two-way street.

4 I've been talking with the

5 insulation manufacturers industries and the

6 window industry for many, many years. The way

7 we've costed things out is to get wholesale

8 pricing from them for insulation. Typically

9 it's a penny per R per square foot. Now,

10 maybe that's changed. Sometimes it's up to

11 1.2 cents R per square foot if it's high12 density, or 15 or 21 in the walls.

13 We can take that. We can apply

14 the manufacturers' markups to that and see

15 what the profit and the retail costs are.

16 But I'd like to work it both ways. 

17 It's not that I don't trust the information,

18 but I want to learn what went into that so

19 that we can evaluate it and feel comfortable

20 that we're voting that these costs are

21 representative of your maximum buying power

22 given that this is a code change.
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1 So, I'd like to also propose that

2 we try to get not just the retail cost, but

3 what the material costs to the manufacturer

4 is. And I'd be willing to sign any

5 confidentiality, non-disclosure agreements

6 here if that's necessary to do that.

7 But I think that that would be a

8 useful way of engaging the manufacturers like

9 Manville and Owens Corning and Dow to say we

10 need a belly blanket that's R22. We need a

11 high-density wall insulation that can go with

12 the eve. So, anyway, that's kind of my little

13 soapbox here. 

14 I'm comfortable with the retail

15 data but I'd like to see the wholesale cost of

16 the materials and some indication as to what

17 the impact is on the production and labor as

18 well. 

19 And whether the markups

20 assumptions that are used. You know, we

21 typically take the wholesale cost and multiply

22 by 2.2 and that seems to be what the
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1 manufacturers over the years we've worked with

2 say is what the retail pricing is. So I'd

3 like to see how that compares to what you get

4 from an aggregate feedback from the industry. 

5 Thank you.

6 MR. RAMIREZ: Mark?

7 MEMBER WEISS: That issue is much

8 more complex than it might appear at first

9 blush because the maximum buying power of a

10 company like Clayton is going to be

11 substantially different from one plant

12 manufacturer putting out a much smaller number

13 of homes. 

14 So, you have potentially an

15 extremely wide range of information that would

16 come into play there with competitive

17 considerations and just a plethora of factors

18 coming into that.

19 MEMBER LUBLINER: It would be

20 great to see that range. It would help to

21 understand the small manufacturers'

22 challenges.
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1 MEMBER LEVY: So, that's number

2 two. The third item here is the baseline

3 building description. 

4 You've seen this before. It was

5 part of the PNNL analysis. 

6 This has some significance for

7 reasons that we've talked about. This would

8 be the baseline for doing the life cycle cost

9 analysis or the economic analysis we're

10 talking about.

11 And I want to just stop on this

12 point for a second. The first question is

13 whether these conditions, everybody agrees

14 that these conditions would be typical. 

15 But also recognize that this is

16 just one set of parameters. A different set

17 of parameters would yield quite different

18 results. 

19 If you had a singlewide as I

20 mentioned earlier with 7-foot side wall and a

21 cathedral ceiling and a scissor truss it would

22 yield different life cycle cost benefits
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1 because the cost of insulating that home would

2 be different. 

3 So, I'll get to looking at

4 outliers later or other conditions later. But

5 this, you need to start someplace and this is

6 one suggested place for starting the analysis.

7 MR. HAGERMAN: Joe Hagerman, DOE. 

8 We're happy, so thank you. We're happy to add

9 to this. If you wanted to have a doublewide

10 with a cathedral, or a singlewide with a

11 cathedral we can make those models and they

12 can run all the analysis with those.

13 This is what we used. I believe

14 this is exactly what we used. 

15 But those are just -- absent of

16 you telling me what the inputs and assumptions

17 should be this is what we came up with.

18 MEMBER LEVY: This probably -- go

19 ahead.

20 MEMBER SCHNEIDER: It's Peter. Is

21 this where we talk about insulation

22 installation grading?
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1 MEMBER LEVY: We could. There's

2 no other place to talk about it so Peter, why

3 don't you go ahead.

4 MEMBER SCHNEIDER: Well, just,

5 again what that base case home looks like

6 after receiving the modeling. I had asked

7 what was the assumption for insulation

8 installation.

9 I haven't spent a lot of time in

10 manufactured plants, but I've watched a lot of

11 videos online of various manufacturers,

12 detailed videos of sort of start to finish

13 construction in the factory. 

14 And being a RESNET energy rater

15 and spending a lot of time grading insulation

16 everything I've seen has been a grade 3. 

17 And so as far as base case and

18 then looking at the benefits of actually

19 improving the insulation and getting a higher

20 grade again from a very cost-effective

21 approach to improving an envelope and an

22 effective R-value, I just want to make sure
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1 that that's represented in this study and

2 evaluation.

3 MEMBER LEVY: Does everybody know

4 what the conversation is about? Grading is a

5 way of evaluating how good the installation is

6 of the insulation material. If there are gaps

7 and voids. 

8 If you put insulation into a

9 cavity, it doesn't completely fill up the gap. 

10 That's a lower-grade installation.

11 Grade 1 usually means it's

12 perfectly put into the cavity and it's the

13 kind of coverage that you're expecting when

14 you get the material.

15 MR. HAGERMAN: Joe Hagerman, DOE. 

16 We assumed a 1 in this analysis, perfect

17 insulation. Perfect installation of

18 insulation.

19 MEMBER SCHNEIDER: Yes, for the

20 base case, right? Or across the board, right?

21 MR. HAGERMAN: Across the board,

22 that is correct.
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1 MEMBER SCHNEIDER: Yes. So, I

2 mean, again, this started for me years ago

3 when I started modeling the homes that I was

4 finding on dealer lots in Vermont to find out,

5 you know, if these were actually meeting the

6 overall U-value.

7 And I got into this grading

8 discussion with different manufacturers'

9 engineering departments about the heat loss

10 calculators and what they were factoring in.

11 But at the end of the day the

12 installation of insulation has a huge impact. 

13 And we're talking about the truth is this is

14 grade 3 insulation installation from what I've

15 seen. And you get a significantly lower

16 effective R-value for what should be the base

17 case. 

18 And if we're meeting IECC 2015 and

19 looking at this from a cost analysis

20 perspective, and again, also from a cost

21 perspective because there's -- it's not a real

22 big cost to spend a little bit more time
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1 putting those baths in correctly or moving to

2 a fill insulation.

3 And then if you look at the

4 language which we talked about earlier today

5 and it was going to come up at some point. 

6 But IECC 2015 does call out that there needs

7 to be good insulation installation. 

8 And there's some language in there

9 that I'd like to see be even more defined, but

10 it's definitely called out. So I'd like to

11 see it different in the modeling.

12 MR. HAGERMAN: This is Joe

13 Hagerman, DOE. We could run the same type of

14 analysis that we're doing for the windows off

15 of the installation of the insulation as well

16 if that's something that the committee wants

17 to see.

18 MEMBER LUBLINER: I'd love to see

19 a little parametric evaluation of the

20 assumption of the grading on the insulation

21 and the impact it has in the life cycle cost

22 analysis. 
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1 I've been in many, many factories

2 over the years. The last factory I was in

3 with Robin we talked to one of the folks there

4 and we were looking at the ENERGY STAR homes

5 and with the non-ENERGY STAR minimum HUD

6 homes.

7 And we said, well, what about the

8 voids and compressions and the things that

9 you're supposed to deal with in ENERGY STAR. 

10 And yes, we get to that, we actually fluff it

11 out and we cut and we pay attention to that.

12 And I said well, what about the

13 other HUD code homes, the ones that aren't? 

14 Oh well, that's not part -- we don't have to

15 deal with that.

16 So this gets back to the proposal

17 that I made to the Consensus Committee in 2009

18 where I said we need to be more specific in

19 our quality assurance plans as to what we mean

20 about insulation installation quality. 

21 So, I'd like to see the parametric

22 analysis to see how big of a deal it makes.
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1 And I'd also like to see in the

2 installation quality assurance plans the

3 specifics that were in that proposal, or

4 something that comes out of the committee.

5 I should point out again that that

6 proposal was rejected by the Consensus

7 Committee because the justification was that

8 DOE was going to address it. Well, we're DOE. 

9 We're here. Are we going to address it? 

10 Thank you.

11 MEMBER SANTANA: Manny with Cavco. 

12 This might be a question for the IECC experts

13 in the room. 

14 What does the IECC say about

15 insulation installation quality? Is there a

16 specific section on it that says?

17 MEMBER LACEY: Yes, there is

18 actually a table that's split up now into two

19 categories. It's Table R402.4.1.1. It's

20 called "Air Barrier and Insulation

21 Installation." And it has some general

22 guidance for how to install appropriately. 
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1 And it's not quite as detailed as

2 the ENERGY STAR thermal barrier checklist. 

3 And I mentioned earlier, and I

4 meant to follow up on this. There was a

5 question about compression. Does the IECC

6 account for compression. 

7 And footnote A to the R-value

8 table does say that if you reduce, you know,

9 if the insulation when it's installed has been

10 compressed you need to make up for it, you

11 know, in simpler terms.

12 But the IECC does account for this

13 and does give some instruction. But this

14 might be a good example of an area where maybe

15 it's cost-effective to go a step beyond. 

16 Maybe you use the ENERGY STAR checklist, or

17 maybe you, you know, incorporate some other

18 things that maybe aren't called out in the

19 IECC but that would be cost-effective and easy

20 to do and would provide some real benefits. 

21 Does that answer your question?

22 MEMBER LUBLINER: So, there's also
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1 some situations and opportunities here.

2 As I understand the grading, if

3 you take an R11 belly blanket and you put it

4 in the belly right now it's not in contact

5 with the underside of the decking, the floor

6 decking. That typically gets a really bad

7 grade.

8 Now, if we were going to be

9 filling the cavity now, at least from the I10 joist to the rim then it is in total contact

11 and you're getting a better grading. So, not

12 only are you getting the R savings, but you're

13 also getting the improved quality assurance

14 that having the thicker insulation forces you

15 to get.

16 So I think that if we're going to

17 do that kind of assessment we need to look at

18 both the base case. You know, I don't want to

19 complication PNNL's life too much, but just

20 make sure that we look at what is the base

21 case grading and how does that grading change

22 if we go to IECC levels. Because it may buy
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1 us some more savings and better practice.

2 The other thing I'd like to ask is

3 what the manufacturers of the insulation

4 believe when they produce something and

5 publish it under Federal Trade Commission

6 laws. 

7 Is that what we're seeing in the

8 factory when we put an R11 in a belly and hang

9 it down 4 inches below the floor? I

10 personally don't think that was what the

11 intent that the test procedures looked at when

12 they stated that R-value. And that's of

13 concern to me. 

14 There's other examples too that we

15 can get into. A 2 by 6 wall with an R11 in

16 the -- we're starting to see manufacturers

17 that have gone from putting R21 in a 2 by 6

18 wall to R11 to save a few dollars. 

19 And what I would contend is that

20 you've changed the quality of the grading by

21 doing that. Because now you've allowed for a

22 big gap where air leakage is going to over-
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1 impact the savings you're getting from the

2 thermal insulation.

3 So grading is an important thing

4 and that's all I'd like to say about it. We

5 should really consider it.

6 MEMBER TOMPOS: Dave Tompos. Just

7 to answer your question, Mike. The

8 manufacturers are reporting actual R-value,

9 not -- you know, if it's an R19 and it gets

10 compressed and they get an R18 they're

11 reporting on their FTC certificates R18. So

12 they do take all that into account.

13 MR. HAGERMAN: So, I just need a

14 little direction here. I offered to do the

15 study at different insulation installation

16 values. If the group wants that I'm happy to

17 do it. You're just going to have to tell me

18 what values.

19 MEMBER TOMPOS: Can I just ask a

20 question? If we're consistent among all

21 packages does it make a difference if you do

22 the assessment at grade 1, 2 or 3 if we're
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1 consistent across the board?

2 MR. HAGERMAN: I have no idea to

3 be honest with you.

4 MEMBER LUBLINER: I guess that's

5 my point. I think if you buy into my point

6 that R11 in the belly is not a grade 1, but if

7 you went to an R21 in the belly at least in

8 the outrigger area with the R11 belly

9 insulation under it, now you're at -- I mean,

10 you're at a grade 1. 

11 So, I'd like to see the study done

12 where you assume both scenarios. You assume

13 that the insulation presently is a grade 3 and

14 that you're going to a grade 1. And then also

15 apples to apples, grade 3 to grade 3, grade 1

16 to grade 1 in the base case and in the

17 analysis case. Does that make sense?

18 MEMBER TOMPOS: One of the

19 manufacturers may have to correct me. Dave

20 Tompos.

21 The current HUD, the way we do the

22 calculations, we factor in I'll say a fudge
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1 factor of I think 10 percent to take care of

2 any possible gaps. 

3 So we're, you know, if we go

4 straight to the code I think -- I think we're

5 doing more than we have to just to account for

6 any possible gaps in insulation.

7 MS. HOFFMAN: Joe asked a question

8 if the committee wanted them to do the

9 research in this area. Can we get a sense if

10 that's valuable for the committee?

11 MR. RAMIREZ: Let's see the thumbs

12 if you think there's some value there.

13 (Show of thumbs)

14 MS. HOFFMAN: Sort of sideways. 

15 Oh. Okay, John, you said no so tell us why.

16 MEMBER CASKEY: I mean, I don't

17 know how to politically correctly say this. 

18 I think we're getting sidetracked and I think

19 we're getting into too much analysis.

20 And I think it's, yes, we can, you

21 know, there's some difficulties out there

22 today in the current installation practices
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1 and things like that. It sounds like the IECC

2 has some good stuff already embedded in there. 

3 But it sounds like we're getting

4 into other agendas from my perspective. And

5 you know, I think the clock is ticking and

6 it's ticking pretty quick from my perspective. 

7 And I'm not sure how we're going

8 to go from this discussion today to an end

9 result in whenever we're supposed to get it

10 done, by the end of September or whatever,

11 devoting this much time and attention to

12 whether there's a difficulty with the current

13 installation practice or whether there isn't. 

14 So, that's just my two cents' worth.

15 MEMBER LEVY: Move on?

16 MR. RAMIREZ: Yes.

17 MEMBER LEVY: Okay. So, the next

18 question is what's our assumptions for doing

19 life cycle cost analysis. 

20 And I think part of this

21 discussion may also be what kind of

22 sensitivity studies would we want to look at
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1 for any one of these parameters.

2 So I try to list out as many of

3 the important items that the analytical team

4 will have to use in terms of doing their

5 analysis to make sure we explicitly talk about

6 them here.

7 The first one I've listed -- these

8 are in no particular order -- is period of

9 analysis. 

10 We're doing a life cycle cost

11 analysis. Matthew explained how that works. 

12 It's over some period of time that you're

13 accumulating costs and benefits. 

14 And the question is what is that

15 time period. Historically it's sometimes been

16 used as the life of the home, the life of the

17 mortgage, the life of home ownership. All

18 those are legitimate places to start the

19 discussion.

20 I said 7 to 30 years because

21 that's -- 7 years is the average occupancy

22 period for the first homeowners in
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1 manufactured homes. Thirty years is actually

2 the longest mortgage length that you'll get on

3 a industry loan now. And that's not typical. 

4 More typical is probably 23. But that's kind

5 of the range of values. Just to throw that

6 open for discussion.

7 MR. RAMIREZ: Eric.

8 MEMBER LACEY: I think this is a

9 good list to start with. The one thing that

10 I would add here is something that Matthew

11 raised in his presentation and that is price

12 elasticity of demand. And only because this

13 issue keeps coming up.

14 I was looking back at the statute

15 and the statute doesn't say the standard shall

16 not increase the cost of the building by $1 or

17 by any amount.

18 I think if we came back with

19 something that showed that it was cost20 effective but it cost $10,000 incrementally to

21 upgrade we'd all say that's a terrible idea

22 even if it is cost-effective. But is it okay
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1 to raise the cost by $1 and what would the

2 effect be.

3 And I think that one thing that we

4 need to add to this is not that it's a -- I

5 don't think it's a straight line, you know, $1

6 would knock out 34 people or whatever.

7 I think there is -- we need to get

8 into the price elasticity of demand. At what

9 point does it start having an impact on which

10 populations and so on?

11 Because as far as I can tell from

12 the statute it doesn't prohibit us from

13 recommending something that would increase the

14 cost, the initial purchase price. It talks

15 about life cycle cost. It talks about

16 considering the impact on purchase price and

17 life cycle construction and operating cost. 

18 All these things are tethered

19 together in my mind. You know, we can't just

20 isolate one and say, well, it fails this test,

21 therefore we can't suggest this.

22 But I think one thing that was
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1 brought up earlier. And it's not going to be

2 part of the initial set of analyses I think. 

3 But as we go on down, if we decide this

4 measure is going to increase the cost by $10,

5 you know, what is the real impact of that. 

6 Are people really going to be

7 homeless if the cost increases $10. Or the

8 impact is $1,000 but the payback is six

9 months. I think some of that would be

10 helpful.

11 And I'm sorry, I don't have a

12 simple way of adding it to your list here

13 other than that I think, you know, price

14 elasticity has to come in at some point. 

15 Maybe not in the first cut.

16 MEMBER LEVY: Eric, if it's okay

17 with you I've added it to the first bullet of

18 the "Other Economic Considerations."

19 MEMBER LACEY: You're way ahead of

20 me.

21 MR. RAMIREZ: That's a good

22 example of what I was talking about earlier,
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1 that as we're having this discussion we may

2 need to do exactly what you just did of jump

3 around to different points.

4 So when you're done running

5 through this I think you're doing an excellent

6 job of outlining some of the components that

7 we're going to need in here.

8 But I mean, we could have a

9 discussion as far as what could we do to get

10 more, especially in other areas. Okay? But

11 please continue.

12 MEMBER LEVY: The other thing. 

13 Just to add to your comment, Javier. I think

14 we have to approach these -- we have to have

15 this discussion about each one of these, but

16 we have to have an action item at the end of

17 this, where are we going to go when we get

18 that information.

19 MS. HOFFMAN: And just in terms of

20 time frame I want to thank John for reminding

21 us we do have a deadline. So we're going to

22 see how we can do. But we're appreciative to
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1 all you're doing.

2 MEMBER LUBLINER: My comment on

3 the period of analysis. I think it really

4 does need to be the life of the home, not the

5 first buyer. Unless you're going to use a

6 salvage value or resale value after the 7th

7 year and promulgate the analysis to the 30th

8 year. Thank you.

9 MEMBER ROY: Robin Roy. And the

10 salvage value or resale value is very

11 complicated. Let's just do the life of the

12 home.

13 MEMBER DENNIS: Just a question. 

14 Where does the length of the actual efficiency

15 measure come into play?

16 Like, say, for the life of a water

17 heater is what, I think 12 years instead of 30

18 years? 

19 And this comes down to I guess

20 also the durability issue with the need to do

21 maintenance and all that type of expense.

22 MEMBER LEVY: I'm sorry, it's on
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1 the next page.

2 MEMBER DENNIS: Okay. So it's

3 lifetime of measures? 

4 I mean because, again, I think for

5 our membership who ends up doing a lot of

6 retrofits on the durability of these measures

7 is a huge issue. And we'd like to see that be

8 an important part of the analysis.

9 MEMBER LEVY: We'll come back to

10 that.

11 MEMBER SCHNEIDER: Can you expand

12 on that just to see as far as what those are,

13 just to outline them now.

14 MEMBER LEVY: Let's come back to

15 that and let's handle this one and move on. 

16 Any suggestions? Any proposals? Somebody

17 want to put something on the table?

18 MR. RAMIREZ: And you're not

19 locked in here. We're still building the

20 strawman here. Just because someone says

21 something doesn't mean you're locked in here.

22 MEMBER LEVY: Separately, we've
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1 asked one of the lenders to give us their

2 assessment of some of these values from their

3 perspective. They obviously have a lot of

4 data.

5 So we'll have information about

6 things like average length of mortgage term

7 for chattel and real estate. We can predicate

8 it -- we can make the decision now to

9 predicate the period of analysis based on

10 that.

11 MEMBER LUBLINER: Do you have any

12 data on the percentage of people that pay

13 cash?

14 MEMBER LEVY: That's one of the

15 questions we've asked.

16 MEMBER WEISS: Sorry, Mark Weiss. 

17 I think there's some information about that in

18 the American Housing Survey that we're

19 actually working up as part of what we're

20 doing.

21 MEMBER EPPERSON: And this is

22 Stacy. We will have this data. I think the
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1 chattel rates, the range on them might be a

2 little bit low here. But we'll have data for

3 that.

4 I would also say we might want to

5 look at this as just total APPROPRIATE so we

6 all points and fees. And even though you

7 begin to break out these points and fees.

8 One more item we might look at is

9 the average lot rent. Somewhere roughly I

10 think close to one-third of going into

11 communities and that's a significant total

12 housing cost too.

13 MEMBER LEVY: So, Stacy, your

14 committee is going to provide some guidance on

15 B, the loan parameters?

16 MEMBER EPPERSON: Yes, we'll do

17 that. Period of analysis we have not been

18 looking at in our committee.

19 MEMBER LEVY: Well, we can agree

20 on a number and then ask for sensitivity

21 studies off of that number. 

22 This is an important -- this will
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1 impact the UO value, so. 

2 MR. RAMIREZ: The period of

3 analysis. 

4 MEMBER LEVY: Not as much as other

5 factors, but yes.

6 MEMBER SANTANA: This is Manny

7 with Cavco. For period of analysis I would,

8 you know, if we talked about the range from 7

9 years to 30 years, you know, I'm not in the

10 financial side of things.

11 I think that the average length of

12 the loan has to play a huge factor. I'm more

13 of the -- in the group that thinks that the

14 life cycle cost should be the cost to the

15 first homebuyer as opposed to the life of the

16 structure.

17 MEMBER EPPERSON: This is Stacy,

18 Next Step.

19 Well, from a financial point of

20 view if we looked at it I think there are two

21 buckets, your chattel finance -- or personal

22 property and your mortgage financing.
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1 With mortgage I agree it should be

2 -- I would look at it as 30 years.

3 But if we're looking on the

4 chattel side we're probably looking at 15 to

5 20 years.

6 MEMBER LUBLINER: Again, I would

7 fundamentally disagree. From the limited

8 economics expertise I have if you're going to

9 use a 7-year life cycle cost it's not the life

10 -- then you don't call it life cycle cost. 

11 But if you want to use a 7-year

12 then you need to evaluate the resale value

13 over the life.

14 And my example is I have a 2,600

15 square foot triplewide that I bought about 15

16 years ago. 

17 And I can look up the energy

18 features in a chattel mortgage in NADA and

19 find that of all the things in the home that

20 depreciated the only thing that didn't

21 depreciate significantly were the energy

22 measures. 
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1 And so I think that there is some

2 argument. And that's why I don't want to go

3 down that route. As Robin said, it gets very

4 complicated if you're going to look at 4

5 buyers over 30 years.

6 I think you're better off if it's

7 life cycle cost. My definition of life cycle

8 cost is the life of the home. So if we want

9 to call it something else, but let's not call

10 it life cycle cost if we're going to do it

11 over seven years and not include any sort of

12 resale or salvage value that home has after

13 seven years. 

14 Next to the home next to it that

15 has none of those energy features. Is there

16 any value to those customers that are going to

17 buy that? Or is it exactly the same? I would

18 argue it's not. The home with the higher

19 energy after seven years is going to sell for

20 more.

21 But we could go down that road. I

22 would recommend we don't and we just define
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1 life as the life of the home.

2 MEMBER WEISS: Mark Weiss, MHAR. 

3 The fact of the matter is the person paying

4 the freight and the person making the purchase

5 decision is the first purchaser of the unit

6 with those features.

7 And when you talk about impact on

8 ability to qualify for a mortgage and all

9 these purchase price issues, it's the first

10 purchaser that you're dealing with.

11 MEMBER SCHNEIDER: This is Peter. 

12 And I'd like to see the actual data on this,

13 but what my finding is in Vermont at least is

14 that even the folks that are in mobile home

15 parks but in manufactured housing in general

16 are staying in those homes a lot longer than

17 the average seven years.

18 And so just, I just would echo

19 what Michael said. I'd prefer not to go down

20 the road and look at one-third of the

21 homebuyers having chattel loans and looking at

22 a shorter life cycle. 
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1 I think that that gets too

2 complicated and the 30 years is more suitable

3 with the goal that hopefully as we're moving

4 forward we're looking at 30-year loans for all

5 of our homes because we're producing homes

6 that are of the same quality as our stick7 built relatives. 

8 And that we are ultimately slowly

9 moving our mobile home parks to ultimately

10 cooperative ownership, or non-profit ownership

11 where the banks have confidence in the

12 longevity of ownership.

13 MR. RAMIREZ: So, the Finance

14 Committee was going to provide numbers for --

15 at least initial numbers for which letters? 

16 B, C and D.

17 MEMBER EPPERSON: Stacy, Next

18 Step.

19 Yes, we will be providing B, C, D,

20 F, we should look at taxes, and G. We have

21 not, but we'll add that to our list.

22 And we need to also look at lot
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1 rent which is not identified.

2 MS. HOFFMAN: That would be a new

3 L?

4 MEMBER EPPERSON: Yes.

5 DR. SAWYER: Make it L.

6 MR. RAMIREZ: Oh, okay. It would

7 be block grant you said?

8 MEMBER EPPERSON: Lot rent.

9 MR. RAMIREZ: Lot grant.

10 MEMBER EPPERSON: Community rent.

11 MEMBER LACEY: I had a question

12 about the lot rent. Are there, and I'm

13 totally naive on this. Are there changes that

14 we're bringing about, or that we could bring

15 about in the energy provisions that would

16 affect the rent?

17 I'm trying to wrap my brain around

18 -- I understand that's part of the

19 consideration for financing and payback and

20 everything, but is there a possibility that we

21 could alter that somehow by a requirement that

22 we put on homes, or don't put on the homes? 
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1 I'm trying to figure this out.

2 MEMBER EPPERSON: Right. Stacy

3 from Next Step.

4 I think what we're looking at here

5 is just affordability and housing cost. And

6 it's a part of manufactured housing cost.

7 When we look at an ability to pay,

8 if we're making a loan, with one-third of

9 these families roughly going into communities

10 generally on the finance side or the non11 profit side we consider that as part of their

12 total housing cost.

13 MEMBER LEVY: So we've almost

14 successfully skirted the first point, period

15 of analysis.

16 So I want to put something on the

17 table. Let me just suggest what the rap is

18 against taking the life of the home for doing

19 a period of analysis.

20 And that is that you're

21 aggregating the benefits over some very long

22 period of time. And the little changes to
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1 your assumptions like fuel escalation rates

2 start to matter more. 

3 If you set the life, again, I'm

4 just throwing it on the table to get the

5 conversation wrapped up here. If you set the

6 life as the life of the mortgage at least you

7 know that that's the period over which all the

8 payments are being made. 

9 So that your costs are really

10 being aggregated over -- and you know what

11 those are because they're in the mortgage,

12 whatever your assumptions of the mortgage are.

13 So if you set that equal to your

14 period of analysis that's one way to think

15 about it. And you're projecting your costs

16 over that period of time which is going to be

17 somewhat less than the life of the home.

18 MEMBER TOMPOS: Dave Tompos. I

19 guess as a business owner when we look at

20 doing something. And we've done some energy

21 efficiency, we've done solar panels. 

22 If I can't get a 5- to 10-year ROI
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1 on that energy efficiency improvement we're

2 not going to do it. It doesn't make business

3 sense.

4 So, I guess in my opinion why

5 would we force consumers to do that if it

6 doesn't make good sense? So my opinion is it

7 needs to be a much shorter time frame.

8 MEMBER WEISS: Mark Weiss. Which

9 relates to the point I was going to make. Not

10 being a statistician, but obviously the longer

11 time period you have, the more speculative and

12 attenuated your assumptions become.

13 MEMBER SCHNEIDER: This is Peter. 

14 Go ahead, Michael.

15 MEMBER LUBLINER: I was just going

16 to say what I learned about life cycle cost,

17 it's the life of the measure. It has nothing

18 to do with the loan. It has nothing to do

19 with the length of time, the period that

20 people are in the house.

21 If we want to do an economic

22 analysis using that approach we can. We can
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1 do return on investment as long as we put in

2 the useful salvage value or resale value at

3 that point.

4 My analysis suggests that if you

5 do return on investment and you get the money

6 out of it that you put into it you're going to

7 be better than the stock market.

8 But I would suggest we not go down

9 that path and we stay with what Congress told

10 us to do and that's life cycle cost analysis.

11 If we have a situation where the

12 term of the loan is 15 years and the house is

13 going to last 30 years the analysis is over

14 the life of the home. 

15 And I think that that's just --

16 it's going to be hard to defend that we did a

17 real life cycle cost analysis if we don't

18 assume the life of the home.

19 MR. RAMIREZ: All right. Let's go

20 to Robin, then Manny. I'm sorry, Robin. 

21 Peter was going to jump in. Peter, go ahead.

22 MEMBER SCHNEIDER: I was actually
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1 going to say almost the exact same thing. 

2 Working for an energy efficiency utility in

3 Vermont that's exactly the definition that we

4 would follow. 

5 And so I think that we would be

6 ultimately not fulfilling what we've been

7 asked to do if we weren't using the life of

8 that measure and started going towards the

9 term of the loan, or even the length of

10 ownership.

11 MR. RAMIREZ: Okay, thank you. 

12 Robin?

13 MEMBER ROY: In year 15, if this

14 home lives to year 15 somebody is paying a

15 different utility bill if the measure was

16 installed. We don't know who that is. It

17 probably wasn't the first buyer, I understand,

18 but somebody is paying a different amount. 

19 If we ignore that somebody is

20 getting that benefit we're ignoring an

21 important benefit. We're doing the wrong

22 analysis. 
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1 So I take your point completely

2 that we need to understand the short tenure. 

3 I think that shows up mainly though in the

4 price of mortgage or chattel loan. You're

5 doing your points over a short number of

6 years. There's something else that's funny

7 going on there.

8 But that measure is going to

9 continue to deliver somebody that we don't

10 know who it is a dollar savings for awhile. 

11 They're not going to ignore it.

12 MEMBER SANTANA: Okay, so this is

13 Manny with Cavco. I'm going to have to

14 apologize for again my lack of understanding

15 of the financial aspects of this. I'm going

16 to need to be educated by you guys.

17 And I'm trying to articulate the

18 question as I go on so it's going to be a

19 ramble.

20 So the way that I understand it is

21 we're here to increase the energy efficiency

22 of HUD homes. 
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1 So one of the points that was made

2 against adding energy efficiency measures is

3 that it's going to increase the purchase price

4 of a home.

5 So one of the counterpoints to

6 that is that although it may increase, or it

7 will increase the purchase price of a home

8 it's going to have a benefit to the homeowner

9 because it's going to lead to less cost to

10 operate the home.

11 And so we're trying to quantify

12 that by providing an analysis of it. And so

13 the life cycle cost may be the incorrect term

14 for it.

15 But my understanding of it is

16 we're trying to figure out just what benefit

17 it has over, you know, to include the

18 operating cost. That means that's the benefit

19 that it has to the initial purchaser. Because

20 the operating cost is going to offset the

21 burden of the higher purchase price. 

22 So I don't understand what the
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1 resale value or the salvage, how that comes

2 into the equation.

3 MR. RAMIREZ: Do you want to

4 answer it? And then we'll get Keith and

5 Robin.

6 MEMBER LUBLINER: So, say I buy a

7 home that's ENERGY STAR and I buy a minimum

8 HUD code home, identical home. I live in it

9 for seven years and I sell it, both homes. Am

10 I going to get the same price for both homes? 

11 I mean, one's got vinyl windows,

12 R30 in the floor. I mean, I would speculate

13 reasonable people would agree that I will be

14 able to sell the energy efficiency higher

15 package for more.

16 The question would become how much

17 more. If the price of electricity has gone up

18 in seven years I would speculate that that

19 value might even be more than what I paid for

20 it.

21 Now, there's a couple of ways we

22 can analyze it. Again, I recommended the life
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1 cycle cost approach because that's what

2 Congress has suggested.

3 We could certainly do what ENERGY

4 STAR does and look at the -- also look at the

5 monthly, the first month you move in. How

6 much more increase in your mortgage payments

7 versus how much did it reduce your electricity

8 bill? That's another way of looking at it.

9 Another way of looking at it is

10 looking at how is that in terms of a return on

11 investment.

12 But any way you look at it, if you

13 don't do it over the life you have to assign

14 a value to the improvement that will be there

15 over the life of the home.

16 And as Robin said, if you discount

17 that you really haven't -- you haven't done

18 the life cycle cost analysis.

19 If we want to ask PNNL to do

20 return on investment, payback, first year

21 cash, first month cash flow and life cycle

22 cost and see how they all compare, great. But
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1 what we've been asked to do here as I

2 understand by Congress is life cycle. 

3 That was clearly defined in

4 testimony in Congress and I have that from

5 Senator Adams back when the act was '94. When

6 you guys argued about it it was what do we

7 mean by cost-effective. There's Senate

8 testimony that says it's lowest life cycle

9 cost. 

10 That was, I think, reiterated by

11 Congress in 2008 in what they said here,

12 lowest life cycle cost. And I believe that's

13 the life of the home.

14 But if you want to do the other

15 analysis, you know, I just think it's going to

16 get in the way.

17 You can't do it just based on

18 seven years without some recognition of

19 salvage value because of the value. I would

20 say it's there from the higher efficiency

21 level. Thank you.

22 MR. RAMIREZ: Let's go to -- we
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1 have Keith, Robin, Mark and then Stacy.

2 MEMBER DENNIS: I kind of just

3 have a question for the experts I guess also. 

4 And I should know this because I deal with

5 this all the time. 

6 But from an economic standpoint I

7 know that when we're looking at a lot of

8 efficiency standards from a national level we

9 look at discount rates for policy.

10 And I know that policy for

11 environmental purposes tends to be pretty low

12 because of -- for certain reasons.

13 But when you look at something in

14 more -- these types of terms where you're

15 actually looking at the opportunity cost for

16 this capital and that -- you have to say that

17 over time having someone delay a payback for

18 10-20 years when they would be using those,

19 that money to, say, buy groceries or something

20 like that when they're being forced to buy

21 something at a minimum standard, that

22 opportunity cost and discount rate that they
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1 would use is going to be a lot higher. It

2 might be that they have a credit card with a

3 very high interest rate. 

4 So, I don't know how those things

5 actually feed into this analysis. And I see

6 discount rate. They were just talking about

7 inflation rates and mortgage rates. 

8 I would argue that the discount

9 rates for a, say, $5,000 payment to somebody,

10 a very small amount of money to get $5 a month

11 back for 30 years is going to be substantially

12 different than when you're looking at a

13 national policy for somebody to spend, say,

14 $20 extra on a DVD player.

15 So, I don't know if it's worth

16 discussion or not. But I'm the same way. I

17 wouldn't wait 30 years on a payback for

18 something in my house. I don't know that I'd

19 wait three or four years.

20 So, I know we're all kind of

21 working on a policy level, but from a

22 practical perspective on something like this
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1 where it is affordable housing I think it's

2 worth it to take a kind of common sense

3 approach to what that actual discount rate

4 would look like, or what these decisions are

5 like. Because people do have to make those

6 decisions.

7 MR. RAMIREZ: Okay. Let's get

8 Robin, Mark and then Stacy.

9 MEMBER ROY: I completely agree on

10 getting the right discount rates -- or the

11 cost of funds, not the discount rates.

12 What I've seen DOE do in appliance

13 and equipment standards before has been pretty

14 smart. Because I worried about that myself. 

15 For example, if it's a

16 refrigerator appliance, a refrigerator

17 standard they did some interesting work and

18 looked to see what fraction is credit card

19 purchase, what's cash. If it's cash, was that

20 cash otherwise going to be put into a savings

21 account, whatever.

22 Or they rolled it into a mortgage
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1 in some fashion. Where was the money coming? 

2 And so they did a pretty sensible job across

3 the spectrum of sources of funds. So it

4 wasn't a silly analysis.

5 So I presume they will do a

6 similarly appropriate analysis. I continue to

7 be quite interested in the distribution across

8 the purchasers group for the reason you point

9 out, the importance for affordable housing,

10 particularly for the less well off in society.

11 So that really is important to

12 look at the distribution, not just the

13 averages for this.

14 I continue to not see how we could

15 ignore that piece of equipment or a home will

16 continue to operate for 30 years and have an

17 energy impact in each one of those years.

18 I realize that in the 30th year

19 the implication for today's present value

20 under life cycle cost is quite small because

21 any discounting, it just gets smaller and

22 smaller over time, the impact in today's
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1 dollars.

2 But it's a 30-year measure. It

3 may not go to the first buyer. It will go to

4 the second or third or fourth buyer. It's

5 going to go to somebody.

6 But to your point, and I kind of

7 missed it the first time. What you're really

8 concerned about is something which I don't

9 think a share a view with Luby on is that

10 there is a somewhat special consideration for

11 that first buyer. 

12 And I think that's wrapped up with

13 this word "affordability" that we use. And

14 what Congress used was the word -- well, when

15 they define cost-effective there they said

16 life cycle cost and purchase price.

17 So I think it's really important -

18 - oh man, are we back to pornography? It's

19 important to bear both of those concepts in

20 mind. 

21 It's not just the minimum life

22 cycle cost with the appropriate cost of funds
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1 and discount rate. It's also the purchase

2 price. And we're going to have to come to

3 some view amongst us whether we share what is

4 a reasonable balancing with those. 

5 And we see what the numbers tell

6 us. Is there a $5,000, $7,000 bump-up for a

7 set of measures that were cost-effective. But

8 we're going to have to think how painful is

9 that. That might be too painful.

10 What if it's a $500 bump-up? That

11 might be too painful toll. But maybe not.

12 And there's no way that we're

13 going to define what that tradeoff is here. 

14 I think we'll have to look at the numbers.

15 MR. RAMIREZ: All right, so now we

16 have Mark, Stacy, Eric and David.

17 MEMBER WEISS: It's always risky

18 stepping outside your field so I do this with

19 trepidation. But and somebody can correct me

20 if I'm wrong.

21 But if the first purchaser can't

22 buy the home based on a seven-year life cycle
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1 or whatever figure you attribute to that then

2 there is no resale to take advantage of a 30-

3 year life cycle. Is there?

4 That person is excluded and all

5 subsequent transactions are excluded too from

6 that person.

7 MEMBER EPPERSON: Stacy at Next

8 Step. I'd be remiss not to underscore the

9 mission at Next Step concerning sustainable

10 home ownership. For us that's defining life

11 cycle cost. And we do that for 30 years.

12 There is a twist here I just want

13 to point out though. We don't only look at

14 energy. We look at all aspects of getting the

15 house done right. 

16 We exceed ENERGY STAR. We put it

17 on the strictest engineered permanent

18 foundation that you could put on the ground,

19 plus design the house for marketability in the

20 future.

21 I had to think long and hard would

22 I use that same measure if I were doing a
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1 single-section here in a community, not on a

2 permanent foundation that was a rectangular

3 box. I think I'd have to think long and hard

4 and seek data about that.

5 But I do want you to know for that

6 multi-section larger home and the way we

7 finance it we would do 30 years.

8 MEMBER LACEY: This is a difficult

9 question as you know.

10 I know we've been talking a lot

11 about what period of time do we need, or could

12 we justify before the upgrade costs are paid

13 back.

14 I want to flip that upside down

15 and talk about the opportunity cost of not

16 installing the measure that would have been

17 cost-effective if the payback period had been

18 longer.

19 Let's say we assume a one-year

20 payback period. The house is going to be

21 built very differently. It's going to be

22 built focused almost exclusively on initial
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1 purchase price with probably very little

2 regard to the operating costs of the building

3 over the rest of its lifetime.

4 Now, it's a difficult question

5 because as has been mentioned before every

6 measure in the house might have a different

7 lifetime. Insulation in the wall may last 100

8 years according to the NHB.

9 Some of the other things -- they

10 publish an analysis, by the way, every few

11 years that tells how long they expect -- the

12 expected lifetime is from various components.

13 Now, I've run into this in other

14 fora before what is the life cycle cost. 

15 Thirty years is kind of the industry standard. 

16 And not because a house only lasts 30 years

17 and then falls apart, but it was kind of a

18 compromise between, well, the house might be

19 here for 100 or 200 years, but you have to

20 have some kind of near-term projection of when

21 you want things to kind of pay for themselves. 

22 And the number 30 has popped up
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1 over and over and over again. So I would

2 suggest that unless there's some other period

3 that's based on some real data that you think

4 Congress meant instead of 30 years when they

5 said life cycle, then we've got to stick with

6 what's common here.

7 But keeping in mind that by

8 shortening that under 30 years you're flipping

9 the preemption upside down and you're kind of

10 leaving on the table the potential higher

11 energy cost that could accrue over the

12 lifetime of the home after that period, that

13 payback period is over.

14 MEMBER TOMPOS: Well, I'm going to

15 hold some of my comments because I think we're

16 getting to an ELMO situation.

17 But I agree with Robin, I think we

18 need to get some numbers on the table so we

19 can see where they fall out. You know, we're

20 kind of just spinning our wheels here.

21 MR. RAMIREZ: Yes, that's what was

22 going through my head when Stacy was done. I
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1 have an idea on that but I may choose to

2 embarrass myself with a smaller group than

3 publicly before I throw it out there. So I

4 probably explore that during the break.

5 MS. HOFFMAN: Right, I was going

6 to say we'll try some ideas during the break. 

7 I think you were next though?

8 MR. RAMIREZ: Yes, so we have John

9 and then Robin, did you have one last comment

10 before the break?

11 MS. HOFFMAN: And then the break.

12 MR. RAMIREZ: Okay. So we'll do

13 John, we'll channel Ishbel and then take a

14 break.

15 MEMBER CASKEY: Okay, this is John

16 Caskey at NEMA. I think we're throwing out a

17 bunch of different terms here.

18 What I would love to be able to

19 see if I'm going to make some intelligent

20 decision over this whole process is, one, is

21 that I definitely think we need a 30-year life

22 cycle cost analysis. And that's basically
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1 what we're obligated to do in support of DOE.

2 But in addition to that I would

3 like to know what the incremental first cost

4 is of those various options that we're talking

5 about.

6 And then at the same time I'd like

7 to know what essentially the delta, what the

8 operating costs are for each of the scenarios. 

9 And from that I can calculate the delta

10 operating cost. And then from that I can

11 derive the simple payback by dividing the

12 incremental first cost -- or the operating

13 cost, the other way around, to find out how

14 many years it's going to take before I can pay

15 this back.

16 And then you can make informed

17 decisions on whether dealing with these low18 income people that are trying to purchase

19 these homes, that then you can have some

20 assessment of, oh yes, it's likely that on

21 average they're going to be in there in seven

22 years. But most of these measures that we're
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1 talking about relative to energy efficiency

2 are going to pay for themselves in five years. 

3 So it seems like a good compromise and that we

4 would use that in addition to what the life

5 cycle cost analysis does.

6 But the other thing dialing with

7 your, you know, what's the value of the house. 

8 You don't really need to deal with that. 

9 If you do the life cycle cost

10 analysis, however, you do need to make sure

11 that you positively include the replacement

12 cost of the HVAC equipment and the water

13 heater and other things like that. Things

14 that have a shorter than 30-year lifetime you

15 need to factor in the cost of replacing that

16 over that 30-year period.

17 So, I mean that's from my

18 perspective how the whole analysis should be

19 done.

20 MR. RAMIREZ: Okay. Ishbel?

21 MEMBER ROY: Channeling Ishbel. 

22 She surveyed her board and hears back that --
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1 from one members who has lived in a home for

2 11 years, that that member happily pay five to

3 ten thousand dollars more to get a more energy

4 efficient home. So there's some interest

5 there. Anecdotal and helpful.

6 And as for lot rent it depends on

7 the private market. Most landlords won't care

8 whether the homes are energy efficient or not.

9 MEMBER SCHNEIDER: Yes, I don't

10 think lot rent is going to change at all. So

11 I'm not even sure that's even a question that

12 needs to be looked at any further.

13 But I was just looking at, you

14 know, for an example for Burlington in our

15 climate zone looking at the actual energy cost

16 of the HUD-compliant home. And again, this is

17 assuming the grade 1 insulation installation.

18 This would certainly be a higher

19 energy cost. And we've seen significantly

20 higher energy costs up here.

21 We also -- there was like $2.60

22 for propane whereas we had $4-plus price for
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1 propane last year and that's what all of our

2 heating systems are. Up here we have all

3 unregulated fossil fuel for the most part.

4 But anyway, just year 1 even with

5 those assumptions that are not accurate, you

6 know, we're looking at a $1,000 savings year

7 one.

8 And you know, if you put you're

9 looking at a year and a half payback on that

10 additional down payment if that home is

11 $10,000 more.

12 So, just the idea that there's --

13 as far as what that initial investment is, you

14 know, not only is the payback of that initial

15 additional down payment a very short period

16 for that homeowner, but month one they are

17 going to have positive cash flow.

18 In this scenario they're looking

19 at just over $400 in mortgage and energy

20 costs, month one, compared to the HUD21 compliant home where they're looking at

22 somewhere around $600, almost $700 a month.
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1 There's a huge difference in cash

2 flow on a monthly basis. So we have to look

3 -- in addition to the initial cost we need to

4 start looking at what those are other factors

5 look like for that homeowner such as cash flow

6 on a monthly basis and how quickly they get

7 that down payment back.

8 And up here, very quick when I

9 look at going from HUD to IECC 2015. For me

10 it's a no-brainer.

11 MR. RAMIREZ: Great, thank you.

12 MEMBER LUTER: Can I comment on

13 his comments, please?

14 MR. RAMIREZ: Who is it?

15 MEMBER LUTER: Very briefly. Rob

16 with Lippert. Peter, if all these advantages

17 are there for these homeowners what's keeping

18 them from buying these homes now? Are the HUD

19 builders telling them no. Or are they not

20 choosing I-code modulars?

21 MEMBER SCHNEIDER: Well, you can't

22 get -- well, we just don't have them, right? 
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1 If you go to a manufacturer's dealer lot which

2 is where all these folks are going there isn't

3 even an ENERGY STAR home on their lot, alone

4 one that is beyond HUD-compliant.

5 So only the bare minimum is out

6 there. They don't know what is available.

7 And I will say it's all about

8 education, advocacy, outreach. And so we just

9 hired a project manager who's going to be out

10 there pounding the pavement trying to educate

11 everybody. You know, our park owners, the

12 folks that live in mobile home parks, the

13 people that live in manufactured homes on

14 private lands, going to home shows. There

15 just is not the education out there. 

16 And there's also not the product. 

17 It's like trying to go out and buy an

18 efficient car before we had efficient cars on

19 the lot. And right now there isn't anything

20 on the lot that reflects what we're talking

21 about and what I'm describing. 

22 There clearly are the benefits but
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1 we just don't have the product. And I think

2 that's what we're talking about today is

3 making that product available. 

4 MEMBER LUTER: I think today we're

5 talking about making that product mandatory.

6 MS. HOFFMAN: I think it might be

7 time for that break. Do you have a concluding

8 comment, please?

9 MEMBER LEVY: It's more of the

10 same and I think Mark has the comment. Let's

11 do it after the break.

12 MS. HOFFMAN: Okay. Hold that

13 thought, okay? We'll come back in 15 minutes. 

14 Thank you. You won't forget it, write it

15 down. Thank you. 

16 (Whereupon, the above-entitled

17 matter went off the record at 3:29 p.m. and

18 resumed at 3:57 p.m.)

19 MR. RAMIREZ: Let's go ahead and

20 get started. Emanuel is going to go ahead. 

21 Mark, you had a comment right before break?

22 MEMBER WEISS: Yes, actually two.
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1 Just to address I think it was

2 Peter's point about what he's finding in

3 Vermont.

4 The fact of the matter is that any

5 consumer right now can get whatever they want

6 in terms of an energy package in a

7 manufactured home as long as it's physically

8 possible.

9 That stuff is available now. It

10 does not take a standard to get that.

11 Instead of the free choice

12 situation we have now essentially what we're

13 talking about is a one size fits all rule

14 which is the source of a lot of concern from

15 our perspective.

16 I had a question though to general

17 counsel. Is there a definition of life cycle

18 cost in the EISA statute?

19 MS. VAIDYANATHAN: Hi, this is

20 Kavita Vaidyanathan in the DOE general

21 counsel's office.

22 In reviewing the statute there is
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1 no definition of life cycle cost. So we would

2 look to this Consensus Committee to provide a

3 reasonable definition and DOE can consider

4 that.

5 MEMBER WEISS: Okay. So a follow6 up question to that. Is there any relevant

7 legislative history with respect to the

8 meaning of life cycle cost for EISA?

9 MS. VAIDYANATHAN: I'm not aware

10 of any.

11 MR. HAGERMAN: We can get you an

12 answer from general counsel's office but I

13 believe life cycle cost is one of the

14 requirements in all of our standards-making

15 activities. So we can give you that

16 definition.

17 MEMBER TOMPOS: Dave Tompos. I'm

18 sorry, Mark, are you done?

19 MEMBER WEISS: Well, my question

20 is directed to this specific statute. But if

21 you have anything you think is relevant I'd be

22 happy to see it.
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1 MEMBER TOMPOS: Dave Tompos. You

2 guys have a lot of experience with energy

3 efficiency in appliances. Have you ever done

4 anything where the financing has to deal with

5 debt-to-income ratio?

6 MR. HAGERMAN: I'd have to ask

7 somebody to be honest with you.

8 MEMBER TOMPOS: Because I think

9 that's what the big difference here is in a

10 lot of the other committees that DOE has dealt

11 with as opposed to this one. That's kind of

12 -- we keep going back to that same issue is

13 that it's that initial cost and not allowing

14 that low-income potential homebuyer to get

15 into the home initially. So it's a little

16 different when you're talking about a DVD

17 player or a dryer or something like that.

18 MR. RAMIREZ: Emanuel, you want to

19 continue on here?

20 MEMBER LEVY: Yes. I just want to

21 make a couple of comments and then I think we

22 need to bring this to some kind of close on
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1 the issue of period of analysis.

2 Just a couple of pieces of

3 information from our own experience of energy

4 efficiency measures which kind of I think

5 impact this discussion to some degree.

6 One, it's mainly through the

7 ENERGY STAR experience in building lots of

8 homes across the country we found that the

9 ENERGY STAR package seems to contribute

10 nothing to resale value. 

11 I mean, that may change over time

12 and we may find 10 years from now that the

13 story is different for ENERGY STAR homes built

14 today. But the experience we have in the

15 field is kind of sobering from our standpoint

16 that it hasn't really contributed to resale

17 value. Sure, there are anecdotal examples to

18 the contrary, but that's been our experience.

19 And by the same token many people

20 in the industry who I've asked this question

21 of have said there's no -- they can't get an

22 increase in assessed value for the home as a
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1 result of the ENERGY STAR package. Again, I

2 don't know how that plays into our discussion. 

3 We can talk about it.

4 And the last thing, I just wanted

5 to kind of repeat something that Keith's

6 mentioned which is in a different perspective. 

7 Going back to our discussion about

8 period of analysis. We are basically saying

9 that if the period of analysis is 30 years or

10 some lengthy time period and a homeowner

11 occupies the house for seven years they're

12 going to get negative value out of that

13 investment. And I think that's been mentioned

14 a couple of times.

15 Philosophically I think the

16 difference that we're talking about at the

17 table is the life cycle of the house or the

18 life cycle of the first buyer of the house. 

19 Is the life cycle of all the homebuyers of the

20 house or just the first buyer?

21 So I think we need to bring this

22 to a head and give some guidance to the
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1 analytical team. So we need a motion I guess,

2 or some kind of suggestion.

3 MR. RAMIREZ: Eric.

4 MEMBER LACEY: This is Eric Lacey. 

5 I just wanted to maybe suggest something. If

6 you're looking -- there are a lot of potential

7 assumptions here. And we could probably fight

8 all day along about, you know, where to do

9 this. But the analysis has to start

10 somewhere.

11 And there was a question raised

12 earlier about whether DOE has every done this

13 for various products, appliances and

14 everything.

15 Department of Energy Building

16 Energy Codes Program did a cost-effectiveness

17 analysis for the residential IECC 2012.

18 Now, I mentioned earlier the 2012

19 and 2015 are almost identical in my mind. I

20 don't know how DOE is going to determine this,

21 but in my mind they're very, very close in

22 terms of energy efficiency. And I think the
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1 cost-effectiveness is going to be the same

2 when we're talking about residential single3 family homes.

4 Now, I recognize there are going

5 to be some differences between the stick-built

6 homes and manufactured homes. 

7 But one thing that I liked about

8 what DOE did in these analyses is they went

9 out with an RFI and asked for a lot of input

10 on what kinds of assumptions to use. 

11 Our organization provided a bunch

12 of ideas. The homebuilders provided a bunch

13 of ideas. A lot of people put information

14 into this process. And DOE published a

15 methodology with a lot -- most or all of these

16 assumptions that's available on their website.

17 And then they used this

18 methodology to calculate cost-effectiveness

19 for just about every state from going from

20 their current code to the 2009 and then to the

21 2012 version of the IECC.

22 And they broke it down in several
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1 ways. They looked at the impact to first

2 cost. They looked at the life cycle cost

3 impact over a 30-year period. And they also

4 looked at the payback, the simple payback

5 period. And so they kind of broke it down.

6 They also did kind of like a

7 month-to-month analysis. At what month do you

8 start seeing a positive cash flow. I think

9 they're really helpful. 

10 When we've gone around the states

11 talking about the IECC we always bring a copy

12 of that state's cost-effectiveness analysis. 

13 In every case they found that they

14 paid back in shorter than -- I think shorter

15 than seven years or seven and a half years. 

16 Most of them were much shorter than that.

17 So, I would encourage you to take

18 a look at this. And as you're filling in some

19 of these assumptions it might be easy to start

20 with what was used in this methodology as kind

21 of a strawman and say this is the discount

22 rate DOE used in the past. Do we agree with
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1 that? Is that close enough? Are we on both

2 sides of that or is it way off? 

3 It might be a way to populate some

4 of these things, rather than just taking a

5 poll of what everybody says, or trying to find

6 it somewhere else.

7 I'm trying to kind of advance the

8 ball here with sufficient level of detail but

9 without getting bogged down in every single

10 issue.

11 Anyway, that's the suggestion. I

12 can send that website around and you can take

13 a look at these analyses and the methodology

14 if you're interested.

15 MR. RAMIREZ: Yes, please. Stacy? 

16 Okay, Michael?

17 MEMBER LUBLINER: Yes, I just

18 wanted to respond to your comment about the

19 fact that you didn't see resale, some

20 anecdotal study you did.

21 Did you talk to the clients about

22 the NADA evaluation of ENERGY STAR in that
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1 assessment? 

2 Because I have a longstanding

3 history with NADA of after our utilities

4 invested $100 million to build these homes

5 more efficient for many years. And when you

6 go into a home and it's got the ENERGY STAR

7 sticker and if you use the NADA you're getting

8 thousands back on resale. 

9 So I'm not understanding if --

10 this is real stuff. It's in their -- if you

11 go and appraise a home using the NADA, and I

12 just did my home, and you add the energy

13 upgrades it's in the thousands. So I can't

14 understand why -- that's like real data, but

15 anecdotally you're not seeing that. I'm

16 trying to understand why there are two so

17 different.

18 MEMBER LEVY: I can explain that. 

19 If you look in the NADA directory you'll see

20 our label too. And it has an assigned value

21 of $1,300 or something like that.

22 But when I go into the field and
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1 talk to people who are actually selling the

2 homes they say we don't look at that. We

3 don't bother with that. I mean, it's there,

4 the information is available, but as a

5 practical matter it's not being used.

6 The Northwest is kind of a special

7 case because of the $100 million that's been

8 put into the program and a great job they've

9 done over the years of building up the brand

10 recognition of energy efficiency and

11 manufactured housing associated with that.

12 But take my word for it, that's

13 unusual and it's atypical of what's happening

14 in the rest of the country. And tell me if

15 you see the same thing, David and Emanuel, but

16 that's been my experience.

17 MEMBER LUBLINER: I guess my

18 follow-up on that is that I still would like

19 to know if this is available nationally and

20 your manufactured homeowners are selling 10

21 percent ENERGY STAR or whatever. 

22 And some of them are using chattel
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1 mortgages that could benefit by valuing this

2 extra $1,600, why aren't they doing it? It's

3 going to provide the value to the customer. 

4 It's going to make it easier for them. Why is

5 that?

6 And when you have a big enough

7 statistical sample like the Northwest you

8 start to see that actually there is a

9 distinction that the market makes here.

10 And it's available throughout the

11 country. It's just that some haven't decided

12 to I guess use it. I don't know. I'm trying

13 to understand why is it that the sales people

14 and the retailers and the manufacturers aren't

15 promoting that to their chattel mortgage

16 customers as a way of better qualifying for a

17 manufactured home.

18 MR. RAMIREZ: John.

19 MEMBER CASKEY: John Caskey, NEMA. 

20 This might be a little bit different resource

21 but this is from energy.gov, Office of Energy

22 Efficiency and Renewable Energy. Life cycle
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1 cost analysis for sustainable buildings. 

2 It says life cycle cost (LCC)

3 rules are promulgated in 10 CFR 436A, Life

4 Cycle Cost Methodology and Procedures, and

5 conforms to requirements in the National

6 Energy Conservation Policy Act and subsequent

7 energy conservation legislation as well as

8 Executive Order 13423.

9 The life cycle cost guidance and

10 materials assume discount rates and energy

11 price projections determined annually by

12 Federal Energy Management Program and the

13 Energy Information Administration.

14 So, it seems like a lot of the

15 stuff we need is already out there and has

16 already been, if you will, blessed by DOE. 

17 And we just need to go back and look at the

18 resource and make sure we're assuming the

19 right numbers in our starting point.

20 MR. RAMIREZ: Which I think goes

21 back to what Eric had just talked about,

22 right? At least part of it is that there's
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1 potentially a strawman out there that we could

2 use as the basis.

3 But we could talk about that as

4 far as next steps, right? So, Emanuel, you

5 want to continue?

6 MEMBER LEVY: Yes. I agree,

7 there's a lot of information up here. For

8 example, I -- where that data, and there's a

9 link to some of the data you just mentioned,

10 John.

11 There are two or three items on

12 this list that are kind of subject to our

13 decision-making. And it's basically you lean

14 on the people who know the most about those

15 topics and make a decision as to what's

16 appropriate.

17 And period of analysis is one of

18 those. That's my only point.

19 And discount rate possibly is one

20 of those things too.

21 So I think we ought to focus our

22 attention on those and come to some conclusion
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1 to give guidance to the team here. And then

2 we can move on and ask them to do sensitivity

3 studies. But we need to give some guidance

4 and move forward on them.

5 MEMBER ROY: I have a proposal for

6 A. Let's change it to two things: periods of

7 analysis and give it different names. A8 seven years or whatever, life of first owner,

9 tenure of first owner. And B, 30 years or

10 whatever number we're going to throw in there. 

11 Life of home. Maybe it's longer than 30

12 years.

13 And then great. Then we can go on

14 and look at the numbers as they come out.

15 MEMBER LEVY: So you want to do

16 two sets of analyses?

17 MEMBER ROY: And be clear in our

18 labeling of them, that one of them is the

19 tenure of the first purchaser and the second

20 is the life of the product we're talking

21 about.

22 MR. RAMIREZ: Everyone go with
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1 that? Let's see a show of thumbs.

2 MS. HOFFMAN: We'll hear from the

3 folks on the remote if there's a problem. 

4 Okay. Did I miss any or was this agreeable? 

5 Okay. Consensus. Hear hear. We did

6 something.

7 MEMBER LEVY: We didn't do

8 anything.

9 (Laughter)

10 MS. HOFFMAN: Thank you, Emanuel. 

11 Moving right along.

12 MEMBER LEVY: Do we want to talk

13 about discount rate? Maybe we could start

14 this discussion by Matthew or Ed talking about

15 what discount rate and what its significance

16 is and what typically has been used in the

17 past and what might be appropriate.

18 MR. WALKER: So this is Matthew

19 Walker with Navigant. Yes, the discount rate

20 affects the value of the future cost savings,

21 particularly in this case associated with the

22 energy cost savings.
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1 A larger discount rate is going to

2 make the value of those savings less, a

3 smaller rate makes them larger. So a smaller

4 rate probably gives you the better chance of

5 offsetting the original housing purchase

6 price.

7 I can say from experience in other

8 of DOE's appliance rulemakings that the

9 discount rate is frequently and I think Robin

10 may have alluded to some of this. 

11 It's usually an assessment of all

12 of the options that a customer or consumer has

13 for placing their money. So it's cash, it's

14 mortgages, it's consumer debt, those kinds of

15 things. And then a weighted average is often

16 done for kind of that middle of the road mean

17 estimate. 

18 And sensitivities can be run

19 around different options, high and low, above

20 and below that.

21 MEMBER LEVY: So as a starting

22 point for discussion could we say the mortgage
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1 rate might be a reasonable discount rate? Or

2 what would you suggest?

3 MR. WALKER: I think that could be

4 a starting point for discussion. So, a real

5 estate rate could be something like 5 or 6

6 percent. You might even have had that up

7 there. Yes, you did.

8 The other thing to think about is

9 that the consumers that are buying these

10 products may -- you may want to think about

11 the most expensive debt or investment type of

12 option they have available which it could in

13 some cases be credit card debt which is

14 frequently an extremely high number. It was

15 like 19 percent or something. So that could

16 be another almost sort of boundary case to

17 look at.

18 So, you know, the decision that

19 they're facing is do I pay down my 19 percent

20 debt that's just killing my financial health,

21 or do I buy a $1,000 more expensive home to

22 live in.
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1 MR. RAMIREZ: At least for a

2 starting point talking about a mortgage.

3 MEMBER WEISS: I have some real

4 concerns with the last thing that was said

5 there. Based on I guess someone that has that

6 much credit card debt, should they be buying

7 a house, period? Let alone an energy

8 efficient home? 

9 Isn't that why we're in the

10 situation we're in now with the meltdown and

11 almost -- I mean, I don't want to get into

12 that. But I have a fundamental disagreement

13 with using that based on the fact that we're

14 talking about affordable housing for people

15 that can afford the house.

16 And if they can't afford to pay

17 their credit card off every month

18 significantly then I have some real concerns

19 about that.

20 But again, you know, somewhere I'm

21 much more comfortable setting it to the

22 inflation rate, fuel inflation rate, because
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1 that's the one that's the uncertainty. And

2 that hinges.

3 If all of a sudden we have another

4 war and the prices go up or regulations that

5 impact the electricity use I would like to see

6 it tied to the fuel escalation rate. I think

7 it's more justifiable. But it's my own

8 opinion. Thank you.

9 MEMBER DENNIS: Yes, I mean I

10 think I'd like to say. Keith Dennis. I think

11 that the process that Robin described, that

12 that's what DOE normally does taking into

13 account the portfolio of what people usually

14 have in terms of debt and finance options at

15 hand seems more important than just using a

16 mortgage rate.

17 I know that the opportunity cost

18 for me in particular to spend on energy

19 efficiency would be much higher than my

20 mortgage rate which is very low.

21 So I don't think that that's

22 really -- it's a number that has to do with
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1 how much you're financing your home for, but

2 I don't think it has a lot to do with

3 decision-making.

4 And I think the reality is that

5 the tradeoff is going to be in some cases

6 between a credit card and energy improvement. 

7 In other cases it might be all cash which is

8 probably the other end of the spectrum.

9 And I think that a realistic

10 approach would be better than just kind of

11 picking a number because it's related to the

12 actual transaction.

13 MEMBER EPPERSON: Stacy, Next

14 Step. We represent a network of non-profits

15 that provide financial literacy, homebuyer

16 education and counseling.

17 The buyers that we are talking

18 about typically pay more for credit than maybe

19 buyers of site-built homes. It's just the

20 income level that they're at.

21 So if I'm thinking of opportunity

22 choices for them it's reasonable rather than
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1 putting money like into the stock market and

2 that opportunity. Rather it's often paying

3 off debt. So I just want to do a reality of

4 what we see as a network.

5 MEMBER LACEY: Yes, sorry, I did

6 have something to say after all. I looked up

7 the methodology that DOE used on the

8 residential. And they just used the mortgage

9 rate as kind of a compromise I think between

10 the range of things you could use.

11 I mean, I recognize that what

12 you're talking about is what is an equivalent

13 investment with similar risks and what is

14 available and all that. 

15 And they came to the conclusion

16 that this is a -- that investing in these

17 efficient options was an alternative

18 investment at a similar risk level and so they

19 just applied it the same rate that they did to

20 the mortgage. So anyway, that's one

21 suggestion I think that kind of hits the

22 middle
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1 MR. RAMIREZ: Okay. And I think

2 that that's where we ended up putting it on

3 there again as an initial position. Right? 

4 Whether it's easier or not we'll see. But we

5 have the mortgage right there, so.

6 MEMBER LEVY: And it doesn't sound

7 like we have another counterproposal? Or we

8 do?

9 MS. HOFFMAN: The only thing I

10 heard was from Michael was the fuel inflation

11 rate. 

12 MR. RAMIREZ: And the way I'm

13 looking at it is that that's not what we're

14 agreeing to ultimately, right? But at least

15 a place to start. So who knows, we may end up

16 back over there. We'll probably have to see.

17 MEMBER DENNIS: I would suggest, I

18 think that DOE normally does a couple of

19 discount rates in their analysis. They

20 usually -- I think they do three to seven.

21 I think there's an OMB circular

22 out there that actually requires a 7 percent
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1 discount rate be used.

2 So, and I think in this case where

3 we're dealing with low-income that it would

4 make sense to look at a scenario with a higher

5 discount rate. 

6 Just as a bounds to see what that

7 does have -- what effect it does have in the

8 out years.

9 So I think it would make sense to

10 have a range just from a review perspective. 

11 But I don't feel strongly enough to hold

12 anybody up on it. It just seems to make

13 common sense to me.

14 MEMBER LEVY: So, if we do

15 something like this which we take the mortgage

16 interest rate as the discount rate and then do

17 a sensitivity analysis as a +/- minus rate. 

18 Does that seem reasonable? 

19 MEMBER DENNIS: Yes, I think

20 that's reasonable but. It comes out to make

21 huge differences I think we could revisit it. 

22 If it doesn't make any difference. I think
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1 that sounds great.

2 MR. RAMIREZ: So let's look at

3 those thumbs if you're all right with that.

4 MS. HOFFMAN: No, he has a

5 question.

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

7 MEMBER LACEY: Sorry, I don't mean

8 to belabor this, but 5 percent of the mortgage

9 interest rate, or 5 percent of -- so if the

10 mortgage interest rate is 5 percent you mean

11 --

12 MEMBER LEVY: Zero to ten.

13 MEMBER LACEY: I don't think you

14 need to go that broad, but okay.

15 MEMBER LEVY: Another number? I

16 mean, Stacy, what do you think the mortgage

17 interest rate is going to be for a chattel

18 loan?

19 MEMBER EPPERSON: There's a range

20 on it. It's double digits and it could range

21 all the way to 19 percent. 

22 MR. RAMIREZ: So with those
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1 averages that +/- 5 does sound like it's

2 probably within range then. So let's see

3 thumbs if you're okay with that for now.

4 All right, don't see any thumbs

5 down or hear any thumbs down. Oh, sorry. 

6 Why?

7 MEMBER LUBLINER: I don't think

8 that we should be driving the national code

9 based on just the small sector that is using

10 chattel mortgages.

11 So I can't vote on this until I

12 know how we're going to analyze the discount

13 rate. Are we going to use a crystal ball,

14 multivariate analysis, or are we going to take

15 an average? So I can't vote on this because

16 it's going to have a huge impact based on what

17 analysis approach we use.

18 MR. RAMIREZ: Just to be clear,

19 this was not a final --

20 MEMBER LUBLINER: No, but you're

21 asking me why I'm putting my thumb down.

22 MR. RAMIREZ: Yes. So, what we're
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1 doing here is just a starting point that we

2 could put some structure to this strawman. 

3 Right now it's a bale of hay. So we want to

4 try to flow it into something. So that's why.

5 MEMBER WEISS: Just in response to

6 Mike talking about a small proportion for

7 chattel. I think this should be on the record

8 anyway.

9 The latest Census data that I'm

10 aware of indicates that 76 percent of

11 manufactured housing placements are chattel.

12 MEMBER LUBLINER: Again, so --

13 MEMBER LACEY: This is Eric. Some

14 of these issues and these numbers keep getting

15 tossed out. I'd really like to see what's

16 behind them. Because I'm wondering what's new

17 and what's been existing.

18 Because what we're talking about

19 is a standard. For new construction. And I'm

20 afraid some of the numbers being tossed out

21 there may involve more than just new

22 construction. 
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1 But I just -- if you have any of

2 that information to share I'd really

3 appreciate seeing that.

4 MEMBER WEISS: Yes, that's Census

5 Bureau data and it was addressed in a

6 rulemaking by the Federal Housing Finance

7 Agency in last -- I believe 2010. But it's

8 something that we can look at.

9 MEMBER LUBLINER: It's Mike

10 Lubliner. So, in the Pacific Northwest a very

11 small percentage of the homes are chattel

12 mortgage. There's actually more in cash then

13 there are in chattel.

14 So four our region of the country

15 for the housing stock there get significantly

16 disadvantaged in the optimum energy efficiency

17 by using the assumption of chattel mortgage. 

18 And I know that that is going to

19 create a lot of lost opportunities. It will

20 cause utilities to have to do things to

21 incentivize or carrots or sticks. 

22 And I'd like to see us not just go
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1 to the lowest common denominator, because it

2 has impact on the industry and particularly

3 our region of the country, California. 

4 There was an article in the Wall

5 Street Journal about reinventing manufactured

6 house this week. Talked about the future in

7 the upper end, not the lower end. 

8 And we're setting standards based

9 on chattel mortgages. And I just have some

10 significant concerns that that's going to

11 drive the analysis in a very non-optimum way

12 for the consumer in general.

13 I think the problem really is that

14 HUD and the lenders haven't recognized to

15 treat manufactured housing that's equivalent

16 to site-built with equivalent financing. 

17 Thank you.

18 MR. RAMIREZ: Let's see Stacy,

19 then Kevin, then Mark. Keith, sorry.

20 MEMBER EPPERSON: I forgot to put

21 mine down too. But I will say that our

22 subgroup will pull this data. We have it.
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1 MEMBER LEVY: So, we're okay with

2 this as written?

3 MR. RAMIREZ: Yes. I mean it was

4 greater than two-thirds. And again, it's not

5 a final position anyway so it's just a place

6 to start. So yes, we're good.

7 MR. HAGERMAN: So what is the

8 number? Are to 7, to 11? Or are we going to

9 research that more? Or what is --

10 MR. RAMIREZ: Well, we don't have

11 that. We're going to that channel number. 

12 When we put all this together we'll have to

13 nail down all of this and then at some point

14 VTE and check for consensus to see if we have

15 final approval.

16 MEMBER CASKEY: Well, just to let

17 you know I'm looking at OMB Circular No. A-94

18 and that's just as Keith says. Peg's off the

19 7 percent rate for the discount rate. Just to

20 let you know.

21 MR. BARBOUR: The circular has

22 been around since 1992. And it's for benefits
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1 to the federal programs, how to calculate the

2 life cycle cost.

3 MEMBER DENNIS: Yes, and you know,

4 I'll just mention that that is very national

5 number. And think that's what we have to use

6 for policy and for affordability.

7 Research shows that private

8 discount rates for efficiency can be a lot

9 here. And with research paper that says they

10 be 15 or 25 percent. So, I think that 5

11 percent looking 5 up and down has a

12 sensitivity on the mortgage wouldn't be

13 unreasonable just for info purposes. I don't

14 think that necessarily means any decisions are

15 going to be made off it.

16 It just goes to show if there's a

17 big indicator one way, people are concerned

18 about affordability, people are concerned

19 about the numbers we're using, it's just

20 helpful information to have.

21 MR. HAGERMAN: This is Joe

22 Hagerman. That's kind of my feeling too. Go
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1 with this for the time being and we'll look

2 forward to seeing what Stacy's committee

3 provides everybody.

4 MEMBER LEVY: Okay, so we're good

5 on that? I just want to go back to B for one

6 second. I know Stacy's committee is going to

7 be working on this, but I want to encourage

8 you, Stacy. I know this is already a lot of

9 work to try to get this data.

10 But it would -- rather than freeze

11 this information in time as in what is it

12 today, we might look over the last five years

13 that we can get that determine and somehow

14 average it. 

15 Because I do think it's

16 fluctuated. I mean you might even take 10

17 years, some longer period of time so that

18 we're not looking at an atypical period and

19 predicating the analysis on that.

20 Does that make sense?

21 MEMBER WEISS: Just a general

22 question for my edification. When did the
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1 first IECC come out?

2 MEMBER LACEY: This is Eric. The

3 IECC is the successor to the Model Energy Code

4 which has been published for a long time.

5 But I think the first IECC was

6 like 1998 or so. But it's the successor code

7 to the Model Energy Code which is referenced

8 in the 1992 Energy Policy Act.

9 MEMBER WEISS: What is the rate of

10 adoption by states?

11 MEMBER LACEY: Almost every state

12 has adopted a version of the IECC. They range

13 in terms of which edition they've adopted. 

14 But yes, nearly every state has adopted it.

15 Some states can't adopt a

16 statewide mandatory code because they're home

17 rule. But of the states that are able to

18 nearly every state has adopted some version of

19 that.

20 MEMBER WEISS: Thanks.

21 MEMBER LEVY: Moving on. I think

22 C through F on this list are probably small
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1 impacts. And we'll rely on Stacy. My

2 suggestion would be to rely on Stacy. I

3 suspect these will have very little influence

4 over the numbers we come up with.

5 And income tax deductibility. I

6 think the case could be made at zero but we

7 can talk about that if somebody feels

8 differently. That people who are buyers of

9 manufactured homes generally don't worry about

10 income tax deductibility of the mortgage.

11 I and J I think as John talked

12 about there's established sources for that

13 information that we can pull from. Anybody

14 else want to comment on those two areas?

15 Okay. Onto K. Other Economic

16 Factors. This is kind of a catch-all for

17 anything else that might go into the life

18 cycle cost analysis and not other economic

19 factors which we'll get to in a second. But

20 are there elements that we can quantify and

21 would be put into the life cycle cost

22 calculation? 
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1 Lifetime of measures is one that's

2 been discussed. Maintenance cost. I guess

3 I'm kind of asking for ideas about what those

4 things might be and how we would get at those

5 figures. Or are there examples of any of

6 these? Or we don't have to worry about it

7 now, we'll worry about it later?

8 MEMBER LACEY: First, just as

9 another plug for the DOE methodology there's

10 a summary table on page 25 of the PDF that I

11 sent to everybody that includes a lot of these

12 things.

13 But as for lifetime of measures, I

14 believe National Association of Homebuilders

15 publishes every few years an expected lifetime

16 of various home components. That might be a

17 good starting point. 

18 I don't always agree with

19 everything in the report but it will give you

20 kind of an estimate of how many years a

21 natural gas furnace is expected to last versus

22 insulation versus a light bulb and all those
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1 things. It might be one source of the

2 lifetime of the individual measures.

3 MR. RAMIREZ: What's that report

4 called?

5 MEMBER LACEY: I don't want to

6 bombard you with emails but I can probably

7 find it and circulate it around. I think it's

8 called "Expected Lifetime of Building

9 Measures" or something like that.

10 MR. RAMIREZ: Yes, if you could

11 forward that that would be great.

12 MEMBER LEVY: The last item I had

13 in here, and I'm not sure it actually will

14 play into the LCC analysis is the lot

15 community rent. Stacy, you're shaking your

16 head no.

17 MEMBER EPPERSON: I'll withdraw

18 it. I think it's not in the life cycle cost. 

19 It's in an overall affordability because about

20 one-third of these homes are going into

21 communities. 

22 And it's a unique housing
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1 situation that you pay rent and loan. And we

2 don't have that anywhere else hardly in the

3 country.

4 MEMBER LEVY: Okay. Before we

5 move on I want to talk a little bit about

6 analysis in a moment. Is there any other

7 comments about the life cycle cost and what

8 will be done with this information?

9 MS. HOFFMAN: Before you do, just

10 a short. We had in our agenda public comment

11 or questions. And what I'd like to do is just

12 see if there is any from people listening or

13 people in the audience. 

14 If there isn't we'll go on. Thank

15 you. 

16 MEMBER LEVY: Okay. I just wanted

17 to mention here. What you see up here, this

18 analysis has now been now changed by events.

19 But it's -- the idea is pretty

20 much intact. And that is what we're doing

21 after we leave this room is we're providing

22 information back to DOE that they need to run
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1 life cycle cost analysis on various cases and

2 bring information back to the committee for

3 evaluation.

4 We have a volunteer to provide

5 cost information. Others have volunteered,

6 Stacy and others to provide other economic

7 data. All that will be sent back in the weeks

8 ahead back to DOE and to their analysis team.

9 It's our understanding that the

10 next step in this process is that they will

11 take that information and they'll run cases,

12 different life cycle cost analyses of

13 different measures in different locations of

14 the country for different sets of variables

15 like different fuel types and those kinds of

16 things.

17 And perhaps, Matthew, you can talk

18 about what your plan is there if you have a

19 plan yet. And specifically what would be done

20 and what would come back to the committee.

21 But I think we should talk a

22 little bit about that so we have a pretty
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1 clear understanding of what we'll get at the

2 end of that analysis period, what comes back

3 to the committee and what kind of information

4 we'll have to work with.

5 One thing I did want to mention,

6 and let me see, is that what we've done in the

7 past, and I assume we would be working towards

8 the same place in this analysis is the dual

9 life cycle cost analysis of enough cases so

10 that we know for any one location in the

11 country, states in particular, what level of

12 efficiency is cost-effective. In UO parlance

13 that might be the way the information, the

14 results are expressed.

15 This is from the last go-round on

16 the code update where at that time the

17 laboratory that was doing the analysis came up

18 with UO values that were determined to be

19 cost-effective for each state.

20 And here you can see the results. 

21 Before they were graphed into zones. 

22 So, if we're all in agreement that
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1 this is what we're building towards. We're

2 getting all this information together to come

3 up with usable values, averages for states,

4 some kind of weighted average which takes into

5 account different kinds of buildings,

6 different fuel types, different cost

7 structures, different energy costs and all

8 those things combine to come up with one

9 figure for each state.

10 And then we would look at UO

11 values across state lines to find and put

12 together groups of states that are similar and

13 lump those into zones. That's what we did in

14 the last go-round.

15 And the HUD map today is a result

16 of taking a bunch of states like this,

17 grouping them together and then weighting the

18 UO values for each of the states based on the

19 shipments to the states to get a zone U value. 

20 That was the process we went through.

21 So I'm putting this up there just

22 to make sure that we're in agreement as this
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1 is the kind of information that we want and

2 this is where we'll be headed and this is the

3 process we want to follow.

4 MEMBER ROY: I think it's fine. I

5 also have a caveat that I'd also like to leave

6 open for the application of the UA approach

7 having heard back from the manufacturers about

8 their familiarity and interest and willingness

9 to go down that path which is using the IECC

10 and might provide you more flexibility and a

11 more harmonious factory floor over the years.

12 So I love the UO, it's great,

13 we're all familiar with it. But I think the

14 UA, I'd really like to hear how you guys think

15 about that before committing to going to a UO16 based standard.

17 MEMBER SANTANA: Manny with Cavco. 

18 So, we're not suggesting that the UO is the

19 only approach we're going to take. We're

20 suggesting it is the only approach we're going

21 to take?

22 MEMBER LEVY: No, no. I think
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1 Robin was brought it up. We can certainly go

2 to the UA approach. We can have a

3 prescriptive approach. We can have a very

4 prescriptive approach. And a performance

5 approach, or any combination we want to have. 

6 Just like IECC does.

7 MEMBER SANTANA: You know, at the

8 risk of increasing our workload I think it's

9 a good idea to have a UO approach, and have a

10 prescriptive approach, and then have a UA

11 approach. I think that options, it provides

12 more efficiency.

13 MEMBER LUBLINER: So, when we you

14 guys the analysis in '74 -- I mean, '94 we

15 didn't have a lot of the multivariate analysis

16 tools available.

17 I think that we've learned based

18 on the way things came out that there was

19 significant lost opportunities by not having

20 that tool.

21 So I would strongly encourage that

22 any way of weighting this uses the
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1 multivariate crystal ball kind of analysis. 

2 And we just don't do averages. I think we

3 would be going down the wrong path and a path

4 inconsistent with other ASRAC policy

5 approaches if we don't at least consider the

6 Monte Carlo multivariate analysis as we set

7 these standards. Thank you.

8 MEMBER LACEY: I'm sorry, I feel

9 like I'm doing a lot of talking today.

10 I have a question about the way

11 this was conducted back in 1992. I think it

12 was in the nineties, not the seventies. 

13 Ninety-four.

14 At the time was there

15 consideration of the impact of air continuing

16 in all these zones? I know a lot has changed

17 and in the residential market air conditioning

18 use has become extremely prevalent. And I

19 would suggest that you should probably assume

20 that.

21 And I want to make sure that

22 whatever analysis you're doing, it's a UO does
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1 it appropriately account for cooling costs

2 which would be impacted by an SHGC, maybe by

3 orientation or other factors. 

4 I don't have all of your inputs in

5 front of me but I want to make sure that if

6 you're going to go down this route and try and

7 calculate an optimum UO that it also accounts

8 not just for heating costs but also cooling

9 costs. Is that all wrapped up in this?

10 MEMBER LEVY: Yes.

11 MEMBER LACEY: Okay, thanks.

12 MEMBER ROY: In one, where we say

13 -- first, I'd like to strongly support Luby's

14 suggestion of an analysis that gives you

15 distributions to look at. It's just much more

16 informative and helpful. 

17 I suspect it's not that much

18 harder for the folks to go through. Perhaps

19 I'm wrong.

20 But in one when you say "and

21 energy types," can we make that a bit more

22 broad to say "and heating and cooling types?" 
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1 Maybe just heating types. Is that what really

2 we're getting at here?

3 Because I heard what Peter said

4 several times. Boy, does he speak strongly on

5 this heat pump world and this ductless world.

6 I'm not sure we want to make

7 standards that require it but I sure would

8 like to understand it more and see what's

9 underlying that.

10 I believe they looked at different

11 heating types at least in that first round of

12 stuff they sent out. So I suspect it's not

13 that much more work.

14 MEMBER LEVY: The point generally

15 is wrong now, but you're right.

16 I should have added before we left

17 this topic of other inputs I should have asked

18 Ed and Matthew whether there was other

19 information you'll need to do this analysis.

20 MR. WALKER: This is Matthew

21 Walker again with Navigant.

22 There is one big thing that I
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1 think we should talk about which was up on one

2 of the first sections. Oh, I'm sorry, it's

3 not on this Word document. It was the

4 spreadsheet. In addition to the 2015 cost

5 data there also needs to be cost data 

6 associated with a reference point which would

7 be likely a HUD minimum code style building. 

8 Or at least the typical construction type

9 that's being sold right now.

10 I just wanted to be sure that that

11 gets into the data collection process. 

12 Thanks.

13 MEMBER LEVY: If that's missing

14 from this list, Matthew, of all the component

15 U-values, if there's a level here that's

16 missing that would correspond to the HUD

17 minimum we can include it.

18 MR. WALKER: Okay. It's possible

19 I misunderstood the spreadsheet about -- I

20 guess I was envisioning a duplicate of what's

21 on the screen right now that's called, that's

22 titled "HUD" rather than "IECC 2015." Because
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1 it's possible that Miami 1A wall factor of

2 0.088 would be a higher U factor for the HUD

3 minimum. 

4 Is that -- am I off topic here?

5 MEMBER LEVY: Yes. You're off

6 topic. This is a U value for -- you can build

7 a wall that has an 0.088 U factor. And that's

8 just one option. 

9 Right here we have two wall

10 options are on this list. One, there's only

11 one ceiling option. So we need to flesh this

12 list out to make sure that all the options

13 that we have here are -- that you could

14 possibly want to have are described here.

15 So, this list is not complete, but

16 it will have all of the options that are on

17 the PNNL analysis. 

18 MR. HAGERMAN: This is Joe

19 Hagerman, DOE. I think maybe what he's asking

20 for is, and maybe you can answer it this way. 

21 You give a cost, cost per square foot price,

22 right? And that's the incremental cost over
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1 a HUD minimum?

2 MEMBER LEVY: No.

3 MR. HAGERMAN: Or is that just the

4 total cost?

5 MEMBER LEVY: I'm sorry, this

6 table wasn't complete. But what it should

7 have had is all the possible ways to insulate

8 each component. So everything from R11 in the

9 wall to R21, 24, whatever is the highest level

10 here.

11 We'll describe each one of those

12 in terms of how it's built and what the cost

13 is. And then you can take whatever

14 combination of measures you need for any one

15 zone that gets you to the HUD minimum as a

16 starting point. That's what we're looking

17 for.

18 MEMBER TOMPOS: Emanuel, Dave

19 Tompos from NTA. Are you asking -- is the

20 data, the cost data that you're getting, is

21 that the consumer cost or is that the

22 manufacturers' cost?
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1 MEMBER LEVY: Well, we were asked

2 to provide both. And also a range of values,

3 what kind of range of values we see in each

4 one of those components.

5 MEMBER EZZO: This is Mark Ezzo at

6 Clayton. I've got a question about these

7 component costs.

8 Mark Weiss brought up a question

9 earlier today about the difference in prices

10 that different manufacturers pay. How are we

11 going to capture that in all this?

12 MEMBER LEVY: So, Mark, what we've

13 been talking about is SBRA will pull together

14 the costs, put together an average, but also

15 express what the range of costs are that we

16 collect from the manufacturers. 

17 MEMBER EZZO: Are you going to

18 have small manufacturers in the mix?

19 MEMBER LEVY: I think we need to. 

20 MEMBER EZZO: That's the point,

21 yes. So, Mark, can we rely on you to maybe

22 help us select some of those manufacturers we
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1 can get that data from?

2 MEMBER WEISS: I'll do what I can.

3 MEMBER EZZO: Okay.

4 MR. HAGERMAN: This is Joe

5 Hagerman. We can always add the RSMeans cost

6 which would be the retail cost.

7 We can always add a column that

8 takes costs from the RSMeans, the

9 construction, cost data book or whatever it's

10 called that gives you the cost that

11 contractors use when they bid a project. So

12 that gives you any clues on markup and 

13 everything you said. It breaks it down. So

14 it would be a good, another data point to

15 consider.

16 MEMBER LUBLINER: Yes, I think I

17 mentioned this on the last meeting. It might

18 be useful to talk to an organization like

19 NAIMA and get a sense of what their margins

20 are for large builders versus smaller builders

21 to help address Mark's concerns in the point

22 that Mark Ezzo brought up.
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1 They are in a position to be able

2 to provide cost data with you without

3 violating their perception of collusion when

4 you ask one manufacturer. 

5 But I would certainly want to

6 bring NAIMA in sooner than later and at least

7 figure out what they are comfortable sharing

8 -- in the way I'd love to check the assumption

9 of R per inch per square foot on volume to see

10 if that's applicable to smaller manufacturers

11 and larger manufacturers. Thank you.

12 MEMBER WEISS: For the court

13 reporter and for me what's NAIMA? What does

14 it stand for.

15 MEMBER LACEY: It's the North

16 American Insulation Manufacturers Association. 

17 Is that what you're talking about?

18 MEMBER LUBLINER: That's correct.

19 MEMBER LACEY: I can ask for that

20 kind of information. I'm not sure they can

21 give out cost information. But I can

22 certainly try them.
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1 MEMBER LUBLINER: Yes. I would

2 think just getting a sense of the percent

3 difference between a volume procurement and a

4 small procurement might be of interest to this

5 discussion. Thank you.

6 MR. RAMIREZ: We have less than 15

7 minutes here. Well, yes, Linda said we could

8 still go along with this but I want to save

9 some time to discuss next steps and also

10 tomorrow.

11 So, did you want to to on and ask

12 your question? 

13 MEMBER LEVY: You know, let's not

14 another section I would say.

15 MS. HOFFMAN: I'd suggest the next

16 section would be tomorrow. But let's talk

17 about tomorrow.

18 Thank you, by the way. Thank you

19 very much.

20 MR. RAMIREZ: Okay. As far as

21 next steps. And you guys correct me if I'm

22 wrong, you guys coming from my Chicago. Don't
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1 let me exclude the ladies, right?

2 But, where do we go tomorrow? 

3 Emanuel still has some information that he

4 could review. But -- and we're creating some

5 ranges. But really it's more -- we're having

6 more value discussions versus actual content. 

7 We need some numbers, right? We

8 need some data. We need to start plugging

9 some things in in order to have some real

10 discussion where we could start sometimes even

11 if what we call fa-meeti-ating, right? 

12 Facilitating and mediating at the same time. 

13 Well, we'll get some discussions and see what

14 we could do to nail down a term sheet.

15 So I don't know if we have enough

16 to have a full-day discussion for tomorrow. 

17 But you all tell me if I'm wrong there and if,

18 what does that look like. Again, because

19 we're moving to some data. At least that's

20 what I'm sensing.

21 MEMBER LUBLINER: If I knew this

22 ahead of time I wouldn't be missing my
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1 daughter's college graduation on Saturday

2 morning if I'd known we were leaving and could

3 adjourn early tomorrow.

4 I have some political issues in

5 marital bliss to justify this. I'd like to

6 get as much work done as we can in the time we

7 were allocated. But that's my own personal

8 preference. 

9 I've already made my flight back

10 for Saturday so I'm going to miss it. I'd

11 like to make this useful time if I'm going to

12 miss it. Thanks.

13 MR. RAMIREZ: And that is a

14 question. So what are we going to do then? 

15 We have some items that we can go through. 

16 But I just don't know how much of it is going

17 to be useful.

18 MEMBER LACEY: This is Eric. We

19 talked about a lot of concepts. And some of

20 these, getting to a specific, the specific

21 requirements we probably need some more data

22 on.
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1 But tomorrow could we work on some

2 conceptual things. Like, for example, do we

3 want to have multiple compliance options is

4 something I kind of introduced here. 

5 What might they look like? Would

6 you have a prescriptive path? A total UA? 

7 Some kind of performance or ERI path and a U

8 of O? Or would you only have two of those. 

9 That's something that I'd like to address at

10 some point.

11 And it wouldn't require, I mean,

12 you know, we can talk later about what the R

13 values could be. But if people are interested

14 in that kind of approach what would the

15 universe look like. That's one suggestion for

16 tomorrow.

17 MEMBER LUBLINER: I'd like to have

18 a discussion about the source of the data for

19 looking at fuel and equipment weighting. I

20 think that's going to be a big driver, what we

21 assume in different climate zones, the

22 percentage of electric furnaces, their heat
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1 pumps, propane, natural gas. And the sources

2 of the information that we're presently

3 seeing.

4 I think that's a really -- as we

5 talked about the big driver being the term of

6 the analysis and the discount rate those

7 things too can have a big factor. So I'd

8 rather find out tomorrow that we don't have

9 enough data to know, or the data we have

10 there's disagreement on how accurate it is. 

11 So maybe we should talk about that tomorrow.

12 MEMBER LEVY: And in a similar

13 vein, just off your point, Michael. The next

14 meeting after this meeting is just two weeks

15 away. Two weeks and the next week after that

16 is the next meeting.

17 I'm a little bit skeptical that

18 all this information is going to be able to be

19 brought together, provided to the contractor

20 and there will be enough results to make it

21 worthwhile to have a meeting.

22 So, I don't know what the dates
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1 are but it seems like it's a little fast.

2 MR. RAMIREZ: We have September 9

3 and 10.

4 MEMBER LEVY: Right. So we have

5 two full weeks after tomorrow. Right, Labor

6 Day weekend.

7 MEMBER EPPERSON: This is Stacy. 

8 I share that. Pulling the financial data will

9 be a little bit challenging. My friends in

10 the industry, this is something that hasn't

11 been widely available. So I think there would

12 be some time involved in getting it.

13 MR. RAMIREZ: All right. So then

14 it sounds like tomorrow we're going to have to

15 discuss, depending how that goes, if there's

16 value in keeping the 9th and 10th, or

17 scrapping that one to use that to gather more

18 information so that we could have a more

19 productive meeting on the 22nd and 23rd if I

20 understand you correctly. 

21 So, we can nail that down

22 tomorrow.
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1 MR. HAGERMAN: So, this is Joe

2 Hagerman. We can always just decide tomorrow,

3 not today of course, that the 9th and 10th may

4 be just a couple of hour phone call and

5 webinar. 

6 I mean, I don't want to miss the

7 opportunity to check in with the group and

8 lose the fast-forward momentum that I think

9 we're trying to provide here.

10 MS. HOFFMAN: And we'll be

11 continuing this framework tomorrow I guess

12 first thing, continue that. 

13 Any other thoughts of topics you

14 want to make sure are discussed tomorrow? 

15 Yes, mark.

16 MEMBER WEISS: At one point during

17 the discussion today there was an issue that

18 came up with regard to the states and

19 preemption and that sort of thing. And I

20 think OGC was going to try to get us something

21 on that.

22 I don't know if they can be
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1 prepared to address that tomorrow so it's

2 something that would be of interest, if

3 possible.

4 MS. HOFFMAN: Is that possible for

5 tomorrow?

6 MS. VAIDYANATHAN: Yes, I will

7 have an answer to you by tomorrow.

8 MS. HOFFMAN: Okay. So we'll have

9 OGC also on the agenda.

10 MEMBER SCHNEIDER: This is Peter

11 from Efficiency Vermont. If there's no

12 additional discussion --

13 MR. RAMIREZ: I'm sorry, Peter,

14 can you mute your -- or pause your

15 GoToMeeting? Because we're getting an echo on

16 this side.

17 MEMBER SCHNEIDER: Is that any

18 better. 

19 MR. HAGERMAN: Why don't you email

20 us, Peter, and we'll make sure that we talk

21 about that tomorrow.

22 MS. HOFFMAN: And while he's doing
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1 that let's just get a process check. How is

2 this going? We heard from John Caskey, you

3 know, hey, we've got some deadlines. And

4 Manny said maybe we need a little more time. 

5 And I think Robin said oh, we can do it. So

6 I just want a sense of how are you feeling so

7 far in terms of trying to get this done. Yes,

8 wishy-washy. All right. 

9 I'm saying get it done and get it

10 done on time.

11 MEMBER ROY: I think it's okay. I

12 do recall a couple of weeks ago when we met we

13 asked if a bunch of numbers could be populated

14 to the best first guesses of the geniuses at

15 Navigant and PNNL. 

16 I worry about losing momentum. I

17 realize it takes a long time to generate all

18 sorts of numbers. But to throw numbers in

19 gives for somewhat more concrete discussions,

20 even if they're pretty crummy placeholders.

21 Because then we flake off of those

22 and riff. I think we'll get a lot done on the
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1 9th and the 10th if we have something like

2 what we asked for three weeks ago.

3 It would be very, very useful even

4 if we don't really believe it. And we're

5 going to do what we can. We're going to

6 update on the fly. We'll never get to the

7 deadline. That's may not a likely thing to

8 get the deadline but we'll certainly not get

9 there if we don't strive for it.

10 MR. HAGERMAN: So this is Joe

11 Hagerman, DOE. I totally agree with you. And

12 Matthew I kind of -- I think he updated you

13 previously about the status of the

14 spreadsheet. 

15 And he's finished putting that

16 together largely. And so we can start doing

17 that. We can start populating just our gut

18 feel of costs. We can populate the annual

19 energy consumption numbers as well that we've

20 already generated. So we can at least take a

21 --

22 MS. HOFFMAN: Manny -- oh sorry. 
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1 And then Peter, we understand, can come back

2 on.

3 So, first Manny and then Peter. 

4 MEMBER SANTANA: Manny with Cavco. 

5 You know, I'm also concerned about the loss of

6 momentum. So it might be a little premature

7 but what if we -- even if we would decide to

8 not meet on the 9th, what if we schedule a

9 call every Friday just to keep this in the

10 front of everybody's mind? Even if it's only

11 a few hours, just to get a status check.

12 It's a good idea. Why don't we --

13 we'll think about it and discuss it tomorrow. 

14 And who knows, maybe we'll have enough

15 material for a meeting in the first time in

16 September. 

17 Peter, you are on now.

18 MEMBER SCHNEIDER: I just want --

19 working with folks on the phone with more

20 experience than myself.

21 MR. RAMIREZ: I'm sorry, Peter. 

22 Let me pause you just because you just need to
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1 speak up. There's no echo now but we need for

2 you to speak up.

3 MEMBER SCHNEIDER: Okay. So I

4 just wanted to request that the folks on the

5 phone with more experience than myself would

6 just hope to find those constraints they seem

7 to exist. With the manufacturing process, the

8 current thermal envelope specifications that

9 won't allow them to meet specific IECC 2015

10 criteria. 

11 And then spend some time

12 troubleshooting that. You know, Michael

13 already indicated that there are some

14 strategies already being used to do that. And

15 I'd like to just really nail those down so

16 that doesn't become a burden later on.

17 MS. HOFFMAN: Did everyone hear

18 him? 

19 MR. RAMIREZ: Yes, and I think,

20 Emanuel, that's what your going to be working

21 with them? Okay.

22 So, in assembling that information
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1 it's not so much the difference between what's

2 physically possible and what's cost-effective. 

3 Right? And those are some of the things that

4 you're going to be working with. Okay.

5 MS. HOFFMAN: And I think in terms

6 of -- don't cancel yet September 9 and 10. 

7 Keep it in your book. We'll make a decision

8 tomorrow, okay? So maybe you want to get

9 Michael back, et cetera.

10 It's been a real pleasure. Any

11 last comments from anyone? I want to thank

12 our wonderful court reporter, and folks, Emily

13 and company, and our economist and general

14 counsel and all of you for giving your all. 

15 And we look forward to seeing you bright and

16 cheery tomorrow at 9 o'clock. Thank you. 

17 MR. RAMIREZ: Thanks, everyone.

18 (Whereupon, the above-entitled

19 matter went off the record at 5:00 p.m.)

20

21

22
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A

$1 287:16 288:1,5

$1,000 289:8 325:6

346:21

$1,300 338:21

$1,600 340:2

$10 289:4,7

$10,000 287:20

325:11

$100 338:4 339:7

$2.60 324:21

$20 312:14

$26,000 219:14

$27,000 127:5

$4-plus 324:22

$400 325:19

$5 312:10

$5,000 219:11,16

312:9 316:6

$500 316:10

$600 325:22

$7,000 316:6

$700 325:22

A-94 358:17

a.m 1:10 5:2

132:14,15

abbreviation 259:2

ability 36:7 50:9

151:20 172:10

233:2 235:3 298:8

301:7

able 12:12 14:5

19:14,14 22:3

49:3 70:2,3,6

90:16 108:16,17

118:20 129:12,13

151:20 182:15

202:14 216:13

231:21 232:4

258:19 308:14

321:18 361:17

379:1 384:18

above-entitled

328:16 392:18

absent 115:11

272:15

absolute 200:11

absolutely 36:3

78:16 87:17 97:5

abstract 120:12

235:6

accept 68:6

acceptable 169:12

accepted 70:19

access 87:3,20,21

accomplish 200:14

accomplished

80:14

account 66:7 69:4

101:17 102:20

106:1,15 109:7

123:20 279:6,12

282:12 284:5

313:21 348:13

368:5 372:1

accounted 72:20

153:9 154:9

accounts 372:7

accrue 320:11

accumulating

286:13

accurate 42:13

117:16 146:16

325:5 384:10

achievable 63:3

achieve 55:16

172:11 187:7

202:20 267:6

achieving 264:18

265:3

acronyms 12:21

act 161:1 234:17

238:5 310:5 341:6

361:8

action 115:9

290:16

activities 3:19 23:1

330:15

actual 10:18 26:7

61:2 62:4 69:8

102:2 201:16

282:8 291:14

298:12 313:3

324:15 349:12

381:6

actuality 63:11

239:19 240:18

ad 221:6

Adams 310:5

adaptable 182:14

add 18:13 37:11

61:16 70:2 74:8

84:2,3 127:19

128:2 143:3 147:8

172:13 192:12

219:11,16 220:12

235:17 237:19,22

244:18 254:21

261:20 263:22

272:8 287:10

288:4 290:13

299:21 338:12

378:5,7

added 20:4 177:6

192:8 289:17

373:16

adding 60:18 252:3

252:5 257:10

265:14 289:12

307:2

addition 201:21

322:2 323:4 326:3

374:4

additional 4:4

20:17 82:3 132:17

159:10,11 197:7

205:19 258:11

263:22 265:20

325:10,15 387:12

address 24:6 28:1

48:17 93:22

100:21 123:14

159:6 173:18

193:2 195:13

203:17 254:11

278:8,9 329:1

378:21 383:9

387:1

addressed 85:22

98:22 106:16

173:11 356:5

addresses 246:1

259:8

addressing 98:19

159:22

adds 144:22 150:17

adjourn 4:19 184:9

190:1 382:3

adjust 43:1 267:18

Administration

341:13

ado 24:13

adopt 361:15

adopted 18:7 149:9

162:18 361:12,13

361:14,18

adopting 90:14

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224:15 228:11

229:19 240:3

247:11 248:2,14

248:15 250:7

251:18 262:1,10

262:12 265:13,16

275:2 277:19

283:9 284:16

290:8 292:4,21

308:11,12 310:7

323:17 332:11

339:3 345:16

347:11 348:9

350:11 353:7,10

353:16 358:3

360:16 370:14

383:11 386:6

meaning 223:10

225:21 330:8

means 72:10 86:13

135:5 175:11

176:15 186:22

195:1 222:8

227:11 248:15,16

248:18 274:11

307:18 359:14

meant 279:4 320:4

measure 103:13

109:13 118:4,6

209:14 210:15

252:6 289:4

291:15 303:17

305:8,15 306:8

315:2 317:22

318:16 319:6

measurement

154:1

measures 36:7

90:15 93:13 99:3

103:5,7,9 104:9

107:15 110:3

111:17 112:10,18

197:8 205:19

210:3,10 211:9,12

212:10 225:15

238:6 247:8

250:19 251:1,9,11

252:4,13,15,18

254:16,22 292:3,6

296:22 307:2

316:7 322:22

332:4 363:1,13

364:2,9 366:13

376:14

meat 195:17

mechanical 216:16

217:1

median 124:5

mediating 381:12

Mediation 1:13,14

2:5 5:5

meet 20:6 63:5,6,13

63:15,18,22 64:3

68:2 69:14 73:18

73:18,19 97:12

99:7 140:3 151:3

151:4,6 158:8

178:5 189:2

207:20 237:15

251:10 254:16

261:15 263:2,7

390:8 391:9

meeting 1:5,9,11

1:13,14 2:4 3:4,18

11:20 13:22 14:11

16:9 17:22 22:10

24:4 26:22 62:13

73:14 89:6 97:7

100:21 137:17

187:13 233:21

236:22 237:14

275:5,18 378:17

384:14,14,16,21

385:19 390:15

meets 19:12 62:5

73:13 254:8

meltdown 347:10

member 6:2,5,7,10

6:13,14,16,19,21

7:21,22 8:3,6,8,9

8:10,11,13,14,16

8:17,18 9:17

13:22 14:9,13,21

15:16,20 16:4,5

16:11,20 17:9,17

18:1 20:17 21:12

21:21 26:12 27:2

27:4,12 31:22

32:4 33:2 34:1,17

34:21 35:15 36:3

36:10 37:8 38:1

39:12 40:3 42:6

42:16 43:7,16

44:2,8 45:5,9,20

45:22 46:17 49:18

50:21 51:2,20,21

52:16,20 53:7

54:12,18 55:19

56:19 58:15,19,21

61:15,20 62:17,22

63:16,20,21 64:4

64:5,15 65:11

68:19 70:8 71:7

71:14 72:7,14

73:6,22 74:19

75:20 76:1,8,10

77:5,6,9 78:7,9,21

79:1 80:17 81:3,5

83:19 84:2,6

85:15,19 86:17

88:6 93:15 94:12

94:14 96:4,14

97:18 98:8 99:11

99:14,17,20 100:2

100:16 101:1,4,10

102:7,19 105:20

106:20 109:5

110:11,15 114:13

115:18,22 116:8

117:4 120:2 122:1

122:12 123:13,15

124:18,21 125:1,3

126:4 127:16,19

128:1,20 129:2,16

130:7,9,22 131:3

131:18 132:17

133:14 144:1

147:6,13,14,16

149:17,18,19

150:3,5,12,13

151:1,4,6,10,12

151:17 152:6

154:15 155:21

163:4,16,17 164:1

164:2,3 165:9,12

165:14 166:17,21

166:22 167:19

168:4 170:4,13,22

171:2 172:7,8,19

173:19,22 174:1

174:10,13,14,18

174:19 175:1,2,5

175:9,16 176:19

177:12,14,19,20

178:9,11,19 179:2

179:4,6,7,8,10,11

179:16 180:8

181:5,11 183:6,9

184:6,11,13 190:4

190:8,20 191:3

192:2,5,14,18

194:7,10,11,12

199:7,11,15,22

200:1,8,22 201:11

201:12,14,20

202:5,6 203:3,21

204:18 205:16

206:9,14 208:15

209:6,17 210:16

211:3,10,14,16,21

212:8 213:1,3,6

213:22 214:12,17

215:17,22 216:1,2

217:6,10,12,13,15

218:13 220:2

221:1 222:12

224:5 225:6,18

229:3,5,9,21

230:9,16,20 231:3

231:6,11 232:14

232:18 234:15

236:7 238:4

242:10,19 245:13

246:18 248:4,9,11

250:8,10 251:20

253:4,18 255:14

256:10 258:21

259:1,3 261:4,10

261:18,22 262:6

262:12 263:11,18

263:20 264:5,15

265:12,22 266:9

266:12 270:7,19

271:1 272:18,20

273:1,4 274:3,19

275:1 276:18

278:11,17 279:22

282:6,19 283:4,18

284:16 285:15,17

287:8 289:16,19

290:12 291:2,9,13

291:22 292:2,9,11

292:14,22 293:11

293:14,16,21

294:13,16,19

295:4,6,17 296:6

298:2,11 299:17

300:4,8,10,11

301:2,13 302:18

303:8,13,15

304:22 305:13

306:12 308:6

311:2 313:9

316:17 317:7

318:8 320:14

321:15 323:21

324:2,9 326:12,15

326:21 328:4,9,22

330:5,17,19 331:1

331:8,20 334:4

337:17 338:18

339:17 340:19

342:6 343:5,15,17

344:7,12 345:21

347:3 348:9

349:13 350:5

351:6,17 352:14

352:19 353:7,12

353:13,15,19
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 419

354:7,20 355:5,12

355:13 356:4,9

357:20 358:1,16

359:3 360:4,21

361:2,9,11,20,21

363:8 364:5,12,17

365:4,16 369:4,17

369:22 370:7,13

371:8 372:10,11

372:12 373:14

374:13 375:5

376:2,5,18 377:1

377:5,12,17,19,20

378:2,3,16 379:12

379:15,18,19

380:1,13 381:21

382:18 383:17

384:12 385:4,7

386:16 387:10,17

388:11 390:4,18

391:3

members 3:8 5:20

7:17 11:1,8 18:8

20:12 21:11 24:20

27:8 28:9 45:4

72:5 116:22 181:2

212:9 245:21

324:1

membership

180:19 292:5

mention 20:12

49:12 96:6 160:14

187:12 195:11

247:1 359:4

365:17 367:5

mentioned 63:1

76:20 152:16

156:13 160:2,6

165:17 173:12

217:11 271:20

279:3 319:5 333:6

333:13 334:18

342:9 378:17

messed 145:6

messy 244:2

met 1:9 9:21 15:4

187:22 388:12

metal 47:8

meter 52:13 53:3

86:10

method 48:11 80:5

80:6,11

methodology 265:8

335:15,18 336:20

337:13 341:4

350:7 363:9

methods 136:19

metric 151:22

221:11,15,17,21

222:1,10

MH 57:2 180:16

MHAR 298:2

MHARR 105:20

Miami 375:1

Michael 2:2,7 3:9

6:1,2 8:17 9:11

13:21 32:21 36:10

65:9 70:9 73:7

76:14 266:11

298:19 303:14

337:16 351:10

384:13 391:12

392:9

microdata 131:9

microphone 9:15

21:1 34:19,20

middle 48:21 68:1

125:12 345:16

350:22

Midwest 73:9

Mike 33:1,1 44:8

98:10 204:18

206:10 238:4

282:7 355:6 356:9

million 338:4 339:7

millions 241:18

min 261:21

mind 20:18 23:22

40:16 41:12

132:18 195:19

198:18 204:16

219:2 246:11,12

288:19 315:20

320:7 334:19,21

390:10

minds 228:21

mine 357:21

mini-split 216:14

mini-splits 202:13

minimizing 222:5

minimum 29:8

33:14 34:3,5

35:19,21 37:13,14

37:16 48:13 63:18

64:1 73:9,14

100:1 149:6 161:7

161:15,20 166:1

167:5 168:22

186:6 225:9,11

277:5 308:7

311:21 315:21

327:5 374:7,17

375:3 376:1,15

minimums 118:8

minus 254:9

352:17

minute 139:2

minute-interval

30:13

minutes 10:22

22:21 107:18

328:13 380:7

misleading 224:9

missed 12:7,21

13:1 167:20

244:11 263:18

315:7

missing 93:11

374:13,16 381:22

mission 126:14

213:20 317:9

misunderstood

374:19

mix 377:18

mobile 233:6

298:14 299:9

327:12

model 19:11 20:6,9

38:14 49:21 51:10

52:10 61:10 62:16

86:8 88:16 93:9

101:7 143:10,16

143:19 144:11

145:12 156:18

243:6 361:3,7

modeled 20:9

28:19 29:4,13

30:10 34:11 62:4

83:10

modeling 34:14

51:9 52:3 62:8,14

62:19,20 83:9

85:20 86:12 88:13

273:6 275:3

276:11

models 29:22 92:13

95:21 272:11

modification 218:7

220:16

modified 186:21

modify 36:14 61:12

81:18

modular 178:4,14

181:8

modulars 180:15

326:20

moisture 109:9

moment 214:15

257:18 365:6

momentum 386:8

388:16 390:6

monetary 90:9

91:10

money 92:14 104:7

108:18 304:5

311:19 312:10

314:1 345:13

350:1

monkeyed 37:6

Monte 120:18

121:21 122:9

371:6

month 309:5,21

312:10 325:16,20

325:22 336:7

347:17

month-to-month

336:7

monthly 309:5

326:2,6

months 289:9

moot 220:5

morning 5:3 7:22

8:11 137:20

172:10 204:4

245:15 382:2

mortgage 104:11

105:6 120:9 124:4

286:17 287:2

293:6 295:22

296:1,18 298:8

302:6,11,12 306:4

309:6 312:7

313:22 325:19

340:15 345:22

347:2 348:16,20

350:8,20 351:5

352:15 353:8,10

353:16 356:12,17

359:12 362:10

mortgages 340:1

345:14 354:10

357:9

motion 334:1

move 84:21 91:21

91:22 92:2,4

103:16 107:1

112:2 168:20

191:21 194:4,17

199:4,8 204:16

220:14 245:9

251:10 285:15

292:15 309:5

343:2,4 365:5

moving 11:5

159:16 204:12

207:9 214:20

234:7 276:1 299:3

299:9 344:11

361:21 381:19

multi-section 41:4

50:3 113:11 114:3

318:6

multiple 67:5 383:3

multiplies 144:20
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 420

multiply 52:14

269:21

multivariate

354:14 370:15

371:1,6

mute 230:18,22

387:14

N

NADA 296:18

337:22 338:3,7,11

338:19

NAECA 100:5

160:21 166:20

167:14 199:21

NAECA's 166:11

NAECA-covered

171:15

NAHB 181:20

nail 228:22 358:13

381:14 385:21

391:15

nailed 246:9

NAIMA 378:19

379:6,13

naive 300:13

name 9:22 89:20

names 9:13 343:7

narrowed 182:12

narrowing 182:12

national 1:15,16,17

2:18 6:11,17 8:2

20:20 21:5 160:22

176:16 236:19

311:8 312:13

341:5 354:8 359:4

363:14

nationally 176:2

339:19

natural 2:5 6:14

29:6 112:14 136:7

161:12 168:7

185:6 363:21

384:1

Navigant 2:11,20

4:3 7:6 89:8,21

344:19 373:21

388:15

near 98:6

near-term 319:20

nearly 361:14,18

neat 149:2

necessarily 63:3

86:21 117:12

121:8 246:8

359:14

necessary 50:12

113:19 269:6

need 11:3,13 15:11

16:19 21:2,19

34:16 35:5 36:6

41:11,18 42:7,14

44:3 47:22 48:17

49:16 51:10,15

53:11 56:7 58:5

58:10 59:3,17

60:1,9 61:10 64:2

71:12 75:17,18

78:2,16,17 79:15

102:22 105:17

107:16 108:10

109:2,21 110:4

112:21 113:15

117:14 118:8

123:10 124:11

127:1,8 150:7

158:8 171:10

187:6 193:2,3

199:1,3,9 206:20

216:11 228:9

233:14 236:3

239:4 241:10,19

242:14,22 243:12

243:13 244:3,5

257:21 259:14,21

261:2 266:17

267:1,6,22 269:10

269:10 272:5

277:18 279:10

280:17 282:13

288:4,7 290:2,7

291:4,20 296:12

299:22 306:2,16

318:11 320:18

321:21 323:8,10

323:15 326:3

331:22 333:21

334:1 341:15,17

343:3 353:14

365:22 373:19

375:11 376:14

377:19 381:7,8,8

382:21 388:4

390:22 391:1

needed 81:11 85:1

147:5

needs 18:19 20:7

24:8 70:18 109:13

114:16 123:20

138:3 184:19

202:14 242:5

257:15,16 259:9

264:16 265:11

276:6 303:7

324:12 374:5

negative 227:14

252:6 333:12

NEMA 17:9 101:5

114:14 163:5

199:11 321:16

340:19

network 1:19 6:6

349:14 350:4

neutralize 149:11

neutralizes 145:20

never 49:12 180:4

219:17 237:18

251:2,3 262:17

389:6

nevertheless 26:10

new 44:22 82:21

109:15 131:13

137:4 216:6

234:10 300:2

355:16,19,21

NFRC 138:10

NHB 319:8

NHP 176:12

nice 87:9 262:2

nicely 246:3

nineties 371:12

Ninety-four 371:13

no-brainer 326:10

nominal 66:6 71:16

72:16,22 74:2,8

75:9 77:16 138:6

140:11 267:16

non 301:10

non-disclosure

269:5

non-energy 33:10

186:8,8 277:5

non-optimum

357:11

non-profit 299:10

non-profits 349:14

normal 115:9

153:18

normalized 186:21

normally 185:4

251:20 348:12

351:18

North 379:15

Northeast 129:20

northern 47:2 48:1

141:17

Northwest 33:6

41:9 65:16 68:16

72:15 152:4

176:20 240:12

339:6 340:7

356:10

noted 206:13

notes 188:15

190:13 191:4

202:2 203:16

Nothing's 242:17

notice 152:8

notion 121:15

NRDC 16:20

171:13

NTA 2:7 6:13 16:6

34:2 94:15 376:19

number 38:3,5,17

62:4 66:1 76:21

78:4 101:20

142:19,21 143:4,8

143:9 144:21

145:4 146:8,13

152:10 161:3

164:20 176:3

186:15 187:9

224:18 227:12,17

244:19 245:2

252:10 270:12

271:1 294:20,21

306:5 319:22

343:10 346:14

348:22 349:11

353:15 358:8,11

359:5

numbers 39:1

40:22 61:17 69:5

78:2,5,8 81:18,22

82:4 102:6 106:2

116:9 126:18

141:9 143:3 145:1

174:21 176:3,6,9

183:10 187:14,14

235:7,17,21 245:9

246:1,10 262:3

299:14,15 316:5

316:14 320:18

341:19 343:14

355:14,20 359:19

362:4 381:7

388:13,18,18

389:19

O

o 36:13,17,18 37:5

46:8 64:14 92:1

134:18 135:1

136:1 142:9,13

143:5,6,8,22

145:6 146:5,13

147:12,19 148:7

148:10 149:15

153:9 154:10

155:20 156:1

383:8

o'clock 192:7

392:16

o-value 111:4,9

O-values 259:16

object 248:4

obligated 322:1
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 421

observing 117:6,8

obvious 146:19

obviously 28:14

38:6 40:8 209:15

256:17 293:3

303:10

occupancy 30:5

286:21

occupied 52:11

occupies 333:11

offense 247:9

offer 114:19 181:15

234:4

offered 214:19

282:14

office 2:12,14,15,16

2:19 3:7,21 5:15

5:17 7:5,11

132:21 133:4

329:21 330:12

340:21

offices 133:13

official 22:13 191:4

offset 92:7,22

307:20

offsetting 105:4

202:16 345:5

OGC 225:19

386:20 387:9

oh 64:4 84:9 85:18

86:15 89:4,10

127:22 130:20,22

153:21 174:13

218:11 229:17

277:14 284:15

300:6 315:18

322:20 353:6

354:5 374:2 388:5

389:22

okay 7:2,8 9:3,4,19

10:3 14:20 16:3

20:11 22:5 25:10

25:15 27:4 28:18

37:22 38:5,16

39:11 43:7,7 45:7

45:11 51:20 58:18

63:16 64:4 65:11

71:5,7 75:22 76:6

79:11 81:3,19

82:10 83:21 84:13

84:16 85:5,9 86:2

86:4,15 89:4,14

89:20 94:12 96:13

98:7 99:11 102:7

106:20 107:3

117:21 118:12

119:10 123:11

124:18,22 127:7

127:15 131:2

132:10 133:1,14

154:14 164:2

165:12 170:2,22

175:2,8 177:12

179:4,10 181:16

184:11,12,13

190:1,20 192:16

194:11 198:21

199:22 200:8

201:11 204:17

206:19 211:15

212:5,7 213:5

214:16 216:1

217:12 218:11,12

225:3 230:14

231:3,11 232:15

232:16,18 234:11

234:12 236:4,17

238:3 242:8

245:11 246:8

247:18 250:9

256:10 266:16

267:20 284:15

285:17 287:22

289:16 290:10

292:2 300:6

305:11 306:12

313:7 321:12,15

323:20 328:12,13

330:5 337:16

344:4,5 351:1

353:14 354:3

358:1 360:4

362:15 365:4,16

372:11 374:18

378:3 380:20

387:8 388:11

391:3,21 392:4,8

old 132:9

OMB 351:21

358:17

once 47:17 48:4

231:8 238:7 239:9

243:11

one's 308:11

one-hour 30:11

one-third 294:10

298:20 301:8

364:20

one-year 318:19

ones 44:22 111:19

119:16 120:11

246:21 277:13

ongoing 97:15

online 9:7,12 21:2

273:11

open 30:7,8 68:2

76:13 209:3 218:5

287:6 369:6

opening 3:5,8

24:19 25:3,8

operate 307:10

314:16

operating 30:22

91:5 92:22 104:2

104:21 112:3,3,7

129:10 226:4

234:5 288:17

307:18,20 319:2

322:8,10,12

operation 90:21

opinion 65:2 303:4

303:6 348:8

opportunities

280:1 356:19

370:19

opportunity 104:8

105:3 311:15,22

318:15 348:17

349:21 350:2

386:7

opposed 116:10

131:12,14 210:4

295:15 331:11

optimum 356:16

372:7

option 137:12,13

139:13 141:10

179:3,9 188:7,9

189:14 197:19

201:8 346:12

375:8,11

options 79:5 80:21

135:19 136:1,6,18

137:1,9 139:11

175:13 177:10

178:21 182:11,13

183:1 185:7 189:2

189:4,7,20 322:4

345:12,19 348:14

350:17 370:11

375:10,12,16

383:3

oranges 224:9

order 3:2 42:21

113:14 187:7

227:21 228:4,9

229:1 252:4 286:8

341:8 381:9

orders 152:1

organization

203:15 206:16

335:11 378:18

orient 157:21

orientation 157:18

372:3

original 345:5

originally 40:22

Orleans 216:7

ought 342:21

outgrowth 185:6

outgrowths 136:7

156:16

outliers 272:4

outline 292:13

outlined 154:19

257:22

outlining 290:6

outreach 327:8

outrigger 66:5

67:22 74:3 283:8

outright 167:15

outs 169:5

outside 59:11

153:17 204:13

233:15 316:18

outweighed 125:11

overall 31:10,10

72:21 73:15

117:15,16 118:8

149:20 162:10

193:19 198:17

202:3 275:6

364:19

overanswered

183:5

overlap 206:12

overlapping 170:9

overlays 255:3

overview 3:17 90:5

91:2 103:18

Owens 269:9

owner 302:19

343:8,9

owners 1:17 8:2

180:14 327:11

ownership 90:8

94:21 286:17

299:10,10,12

305:10 317:10

owning 90:10 127:4

127:4

P

P-R-O-C-E-E-D-...

5:1

p.m 191:14,15

328:17,18 392:19

p.p.s 243:9

p.s 243:8

pace 16:18,18

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R11 47:10,11,12

59:16,18,22 60:3

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281:8,15,18 283:6

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recommendation

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recommendations

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relative 32:9 46:15

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353:3 354:4 355:3

373:15 374:9,21

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202:6,7 203:21

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scissor 50:9 271:21

scope 205:1

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score 10:2 186:4,17

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scores 15:10 188:5

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scrapping 385:17

screen 26:20 85:8

144:2 374:21

scrolling 139:13

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Seattle 8:4

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130:14 139:13

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secondary-order

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Secretary 225:21

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305:1 323:6 333:4

335:7 339:15

346:8 347:4 351:9

367:5 373:22

386:12,19 389:7

things 9:20 12:9

16:13 17:4 40:8

47:21 50:13,17

54:1 63:5,6 72:5

73:7 75:14 76:22

97:8,8 105:17

107:19 109:1,1,19

110:21 113:20

114:18 120:13

122:5 128:15

130:10 135:8,9

138:15 151:16

153:16 157:4,6,9

160:19 172:13

173:14 185:14,17

188:18,19 190:9

197:2,8 199:13,20

200:7 205:21

207:2,12 209:20

212:14 215:19

218:1,4 221:6,19

227:16,22 232:8

235:6 236:7,12,15

244:19 245:2,4

248:5 256:4 258:2

260:20,22 263:3

267:14 268:7

277:8 279:18

285:1 288:18

293:6 295:10

296:19 312:4

319:9,21 323:13

323:13 337:4

342:20 343:6

345:15 350:10

356:20 363:4,12

364:1 366:16

368:8 370:18

381:9 383:2 384:7

392:3

think 9:3,22 10:17

11:1 13:1,4,15

14:17 15:1,17,21

16:7,9,12,13,17

16:18,21 17:5,10

17:11,13,19,20

18:11,17 19:5

21:15,17 22:19

25:10 26:6 31:19

32:7,10,21 33:14

34:3 35:16,18

38:4,9,11,14,21

39:6 40:16 42:8

43:21 47:16,19

48:16 49:4,10,16

49:22 50:14,16

53:9,11 55:15

56:20,21 57:11

58:5,17 59:4

63:16 66:9 67:6

67:10,11 68:6

70:10 72:8 73:4

73:22 74:20 75:4

75:13,20 76:1

78:2 81:1 82:7,16

83:3 85:3 86:20

87:4,17 88:1,17

88:22 95:15 97:5

97:6,20 102:5,15

103:4,12 104:4

105:7 108:8,13

109:19 110:2,6

112:18 113:21,22

115:2,6,8 116:12

117:7,19 118:19

118:21 119:3,6

121:18 122:2

123:7 124:11

125:5,14,22 128:4

128:10,13,18

129:14 130:1

132:7 133:7 134:1

134:13 135:21

137:13 144:5

148:1 150:3

153:14 158:16

169:13 171:3,8,10

173:4 176:13,20

177:8 178:15,17

180:9 183:16

184:18 191:20

197:22 201:20

204:1,3,13 205:20

207:4,9 208:11,16

208:21 209:10,17

209:22 210:9

211:17 212:13,19

213:6,18 215:10

215:11 217:17

220:4,11 222:12

223:13 226:6

227:18,22 229:3,9

229:10,21 230:2,6

231:11,16 232:21

233:4,12,14,14

234:15 235:15,18

236:2 237:12

239:1,3,17 240:15

241:9 242:1,11

243:1,11 244:8,10

245:13 246:5

247:2,10,13 249:1

251:5 253:8

254:19 255:10

256:11,17 258:2,9

259:14 260:17

262:22 263:16

264:6,16 266:9,12

266:16 267:2,8,13

267:21 269:7

280:16 281:10

283:5 284:1,4,4

284:12,18,18,20

285:5,20 287:8,18

288:3,5,7,22

289:2,9,13 290:5

290:13 291:3,17

292:4 293:17,22

294:10 295:11,20

297:1,6 299:1

301:4 302:14

304:15 305:5

306:3 310:10,15

313:1 315:9,12,17

316:8,14 317:21

318:3,3 320:3,15

320:17 321:7,16

321:21 324:10

328:1,4,6,10

329:1 330:21

331:8,21 332:4

333:13,15,21

334:22 336:8,14

341:20 342:21

345:9 346:3,8,10

348:6,10,10,21

349:2,4,9 350:9

350:21 351:1,18

351:20,21 352:2,9

352:19,21,22

353:13,16 354:7

355:7 357:13

359:5,10,14

360:15 361:5,21

362:6,11 364:7,18

366:21 369:4,13

369:14,22 370:8
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391:19 392:5

thinking 155:19

193:22 196:22

202:9 254:12

349:21

thinks 295:13

thinner 140:21

third 142:3 197:7

256:21 262:3

271:2 315:4

Thirty 287:1

319:15

thoroughly 156:6

thought 14:3 25:1

63:9 71:10 116:1

134:4 158:14

161:10 164:19

181:17 193:1

194:16,21 195:2

195:22 203:19

239:6 328:13

thoughtful 15:1

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thousand 127:6

324:3

thousands 338:8,13

three 29:16 41:22

66:16 135:19

136:22 137:5,15

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235:12 257:9

312:19 342:11

351:20 389:2

throw 158:14 208:9

287:5 321:3

343:10 388:18

throwing 80:12

245:10 302:4

321:16

thrown 221:6,6

thumb 45:13

354:21

thumbs 44:16 45:5

45:8,9 212:4,6

214:1 284:11,13

344:1 353:3 354:3

354:4,5

THURSDAY 1:7

ticket-adopting

212:10

ticking 285:5,6

tie 56:11,12 205:9

tied 348:6

ties 89:17 193:12

tighten 139:18

tightening 109:8

210:4

tightness 140:1,1

141:13 197:15,17

198:11 200:16

203:11,12

time 9:20 10:10

15:13,18 16:13

56:13 67:1 72:11

88:20 91:13 94:20

102:4,8 104:7,20

105:10 107:9

108:9 114:9 116:5

118:18 121:20

129:15 145:6

154:13 162:3

168:3 177:5

179:20 183:20

190:11,12 191:11

207:10 212:8

216:17 234:12

244:15 262:2

265:15,18 273:9

273:15 275:22

285:11 286:12,15

290:20 301:22

302:16 303:7,11

303:19 311:5,17

314:22 315:7

318:11 322:6

328:7 332:11

333:10 360:1,11

360:17 361:4

367:16 371:14

380:9 381:12,22

382:6,11 385:12

388:4,10,17

390:15 391:11

timeframe 58:12

81:15 83:16

times 12:20,22 13:1

30:7,8 95:5 127:1

142:18,20,21,22

143:1 144:20

182:14 206:6,6

333:14 373:4

Timing 229:13

titled 57:2 374:22

today 5:10 7:21

14:6,18 15:10

16:9 19:14 20:8

22:18 26:19 76:5

78:13,17 83:18,20

85:1 98:5 121:13

126:9 127:3

196:16,18 206:7

210:18 259:10

260:3 276:4

284:22 285:8

328:2,4 332:14

360:12 368:15

371:9 377:9 386:3

386:17

today's 314:19,22

token 332:19

told 304:9

toll 316:11

tomorrow 5:10

20:2,8 23:21

81:15 83:11

258:19 380:10,16

380:17 381:2,16

382:3 383:1,16

384:8,11 385:5,14

385:22 386:2,11

386:14 387:1,5,7

387:21 390:13

392:8,16

Tompos 2:7 3:11

6:13,13 16:5,5

34:1,1 35:15,15

44:2,2 46:17,17

53:16 55:15 57:11

68:19,19 73:6,6

94:14,14 130:9

218:13,14 262:6,6

263:11,11,20

265:12 266:9

282:6,6,19 283:18

283:20 302:18,18

320:14 330:17,17

331:1,1,8 376:18

376:19

tool 370:20

tools 370:16

topic 108:8 112:20

124:20 125:21

162:15 165:6

197:22 373:17

375:4,6

topics 24:5 125:4

196:3 199:3,4,10

246:21 256:20,22

342:15 386:13

tossed 355:15,20

total 11:18 64:19

142:4,7,8,15

143:9,10,19,22

146:7,13 156:22

157:2,7 160:7

178:22 179:2,9

182:13 183:16,17

222:9 226:4 250:2

280:10 294:5,11

301:12 376:4

383:6

totally 176:14

300:13 389:11

touched 103:20

tough 72:11 163:21

244:21

track 33:7

trade 36:7 141:15

151:16 157:7,11

160:4 164:13

169:11 182:21

281:5

traded 188:1

tradeoff 35:5 151:8

158:2 162:2

164:12 316:13

349:5

tradeoffs 99:13

104:1 162:19

171:7 186:1 189:7

235:14

trading 33:21

187:19 188:10

traditional 216:13

233:8

traditionally 95:4

trailer 265:6

transaction 349:12

transactions 317:5

transcript 12:18

22:12

transcripts 12:15

12:15

transforming 67:7

translated 31:11

transparent 15:2

travel 69:22

treat 357:15

treating 11:9

treats 158:18

tree 206:17

trepidation 316:19

tricky 170:15

tried 159:6 167:7,8

191:5,5

triplewide 296:15

troubleshooting

391:12

true 72:20 146:17

267:16,16

trumpeted 84:15

truncated 160:9

truss 49:9,11 50:9

60:7 80:4 204:7

266:3 271:21
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214:22 223:14

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turnaround 18:16

turning 37:2

tweak 221:19

239:17

Twenty 79:18

Twenty-seven

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twist 317:12

two 5:9 22:10 24:3

25:20,21 28:19

48:16 59:18 64:22

69:22 74:21 75:1

79:5 91:13 102:5

108:1,3 118:14

125:4 129:8,12

130:10 134:15

136:18 156:9

172:5 175:12

178:21 190:14

209:19 216:6

224:13,16 227:18

236:7 237:17

254:5 256:11

261:21 264:7

271:2 278:18

285:14 295:20

328:22 338:16

342:11 343:6,16

362:14 375:9

383:8 384:14,15

385:5

two-thirds 162:17

358:4

two-way 268:3

twofold 136:16

type 18:18 39:19

41:3 79:9 97:2

108:2 113:7

126:21 144:12

155:19 166:2

276:13 291:21

346:11 374:8

types 49:14 88:10

113:16 114:1,17

122:20 131:6

248:5 255:5,7

311:14 366:15

368:6 372:21,22

373:1,11

typical 49:22 50:2

50:3 59:7 61:8

136:8 233:12,21

258:21 271:14

287:3,4 374:8

typically 47:4,9

59:8 66:3 210:22

260:7 262:9 268:8

269:21 280:6

344:16 349:18

typo 31:19

typos 12:16

U

U 36:13,17,18 37:4

46:8 64:14 76:13

76:17 77:15 135:1

136:1 142:9 143:5

143:6,8,22 145:5

146:5,13 147:11

147:19 148:7,10

149:15 153:9

154:10 155:20

156:1 368:19

375:2,6,7 383:7

U-factor 31:10,10

57:6,15,18 58:1

72:3,4 80:2 138:9

140:8,19,20 141:1

141:9,22 142:20

142:21,22 143:1

144:17,20 146:8

151:7

U-factors 31:3

53:13 65:7 80:8

138:14 140:12

142:16,18 143:6

143:18 152:9

U-favor 140:12

U-value 33:20 43:2

53:18,21 57:20

63:18 72:21 73:15

75:10,10 76:5

77:17 110:21

201:5 263:6 275:6

U-values 53:7,8

54:3,10,15 58:6

64:3,17,19 75:1

172:11 260:1,8,15

261:5 374:15

U.S 1:1 2:12,14,15

2:17,19 3:7,15,21

UA 142:4,7,8,14,15

142:17 143:4,9,10

143:12,19 144:1

144:21 145:1,1,20

147:11 148:14,16

149:9,20 154:19

155:19 156:19,22

157:2,7,10 160:7

173:8 178:22

179:2,9 181:1,9

182:14 183:11,16

245:17 246:2

264:19 369:6,14

370:2,10 383:6

Uh-hum 63:20

166:21 179:2

ultimate 214:21

ultimately 204:4

216:10 225:7

233:16 249:3

299:8,9 305:6

351:14

unable 94:4

unaffected 125:12

uncertainty 348:1

unclear 204:22

underlying 54:14

131:21 373:9

underneath 47:8

59:12 136:4

underscore 317:8

underside 280:5

understand 46:7

62:6 101:6 117:11

123:2 129:6

135:10 163:7

199:2 204:11,12

220:9 223:13

225:4 236:9

248:19 249:20

253:12 270:21

280:2 300:18

305:17 306:2,20

307:22 310:2

338:14,16 340:13

373:8 385:20

390:1

understanding

100:5 122:17,22

165:21 170:18

171:19 181:21

182:7 199:1

215:16 234:19

235:13 245:8

258:12 259:15

306:14 307:15

338:9 366:9 367:1

understood 70:18

215:1

unexpurgated 23:7

unfortunately

127:10 214:12

uniform 69:6

unique 88:9,11,11

364:22

unit 52:10,11 62:20

298:5

United 240:5

units 61:2 78:20

261:14

universe 185:9

383:15

University 2:2 6:3

unknowns 113:22

unlimited 148:18

unreasonable

359:13

unregulated 325:3

unusual 339:13

Uo 18:22 33:16

40:9 42:11 57:2

66:11 77:13 78:4

86:19 87:8 106:14

146:4 150:1,11

153:18 295:1

367:12,18 368:10

368:18 369:12,15

369:18 370:9

371:22 372:7

up-to-speed 170:20

update 93:8 367:16

389:6

updated 389:12

upfront 148:15

upgrade 287:21

318:12

upgrades 338:13

upper 208:5 247:6

357:7

upscale 242:15

upside 149:12

318:14 320:9

upwards 175:18
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91:22 92:1 102:3

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136:19 142:13

144:5,7,13 145:9

155:19 158:1

162:6 175:19

178:20 181:9

183:14 189:2,6

197:10 222:22

223:5,5 251:6

257:7 259:16

279:16 286:4

291:5 296:9,11

312:1 315:13

317:22 323:4

335:10 338:7

340:12 342:2

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354:13,17 359:5

371:18 378:11

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useful 17:1 18:4

87:3 125:18

153:15 205:14

266:13 269:8

304:2 378:18

382:11,17 389:3

uses 57:18 370:22

usual 61:2

usually 274:11

345:11 348:13

351:20

utilities 338:3

356:20

utility 53:4 166:4

305:2,15

V

vacation 14:10

Vaidyanathan 2:19

7:4,5 170:17

223:11,12 225:3

249:18,19 250:9

329:19,20 330:9

387:6

valuable 284:10

value 40:9 48:10

57:13 66:11 77:7

91:9 95:12 101:14

104:7,14 105:12

121:14 140:14,15

211:18 234:7,8

264:9 284:12

291:6,6,10,10

295:1 296:12

297:12,16 304:2,2

308:1,19 309:14

310:19,19 314:19

323:7 332:10,17

332:22 333:12

338:20 340:3

344:20 345:2

368:19 375:6

381:6 385:16

valued 128:4

values 31:12 33:21

43:2 64:11,13

86:22 105:16

106:14 110:20

111:21 141:7

144:16 147:12

240:17 246:2

264:19 282:16,18

287:5 293:2

367:18 368:3,11

368:18 377:2,3

383:13

valuing 340:1

variable 122:15,16

222:5

variables 120:4,6,9

124:3 366:14

variation 260:12

varies 175:17

variety 135:3

136:13 169:20

189:2 245:2

various 144:7

176:5 259:16

273:11 319:12

322:4 334:13

363:16 366:1

vary 113:18

varying 133:18

140:21

vast 176:20

vein 384:13

ventilation 197:15

verged 226:19

verification 197:22

206:11

verify 260:10

Vermont 2:6 8:15

129:3,17 161:10

202:7 216:3,9

229:6 233:5

264:22 266:7

275:4 298:13

305:3 329:3

387:11

version 22:14 23:7

31:17 135:6 160:9

179:22 180:1

185:20,22 187:8

207:5 335:21

361:12,18

versions 79:4

161:18

versus 65:20

104:10 113:10

200:19 231:2

246:14 309:7

363:21,22 378:20

381:6

vertical 91:19

videos 273:11,12

view 111:7 171:14

207:16,17 208:4,8

227:3 253:2

295:20 315:9

316:3

views 194:13

208:13

vinyl 308:11

violating 379:3

violation 167:10

Virginia 2:3

void 66:22

voids 274:7 277:8

volume 379:9

380:3

voluntary 166:15

volunteer 366:4

volunteered 257:20

259:11 366:5

vote 41:18 354:11

354:15

votes 229:15

voting 7:21 8:3,8

8:10,13,15,18

268:20

VTE 358:14

W

Wade 2:7 8:17,17

9:11

wait 117:18 312:17

312:19

waiting 106:21

230:10 232:11

walk 25:19 27:18

93:15 133:16

135:4 137:5,14

193:9,18

walked 134:18

Walker 2:20 4:2

89:20,21 93:20

94:13,22 96:13

101:9,18 102:15

103:15 106:6,10

106:22 107:4

109:11 110:14

112:1 115:2

121:12 131:16,19

344:18,19 346:3

373:20,21 374:18

walking 118:22

wall 36:20 46:6,11

53:2,9 61:7,9

79:18,18 140:15

141:4 146:22

155:3,4 163:15

187:20 269:11

271:20 281:15,18

319:7 357:4 375:1

375:7,9 376:9

walls 31:3 59:21

60:1,8 69:11

70:12 74:10 139:8

141:5,7 142:20

144:9,13 148:1,22

268:12

want 7:16 9:21

10:9 11:18 20:9

20:12 22:14 31:16

32:20 34:13 35:20

37:5 42:2,4 49:14

51:10,12,13 58:19

61:21 67:15 70:4

73:11,16 75:13

84:21 85:10 98:20

100:11 102:12,19

116:4,18,20

123:14 127:16

128:2,6,8,15

130:20 135:13

139:10 140:7

141:4 150:8 153:7

154:15 163:20

167:8 178:10

181:15 191:1,16

192:17 194:1

198:11,20 204:10

204:12,19 206:19

207:6 213:8

217:16 220:12,21

229:14,18 232:1

234:12,22 238:12

243:17 244:18

245:3 246:17

247:1 254:1

265:22 268:18

271:11 273:22

280:18 285:22

290:20 292:17
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373:6 375:14

379:5 380:8,11

383:3 386:6,14

388:6 390:18

392:8,11

wanted 10:21 22:7

27:17 69:15 83:12

89:11 134:11

139:6,7 147:8

150:14 188:14

193:5 195:3

207:11 236:15

257:14 272:9

284:8 333:4 334:5

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wants 56:1 168:20

241:10 242:21

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war 348:4

Washington 1:10

2:2 6:3 171:8

wasn't 63:2 213:15

305:17 314:4

376:6

waste 116:5

watched 273:10

water 31:4 98:16

161:5 202:15

204:20,21 205:22

238:17,20 291:16

323:12

water-heating

185:12

way 9:21 21:18

38:10 42:13 47:7

48:6 57:10 61:14

66:10,13,14 67:18

67:20 68:16 80:1

80:14 90:12 92:21

117:11 119:13

120:13 134:17,21

134:21 138:13

141:16 142:15

143:9 147:17

155:18 157:12

158:17 159:18,22

159:22 164:4

165:11 170:1

171:4 173:17

187:17 191:1,18

193:17 194:2

197:19 205:12,13

210:22 228:11

232:10 235:1,5,6

241:4 246:6

247:11 250:13

251:21 253:14

260:5 263:1 268:6

269:8 274:5

283:21 289:12,19

302:14 306:20

309:8,9,12 310:16

312:16 316:12

318:6 319:10

322:13 337:2,3

340:16 351:12

353:21 357:11

359:17 367:13

370:18,22 371:10

375:20 379:8

380:18

ways 134:16 136:13

137:16,16 167:12

167:13 194:14

203:15 242:1

268:16 308:21

336:1 376:7

we'll 203:6 206:16

233:1 235:12,22

236:6 244:15

249:5 254:7,9,10

254:17 255:10

256:22 257:21

292:9 293:5 294:2

294:16 299:21

308:4 316:14

321:6,12,13

328:13 344:2

351:4,16 358:12

360:1 362:1,19

363:7 365:14

367:1,4 369:2

376:11 381:13

386:10 387:8,20

388:22 389:6,8

390:13,14 392:7

we're 191:22

196:22 199:17,18

199:19 200:5,6

202:1,11 205:11

207:8,9 209:11

210:11,11,17

211:12 214:22

215:8,12 219:21

221:8,10 223:7

224:21 228:13,14

228:15,19,21

230:18 231:21

232:3 233:5 234:6

235:14 236:21

238:14 239:19

240:21 241:2

243:14 244:13

246:10,11,12,16

246:20 247:2

248:14,18 249:1,6

254:20 255:5,16

256:16 257:6,7,12

259:18 265:1

267:5 268:20

271:9 272:8,8

275:13,18 276:14

278:8,9 280:16

281:7,16 282:20

282:22 284:3,4,18

284:19 285:3,7,9

286:10 290:1,7,21

290:22 292:19

293:18,19 296:3,4

297:10 299:3,4,5

300:14 301:4,8

303:1 305:20,21

306:21 307:11,16

311:7 312:20

316:2,8,12 320:15

320:19 321:16

322:1,4,22 325:6

327:20 328:2,4

329:12 333:16

335:2 341:18

343:10,20 347:9

347:10,13 351:13

352:3 354:12,22

355:18 357:8

358:1,6,11 359:19

360:4,18 365:20

365:21 367:22

368:1,1,22 369:13

369:18,19,19,20

373:2 376:16

381:4,5,19 384:2

385:14 386:9

387:15 389:4,5

we've 9:8 193:13

196:17 238:8

239:9 240:12

244:18 246:20

256:11 265:6

266:4 268:7 270:1

271:7 292:22

293:15 301:13

302:20,21 305:6

310:1 318:10

320:5 324:19

336:10 367:6

370:17 377:12

388:3 389:19

weaken 159:12

162:9

weaker 148:1,1

185:22

weakest 186:10

weakness 147:19

weaknesses 148:14

148:16

webinar 25:14

26:21 230:18

232:10 386:5

website 22:8

335:16 337:12

week 15:4 25:21

85:22 89:17 126:8

357:6 384:15

weekend 385:6

weeks 25:22 91:13

190:12 235:12

236:1 259:19

366:7 384:14,15

385:5 388:12

389:2

weigh 103:10,11

104:9 260:1

weigh-in 58:20

weighed 107:13

weighing 247:10

weight 176:15

262:14

weighted 345:15

368:4

weighting 245:8

368:17 370:22

383:19

Weiss 2:8 3:10 6:7

6:7 15:16,16

51:18,21 52:16,20

71:7 85:15,19

88:6 93:15 94:12

105:20,20 106:20

109:5 124:21

125:1 126:4

127:16 170:4

194:7,11 213:22

214:12 225:18

229:3,9,21 236:7

242:10 250:1

259:1 270:7

293:16,16 298:2,2

303:8,8 316:17

328:22 330:5,19

347:3 355:5 356:4
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 439

360:21 361:9,20

377:8 378:2

379:12 386:16

welcome 3:2 5:8

10:3 22:15 25:8

well-founded

235:19

went 14:4 74:9

132:14,14 165:4

191:14,15 268:18

283:7 328:17

335:8 368:20

392:19

weren't 162:4

232:4 305:7

whatnot 12:17

28:14

wheels 320:20

wholesale 268:7

269:15,21

Wi-Fi 13:3

wide 47:5 270:15

widely 176:7

385:11

width 77:1

willing 269:4

willingness 369:8

window 31:3 39:21

40:7,10 41:2,6,7

41:10,14 43:2

50:4 79:9,16

140:16 141:11,19

144:18 145:9

152:13 154:3,7

177:6 182:17,21

188:1 258:21

268:6

window-to-wall

258:17

windows 35:20

138:9 141:15,15

143:2 144:9,13

148:21 151:14

152:2 157:22

160:4 164:18

276:14 308:11

winds 170:9

winners 121:6

122:3,10 123:1

125:11 126:6

Wisconsin 168:5,8

168:19

wishy-washy 388:8

withdraw 364:17

wonder 213:15

wonderful 24:1

392:12

wondering 123:4

131:10 205:11

355:16

word 23:5 68:8

102:3 218:17

315:13,14 339:12

374:3

words 232:5 248:15

wordsmith 217:16

wordsmithing

228:5

work 5:17 6:17

10:5 14:15 37:7

47:7 56:15 60:19

77:22 89:21 98:11

102:6 135:8 138:4

138:21 153:12

156:8 164:4 177:3

179:15 232:12

237:5 241:3

243:17 248:3

251:15,16 253:17

254:3,3 255:1

257:22 266:7

268:16 313:17

360:9 367:4

373:13 382:6

383:1

workable 128:12

worked 18:4

144:12 154:5

177:1 195:20

213:16 270:1

working 1:3 3:8 5:7

5:20 13:17 18:19

20:7 23:17 24:8

24:20 27:8 28:9

56:2 59:4 90:3

109:1 112:21

121:19 122:5

222:14 244:20

293:19 305:2

312:21 360:7

367:7 390:19

391:20 392:4

workload 370:8

works 77:20

133:17 135:10

143:10 201:2

243:6 246:5 266:6

286:11

world 95:5 373:5,5

worried 313:14

worry 36:6 362:9

363:6,7 388:16

worse 186:15

187:16,18

worst-case 40:12

worth 43:22 104:5

181:4 285:14

312:15 313:2

worthwhile 384:21

wouldn't 13:15

132:18 139:8

176:10 184:16

212:9 263:7

312:17 359:12

381:22 383:11

wow 209:1

wrap 79:19 300:17

wrap-up 23:20

wrapped 302:5

315:12 372:9

write 27:21 328:14

written 174:5

358:2

wrong 28:16,17

42:20 122:13

142:10 145:8

169:3 176:13

191:5 305:21

316:20 371:3

372:19 373:15

380:22 381:17

X

X 114:21 116:12,12

116:13 239:20

Y

Y 116:14 240:1

yardstick 205:8

year 52:11 112:5

219:13 291:7,8

305:13,14 309:20

314:18 317:3

325:1,4,6,9

years 40:18 66:15

95:7 101:20

110:16,17 132:9

168:6 184:16

218:22,22,22

219:10 268:6

270:1 275:2 277:2

286:20,21 287:1

291:17,18 295:9,9

296:2,5,16 297:5

297:11,13,19

298:17 299:2

304:12,13 306:6

308:9,18 310:18

311:18 312:11,17

312:19 314:16,17

317:11 318:7

319:8,11,15,16,19

320:4,8 322:14,22

323:2 324:2

332:12 333:9,11

336:15,15 338:5

339:9 343:8,9,12

352:8 360:12,17

363:15,20 369:11

yellow 93:3

yesterday 12:15

yield 271:17,22

Z

zero 186:13 353:12

362:6

zone 19:18 42:22

55:13,13 56:6

61:5,5,8 63:2

79:14 113:18

139:7 141:17

187:11 196:10

324:15 368:19

376:15

zones 29:14,17 47:2

48:1 55:6,6 57:4

131:5 136:9,11

196:13 261:13

367:21 368:13

371:16 383:21

0

0.034 262:9

0.088 375:2,7

031 77:3

032 79:16

033 76:19

034 53:18,21 54:6

57:6,8 77:5,6,15

77:17

040 76:19

042 76:17

1

1 54:20 61:4,5

139:7 155:6 227:1

274:11,16 282:22

283:6,10,14,15,16

324:17 325:4

1-A 55:3

1-C 131:7

1.2 268:11

1:00 23:9,10

1:15 191:11

1:22 191:15

10 25:22 26:3 36:4

38:10,22 42:3

43:12,13,22 44:9

44:12,13,16,21,22

82:13 110:16

134:9 138:21

148:6 257:10

284:1 332:12

339:20 341:3

360:16 385:3

392:6

10-20 311:18
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 440

10-inch 265:2

267:6

10-year 302:22

10:59 132:14

100 155:6 159:18

178:15 186:4,14

186:14,16 319:7

319:19

100-percent 149:1

100,000 65:13

68:15

1000 1:10

10th 385:16 386:3

389:1

11 3:5 50:4 61:9,9

192:7 324:2 358:8

11:18 132:15

111 38:15

12 33:3,15 34:4

35:3,7,19,20 36:4

38:3,11,16,22

42:3 43:12,13,17

43:18,20 44:14,16

44:18 50:4 60:15

82:13 148:6 163:9

163:10,12 211:13

262:13 291:17

12:00 23:9

12:13 191:14

121 74:10

13 35:8 61:6 138:21

13'6 70:1 263:21

264:22

130 39:8

133 4:4

134 4:6

13423 341:8

14 3:8,9 36:4 38:11

38:22 39:6,7,21

42:3,21 43:12,13

43:18,18,21 44:14

44:16,22 47:5

61:8 82:13 148:6

149:7

14'x66 29:1 38:14

38:18,19 39:8

14-inch 265:2

15 3:10 29:13,14

30:12 36:2 145:11

145:15 158:19,22

159:2,3,7,17,19

163:12,19 164:9

164:10 165:4

247:8 268:12

296:4,15 304:12

305:13,14 328:13

359:10 380:6

15-minute 130:19

16 3:10,11 76:15

149:7

164-inch 76:16

17 3:11,12,12

18 3:13,13 60:16

164:6,7,10

18.7 47:20

19 3:14,14 47:19

346:15,19 353:21

192 4:11

1992 358:22 361:8

371:11

1998 361:6

1A 61:6 375:1

2

2 61:4 159:9 227:1

262:13 267:8,10

267:11,14 281:15

281:17 282:22

2,000 143:13,14

2,600 296:14

2.2 269:22

2:00 23:10,12,12

20 36:2 110:17

111:5,9 138:20

145:16,17 158:21

296:5

200 319:19

2006 29:20 159:15

185:21 186:4,5,11

186:14,17 254:17

2008 310:11

2009 29:20 131:9

132:3 160:15

162:5 187:16,19

277:17 335:20

2010 356:7

2012 29:20 160:16

187:17 190:10

334:17,18 335:21

2013 105:14

2014 1:7 127:7

2015 4:6 23:3,11

29:21 65:6 78:13

78:18,19 79:3,14

83:4 96:8 97:7,12

98:3 133:8 135:6

153:6 160:16

184:15 187:4,18

190:11 207:21

212:12,17 213:8

213:14,16 214:1,2

214:10 216:5,11

217:18 219:6

220:5,13,21

222:20 223:10,16

223:20 224:6,12

224:17 225:5,13

225:22 226:12,14

226:21 228:14

233:22 236:22

237:6 242:6

244:22 245:6

246:13 247:6,20

248:18 249:11,16

250:16 251:3,10

252:9,13 253:7,15

254:3,8,17 255:1

255:8 258:13

261:9,15 264:19

275:18 276:6

326:9 334:19

374:4,22 391:9

21 1:7 268:12

22 63:9,11

22nd 385:19

23 3:15,16,17 287:4

23rd 385:19

24 376:9

25 3:19 154:4

359:10 363:10

26 4:1

28'x56 29:1

2x10 58:10 69:17

76:19

2x6 47:5 53:21 59:8

60:1 65:18,20,22

68:5 73:2 76:15

2x8 65:17,20 69:17

72:12 76:18

3

3 55:13 159:9

273:16 275:14

282:22 283:13,15

283:15

3:29 328:17

3:45 23:13

3:57 328:18

30 54:9 55:12 57:16

61:7,7,22 62:2,6

62:10,11,14,15

63:1,2 95:7

218:22 219:10,12

286:20 291:17

295:9 296:2 297:5

299:2 304:13

312:11,17 314:16

317:2,11 318:7

319:16,22 320:4,8

333:9 343:9,11

30-year 299:4

315:2 321:21

323:14,16 336:3

30th 291:7 314:18

34 288:6

34-inch 265:6

344 149:20,22

352 145:3

365 4:15

38 54:9 62:10,11

79:17,21

380 4:17

392 4:19

4

4 264:1 281:9 297:4

4.5 60:10

4:30 23:18

436A 341:3

49 79:17

5

5 138:20 141:17

154:7 218:22

302:22 346:5

353:8,9,10 354:1

359:10,11

5.5 47:18 60:9,17

5.5-inch 69:12

5:00 23:18 392:19

50 69:2 218:22

56 144:22

6

6 3:2 267:15 281:15

281:17 346:5

60 16:14

600 29:22 42:1

61 69:7

6A 63:2

7

7 57:4 79:14 286:20

286:21 295:8

351:22 358:8,19

7-foot 271:20

7-inch 47:16

7-year 296:9,11

7.5 266:4

74 370:14

76 355:10

78 161:15 168:16

78-percent-effici...

162:1

7th 291:6

8

8 33:14,15 35:3,3,9

35:19 36:4 37:16

39:4 40:13 42:5

43:12,13,15,22

44:3 55:13 57:5

79:14 141:17

145:18,19 149:6

267:8,10,11

8.5 266:4

80 175:18

800-pound 96:6

8E-089 1:10
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 

441

Manufactured Housing Working Group

US DOE

08-21-14

Washington, DC