To: File 

From: Michael Jensen, DOE GC-71 

Date: September 23, 2010 

Re: Ex parte discussion with RADCO, Inc. 

On September 22, 2010, Michael Jensen (GC-71), Bob Lucas (PNL), and Dave Conover (PNL) 

spoke with Mike Zieman of RADCO, Inc., on RADCO’s role as both a production inspection 

primary inspection agency (IPIA) and as a design approval primary inspection agency (DAPIA) 

under the U.S. Department of Housing and Urban Development (HUD) manufactured housing 

program. 

Mr. Zieman mentioned that RADCO rarely performs site inspections of manufactured homes. 

He noted that, in many states, state or local government regulates the installation of 

manufactured homes and other work performed on site; HUD is required by current law and 

soon will be regulating the installation of homes in states without these codes (“default states”). 

Mr. Zieman also recommended that it would be most efficient for DOE use the HUD 

enforcement system to avoid having dual enforcement programs with multiple inspection 

agencies operating in plants. Mr. Zieman explained that IPIAs and DAPIAs currently are 

monitored by HUD and HUD’s monitoring contractor: The Institute for Building Technology 

and Safety (IBTS). He noted that DAPIAs and IPIAs are required to send IBTS: (1) copies of all 

approved manufactured home designs; (2) reports certifying new manufactured housing plants or 

plants that have undergone significant changes; and (3) monthly manufactured housing 

production reports. Moreover, he explained that IBTS performs annual audits of all DAPIAs and 

IPIAs and that the reports are shared with HUD. 

Mr. Zieman also provided a general overview of how the DAPIA and IPIA approval processes 

works. On the design side, he explained that the DAPIA will issue a design deviation report to 

the manufacturer upon any finding of noncompliance with HUD standards (MHCSS) or 

regulations. The DAPIA will perform a second review after the design is corrected. This 

process continues until the design is finally accepted as conforming. A copy of the conforming 

design is forwarded to IBTS. On the production side, Mr. Zieman explained that any instance of 

noncompliance is listed in the IPIA inspection report along with the root cause of the problem, 

whether the problem has been corrected, and the action taken to correct the problem. If the 

problem is not corrected, he noted that IPIAs must “red-tag” the manufactured home, preventing 

the manufacturer from attaching a HUD certification label to the home. 

He noted that genuine disagreements among manufacturers, DAPIAs, and IPIAs over whether a 

manufacturer has adequately complied with HUD standards or regulations occur very 

infrequently, but that these rare occurrences involve HUD in the resolution of the disagreement. 

Mr. Zieman also mentioned that HUD may involve itself in instances where a manufacturer 

disagrees with an IBTS audit. 

Mr. Zieman was uncertain about the extent to which manufacturers use 2x4 versus 2x6 

construction. Addressing issues associated with the number of climate zones, he noted that, 

during periods of slow sales, manufacturers often know the eventual destination of the home and 
thus can design and build the home for a specific zone. However, if the eight IECC zones are 

used in the DOE standards, manufactured home manufacturers can supply a market 

encompassing 2, 3, or even 4 IECC climate zones. When business picks up, manufacturers 

would be forced to design and build the house to the most restrictive and therefore the most 

costly zone, thus adding needless cost to the consumer. 

Finally, Mr. Zieman addressed the complexities of basing the proposed DOE energy efficiency 

standards on lifecycle costs versus the initial purchase price of the home, and that DOE should 

consider a compromise. He noted that initial purchase price is an important consideration 

because if the consumer cannot afford to buy the house, the lifecycle cost is of little importance. 

End of conversation.