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 THE MANUFACTURED HOUSING WORKING GROUP MEETING

 August 5, 2014

 Department of Energy

 Forrestal Building

 1000 Independence Avenue, SW

 Washington, DC 20585

 Reported by: Natalia Thomas,

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1 A P P E A R A N C E S

2 John Cymbalsky

U.S. Department of Energy

3

Javier Ramirez

4 Federal Mediation and Conciliation Service

5 Robert Luter

Lippert Components

6

Michael Lubliner

7

Peter Schneider

8 Efficiency Vermont

9 Eileen Hoffman

10 Mark Weiss

11 Manufactured Housing Association for

Regulatory Reform

12

Ishbel Dickens

13 National Manufactured Home Owners

Association

14

Manuel Santana

15 Cavco Industries, Inc.

16 David Tompos

NTA

17

Lowell Ungar, Ph.D.

18

Eric Lacey

19

Rob Roy

20 Natural Resources Defense Council

21 Joseph Hagerman

U.S. Department of Energy

22
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1 A P P E A R A N C E S

2 Mike Jensen

3 Keith Dennis

4 Lois Starkey

5 Mark Ezzo

6 Emanuel Levy

7 Stacey Epperson

Next Step

8

Bert Kessler

9

10

11

12

13

14

15

16

17

18

19

20

21

22
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1 P R O C E E D I N G S

2 MODERATOR HOFFMAN: Okay, we're going to

3 get started and before we officially begin, we

4 just want to have the people in the audience to

5 just go up to the microphone and say you are,

6 where you're from. Thank you.

7 MS. FREIMUTH: Janet Freimuth, I'm from

8 the Department of Energy's office of conflict

9 prevention and resolution.

10 MODERATOR HOFFMAN: Thank you.

11 MR. SURRENA: I'm Don Surrena, I'm with

12 the the National Association of Home Builders.

13 I'm with the Codes and Standards Department. I'm

14 a program manager in energy efficiency.

15 MR. MARTIN: I'm James Martin, I'm with

16 HUDs Office of Manufacturing Housing Programs.

17 MR. MENDLIN: Rick Mendlin, Office of

18 Manufactured Housing Programs at HUD.

19 MODERATOR HOFFMAN: All right, thank

20 you. Okay, we're formally back after lunch and a

21 couple of announcements I think before we get

22 started from Joe.
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1 MR. HAGERMAN: Yes, so I just -- this is

2 Joe Hagerman. I wanted to over lunch just

3 reconfirm with the national labs the analysis

4 they're doing since a lot of questions have come

5 up on it, so I did that. And I think it's been

6 consistent with what it is that everybody's

7 expecting, so what they're going to show is single

8 wide -- single section, sorry, unit and a double

9 section unit modeled in all the IECC climate zones

10 for the various IECC versions from 2015, 2012,

11 2009, 2006, and so forth.

12 And then they've also modeled a unit

13 based off of the manufactured housing code, just

14 straight. And then the things we're going to show

15 you are the annual energy results from that and

16 they're also going to give you clear definition on

17 things like the finistration U factor, the ceiling

18 R value, the wall R value, the floor R value and

19 the glazing solar heat gain co-efficent as well.

20 So if you know of some other levels or

21 any other variables that you'd like them to show

22 in that analysis, then let me know and, you know,
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1 we can ask them to add that, and in hopes that

2 once I -- in hopes that they can, you know,

3 quickly turn that around and not delay getting us

4 the whole package.

5 MR. POTTS: Richard Potts. Do you want

6 that information now or just offline as far as the

7 variables and whenever? Maybe fuel types, you

8 know, just throw in samplings of different fuel

9 different fuel types; whether it's gas, obviously

10 electric, propone and maybe that's all that comes

11 to mind.

12 MR. HAGERMAN: So fuel types. We'll ask

13 for that, anything else?

14 MR. UNGAR: This is Lowell. I don't

15 have a specific request but I'll just note that it

16 sounds like it's all 2005 1590CC or lower, of

17 course, when you can also consider improvements to

18 it, so we might just as we go along consider if

19 there's at least, I don't know that there's a

20 broad standard above it that we would consider as

21 much as if there may be specific improvements that

22 would make sense to model as well.
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1 MR. HAGERMAN: Right. I was hoping that

2 somebody might -- a manufacturer might say, well,

3 you know, we use the following U factor and wall,

4 our value and ceiling our value, and we can go

5 ahead and model that pretty easily. So if there's

6 somebody out there that knows what they ship and

7 it's not, you know, it's a variant of any of those

8 things, let us know and we can do that analysis as

9 well.

10 MR. SCHNEIDER: Yeah, and I -- Peter

11 Schneider, certainly mechanical option quickly a

12 duct with many split to replace the traditionally

13 ducted system combined with heat pump water

14 heater, just make sure that options like that

15 again improving upon 2005 and looking at value

16 engineering and ways to significantly improve

17 efficiency through very low cost measures.

18 MODERATOR HOFFMAN: Let's see, Javier,

19 you want to pave the way?

20 MR. RAMIREZ: Yeah, all right, so what

21 we want to try to do is, first of all, Eileen and

22 I with the assistance of a few folks that were
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1 eating while we're working on this --

2 MODERATOR HOFFMAN: Took advantage of

3 Subway to come up here.

4 MR. RAMIREZ: Yeah, so we try to group

5 these into the four larger groups that we had

6 identified earlier and we want to see if you agree

7 with how we've grouped them. So we passed them

8 out so that you would have them in front of you.

9 So what we could do is we could go one at a time.

10 So looking at the envelope of building, do these

11 six and the subparts of them belong here or do any

12 of these belong anywhere else?

13 MR. LUTER: I might suggest the addition

14 of one -- Robert Luter, sorry, infiltration.

15 MODERATOR HOFFMAN: And where would it

16 go, is it not just a number?

17 MR. LUTER: As 1.7. There's a -- my

18 rational is there's a certain amount of

19 infiltration inherent with the fenestration with

20 windows and doors.

21 MR. RAMIREZ: Okay.

22 MR. LUTER: And it will need to be
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1 considered.

2 MR. SCHNEIDER: Yeah, this is Peter

3 Schneider. I think there's 1.3 and I don't know

4 what that includes, but duct less would be

5 something to evaluate and what it would take to

6 get to duct with and then with regards to windows,

7 I would say single and double-hung windows are

8 inherently leaky, so what it would take to go to

9 casement and awnings with compression gasgeting

10 that is far better from both a performance

11 standpoint day one, but also durability long-run.

12 MR. LUTER: Robert Luter. Those are

13 currently prohibited by the HUD Code, there's an

14 egress issue. Crank operated windows are not

15 allowed.

16 MR. SCHNEIDER: That's why I was

17 throwing it out there.

18 MR. RAMIREZ: Okay, so do I -- is there

19 anything that needs to be changed on here?

20 MR. LUTER: For the record, I don't

21 disagree with your -- your position that a

22 compression sealed window is superior.
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1 MR. SCHNEIDER: Yeah, great. So I don't

2 think 1.4 glazing captures type of window.

3 MR. HAGERMAN: This is Joe Hagerman.

4 Also, I think I heard you say 1.3 should read duct

5 and ductless; is that right? So ductless --

6 MR. SCHNEIDER: Right.

7 MR. HAGERMAN: -- typically reminds --

8 you're typically talking about a -- like a heat

9 pump, a ductless heat pump --

10 MR. SCHNEIDER: Right.

11 MR. HAGERMAN: -- and then ducts are

12 thinking about, you know, the actual ducts, not

13 the mechanical system?

14 MR. SCHNEIDER: That's right,

15 absolutely, yeah, so there could be two different,

16 you know, categories together cause duct comes

17 inherent with all sorts of issues, duct with -- is

18 another strategy all together that other

19 requirement are -- a more comprehensive approach

20 is required to make that work.

21 MR. HAGERMAN: Right, so I'm just trying

22 to advocate that maybe we leave duct in 1.3 and
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1 then put ductless equipment in section 2.

2 MR. SCHNEIDER: That sounds good.

3 MR. RAMIREZ: All right. So -- okay, so

4 how does this look?

5 MR. LUTER: I might suggest infiltration

6 be changed to air leakage because I think that's

7 the actual language that's -- that's used.

8 MODERATOR HOFFMAN: After I corrected

9 spelling.

10 MR. LUTER: Yes.

11 MODERATOR HOFFMAN: Okay.

12 MR. RAMIREZ: Okay. Does this look --

13 does this look good? Yeah.

14 MR. POTTS: Not to split hairs, Richard

15 Potts. Looking at thinking about ducts, to me

16 ducts aren't really an architectural detail that

17 might -- I mean, it's a component of the

18 mechanical system. I don't know if everyone would

19 agree with me, but that might be moved into

20 mechanical as well.

21 MODERATOR HOFFMAN: Actually, I had

22 asked that question to a couple of folks that were
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1 in the room and the answer to that was, it depends

2 on what you're talking about with the ducts is

3 what was the answer. So should we put it in both?

4 Should we leave it here and then put it into the

5 other one as well?

6 MR. SCHNEIDER: I'd advocate for both.

7 There've been some great studies Michael could

8 speak to, you know, where these ducts were brought

9 inside the envelope, so they're certainly a part

10 of the thermal envelope right now except in the

11 rare occasion where there was a demonstration

12 project that brought them into a chase within the

13 thermal envelope, so I think it -- so they do

14 belong in both places.

15 MR. RAMIREZ: So are we good with 1

16 then? I'm sorry, Emanuel.

17 MR. LEVY: Emanuel. Don't want to split

18 hairs, but 1 and 1.2 (inaudible) are the same.

19 You value as a measure of thermal and it probably

20 -- what we really mean by thermal there is the

21 envelope, the thermal envelope.

22 MR. RAMIREZ: Okay, so it's under the
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1 heading of envelope of building, so do we need to

2 clarify that up here? We could -- we could put in

3 parenthesis up here you value.

4 MR. LEVY: But the thermal requirements

5 can apply to the other terms on that list, too, so

6 if you're breaking out glazing, you could call one

7 opaque envelope materials or products or systems.

8 Specifically we're talking about the amount of

9 insulation in the wall, floor and ceiling.

10 MR. SCHNEIDER: And this is Peter

11 Schneider. I'm not sure if this fits under that

12 heading, but the idea of advanced framing,

13 structural requirements that, you know, or I

14 should say, structural engineering that needs to

15 be done to really evaluate the amount of lumber

16 we're putting in these walls and whether it's

17 really required or not.

18 MODERATOR HOFFMAN: Envelope what?

19 MR. LEVY: Opaque envelope.

20 MODERATOR HOFFMAN: And then?

21 MR. LEVY: I'm sorry, and that would

22 subsume Peter's point about framing.
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1 MODERATOR HOFFMAN: And then we could

2 strike this one?

3 MR. LEVY: Yeah.

4 MODERATOR HOFFMAN: Peter, is your point

5 reflected there?

6 MR. SCHNEIDER: Yeah, that's great, I

7 just, yeah, just evaluate the actual framing of

8 these homes. I think that that's -- just so it's

9 not forgotten.

10 MR. RAMIREZ: Okay. And so right now,

11 all we're trying to do is put them into

12 categories. The next step is going to be what do

13 we need, right what information do we need on all

14 these, okay. So if everyone's good with that,

15 we'll move on 2 and we'll come back if we need to.

16 How does that look?

17 MODERATOR HOFFMAN: Can you all see --

18 can you all see it? Do you want him to read it?

19 MR. RAMIREZ: I guess, Matthew, you're

20 pretty far back there. Can you see? Okay.

21 MR. WALKER: I have good eyesight.

22 MR. LEVY: Let me suggest a couple
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1 clean-up items. Probably DHW should be its own

2 item, and maybe even appliances should be its own

3 item. They're separately and they're different

4 issues associated with them.

5 MR. RAMIREZ: Okay. So DHW and

6 appliances (inaudible)?

7 MR. LEVY: I would suggest that. And

8 the duct and ductless -- let me slow down here.

9 MR. RAMIREZ: Okay.

10 MR. LEVY: And the duct and ductless are

11 characteristic of the HVC equipment so they could

12 be subsets of that -- a number of 2.1. Not

13 acoustics.

14 MODERATOR HOFFMAN: Where would

15 acoustics go?

16 MR. LEVY: I suppose acoustics could be

17 part of that because I think we're talking about

18 how much noise is generated by the HV's.

19 MR. RAMIREZ: Yeah, the note yesterday

20 was referring to that, the noise that it makes.

21 Everyone go with this one then?

22 MR. UNGAR: This is Lowell. I just note
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1 we have indoor air quality later on.

2 MR. RAMIREZ: Right.

3 MR. UNGAR: I don't know if (inaudible)

4 we want here or under building performance or

5 both. I don't know that it matters, but.

6 MR. RAMIREZ: I mean, we could -- we

7 could put it in both, I mean, if -- if it is dealt

8 with completely under 1, then it's an easy fix in

9 a second. Is everyone comfortable putting them in

10 both? Okay. Yeah?

11 MS. DICKENS: Sorry, this is Ishbel.

12 Under the main heading is DWH and then in the

13 subheading it's DHW. Is that just a type or are

14 they different things?

15 MODERATOR HOFFMAN: I think it's a typ.

16 MR. RAMIREZ: So what is it supposed to

17 be?

18 UNIDENTIFIED SPEAKER: DHW.

19 MODERATOR HOFFMAN: So change it there,

20 yeah.

21 MS. DICKENS: Sorry, thank you.

22 MR. SCHNEIDER: This is Peter.
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1 Equipment HVAC, I mean, it could be equipment

2 heating and cooling and then have, you know,

3 instead of HVAC, referencing ventilation at that

4 separate so HVAC might misrepresent what the focus

5 would be there, so it would be heating and air

6 conditioning and then ventilation under 2.2.

7 MR. RAMIREZ: So, I'm sorry, what do you

8 need there?

9 MR. SCHNEIDER: Well, 2.1 would indicate

10 equipment heating ventilation and air conditioning

11 and I'm wondering if we want to specify instead of

12 using the acronym HVAC equipment heating and

13 cooling or heating and cooling equipment and then

14 2.2 is really dealing with ventilation. Just a

15 suggestion for the group.

16 MR. RAMIREZ: Good for you all? It's

17 the -- show with hands if you're okay with 2. And

18 this is just for the groupings, right?

19 MR. HAGERMAN: Can I suggest that you

20 maybe zoom out since we've had some new people

21 rejoin us, or some people rejoin us so they can

22 get caught up real quick?
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1 MR. RAMIREZ: So what we're trying to do

2 here is for the group -- for the folks that just

3 came back, yeah, my head was on the computer here,

4 I wasn't -- my head wasn't up.

5 So what we're going here is we passed

6 out -- what we're trying to do is just clean it up

7 a little bit to try to see if everything fits into

8 those four categories. So we put the four

9 categories in there and while you're eating, we

10 made an initial attempt -- Eileen and I made an

11 initial to group them. So we're just reviewing

12 right now to make sure that it does fit, okay, so

13 that's all we're doing right now. Okay.

14 MR. HAGERMAN: Can I -- one more

15 suggestion, too. Can I make just a -- can I throw

16 an idea out here maybe that after we clean up the

17 different, you know, items, that erase the things

18 that are in parenthesis underneath?

19 MR. RAMIREZ: Okay.

20 MR. HAGERMAN: Do you follow me? So

21 where you have envelope and billings.

22 MR. RAMIREZ: These right over here?
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1 MR. HAGERMAN: Yeah, it seems kind of

2 redundant since that's kind of explained and --

3 MR. RAMIREZ: Both of the topics that

4 are in there.

5 MR. HAGERMAN: I think it's a legacy

6 thing.

7 MR. RAMIREZ: Okay. I could do that as

8 we go so this one's done.

9 MR. LUBLINER: This is Mike Lubliner.

10 Can anybody hear me?

11 MODERATOR HOFFMAN: Yes.

12 MR. RAMIREZ: Yeah.

13 MR. LUBLINER: Okay. I've been muted

14 for the whole afternoon so --

15 MODERATOR HOFFMAN: Oh.

16 MR. LUBLINER: -- I think we're on the

17 right track. I do have a comment on the ducts

18 thing. We've been working with manufacturers and

19 to move their ducts in the condition space or not

20 use them at all and use ductless grip, and I want

21 to make sure that we have the opportunity to look

22 at that. I guess I have a major question related
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1 to that and it's probably a question for HUD or

2 the manufacturers of the (inaudible), but in the

3 UO calculation, does it include the crossover duct

4 surface area and heat loss? I haven't been able to

5 get clarity on that, but it seems like you have a

6 couple different ways of doing it. You have the

7 crossover duct or you have the through the rim

8 system or you have no ducts at all or you have

9 ducts in the condition space. And I want to make

10 sure that manufacturers have resources and

11 incentives and aren't constrained to be able to

12 evaluate and utilize these different systems, so

13 thank you.

14 MR. RAMIREZ: Okay. Yeah, and I think

15 that's some of the stuff that we'll be getting

16 into right once we start digging into it.

17 MR. EZZO: Do you want me to answer?

18 MR. RAMIREZ: Or do you want to answer

19 right now?

20 MR. EZZO: Hey, Mike, it's Mark Ezzo.

21 Yeah, to answer your question, yeah, we account

22 for the crossover duct between multi-section homes
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1 and the heat loss calc.

2 MR. LUBLINER: Thanks, Mark. So I make

3 sure that PN & L is doing that in the analysis

4 job.

5 MR. RAMIREZ: So now we'll look at No.

6 3. How does this look? I guess what I'm looking

7 for here is to make sure that everything is in its

8 right place or if we've really missed something.

9 MR. LACEY: Eric Lacy, I just had a

10 question. I'm trying to remember what

11 justification meant. Just standing alone,

12 justification, what is that?

13 MR. RAMIREZ: Yeah, if I remember

14 correctly, that one was talking about any changes

15 that we do, is the cost justified? In other

16 words, is the financial benefit justified.

17 MR. LACEY: Okay. So like a cost

18 effectiveness or cost justification.

19 MR. RAMIREZ: Right.

20 MR. LACEY: Okay. That makes sense.

21 MR. RAMIREZ: At least that's how I

22 remember, unless anybody remembers it different.
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1 Mark?

2 MR. WEISS: I was just going to say if

3 you're taking out the parenthetical as Joe

4 suggested, I think you need to shift at least some

5 of these over to, you know, 3. Something.

6 MR. RAMIREZ: Okay. Which ones?

7 MR. WEISS: Well, just the word

8 affordability itself should show up here

9 somewhere. Financing you already have, 3.2.

10 Affordability/purchase price, OM cost, something

11 like -- just something under there so you still

12 have that terminology.

13 MR. SCHNEIDER: This is Peter, I was

14 thinking total cost of ownership should be maybe

15 with affordability.

16 MR. RAMIREZ: Okay.

17 MR. WEISS: Well, I -- my suggestion

18 would just be make affordability 3.6 and you have

19 operation and maintenance under purchase under

20 that or put it all together, either way.

21 MR. RAMIREZ: And you said this 3.6

22 should be off of here as well?
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1 MR. WEISS: I'm sorry?

2 MR. RAMIREZ: This one should be off of

3 affordability, operation and maintenance and our

4 purchase should be off --

5 MR. WEISS: Yeah.

6 MR. RAMIREZ: Okay. And then operation

7 maintenance, okay, that's there. All right, so

8 with that we could get rid of all this.

9 MR. SCHNEIDER: Would appraisal be a

10 category that would fit here that I'm not seeing

11 elsewhere?

12 MR. RAMIREZ: I guess in relation to

13 what we're going here. I don't know, let me as

14 the group?

15 MR. LUTER: So an appraisal wouldn't

16 (inaudible)

17 MS. EPPERSON: Stacey next up. We find

18 that appraisals really often matter when we're

19 doing Energy Star homes new, making sure we're

20 getting value in the marketplace, it tends to be

21 an issue for us. And then under financing, we

22 need to look at chattel, just call it out
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1 separately from mortgage financing since it's two

2 different -- and I've kind of lost sight of what

3 nontraditional financing means.

4 MR. RAMIREZ: So, I'm sorry, what do you

5 want to do here?

6 MS. EPPERSON: I think chattel as a

7 category and mortgage financing, two different

8 products.

9 MODERATOR HOFFMAN: Under financing.

10 MS. EPPERSON: Under financing, if the

11 group agrees.

12 MODERATOR HOFFMAN: And chattel.

13 MS. EPPERSON: Then I need clarification

14 on what nontraditional means.

15 MR. RAMIREZ: Yeah, I think that was --

16 MODERATOR HOFFMAN: Yeah, because it

17 says example --

18 MR. SCHNEIDER: I think that replaces 3,

19 2,

20 1.

21 MR. RAMIREZ: You said shadow?

22 MODERATOR HOFFMAN: Chattle. C-h-a-t-t-
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1 e-l, when women were once considered.

2 UNIDENTIFIED SPEAKER: e-l-e. a-l.

3 MR. RAMIREZ: That?

4 MODERATOR HOFFMAN: You had asked about

5 nontraditional, though.

6 MS. EPPERSON: Just for clarification,

7 what a nontraditional --

8 MR. SCHNEIDER: What is it?

9 MODERATOR: Peter, is that Peter

10 Schneider?

11 MR. SCHNEIDER: Well, yeah, this is

12 Peter here. Really, this is traditional which

13 would be, again, this is manufactured homes on

14 leased land would be tradition in my mind;

15 nontraditional would be where we're going, which

16 is getting traditional financing, which would be

17 the mortgage. So getting mortgages would be

18 nontraditional which is with a new product that

19 the lenders deem as equivalent to a typical stick

20 built modular home and chattel loan being

21 traditional method for manufactured housing on

22 leased land. That's what I view there.
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1 MS. STARKEY: This is Lois from MHI. I

2 think from as long as the HUD code has been in

3 existence, we've been making conventional

4 mortgages on real property and it's about 30,

5 maybe 30 percent of the market right now is

6 conventional financing, so I would suggest you use

7 conventional versus personal property or chattel.

8 We like to use the term personal property

9 financing. That's how it's used in the FHA

10 program, for example. The personal

11 property/chattel and then conventional financing

12 and you've covered the whole market.

13 MR. SCHNEIDER: Yeah, the two

14 categories, they are not great.

15 MR. LUBLINER: Mike Lubliner has a

16 question here. It's a scoping question. Do we

17 want to be looking at the implication of the tax

18 credits, energy tax credits in terms of how this

19 might help in the affordability gap as part of our

20 scope? And if so, I might suggest that we look at

21 utility/federal energy tax credits. Perhaps it

22 could be part of the analysis that could help to
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1 inform and mitigate some of the issues associated

2 with the first costs for the affordable housing

3 portion of the sectors that we're looking at.

4 MR. HANGER: This is Rick Hanger, state

5 of Colorado. I would also second that. I think

6 that the -- the possibilities of other financing

7 mechanisms, including utility rebates, would be a

8 good piece to include here.

9 MODERATOR HOFFMAN: So you think that

10 personal and chattel are the same, personal and

11 slash chattel? Personal property, PRO, you know,

12 personal property slash chattel.

13 MR. RAMIREZ: So it is basically other

14 here

15 --

16 MR. LUBLINER: Yeah, so this is here, I

17 was just going to summarize.

18 UNIDENTIFIED SPEAKER: (Inaudible).

19 MODERATOR HOFFMAN: Only two, okay.

20 MR. LUBLINER: Yeah, I think 3, 2, 1

21 could be removed because 3, 2, 2, 1 and 3, 2, 2,

22 2, that's redundant. And then I think under
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1 other, if that were 3 -- if that becomes 3, 2, 1

2 mortgage and 3, 2, 2 could be other because it's

3 not under mortgage, it would actually be related

4 to tax credit, other grants, onbill financing, all

5 the things that are happening at least up here

6 locally that should be considered.

7 MR. RAMIREZ: Okay. Did I capture that

8 accurately? Okay.

9 MR. LUBLINER: How about cash sales?

10 What percentage of the homes are purchased with

11 cash and is that something we want to evaluate?

12 MR. RAMIREZ: Well, is that -- is that

13 under or do we need a separate one for cash?

14 MR. LUBLINER: I'll leave that to the

15 group.

16 MS. DICKENS: It could just be slashed

17 with personal property slash chattel slash cash,

18 just another purchasing option.

19 MS. HOFFMAN: And, Lois, do you --

20 MS. STARKEY: Yeah, no, I really if you

21 do personal property slash chattel, conventional

22 slash mortgage or conventional mortgage if that
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1 makes it clearer, and the third one would be other

2 where you have utility incentives, other kinds of

3 assisted financing which I think is worth talking

4 about. And then I think you've covered

5 everything.

6 MR. UNGAR: This is Lowell. But others

7 not under mortgage, there would have to be a

8 separate --

9 MS. STARKEY: Yeah, I mean, cause you're

10 usually combining it --

11 MR. UNGAR: -- because you're talking

12 about incentives --

13 MS. STARKEY: You're usually combining

14 it with some other form of financing.

15 MR. LUBLINER: This is Mike Lubliner.

16 I'd like to see some explicitly broken out under

17 other; maybe tax credits is one, utility

18 incentives is another and cash purchases. Oh, you

19 have cash up there, never mind. Just tax credits

20 for utility incentives and utility incentives is

21 the next one and then other after that. Or just

22 do --
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1 MS. DICKENS: Actually, I would like to

2 support Mike and food cash and his other

3 categorigation (sic) go under chattel, I'm sorry,

4 my mistake.

5 MODERATOR HOFFMAN: You've got tax

6 credit?

7 MR. LUBLINER: I'd say federal or state

8 tax credits and the second would be utility

9 incentives, and then a final one would be HUD

10 grants or other affordable housing grants. Thank

11 you.

12 MODERATOR HOFFMAN: And do you want to

13 put cash under that?

14 MS. HANGER: Yeah, this is Rick from

15 Colorado. I would also expand that beyond just

16 HUD grants to include other grant resources.

17 MODERATOR HOFFMAN: So HUD and other

18 grants.

19 UNIDENTIFIED SPEAKER: (Inaudible).

20 MS. EPPERSON: This is Stacey from Next

21 Step Support. Just other because there is a

22 laundry list long of HUD grants, USDA grants, it
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1 goes on and on.

2 MR. RAMIREZ: So let me sure I got this

3 right. So what I'm hearing is just delete all

4 this -- let me do it over so they can see that.

5 You're saying just delete all this and leave just

6 other?

7 MS. EPPERSON: Correct. I concur.

8 MR. RAMIREZ: All right, folks --

9 UNIDENTIFIED SPEAKER: (Inaudible).

10 UNIDENTIFIED SPEAKER: (Inaudible) the

11 whole list.

12 UNIDENTIFIED SPEAKER: I think that's a

13 good idea. I think it will be helpful for

14 (inaudible).

15 MR. RAMIREZ: So is this a good

16 representation then for what we're talking about,

17 to leave it like this?

18 MODERATOR HOFFMAN: I'm hearing two

19 different views.

20 UNIDENTIFIED SPEAKER: (Inaudible).

21 MODERATOR HOFFMAN: You could put et

22 cetera and deal with it for purposes of today.
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1 MR. KESSLER: This is Bert Kessler

2 (inaudible). I'm not too sure that tax credits

3 and/or utility incentives need to be part of --

4 part of this. They're not controlled by anything.

5 There's really no longitivity that you can assign

6 to it and it's, you know, if you can get it, good

7 for you. But I don't know that they would be

8 available to a great number of people, you know,

9 and it's regional too. You know, Mike up there in

10 the pacific northwest, they've got a bunch of it.

11 We don't have hardly anything here in Texas.

12 MS. LUBLINER: Yeah, that's why I'm

13 interested in arguing to make sure that it's

14 considered in the analysis, or at least parametric

15 analysis done to see what the implications are.

16 I guess what I was thinking, Bert there,

17 is cause I agree with you that they come and they

18 go on the whim of Congress, but I would like to

19 make sure that the silos within HUD and to

20 Congress, the feedback from this group is for the

21 affordable housing sector of this industry, that

22 these kind of things are extremely important in
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1 helping to set the energy levels and make sure

2 that people at the low end aren't losing out from

3 their opportunities to purchase energy efficient

4 homes. I was hoping that the analysis would help

5 make the case for industry to Congress and to HUD

6 FHA to continue to support these things. Thank

7 you.

8 MR. CYMBALSKY: So this is John --

9 MR. KESSLER: Bert again. I don't

10 disagree with you, Mike, but I don't think it

11 needs to be part of any kind of a standard.

12 MR. LUBLINER: Oh, I agree, it should

13 not be

14 --

15 MR. CYMBALSKY: Excuse me, fellows, this

16 is John from DOE representing Azrac. The charter,

17 this has gone beyond the charter, in my opinion.

18 I understand the important of tax credits and

19 rebates and grants, whatever may have you,

20 however, when we do the analysis it's going to be

21 sort of clean of that, right, and we're going to

22 negotiate standards based on what the normal costs
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1 are to do this manufactured housing. I appreciate

2 the sidebars about how other policies, federal or

3 otherwise, could impact efficiency here, but it's

4 not part of our charter and we really need to move

5 off this discussion point.

6 MR. RAMIREZ: So I was just ELMO'd,

7 right, so everyone okay with that, moving on?

8 All right. So financial as a group

9 here, good enough to look at the last one?

10 MR. TOMPOS: I think we should add

11 capital investment by the manufacturer in regards

12 to testing equipment for changes in their process

13 that may or may not happen.

14 MR. RAMIREZ: It capital investment

15 enough to jog memory on that by manufacturer?

16 MR. TOMPOS: Yeah, by manufacturer.

17 MS. DICKENS: This is Ishbel. Can I

18 just add that relevant environmental

19 externalities, you just make it climate change?

20 MR. LUTER: This is Rob --

21 MS. DICKENS: So we all know what that

22 means.
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1 MR. LUTER: Could I suggest that that's

2 beyond our charter as well? 3.5 should be

3 omitted, just like tax credits and utility

4 incentives.

5 MR. LUBLINER: This is Mike Lubliner. I

6 think that there's a distinction I'd like to make

7 between what we include in the analysis in the way

8 of tax credits or these other things, versus what

9 we actually put in the standard. If it's

10 possible, and, John, I'm going to refer back to

11 you, having PNL do this parametric sensitivity

12 study of what these implications of these external

13 things are, I think would be useful.

14 But again, if it's beyond the scope,

15 fine, but I think this is the only chance HUD and

16 DOE are going to get to look at this in this

17 context, so I'm hoping that that will come

18 through. I'm good either way though.

19 MR. RAMIREZ: Okay. So this 3.5, it was

20 suggested that what are we going to deal with that

21 and the suggestion was to eliminate it or modify

22 it to just climate change.
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1 MODERATOR HOFFMAN: Eric.

2 MR. LACEY: Eric Lacy. Yeah, I mean,

3 environmental impact seems important but it might

4 be outside the scope of here. But there are other

5 externalities that I'm wondering where these could

6 capture. One -- one would be peak electricity

7 use, and I don't know if that's -- I mean, energy

8 use is obviously part of the charter, but peak

9 energy use is important, I assume, to utilities

10 and to the people paying the rates.

11 I'm wondering if that fits into general

12 externalities, sort of a calculation we were

13 talking about cost effectiveness or whether that

14 belongs somewhere else. But before we completely

15 delete externalities, I wanted to throw that out

16 there. It's important at the state level, I'll

17 tell you, where you have to site new power plants

18 to meet rising peak demands but, you know, I'm

19 wondering if we can capture that somewhere.

20 MR. RAMIREZ: Peak energy usage, is that

21 what you're saying?

22 MR. DENNIS: I'll second that. I mean,
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1 I've been assuming that that would be included in

2 costs and also in energy efficiency. I mean, not

3 -- demand, using energy at the wrong time is

4 inefficient use of energy too, so I'm hoping that

5 that's -- that's kind of -- that's why I haven't

6 been chiming in, but that's very important to the

7 national interest use in energy, so.

8 MR. CYMBALSKY: This is John at DOE. So

9 the rule making itself, I don't think is things we

10 need to worry about in terms of negotiating

11 positions. However, I think a lot of these things

12 that were just brought up are very important, sort

13 of impacts the rule we'll have on. So, for

14 example, we do have certain requirements we must

15 do in a rule making to address environmental

16 impact, we will do that.

17 We will include the social cost of

18 carbon as a natural fall-out from the impact of

19 the rule. Peak energy is we, you know, in the

20 appliance world we definitely talk about it in the

21 rule but, again, I think we recognize it as

22 important here but I still don't think that's
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1 something that needs to get muddled in this

2 discussion right now.

3 MR. RAMIREZ: Yeah, I'll tell you, as

4 far that goes, we're trying to take it step by

5 step. I know sometimes it's difficult because you

6 want to eat the elephant in one bit, right, so did

7 you ever hear how to eat an elephant, all right,

8 one bite at a time? So that's what we're trying to

9 do, we're trying to serve it to you little by

10 little here.

11 And these items, although they're up

12 here, we may never even discuss them, right?

13 Because like say, for example, these two that were

14 crossed out, the tax credits and utility

15 incentives, if this doesn't have an impact on it

16 when we go to prioritize them, they're just going

17 to be at the very bottom, right, we're not -- we

18 may not get to them, all right. So it's okay that

19 they're up here but the next -- the next step when

20 we start to prioritize them is where they may --

21 they might fall to the wayside. Right?

22 MODERATOR HOFFMAN: Well, I just have a
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1 question then on the tax credits and utility

2 incentives. Should they be up there at all or

3 out, I don't, I mean, just to --

4 MR. RAMIREZ: Let me see -- let me see

5 if (inaudible) just striking it to clean it up a

6 little bit.

7 UNIDENTIFIED SPEAKER: To strike it?

8 MR. RAMIREZ: To strike it, to eliminate

9 it.

10 MS. HOFFMAN: Okay, thank you.

11 MR. RAMIREZ: Okay, I didn't see any

12 thumbs down, so.

13 MS. HOFFMAN: Okay. And Brian Rocky has

14 a comment. You want to -- you're on the phone,

15 right?

16 MR. ROCKY: Yes, I am, thank you. Just,

17 and I think it's already been answered, but the

18 discussion on the energy efficiency measures that

19 the department is moving forward with on equipment

20 always includes social cost of carbon now as part

21 of the economic justification. And so the

22 environmental change impact does become a
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1 significant part of the financial considerations

2 for this and I believe that was already answered

3 by DOE here in the last minute or so.

4 MODERATOR HOFFMAN: Okay, thank you.

5 Moving right along.

6 MR. ROCKY: Thank you.

7 MR. RAMIREZ: Okay. Then we'll go with

8 financial. All right, so. . . Number 4, ability

9 performance. Do these all fit?

10 MODERATOR HOFFMAN: And can you all see

11 them? Matthew, yeah? Okay.

12 MR. RAMIREZ: You have to get out of

13 your (inaudible) seat if you want to.

14 MS. EPPERSON: Stacey from Next Step.

15 What you have parenthetically, some of that does

16 need to move over.

17 MR. RAMIREZ: Okay, which ones.

18 MS. EPPERSON: So I'm not seeing

19 durability as one. I don't see Energy Star

20 rating, comfort.

21 MR. RAMIREZ: Everything else is there?

22 MS. EPPERSON: I don't see energy
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1 consumption. Is it there?

2 MR. RAMIREZ: Is it here?

3 UNIDENTIFIED SPEAKER: (Inaudible).

4 MR. RAMIREZ: What number is it?

5 UNIDENTIFIED SPEAKER: (Inaudible).

6 MR. RAMIREZ: Oh.

7 MS. EPPERSON: We're moving yellow over.

8 UNIDENTIFIED SPEAKER: (Inaudible).

9 MODERATOR HOFFMAN: Operations and

10 maintenance, is that there? Is that part of this?

11 MS. EPPERSON: But isn't that in

12 financial?

13 UNIDENTIFIED SPEAKER: That's under

14 financial.

15 MODERATOR HOFFMAN: Okay, we don't need

16 it here?

17 MS. EPPERSON: We need to delete here.

18 MODERATOR HOFFMAN: Okay.

19 MR. RAMIREZ: That's a nice clean up.

20 And does that look good?

21 MS. DICKENS: I just have a question why

22 4.2 is climate zone impacts and then 4.2.1 is
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1 single (inaudible) double others -- I don't know

2 if those -- that the subs under 4.2 are actually

3 in the right place.

4 MR. RAMIREZ: Yeah, when we're cleaning

5 it up, those were subsets of that so I just

6 brought them over. If they're not, do we

7 eliminate them from here? Do we put them somewhere

8 else or just delete them?

9 MS. DICKENS: I mean, is that -- is that

10 where you'd have -- where the impact would be, a

11 single versus double would be a climate zone issue

12 rather than any other zone issue, or any other

13 head -- I just don't know.

14 MR. POTTS: I think that's where Joe

15 said that they were going to look at those

16 different variables within the climate zones, so

17 maybe that's why --

18 MR. RAMIREZ: Okay.

19 MR. POTTS: -- they're included in

20 there.

21 MR. RAMIREZ: So for, you know what, it

22 sounds like for our purposes though we may not
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1 necessarily -- I'll just do a strike through

2 keeping there just in case there was a purpose

3 that we didn't -- that we can't think of right

4 now. Is that okay with everyone? Okay.

5 Now, what I'd like to do is go through

6 here and look at these categories and see what

7 information do we need? What data do we need?

8 Who's going to get it and by when, right, we need

9 to be realistic with this. I would suggest that

10 we take a quick break, do a one function break,

11 right, and then when we come back, let's look at

12 all this. You know what, maybe we could even try

13 to get a printout of this so that we have a clean

14 copy in front of you and then we'll start to try

15 to identify the information. Sound good? 10

16 minutes?

17 (WHEREUPON, a brief recess was

18 taken.)

19 MR. RAMIREZ: Okay. Did it feel good to

20 stretch the legs for a little bit? It felt good

21 to stretch the mind a little bit for me. I think

22 I scrambled it a little bit.
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1 All right. So what we want to do next

2 is that we want to look at -- we want to look at

3 these and we'll blow them up as we're talking to

4 you about them. But we want to identify what

5 information or data do we need and who's going to

6 provide it and is it a realistic -- well, two

7 things. Is it a necessary request and is it a

8 realistic request meaning that, first of all,

9 necessary -- do we really need it for what we're

10 going versus it's nice to have? I would say we

11 eliminate the nice to have's versus what we need.

12 And then the realistic part is that can

13 we actually get it on time, right, are we going to

14 request them to just sole voluminous that we just

15 can't put -- assemble it, you know, on time.

16 So that's the kind of information we're

17 looking for. What data or information do we need

18 in order to truly problem solve this? And I think

19 the way to go through this would be to go one by

20 one and we'll just take that envelope of building

21 and if we could make that one as a local -- we'll

22 put notes in that envelope of building. I just
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1 showed them how to use this this morning, just a

2 couple of minutes and we can buzz it around.

3 Okay. So what information do we need,

4 or data do we need in regards to this issue?

5 MODERATOR HOFFMAN: Can they see the

6 whole thing?

7 MR. RAMIREZ: Yeah, they have copies in

8 front of them too.

9 MODERATOR HOFFMAN: Oh, okay.

10 MR. RAMIREZ: I put out new copies.

11 MODERATOR HOFFMAN: Got it.

12 MR. RAMIREZ: You know, and as I'm

13 looking at this, if there are -- if there's

14 information and some of the builders (inaudible),

15 right, when this was thrown out there. But if

16 there's information that you all as, what I would

17 say, practitioner's data or information that you

18 have that could be put into the study that's being

19 done, give Joe a little scenario so that way he

20 could plug it in.

21 MODERATOR HOFFMAN: We're just asking

22 about data.
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1 UNIDENTIFIED SPEAKER: (Inaudible).

2 MR. RAMIREZ: You're good. That was

3 (inaudible).

4 UNIDENTIFIED SPEAKER: Thought I heard

5 my name.

6 MR. RAMIREZ: A far side -- a far side I

7 think went through my head, but all right. Yeah,

8 Eric?

9 MR. LACEY: Eric Lacey. This seems to

10 be the category for which PN & L is going to be

11 providing a lot of information, so, I mean, things

12 like the efficiency of the various opaque envelope

13 components and the fenestration you factor in SHGC

14 and all those things are kind of included in

15 there. I didn't see anything in here that I

16 didn't hear was going to be included in that

17 report.

18 MODERATOR HOFFMAN: Okay, great.

19 MR. LACY: I think there are other

20 categories that may have bigger needs, but I think

21 this is on that's --

22 MR. HAGERMAN: So this -- this is Joe
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1 Hagerman. So this is the primary category, I

2 would say, that you're going to see the PNL

3 analysis based off of. However, just to keep in

4 mind, they're going to base that strictly off the

5 code, right, so they're not going to -- nobody's

6 asked to do an Energy Star analysis or, you know,

7 anything like that, what you normally ship, et

8 cetera, et cetera, nobody's asked for that so

9 they're not going to do anything like that.

10 So if we have a request for somebody to

11 say model this U factor, this R, give it to us and

12 we'll do it. Absent of request, though, we're

13 just going to provide what we've been consistently

14 talked about.

15 MR. RAMIREZ: So you guys -- at least

16 from an outsider, it seems like if guys have some

17 of that practices that you're doing or some ideas

18 for him to run, it seems like that would be a

19 valuable information.

20 MR. HAGERMAN: And you don't have to

21 give those to me today, right, as long as we get

22 those, you know, by, let's say, Wednesday,
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1 tomorrow, close of business, early Thursday, we

2 can start including this. And it can be an

3 individual request from a (inaudible) number.

4 MR. SANTANA: This is Manny with Cavco.

5 I think without seeing what, you know, what

6 information DOE or people have developed already,

7 it's hard to know what's missing, you know, so

8 once we get some information to start analyzing,

9 then I think the ideas are going to start coming

10 through of, oh, we need this, we need that, we

11 need this other thing.

12 MR. LUTER: Rob Luter to expound on

13 that. I really do think as well that we're going

14 to need to see what they come up with. There's

15 going to be a baseline that's provided. We'll

16 call it -- been calling it the HUD baseline. Will

17 that HUD baseline reflect what's really being

18 produced or the lowest common denominator that can

19 be produced? Don't know. I'm prepared to do some

20 research on my own and offer up to that group

21 statistics on what from the fenestration side is

22 actually being sold most often.
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1 We know there's -- there's products out

2 there that are quite poor performers, but they're

3 in the distinct minority and have very limited

4 use. I'd hate for their analysis to reflect that

5 those are really the primary products that are

6 used simply because they can be used.

7 MR. HAGERMAN: Yeah, so appreciate that.

8 So whatever information you give us --

9 MR. LUTER: Okay. We'll model that.

10 MR. HAGERMAN: -- we'll forward this to

11 you. Just forward it to me.

12 MR. LUTER: I can say the current, you

13 know, baseline that they're using is just a

14 straight -- a straight manufactured house that

15 meets the HUD code, right, so, you know, to what

16 John said --

17 MR. HAGERMAN: Well, as we discussed, it

18 being -- it being a performance-based code,

19 there's lots of ways to skin that cat.

20 MR. LUTER: Right.

21 MR. HAGERMAN: So the end result, well,

22 it winds up being the same amount of energy used
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1 can look very different in a lot of respects, so.

2 MR. RAMIREZ: So just before I get to

3 Mark -

4 -

5 MODERATOR HOFFMAN: (Inaudible).

6 MR. CYMBALSKY: So just to address the

7 analytics a little bit, so, you know, how we

8 generally set these up in -- in sort of the

9 appliance world and I think it will fit here

10 pretty -- map pretty well, you'll have the

11 baseline how -- like the one that's the least

12 efficient but legally meets the code, so that will

13 be what I'll call the baseline for lack of a

14 better term.

15 And then what we do is, you know, there

16 are options to get to these different levels that

17 we're going to pick and I think what we've kind of

18 focused on is different bumps up in the code

19 levels. And so normally what we do in the

20 appliance world, we do tear downs and I know it's

21 a lot different than the house at this point, but

22 we normally try to pick the -- what would be the
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1 cheapest way to achieve that level of efficiency

2 and then that's how we'll bundle the different

3 choices for the analysis.

4 It's not to say we have to do it that

5 way here. If you guys have data, that suggests,

6 you know, the way we do it to meet the 2006 is

7 this way and the way we would do it for 2008 is

8 that way, you know, knowing that there's lots of

9 different ways to do it, but I'm assuming that

10 businesses that -- in the manufactured housing

11 industry isn't too much different in that they're

12 trying to control costs, you know, and increase

13 their profit margins which, you know, that's what

14 we do here.

15 So I'm hoping I'm not too far out by

16 saying what you guys will bundle things together

17 most cost effectively for your business and that's

18 how you would do it. I mean, that's kind of the

19 assumption that we make when we do the analysis.

20 MODERATOR HOFFMAN: Okay. I'm sorry,

21 Mark.

22 MR. WEISS: Question first -- Mark
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1 Weiss, MHIR. Working from the more general to the

2 more specific, how voluminous are the relevant

3 sections of the IECC that we're talking about

4 here?

5 UNIDENTIFIED SPEAKER: Not very.

6 MR. WEISS: Not very? Okay, thank you.

7 I mean, I'd like to see it again not be a

8 technical person. What I'd like to see just in

9 general to begin with is a copy of the relevant

10 portions of the IECC and then send a copy of the

11 HUD standards --

12 MR. CYMBALSKY: For copies of relevant.

13 Let's make sure we get it down, copies of relevant

14 IECC.

15 MR. WEISS: Relevant sections of the

16 IECC. If we need to look at 15 in the previous

17 iterations, they should be included as well to see

18 the evolution of that standard and the relevant

19 portions from the HUD standard. And then going

20 back to something that Robin raised yesterday and

21 I asked Joe about it at lunch, I think we need to

22 see what DOE generated previously since 2007,
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1 draft proposed rule on the information developed

2 as part of that process to see where they were at

3 that point.

4 MR. CYMBALSKY: I'm sorry, why is that

5 relevant necessarily here?

6 MR. WEISS: I'm sorry?

7 MR. CYMBALSKY: I'm trying to figure out

8 the relevance of the old rule that kind of we've

9 moved past that and we're doing new stuff now, so

10 I guess --

11 UNIDENTIFIED SPEAKER: (Inaudible).

12 MR. CYMBALSKY: Yeah, you know, we'll

13 have - - we're going to hand out analysis as

14 quickly as possible and there will be a bunch of

15 numbers for you to look at, but, you know, what

16 was done for the (inaudible) that was then

17 withdrawn from (inaudible) is kind of, that's

18 history in my opinion, I think.

19 MR. WEISS: Well, our legal opinion --

20 MR. RAMIREZ: All right. So let me

21 chime in here so -- just to make sure that I'm

22 clear. What you're talking about is a 2012 piece,
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1 is that what you're talking about?

2 MR. WEISS: I've never seen it. I

3 assume it's 2012.

4 MR. RAMIREZ: But is that what you're

5 talking about?

6 MR. WEISS: I believe so.

7 MR. RAMIREZ: Okay.

8 MR. CYMBALSKY: He means the 2012. You

9 want an analysis with the 2012 code or do you want

10 to look at the old Noper (ph) analysis? I'm

11 sorry, I may have misheard you.

12 MR. WEISS: No, what I'm referring to is

13 what I think we discussed yesterday which was the

14 draft proposed rule developed by DOE and --

15 MR. CYMBALSKY: Yeah, we're not going to

16 hand that out anything.

17 MR. WEISS: And any -- well, let me just

18 finish -- any related analysis.

19 MR. CYMBALSKY: Right, we're not going

20 to -- we're not -- we've moved past that, right,

21 so we're going to have all new data, all new

22 numbers and we will provide that as a basis to
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1 talk about.

2 MR. LUTER: It was suggested yesterday

3 (inaudible).

4 MR. CYMBALSKY: Not at this point. I

5 mean, I think we're hoping in a few days to a

6 week's time we'll have a bunch of numbers to hand

7 out.

8 MR. WEISS: Well, if I may just respond.

9 You say it's history and that's fine, but I don't

10 know if it's history or not, okay, I don't know --

11 I don't know what it was and how it might relate

12 to where we start from here. So I understand

13 you're saying it's history but I don't know one

14 way or the other. And I think to have a clear

15 record in this proceeding, given the fact that DOE

16 spent quite some time working on this prior to

17 this proceeding and then we're only talking about

18 two months here potentially, I think we need to

19 see where you were before and where we're going in

20 relation to that.

21 MR. RAMIREZ: Let me -- let me chip in

22 real quick cause I don't think --
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1 UNIDENTIFIED SPEAKER: (Inaudible).

2 MR. JENSEN: I just have -- this is Mike

3 Jensen from DOE GC. I just have two comments in

4 that regard. As far as we're concerned, the

5 document that was sent to OIRA in October 2011 is

6 still a pre- decisional document. I understand

7 that it was impermissibly distributed to many

8 people in this room. But as far as we're

9 concerned, that that's history. We're starting --

10 we're hitting the reset button and we are

11 beginning negotiations again today.

12 That information, the proposed rule and

13 the accompanying documents are still pre14 decisional at this point, will not be distributed

15 outside of DOE.

16 On a slightly, just to move slightly to

17 a separate issue that I think I'd just like to

18 address and then I'll put it out there for

19 everyone's consideration is that there was a

20 discussion about two or three minutes ago about

21 the need for DOE to set forth the relevant

22 provisions of the IECC for all of the committee to
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1 understand what provisions we're actually working

2 with.

3 There are certain provisions of the IECC

4 that may or may not be energy efficiency related,

5 depending on what this committee deems those to

6 be. For example, mechanical ventilation or light

7 in. You know, these are issues that I think that

8 the -- the committee needs to address to determine

9 exactly which provisions of the IECC DOE needs to

10 come back and give data to all of you about.

11 MR. RAMIREZ: Yeah.

12 MR. WEISS: Two questions. First of

13 all, can you specify OIRA, what that refers to?

14 MR. JENSEN: Excuse me. In October of

15 2011, DOE transmitted our pre-decisional draft of

16 the rule making at that time to the Office of

17 Management and Budget. There's a section in OMB,

18 the Office of Information and Regulatory Affairs,

19 which is OIRA. That document was never intended to

20 be released to the public and was for OMB's

21 review. That document has since been kicked back

22 to DOE to -- with the instructions to begin the
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1 process anew, so that's why we're here today.

2 MR. LUTER: And your position, OGC's

3 position is that regardless of the disclosure to

4 others outside of DOE, that that's still pre5 decisional and still exempt from disclosure?

6 MR. JENSEN: That's correct.

7 MR. RAMIREZ: So there was -- what

8 exactly is the status of PNL?

9 MR. CYMBALSKY: That's the national

10 laboratory.

11 MR. RAMIREZ: Okay.

12 MR. CYMBALSKY: Pacific Northwest

13 National Laboratory.

14 MR. RAMIREZ: Okay. So another piece

15 then would be the PNL study.

16 MODERATOR HOFFMAN: And is Eric -- is

17 that up there for -- you want to speak?

18 MR. LACEY: Yeah.

19 MODERATOR HOFFMAN: Okay.

20 MR. LACEY: Eric Lacey. Just two

21 issues. Don Surrena back here with NAHB reminded

22 me that there are some free resources available if
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1 you've not seen the IECC. The ICC (sic) website

2 has, and it's kind of hard to find on the ICC

3 website so if you want this, let me know and I'll

4 show you how to get there.

5 Also, on our organization's website,

6 RECA_codes.com, you can get a copy of state by

7 state what the requirements are for various

8 additions of the IECC. We don't yet have the 2015

9 up, but it will be the same for 2012.

10 Anyway, if you don't have a copy of the

11 code and want to see one of these resources, come

12 grab me and I'll point you to one of those.

13 MR. RAMIREZ: Let me pause you right

14 there -

15 -

16 MR. LACEY: Okay.

17 MR. RAMIREZ: -- because can you just

18 send that link out, do a reply all to one of the

19 group emails and just send that out to everybody?

20 MODERATOR HOFFMAN: And also I believe

21 you should have a copy of the ground rules,

22 they're been sent out to everyone as well.
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1 MR. RAMIREZ: You can do a reply all to

2 that one.

3 MODERATOR HOFFMAN: Cause that includes

4 all the working group members.

5 MR. LACEY: Okay.

6 MODERATOR HOFFMAN: Thank you.

7 MR. LACEY: The second issue, going back

8 again to what the statute and what the scope is

9 under the statute, you're asking whether there's

10 anything in addition to what PNL is already

11 looking at. PNL is going, you know, 2015, 2012,

12 2009, 2006. You know, are there standards that go

13 beyond the 2015 that could be looked at?

14 On fenestration, you know Energy Star

15 version 6.6 might be something to look at in terms

16 of, you know, I'm trying to complete this curve

17 that Emanuel outlined for us. At what point do we

18 reach diminishing returns? If we haven't looked

19 at the standard yet, maybe it's good to throw

20 something in beyond the 2015 IECC just to see

21 where it goes, you know, if it's going to take a

22 lot of resources to get there, then maybe it's not
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1 worth it. But it seems like the statute wants us

2 to go to, you know, more cost effective, you know,

3 go beyond it if it's cost effective or to go below

4 if it's not cost effective.

5 So I don't know if there's a comparable

6 standard for the opaque envelope, you know,

7 building America or something else, but at least

8 on the windows I think there's a slight

9 improvement by going through Energy Star Windows.

10 MR. RAMIREZ: So the question is, is

11 there any information that would provide

12 efficiencies for beyond 2015, if there's any data

13 on that?

14 MR. LACEY: Right. If we haven't gotten

15 all the cost effective energy savings out of

16 windows that we can, would it be worthwhile to

17 look at Energy Star version 6 or windows.

18 MR. RAMIREZ: Is there -- is there

19 anything out there like that?

20 MR. CYMBALSKY: No, sir, that's what Joe

21 described before, that as we get in -- more into

22 the negotiations, people say well that's great,
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1 but what if we do "X", "Y" and "Z". And so one of

2 the X's could be we go higher on windows and maybe

3 a little lower here, I don't know how you guys

4 want to do it, but we're higher on everything.

5 You can have, you know, a stretch code, for

6 example, that you want to see analyzed.

7 MODERATOR HOFFMAN: But in terms of

8 time, though, I just wanted to check -- Eileen

9 Hoffman -- is this a request for PNL to run

10 numbers for Energy Star 6 for windows?

11 MR. HAGERMAN: Or can we make a request

12 that you form some type of a, you know,

13 subcommittee and then get us a proposal on what

14 you'd like us to run in addition to what we've

15 already run.

16 MR. LACEY: That's fine, and this is

17 mostly more of a general comment that, you know,

18 maybe we're all assuming the 2015 IECC is the end

19 of that curve when maybe it's not and, you know.

20 UNIDENTIFIED SPEAKER: It's a good

21 comment.

22 MR. LACEY: That was just one example I
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1 thought of.

2 MR. RAMIREZ: All right. So -- but now

3 what's come out of that though is the idea of

4 maybe forming a subcommittee where some of you get

5 together and put together different scenarios that

6 they could through the PNL study. Is there any

7 traction on that, some of you want to get together

8 and assemble different scenarios for that?

9 MR. LUBLINER: This is Mike Lubliner.

10 MR. RAMIREZ: Go ahead.

11 MR. LUBLINER: I'd like to suggest along

12 with windows, we work with the Building America

13 Program and I know (inaudible) does too the areas

14 that might be of interest. We're putting triple

15 pane windows in demonstration homes now.

16 But I think the other areas are -- and

17 this also in the cold climates zone -- foam

18 shooting on the walls, moving the ducts into the

19 conditioned space which would be --

20 MR. RAMIREZ: Michael, let me -- let me

21 cut you off there because that's, I think,

22 something that the subcommittee would work on,
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1 right, those things that you're running through

2 right now, putting together scenarios like that

3 that could be run through the study. Is that

4 accurate?

5 MR. LUBLINER: Correct.

6 MR. HAGERMAN: Right. So this is Joe

7 Hagerman.

8 MR. LUBLINER: Right. I speak in

9 support of the subcommittee, I just want to be

10 clear as to, you know, what the four technologies

11 that the subcommittee might be looking at besides

12 the one that was mentioned by windows. I had

13 three others I was hoping to share but it's not --

14 MR. RAMIREZ: That's not (inaudible)

15 limiting at all. Whatever you can come up with.

16 MR. HAGERMAN: Right. So let me

17 interrupt real quick. So I have a real trouble

18 just, you know, modeling some generic language,

19 right, I need a specific proposal. So maybe if,

20 you know, you could form a subcommittee, or you

21 and (inaudible) form a subcommittee and gin up a

22 max tack home, right, maximum technology's out
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1 there, so we can look at that as an example,

2 right?

3 Or if you want to say what is -- what is

4 an Energy Star manufactured home, you want to give

5 us that, we can run that. Or if Cavco says we

6 have a, you know, Cavco extra special home, or a

7 next up home, right, you know, if you want to put

8 a straw man out there, we'll model it so you can

9 see where it falls against all the other.

10 MR. RAMIREZ: Michael, was that a -- was

11 that a volunteer to be on that subcommittee?

12 MR. LUBLINER: Sure, you know, I was

13 hoping to get a little scope of kind of where the

14 areas are so we don't go off on a tangent but,

15 yeah, I'm very happy with overseeing that

16 subcommittee.

17 I think the big one that I want to make

18 sure doesn't get (inaudible) an analysis because I

19 know that some of the energy plus analysis won't

20 do some of the things that we may want to do, we

21 found this in Building America, particularly the

22 heat pump water heater one. It's important -- I
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1 think it's an important one. So I'll leave it at

2 that and I'll take -- accept any task necessary to

3 scope those things out. Appreciate that, thanks,

4 Joe.

5 MR. RAMIREZ: Who would like to get

6 together with Michael to put together --

7 MODERATOR HOFFMAN: And Eric.

8 MR. RAMIREZ: Eric Lacy?

9 MODERATOR HOFFMAN: Emanuel.

10 MR. RAMIREZ: Emanuel Levy.

11 MODERATOR HOFFMAN: So we have Michael,

12 Eric, Emanuel.

13 UNIDENTIFIED SPEAKER: Your Honor,

14 (inaudible) designate someone.

15 MR. RAMIREZ: Lowell Ungar.

16 MODERATOR HOFFMAN: Okay. Lowell were

17 his designee, okay. And this is a subcommittee.

18 What would you call it, subcommittee on?

19 MR. RAMIREZ: I called it the

20 subcommittee for PNL scenarios.

21 MR. CYMBALSKY: Yeah, I would just call

22 -- yeah, I would just call it trial standard
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1 levels for the standard negotiations.

2 MR. UNGAR: Can I ask a question about

3 that? This is Lowell. I wonder how this is going

4 to work in two ways, actually. One is, right now

5 we only have energy savings. If we don't have

6 costs in these, I think this group is going to

7 have a very hard time dealing with what it means.

8 And, yes, it will clear enough to save energy, but

9 so what?

10 The other piece of that is, I mean, one

11 could come up with a max tech home and which one

12 does 10 different things to improve the energy

13 efficiency. I think in the end we're going to be

14 looking at a lot of things separately and I don't

15 know how we're going to evaluate it unless we can

16 do -- look at each of the individual measures

17 separately, but then I don't know if that becomes

18 a completely unwieldy analytical task if you have,

19 you know, 10 measures above and maybe 50 or 100

20 different measures going below 2015 IECC as to how

21 we -- do we try to put together packages that we

22 think are most likely? Do we then need to figure
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1 out what is within scope?

2 It may be if we're -- if we're going to

3 limit the analysis, we made need to figure out

4 what we can do within a standard as opposed to

5 things which would just may be real hard to deal

6 with in a standard even if they make technical

7 sense. It just seems to me before we -- before we

8 start putting this together, we have to have a

9 clear picture of what's going to be useful to do.

10 MR. HAGERMAN: Yeah, so this is Joe

11 Hagerman. So likely by, you know, they're going

12 to -- they're supposed to give me the analysis

13 Thursday or Friday so if you could give us maybe

14 two packages, right, just as a straw man, I think

15 that would be something that they could reasonable

16 get accomplished by then.

17 I mean, they do have the capability of,

18 you know, modeling increments of values but it is

19 very time-consuming. All right?

20 MR. RAMIREZ: Let me -- I'll throw this

21 out there. It might (inaudible) up the works, but

22 --
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1 UNIDENTIFIED SPEAKER: (Inaudible).

2 MODERATOR HOFFMAN: Oh, Robin. Oh, yes.

3 MR. ROY: It's the same thing I've said

4 a few times, it's nothing new.

5 MR. RAMIREZ: You know what, Robin, just

6 really quick though. That's new to us, putting

7 the placard like that.

8 MR. ROY: Is it?

9 MR. RAMIREZ: I like it. I'm just not

10 used to it.

11 MR. ROY: Okay.

12 MODERATOR HOFFMAN: Oh, yeah, cause we

13 have a manual also.

14 MR. RAMIREZ: Yeah, okay. We're just

15 not used to it, we're not ignoring.

16 MODERATOR HOFFMAN: Maybe that should be

17 a rule, a ground rule we didn't --

18 MR. ROY: I'm sorry.

19 MODERATOR HOFFMAN: -- you've done

20 before without us.

21 MR. ROY: Can we use this as a sign in

22 the future?
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1 MODERATOR HOFFMAN: Yes.

2 MR. RAMIREZ: Yeah, yeah.

3 MR. ROY: It's sort of further to

4 Lowell's point. It's very useful to have more

5 cost information sooner than later and I

6 appreciate the PNL is not working towards any cost

7 information. But perhaps it can be -- maybe we

8 can make a request as a working group of DOE to

9 start populating to the best of Navigant or PNL.

10 I'm not sure who you'd want to delegate this

11 assignment to, populating the incremental cost

12 associated with a different efficiency levels that

13 are being represented in this PNL work.

14 We will undoubtedly have many comments

15 on those -- those proposed costs, but it would be

16 very useful to have that structure and to have

17 that starting point information of what DOE has

18 been able to glean and DOE's contract has been

19 able to glean. And it's not going back to the --

20 to the old 2010, '11 analysis, it's what you're

21 thinking now. So it's just another assignment to

22 give to your consultants.
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1 Would we think that's a useful thing for

2 them to start populating? Can we show a thumbs?

3 MR. HAGERMAN: All right. So this is

4 Joe Hagerman. Absolutely double thumbs up on

5 that. The only cost that I'm aware of that we've

6 received is in the RFI and it was pretty thin. So

7 if manufactures could again the route to sign an

8 NDA with Navigant and supply some cost and

9 shipment data, that would be great, or you can

10 just submit it through the, you know, public

11 comment -- I mean, the comment process too, so.

12 MR. ROY: Robin again. I'd also suggest

13 that these PNL and Navigant folks are incredibly

14 bright and cross a lot of information and I would

15 love to see what their hunches are even if they

16 can't refer to something specifically within this

17 docket. As a starting point, it would be useful.

18 They have all sorts of resources and experience

19 and, you know, if they start populating that. If

20 you wait, it's not going to go faster.

21 MODERATOR HOFFMAN: So are you -- is

22 this a suggestion --
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1 MR. ROY: It's a -- it's a continuation

2 of my original one which I was asking for a thumbs

3 up from for --

4 MODERATOR HOFFMAN: That is asking of

5 DOE but also with some assistance if needed?

6 MR. ROY: All the magic that PNL and

7 Navigant usually brings to a problem. They bring

8 great genius to most problems. I think they make

9 a few phone calls. Sometimes you won't get

10 information thrown over the (inaudible) and

11 they'll have to go out and solicit it. I think

12 they're incredibly capable of doing so.

13 MODERATOR HOFFMAN: Is this a request

14 that has the endorsement of the entire working

15 group? That's what -- is this -- does everyone

16 understand the request?

17 MR. LUTER: There was a lot of words

18 coming out of your mouth.

19 MR. ROY: Cogent (sic) queries and

20 requests are not my forte.

21 MR. RAMIREZ: Headline.

22 MR. ROY: Headline.
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1 MODERATOR HOFFMAN: Elevator speech.

2 MR. ROY: Yeah, the working group is

3 requesting the Department of Energy to begin

4 populating its energy models with a first -- a

5 first estimate of incremental costs for the

6 measures that are going beyond the current HUD

7 code.

8 MR. LUBLINER: This is Mike Lubliner.

9 We've got costs dated I thought we submitted

10 during the RO5. This is work we did for the

11 Department of Energy, (inaudible) administration.

12 We surveyed all the manufactured region that's in

13 partnership on energy and were able to get some

14 reasonably good cost data on those things. So,

15 Joe, if you don't have that, I can get it to you

16 or you can get it from BPA.

17 MR. HAGERMAN: So thank you, Michael.

18 The general counsel's office just helped me

19 remember something. So in 2011 I think their

20 office and DOE reached out to a lot of the

21 manufactures asking for a call stata, and all

22 their discussions should be on the docket, some
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1 docket, right. So maybe we could circulate that

2 document and see if we should update the

3 information that you already provided.

4 MR. LUBLINER: Sure.

5 MR. JENSEN: Just to echo that point,

6 this is Michael Jensen from the DOE Office of the

7 General Counsel. We about four years ago we

8 reached out to half dozen, a dozen or so

9 manufactured home owners and manufacturers and

10 many of you who are maybe represented in this

11 room, and we received quite good information and

12 all that's published on regulations.gov, dewey's

13 docket, and there's a manufactured housing website

14 on the DOE Office of Energy Efficiency and

15 Reliable energy home page that contains a link to

16 that document where you can see the conversations

17 that we did have back in 2011. So it would be

18 helpful for DOE if we could actually -- if those

19 of you that we did have conversations with could

20 review those -- that information at this point and

21 let us know if there's any information that needs

22 to be updated.
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1 MS. DICKENS: Could you share that link

2 with all of that, please? I don't know what

3 you're talking about.

4 MR. JENSEN: I don't know the exact link

5 offhand.

6 MR. RAMIREZ: Could it be sent out to

7 the work group?

8 MS. DICKENS: Could it be sent out to

9 our group though?

10 MR. JENSEN: It can be sent out.

11 MS. DICKENS: Yeah, thank you.

12 MR. JENSEN: It's on the DOEERE

13 manufactured housing website and I'll send a link

14 after this (inaudible).

15 MODERATOR HOFFMAN: You'll send it to

16 Emily and to Javier and we can send it to

17 everyone?

18 MR. JENSEN: Yes.

19 MR. ROY: Robin Roy. That's fantastic,

20 that will be very useful. But I now having heard

21 that, I doubly implore DOE to start populating

22 with costs and urge it not take the approach --
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1 DOE not take the approach that the members of this

2 subcommittee or this working group pour through a

3 docket that's several years old to try to update

4 pieces of it. It would be much, much more

5 effective of everybody's time if DOE would start

6 populating a model on its own much more concise

7 for everybody's input.

8 MR. LUBLINER: This is Mike Lubliner. I

9 agree with Robin also. Resources that you might

10 be able to get cost data from -- including I

11 suggest you look at NAIMA for insulation, also

12 insulation prices in the kind of bulk procurement

13 quantities that this industry's used to procuring

14 them. So that might handle a lot of the

15 insulation, both the floor, the wall and the

16 ceiling insulation.

17 Then for windows, we have Rob at NFRC

18 might be an organization that could help provide.

19 Some of these individual insulation window

20 manufacturers are uncomfortable sharing their own

21 information, they like to go through their own

22 organizations for -- to avoid a perception of
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1 collusion on prices and stuff.

2 So those would be two areas, NFRC and

3 the NAIMA group for insulation.

4 MR. RAMIREZ: So there's a couple

5 things. I need to back up here because I want to

6 tighten this up a little bit so that way these

7 ideas aren't just thrown out there and these are

8 great ideas but nobody's following up on them.

9 All right. So on the subcommittee, it sounds like

10 Michael's going to take the lead on that and we

11 have Eric Lacy, Emanuel Levy and Lowell Ungar.

12 Now if I'm understanding everyone's role

13 here, who's the builder rep on there? Is there a

14 builder rep on there? I think that's missing,

15 right?

16 MR. LUBLINER: I hope I didn't scare

17 these guys away.

18 MR. RAMIREZ: What I'm getting at is if,

19 look, if you're going to be throwing some possible

20 scenarios to have the study in there, I think it

21 might be worthwhile having a builder rep in that

22 subcommittee.
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1 MR. LUBLINER: I totally agree. I don't

2 want to be preaching to the choir here, I want to

3 get a good dialogue on this committee with the

4 industry.

5 MR. SANTANA: I would have volunteered

6 to join. I can see the initial --

7 MODERATOR HOFFMAN: Push your button.

8 MR. SANTANA: Yeah, it's pushed, it's

9 just too far from my mouth. You know, I'd like to

10 see the original reports that DOE came up with,

11 then I can see what's missing before we just throw

12 out some pie in the sky stuff.

13 MR. RAMIREZ: And from what I

14 understand, that's going to be coming out pretty

15 soon. I think -- I think the whole subcommittee

16 wants that to get an idea of how that looks and

17 then to be able to create a scenario. So, yeah,

18 you would the --

19 MR. SANTANA: It just looked a little

20 preemptive to set it up and, you know, we wouldn't

21 be able to do anything we validate the report.

22 MR. RAMIREZ: Right, you probably
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1 wouldn't meet until you get that. So is it safe

2 to put your name on there?

3 MR. SANTANA: Yeah.

4 MR. RAMIREZ: Great, so we'll put Manual

5 Santana.

6 MODERATOR HOFFMAN: All right, Eric.

7 MR. LACEY: Eric Lacey. Just for the

8 sake of scope, my intention is not to put out the

9 extreme potential for every single component of

10 the building, but maybe to find a handful of areas

11 where we think either there's an existing that

12 goes beyond or a commonly used standard or

13 something where we think -- or a product or

14 something that we think would work. And for that,

15 I think the input of the manufacturers and

16 builders would be very helpful, you know. The

17 could point out that, you know, without endorsing

18 a specific practice could say here's an area where

19 you might test out, you know, whether this is cost

20 effective. But at least I wouldn't see us going

21 into every single aspect of the building and

22 asking PNL to go and, you know, give us
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1 calculations on everything.

2 MR. HAGERMAN: Maybe with Emanuel's

3 placard up, that means he's nominated himself to

4 help you guys.

5 MODERATOR HOFFMAN: He's already on it.

6 MR. HAGERMAN: Oh, you're already on it?

7 MR. RAMIREZ: Emanuel's been patient.

8 He's been -- I was just trying to back up and

9 tighten some of this stuff up.

10 MODERATOR HOFFMAN: Yeah.

11 MR. RAMIREZ: But go ahead, go ahead.

12 MR. LEVY: Emanuel Levy. A couple

13 things. Lowell had brought up the issue about how

14 do you organize this process and I just want to

15 throw one more thing on the table just to add

16 confusion to the - - to the mix. There's another

17 program called BEopt which is run by another

18 laboratory which generates curves like that. It

19 does the same thing Energy Plus does and it does a

20 cost benefit curve.

21 And the way -- so that might be worth

22 looking at too and PNL can run that software, it's
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1 called BEopt.

2 What they need, and I think it's been

3 discussed around the table, is both energy

4 information which, you know, can generate, and

5 cost information in which some of which they have,

6 some of which we can provide as industry. Some of

7 which we're going to have to be more creative

8 about because there are a lot of options that Eric

9 and Lowell alluded to more efficient items that

10 are typically considered now for which if we ---

11 we were going to include them, we'd have to come

12 up with the price and it would have to be a price

13 that is comparable to the price that we're going

14 to quote for insulation, which means car load

15 quantities sold to the industry and that's as much

16 art as science to come up with that information,

17 so it would be good to have somebody from industry

18 who participates in that process and can

19 contribute to that discussion.

20 But I don't think -- I think what we're

21 coming up with here is a series of a larger group

22 of actions that we can, we don't have to worry
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1 about it whether it fits within IECC or just a

2 series of options so that we can create a spectrum

3 and a curve like what you see up here. It doesn't

4 have to be part of a standard today, so we don't

5 have to worry specifically what's in the

6 standards.

7 Later on we can go back and show on any

8 one curve that we generate where the standard

9 falls. But right now I think we're only concerned

10 with a series - - largest series of options that

11 we can put together, for which we can get both

12 energy, use information and cost.

13 MR. DENNIS: So it seems like, you know,

14 we have the ability to model the energy components

15 of some of these kind of above like ICC codes.

16 But the cost analysis is kind of a separate

17 component. And, you know, before throwing a much

18 of max tech information into the energy models, it

19 might be good to also pair those with the cost

20 that we could all kind of review and say, okay,

21 now we're not going to just do analysis and we

22 don't have the cost and have five analysis and
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1 then say, oh, this one, let's just do cost on this

2 one. It might make sense to have line item, you

3 know, things and costs and kind of go through it

4 and say, we're not, you know, running it and then

5 later saying, well, the cost of this is actually

6 because a subgroup looked at it or there was no

7 cost in it and they just wanted to see what the

8 max tech would look on energy.

9 And like Lowell was saying, it's in a

10 vacuum. How much energy you save doesn't relate

11 to cost effectiveness without the cost part. So

12 it might make sense to kind of come up with, you

13 know, these scenarios for the model also with cost

14 before spending the time and resources to run the

15 models when we're not sure we're going to have the

16 cost or they're going be technology.

17 And the other thing besides cost is also

18 practical considerations that might, you know, not

19 allow a technology. We've seen it in other

20 standards like transformers or something where the

21 cost might look a certain way but there's a, you

22 know, some kind of supply chain problem or, you
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1 know, all these things could maybe be worked out

2 so that we're not just working in an ideal world

3 where, you know, it's max tech but.

4 MR. CYMBALSKY: Yeah, this John from

5 DOE. So all of that will come in at some point,

6 but you got to start somewhere. There's no reason

7 to sit around and wait for things to happen.

8 Clearly, you know, if we don't know the

9 cost of something, you're not going to set a

10 standard around it, I don't think, so.

11 MR. RAMIREZ: So it sounds like we're

12 going top start off with the initial study, it's

13 about done. That's going to go out soon. And then

14 the subcommittee will, once they have it, look at

15 it and see what other scenarios they would like to

16 see run.

17 But could I suggest, Emanuel, that work

18 with Joe and if there are things on the study that

19 you would like to see, can it look like this, can

20 you do that? Can you work with him on that to try

21 to capture some of the points that have been

22 discussed here?
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1 MODERATOR HOFFMAN: And also, I'd just

2 add we have a consensus request, I guess, to begin

3 populating energy models with, what does that say,

4 first estimates of incremental costs from measures

5 to ask DOA -- DOE to help with, and the whole

6 committee has asked you to do that, so hopefully.

7 MR. ROY: Just to clarify the last line

8 of the sentence up there, it's not just to use the

9 2011 information to populate the study, but it's

10 to use that in other sources that the geniuses at

11 Navigant and PNL and DOE can bring to bear. They

12 do amazing work whenever given such commission.

13 MODERATOR HOFFMAN: And any questions on

14 that?

15 MR. CYMBALSKY: I mean this is standard

16 fair for these guys. There's nothing earth

17 shattering here, we do it all the time.

18 MODERATOR HOFFMAN: Okay.

19 MR. CYMBALSKY: We just need to get, you

20 know, need to find the data and so that's where

21 again any information the manufacturers can

22 provide, whether it be by the NDA route or public
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1 route, either way you want to do it, that's going

2 to help. Otherwise we'll go with what we have,

3 just like we do in other rankings.

4 MR. ROY: Can I request, and I

5 understand it's very hard to do, but if it's

6 possible at all to get that in two weeks before we

7 come back here because we're coming back here two

8 weeks from tomorrow.

9 MODERATOR HOFFMAN: Right.

10 MR. ROY: Wow, how much fun. If we

11 don't have that, it's going to be a much less

12 productive session that it will be with it. And

13 even recognizing that it will probably be

14 populated with a lot of things that we'll all have

15 many comments on. That would be very helpful.

16 MR. HAGERMAN: Yes, this is Joe Hagerman

17 and I totally agree with you and John and I have

18 discussed about seeing if PNL could go ahead and

19 add costs, whatever costs that they have already,

20 go ahead and add that to the analysis they're

21 going to deliver at the end of the week.

22 MODERATOR HOFFMAN: How do you feel now?
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1 MR. HAGERMAN: We're not trying to slow

2 -- trying to slow things down here, right. Those

3 geniuses can work faster.

4 MODERATOR HOFFMAN: Almost dismissed, a

5 couple of things. We're not dismissed yet.

6 MR. RAMIREZ: No, no, we're not

7 dismissed. No, just a -- on a happy note.

8 MODERATOR HOFFMAN: Yeah, right. Yeah,

9 because we also have at 3:00, we said we'd have

10 public comments so we -- yeah.

11 MR. RAMIREZ: Oh, you know what? We --

12 the group yesterday talked about possibly staying

13 till 5:00 if we needed to, right. But on the

14 agenda we had that at 3:00 was going to be public

15 comment.

16 MODERATOR HOFFMAN: So we should honor -

17 - I think we should honor that. The 3:00 public

18 comment you can -- people who've been listening

19 and waiting in the back, if they have any

20 questions and, yeah.

21 MR. RAMIREZ: Let me see if we could

22 finish this.
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1 MODERATOR HOFFMAN: Sure.

2 MR. RAMIREZ: I think we're almost done

3 with this one, right, and then we go to public

4 comment. So is it -- Joe, it sounds like you got

5 your hands full as far as communicating some stuff

6 to PNL, but is that good enough for number one at

7 least for now, as far as information needed? So

8 we have the subcommittee that's going to be

9 working and probably running out some different

10 studies but -- and Emanuel's going to work with

11 Joe once they get the study, say look, could we

12 tweak it this way or that way so that we could use

13 that information the best that we can.

14 MODERATOR HOFFMAN: And that's for

15 number one envelope of the building?

16 MR. RAMIREZ: Yeah.

17 MODERATOR HOFFMAN: That's the one,

18 okay.

19 MR. RAMIREZ: Okay?

20 MODERATOR HOFFMAN: Yes, Lowell.

21 MR. UNGAR: Just mention I -- it seems

22 to me eventually we're likely to need perhaps like
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1 a sensitivity analysis on -- particularly on air

2 leakage and possible glazing percentage, and I

3 think it's probably premature to do anything on

4 that now. I think we should wait to see what

5 assumptions PNL is making, but I suspect that will

6 then come into the discussions. We'll need some

7 way of determining what

8 --

9 MR. RAMIREZ: Is that under building

10 performance?

11 MODERATOR HOFFMAN: Or an envelope for

12 the building?

13 MR. UNGAR: Or envelope or both, I don't

14 know.

15 MR. RAMIREZ: Okay, okay. But either

16 way, that would not be number one?

17 MR. UNGAR: I'm just saying I don't -- I

18 don't -- I'm not saying we should do anything

19 about it now, I just think those are going -- you

20 know, the question will come not just for these

21 packages, but how do you deal with, you know, when

22 we get down to these issues, I think those are
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1 going to be -- come into play, we'll need to work

2 it out somehow.

3 MR. RAMIREZ: Make that comment again

4 when we get there so we can add it in there.

5 MR. LUTER: Rob Luter.

6 MR. LUBLINER: This is Mike Lubliner.

7 I'm sorry, Rob. Go ahead, Rob.

8 MR. LUTER: Just briefly, the HUD Co

9 does have some prescriptive minimums for a glazed

10 area based as a function of square foot. I would

11 hope that the lab's following those minimums. One

12 would assume, right?

13 MR. HAGERMAN: One would assume that

14 geniuses would be following those minimums.

15 MR. LUTER: Well, but it's part of the

16 HUD Code, it's not part of the IECC, so.

17 MR. HAGERMAN: Right, they're making a

18 HUD Cole model as your base line.

19 MR. RAMIREZ: Okay. So I want to try to

20 keep you folks in cause that sounds like that's

21 under one of the other bullets, right?

22 MR. HAGERMAN: I sort of think we're at
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1 ELMO situation with the analysis, right?

2 MR. RAMIREZ: That's what's I'm trying -

3 -

4 MODERATOR HOFFMAN: Right. We're moving

5 ahead.

6 MR. RAMIREZ: That's what I'm trying to

7 get (inaudible), yeah.

8 MR. HAGERMAN: Okay. I think we've

9 beaten the dead horse like four times already. Is

10 there a rule about that, too?

11 MODERATOR HOFFMAN: Yeah.

12 MR. RAMIREZ: I'm sorry, Michael, do you

13 have something?

14 MR. LUBLINER: Yeah, I just wanted to

15 get clear on how we're going to look at mark-ups

16 from material cost to retail. There has been

17 historically values that the industry's shared and

18 we've used to take, say, the crude cost of

19 material, factor in their overhead profits and

20 costs and then the retails profits so that we get

21 something that's more closer akin to what the

22 consumer's going to see in price.
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1 So that's an area that I would hope that

2 we're going to get into as well as the mark-ups

3 from materials. And I understand that can be

4 confidential so we need to be sensitive to the

5 industry on that stuff.

6 MODERATOR HOFFMAN: Okay.

7 MR. RAMIREZ: Okay. Public comment and

8 then once we're done with public comment we'll

9 take a break and then come back.

10 MR. SURRENA: Don Surrena, National

11 Association of Home Builders.

12 Today when you were talking about the

13 impact, the increase in cost for manufactured

14 housing, I had our economics department run some

15 numbers. And we estimate that in 2014, the

16 average price of -- this is for entry level, not

17 some of the more specialty things -- for

18 manufactured homes, including the cost of lot

19 development is about $53,000 for single homes and

20 $100,000 for double homes.

21 The increase of the price for a single

22 manufactured by $1,000 will disqualify 347,901
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1 households from being able to afford these homes.

2 Similarly, if the price of a new double

3 manufactured homes raises $1,000, 315,385

4 households will be priced out of the market.

5 The effects are not cumulative since

6 they're based on the same income distribution of

7 all U.S.

8 households. There are not effects on

9 sales -- these are not effects on sales, rather

10 only on the ability to qualify for a mortgage.

11 So when you raise the cost of housing,

12 irrespective of whether it's manufactured housing

13 or single-family housing, there are people who

14 just won't be able to qualify for it. If you

15 qualify them out of the market, then they stay in

16 the same older energy inefficient homes that

17 they're in already.

18 And if you raise the bar too high, they

19 won't go in at all. But if you raise it at level

20 where they could still get in but they're in

21 better housing than they were, the energy

22 efficiency of the country improves. The carbon
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1 footprint is better if you can't keep those things

2 in mind.

3 When we talked about the IECC, and I

4 understand it's already in legislation, the IECC

5 was made and designed for stick built single6 family detached housing. It never had any

7 intention of being covered for manufactured

8 housing. There are just some things that you

9 can't do in manufactured housing, especially the

10 single wide, that you can do with a stick build or

11 even a double wide.

12 The buyers of manufactured housing are

13 affected to a large degree for qualifying for

14 mortgages. They aren't mortgages of standard

15 housing, they're a lower income bracket. And

16 being able to afford a home for people living in

17 older homes is what we're trying to do. That's

18 what HUD was mandated to do, was to follow low

19 income or affordable housing. Not affordable

20 housing for myself or affordable housing for

21 possibly some of us in this room, but for people

22 who can't get a single-family detached home or
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1 they just need housing in an area for replacement

2 housing.

3 We talked about comfort. Comfort is not

4 an enforceable or a buildable result. It is the

5 determination of each individual. The codes, the

6 building code and the residential code, set a

7 minimum for the minimum amount of heat that is

8 required to be in a home to make it livable.

9 There's nothing that goes on the opposite scale to

10 say what the minimum cooling is. There's no

11 requirement in the codes for cooling. There's

12 talk of it but it hasn't occurred yet.

13 And fenestration in the codes again is

14 set for standard housing where the width and depth

15 of the frame is not conducive to single-wide

16 housing, manufactured housing. It's just not

17 there with the fenestration that is called out in

18 the codes.

19 I just wanted the working group to be

20 aware of these things and have them there to think

21 about and talk about. And if you would have any

22 questions, feel free to email me. I'd be glad to
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1 get my email address out to whoever would like to

2 have it. Thank you very much for this time.

3 MODERATOR HOFFMAN: Thank you. Thank

4 you very much for your comments.

5 Okay, anyone else? Well, then, given

6 that we want to take a, how long, 10? A 10-minute

7 break, we come back, we'll be finishing up. Okay,

8 so come back in 10 minutes please.

9 (WHEREUPON, a brief recess was

10 taken.)

11 MODERATOR HOFFMAN: Okay, we're back

12 from break. A couple of small announcements. One

13 is that there's a very nice list that Brenda from

14 DOE has put together of everyone's business card,

15 so if you want a copy of who was here for today,

16 it's out there.

17 Okay. Second, we're hopeful we might

18 end at around 4:00 or earlier. We had originally

19 said we'd leave at 3:30, but we got a request to

20 stay till 5:00 and my sense is the energy level is

21 such that we'll see what we can do. But really

22 what we want to do know is go through and see if
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1 there are anymore assignments or data and then

2 just recap, tell you about the next meetings and

3 tell you sort of a tentative agenda that we're

4 thinking of. Okay?

5 MR. RAMIREZ: All right. So looking at

6 2, 3 and 4 and I'll put that out there broadly,

7 right? What information do you think you

8 absolutely need that you could identify at this

9 moment? It's not like if you don't mention it

10 today, the door's closed, all right, but at least

11 for now, what information have you been able to

12 identify for those areas?

13 MR. LUTER: Can we zoom in a little more

14 (inaudible).

15 MODERATOR HOFFMAN: Yeah.

16 MR. RAMIREZ: So let's start with 2.

17 Yeah?

18 MR. WEISS: Well, just consistent with

19 what I've asked for previously, if we could get

20 the relevant sections of AShrae 62.2 or what folks

21 think is relevant, believe is relevant, that would

22 be helpful.
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1 MR. RAMIREZ: Joe has something that --

2 MR. HAGERMAN: Yes. Both the AShrae and

3 the ICEE are copyrighted, so we'll have to think

4 about how to provide copies of that, but we're

5 looking at that. We've talked to both our

6 contractors about it.

7 MR. LUTER: Rob with Lippert. Are we

8 looking for the information we would like to

9 evaluate how these bullet points are going to

10 effect our end energy analysis or -- for example,

11 are these items addressed in the IECC right now?

12 My understanding is IECC is construction. Do we

13 have appliances or heat, you know?

14 UNIDENTIFIED SPEAKER: So I think some

15 facets of everything that's up there is addressed

16 in the ICC. I mean, the ICC doesn't cover

17 appliances. They don't cover hot water heaters or

18 water heaters, but they do cover things like the

19 insulation on water heaters.

20 MR. LUTER: Okay.

21 UNIDENTIFIED SPEAKER: Or insulation on

22 pipes that deliver hot water.
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1 MR. LUTER: So the context would be what

2 information are we looking at as these things

3 apply --

4 UNIDENTIFIED SPEAKER: Yeah, absolutely.

5 MR. LUTTER: -- to the IECC currently,

6 okay.

7 UNIDENTIFIED SPEAKER: I think I

8 understand the intent, too.

9 MODERATOR HOFFMAN: Mark?

10 MR. WEISS: Yeah, I think I understand,

11 too. I mean, this is not a final statement of

12 what's relevant to the encore necessarily.

13 MR. RAMIREZ: Good for 2? This is the

14 auction. Going once, going twice.

15 MR. HAGERMAN: I will say that I will,

16 you know, I just ask PNL to provide the --

17 whatever costs they have to their analysis as well

18 and I'll get them to tell you what the sources of

19 for their costs, so that's the best I can do

20 without you all submitting information.

21 MR. RAMIREZ: All right. So, Emanuel.

22 MR. LEVY: I just realize as we're
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1 talking about this. In terms -- if we want to get

2 to cost benefit analysis, we need more than just

3 the cost of the items, we need the economic

4 assumptions that go into the (inaudible) cost

5 calculation. Things like discount rates, rule

6 escalation rates, rule rates, energy costs and

7 those kind of things. So I think there's probably

8 a longer laundry list of financial assumptions

9 that go into the cost benefit analysis that we

10 need to get ahold of.

11 MR. RAMIREZ: All right. And I think I

12 picked the right person then, huh, to work with

13 Joe?

14 MR. HAGERMAN: Let us first -- let us

15 try to answer that because, you know, we get a lot

16 of the -- a lot of the fuel costs, for example,

17 from EIA projections and everything, so. So let

18 us try to just respond to all this and show you

19 how we're responding before you just litter us

20 with a lot of information like that. There's a

21 stuff that the department already does in terms of

22 energy costs.
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1 MR. RAMIREZ: Some of it may be doable,

2 some may not, but I think that if you -- once you

3 get it, see what's missing, work with it.

4 MR. LEVY: Anything specific under

5 financial?

6 MS. EPPERSON: Stacey, Next Step. I

7 think we're going to have to have data to

8 understand the current income levels, people

9 buying manufactured homes, so I think there's a

10 couple we can go for that to industry and some

11 other studies that have been done since this data

12 and I volunteer to help work on that.

13 MODERATOR HOFFMAN: Is there someone --

14 would you like someone to work with you on that?

15 MS. EPPERSON: It might be appropriate

16 to form a subcommittee --

17 MODERATOR HOFFMAN: Subcommittee.

18 MS. EPPERSON: -- in this area since

19 it's such a large area to look at.

20 MR. RAMIREZ: All right. And let's do a

21 new subcommittee -- subcommittee to gather

22 financial data.
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1 MS. EPPERSON: Financial data. Then

2 we're also going to have to look at financing

3 that's available. You might as well look at that

4 at the same time and look at averages with what's

5 going on in the industry, look both at personal

6 property finance and conventional mortgage

7 financing what's available and what those rates

8 are.

9 MODERATOR HOFFMAN: Who would like to

10 work -

11 -

12 MR. RAMIREZ: Stacey Epperson.

13 MODERATOR HOFFMAN: And also guess who?

14 Lois.

15 MR. RAMIREZ: Robin Roy.

16 MODERATOR HOFFMAN: And, wait, Robin and

17 Mark.

18 MS. DICKENS: And Ishbel.

19 MODERATOR HOFFMAN: And Ishbel, a

20 popular group, okay.

21 MS. DICKENS: Because I think that I'd

22 like to just know standard prices of homes
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1 themselves. I don't know even what homes cost.

2 MODERATOR HOFFMAN: Okay.

3 MR. RAMIREZ: Okay. So I have Stacey,

4 Robin, Mark, Ishbel --

5 MODERATOR HOFFMAN: And Lois.

6 MR. RAMIREZ: -- and Lois. Was that it?

7 MODERATOR HOFFMAN: I think so.

8 MR. RAMIREZ: And Stacey, is it okay to

9 put you as the point person on that to reach out

10 to them and --

11 MS. EPPERSON: Yes.

12 MR. RAMIREZ: Okay, then is that it for

13 3? 4? Anything we need here or a lot of this

14 covered under No. 1, but is there anything

15 additional you think under 4?

16 MR. EZZO: This is Mark. I think the

17 main we're going to need is a copy of the

18 residential section of the 2015 IECC because a lot

19 of what's under 4 is covered in the code. And I

20 think, Mark, you mentioned, it's not, you know the

21 IECC 2015 is -- it's maybe a couple hundred pages,

22 but the residential section is not huge, it's 20
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1 pages.

2 So I know someone was saying, I think

3 Joe might have said it's copyrighted. You can't

4 just make a photocopy of it and PDF it to

5 everybody, but it's available on line, you can buy

6 it and probably have it in your office in a week.

7 UNIDENTIFIED SPEAKER: (Inaudible).

8 MR. EZZO: Okay.

9 MR. LUTER: Let me add something, if I

10 could. Rob with Lippert. The notion of an

11 organization like the Code Counsel or AShrae or

12 anybody furnishing free of charge a copy of the

13 publication for use with a group like this, it's

14 not without precedent, it goes on all the time.

15 They come out watermarked on the -- electronically

16 watermarked just as if we'd buy it and it's for

17 the common good.

18 I would reach out to them and find out.

19 I mean, they can say no or not.

20 MR. RAMIREZ: Sometimes my hearing isn't

21 too good. Did you say you're going to reach out

22 to them?
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1 MR. LUTER: Well, I would suggest that

2 the DOE reach out to them. I mean that's --

3 MR. HAGERMAN: Yeah, that's what we're

4 going to do. That's the process.

5 MR. LUTER: I would not be surprised if

6 they would say no, we'd be glad for you.

7 MR. HAGERMAN: Yeah, worst case, we just

8 buy you all a copy.

9 MODERATOR HOFFMAN: And the third thing

10 is Eric I think has a copy.

11 MR. HAGERMAN: I mean, it's like 30

12 bucks, yeah.

13 MODERATOR HOFFMAN: Eric has one he can

14 send us.

15 MR. HAGERMAN: It's only 30 bucks, so

16 we're going to resolve it. All right?

17 MODERATOR HOFFMAN: Okay. We'll go with

18 that first.

19 MR. HAGERMAN: I'm not going to promise

20 tomorrow. I mean, you all are giving me a, you

21 know, a lot of action items I dare to say.

22 MODERATOR HOFFMAN: The to-do list to
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1 die for, there it is. Well, that's great.

2 MR. DENNIS: Just background. On

3 durability, one of the problems that we find is

4 that the housing stock, you know, they're designed

5 a certain way and then they kind of start

6 deteriorating and then we have energy problems

7 with, you know, a lot of demand and a lot of

8 consumption. So there is a real value to having a

9 durable product in terms of not having a

10 (inaudible) as an existing home later. I don't

11 know how that's incorporated into the standard,

12 but is that something that is factored in? And I

13 mean our problem ends up being with existing --

14 that we try to go retrofit and it's so expensive,

15 but we have so high bills that we need to do it.

16 So that upfront durability, whether or

17 not there's a heat pump or whatever, if the ducks

18 are falling or something like that five, 10 years

19 down the road, we run into a lot of problems. So

20 there's a value to durability. I don't know if

21 it's financial or how that's incorporated. Any

22 background would be appreciated, but that's a real
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1 consideration for us, I know.

2 MR. RAMIREZ: So what -- what do we --

3 what could be gathered here, who would get that?

4 MR. DENNIS: Well, there's a metrics

5 that's taken into account. I don't know if there

6 any data that we use or what has historically been

7 done. Is it just a kind of qualitative statement

8 or qualitative statement or, you know, if the

9 measures are going to - - you know, certain

10 measures are not going to work if the envelope's

11 falling apart, whether or not it's appliance or

12 heating HVAC. It's important that there's a

13 durable envelope as well as, you know, a thick

14 envelope.

15 MR. RAMIREZ: So has anybody has that

16 information?

17 MODERATOR HOFFMAN: Data or is there any

18 data or metrics on durability (discernible)?

19 MR. CYMBALSKY: No, I mean, I would look

20 to the manufacturers and others for that. We

21 typically don't -- they could speak to a -- the

22 DOE's not going to speak to that.
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1 MR. RAMIREZ: So let's ask the group.

2 Is there -- is it that out there?

3 MR. LUBLINER: This is Mike Lubliner.

4 MR. RAMIREZ: Go ahead, Mike.

5 MR. LUBLINER: The durability, I think

6 one of the things we might want to do is look at

7 the ICC codes and their recommendation for pan

8 flashing of windows and a weather-resistant

9 barrier. We introduced this discussion to the

10 consensus committee about four years ago, the HUD

11 consensus committee and has nowhere as far as I

12 understand.

13 But if we're going to talk about being

14 equivalent to site built in terms of durability so

15 that we can get the kind of financing that site

16 built gets, I think it's important to look at

17 what's in their code for durability and see what

18 the costs are even if we can't calculate the

19 economic intangibles in the life cut cycle cost

20 analysis. Thank you.

21 MR. RAMIREZ: Michael, what's the name

22 of that group that you said?
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1 MODERATOR HOFFMAN: Or that's the

2 manufacturer's consensus. But you do another one,

3 site built?

4 MR. LUBLINER: If you go to the eye

5 codes, the ICC and you'll see in the precise built

6 building codes, there's a requirement for weather7 resistant barriers, that keep rain and moisture,

8 things like tie vac, all the manufacturers have

9 them. I know that the industry uses them in

10 modular and so they probably have the cost

11 associated with it and some experience as far as

12 callbacks and durability issues that they see from

13 using those products.

14 But I think it gets back to the previous

15 commoners that we need to be able to track these

16 benefits even though we can't use them in the

17 economic analysis per se.

18 MR. RAMIREZ: Okay, Emanuel.

19 MR. LEVY: Yeah, Emanuel. Yeah, there

20 are a couple different aspects of that question.

21 One is the durability you could include under that

22 lifetime of certain measures; for example, certain
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1 kinds of equipment are going to have a shorter

2 lifetime than the life of the home. Maybe

3 compression lasts 10 years. That kind of

4 information there is some track record on and it

5 can be included in the analysis, the cost of

6 changing that equipment out.

7 But the durability of the home, I think

8 we have some anecdotal data but it's not

9 substantial enough to be the basis of an economic

10 analysis and you have to tease that of the

11 discussion of durability, the issue of

12 maintenance, how well people maintain their homes

13 because that could be the cause of a lot of

14 failures that we see, even if we're just talking

15 about the energy component, energy-related

16 components.

17 But things like insulation which is --

18 which comes down, falls down from the wall so you

19 have thermal breaks, that is -- that's entirely

20 anecdotal from what we can -- we can see. There's

21 no good data saying what percentage of the homes

22 has that happened in and our experience is not
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1 common but it happens.

2 MR. RAMIREZ: So I'm still struggling of

3 how do we gather this data? Is that something

4 that's just going to have to be -- if you're

5 interested you gather it or where do we go from

6 here as far as assembling that?

7 MR. WEISS: Part of it depends on what

8 you mean by durability for this particular

9 purpose. I mean, durability's a word that's used

10 in the HUD law but -- and I know what context and

11 what that means within that context, but I don't

12 know who raised durability as a part of this but

13 you better define it before you start trying to

14 gather data on it.

15 MR. CYMBALSKY: This is John from --

16 MR. WEISS: If it's relevant at all.

17 MR. CYMBALSKY: The durability is what

18 it is, right, the market does what it does, the

19 units last some expected lifetime based on

20 durability or whatever it is. I think what we're

21 interested here in terms of the term is how

22 whatever we do for efficiency upgrades off of the
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1 baseline would impact the life expectancy. I

2 think that's what -- I don't know, I'm not putting

3 words in Keith's mouth but that's what we do in

4 other rule makings, is if you make that efficiency

5 upgrade, does it impact the useful life of the

6 product, in this case a manufactured home.

7 You know, again I'm not an expert in

8 this subject, but the things we discussed in here

9 I don't see how, you know, if we put in better

10 windows does the product become less durable? I

11 think everyone would say no. If we make the walls

12 a little thicker and does it make it less durable?

13 No.

14 But maybe there are efficiency upgrades

15 that will do that, but otherwise I would suggest

16 we leave this table, this issue of durability

17 unless and what we're doing in terms of --

18 MR. LUBLINER: I got a --

19 MR. CYMBALSKY: -- packaging our

20 efficiency upgrades together would impact it and

21 impact consumer utility based on that.

22 MR. RAMIREZ: So it's very much
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1 situational. If whatever scenario we're talking

2 about, if durability is impacted by it at that

3 time, we could gather the data then?

4 MR. CYMBALSKY: Yeah, I mean, I think

5 that's how we should think about it. It's an idea

6 but if someone else has a different idea.

7 MR. DENNIS: Yeah, and I would just

8 suggest in the back of everyone's head, you know,

9 if there is something that is a little

10 modification to say like belly board, which we

11 have a lot of problems with we end up fixing, that

12 makes -- changes the life span to make sure that

13 that's captured so that, you know, one's going to

14 last 10 years and one is going to last 20 years

15 and all it takes is an extra couple of bolts or

16 something, that it's a different technology with a

17 different, you know, life span so that we can do

18 what we can to get that in there.

19 I don't know if -- we're working within

20 the confines of whatever analysis and data we

21 have, but that's something that is a community

22 that ends of retrofitting this real issue in terms
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1 of issues.

2 MODERATOR HOFFMAN: What's a belly

3 board?

4 MR. DENNIS: The underbelly of, I guess,

5 maybe older manufactured homes or mobile homes.

6 I'm not really a super expert at that either.

7 MODERATOR HOFFMAN: Okay, all right.

8 MR. DENNIS: But that's what I -- that's

9 what we have a lot of problems with.

10 MODERATOR HOFFMAN: Okay.

11 MR. LUBLINER: This is Mike Lubliner.

12 I'd like to make another comment when I can.

13 MR. RAMIREZ: Yeah, go ahead.

14 MR. LUBLINER: We did a -- thank you.

15 We did a study in the northwest to investigate why

16 we weren't getting the preferential lending for

17 the HUD Code industry that we get for site bill.

18 There's a recent study and I'd be happy to share

19 it with you guys. I think it was funded by Bona

20 Bill DOE (phonetic).

21 Anyway, the study of -- one of the

22 findings was is that these lenders and appraisers
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1 were more interested in durability in terms of

2 added value or not depreciating the home. It was

3 more important that it had a weather-resistant

4 barrier than the energy efficiency. And so that's

5 one point and I'd be happy to provide that data.

6 The second thing I want to direct

7 towards Joe in terms of our understanding of the

8 way we do building science within the Building

9 American Program, we take a systems approach where

10 we looked at indoor air quality, durability and

11 energy efficiency as a package. Now I understand

12 for rulemaking here we're focused on life cycle

13 frost and energy, but I don't think we can ignore

14 the impacts of durability whether it's worse --

15 making it worse or making it better.

16 I for one have been living in a

17 manufactured home 15 years, I have a first-hand

18 experience with durability and the impacts of

19 belly insulation that falls out because the tape

20 fall off and the rodents get in. I can give you a

21 thousand different scenarios and I'm not going to

22 do that now. But I don't think we should totally
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1 discard in the discussion, even if it comes in as

2 an added point for the preamble. But I think it's

3 very important, thank you.

4 MR. RAMIREZ: Michael, I don't think

5 that we're talking about that at all. I think

6 what we're saying was we'll deal with it as it --

7 as it occurs. We're very situational. I think

8 that's the only, we weren't talking about

9 ignoring.

10 MR. LUBLINER: Thank you, I appreciate

11 that, thank you.

12 MR. RAMIREZ: Sure. Is there someone

13 else on line that wanted to --

14 MR. HANGER: This is Rick with the state

15 of Colorado. I would also perhaps add the word

16 resiliency to this discussion. It is very

17 important in Colorado as move forward out of our

18 flooding how and when we can use the manufactured

19 product as we rebuild. The durability of that

20 product, the resiliency of that product, it is

21 ultimately going to be very important just how

22 much of that product even gets used in Colorado in
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1 the future, so thanks.

2 MR. RAMIREZ: What's the difference

3 between durability and resiliency as it relates to

4 manufactured housing? Is there a big enough

5 different that we need to -- let's leave it on

6 there, all right. Let's leave it on there.

7 MODERATOR HOFFMAN: Yeah.

8 MR. RAMIREZ: Okay. We'll cross that

9 bridge when we get there.

10 Any other broad information that we --

11 that we need? Okay. Then there's a lot of

12 homework that needs to be done and there were a

13 couple items on here that we just weren't quite

14 sure if -- 5, 6 and 7, we weren't exactly sure

15 where to put those. These were items that were on

16 the original map, so we had that energy labeling,

17 compliance and field versus factor performance

18 testing. How are these thing implemented.

19 MS. DICKENS: I wonder if -- this is

20 Ishbel -- I wonder if these are things that are

21 kind of after we've got the analysis and the data,

22 we then -- they're kind of criteria against which
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1 we'll measure things as opposed to items that

2 actually need research at this point.

3 You know, once you get -- once you

4 figure out how, you know, some of the energy

5 standards are put together, so how would they be

6 implemented performance rather than prescriptive,

7 or why would manufactured homes have to be dealt

8 with differently based on this data analysis. So

9 it might be that there are --

10 MODERATOR HOFFMAN: We can just save

11 that for next steps.

12 MS. DICKENS: -- next steps. If that's

13 agreeable, we'll put it aside, then we've got a

14 lot on our plate but I just wanted to make sure we

15 have it. And it is in our chart so it's not lost.

16 MR. RAMIREZ: Right, it won't fall off

17 the table.

18 MODERATOR HOFFMAN: Okay.

19 MR. RAMIREZ: Then as far as homework,

20 Joe, you have a lot.

21 MODERATOR HOFFMAN: Any more for Joe?

22 MR. RAMIREZ: And then we have the
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1 financial subcommittee and PNL -- what I'll call

2 the PNL subcommittee, right, they're going to do

3 some scenarios. And I guess on the financial end

4 if there's information that you gather that the

5 group will find useful, if you would get that out

6 to the group as possible. You could either send

7 it to Eileen or Joe and we'll forward that on.

8 And then, Emanuel, that's going to be a

9 little later on as far as how to tweet the result

10 of the study or if there's anything needed to be

11 modified or include in there, but that's a little

12 bit later once we see what those initial studies

13 look like.

14 As far as the next meeting goes, we're

15 looking at August 21st, right? We have August

16 21st, August 22nd, September 9, 10, 22, 23 and

17 October 1st and 2nd. But we're not going to need

18 September 21st or 2nd because we're going to get

19 it done by the 22nd, right?

20 MODERATOR HOFFMAN: Right.

21 MR. RAMIREZ: So I think those October

22 dates will work but, you know, we'll see if we
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1 need them or not.

2 So for October 21st, and we will have to

3 send out the exact location. I understand that

4 we're looking at alternate meeting rooms, space so

5 we'll have to get that out to you. It's going to

6 be somewhere in D.C., right, but we'll have to

7 figure that out.

8 MODERATOR HOFFMAN: And you'll also have

9 the go to meeting approach to participate. And

10 you see there's not two levels of citizens.

11 People on -- on line have been just as valuable as

12 they are to folks here.

13 MR. RAMIREZ: And they are -- somebody

14 did ask can they see the map and things like that,

15 and the answer is yes, they can see that.

16 Okay. Then as far as the agenda for the

17 next meeting, I think that it would make sense to

18 start off with any questions on the data receipt,

19 right, we're going to be getting quit a bit of

20 data. Does anyone need explanation on that? And

21 then on these issues here, are we going to be

22 dealing with envelope of building first? Is this
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1 the order for 2nd, 3rd, 4th, and I don't know if

2 it is because I was just typing them in there, so

3 I'm asking you all.

4 Is this the order or how do we need to

5 move it? Are we going to deal with envelope of

6 building first with equipment including

7 appliances; financial or building performance?

8 MODERATOR HOFFMAN: Any thoughts, I see

9 you're nodding

10 MR. LEVY: Emanuel. I think we're

11 probably, if you look at how the standards are put

12 together, we pretty much focus on the envelope is

13 usually the first item out of the gate.

14 MODERATOR HOFFMAN: Okay.

15 MR. LEVY: But it's hard, and then

16 equipment plays into that eventually. But I think

17 there's a -- the discussion about financial

18 probably has to keep a pace of that because those

19 two things play off of each other. So I don't see

20 how you can actually put these in the priority

21 list, priority order, I think they're all kind of

22 dealt with simultaneously.
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1 MR. RAMIREZ: Okay, so, well, let me ask

2 you this. So what if we put 4 -- so it would be

3 envelope of building, equipment, building

4 performance, leaving financial at the end but

5 knowing that that conversation on financial is

6 going to be all throughout?

7 MR. SANTANA: This is Manny with Cavco.

8 You know, I think that if you do with the

9 envelope, the building performance and you get

10 those out, but things like cost, durability and

11 how they're supposed to be built and implemented

12 are probably going to apply to most of those items

13 one by one, you know, so I think that you get

14 through the envelope and the building performance

15 first and then a lot of other stuff is going to

16 apply, you know, to each of the items.

17 MR. KESSLER: This is Bert at Palm

18 Harbor. I agree with Manny. I think before we can

19 even think about cost and durability and some of

20 the other issues that we've discussed, we need to

21 know a couple of things; number one, what are the

22 minimum requirements and whether that is expressed
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1 in the form of a UO or prescriptive. And by the

2 way, the IECC does provide for UO alternates and

3 the industry's used to you dealing with that.

4 And then I think the rest of it is all

5 going to be a function of what is being determined

6 through envelope and whether we're going to go

7 performance or prescriptive.

8 MR. RAMIREZ: Okay. So then that change

9 in the -- the slight change in order that we did

10 here with envelope building equipment and

11 financial understanding that those conversations,

12 financial and prescriptive versus performance are

13 going to be sprinkled throughout, is everyone okay

14 with that order?

15 MR. KESSLER: And, quite frankly, I

16 think the first thing we need to do is decide on

17 the thermal zones and, you know, some kind of a

18 minimum requirement for each before we can do any

19 of the other stuff.

20 MR. RAMIREZ: We had some of that --

21 MR. KESSLER: I mean, if I want to --

22 MR. RAMIREZ: I'm sorry, go ahead.
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1 MR. KESSLER: If I want to evaluate the

2 envelope of a building, I need to know what it

3 needs to be.

4 MR. RAMIREZ: We had some conversation

5 on that where the folks want to look at the data

6 first before we engage in that discussion, but

7 then I also heard there was a second part of that

8 where we also need to get an idea of what we're

9 talking about as far as some of these changes to

10 see how big of a cost it's going to have depending

11 on the number of zones that you ultimately agree

12 upon.

13 So I hear what you're saying. I think

14 the group was already thinking that we might need

15 to start processing some of this out before we

16 nail down the zone. Am I right in that takeaway?

17 Okay. Okay. Then we will get to it. I think the

18 group will decide exactly when. I think you'll

19 know when is the time to nail that one down, but

20 obviously that's going to be on our minds while

21 we're discussing this.

22 MODERATOR HOFFMAN: And I know we're
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1 giving you a lot of homework also, but -- and some

2 of you have done a lot of homework before you came

3 here. There was a lot of other thoughts coming out

4 about this and if you have some thoughts about how

5 to solve these things, bring them with you for

6 next time.

7 But it's a good idea, I'm glad people

8 are holding back a little to see the new data and

9 see how things work. And there's also a synergy

10 being in the room, seeing people and being able to

11 try out ideas and learn from each other. So if

12 you can all possibly get here, or remotely, I

13 think you'll find it's been helpful.

14 And one last comment from me, I know

15 that for many of you, you're used to things

16 happening a lot faster and I don't say that

17 Washington has a -- not really? Oh, good. So the

18 paint is drying in this room, okay. Anyway, I was

19 going to say you will see us moving a little

20 faster next time. But having the data is also

21 helpful but also a common understanding is

22 critical for this.
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1 MR. RAMIREZ: You know what -- we talked

2 about the ELMO, right?

3 MODERATOR HOFFMAN: Yeah.

4 MR. RAMIREZ: But if we're going to be

5 pushing you to go a little bit quicker, you know,

6 you need to tell us on the ELMO right, and you

7 have and I appreciate that but you need to

8 exercise that a little bit more. But also the

9 brake. Because if Eileen and starting pushing

10 you, you know, hey let's move this, you know if

11 you're saying, Javier, I think you're going too

12 fast you need to slow down, we're not going to be

13 offended by that.

14 MODERATOR HOFFMAN: Yea.

15 MR. RAMIREZ: I tell folks I'm skinny

16 but I have thick skin, all right, so don't be

17 afraid to tell us if we need to do something

18 different.

19 MODERATOR HOFFMAN: Yeah, and I want to

20 thank all of you as well as well as our incredible

21 support staff --

22 MR. RAMIREZ: Yes.
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1 MODERATOR HOFFMAN: -- from DOE. What?

2 UNIDENTIFIED SPEAKER: And security.

3 UNIDENTIFIED SPEAKER: Did you thank

4 them?

5 MODERATOR HOFFMAN: And security? I'm

6 not that -- it's no offense here, it's on the

7 record here but anyway we'll look forward to

8 seeing you in just a couple of weeks and you can

9 reach us, by the way, through email and everything

10 else.

11 MR. RAMIREZ: So just to end on a

12 somewhat happy note, having been through a few

13 these already, I think we've actually made a lot

14 more progress in the two days in this group than

15 we have in other groups in terms of getting

16 through the process part of the discussion. We

17 focused on quite a bit of discussion. We focused

18 on quite a bit of content, which I'm a little

19 surprised we got through as much as we did. And

20 once we put the data out there and you all see the

21 numbers, I really think we'll pick up the pace on

22 the meat of the matter here and I really am
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1 optimistic for some good things to come out here,

2 so.

3 MODERATOR HOFFMAN: And just so you're

4 all aware, Eileen snuck in a homework assignment

5 for you, I want to make sure that it's clear,

6 right, where she said you all need to gather

7 options or ideas for possible resolutions. Right.

8 And I'm being careful and Eileen was too as far as

9 the verbiage, options, right, and ideas not

10 positions, right, not demands. Options and ideas,

11 right? Keep the mind open and there may be other

12 ways to do it, but at least let's hopefully you

13 come in with some starter points for us to

14 discuss.

15 MODERATOR HOFFMAN: I want to thank you

16 all, especially Emanuel for your wonderful lecture

17 this morning, presentation and it will be on

18 YouTube tomorrow so thank you.

19 MR. RAMIREZ: Thank you very much.

20 (A LUNCH RECESS WAS TAKE)

21 MR. RAMIREZ: Let's go ahead and get

22 started. Poor Ishbel had to do some additional
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1 security screening. So she is here, but she is

2 going to have to join us in progress. We have no

3 idea how long it is going to take or if we are

4 going to have to have her dial in Guantanamo. I'm

5 not sure how --

6 MS. HOFFMAN: No, no, no, no. She said

7 the Washington State license, driver license, is

8 somehow not accepted. So we will figure that one

9 out.

10 (Simultaneous speaking.)

11 MR. RAMIREZ: Hold on a second. The

12 court reporter over here is having some -- her

13 head is about to pop, and it's too early for that.

14 MS. HOFFMAN: It is.

15 MR. RAMIREZ: So let's use the mikes.

16 So yes, that is exactly what it is. The

17 new standards went into effect. I guess today is

18 the day; right?

19 MS. HOFFMAN: Okay. But she was able to

20 get in yesterday.

21 MR. RAMIREZ: Yes.

22 MS. HOFFMAN: But yes. One way, Joe was
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1 saying we might meet at a building that is a

2 little easier to get into than this one, less

3 secure, a little easier to get into. Anyway, so

4 we're going to start officially, but we may have

5 some folks joining us a little bit later.

6 MR. RAMIREZ: Do we have some folks

7 online?

8 MR. FREEMAN: Yes.

9 MR. RAMIREZ: Okay. So let's do this.

10 Let's go around. Everyone introduce yourself

11 again, just your name and organization, so that

12 the folks online know who is in the room. And

13 then we'll also have the folks online introduce

14 themselves. Okay. So let's start off here with

15 Keith.

16 MR. DENNIS: Keith Dennis, National

17 Rural Electric Cooperative Association.

18 MR. DRAKE: Scott Drake, East Kentucky

19 Power Cooperative.

20 MS. EPPERSON: Stacey Epperson, Next

21 Step Network.

22 MR. EZZO: Mark Ezzo, Clayton Homes.
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1 MR. UNGAR: Lowell Ungar, American

2 Council for an Energy-Efficient Economy.

3 MR. LACEY: Eric Lacey, Responsible

4 Energy Codes Alliance.

5 MR. SANTANA: Manny Santana, Cavco

6 Homes.

7 MR. LUTER: Rob Luter, Lippert

8 Components.

9 MR. POTTS: Richard Potts, Virginia

10 Department of Housing and Community Development.

11 MR. ROY: Robin Roy, Natural Resources

12 Defense Council.

13 MR. WEISS: Mark Weiss, Manufactured

14 Housing Association for Regulatory Reform.

15 MR. TOMPOS: Dave Tompos, NTA.

16 MR. LEVY: Emanuel Levy, Systems

17 Building Research Alliance.

18 MR. HAGERMAN: Joe Hagerman, DOE.

19 MS. HOFFMAN: And Eileen Hoffman, FMCS,

20 one of your facilitators.

21 MR. BARBOUR: Ed Barbour, Navigant

22 Consulting.
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1 MR. RAMIREZ: And Javier Ramirez,

2 facilitator. And, Jeremiah, could we get the

3 folks --

4 MR. FREEMAN: Yes. I'm going to read

5 off the names.

6 MR. RAMIREZ: Would you introduce

7 yourself?

8 MR. FREEMAN: Yes. I'm sorry. Jeremiah

9 Freeman, New West Technologies.

10 MR. HAGERMAN: Jeremiah is the guy who

11 has been emailing you all the stuff. So if you

12 need any help, Jeremiah is great.

13 MR. RAMIREZ: And Alex is with the same

14 group here; right?

15 MR. FREEMAN: With Energetics.

16 MR. RAMIREZ: Okay.

17 MR. FREEMAN: Do we have Bert Kessler on

18 the line? Bryan Rocky?

19 MR. RAMIREZ: Where are they from?

20 MR. FREEMAN: I don't have that

21 information.

22 MR. RAMIREZ: Is there a way to unmute
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1 them and let them --

2 MR. FREEMAN: You can if you would like

3 to try it that way.

4 MS. HOFFMAN: Yes.

5 MR. HAGERMAN: I think Bert Kessler is

6 with Palm Harbor.

7 MR. ROCKY: Good morning. This is Bryan

8 Rocky. Can you hear me?

9 MR. SCHNEIDER: Peter Schneider from

10 Efficiency Vermont.

11 MR. ROCKY: Bryan Rocky from Johnson

12 Controls. I'm also one of the members of the

13 ASRAC group for the regional efficiency standards

14 activities.

15 MS. HOFFMAN: Is there anyone else?

16 MR. FREEMAN: Yes. Caija Owens, who

17 doesn't have the ability to be unmated -- they

18 haven't been given their PIN number -- and Michael

19 Lubliner.

20 MR. RAMIREZ: So of the folks that are

21 online, which of you are voting members?

22 MR. FREEMAN: Bert Kessler, Michael
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1 Lubliner, and Peter Schneider.

2 MR. RAMIREZ: Okay. So we have 16

3 people today. If we are going to be formally

4 voting on anything, 16 is the base number that we

5 are going to be using. All right.

6 Then what we want to do today, we wanted

7 to finish going over, make sure there's nothing

8 else that you want to add to the mind map here.

9 And, if you notice, there are a few highlighted

10 pieces on there. We're going to go over that in a

11 little bit. We're anticipating that that is

12 probably going to -- we'll actually take a little

13 bit of time. It's not necessarily just adding

14 pieces on there because once they're all on there,

15 we're going to take a look, make sure that how we

16 are prioritizing them or putting them into the

17 queue if that's the word that we want to process

18 them in, but we also want to identify information.

19 What information are we going to need? What data

20 are we going to need? Who is going to get it?

21 And by when; right, if we're going to truly

22 problem-solve these issues?
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1 The other thing that we wanted to do was

2 Emanuel had offered to take about five minutes or

3 so to explain how a standard is developed. Is

4 that accurate? And so we thought there might be

5 some value to doing that up front for some folks

6 who may not be familiar with that. So the floor

7 is yours for now.

8 MS. HOFFMAN: Great. Do you need a

9 mike?

10 MR. LEVY: It's been about 30 years

11 since this process. We have developed this

12 process as part of an ASHRAE effort. And this

13 method that I am just going to go through quickly

14 -- I'm sure many of you are already familiar with

15 this, but I think it's helpful if you're not --

16 MR. UNGAR: Can you start off by saying

17 what kind of standard?

18 MR. LEVY: Yes.

19 MR. UNGAR: So this is Lowell Ungar.

20 Just so we know what kind of standard you're

21 talking about.

22 MR. LEVY: I'm going to just talk about
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1 how the technical requirements were developed for

2 the manufactured housing standard, specifically

3 the use of o values.

4 MR. UNGAR: You mean for the HUD code,

5 the

6 --

7 MR. LEVY: For the HUD code. Right.

8 MR. UNGAR: -- manufactured housing

9 standards?

10 MR. LEVY: The methodology is generally

11 applicable to development of cost-effective

12 standards. If your criteria is cost-effectiveness,

13 then what I am going to explain very briefly is

14 the process that has kind of been adapted over the

15 years for standard setting for manufactured

16 housing, specifically in how the decisions are

17 made about the zones and what the Uo values are

18 for the zones. Was this useful? Okay.

19 This came out of some work that was done

20 by ASHRAE, ASHRAE SP-53 Committee. And that work

21 still stands, but it was way ahead of its time in

22 terms of the concept of it developing a piece of
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1 software that allowed you to update your

2 requirements, your cost information, and your

3 energy requirements. And it would automatically

4 repopulate the requirements for that moment in

5 time as to what they should be for the Uo values.

6 But this is still the method that is used by PNNL

7 when they develop the standards and what we used

8 back in the early '80s to develop the original

9 manufactured housing variations on the standard.

10 And it's based upon this concept. And this will I

11 think come up a lot in our discussions.

12 The industry typically uses Uo value as

13 a way for setting what the thermal requirement is

14 for the entire structure, the entire envelope of

15 the building, not equipment, just the envelope

16 requirements; that is, the windows, the insulation

17 on the walls and the floors and ceilings and the

18 ducts. And it's all rolled together into one

19 single number, which is the Uo value. We often

20 refer to that -- it's confusing -- as a

21 performance standard because it regulates the --

22 it sets the performance target for the entire
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1 building, as opposed to the IECC, which says the

2 walls must be R this and the ceiling must be R

3 that. Instead, the manufactured housing standard

4 has forever been based upon a Uo value for the

5 entire structure. And any manufacturer can meet

6 that in any way they want as long as they get to

7 that Uo value.

8 The Uo value was somewhat proportional

9 assuming that the equipment is fixed, somewhat

10 proportional, to energy use. And the process that

11 is followed in terms of determining what the

12 standard should be is finding the least-cost point

13 for any particular home. So, for example, if you

14 are in a place like Cleveland and you want to find

15 out for a manufactured housing that's, let's say,

16 a double- sectioned home, 24 by 66, how that home

17 should be built in order to get to the minimum

18 lifestyle cost value and that is the point at

19 which the homeowner's cost will be minimized over

20 the life of the home -- yes?

21 MR. WEISS: Hold on a second. Minimum

22 what value?
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1 MR. LEVY: Lifecycle cost.

2 MR. WEISS: Okay.

3 MR. LEVY: Okay? Lifecycle cost

4 basically -- sorry for the detail here, but this

5 is kind of the thinking behind the standard

6 generally. Lifecycle cost is taking all of the

7 costs associated with the measures; that is, the

8 cost of buying the efficiency items, like the

9 insulation, and the maintenance costs and any

10 other costs that would be associated with all of

11 the measures that are being considered, and the

12 energy savings. So if the energy savings is

13 greater than over some period, let's say a 30-year

14 period if that is what your period of analysis is,

15 if the energy savings accumulated over 30 years

16 for a whole series of measures equals the cost of

17 those measures, the first cost of those measures

18 and whatever the cost is of embedding those

19 measures into the loan, the total cost to the

20 homeowner over some period of time if the energy

21 cost savings and the cost of those measures is

22 equal, you come out with this point here, which is
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1 considered the minimum point. This is usually how

2 standards are set. You try to find what the

3 minimum cost is.

4 And the way you start is you start with

5 a home. Let's say this is today a minimum home in

6 Cleveland. And let's say for argument's sake that

7 would be double glass, R-28 in the ceiling, R-28

8 in the floor, and R-11 in the walls. If that is

9 your starting package for the features of the

10 home, then you might consider increasing that by,

11 let's say, going up a little bit higher with the

12 insulation value in the wall to R-13 or R-19. So

13 what this curve is is incremental increases in

14 performance by adding in measures. Again, if you

15 start here with 28, 11, 28; and then you go up to

16 28, 13, 28; the next change is 28, 19, 28, what

17 you are doing here is incrementally adding

18 measures. And each measure you are adding is

19 increasing the cost of the home and increasing the

20 mortgage by some amount. But at the same time, it

21 is decreasing the amount of energy that is being

22 used by the home. And these measures will return
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1 more in terms of energy savings than their cost.

2 So every incremental increase will improve, will

3 make the lifecycle cost analysis lower, will make

4 the cost of operating the home lower, and make the

5 energy use obviously lower until you reach this

6 point.

7 At this point, every incremental change

8 you make -- and let's say at this point you

9 haven't included, let's say, argon-filled glazing

10 in Cleveland. And the cost of adding that measure

11 is over a lifecycle cost more than the energy

12 savings it returns. It will increase the energy

13 efficiency. It will drive down the energy

14 efficiency by adding that measure, but it will

15 increase the lifecycle cost. So from the

16 standpoint of benefit, this is not going to pay

17 for itself. From the homeowner's perspective, if

18 they buy that additional measure, it is going to

19 increase their cost. So it's considered to be not

20 cost-effective.

21 Yes?

22 MR. WEISS: I'm sorry. I don't mean to
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1 interrupt. Are you referring to a specific HUD

2 standard?

3 MR. LEVY: No. I'm saying this is the

4 method that was used to determine the values in

5 the standard.

6 MR. WEISS: Okay. Which standard?

7 MR. LEVY: The one you hold in your

8 hand.

9 MR. WEISS: Well, which section? Five10 o- eight?

11 MR. LEVY: Yes.

12 MR. WEISS: Okay.

13 MR. LEVY: The Uo values. But this

14 underpins the entire philosophy of standards

15 development, where the cost associated with a

16 measure should be returned to you in energy

17 savings. If you're looking at it from the

18 perspective of the homeowner to make a good

19 investment, they want to make sure that whatever

20 they are investing in, the next measure they are

21 investing in is going to have a positive return

22 over some lifecycle cost.
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1 Yes?

2 MR. SANTANA: So now when you say the

3 lifecycle cost, each of the measures is going to

4 increase the purchase price on the initial price

5 of the home.

6 MR. LEVY: That's right.

7 MR. SANTANA: So each thing that you add

8 is going to make the house more expensive, but

9 when you take into account energy costs, operating

10 costs, interest on the original loan, it's still

11 overall adding more value up until it gets to a

12 point; right? And that is the minimum point that

13 you have there; right?

14 MR. LEVY: That's right. That is this

15 point. It will continue to drive down the total

16 overall net cost to the homeowner until you reach

17 this point. You can get to zero, but the zero

18 might be way up here. And it would cost the

19 homeowner more money. They would never get back in

20 terms of energy savings what they put out in terms

21 of cost.

22 Mark?
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1 MR. EZZO: Mark Ezzo. I think it might

2 be helpful if you just below that put the formula

3 for lifecycle cost now.

4 MR. LEVY: Yes.

5 MR. EZZO: So if I'm writing it on my

6 own piece of paper, I've got down the price, cost

7 of the home, initial price of the home, plus

8 utility bill, plus maintenance. Is that it?

9 MR. LEVY: Well, this is the way it is

10 typically done. The principal, the interest,

11 taxes, the --

12 MR. EZZO: Okay.

13 MR. LEVY: -- and the energy. These are

14 all the costs but accumulated over some period of

15 time. And one of the things we can argue is what

16 should that period of time be. Typically when

17 these are set and I think was the case with the

18 last standard update is they assumed that the

19 period was 30 years, 30-year lifecycle cost, which

20 means the energy benefits were accumulated over 30

21 years. That can make a lot of things cost22 effective.
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1 MR. WEISS: I'm sorry. You said,

2 "they." Who's "they"?

3 MR. LEVY: When HUD set this, they had

4 PNNL do the analysis. And that was the method

5 that they used.

6 MR. DENNIS: I understand the concept

7 like when something doesn't pay back over a set

8 term. Are there times when something is a quick

9 payback? You mentioned that --

10 MR. LEVY: These are quick paybacks.

11 MR. DENNIS: So do you always keep going

12 until you hit the zero point or do you sometimes

13 stop before you get -- like if something pays back

14 in 10 years, it's 15 years, but that's kind of --

15 so you've got 5 years worth of actually paying you

16 back. Do you then have to keep going until you

17 get to zero or do you stop at that point in some

18 way?

19 MR. LEVY: From a standard-setting

20 standpoint, philosophical standpoint, this point

21 is the point that optimizes the benefit for the

22 homeowner. So this is the point that you stop and
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1 say, "Okay. What is my use of o value at that

2 point?" And here it gets a little bit messy.

3 MR. DENNIS: So it might not always be

4 exactly the day that it pays back? It's just the

5 optimal of whatever the equation is?

6 MR. LEVY: You mean it might be here or

7 it might be here because they are increments? Is

8 that what your question is?

9 MR. DENNIS: Well, I am just wondering

10 if that zero point, that kind of inflection point,

11 is always when that energy cost payback is the

12 same time as the measure or sometimes that

13 inflection point comes when the payback might be

14 before the life of the measure.

15 MR. LEVY: Payback is a different way of

16 looking at benefit. And payback means it just

17 pays back in a certain number of years, but that

18 is an artificial measure. This --

19 MR. LEVY: Or when lifecycle cost is I

20 guess negative?

21 MR. LEVY: Right. Well, this point is

22 the point that objectively provides the greatest
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1 benefit for the homeowner. Any more investments,

2 they're going to lose money. Any less investment,

3 there are going to be opportunity costs that they

4 are not going to ever realize.

5 And the way this is then used is at this

6 point -- and, again, let's say this is Cleveland.

7 And let's just say for argument's sake that this

8 value is .070 as a Uo value. The way that this

9 information is then used is that this point is

10 calculated for homes in Cleveland that are single11 wides, a typical single- wide, a typical multi12 section home, home with gas heating, home with

13 electric heating because those will all produce

14 different numbers, different use of o values.

15 Electric will generate much more benefit because

16 electric costs are higher generally. So the

17 optimum use of o value for an electric home will

18 be lower than a gas in general.

19 But the way you develop a standard from

20 this is you come up with these values for all the

21 different parameters. You do sensitivity studies,

22 in other words. And you start to aggregate them
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1 over areas. So you would take the Cleveland value

2 and combine that value with the same kinds of

3 values throughout Ohio. You come up with a use of

4 o value which is kind of a balanced use of o value

5 for Ohio. And typically they're weighted by the

6 number of units of that particular kind. So the

7 number of electric units in Ohio, if there were a

8 lot of electric units, would drive the use of

9 average value for Ohio further down.

10 Once you have Ohio, -- this is how we

11 did it 30 years ago -- you would do it for all of

12 the other states. And you would start to

13 aggregate states together based upon similarities

14 of use of o value. And what you find is that --

15 sorry for that. Here is the HUD map today. And

16 you have use of o value, let's say, of 079 here

17 today, 096, 116. These are the requirements today

18 for the three zones. But if you actually look

19 carefully at the values here for the states here,

20 they might be 060. And the ones down here might

21 be 083.

22 MR. DENNIS: Basic question. I don't
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1 want to say better or worse, but use of o higher

2 is --

3 MR. LEVY: Higher is less efficient.

4 MR. DENNIS: Higher is less efficient?

5 MR. LEVY: Yes. There is a U value. So

6 the lower the value, the more efficient the home.

7 MR. LUBLINER: Emanuel, this is Mike

8 Lubliner. Hello?

9 MR. RAMIREZ: Yes? Yes, Mike?

10 MS. HOFFMAN: Yes, Mike?

11 MR. LUBLINER: Yes. I just wanted to

12 say, you know, there is a distinction, I believe,

13 between the cost of propane and the cost of

14 natural gas. So you would be able to afford with

15 the lifecycle cost models more conservation with

16 propane than natural gas, a similar analogy to the

17 electric?

18 MR. LEVY: Right. So I guess the point

19 here is that if you create a zone that looks like

20 the zones we have today, you have made the

21 decision that people in Montana are going to get

22 too little conservation and people in Ohio are
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1 going to get too much for what is really cost2 effective for them. Those are the sacrifices you

3 make when you start putting things together

4 because you are no longer at the optimum for any

5 one homeowner everywhere in the country. Does

6 that make sense?

7 MS. HOFFMAN: Thank you.

8 MR. RAMIREZ: Yes. And so we will

9 probably keep that chart up there because you may

10 have to refer back to that or it may be beneficial

11 to refer back to that when we get to that number

12 one discussion; right, and maybe even throughout

13 some of the other pieces as far as the formula of

14 the zone, also the formula there.

15 MR. LEVY: May I just add one small

16 detail here? The question was asked about

17 lifecycle cost, about economic parameters. If you

18 say instead that, instead of a 30-year lifecycle

19 cost analysis, that you are only going to

20 accumulate the energy benefits over 20 years or 7

21 years because that is the average term of

22 homeownership, this curve moves backwards. This
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1 curve will move like this. So this point is a

2 function of all of your assumptions. And if you

3 don't take a long time to pay back, take a shorter

4 term, the use of o value that is cost-effective is

5 going to be higher. So one of the discussions I

6 think we need to have is what should be the

7 economic assumptions.

8 MR. LUBLINER: Emanuel? Mike Lubliner

9 again.

10 MR. RAMIREZ: Yes? Go ahead, Mike.

11 MR. LUBLINER: I wanted to say if the

12 term of the analysis is 30 years for the lifecycle

13 cost and the homeowner moves out after 7 years,

14 then there's still residual value in the

15 investment that the homeowner accrues through the

16 equity in that investment. We see this in the

17 resale value in chattel mortgage loans of energy18 efficient homes. I think if we're going to use a

19 shorter term than the life of the home, we need to

20 recognize the salvage or resale value. I've

21 typically done a lifecycle cost analysis.

22 MR. ROY: Robin Roy. I think that is
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1 sensible, but I think a better way to deal with

2 the life of the home is not to try to assess what

3 the resale value is at year seven. I think what

4 we want to do is look at the life of the home and

5 all the occupants of it over that home's

6 productive life, so trying to figure out, well,

7 what is the split between the first buyer's and

8 the second buyer's benefits from the energy

9 savings. It's very complicated. Let's figure out

10 what the life of the home is.

11 MR. LUBLINER: I totally agree with what

12 Robin just said there. I think the other point I

13 would like to make on the term of the loan is if

14 you do it for 30 years or longer, what tends to

15 happen because you are discounting it to present

16 value is that what happens out at 30 years has

17 very little impact on the actual cost-effective

18 package. But that's a sensitivity study that we

19 could have DOE do for us.

20 Thank you.

21 MS. HOFFMAN: All right. Thank you.

22 MR. RAMIREZ: Yes, Lowell?
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1 MR. UNGAR: Yes. What he just said,

2 just know that it's discounted. The savings

3 through the years from now are not worth the same

4 as the cost of the home today. You put in a

5 discount rate to take that into account.

6 MR. RAMIREZ: Mark?

7 MR. EZZO: Mark Ezzo. What term was

8 used when HUD developed this back in '94?

9 MR. LEVY: Thirty years.

10 MR. EZZO: They used 30 years?

11 MR. LEVY: Yes.

12 MR. EZZO: Okay. And I lost you on if

13 you reduce the length of time, the curve moved to

14 the left. Is that correct?

15 MR. LEVY: Yes.

16 MR. EZZO: So if the curve moved to the

17 left, the optimum point for Uo goes down?

18 MR. LEVY: It goes up. I'm sorry. This

19 curve has the zero energy to the right. So Uo

20 goes down to the right.

21 MR. EZZO: Gotcha. Okay. Thank you.

22 MS. HOFFMAN: Keith, did you have --
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1 MR. DENNIS: That was the same question

2 I had. Thanks.

3 MS. HOFFMAN: All right. Thank you.

4 Was it helpful? Okay. Good.

5 MR. RAMIREZ: Okay. Great.

6 MS. HOFFMAN: Actually, this is your

7 meeting, too. We're facilitating. But if there

8 is something critical that you want to make sure

9 we get to, we're going to do it.

10 And let me just summarize. It was a

11 very productive day yesterday, even if it was sort

12 of frustrating. We reached some agreement on our

13 ground rules. We also reached agreement on what

14 is consensus. You got to know each other if you

15 hadn't before. And we're going to move ahead now

16 today on -- and we also did a sort of a rough

17 identification of key issues. What we're going to

18 hone in now is how to organize this, look at

19 definitions, and look at how to -- actually what

20 kind of data we need, who can give it to us on

21 these issues for this standard.

22 MR. ROY: Robin Roy.
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1 MS. HOFFMAN: Yes?

2 MR. ROY: A quick question. This is

3 great. I love it. This is one definition of what

4 might comply with the statutory requirements of

5 setting the energy levels based on cost6 effectiveness, which is some not-quite-well7 defined combination of lifecycle cost and purchase

8 price. The way the location is written is a

9 little bit odd; right? It doesn't say, "minimum

10 lifecycle cost," which I think is part of why we

11 start having these discussions so much moving

12 quickly away from lifecycle costs or cost13 effectiveness to things like affordability. It's

14 a very popular term. It came up yesterday,

15 "affordability," which is, again, not well16 defined. Does that mean minimum first cost? Does

17 it mean minimum lifecycle cost? I think it is

18 something that is not defined in law. It's one of

19 the reasons it shows up on this page that you've

20 got behind you. Yet, it doesn't show up in the law

21 or anywhere else. It's very interesting.

22 That's an aside. We need to figure out
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1 what exactly our objective function is. That is

2 cool. But I'm curious. On air infiltration,

3 would you use the same sort of approach as you

4 would use on setting the U value because you can

5 put in additional measures to reduce air

6 infiltration, which is another driver of energy

7 consumption; right?

8 MR. LEVY: If you could quantify the

9 cost and the benefit.

10 MR. ROY: Right. Okay. I mean, in

11 principle, it seems like a fine way to approach

12 air infiltration as well.

13 MR. RAMIREZ: Okay. Mike, you had a

14 question or a comment?

15 MR. LUBLINER: Yes. I want to just

16 comment. Yes. I believe that infiltration and

17 other energy measures should be considered there.

18 I wanted to give a little background.

19 Emanuel, let me know if I am getting this right.

20 This is back in '94. What I understand is that

21 Congress had designated that we go in in '94 and

22 come up with a cost-effective upgrade to the Uos
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1 that hadn't been updated since '74. And I believe

2 there is Senate testimony that defined lifecycle

3 cost and also defined need to be technically

4 feasible. Those were the two parameters that

5 Congress gave you guys in '94 to work off of.

6 I believe we got a little more guidance

7 from

8 Congress in 2008 where they also said

9 they wanted to look at the purchase price, the

10 impact of purchase price and the impact on the

11 manufacturers. So that is my recollection of what

12 guidance we have gotten over the years: lifecycle

13 cost for technical feasibility in '94 and then

14 looking at the impact of purchase price.

15 And people typically use a price

16 elasticity economic model that looks at the impact

17 on the manufacturers' sales to address the

18 purchase price implications.

19 Thank you.

20 MR. WEISS: Mark Weiss, MHARR. If you

21 look at the statute itself under section 604,

22 Congress said back in 1994 "The energy
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1 conservation standards established under this

2 subsection shall be cost- effective energy

3 conservation performance standards designed to

4 ensure the lowest total of construction and

5 operating costs."

6 There is further reference in the ISA

7 statutes specifically to the purchase price of

8 manufactured housing. So it's really an amalgam

9 of all of these things, but, again, as I indicated

10 yesterday, if price is an entry barrier to

11 accessing housing that's supposed to be deemed by

12 Congress to be affordable, that seems to me to be

13 a very important consideration, if not the most

14 important consideration.

15 MR. RAMIREZ: All right. So let's try

16 to put a little bit of focus on the conversation

17 here because a comment was made yesterday. And I

18 think it was glossed over pretty quick. I want to

19 make sure that I guess we are kind of on the same

20 page here. Let me make this a bit larger here.

21 One of the comments made was "What are

22 we trying to do here?"; right? And I think that
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1 the summary was to increase energy and efficiency

2 in manufactured housing while maintaining its

3 affordability; right? And one of the placers that

4 we left off yesterday was, can we have a

5 conversation about what is affordability?

6 And so all of this kind of blending into

7 three points here; right: what are we trying to

8 do, this conversation of affordability, and also

9 to remember right at the very beginning, when I

10 was talking about consensus, you all agreed. I

11 mean, it's consensus. You said let's agree on

12 what important words mean; right, the definitions.

13 That goes into that affordability piece. And that

14 was what you all wanted to do, was have a

15 conversation on affordability.

16 Now, what I would suggest is that we

17 time- box this; right, because we could probably

18 take the entire day and talk about it, but let's

19 do our best to try to keep it focused and come up

20 with some common definition or agreement of what

21 we mean by affordability. I think that is where

22 the group wanted to go yesterday. Is that
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1 accurate?

2 MS. HOFFMAN: Yes. I think Robin has

3 got a point. Yes?

4 MR. ROY: To add a little bit --

5 MS. HOFFMAN: Yes?

6 MR. ROY: -- I think I threw that out.

7 I think I withdrew that one.

8 MS. HOFFMAN: Yes.

9 MR. RAMIREZ: Someone did it, yes.

10 MR. ROY: I suspect in the title, we

11 should be more explicitly referencing the language

12 that is in the law.

13 MS. HOFFMAN: Yes.

14 MR. ROY: So, instead of saying,

15 "affordability," we should say, "cost-effective,"

16 which is some combination of purchase price,

17 lifecycle construction, operating cost.

18 MS. HOFFMAN: Say that slowly because

19 the word "affordability" isn't in the --

20 MR. ROY: It is not. That's right.

21 MS. HOFFMAN: It's not there. Okay.

22 MR. ROY: While I would put the word in
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1 "optimizing" because they're saying go higher or

2 lower, I think it's a fair word, optimizing cost3 effectiveness is defined as some combination of

4 lifecycle cost and purchase price. And then we

5 have to decide --

6 MS. HOFFMAN: Yes.

7 MR. ROY: -- to help interpret what

8 Congress' intent was there, I suppose.

9 MR. RAMIREZ: Lifecycle and --

10 MR. ROY: Lifecycle cost and purchase

11 price. What they added in the ISA in 2007 was

12 purchase price. Before that, we had been talking

13 about lifecycle cost. So they added something,

14 reflecting Mark's point that there must have been

15 some sense that there was inadequate attention to

16 that first cost hurdle that buyers experience,

17 maybe.

18 MR. WEISS: Mark Weiss. And it also --

19 MR. ROY: Did I overstate Congress' --

20 MR. RAMIREZ: Before we get on there,

21 though -- and I'll get you, Mark. You're next.

22 But time limit. How much time do we want to put
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1 on this for this conversation --

2 MR. WEISS: It's a very good question.

3 MR. RAMIREZ: -- knowing that we still

4 have a quite a bit that we need to do with the

5 rest of the agenda?

6 MS. HOFFMAN: Or is it a threshold

7 conversation?

8 MR. WEISS: I think it is.

9 PARTICIPANT: What is the objective

10 function?

11 MS. HOFFMAN: You mean we can do all of

12 this without our objectives? All right. What

13 about we see where we are in about an hour, you

14 know. Okay? By then, we'll take a break also.

15 All right?

16 MR. RAMIREZ: Okay. All right. We go

17 until we need a break. All right. That sounds

18 good.

19 MS. HOFFMAN: Oh, by the way, just in

20 terms of that, if you do need a break, let us know

21 earlier, but let's say there will be an hour

22 discussion. Okay.
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1 MR. RAMIREZ: Okay. Great.

2 MS. HOFFMAN: All right.

3 MR. RAMIREZ: All right. Mark?

4 MR. WEISS: Yes. We need to define need

5 maybe. But, anyway, the point I was going to make

6 very quickly is the reflection of purchase price

7 in the ISA statute is also consistent with the

8 statute that HUD operates under for establishing

9 our standards, which talks about the price of the

10 home to the consumer. And I don't remember the

11 section off the top of my head.

12 MR. LUBLINER: Mike Lubliner. I think

13 that we could look at the price elasticity models,

14 economic models, to address that. I think that

15 should be part of the discussion when we get into

16 the analysis. The price elasticity model for

17 those who don't understand I'm talking about is

18 for every dollar you raise the cost of the home,

19 you lose so many people in sales. And what this

20 does is allows you to evaluate the impact on the

21 manufacturer based on an increase in purchase

22 price. So if we are going to be using that in the
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1 overall definition of affordability, I would

2 encourage that technical analysis to help to

3 determine that.

4 And, last, there was one other thing

5 that happened in '74. Congress not only said

6 lifecycle cost but said technically feasible,

7 which means you couldn't come up with a product.

8 The manufacturers had to be able to build it. I

9 think you might want to add that to the points.

10 Thank you.

11 MR. RAMIREZ: All right. So can you

12 capture those in bullets for us so we could --

13 what were those points?

14 MR. LUBLINER: Technical feasibility,

15 lowest lifecycle costs, and impact on purchase

16 price. And my recommendation was to use a price

17 elasticity model for the last one.

18 MR. EZZO: Mark Ezzo. Mike, can you go

19 over again what you -- you kind of defined the

20 price elasticity model, something to the effect of

21 it's a number to where X amount of people can no

22 longer afford. Can you go over that again?
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1 MR. LUBLINER: I sure can. And I think

2 that if we were able to get some of the analysis

3 that has been done, it would give us some

4 specifics. But I know of a couple of different

5 studies that have been done to look at what price

6 elasticity should be for the manufactured housing

7 industry. I think MHI sponsored Carol Meeks, Dr.

8 Meeks, to do that years on single-section, double9 section homes. And there was some work done by

10 researchers in Washington State University that

11 was published on price elasticity in the

12 manufactured housing sector. And basically what

13 we're talking about is if I raise the price of a

14 home by $1,000, what percentage of the market do I

15 lose to those at the entry level that can't fit

16 into that home. And there is a financial cost to

17 the manufacturer that needs to be considered

18 there. That's part of trying to get a sense of how

19 many sales are you going to lose, like Mark says,

20 and how do we quantify that?

21 I think as soon as we get some analysis,

22 we will be able to actually look at if they use
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1 the price elasticity model the specifics and see

2 if we're all comfortable with those assumptions.

3 I hope that helps, Mark.

4 MR. CYMBALSKY: This is John from DOE.

5 I would just like to give a little primer on what

6 we do for appliance standards. What he is

7 discussing is what we call the shipments model for

8 appliance standards. And what we do there is, you

9 know, we have a model that projects the shipments

10 without standards. So that will be kind of our

11 baseline going in. So we will say this is the

12 shipments of manufactured homes for the next 30

13 years absent any intervention from standards.

14 We will also have the modeling. And it

15 uses price elasticity. So the gentleman on the

16 phone is correct. That is how we do it. It will

17 show what we think the impact is of shipments with

18 the standard in place. And you can run different

19 efficiency levels of standards that we are looking

20 at to see the impact of each one of those

21 different standards we think will have on the

22 market. And you could do kind of a manufacturer
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1 impact analysis, like we do in standards.

2 So I think we will get there. And,

3 obviously, we don't have all of those numbers yet,

4 but I think, you know, he is exactly right. Those

5 are the types of things that we are going to look

6 at and be the basis of the negotiation.

7 MR. RAMIREZ: At least to me, that

8 sounds complicated. What kind of timeframe are

9 you talking about that you would be able to have

10 that type of data?

11 MR. CYMBALSKY: You know, this is the

12 analysis we will be doing as we go along. So I'm

13 going to pin a tail on the donkey here, but, you

14 know

15 --

16 MR. RAMIREZ: I guess what I'm looking

17 at is for our next meeting, which is scheduled on

18 the 21st, is it a possibility to have it?

19 MR. CYMBALSKY: Right. So I think we

20 mentioned yesterday that we are working on getting

21 some data together based off the 2015 IECC. And

22 we're hoping to get the lifecycle costs and all of
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1 the different analyses in order by then.

2 MS. HOFFMAN: Perhaps by our next

3 meeting, then?

4 MR. CYMBALSKY: Hopefully prior to that

5 so that before people come into the room, they'll

6 have a chance, at least a few days or maybe

7 hopefully a week or two, to look at the numbers.

8 MS. HOFFMAN: Okay. Mark and then Eric.

9 MR. WEISS: And this was mentioned

10 yesterday. I think it was Mike. Financing is

11 also an aspect of this, particularly when you're

12 dealing with manufactured housing and particularly

13 given some of the changes that we have been

14 through in recent years with the availability of

15 financing and also new regulations that have come

16 into effect under the Dodd Frank law. It's a very

17 different financing market than it was probably

18 back when previous studies were done regarding

19 affordability, and I think that definitely has to

20 be factored into it as well. If you can't get

21 financing, most people, you are not going to be

22 able to buy the home.
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1 MR. ROY: Is it possible to get Ishbel

2 in here someplace, perhaps by phone? She would

3 really care about this conversation.

4 MS. HOFFMAN: Oh, right.

5 MR. ROY: This is so core to what she

6 thinks about.

7 MS. HOFFMAN: Before we continue, any

8 status on Ishbel?

9 MR. CYMBALSKY: We are still trying to

10 get her access into the building. It takes a

11 little time, but --

12 MS. HOFFMAN: Can she communicate via --

13 MR. FREEMAN: That's why I brought her

14 laptop.

15 MR. LUBLINER: Mike Lubliner here. It

16 may be useful as backup research to get a copy of

17 some of the existing price elasticity analysis

18 that has been done in the manufactured housing

19 sector so you, Mark, and you always can get a

20 sense of what the models have suggested.

21 The two studies that I would recommend

22 was one that Dr. Meeks at MHI probably has. The
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1 other one was a Professor Marsh, Dr. Marsh, from

2 Washington State University. I would be happy to

3 share that. What he found was that there are two

4 price elasticity decision points. One is by the

5 purchaser, and one is by the retailer. So, you

6 know, I think that this is an opportunity here to

7 work with industry to get updated data that would

8 reflect the current climate in the funding and see

9 if we can come to agreement on what those price

10 elasticity factors are so that we could use that

11 approach in this rulemaking negotiation.

12 Thank you.

13 MS. HOFFMAN: All right. Eric, you had

14 a question or concern.

15 MR. LACEY: Thank you.

16 I kind of want to circle back to what

17 Robin said earlier, and then I do have a comment

18 about price elasticity or demand because that

19 comes up frequently in state code adoption

20 debates. First, I think I agree mostly with what

21 Robin has said, but I wanted to go back to the

22 statute because I think that is a standard by
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1 which this core group will be judged and

2 ultimately the NOPR will have to -- you know, the

3 hurdle that we will have to clear. And the one

4 tweak I would make to kind of the scope of work is

5 the first clause in the statute related to

6 updating the standard says, "The energy

7 conservation standards established under this

8 section shall be based on the most recent version

9 of the IECC." So, as a starter, that is kind of

10 the starter. And then there are some exceptions

11 to that. I just wanted to make sure that we keep

12 that in mind that what the statute requires is the

13 most recent version of the IECC except in cases,

14 and there are the exceptions where the Secretary

15 finds the code is not cost-effective or a more

16 stringent standard would be more cost-effective.

17 And this is judged by based on the impact of the

18 code on purchase price of manufactured housing and

19 on total lifecycle construction costs,

20 construction and operating costs.

21 So I agree, you know, with what Robin

22 says. You know, we need to look at cost-
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1 effectiveness, both on the lifecycle and on the

2 purchase price, but within keeping the 2015 IECC

3 kind of as a starting point. And I think that was

4 referenced yesterday. I don't want to lose sight

5 of that as we're kind of charging ahead.

6 And the second point I wanted to make

7 was on price elasticity. It's been a long time

8 since I took economics, but this is a challenging

9 question because there are some who will assume a

10 price elasticity of - 1, where you will have one

11 seller and all of the same item and if you

12 increase the price by one penny, it knocks out X

13 number of buyers because they are buying at the

14 absolute limit of their credit or whatever when,

15 in reality, there are several options. There are

16 several suppliers out there. Not everyone is

17 maxxing out the purchase capabilities. And so the

18 price elasticity is something less than that

19 fixed, straight-line amount.

20 So this is a very complicated sort of

21 question. And, you know, it does need to come up

22 later on when you are talking about purchase
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1 price, but I don't think that there is a set --

2 it's as complicated as any of the other cost3 effectiveness issues.

4 So, anyway, I just wanted to, you know,

5 circle back on the 2015 IECC as kind of the that's

6 the base case unless it meets an exception.

7 MS. HOFFMAN: No. Thank you. Lowell?

8 Thank you very much.

9 MR. UNGAR: Yes. I also wanted to go

10 back for a moment to the statute. I am not an

11 expert on the technical aspects of manufactured

12 housing, but I do know something about Congress

13 and the laws. And I wanted, one, to note I think

14 the discussion of the statute from I assume it's

15 '92 probably for HUD is illustrative, but know

16 that that, again, is not a governing statute.

17 That one was the old HUD code. In fact, we were

18 involved and recommenced modifying that. Congress

19 chose not to do that. Congress chose to do a new

20 statute with a different agency. So I want you to

21 take that for illustration but not as something

22 governing this standard.
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1 And, you know, my sense in terms of the

2 language was not that they were trying to

3 introduce new factors. As Mark pointed out, these

4 factors had been under consideration. And I think

5 that my read of that is they are talking about

6 lifecycle costs. And they were trying to say what

7 lifecycle cost means. In particularly, as Eric

8 can say, there's been a lot of discussions in

9 terms of the IECC about what to look at. And

10 they're saying they think lifecycle cost is a way

11 to look at these questions.

12 Thanks.

13 MS. HOFFMAN: Thank you.

14 I have just heard from Joe that Ishbel

15 should be back in 15 minutes. So here's hoping on

16 that score.

17 Yes, Emanuel?

18 MR. LEVY: I think Eric put his finger

19 on the key, the key language here. And this is a

20 point of debate. The language in the EISA law is

21 confusing. It is actually a dichotomy because it

22 says IECC, on the one hand, and lifecycle cost, on
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1 the other. Those two things are never going to

2 match up. Why should a consensus standard that

3 was developed for site-built be cost-effective for

4 manufactured housing? And it's not to say that

5 what is cost-effective today -- and this is a

6 point for our debate -- is less or more than the

7 IECC 2015 or 2012 or any version of the IECC. It

8 may be that the 2015 or something close to it is

9 cost- effective in one part of the country and not

10 another part of the country, but from what Eric

11 said, the way I interpret it is that if it's not

12 cost-effective, cost-effectiveness should dictate.

13 And the question is whether if it's not cost14 effective but less stringent than 2015, is that

15 acceptable? Is that the way you would interpret

16 it, that we could go less than 2015 or even less

17 than 2012 if it's shown through our own analysis

18 to be cost-effective to be at those lower levels?

19 MR. UNGAR: Yes. So I should have

20 mentioned that. I think the intent of Congress

21 here is -- and in 2007, the HUD code on energy

22 issues had not been updated for 13 years by that
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1 point. Congress felt that that was not

2 acceptable. It was falling behind building

3 science and practice. And they looked and said,

4 "IECC is getting updated every three years. There

5 is actual that, and it has gone well beyond where

6 the HUD code is," And it wasn't clear. You know,

7 they felt that there was no reason manufactured

8 housing in general could not be as good as stick9 built homes. And so they said, "Let's take that

10 as a basis that you should look to that at least

11 as a starting point," but recognizing that there

12 could be differences for manufactured homes and

13 that yes, absolutely, that what makes sense --

14 either that you may either be able to get to

15 higher levels or lower levels and that if it

16 didn't make sense for manufactured homes, if DOE

17 could demonstrate that that wasn't a good standard

18 for manufactured homes, they should go above or

19 below, as warranted, but take that as a starting

20 point because, you know, not, say, an old HUD code

21 at that point was old and now is even older, but

22 take IECC as a basis and look, only if there is a
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1 good justification why you need to go above or

2 below, use that.

3 MS. HOFFMAN: Manny?

4 MR. SANTANA: Yes. This is Manny with

5 Cavco. Understanding that the mandate DOE has is

6 to develop a standard based on the most recent

7 IECC, you know, I don't think they meant that

8 should be our starting point. I think they have

9 that as the goal.

10 You know, so, again, I think we can't

11 ignore where HUD code construction currently

12 stands. You know, because we use words like

13 "affordability." We're saying, "cost-effective,"

14 but we don't know. We don't have a number

15 associated with that. So we don't know exactly

16 what that means. That is not very well- defined.

17 You know, so what we have to use instead is

18 minimum occurring construction standards when it

19 comes to energy. That defines cost-effectiveness.

20 So I think we have to start with what we currently

21 have and then say the most recent International

22 Energy Conservation Code is the goal and then take
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1 it in increments and see, well, how far can we get

2 before costs really start to rise? You know, I

3 think that if we start at the 2015 IECC and then,

4 you know, try to give a cost to that and compare

5 that to the cost of where we're at, it's going to

6 be impossible to come up any kind of comparisons.

7 MR. RAMIREZ: I think Stacey and Keith

8 had their hands up first.

9 MS. EPPERSON: So this is on a different

10 subject, maybe a question for Emanuel. It's

11 lifecycle cost, the PITI plus energy. Originally

12 did we also look at lot rent as part of the

13 lifecycle cost? Because for the 50,000

14 manufactured housing communities -- okay. Thank

15 you.

16 MR. DENNIS: Mine might be a question

17 for Emanuel, too. So when looking at the price

18 elasticity and saying, you know, looking at

19 affordability and you say you raise the cost by

20 $1,000, this many people don't buy the house, is

21 that then compared to an energy baseline, like

22 what they have now, like so you're losing that
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1 energy savings if they had bought that house or is

2 that just strictly financial to the manufacturer,

3 financial losses, factored in? Like is it energy

4 analysis that you are talking about when you are

5 losing that new increment to the new house or is

6 it just a financial loss to the manufacturer and

7 the retail market?

8 MR. LEVY: You might be mixing two

9 things. What we were talking about --

10 MR. LUBLINER: Okay. Well --

11 MS. HOFFMAN: Emanuel is answering

12 first, Mike. Okay. Go ahead.

13 MR. LUBLINER: Thank you.

14 MR. LEVY: What we were talking about

15 here is simply determining, indifferent to whether

16 the homeowner can afford the home or not, what

17 level of energy efficiency is cost-effective.

18 MR. DENNIS: Right.

19 MR. LEVY: Mike brought up the other

20 issue. If the cost of doing these things is three

21 or four thousand dollars, there are going to be

22 people who can no longer afford to buy a home if
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1 the price of that home goes up by that amount of

2 money. So you are, in effect, knocking those

3 people out of the market entirely or the ability

4 to purchase a home. How should that consideration

5 enter into our decision- making?

6 MR. DENNIS: Right. And then do you see

7 that as a loss of energy compared to the homes

8 that they are in now because they're not

9 purchasing the new? I mean, is that part of the

10 equation? No.

11 MR. LEVY: You mean the fact that they

12 have to continue to rent, instead of buy a home?

13 MR. DENNIS: Rent their older home? No.

14 That's not --

15 MR. LEVY: It's very difficult to

16 quantify that.

17 MR. LUBLINER: Yes. I concur with what

18 Emanuel said.

19 MR. RAMIREZ: Mark?

20 MR. WEISS: Hi. I just wanted to

21 address a point that Lowell made earlier. And he

22 is correct in pointing out that the Congress in
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1 the EISA law went beyond what HUD has

2 traditionally done with respect to energy. But

3 the fact that Congress chose to legislate with

4 respect to energy doesn't change or doesn't negate

5 other aspects of federal law that were already in

6 place, including the HUD Act, the Federal

7 Manufactured Housing Act, which specifically

8 refers to the availability of affordable housing

9 and manufactured housing as affordable housing.

10 So I just want to make clear that that specific

11 legislation or regulation does not alter the other

12 requirements that we operate under with respect to

13 the affordability of manufactured housing. And

14 there is a nexus between the two in the 2000 EISA

15 statute, where it says that DOE shall act in

16 consultation with HUD.

17 MS. HOFFMAN: Eric?

18 MR. LACEY: Eric Lacey. I hate to

19 disagree with my seat mate here, Manny, but I do

20 think the starting place needs to be the IECC,

21 just because of what the statute says. And it may

22 be as simple as using Mr. Levy's chart there, you
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1 might put your first point on there and say, "This

2 is the U of o for the 2015 IECC." You know, if we

3 move it to the left or to the right, is this more

4 cost-effective, less cost- effective?

5 I mean, Congress decided to start

6 somewhere, I think. And I think your illustration

7 is very good here. It may be as simple as that

8 that this is where the 2015 IECC would be. They

9 needed a frame of reference that was more recent

10 than 1994. And so this is what they picked. They

11 picked the IECC because it applies to, you know,

12 single-family homes. And obviously it's not going

13 to be the same in every case because the homes are

14 different. But they needed a point of reference,

15 and they chose not to reference the old HUD

16 standard. They chose to reference the energy

17 code. And, you know, taking into consideration

18 the differences of the home and the different,

19 some of the very unique characteristics, this is

20 kind of where they intended to start. That is my

21 reading of that statute.

22 MS. HOFFMAN: Joe?
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1 MR. HAGERMAN: Yes. So not to confuse

2 anything but just to offer up maybe some helpful

3 suggestion or whatever, the analysis that we are

4 going to be providing is going to be based on the

5 2015. So we're going to show everybody that, of

6 course. And then we are going to show you also

7 how it compares to 2012, 2009, 2006, et cetera, et

8 cetera; right? But I agree. I think we should

9 start with 2015 as a starting place and then

10 discuss backwards.

11 MR. RAMIREZ: Yes. Before we get to

12 Richard, I am not hearing too much of a

13 difference. It's just a matter of how we are doing

14 it; right, whether it be reverse engineering or

15 forward lighting; right? What you are saying is

16 go forward, using this and go forward. What

17 they're saying is let's go here and go backwards.

18 So either way, I think that you end up dealing

19 with the same components is kind of what I am

20 hearing there. But the preference is to start off

21 with 2015 IECC.

22 Go ahead.
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1 MR. POTTS: Richard Potts. Not to put

2 him on the spot, but I don't know if the HUD reps

3 are here to observe and report or if they can

4 weigh in on or if we need any clarification.

5 MR. RAMIREZ: At this point, the

6 observers will have a moment for comment at the

7 end of the day. We're trying to keep it with the

8 Working Group.

9 MR. HAGERMAN: Yes. Just to be clear,

10 HUD is just a member of the public in this Working

11 Group meeting? They're not a Working Group

12 member?

13 MS. HOFFMAN: Right, but at a break, if

14 you want to talk to the people, sure.

15 MR. HAGERMAN: Maybe clarifications on

16 things and --

17 MS. HOFFMAN: Sure.

18 MR. RAMIREZ: I'm sure they wouldn't

19 mind if you picked their brain during the break.

20 MS. HOFFMAN: Yes. We'll make sure

21 there's a break as well. Okay.

22 MR. RAMIREZ: Let's get Robert and Mark.
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1 MS. HOFFMAN: Yes.

2 MR. LUTER: Rob Luter with Lippert

3 Components. In this discussion, are we to assume

4 that it is the intent of Congress or DOE that once

5 we have an end product here, all things thermal in

6 the current HUD code will be discarded? Are we to

7 not consider those at all, the methodology?

8 MR. RAMIREZ: I think it's up to you.

9 MR. LUTER: Is this going to be a DOE

10 code? It is going to be a HUD code? What's it

11 going to be?

12 MR. HAGERMAN: It is definitely a DOE

13 standard.

14 MR. LUTER: Okay.

15 MR. HAGERMAN: And I would assume that

16 the levels that are selected would be superior

17 than what is in the current HUD code. So you

18 would by default

19 --

20 MR. WEISS: So it would supersede the

21 HUD code.

22 MR. HAGERMAN: Yes. By default, you
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1 would already meet the requirements of the HUD

2 code.

3 MS. HOFFMAN: Does that answer your

4 question, Rob?

5 MR. LUTER: Kind of. Yes. Sure.

6 MS. HOFFMAN: Who is next?

7 MR. RAMIREZ: Manny.

8 MS. HOFFMAN: Manny?

9 MR. SANTANA: Yes. Manny with Cavco.

10 You know, going back, you know, just a little bit,

11 still on the point of how to start and which way

12 to go, you know, one reason why I think that it is

13 important to start with the HUD code, you know,

14 again, is because that is where we are. And we

15 need to see this thing in terms of improvement.

16 Anything that we do is going to be an improvement.

17 You know, anything that we do is going to be an

18 improvement, potentially is going to add cost, you

19 know. So I think it would be easier to see it in

20 "Okay. This is where we are at. This is how we

21 are going to improve. This is how much it is

22 going to cost. This is how we are going to
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1 improve again. This is how much that is going to

2 cost. This is how we are going to improve again.

3 This is how much that is going to cost."

4 If we start at 2015 and start taking

5 away, it is going to be harder to quantify "This

6 is how much we are going to save" because we're

7 not actually going to save anything. So if we go

8 back down, how much are we going to save then?

9 We're still going to have to go back and figure

10 out how much of a cost increase that is.

11 So, again, starting with the HUD code,

12 this is what we add. This is what we increase in

13 cost. This is what we add. This is what that cost

14 is. It will be easier than saying, "This is where

15 we are in 2015. We're going to take this away.

16 What is that going to cost us? Then we are going

17 to take that away. Now how much less is that

18 going to cost?" You are still going to have to --

19 you know, I can draw you a chart, I think, of what

20 I have in my head. But I think it would be easier

21 to start at the HUD and then come in because

22 everything is increasing.
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1 MR. HAGERMAN: In the analysis we

2 provide, you can do that. All right? You will be

3 able to take -- you know, you were working from

4 the left side of the table to the right. And I

5 think Eric is working from the right to the left.

6 But you will have all of the data there; right?

7 And you can run all of your costs off that data.

8 MR. RAMIREZ: Let's get Mark. And then

9 we'll get you, Rob.

10 MR. WEISS: Yes. Just to go back to

11 Rob's question, I think what you were asking, it

12 goes back to why the statute says "in consultation

13 with HUD." I think they have to have input into

14 this and, you know, as I have said before, input

15 at a meaningful point so that they can relate this

16 to the existing HUD code and make relevant points

17 with respect to that.

18 As far as Rick or anybody from HUD

19 participating, I don't have the new ground rules

20 in front of me, but I believe they said yesterday

21 that a participant can call on another individual

22 to elaborate on a relevant point.
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1 MS. HOFFMAN: Right.

2 MR. WEISS: And I think that is what

3 Richard was talking about.

4 MS. HOFFMAN: Okay. Who's next? Rob?

5 MR. RAMIREZ: Rob.

6 MS. HOFFMAN: Rob, yes? Okay. Richard?

7 MR. POTTS: Richard Potts. I might have

8 used up my 17 seconds of attention span, but what

9 are we trying to resolve or reach at this point?

10 Are we just kind of going over some ideas or

11 issues that people have or are we trying to figure

12 out, are we going to use the IECC or the HUD code

13 as a starting point? I'm trying to figure out --

14 MR. RAMIREZ: Yes. At this point --

15 MR. POTTS: -- how we're getting into

16 this point.

17 MR. RAMIREZ: Yes because we are getting

18 a bit off --

19 MR. POTTS: Okay.

20 MR. RAMIREZ: -- as far as where we are

21 going into the process. You all want to talk

22 about what we are calling affordability, which
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1 later on was clarified to be increase the

2 efficiency of manufactured homes while optimizing

3 cost-effectiveness as in cost-effectiveness and

4 lifecycle cost and purchase price. So there is

5 more going towards that cost-effectiveness. What

6 is it? We need to make sure that we are all on

7 the same page. That is where the conversation was

8 hopefully going. I think we saw a squirrel at

9 some point and got diverted.

10 MS. HOFFMAN: Yes.

11 MR. LUTER: Very quickly. I was at my

12 18 seconds. That's why I lost it. The exchange

13 between Joe and Manny, Manny is advocating for

14 starting at the HUD code. Joe and others are

15 advocating for starting at the 2015 IECC. And Joe

16 indicated that we would be receiving analysis from

17 PNNL that we could have a starting point. It is

18 my understanding that the analysis that is being

19 done isn't even including the current HUD code.

20 It's various releases of the IECC. Now, did I

21 misunderstand or will there be an analysis based

22 on the current HUD code?
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1 MR. HAGERMAN: Yes. So I believe they

2 start with a HUD baseline, but you would have to

3 review all of the assumptions that they made. My

4 understanding is they modeled. So it's an energy5 plus model. It's a 3D model of a building with

6 all the insulation and everything. So what they

7 have done is they have taken, you know, some

8 geometry and then modeled that following the HUD

9 code, --

10 MR. LUTER: Sure.

11 MR. HAGERMAN: -- run that simulation.

12 Then they do the same for the 2006.

13 MR. LUTER: Okay. Okay.

14 MR. HAGERMAN: So then you see an apples

15 to apples comparison.

16 MR. LUTER: Whichever way we approach

17 this, I think it's going to be important that we

18 can very clearly relate it back to today's HUD

19 baseline, if, for nothing else, to toot our horn

20 that we did a great job and look what we have

21 achieved here.

22 So all right. Thank you.
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1 MR. CYMBALSKY: This is John from DOE.

2 So I would like to query the people in the room.

3 What is the shipped average today? So I think in

4 my mind, when we think about the baseline and how

5 to do national energy savings from our work here,

6 we do need to know what is the average being

7 shipped right now. So I'm hearing the HUD

8 baseline. I'm hearing different versions of IECC.

9 If you took a shipment- weighted average of the U

10 factor, do we know what that is? So how efficient

11 are the homes that are being shipped today?

12 MR. LUBLINER: This is Mike Lubliner.

13 MR. EZZO: Mark Ezzo. So what you are

14 saying is take the 60,000 shipments that industry

15 did last year and what is the average actual use

16 of o of each? Okay. I see what you are saying.

17 MR. CYMBALSKY: In my mind, so that is

18 what we do in appliances. Right? So the federal

19 minimum could be 300 kWh per year, let's say. But

20 industry because of ENERGY STAR and other things,

21 they could produce above the baseline more

22 efficient. And so when we go to do our national
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1 energy savings, we don't want to refer back to the

2 HUD code that may be irrelevant to what is

3 actually -- I mean, it's relevant in a sense that

4 people follow it, but they also exceed it to some

5 degree. I may be wrong, but I hope that is the

6 case. And if it is the case, we want to get the

7 arithmetic right. We want to be able to say our

8 work here saves, you know, X btus, it costs $X to

9 do that. I mean, that's the nitty-gritty of what

10 we are trying to compare and negotiate around, I

11 think.

12 MS. HOFFMAN: I think, Emanuel, you have

13 --

14 MR. LEVY: Yes. We have been asked that

15 question a number of times. And the answer is

16 pretty much the same. We don't know for sure, but

17 we know a couple of things that might help answer

18 the question. One is that about ten percent of the

19 homes that are being built today are ENERGY STAR

20 homes. We know exactly how each one of those

21 homes is built because we have a database of all

22 of those homes.
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1 The second thing is if you asked that

2 question five years ago or ten years ago, you

3 would get a different answer than today because

4 the market became much more competitive, as Mark

5 will tell you. And, as a result, builders started

6 building closer to the HUD minimum. And over that

7 period, as the competition kicked in and price

8 became a much bigger factor and people were

9 willing to pay less, so over time, that has

10 changed. Just anecdotally, it has gotten lower,

11 but it is probably headed back up right now.

12 In some parts of the market, there will

13 always be low-cost product. HUD minimum product,

14 Mark and Manny and others can comment better than

15 I can where that product is being built in what

16 proportion, single-section units. By and large,

17 if you drew a triangle, I think, between, let's

18 say, Kentucky, Virginia, and Florida, within that

19 triangular area, you would have the least-cost

20 product being built today.

21 MR. LUBLINER: This is Mike Lubliner.

22 MR. RAMIREZ: Go ahead, Mike.
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1 MR. LUBLINER: Yes. I kind of concur

2 with Manny that if we were to go ahead and look at

3 the ENERGY STAR as kind of a weighted current

4 process, so, you know, X is ten percent ENERGY

5 STAR with this Uo and the rest are minimum HUD,

6 that may be a good starting point for this

7 analysis. One thing to caution, though, is with

8 the ENERGY STAR package, at least historically,

9 that was subsidized, in part, by tax credits by

10 all the taxpayers in the United States. So when

11 the tax credits aren't there, you might not get as

12 high a percentage of ENERGY STAR homes. And I

13 defer to Emanuel to assist us with that, but I do

14 think it is appropriate.

15 And, finally, on this point, I would

16 like to point out that, you know, getting back to

17 Mark's comments about affordability and the entry18 level buyer, one thing to think about if we're

19 looking at that area, those entry-level buyers

20 don't typically opt for anything beyond the

21 minimum. So my recommendation is to try to stick

22 as close to the HUD minimum unless we have data
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1 like ENERGY STAR or other manufacturer data that

2 supports a higher what we'll call current practice

3 baseline.

4 Thank you.

5 MS. HOFFMAN: Okay. Okay. My thought

6 is just a thought. I think we should take like a

7 15- minute break. When we come back, we will look

8 at this and then take a look at that as well.

9 MR. CYMBALSKY: Can I just add one item

10 here?

11 MS. HOFFMAN: Yes, sure.

12 MR. CYMBALSKY: And then we'll break.

13 So in appliance standards, we have our consultants

14 have the opportunity to sign nondisclosure

15 agreements with manufacturers to collect data.

16 That data is not disclosed to the federal

17 government. It is rolled up to be used in our

18 analyses. And the public only gets to see sort of

19 industry-wide data. I bring this up because if

20 there are manufacturers who may be willing or

21 organizations be willing to sign the NDAs and

22 provide data they otherwise might not want to
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1 provide and make public, that vehicle does exist.

2 That data does a really good job of framing our

3 analyses and making a better analysis when we get

4 into the nitty- gritty. So I just want to throw

5 that out there. And if you have questions, I

6 would be happy to take them about that.

7 MS. HOFFMAN: Okay. Okay. So we are

8 going to take a 15-minute break and come back

9 refreshed and continue. Thank you.

10 (Off the record.)

11 (On the record.)

12 MS. HOFFMAN: First we want to welcome

13 Ishbel back. And, Stacey, thank you for

14 summarizing what had happened. And maybe at

15 lunch, Ishbel, you can get the same wonderful

16 presentation from Emanuel that we had. Oh. Well,

17 then another time.

18 The other thing is in talking with the

19 folks from Navigant, we'll send out a list of

20 those states where you may have to bring if we're

21 back meeting here alternative IDs beyond your

22 driver's license.
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1 MR. RAMIREZ: It's not just Washington

2 that's caught up in that.

3 MS. HOFFMAN: Yes. We found out quite a

4 few states. So we'll definitely make sure

5 everybody is aware of that and for alternative

6 methods of identification get in. Okay.

7 Also, there was a question about

8 relationship of talking with folks in the

9 audience; right? And did you have a --

10 MR. CYMBALSKY: Mike Jensen is going to

11 come back and explain.

12 MS. HOFFMAN: And explain. Okay. On

13 that score.

14 Where we are now has been a discussion a

15 little bit about, really, the charter for this

16 group, which is what to apply and how to do it.

17 And we haven't reached total consensus on that,

18 but we have had a discussion about the

19 International Energy Conservation Code and the use

20 of the most recent publication of that document.

21 And also we'll be receiving the numbers, which we

22 can go over in time for the next meeting using
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1 whatever approach you want to use, which we'll do.

2 I'm going to turn it over to Javier now

3 because I think we might want to look at some of

4 the things we started with yesterday.

5 MR. RAMIREZ: Yes. Because probably I

6 guess what I'm struggling with is that yesterday

7 when we were outlined the whole scope over here

8 and even before then, it was my understanding that

9 we were over here to talk about a DOE standard.

10 And also yesterday this was for a -- we were only

11 going to be using the 2015, 2015 IECC, as a

12 starting point. And, Manny, I hear you loud and

13 clear. In my head, I think it's just seriously

14 which way you attack it. I don't think anyone is

15 dismissing at all what you are saying as far as

16 but where are we at; right? So I'm not seeing

17 that as a big problem. It's just a matter of do

18 we make sure that we are looking at both of those

19 values; right?

20 MR. SANTANA: You know, I think that is

21 going to depend on whether --

22 MR. SCHNEIDER: Peter Schneider.
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1 MR. RAMIREZ: I'm sorry, Peter. Hold on

2 one second. Manny?

3 MR. SANTANA: That just depends on

4 whether or not the analysis includes, you know,

5 the versions of the IECC as well as the HUD

6 baseline. And that does. And then it would be

7 easy to see where we are at.

8 MR. RAMIREZ: Okay. I believe we are

9 going to get some of that.

10 MR. HAGERMAN: Yes, absolutely. And let

11 me just add, too, if you know that there are some

12 items that are, you know, specific to manufactured

13 homes that would have to be changed to meet the

14 2012, like you know, you have already done the

15 analysis yourself and you know if you go from --

16 MS. HOFFMAN: Do you mean 2012 or 2014?

17 MR. HAGERMAN: No. I mean 2012 just

18 right now --

19 MS. HOFFMAN: Okay. Sorry.

20 MR. HAGERMAN: -- as an example or 2006

21 or 2009, whatever code we're talking about here.

22 If you know there are changes, give those to me.
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1 And we'll have the analysts run those as well;

2 right? I mean, they stand ready to -- you know,

3 if this group talks and says the U value in this

4 climate zone should be this number, they're ready

5 to spin up the models and give you results of the,

6 you know, annual energy consumption overnight.

7 MR. RAMIREZ: So, Peter, I'm sorry. You

8 had something?

9 MR. SCHNEIDER: Yes, just in regards to

10 next steps. I had submitted a question yesterday

11 just in regards to what climate zones are going to

12 be utilized in the energy modeling assuming that

13 our next steps are to utilize a 30-year lifecycle

14 for our cost- effectiveness analysis, which HUD

15 did originally and the DOE does, and then

16 utilizing that energy modeling. I just want to

17 make sure that we are not disadvantaging, for

18 instance, a heating-dominated climate, like in

19 Vermont, that is currently put in the same block

20 as Virginia. That would disadvantage, you know,

21 the argument for efficiency and affordability.

22 MR. RAMIREZ: Okay. And it seems like
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1 everyone really wants to get to that first one;

2 right? I want to make sure that you all want to

3 have that discussion of affordability, but we kept

4 veering off. It always seemed like we kept trying

5 to go to that climate zone and really starting to

6 dig into some of the issues. Go you want to

7 continue that discussion on affordability with

8 hopefully developing some type of understanding or

9 do you want to move on to that first issue?

10 MR. SCHNEIDER: Well, this is Peter

11 again from efficiency. But, now, just one

12 additional comment, just in regards to the idea of

13 like where do we start. This idea that we would

14 start at HUD and move up, I think that starting

15 with the 2015 IECC is the right approach because

16 we are talking about a comprehensive package. You

17 know, at the end of the day, if that standard is

18 to be met and can be met by our manufactured

19 housing industry, a whole different assortment of

20 benefits come into play in regards to the way that

21 we heat and cool and dehumidify these spaces, the

22 way we ventilate these spaces. And if we just
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1 take the current HUD standard and start adding one

2 piece at a time, we lose the comprehensive nature

3 of that package. And I think that that is where

4 we should start.

5 I mean, I am confident that the

6 manufactured housing industry can build to that.

7 So the question just comes back, I think, to the

8 energy modeling and the cost analysis in regards

9 to what really makes sense and then factoring in,

10 as Michael said, when we start looking at the

11 shipment model or the price elasticity.

12 MS. HOFFMAN: Thank you.

13 MR. RAMIREZ: My original question still

14 stands, though. Do you want to continue talking

15 about affordability or do you want to move on to

16 the first issue? Robert?

17 MS. HOFFMAN: I'll just throw this out.

18 Do you want to decide today or talk about starting

19 with the 2015 model and working with that? Yes?

20 MR. LUTER: The caller kind of prompted

21 a thought on my part. And I would like to throw

22 something out.
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1 MS. HOFFMAN: Sure.

2 MR. LUTER: In addition to --

3 MS. HOFFMAN: This is Rob Luter.

4 MR. LUTER: I'm sorry. Rob Luter with

5 Lippert. In addition to the overall

6 impact on affordability, bullet 4 up there, I

7 would like to consider consumer awareness from a

8 couple of perspectives: one, that the consumer

9 understand that their potential larger investment

10 could pay off in the end; and, secondly, that the

11 consumer of today even be aware that there are no

12 barriers that exist right now for a customer today

13 buying a home that meets the 2015 IECC. All they

14 have to do is ask for the performance. Products

15 are available. In perhaps some very rare cases

16 with respect to a particular size home, there

17 might be, but all these building science products

18 exist so that if a customer could write the check,

19 they could have a home today that met the 2015

20 IECC. And it's all about customer awareness.

21 MR. RAMIREZ: Okay. Let's --

22 MR. LUBLINER: This is Mike Lubliner.
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1 MR. RAMIREZ: Mike? Hold on one second,

2 Mike.

3 MR. LUBLINER: Okay.

4 MR. CYMBALSKY: So this is John from

5 DOE. That's great news, actually. I think hearing

6 that piece of news actually gives me confidence

7 that the analysis and the numbers that we provide

8 to negotiate upon are -- are based on what the

9 market conditions are and the potential for the

10 efficiency gains are there, so that's good.

11 What we're going to, again, talk about

12 is how much does it cost to build that home, and

13 we're going to do the -- we're going to look at

14 the trade- off for upfront cost versus life-cycle

15 operating cost savings generically, so I know that

16 says life-cycle cost and purchase price, but I'm

17 not sure if we meant to say that, because we all

18 know that purchase price is part of life-cycle

19 cost, right?

20 MR. RAMIREZ: So how would that be

21 better captured?

22 MR. CYMBALSKY: I think -- I think what
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1 Robin said was the life-cycle operating cost and

2 purchase price.

3 MR. RAMIREZ: Oh.

4 MR. LUTER: Perhaps inclusive of

5 purchase price.

6 MR. LUBLINER: Correct. This is Mike

7 Lubliner. I want -- I want to follow-up on Rob's

8 comment, if appropriate, here.

9 MR. RAMIREZ: Yeah. Yeah, go ahead,

10 Mike.

11 MR. LUBLINER: Okay. So I totally agree

12 with what Rob's saying. I want to give the

13 Northwest experience. We've had a partnership

14 with the manufactured housing industry since the

15 '80s, and as a consumer in Washington State, I can

16 go into a manufactured home retailer lot, and the

17 majority of homes that are on that lot are pretty

18 close to the 2012 and even, in some cases,

19 exclusive to the 2016 IECC. We're typically

20 seeing in the marketplace, in dealer lots, R33 in

21 the floor, R38 in the lid, an R19 to R21 wall, and

22 a U-value of -- equivalent to a vinyl low-E
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1 window. And this is probably 60 percent of the

2 market, and then a good chunk of the remaining is

3 well above the HUD code minimum.

4 So I do think that the market, at least

5 in the Northwest, where we've had a partnership

6 and really done a lot of consumer awareness with

7 industry, has shown an example of if you build it,

8 they will come. Thank you.

9 MR. RAMIREZ: Okay. Rob?

10 MR. LUTER: Just a follow-up comment.

11 My point was not -- how can I articulate this

12 properly -- that -- it's been suggested by some

13 that the state of the current HUD energy code

14 presents a barrier for the consumer to get this

15 kind of performance, and it doesn't. It creates a

16 floor, minimum performance level. The barrier

17 does not exist to this.

18 MR. RAMIREZ: Uh-huh.

19 MR. LUTER: There may be some elements

20 of the marketplace where if you build it, they

21 will come. I agree, but I think if the public is

22 aware that it will come if they ask for it, they
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1 can get it today. That was my point.

2 MR. RAMIREZ: Okay.

3 MR. LUBLINER: And it --

4 MR. RAMIREZ: Yeah, go ahead.

5 MR. LUBLINER: I was going to say it's a

6 kind of a chicken-or-the-egg thing. If you offer

7 it, you'll find that many will take it. If you go

8 to a retailer lot and all there is is minimum HUD

9 and there's no buyer education, then exactly

10 that's what happens. They don't know, they don't

11 ask. They go inside. There's no label that says

12 what the energy standard is, so they can't compare

13 one to another effectively. And I think that's

14 what we'll be talking about here over the next few

15 months here.

16 MR. RAMIREZ: Mark, then --

17 MR. SCHNEIDER: Peter Schneider from

18 Efficiency Vermont. I just want to concur with

19 Michael's comments with my experience in the

20 Northeast.

21 MS. HOFFMAN: Okay. We've got Mark, and

22 then Manny.
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1 MR. WEISS: But the point is, is, as Rob

2 was indicating, the manufacturers right now can

3 provide whatever level of energy efficiency the

4 consumer wants as a matter of consumer free

5 choice. It's a different matter when you start

6 talking about mandating particular criteria

7 standards for across the board and what impact

8 that's going to have on the purchaser. But these

9 things are all available right now as a matter of

10 choice.

11 MR. RAMIREZ: Ishbel?

12 MALE SPEAKER: Yeah, Rob, again --

13 MR. RAMIREZ: I'm sorry, hold on a

14 second. Ishbel has a --

15 MS. DICKENS: Thank you. So apologize

16 again for not being here this morning. This is

17 Ishbel from National Manufactured Home Owners

18 Association. So I think -- having missed this

19 morning's conversation, I think we're getting to

20 the rub, though, in terms of, yes, the options may

21 be available, Rob, as you say, if you're willing

22 to sign the check, but I think the idea for this
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1 group is to make the -- make it not an option, but

2 just a normal part of doing business, that energy3 efficient homes are available at a cost that as

4 many people as possible can afford to pay.

5 And I don't know enough about the

6 industry, so I apologize for the very naivete of

7 my assumption, but it seems to me that when you

8 get to an economy of scale, there's an assumption

9 on my part, anyway, that the cost will be less

10 than an individual customer coming and asking for

11 a custom-built home.

12 And so my sense is that we would try to

13 get to a place where affordability and energy

14 efficiency have this magic meeting point that

15 makes the home attractive for the long term in

16 terms of energy savings, but also equally

17 attractive to as many consumers as possible

18 wanting to purchase new homes. So I don't want it

19 just to be those who can afford to get the Prius,

20 I think we called it yesterday, but that everyone

21 can afford the Honda Civic that's pretty

22 efficient.
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1 MS. HOFFMAN: And Manny was next.

2 MR. SANTANA: Yeah, this is Manny with

3 Cavco. You know, I don't think it's so much a

4 question of if you build it, they will come. Some

5 people will. You know, but I think when we talk

6 about what's affordable and what's cost-effective,

7 you know, the importance behind that isn't in just

8 the additional cost to the manufacturer. The

9 importance in that is how many people are no

10 longer going to be able to buy a house.

11 And that's -- so if you build it, they

12 will come, but if you build it and they come and

13 they can't afford it, that doesn't do them any

14 good. You know, so we -- I'd like to find out if

15 there's any way we can determine just what segment

16 of the population or what segment of the people

17 looking for affordable housing will no longer be

18 able to afford it if we get to certain increases

19 in the cost. That's what we're trying to get to,

20 you know. If we find out that's a very small

21 number, you know, and, you know, small enough to

22 be insignificant and -- then, good, that'll make
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1 our job a lot easier. But if we find out that's a

2 very large number, you know, I think it's

3 important for us to quantify just what that is.

4 MR. SCHNEIDER: This is Peter Schneider

5 from Efficiency Vermont. I just want to speak to

6 what's happening in Vermont, just as an example,

7 with our -- what's called the High-Performance

8 Mobile Home Replacement Program. I think we need

9 to think outside the box of where we need to go,

10 and once you start changing the financing picture,

11 you start changing the appraisal picture -- as an

12 example, our high- performance mobile home

13 replacement units are getting traditional

14 financing, so we have under 5 percent interest

15 rates with 30-year terms being offered statewide

16 for this product in our mobile home parks on

17 rented land. It's not an issue on privately owned

18 land.

19 We have appraisers that are trained in

20 evaluating sustainable building, so they're using

21 the Energy-Efficient and Green Addendum, and

22 they're valuing these homes far above utilizing
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1 the tools that the Institute of Appraisers have

2 developed for these types of buildings. So I feel

3 like we need to think about things outside of

4 just, you know, straight cost- effectiveness.

5 And I also just wanted to speak to, you

6 know, recently, the DOE did a study for Vermont as

7 we rewrite our energy code, going from basically

8 2009 IECC to 2012. The findings were that using a

9 30-year life cycle, you know, we're looking at

10 over $12,000 in savings to that homeowner, a 3.3-

11 year payback, and energy savings of over $705 per

12 year.

13 So, you know, again, I'd come back to

14 affordability. We need to be evaluating these

15 regional climates and not disadvantaging places

16 like the Northeast and the heating-dominated

17 climates or even the real cooling-dominated

18 climates by having these real broad HUD climate

19 zone.

20 MR. RAMIREZ: Okay, so --

21 MR. LUBLINER: This is --

22 MR. RAMIREZ: Go ahead.
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1 MR. LUBLINER: Thank you. I want to

2 just back up what Peter just said. In the

3 Northwest, since we've built over 125,000 high4 performance manufactured HUD code homes, we've

5 worked with NADA, who's the appraisal guide for

6 manufactured homes and chattel mortgage, which is

7 the most challenging area for us to improve upon,

8 and they actually have recognized values for

9 Energy Star homes and other high-efficiency values

10 that, if communicated toe the buyer, may induce

11 more buyers to take the option.

12 And back to what Ishbel was saying,

13 we're trying to get more product on the market so

14 that consumer has a choice to buy that, you know,

15 in a volume purchasing price, which is why this

16 industry is so good. They can compete pricewise

17 because they bulk buy (ph). So if we build all

18 the homes to a certain standard and that standard

19 is higher, then the consumer's going to get a

20 better price on the home, and the manufacturer, I

21 believe, will sell more homes.

22 But I would go back to the NADA
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1 documentation as an example of added value that is

2 in the chattel mortgage industry for energy

3 efficiency. Thank you.

4 MS. HOFFMAN: Okay. We've got two

5 folks, David and Lowell, and then we may want to

6 move around a little bit. David, please.

7 MR. TOMPOS: Dave Tompos from NTA. I

8 just want to point out that this industry has

9 changed a lot in the last 10 to 15 years.

10 Manufacturers aren't building as many stock homes.

11 I don't know what the percentage is. We'd have to

12 find out from a manufacturer, but most of these

13 homes are custom homes. The consumer comes in and

14 asks for whatever options they want. There's not

15 a lot of homes sitting in lots that -- most homes

16 that are sold are sold because they have an order

17 for that home from a consumer, so there's not

18 stock units just sitting out on lots anymore.

19 MS. HOFFMAN: And --

20 MR. LUBLINER: Hey, Dave, Mike here.

21 Just follow-up on that, if it's appropriate here.

22 Do you find that that's the case for the entry-
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1 level home, the single-wide entry-level home, or

2 for the higher- priced multi-section home,

3 generally? Do you see a lot of distinction there

4 in terms of custom orders versus what they buy off

5 the lot?

6 MR. TOMPOS: I think it's across the

7 board. I mean, I'm sure you're going to see more

8 of that with the higher-cost units, but from what

9 I've heard from manufacturers recently is almost

10 all of their orders now are because they have an

11 order for it. It's not a stock unit.

12 MS. HOFFMAN: Okay. Lowell? Thank you.

13 DR. UNGAR: Thanks. There's two things.

14 One is on impact on who can afford it. I think

15 that's an interesting question. I would just add

16 we should also look at the impact of being able to

17 afford to keep the home, of the being able to

18 afford the energy bills, assuming our

19 understanding that for some of these homes,

20 particularly older homes, there are some very high

21 energy bills and have been a real problem for some

22 of the homeowners who may have the home to be able
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1 to actually heat and cool them. So that just

2 needs to be taken into account as well.

3 On the question of being available on

4 the market and need for a standard, it's great if

5 people can build these home. That sounds like the

6 technical capability that Mike has referred to may

7 not be an issue, which certainly would make our

8 job easier. The -- I mean, there's long debates

9 about standards and need for them. I'm happy to

10 bring in some of the literature on economic

11 barriers and on the impact of -- particularly in

12 appliance standards as well as vehicle standards.

13 There's been a lot of literature on historical

14 impact and such.

15 In the end, I mean, if we conclude that

16 there's no standard necessary, that's not very

17 much help to DOE, because DOE is under mandate to

18 set a standard. I mean, Congress has already

19 decided there needs to be an energy standard, and

20 our work will be more useful if we say what the

21 best way to set it is than if we spend our time

22 debating the need for one.
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1 MR. RAMIREZ: Yeah, that's what --

2 that's what I was going at initially when we came

3 back from break, and I want to go back there,

4 because it seems like, even though we had some

5 discussion on the affordability, we're not going

6 to be able to necessarily agree on, you know,

7 common definitions, because I think there's too

8 many moving pieces, where it might be applied to

9 each component as we're going through. Right?

10 So instead of actually trying to nail

11 down what's the definition of cost-effectiveness,

12 I think in general, we're talking about life-cycle

13 operating cost and purchase price, a combination

14 of that. With that general understanding, are you

15 all okay with moving on to that first issue?

16 MR. WEISS: Well, what I wanted to say

17 was I think that we cannot get away from this

18 issue totally without having some understanding of

19 the financing climate, because that's directly

20 relevant to affordability, no matter how you look

21 at -- from which perspective you look at it,

22 that's very relevant information. And part of the
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1 purpose of the discussion, as we know from the

2 beginning, is we want to be able to have -- we

3 want to identify the information we need in order

4 to have the conversation that we need to have. So

5 I think we need information on financing and the

6 current market conditions for financing.

7 MR. RAMIREZ: Okay. So what I wanted to

8 do -- there were a few things. One of them is if

9 you notice on Number 13, you all didn't see these

10 11, 12, 13, 14 points yesterday or even this

11 common definition. But on that 13, it's financial

12 and has the financing -- and if you could go --

13 yeah, then view, and then single it out, just to

14 enlarge it, and then fit to window. Yeah.

15 MS. HOFFMAN: Better, yeah?

16 MR. RAMIREZ: Better for me. I was

17 right up here. That's why it's paused.

18 MS. HOFFMAN: How many fingers am I

19 holding up?

20 MR. RAMIREZ: Yeah. All right. So --

21 no, that's not the one.

22 MS. HOFFMAN: That's not the financing -
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1 -

2 MR. RAMIREZ: No, go back to the -- all

3 topics. Yeah, 13. I'm sorry. And then -- yeah,

4 it's just a few clicks here. All right. So what

5 you're talking about, we're going to get there,

6 right, because the financing is in that component

7 there. So we go back to all topics.

8 What I wanted to do was to, at some

9 point today -- I think we might be better off

10 seeing if we can't maybe get agreement on one, but

11 at some point, I want to see if we could put these

12 topics into four broader categories, right, one of

13 them being envelope of building, which includes

14 flashing windows, skylights, insulation, et

15 cetera. That would be one.

16 Equipment, including appliances, HVAC,

17 DWH (ph), ducts, ventilation, et cetera.

18 Financial, which we just saw, and then building

19 performance, operating and maintenance,

20 durability, climate zones, energy consumption,

21 comfort, indoor air quality, Energy Star Rating,

22 things like that.
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1 Do those broad categories make sense to

2 you? And, you know, go in and enlarge it and put

3 them up like this goes over here, and you can

4 slide it too. Yeah, go ahead and make it bigger,

5 and then you can use the bars here to center it.

6 Yeah, that's what I want to focus on, the four

7 highlights. The four highlights at the center. Do

8 those four broad categories make sense? We could

9 add others or tweak them if need be.

10 MR. CYMBALSKY: Since I'm here for John

11 Caskey and he sent the email, just say yes,

12 because he wrote in his email to everybody --

13 well, at least to a few of us -- that these are

14 the four categories that he thinks are what we

15 should focus on. And he also mentioned we should

16 start with the climate zones at some point.

17 MR. RAMIREZ: Yeah, I want --

18 MS. HOFFMAN: But we're going to get to

19 that. Don't worry.

20 MR. RAMIREZ: Yeah, the --

21 MS. HOFFMAN: Yeah.

22 MR. RAMIREZ: The group definitely
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1 identified that one as the -- what I call the low2 hanging fruit, right, something that we could

3 probably reach agreement on. So we'll -- we can

4 come back to this and see if we can get what we've

5 already put on here into an offset of one of these

6 four categories, right? But are you all okay --

7 so the first question, are you okay with the

8 general understanding of affordability that we had

9 discussed, which is at the very top?

10 MS. HOFFMAN: Where would the consumer

11 awareness come in? Thirteen?

12 MR. RAMIREZ: Yeah.

13 MS. HOFFMAN: So you might add consumer

14 awareness there.

15 MR. RAMIREZ: Yeah, that --

16 MS. HOFFMAN: What -- by the way, we did

17 get that email. I realize it wasn't everyone.

18 For a minute, I thought it was. He's sorry he

19 can't be here today. We do have John Cymbalsky

20 instead. But he thought maybe it would be easier

21 to get our arms around things if we had a broader

22 four categories instead of all of those, but we'll
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1 --

2 MR. RAMIREZ: We'll still deal with

3 these issues.

4 MS. HOFFMAN: We'll still get to them --

5 MR. RAMIREZ: Right.

6 MS. HOFFMAN: -- all of them.

7 MR. RAMIREZ: So let me back up and take

8 it up by pieces, right? So the first one, is

9 everyone okay with just broadly that life -- that

10 operating cost effectiveness is life-cycle

11 operating cost and purchase price? Let me see a

12 show of thumbs if we're okay with that as a broad

13 understanding. And then dealing with cost14 effectiveness on each issue. Eric?

15 MR. LACEY: Just going back to the

16 statute, it says on --

17 MS. HOFFMAN: Push your button.

18 MR. RAMIREZ: Mic?

19 MR. LACEY: Oh, I'm sorry. I'm sorry.

20 Eric Lacey. Going back to the statute, it does

21 say, on the purchase price in manufactured housing

22 and on total life-cycle, construction, and
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1 operating costs, just a minor thing, could you add

2 construction and operating costs and purchase

3 price? Minor thing.

4 MS. HOFFMAN: Construction before

5 operating costs, right?

6 MR. LACEY: Yeah.

7 MS. HOFFMAN: Life-cycle, comma --

8 MR. LACEY: Yeah, right there.

9 MS. HOFFMAN: -- construction, and

10 operating costs?

11 MR. LACEY: Life-cycle, construction,

12 and operating costs.

13 MS. HOFFMAN: Okay.

14 MR. LACEY: And purchase price.

15 MR. ROY: Yeah, Rob Roy. A question --

16 MR. LUBLINER: Mike Lubliner here.

17 MR. ROY: Question for Joe. The

18 analysis you're getting from PNNL, that will give

19 us four different efficiency levels, total

20 purchase price implication, or total cost, as well

21 as life-cycle costs?

22 MR. HAGERMAN: There's no cost. It's
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1 just --

2 MR. ROY: No cost?

3 MR. HAGERMAN: -- annual energy.

4 MR. ROY: Just the annual energy.

5 MR. HAGERMAN: Yeah.

6 MR. RAMIREZ: All right. So backing it

7 up again --

8 MR. HAGERMAN: Yeah, I'm sorry. Hold

9 on. Annual energy, and then you'll see all the

10 inputs that were used, so you'll see what the

11 selection was for each model in terms of window

12 and, you know, amount of insulation, so

13 MR. RAMIREZ: So with that modification

14 to that understanding of cost-effectiveness, is

15 everyone okay with that general understanding to

16 move on? Let me see a show of thumbs again.

17 MR. LUBLINER: Yes.

18 MR. RAMIREZ: Okay. All right. Then --

19 and I'll tell you what. For the folks who are

20 online, if you object, just speak up; otherwise,

21 we'll assume that you're on board. Okay?

22 MALE SPEAKER: You've got it.
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1 MR. RAMIREZ: So then, moving on, let's

2 look at that -- let's look at that first topic up

3 there. And let me try something here. If you go

4 to "Tool," and then --

5 MS. HOFFMAN: You mean HUD or this one,

6 Number 1?

7 MR. RAMIREZ: Yeah, uh-huh.

8 MS. HOFFMAN: Yeah.

9 MR. RAMIREZ: And then split. Uh-huh.

10 MS. HOFFMAN: Because I believe that Joe

11 has some information to distribute on climate

12 change.

13 MR. HAGERMAN: On climate zone.

14 MS. HOFFMAN: Climate zone.

15 MR. HAGERMAN: Climate zone information.

16 MS. HOFFMAN: Climate zone.

17 MR. HAGERMAN: So I pulled some analysis

18 -- or last night, late last night, on the climate

19 zone discussion. So it's an energy analysis

20 methodology -- it's a report from PNNL, the

21 climate zone mapping between HUD and the IECC, so

22 I'll give you this. It's just three figures and a
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1 little description.

2 MR. RAMIREZ: All right. So we'll take

3 a few minutes and read that before we --

4 MS. HOFFMAN: Talk about it.

5 MR. RAMIREZ: -- start the conversation.

6 MR. HAGERMAN: And we're going to --

7 Jeremiah just sent -- should have just sent that

8 out to everybody so you have a copy of it.

9 MR. LUBLINER: This is Mike Lubliner.

10 MS. HOFFMAN: Yes, Mike?

11 MR. LUBLINER: I was wondering if we may

12 be able to solve this climate zone one pretty

13 quickly here, and so I was wondering at some point

14 after we read this, if we could do kind of a straw

15 poll on how many people would think that it's

16 appropriate to retain the HUD climate zones. We

17 may be able to get through this one real quick.

18 MS. HOFFMAN: Well, let's let everybody

19 read them first, okay, and --

20 MR. LUBLINER: Sure. Sure.

21 MS. HOFFMAN: -- then we'll see. I hear

22 what you're saying, though.
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1 MR. LUBLINER: And I wanted to just

2 comment to Peter, it's my understanding the HUD --

3 the Climate Zone 3 is Vermont, so it's the most

4 stringent climate zone for HUD code.

5 MR. SCHNEIDER: Hey, Michael, this is

6 Peter. I was just suggesting that it's the same as

7 Virginia, and that was a problem.

8 MR. LUBLINER: Oh, I'm sorry.

9 MS. HOFFMAN: Hi. I'm just going to

10 interrupt your reading just for a moment, and

11 we'll go back to it in a second. I want to

12 introduce Mike Jensen, who's with the General

13 Counsel's office at Department of Energy, and

14 we're going to ask him to talk about the

15 relationship between this committee and the

16 audience and the public.

17 MR. JENSEN: Good morning, everyone.

18 I've just been asked to talk briefly. A

19 procedural issue came to mind, and I thought I

20 would give you my 30- second spiel, and that is

21 the relationship between the committee that we

22 have here and members of the public.
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1 Based -- it came to my attention that

2 there was some misunderstanding of how there was

3 the relationship between whether this committee

4 could actually interact with members of the public

5 and have a back-and-forth dialogue. Based on what

6 it seems in the charter that we agreed to

7 yesterday, it lays out that any working group

8 member may call upon another individual to

9 elaborate on a relevant point, and that extends to

10 members of the audience, including other agencies

11 that are represented as members of the audience

12 today.

13 I also understand that the way that the

14 schedule is laid out today, that there'll be a

15 period at the end of the session this afternoon --

16 MS. HOFFMAN: Uh-huh.

17 MR. JENSEN: -- where members of the

18 audience, including other agencies, can offer

19 their opinions. We only ask that members of the

20 audience identify whether they're speaking on

21 behalf of a particular agency, identify

22 themselves, or identify as to whether they're
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1 submitting a comment as a member of the public.

2 And this committee should just keep in

3 mind that the ASRAC and -- the committee is

4 presenting, I guess, a path forward for the

5 secretary to make a decision on how to accept

6 proposals are a rulemaking, so we should consider

7 each member of the audience's opinions as that --

8 as an opinion as one idea or issue that we should

9 take into consideration moving forward towards

10 achieving that consensus. So with that --

11 MS. HOFFMAN: Uh-huh.

12 MR. JENSEN: -- that's all that I wanted

13 to add.

14 MS. HOFFMAN: All right. Thank you.

15 MR. JENSEN: Is there any -- does anyone

16 have any questions as to how we should proceed

17 moving forward with the relationship between

18 members of the public and this committee today or

19 in future meetings?

20 MR. LUBLINER: This is Mike Lubliner. I

21 had a question. I understand that HUD is part of

22 the public, and so that's what I heard today. I
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1 want to just confirm that.

2 MR. JENSEN: Yes, for --

3 MR. LUBLINER: Because if so, I'd like

4 to be able to -- if HUD is going to speak during

5 public comment, I'd like to be able to provide --

6 ask some questions to help inform the committee of

7 HUD. So I'm trying to figure out when it would be

8 best to dialogue and ask my questions of HUD.

9 MR. JENSEN: Yes. For those of you that

10 are on the phone, well, there is a representative

11 from HUD in the audience, and any of you in the

12 room or on the phone may ask questions of HUD as

13 we move throughout the negotiation, and HUD may

14 offer its input on any -- on clarification on any

15 particular issue. If there are opinions that HUD

16 would like to state, or any member of the public

17 would like to state on behalf of a particular

18 organization, agency, or just individual, we ask

19 that we -- that those positions hold off until the

20 session at the end of this afternoon.

21 MS. HOFFMAN: Yeah, we do have a

22 specific time at three o'clock, actually, a half-
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1 hour, so -- for discussion, and we had something

2 similar yesterday at 4:30.

3 MR. RAMIREZ: Yeah, and I guess to be --

4 MR. LUBLINER: Thank you.

5 MR. RAMIREZ: -- a little more clear on

6 that, Mike, yeah, you -- if there is a moment at -

7 - during that time, if you want to ask a question,

8 we would facilitate that.

9 MS. HOFFMAN: Uh-huh.

10 MR. LUBLINER: Thank you.

11 MS. HOFFMAN: Okay. Thank you. And

12 right now, let's go back to reading this so we can

13 look at climate zones. Thank you, Mike.

14 MR. RAMIREZ: All right. Do you want a

15 few minutes, or are we ready to start talking

16 about this? All right. So I'm pretty grateful

17 that I don't have to understand this sheet, but

18 you all do, so let me start off with are there any

19 questions for understanding? We could ask other

20 type of questions, right, but so just to

21 understand what we're looking at.

22 MR. DENNIS: Yeah, I have a very basic
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1 question. So if a -- if, say, the group chose the

2 HUD zones, and then ICC -- IECC 2015 is certified

3 by DOE and a state chooses to adopt it, does that

4 not cover manufactured housing, so it wouldn't

5 preempt the HUD standard? Okay. And then on a

6 state level, I know some states are probably going

7 above ICC (sic) code. Would they be able to go --

8 if they chose a code above IECC, would they have

9 to specifically mention a code for manufacturing

10 above whatever we choose, and then -- but that's

11 possible. They're allowed to do that? Just --

12 that's a floor -- so just kind of an overview of

13 how that works.

14 MS. STARKEY: No, the HUD code is

15 preemptive. Now, there was a recent issue in

16 Minnesota with respect to a requirement of site

17 built and modular to do duct blower door testing

18 on-site. That ruling just came down from HUD,

19 saying, no, that even though that provision is not

20 in the HUD code, there's no aspect of performance

21 for blower door testing at this point, the HUD

22 code does address energy standards, thermal
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1 performance, and therefore it is preemptive, so

2 Minnesota could not implement that aspect. In

3 general, the HUD code is preemptive. In every

4 aspect of performance that is in the HUD code,

5 generally a state cannot adopt anything for that

6 HUD code. It has to adopt the HUD code.

7 MR. LUBLINER: This is Mike Lubliner.

8 Lois, I was just wondering, on the Minnesota

9 thing, I think that's something for the parking

10 lot that we should follow up with, but I did --

11 wondered if DOE's legal counsel has looked at

12 HUD's interpretation, because I've had numerous

13 legal people look at HUD's interpretation on the

14 blower door requirements in Minnesota, and they

15 have different spins. So I would be interested in

16 getting HUD's interpretation to legal counsel, if

17 it hasn't happened, to see if we concur, and then

18 we can talk about that when we get to the blower

19 door discussion.

20 But I concur with you that it's a

21 preemptive -- the HUD code is preemptive, and so

22 it's -- in the Northwest, we've had a lot of lost
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1 opportunities, as compared to our site build (ph)

2 code because of the preemptive nature of the code,

3 and that's one of the reasons we're here.

4 MR. CYMBALSKY: So this is John from

5 DOE. So the DOE GC is not going to opine on HUD's

6 decision at this point. Just leave it at that.

7 MS. HOFFMAN: Go ahead.

8 MR. TOMPOS: Dave Tompos. I just wanted

9 to make sure everybody understands that the

10 consumer can still choose to do that blower door

11 testing anywhere in the country. It's not

12 required, but they can always choose to do that,

13 and we do do that with the Energy Star homes.

14 MS. STARKEY: And if I might clarify

15 too, a lot of local jurisdictions will, as they

16 have done in Vermont with smoke detectors or --

17 they will say, "Well, we don't care what the HUD

18 code says. If you want to put your house in this

19 jurisdiction, you need to have this particular

20 smoke detector." And unless a manufacturer or a

21 retailer or a homeowner is -- you know, is going

22 to protest, most of the time -- you know, so it
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1 doesn't -- you know, consumer wants to have that

2 house there, and the manufacturer will put the

3 smoke detector in.

4 MR. RAMIREZ: Eric?

5 MR. LACEY: My comment is not about the

6 Minnesota issue. I don't know if anyone else

7 wanted --

8 MS. HOFFMAN: Yeah.

9 MR. LACEY: -- to say anything else

10 about that.

11 MS. HOFFMAN: I would just deal with

12 climate zones --

13 MR. LACEY: Okay. Well --

14 MS. HOFFMAN: -- in this --

15 MR. LACEY: -- then I --

16 MS. HOFFMAN: -- (inaudible).

17 MR. LACEY: -- I had a question. I have

18 some thoughts on -- when we get to discussing, you

19 know --

20 MS. HOFFMAN: Yeah.

21 MR. LACEY: -- you know, our opinions on

22 the climate zone map, but I had a question for the
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1 manufacturers of the homes. I see that there are

2 -- there are three, you know, climate zones here.

3 The Climate Zone 2 seems to be a really narrow

4 little swath, and I'm curious as to whether you

5 build that specifically to each of the three

6 different climate zones or whether you would build

7 something that's good in two or three of the

8 climate zones.

9 I -- my experience with specific product

10 manufacturers, you have some examples in the

11 window industry, for example, where, you know, the

12 Energy Star map is a little different than the

13 IECC climate zone map. Again, it's, you know, a

14 few -- or a few climate zones as opposed to eight.

15 But in reality, some of them make a window that's

16 good in all climate zones or in northern climate

17 zones and southern climate zones. They'll make

18 two different -- so I'm curious. I don't know if

19 this is something you can say, but do you very

20 specifically go for one specific climate zone, or

21 do you sometimes make a home that's good in two or

22 three climate zones? I don't know this.
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1 MR. SANTANA: This is Manny with Cavco.

2 You know, if -- anything that's good for Climate

3 Zone -- or Thermal Zone (ph) 3 is good for 2 and

4 1. So anything -- yeah, 2 is good in 1; 1 is only

5 good in 1.

6 MR. RAMIREZ: So let me back it up

7 again. Are there any additional questions as far

8 as for clarity, clarity of what we're looking at?

9 MR. WEISS: I would just appreciate if

10 perhaps -- if Joe could just go over this and just

11 give a general --

12 MS. HOFFMAN: Yeah.

13 MR. WEISS: -- for the non-technical

14 folks here.

15 MR. RAMIREZ: Yeah.

16 MS. HOFFMAN: Sure.

17 MR. RAMIREZ: Okay, sure.

18 MS. HOFFMAN: Joe or John, can you walk

19 us through this?

20 MR. CYMBALSKY: No, no. No John.

21 MS. HOFFMAN: No John? All right.

22 MR. CYMBALSKY: I can pick out the
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1 states on the map.

2 MS. HOFFMAN: All right. Thank you.

3 MR. CYMBALSKY: And --

4 MS. HOFFMAN: Okay.

5 MR. CYMBALSKY: And I can name the

6 capitals. I remember --

7 MS. HOFFMAN: Okay. Joe, can you walk

8 us all through this, please?

9 MR. HAGERMAN: Yeah, so what PNNL tried

10 to do here was -- and you correct me. The HUD

11 code experts, with the HUD code, correct me where

12 I make some mistakes here, but my understanding is

13 like for Figure 1, what they've tried to draw here

14 is one of the HUD climate zones; is that correct?

15 MR. TOMPOS: Yeah, I mean --

16 MR. HAGERMAN: Yeah.

17 MR. TOMPOS: -- (inaudible).

18 MR. HAGERMAN: What page is that, or

19 what

20 MR. TOMPOS: Well, it's going to be

21 different.

22 MR. HAGERMAN: Okay. Well, what
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1 section?

2 MR. TOMPOS: Section 506.

3 MR. HAGERMAN: So the climate zones are

4 in Section 506 of the HUD code, right?

5 MR. TOMPOS: Yeah.

6 MR. HAGERMAN: So what they've tried to

7 do here is they take the HUD climate zone, and

8 then they overlay on top of that HUD climate zone

9 the different IECC climate zones that are in the

10 IECC, right? So here in -- this is where John

11 needs to help me here with that northern part of

12 Texas is Zone 4, right? And the lower part of

13 Texas is Zone 2, and the tip of Florida is Zone 1,

14 right?

15 And then what they've tried to do on top

16 of that is overlay the percentage of -- of

17 building codes or some type of distribution of,

18 you know, how many shipments are going into these

19 different areas, right? So that's what the

20 percentages are. So you see in that Zone 4, top

21 part of Texas is 1.8 percent, and then Zone 2 is

22 48.3. It's kind of hard to read, 48.3. And then
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1 that middle band, the IECC Zone 3 is 47 percent,

2 and then that bottom tip of Florida is 2.9

3 percent.

4 MR. TOMPOS: (Inaudible).

5 MR. HAGERMAN: Yeah, that should be 100

6 percent, yeah.

7 MR. TOMPOS: (Inaudible).

8 MR. HAGERMAN: I see in this other

9 write-up that it's 2002.

10 MR. TOMPOS: That one?

11 MR. HAGERMAN: That one, yeah, right.

12 No, 2002 shipments, yeah. I can't explain why

13 they use that number, to be honest with you. So

14 then Figure 1 is for whatever HUD zone -- climate

15 zone that is, 1. Oh, yeah, there it is on my

16 figure. Thank you.

17 And then Figure 2 is for Zone 2 and

18 Figure 3 is for Zone 3. So that is just a

19 straight kind of engineering comparison of the two

20 codes, right? It doesn't take into account, I

21 think, you know, how manufacturers ship,

22 necessarily, outside of how the HUD code already
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1 deals with that.

2 MR. LUBLINER: Joe? Mike Lubliner.

3 MR. HAGERMAN: Hey, Mike.

4 MR. LUBLINER: Hey, I have a -- I --

5 when I'm looking through this, it's looking pretty

6 much like -- there's this small -- the -- if we go

7 to stay with the HUD three climate zones, it makes

8 a pretty small impact in energy savings relative

9 to the benefits to the industry of staying with

10 the same climate zones. Am I reading this right?

11 And -- and I guess the point is I did

12 some research published in papers, peer-reviewed

13 research in Engineering Journal and ASHRAE with my

14 colleagues and some industry folks that concluded

15 the same thing, looked at the impact of staying --

16 keep it simple and stay with the existing climate

17 zones and reduce the burden on the industry and

18 engineering and changing and the challenges.

19 So I think that this is some good

20 information here. I'd like to get some input from

21 the industry and you.

22 MR. EZZO: Mark Ezzo. I guess the
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1 $64,000 question on all this is if you lump it --

2 if we lump it into three zones like we've got it

3 now -- let's just take HUD Zone 1, Figure 1. So

4 if we decide, okay, we're going to do that, we're

5 going to base the new standard on the same

6 boundaries we have now, which ICC -- IECC zone are

7 we going to assign to the current HUD Zone 1

8 boundary?

9 So, you know, and it's a pretty big

10 range. It goes from IECC Zone 1 all the way up to

11 IECC Zone 4. And if you look in the -- in the

12 IECC code, there's some pretty significant

13 differences from Zone 1 to Zone 4 in terms of

14 construction.

15 So I guess that's my question, is are we

16 going to average it? Are we going to pick the

17 worst zone, hardest to hit, if we keep the

18 boundaries the way they are? I mean, from a

19 retailer's perspective, they're absolutely going

20 to want us to keep the same zones we have now, but

21 I'm afraid that we may be doing them a disservice

22 if the zones end up being more restrictive than
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1 what they could otherwise be, especially when you

2 look at Zone -- HUD Current Zone 3 on the

3 flipside. I mean, if we were forcing homes in,

4 you know, lower Illinois that is right now -- or

5 worst case would be in Nevada, right? You've got

6 some IECC Zone 3 of Nevada. If we were to say,

7 "Well, all HUD Zone 3 is going to be based on IECC

8 Zone 7," that would have a huge impact for those

9 lower areas of Nevada.

10 MR. CYMBALSKY: Yes. I think this comes

11 back to the question that Manny addressed a few

12 minutes ago, was that do the manufacturers build

13 three different types of homes currently, or do

14 they -- do they build to one and over-comply in

15 maybe another one? Or like -- you know, I don't

16 know -- I'm going to plead complete ignorance, but

17 I'm assuming the northern ones are more stringent

18 in its energy requirement than the southern ones,

19 so --

20 MR. EZZO: This is Mark Ezzo. I can

21 tell you it's -- for our company, because we're

22 all over the country, it's all over the board. So
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1 if I pick a couple of our plants in North Carolina

2 -- for instance, look at Figure 2 -- their

3 distribution is all three zones. Right? It's not

4 too difficult for them to ship into a HUD Zone 3.

5 They're obviously located in Zone 2. And then,

6 you know, one state south, they're in Zone 1.

7 So those plants are offering all three

8 zones. If I point to a plant in Sacramento,

9 California, it's typically a higher-end plant,

10 okay, higher-end customer, kind of like what Mike

11 Lubliner was saying. Their base house is all HUD

12 Zone 3. They don't even mess with 2 because

13 they're going into Nevada, they're going into

14 Oregon. So it depends on location.

15 MR. CYMBALSKY: Okay. So, I mean, in

16 the examples that you just presented -- and I'm

17 not putting words in your mouth, so correct me,

18 but it seems to me that it wouldn't be a stretch

19 if -- let's just assume everyone says, "Let's use

20 the IECC zones." It sounds to me that the plants

21 that -- at least that you described have the

22 capability to run the gamut of IECC; is that
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1 correct?

2 MR. EZZO: Yes.

3 MR. CYMBALSKY: Okay. Thank you.

4 MR. RAMIREZ: Eric?

5 MR. LACEY: Thanks. Eric Lacey. I

6 recognize there are going to be some regulatory

7 efficiency from keeping the three HUD zones, and I

8 think that's probably the best approach, you know,

9 for expressing opinions right now. You know, one

10 of my concerns was that, you know, a lot of this

11 depends on what the number actually is, and I

12 think that's what you're saying. We may have to

13 revisit this later. If you're picking the high

14 number or the low number, those three climate

15 zones may sound like a really bad idea at the end

16 of this debate. But I think -- I think at least -

17 - for me, at least, I'm comfortable moving forward

18 with the three climate zones.

19 I think, looking at -- I know the IECC

20 fairly well and have, you know, getting an

21 adoption in a lot of states, and I can tell you

22 that they're not eight different product
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1 classifications for eight different climate zones.

2 There's kind of groupings of products. You know,

3 there's kind of three basic types of windows that

4 are required around the country. There's northern

5 windows, there's kind of middle of the country,

6 and there's southern windows.

7 And the same thing for insulation.

8 There's really kind of three different groupings

9 of insulation products, and so I think, for the

10 most part, you know, they match up fairly well

11 with these, not perfectly. You know, especially

12 this northernmost zone is really big, and there's

13 probably two different wall types that are

14 specified in the IECC. But I think for the most

15 part, you find in the IECC there are pretty broad

16 groupings of products, and you -- I think in a lot

17 of cases, it won't be that hard to say, "This is

18 the product that should probably apply," if your

19 starting point is the 2015 IECC. You know, and

20 you can ratchet that up or down, as we discussed

21 earlier, but I think it won't be quite as

22 complicated when we start looking at the -- you
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1 know, matching up the code with these climate

2 zones.

3 MR. RAMIREZ: Let me get Manny, then

4 Mark.

5 MR. SANTANA: Hi. Manny with Cavco.

6 You know, I'd like to answer a little bit of John

7 -- what John asked with -- you know, and I'd like

8 to explain, in a general sense, manufacturers

9 don't determine what thermal zone you're going to

10 build to. That's per request.

11 Usually -- and Mark can correct me, but,

12 you know, so the retailer, he knows where he's

13 going to sell, you know. And that has changed

14 over the years when -- before the economy tanked

15 and when times were good, you guys might be

16 familiar with the phenomenon of stock homes. You

17 know, so what that means is that a dealer or

18 retailer would -- you know, he was anticipating

19 having a certain amount of sales, so he would buy

20 homes that didn't have -- that weren't sold yet,

21 and he'd have them because he'd know he would sell

22 them.
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1 So when you have that scenario, you want

2 to increase your range of options with who you can

3 sell to and where you can go to. So then you

4 might have more of a -- you know, he might be

5 building to a more stringent thermal zone because

6 he didn't want to risk not being able to sell

7 there, but now, as Dave pointed out, most of the

8 homes that are built there are already built with

9 a customer in mind. There's already an order on

10 that.

11 Now, that's starting to change a little

12 bit, you know, and hopefully, this starts to --

13 that trend continues towards more ordering stock

14 homes, but, you know, right now, I think

15 manufacturers build for whatever zone the house is

16 going to because you generally know where the

17 house is going to, so you won't overbuild it if

18 you know where it's going to, and that's per

19 request. You know, if every request that came

20 into the plant was, you know, Thermal Zone 3,

21 Thermal Zone 3, the manufacturer's not going to

22 say, "Well, you only need one. I mean, we're not
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1 going to give you three." They're going to build

2 whatever they request, because they charge for

3 that.

4 MR. RAMIREZ: Mark?

5 MR. WEISS: Sorry. Mark Weiss, MHARR.

6 To to back to John's original question and then

7 Mark's response to that, that's one area where

8 there's a significant difference between a larger

9 manufacturer like Clayton, with multiple plants

10 serving essentially a nationwide market as opposed

11 to some of the folks we represent who are smaller

12 manufacturers with maybe one plant, maybe a couple

13 plants, that are primarily serving a regional

14 market, a much smaller area. And, you know, the

15 economies of scale and efficiencies there go way

16 down from what you're talking about with a large

17 company like Clayton or some others.

18 MR. RAMIREZ: Let me get -- I'm sorry.

19 MR. CYMBALSKY: So I think just to

20 finish this thought --

21 MR. RAMIREZ: Yeah.

22 MR. CYMBALSKY: So I think -- it was
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1 brought up, so I want to just reinforce that I

2 think what we're trying to balance here with this

3 climate zone thing just is probably obvious by

4 now, but it's -- you know, to keep the burden on

5 manufacturers in check, but also, you know, try to

6 squeeze as much energy efficiency out of this as

7 possible, minimizing, of course, that burden to

8 the manufacturers. So that's, you know, kind of

9 what we do in appliance standards all the time, so

10 I think if we kind of tee it up that way, you

11 know, think about it that way, we could probably,

12 you know, hit that spot, I hope.

13 MR. RAMIREZ: Let me get Emanuel, Robin.

14 Do you want to give a quick reply to that?

15 MR. WEISS: Just a very brief and a very

16 specific point. John mentioned the appliance

17 standards, and I know that's where he's been doing

18 his work, but I think it's important for all of us

19 to keep in mind there's a difference between

20 standards appliances -- appliance standards,

21 excuse me, and standards for manufactured housing

22 in that we're specifically recognized in law as
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1 affordable housing, we serve specific purposes,

2 and it will recognize as such by -- as affordable

3 by law. So there's a difference, you know, apples

4 and oranges, as far as we perceive it between the

5 two.

6 MS. HOFFMAN: That was your point?

7 MR. SCHNEIDER: Can you explain that? I

8 didn't quite understand that. This is Peter from

9 Efficiency Vermont.

10 MR. WEISS: Well, Mark Weiss again.

11 What I'm saying is manufactured housing is

12 specifically recognized in federal law, and

13 specifically the act that HUD operates under, as

14 affordable housing as serving specific purposes as

15 -- specifically national housing policy purposes

16 as affordable housing. And, therefore, I think

17 it's distinguishable from appliances generically

18 that don't have that sort of recognize in federal

19 law.

20 MR. RAMIREZ: Emanuel?

21 MR. SCHNEIDER: This is Peter Schneider

22 again. I mean, I think we defined affordable
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1 housing, you know, a little bit differently than

2 just first cost, if that's what you're implying.

3 So, you know, the idea that, you know, we need to

4 look at total cost of ownership, and I don't want

5 to move forward for convenience sake and ignore

6 building science, you know, when we have drastic

7 climate differences between, you know, the lower

8 part of, you know, one climate zone and the top of

9 that.

10 You know, so I'd like to accommodate

11 these climate regional differences, definitely

12 into the energy modeling, and as we look at, you

13 know, millions of BTUs used or saved as we do our

14 cost analysis and our life-cycle analysis, but,

15 you know, just from a -- a building science

16 standpoint, I think, you know, that's where the

17 discussion lies. Are we serving these customers

18 and delivering homes that are suitable for the

19 environment in which they're set?

20 And right now, I think that, you know,

21 the northern tier customers are -- you know, are

22 not receiving a product that is suitable for their
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1 climate. There was a lot of discussion earlier

2 that you can get anything you want. Well, I've

3 spent a ton of time visiting dealers and modeling

4 homes on dealer lots all around the Northeast, and

5 I'll tell you that there is nothing available

6 beyond, you know, sort of the HUD code minimum,

7 and I would argue that the Energy Star, you know,

8 version of the HUD home is not much different than

9 that either, at least what's sitting on our lots

10 up here and labeled as such.

11 So I just don't want to ignore building

12 science for convenience when we're talking about

13 developing these standards and, almost more

14 importantly, this cost of --

15 MR. RAMIREZ: Thank you.

16 MR. LUBLINER: This is Mike Lubliner. I

17 concur --

18 MR. RAMIREZ: Oh, sorry, Mike, hold on a

19 second. Emanuel's been very patient over here.

20 MR. LUBLINER: Okay.

21 MR. RAMIREZ: Go ahead --

22 MR. LUBLINER: Sorry, Manny.
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1 MR. LEVY: I think Peter and Mark made

2 comments that I want to just weigh in on. Right

3 now, our experience has been that -- manufacturers

4 who are in Zone 2 in North Carolina being a

5 perfect example -- are very circumspect about

6 building a Zone 3 home and won't build it if it's

7 going to Zone 3. They won't build it routinely

8 because they want to have a product that they

9 could ship anywhere. And the reason for that is

10 the cost difference between 2 and 3 is relatively

11 significant and they don't want to add the cost in

12 unless it's absolutely necessary.

13 I think what we're -- we're talking

14 about the next generation of standards in which

15 those cost differences are going to be even more

16 substantial. So and that, I think, plays into the

17 point that Peter's making, Mark made it, and that

18 is that the zone determination should continue to

19 be on the table for the time being until we can

20 see, as Eric pointed out, what the real

21 implication is of having two zones butting up

22 against each other with significantly different
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1 requirements.

2 So I think my takeaway from this is this

3 is an important issue, let's keep it on the table,

4 let's not make a decision about it quite yet. We

5 can make a preliminary decision and see what the

6 implication is, but with the full recognition we

7 may want to revisit that and change our mind

8 later.

9 MR. RAMIREZ: And we can do something

10 like that. Let me get Robin, and then Lois.

11 MR. ROY: Robin. Emanuel, I thought

12 that -- that kind of summed up what I was thinking

13 too. The real question is do we have the analytic

14 capabilities to differentiate between the IECC

15 zones? Joe, the model that PNNL was working

16 towards, it presumably will eventually be filled

17 out with some cost information as well that can be

18 desegregated (ph) and chopped and changed and then

19 stuffed back into the HUD zones.

20 So maybe the right thing to do is just

21 proceed with the analysis and let the numbers talk

22 for themselves as we learn something about what
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1 the implication would be of going different ways.

2 At the same time, I think it's very important to

3 take the MHARR perspective into some real

4 consideration and see if we can come up with some

5 sort of quantification of the challenges that your

6 members will be -- the burden that -- the

7 quantified burden that your members would be

8 facing so we can put that into our calculus (ph)

9 once we get the understanding of the energy

10 impacts, the economic consumer impacts. We'll see

11 how that all relates together. Of course,

12 interested in the larger manufacturers' costs as

13 well, but it sounds to me like those might be more

14 controllable than they would be for the smaller

15 folks, so I'm seconding your opinion, Emanuel.

16 MR. RAMIREZ: Okay. Lois, and then

17 Robert?

18 MS. HOFFMAN: And I also think Joe

19 wanted to respond, so --

20 MS. STARKEY: Just --

21 MS. HOFFMAN: -- but Lois first.

22 MS. STARKEY: Just --
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1 MR. HAGERMAN: I just wanted to say just

2 real quick -- Lois, I'm sorry -- you're absolutely

3 right about the analysis. This is going to be

4 presented. And, you know, we're doing this in

5 hopes, after you see it, that you'll say, "Hey,

6 this is right. This is wrong. Go do this

7 analysis. Here's some cost information." We're

8 trying to -- you know, we need information from

9 everybody, right? Or you're just going to use the

10 assumptions that the labs come up with, which are

11 sometimes right, sometimes wrong, right, so

12 MR. RAMIREZ: Okay. Lois?

13 MS. STARKEY: Just -- I just wanted to

14 talk about the small manufacturer, because MHI

15 also represents small manufacturers, and what

16 we've found on the energy side is that there are -

17 - and Emanuel's comments notwithstanding -- the

18 smaller manufacturers who do deal, perhaps, maybe

19 only in three states, they may very well make the

20 choice to go to that one single zone that's going

21 to impact all those states, that Zone 3. Also,

22 they tend to be, you know, very, very sensitive to
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1 that, as they all are, but they've focused on a

2 market that they're going for, and so they may

3 very well be just at the higher end of the market,

4 and these issues are not an issue.

5 And we have some members that are

6 sitting there saying, "We're still talking about,

7 you know, 1994 standards?" So, you know, I want

8 to be on record that MHI is, you know, very

9 interested. We also certainly want to maintain

10 that affordability, but also understand that, you

11 know, small manufacturers, you know, they'll

12 compensate for the market.

13 MR. RAMIREZ: Okay. Robert?

14 MR. SCHNEIDER: Peter Schneider here. I

15 was just quickly -- is there anything that we can

16 gain in regards to insights from the modular

17 manufacturers in regards to having to meet these

18 requirements and what a burden it is on them and

19 that that can help guide the discussion here?

20 MR. EZZO: It's Mark Ezzo. I mean, we

21 do have a lot of facilities that build modular

22 homes, and, of course, they have to comply with
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1 the IECC tables, depending on whether it's Zone 1

2 or Zone 7, and, like it's been said before, a

3 hundred percent of what they do is a retail-sold

4 home. They're not building any inventory. So

5 when the request comes in to the facility for a

6 modular home, it's they want this home, and here's

7 the address it's going to, and our engineering

8 team knows that it's going to be in Zone 1 or Zone

9 7. They run the energy calculation, and it's not

10 all that cumbersome.

11 MR. SCHNEIDER: So we should look at,

12 you know, how many homes are not being custom13 ordered in the manufactured housing industry,

14 because if that is the majority of homes, I don't

15 see a difference between the requirements for

16 modular and manufactured, unless there's a real

17 high percentage that are just, you know, built

18 basically to be delivered to dealers to sell on19 site.

20 MR. SANTANA: You know, this is Manny,

21 you know, again, and, you know, to answer your

22 first question, I think it comes down to what I
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1 said earlier about it isn't so much a question of

2 manufacturer's ability to build to different

3 climate zones or their ability to build to more

4 conservative energy standards. It's about the --

5 the -- the customer's ability to pay. So that --

6 that -- that's what it comes down to. You know,

7 there's also -- you know, there's additional costs

8 with the modular just because of regulatory, you

9 know -- in addition to energy and other

10 considerations.

11 So, you know, again, it doesn't come

12 down to can a manufacturer build it. It comes

13 down to, you know, who the customer is.

14 MR. RAMIREZ: Let me get Robert.

15 MR. LUTER: Thank you. Rob with

16 Lippert. Just one observation I wanted to make

17 with regard to the comparison between the two

18 zones and the opportunities for consolidation of

19 IECC zones or splitting up of HUD zones. The HUD

20 zones are reflective of U-Sub-O (ph). There's no

21 consideration given to solar heat gain. IECC

22 considers solar heat gain coefficient as well, and
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1 those two performance ratings move in opposite

2 directions, depending on where you are.

3 So a window that is designed to meet the

4 U- value needs of the North and the solar heat

5 gain needs of the South generally is a window

6 that's not very well-suited to anywhere. It does

7 meet both goals, but there are much more cost8 effective ways to address the specific performance

9 required, either in that northernmost zone or

10 southernmost zone. So just an awareness that the

11 HUD zones don't consider solar heat gain at this

12 point.

13 MR. RAMIREZ: Let me get Stacey, then

14 Mark

15 MS. EPPERSON: I'm Stacey Epperson, Next

16 Step network. At Next Step, we spec a Zone 3 home

17 an Energy Star home, but when -- I want to follow

18 up on Manny's point. It's what the customer can

19 afford. I just want everyone to know that we're

20 having to subsidize these to afford these energy

21 upgrades most of the time, so I just want to make

22 that a point of affordability as what we're doing
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1 here.

2 MR. RAMIREZ: Mark?

3 MR. WEISS: To go back to the original

4 question, I just don't think modular -- the

5 modular market is comparable to different market

6 with different price points, different buyer, and

7 a different size of the overall market, for one

8 thing. Manufactured housing, traditionally, has

9 been a much bigger market. So, again, that goes

10 back to the point I made earlier about the apples

11 and oranges and the specific recognition of

12 manufactured housing as affordable housing, which

13 modular does not --

14 MR. RAMIREZ: Okay. Yeah.

15 MR. LEVY: Emanuel Levy. Just one last

16 point --

17 MR. LUBLINER: Mike Lubliner.

18 MR. LEVY: -- that Rob has raised. The

19 IECC zones are dictated by climate, climate

20 considerations. The HUD zones are dictated by

21 cost-effective levels of efficiency. Those are

22 different things, and, therefore, the IECC overlay
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1 is kind of a limited utility. It might be

2 demonstrated -- and I'm expecting this will be the

3 case -- Virginia may have a lower use of O-value

4 (ph) than Vermont. It's possible, simply because

5 Virginia has a lot of electrically heated homes

6 and Vermont has mostly gas- heated homes.

7 So if you look at those from a cost8 benefit standpoint, it could prove that Virginia

9 should have a lower use of O-value. So I think we

10 should be careful about how we use the IECC zones.

11 MS. DICKENS: Just anecdotally -- this

12 is Ishbel. I'm staying with my vice president in

13 a manufactured home in Virginia right now, and her

14 A/C is electric, so her -- she's a paying $165 a

15 month on A/C during the summer. She heats her

16 home with gas during the winter, so she has both,

17 yeah.

18 MR. RAMIREZ: All right. So --

19 MR. LUBLINER: And my -- this is Mike

20 Lubliner. I wanted to add that my understanding

21 is even when there's gas available, 90 percent of

22 the homes still have electric water heating. Is
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1 that your industry findings?

2 MR. SCHNEIDER: That's definitely the

3 case in Vermont. We have propane furnaces because

4 we don't have natural gas, for the most part, in

5 Vermont, and a lot of the Northeast, including

6 Maine, and we have electric hot waters in a

7 hundred percent of the homes.

8 MR. LUBLINER: And is the propane more

9 expensive in Vermont than the electricity, or are

10 they comparable?

11 MR. SCHNEIDER: It depends on the year,

12 but more expensive right now.

13 MR. LUBLINER: Thank you.

14 MR. RAMIREZ: All right. So it seems

15 like the group is saying -- we like to do what I

16 call a temperature check, right, to get an idea of

17 where you're leaning without being locked into it,

18 depending on how some of the stuff works out

19 later. And it sounded like, at least to my ears,

20 that initially it looked like you were adopting

21 the HUD zones, but then -- but let's be careful.

22 Let's not, you know, rush to this, right?
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1 So as far as a temperature check, as far

2 as proceeding, and keeping in mind that maybe it

3 is going to be HUD, is that where you're going

4 right now? Let me see a show of thumbs if you're

5 looking at going under the understanding of

6 applying it towards HUD zones.

7 MS. HOFFMAN: Oh, I see no

8 MR. RAMIREZ: That's okay. Okay. Is --

9 so is that why your thumb is down, because of the

10 data? All right. So (inaudible)?

11 MS. HOFFMAN: Yeah. So maybe the

12 parking lot and -- or no?

13 MR. RAMIREZ: No, no. You know what?

14 The reason I'm saying no to the parking lot is

15 this.

16 MS. HOFFMAN: Uh-huh.

17 MR. RAMIREZ: This is exactly why, when

18 we're putting together the agenda -- if you look

19 at the original agenda, it says to identify the

20 issues, talk about them, identify information

21 that's needed, and then to prioritize. Right?

22 Because we were thinking that it was going to be
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1 awfully hard for you all to start problem-solving

2 without the information that you're going to need.

3 Right? But we're hearing from the group, "Whoa,

4 we could do this," right? Yeah, it's -- now you're

5 seeing some of the road blocks that we were

6 anticipating.

7 MS. STARKEY: I might suggest, I think

8 if you ask the question fewer zones rather than

9 more zones at this point, I think you'd get a

10 different response.

11 MR. RAMIREZ: All right. Excellent.

12 Let me -- let's try it.

13 MR. LUBLINER: Can you share with me

14 what the response is? Because we can't see the

15 hands here.

16 MR. RAMIREZ: Yeah. You know what?

17 Everyone was sideways, with the exception of

18 Robin, who was a thumbs-down, but everyone else

19 was sideways. From what I could tell, it was

20 because they needed more information. That's why

21 Robin's thumb was down.

22 MR. LUBLINER: Okay.
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1 MR. RAMIREZ: Oh, Manny was thumb-down

2 also. Same reason. Okay.

3 MS. HOFFMAN: More information.

4 MR. RAMIREZ: So there were a couple

5 thumbs- down, and overall, it just seemed like

6 people needed information.

7 MS. HOFFMAN: Right.

8 MR. ROY: Probably it's more

9 information, and second is we don't need to make a

10 decision -- a determination on that because PNNL's

11 work and the rest of the analysis is going to roll

12 through that information, not giving anything up.

13 MS. HOFFMAN: I see.

14 MR. SCHNEIDER: Can you just tell us

15 what energy modeling is going to come back? Are

16 we going to have every IECC climate zone modeled

17 with -- I'm just -- I'm still confused as to what

18 modeling will come back. I've posed that question

19 before. Is that going to include all IECC zones

20 so we can evaluate what the difference is between

21 these?

22 MR. HAGERMAN: Yes. This is Joe
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1 Hagerman at DOE. Absolutely. So what they've

2 done is they've built a model of a manufactured

3 home, and then -- or multiple manufactured homes

4 and placed that -- one unit in every climate zone,

5 and then -- so they get that annual energy

6 consumption for that model, and then they rotate

7 it 90 degrees and run it again, and they rotate it

8 90 degrees, and they run it again. They rotate it

9 90 degrees, and then they run it again. So then

10 they pick the worst case, right? So you get the

11 worst-case answer.

12 MR. SCHNEIDER: And how were the fuels -

13 - yeah, and how were the fuels chosen --

14 MR. HAGERMAN: I don't know that.

15 MR. SCHNEIDER: -- for those?

16 MR. HAGERMAN: I -- yeah, I'd have to

17 see how they ran that, depending on the model.

18 And then, two, they've run it for the 2015 code.

19 They've done that same thing for the 2015 code,

20 2012 code, 2009 code, 2006 code, et cetera, et

21 cetera, so -- and we're trying -- we're working as

22 hard as we can to get you all those numbers.
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1 MS. HOFFMAN: And thank you.

2 MR. SCHNEIDER: (Inaudible) percent --

3 MR. HAGERMAN: Yes, it --

4 MR. SCHNEIDER: -- is just --

5 MR. HAGERMAN: Right.

6 MS. HOFFMAN: Now, Lois, you had a

7 point.

8 MR. RAMIREZ: Yeah, the -- okay.

9 MR. CYMBALSKY: So just to -- I mean,

10 this was valuable, from my point of view, just to

11 understand how the manufacturers can or cannot,

12 you know, do this differentiation. So, I mean,

13 that's where I was coming from with trying to

14 understand the climate zones, not necessarily

15 wanting to make a decision today on that, but just

16 trying to understand how the manufacturers can or

17 cannot adopt more or less, you know, requirements

18 upon that, so -- and I think we got that

19 information from both the large guys and the small

20 guys.

21 MR. LUBLINER: Mike Lubliner here.

22 MR. RAMIREZ: Go ahead, Michael.
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1 MR. LUBLINER: A question for Joe. Joe,

2 what I heard before when you were explaining this

3 is that in terms of setting -- comparing the

4 climate zones from the HUD to the I codes (ph),

5 that you looked at a weighting based on

6 production, and I wonder if people are comfortable

7 with that methodology. I think that's the best

8 methodology, and I wanted to clarify it, that

9 we're weighting it by production as we try to

10 investigate whether we should be going with more

11 climate zones or less, as Lois has characterized.

12 And I think it would be useful to get a sense from

13 the group if that methodology is an acceptable

14 one; in other words, you know, if one home is

15 built in Fargo, North Dakota, it gets a smaller

16 weighting in terms of the cut on climate zone than

17 thousands of homes in another portion of that Zone

18 3 area, where there is more weighting. Thank you.

19 MR. RAMIREZ: Comments?

20 MR. SCHNEIDER: Well, this is Peter

21 Schneider from Efficiency Vermont. We certainly

22 haven't seen that serve Vermont very well.
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1 MS. HOFFMAN: Any other comments from

2 members of the committee, working group?

3 MR. RAMIREZ: All right. Well, then,

4 let's just --

5 MR. KESSLER: This is Bert. I've been

6 quiet so far, but

7 MS. HOFFMAN: All right. Bert Kessler.

8 MR. KESSLER: -- I think I'm going to

9 comment on this issue here. I believe that we

10 should stick with the three zones that we

11 currently have. At the end of the day, what's

12 really going to control the performance will be

13 what use of O's (ph) will assign to those

14 different zones, and I think at that point in

15 time, it would be more of an issue to dissect the

16 individual zones into, you know, something like

17 what we're looking at here with the IECC zones and

18 analyze and see just how much difference there is.

19 MR. RAMIREZ: All right. So let's see a

20 show of thumbs on the idea of looking at fewer

21 zones than more zones as we have our discussions

22 going forward.
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1 MR. SCHNEIDER: This is Peter Schneider.

2 I'd say thumbs down on that.

3 MALE SPEAKER: (Inaudible).

4 MR. RAMIREZ: Yeah. As we're going

5 forward, the group would prefer to have less zones

6 than more zones; in other words, leaning more

7 towards three versus seven as we're going forward.

8 MR. LEVY: As a philosophical goal.

9 MR. RAMIREZ: Yes, just as we're going

10 forward, but we're going to have to look at the

11 information.

12 MS. HOFFMAN: Yeah.

13 MALE SPEAKER: (Inaudible).

14 MR. SCHNEIDER: But that'll be very

15 different for the cost analysis, where we'll be

16 looking at the most zones and evaluating specifics

17 of that regional climate and the fuel sources

18 there, correct?

19 MS. HOFFMAN: It sounds like there's a

20 lot more information that's needed for making a

21 decision, but, first, thank you for this as a

22 start, very much. And what I'm thinking is you're
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1 right, not in the parking lot.

2 MR. RAMIREZ: Yeah, yeah, we're going to

3 have to deal with this up here.

4 MS. HOFFMAN: We're going to have

5 to deal with it, but subject to further analysis.

6 That's what I'm hearing, because it's going to be

7 critical, and it is in our charter, what we need

8 to do for the working group. Any other comments

9 on this before we move on or make a -- actually,

10 we might break for lunch in a few moments, but how

11 is the pace going? Let me do a process check.

12 Are you frustrated, or you feel we're moving

13 ahead, or any of the above, or not? Good -- well,

14 we're getting good information. That's good. And

15 we're not rushing to make decisions, because we

16 want to get as much information. On the other

17 hand, if you felt like we should have made a

18 decision, I'm sorry about that. Any other

19 comments, though, about how the process is

20 MALE SPEAKER: (Inaudible).

21 MS. HOFFMAN: Oh. Sixty days is on your

22 mind. Right. Okay.
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1 MALE SPEAKER: (Inaudible).

2 MS. HOFFMAN: Okay. What we can do

3 through lunch, the facilitators, is come up with

4 maybe an idea for how to move it ahead, okay, for

5 you to look at. But, again, we will need

6 information, and that sounds like it's going to

7 come in time for our next meeting. Yes, Rob?

8 MR. LUTER: Just one observation

9 regarding the direction we're going to head.

10 MS. HOFFMAN: Uh-huh.

11 MR. LUTER: To Bert's comment, you know,

12 U- sub-o's going to be important. Three zones

13 would make more sense. I've heard commentary so

14 far that would suggest that U-sub-o's is not going

15 to be relevant, because the energy portions of the

16 HUD code are going to be gone. So if that's truly

17 the case, let's man up and say that's what's going

18 to happen so we can head down the right path. If

19 it's still uncertain, okay, let's continue that

20 conversation, but we really need to know which

21 direction this is heading. If this is going to be

22 a carved-up IECC, let's just say that's what it's
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1 going to be and start working on it. If the HUD

2 code or elements of it are still going to be

3 relevant, let's identify which ones those are

4 going to be so we can go down the right path and

5 not waste any time. Again, 60 days.

6 MS. HOFFMAN: Manny?

7 MR. SANTANA: Manny with Cavco. You

8 know, I like the point that Emanuel brought up,

9 that the HUD zones and the IECC zones aren't

10 exactly apples and apples. You know, one is based

11 on purely energy considerations, and another one

12 is based on optimal energy versus life costs. You

13 know, what are we supposed to do to make a

14 decision going forward? Are we going to also have

15 numbers on life cost versus energy, or is it going

16 to be only energy-based? Because that'll have a

17 determination on what zones we end up with.

18 MS. HOFFMAN: Okay. Any other comments?

19 MS. DICKENS: Yes, remind us of the 60-

20 day thing, the 90 percent of the what and the 10

21 percent of the why, so I think we're okay where we

22 are right now.
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1 MR. RAMIREZ: Yeah. Everyone understand

2 what she's talking about? Hopefully we spend more

3 time understanding what the issue is and the

4 problem, and that will speed up the problem5 solving component.

6 MR. WEISS: (Inaudible) I think there's

7 value discussing these issues and circling back to

8 (inaudible).

9 MS. HOFFMAN: Uh-huh. True.

10 MR. RAMIREZ: Okay.

11 MS. HOFFMAN: Okay. So I would suggest

12 lunch, come back at -- oh, Emanuel? Yeah.

13 MR. LEVY: Emanuel Levy. I just want to

14 make one quick comment in terms of timing and what

15 the next steps are from what the laboratory's

16 going to furnish. I think the energy

17 information's going to be interesting and useful.

18 I think ultimately what we're looking for is what

19 levels of efficiency are cost- effective, and

20 that's going to be the time when I think is --

21 where the time is placed, and I would see if we

22 can put some more urgency on doing that part of
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1 the analysis, taking the energy information, but

2 overlaying on top of that cost-benefit, the costs

3 and ultimately the cost-benefits and breaking that

4 down by climate. That is where we're headed.

5 MR. CYMBALSKY: Right, so --

6 MR. SCHNEIDER: And this is Peter

7 Schneider. I was just wondering if Emanuel or

8 somebody else has good cost data that we can start

9 to build upon so once -- you know, we already have

10 these model packages, correct? So to begin

11 working on a cost associated with these energy12 efficiency upgrades, ventilation upgrades and so

13 forth, it would be really helpful if we began

14 building that database so we could utilize that as

15 soon as possible, because the -- you know, the

16 energy analysis is really one half of what we

17 need.

18 MR. HAGERMAN: Right, so this is Joe

19 Hagerman, DOE. And so that's why we recommended,

20 wherever possible, where you have data on

21 shipment, costs, whatever data that you think is

22 relevant, you know, sign an agreement with
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1 Navigant and give it to them, and those analysts

2 can start helping us consider that the -- in all

3 the stuff that we've prepared, so

4 MS. HOFFMAN: And the question --

5 MR. SCHNEIDER: Do we know who -- has

6 that been provided yet? Do we know what may be

7 currently available? I mean, ultimately I know

8 there's a lot of partners of this working group

9 right now that have done significant work in this

10 arena. Next steps, Emanuel, I was just wondering

11 what we currently do have and we can expect, come

12 Friday, as an example.

13 MR. RAMIREZ: You have information?

14 MR. LEVY: We do have data.

15 MR. RAMIREZ: Okay, great.

16 MS. HOFFMAN: And you could share --

17 MR. LUBLINER: This is Mike Lubliner. I

18 had a question on cost.

19 MR. RAMIREZ: Go ahead, Mike.

20 MR. LUBLINER: Okay. Joe, we did a --

21 you did an ANOPR (ph), and you did an RFI, and if

22 I -- I think we provided costs from our regional
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1 programs. We have a little track record and worked

2 with the manufacturers. I'm just wondering, a lot

3 of these manufacturers are building modular, and

4 they have experiences. Did you get sufficient

5 costs data from the RFI or the ANOPR from

6 industry, or are we now trying to get additional

7 information?

8 MR. HAGERMAN: We're looking for

9 additional information, but you are correct --

10 MR. LUBLINER: Thank you.

11 MR. HAGERMAN: -- that if -- absent of

12 information, we'll use the information we've

13 already received.

14 MR. LUBLINER: So I'd like to follow

15 that up by asking the industry folks since you

16 didn't provide cost data during the ANOPR and

17 limited cost data during the RFI, are you now

18 going to sit down and share cost data with us so

19 that we make sure that we have the benefit of your

20 expertise and costs?

21 MS. STARKEY: This is Lois from NHI.

22 We'll do the best to -- that -- you know, to get
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1 the information that you need. As Emanuel

2 suggested, we have done some work. We haven't

3 just been putting our head in the sand since the

4 DOE proposal first came out. So we do have some

5 information we can share. Now, whether or not --

6 MR. LUBLINER: Thank --

7 MS. STARKEY: -- we can go to every

8 manufacturer -- because I think manufacturers are

9 struggling with the kinds of data that they

10 collect and how to get the data that you would

11 really like to have, and that is how many homes

12 that Clayton ships every year, for example, go to,

13 you know, Zone 1, go to Zone 2, go to Zone 3, and

14 what kind of energy standards do they actually

15 have? How efficient are they? Because, you know,

16 that's just -- I would say -- correct me if I'm

17 wrong -- that that's not really information that

18 they currently correct (ph). But we have looked

19 at component costs of going to different kinds of

20 energy standards, and we can get that.

21 MS. HOFFMAN: Great.

22 MR. LUBLINER: Thank you, Lois.
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1 MS. HOFFMAN: Great. Okay. Well, with

2 that, let's come back at one o'clock. Thank you.

3 (Whereupon, at 3:54 p.m., the

4 meeting was concluded.)

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1 CERTIFICATE OF COURT REPORTER 

2 I, NATALIA THOMAS, the reporter before whom the 

3 foregoing hearing was taken, do hereby certify 

4 that the witness whose testimony appears in the 

5 foregoing deposition was duly sworn by me; that 

6 the testimony of said witness was recorded by me 

7 and thereafter reduced to typewriting under my 

8 direction; that said deposition is a true record 

9 of the testimony given by said witness; that I am 

10 neither counsel for, related to, nor employed by 

11 any of the parties to the action in which this 

12 deposition was taken; and, further, that I am not 

13 a relative or employee of any counsel or attorney 

14 employed by the parties hereto, nor financially or 

15 otherwise interested in the outcome of this 

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1 CERTIFICATE OF TRANSCRIPTION 

2 

3 

4 I, VONDA WEBER, hereby certify that I am the Court 

5 Reporter who reported the following proceeding and 

6 that I have typed the transcript of this 

7 proceeding using the Court Reporter's notes and 

8 recordings. The foregoing/attached transcript is 

9 a true, correct, and complete transcription of 

10 said proceeding. 

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C6 ~/lLI AuguStff, 2014 VONDA WEBER 

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1 CERTIFICATE OF TRANSCRIPTION 

2 

3 

4 I, SARAH VEACH, hereby certify that I am the Court 

5 Reporter who reported the following proceeding and 

6 that I have typed the transcript of this 

7 proceeding using the Court Reporter's notes and 

8 recordings. The foregoing/attached transcript is 

9 a true, correct, and complete transcription of 

10 said proceeding. 

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1 CERTIFICATE OF TRANSCRIPTION 

2 

3 

4 I, MARY E. YOUNG, hereby certify that I am not the 

5 Court Reporter who reported the following 

6 proceeding and that I have typed the transcript of 

7 this proceeding using the Court Reporter's notes 

8 and recordings. The foregoing/attached transcript 

9 is a true, correct, and complete transcription of 

10 said proceeding. 

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f:sf l~/y Date 

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$1,000 92:22 93:3

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$100,000 92:20

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2008 51:7 157:8

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183:7 200:21

213:8 269:20

2010 70:20

2011 56:5 57:15

73:19 74:17

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54:3,8,9 59:9

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appropriate

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barriers 109:7

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bridge 117:9

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clause 171:5

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commonly 79:12

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218:11 225:14

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database 193:21

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deteriorating

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DOA 85:5

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210:8 248:14

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everyone 11:18

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273:20 274:1

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66:15,16 67:3

77:11 80:13

81:9 83:9 88:20

131:1 135:19

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180:21 215:5

216:12

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147:18 149:6

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26:15 27:16,20

28:9,14 29:15

30:7 32:12

33:12 35:5

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65:12 73:8 74:4

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112:18

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156:15 163:12

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263:17

264:19,20
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267:13,22

270:21 271:1

279:17,20

280:10,14

281:6,22

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52:21 128:20

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159:2

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57:17

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217:17

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171:18 173:11

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263:8,12 264:13

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165:17 166:22

179:2,6 196:1

211:8 214:20

215:12 235:20

236:2 250:9

258:14 261:12

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19:18 20:2,10

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107:20 109:8

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216:9 237:1,10

241:21 244:12

248:8 249:15

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130:22 131:13

143:22 144:1

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161:18,21 163:3

164:18 165:19

166:3 168:8

169:19 174:3

180:19 184:22

188:8 192:13

194:4,14
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242:22 244:20

248:4,11

250:4,5 252:10

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168:3 184:11

197:21 198:22

210:14 275:7

282:4

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230:19

meets 49:15 50:12
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member

184:10,12 229:8

230:1,7 231:16

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128:11 134:8

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122:22 123:18

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194:6,13

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90:9,11,14

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234:2,8,14

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222:18

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45:2 56:20 96:8

135:2 174:15

227:3 232:15

244:12

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models 73:4 82:18

83:15 85:3

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MODERATOR
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8:2,15

11:8,11,21

13:18,20

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119:20 120:8

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113:10 225:13

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25:17 28:2,3,22

29:7 93:10

102:6 140:20

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121:5 126:10

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192:5,22 209:17

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250:10

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71:8,13 72:7

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197:19 279:1

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NDAs 196:21

necessarily 43:1

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134:13 218:6

241:22 270:14

necessary 44:7,9

66:2 217:16

255:12

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negative 146:20

negotiate 33:22

193:10 205:8

negotiating 37:10

negotiation 167:6

170:11 231:13

negotiations

56:11 61:22

67:1
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neither 283:10

net 143:16

network 130:21

262:16

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nominated 80:3

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238:13

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North 245:1 255:4

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206:13 207:5

214:3 234:22

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285:7 286:7

nothing 69:4

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148:3,5,7,9,10

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19:7,13 20:14

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27:19 28:7,8

34:7 35:19

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41:15,18 42:18

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69:11,14 82:20

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89:15 90:19

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96:5,7,11,17
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102:20

103:2,3,8,12

104:8 105:17

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117:8,11 118:18

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215:4 216:12

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223:9,12 224:13

225:15,18,21

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233:5 236:13

238:17

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276:18,21

277:10,11

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160:17 171:20

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228:15,21 229:3

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218:20,22 229:9

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21:10,13,22

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remembers 21:22

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reminds 10:7

remotely 125:12

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Capital Reporting Company

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231:10

represented 70:13

74:10 229:11

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196:17
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room 12:1 56:8

74:11 94:21

125:10,18

130:12 168:5

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rooms 120:4

rotate 269:6,7,8

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route 71:7 85:22

86:1

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69:3,8,11,18,21

70:3 71:12

72:1,6,19,22

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78:5,8,19 79:3,5

122:7 131:5

143:2,7 177:4

186:9 199:20

200:3 211:2

238:1 248:5

260:20 276:7

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save 67:8 83:10

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savings 61:15

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139:12,15,21

141:1,12 142:17

143:20 152:9

153:2 179:1

192:5 193:1

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213:10,11 242:8

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scale 95:9 210:8

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scenario 45:19

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77:20 83:13

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119:3

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scheduled 167:17

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7:10,11 9:2,3,16

10:1,6,10,14

11:2 12:6

13:10,11 14:6

16:22 17:9

22:13 23:9

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201:9 202:10

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269:12,15

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271:20,21

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36:4 60:8 65:13

66:3 68:1 79:8

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score 174:16

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screening 129:1

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second 16:9 27:5

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138:21 152:8

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seconding 257:15

secondly 204:10

seconds 189:8

190:12

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230:5

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Capital Reporting Company

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57:17 103:18,22

142:9 147:12

157:21 163:11

165:9 171:8

240:1,2,4

sectioned 138:16

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211:15,16

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248:13,21

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105:14 119:6

120:3 197:19

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68:7 83:2,12

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165:18 169:20

174:1 176:13,16

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210:12 221:1,8

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separate 17:4

28:13 29:8

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119:16,18

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82:2,10 139:16

seriously 199:13

serve 38:9 252:1

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Service 2:4

serving 250:10,13

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session 86:12

229:15 231:20

sets 137:22

setting 136:15

137:13 155:5

156:4 271:3

seven 152:3 273:7

several 76:3

172:15,16

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share 64:13 75:1

114:18 170:3

267:13 279:16

280:18 281:5

shared 91:17

sharing 76:20

shattering 85:17

sheet 232:17

she's 264:14 277:2

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shift 22:4

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241:21 245:4

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shorter 110:1

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sign 69:21 71:7

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significant 40:1

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significantly 7:16

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similar 149:16

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simple 181:22

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simply 49:6

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simulation 191:11

Simultaneous

129:10

simultaneously

121:22

single 5:7,8 9:7
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42:1,11 79:9,21

92:19,21

94:5,10 137:19

147:10,11

219:13 258:20

single-family

93:13 94:22

182:12

single-section

165:8 194:16

single-wide 95:15

216:1

sir 61:20

sit 84:7 280:18

site 36:17

108:14,15 109:3

114:17 233:16

235:1 260:19

site-built 175:3

sitting 215:15,18

254:9 259:6

situation 91:1

situational 113:1

116:7

six 8:11

Sixty 274:21

size 204:16 263:7

skin 49:19 126:16

skinny 126:15

sky 78:12

skylights 220:14

slash 27:11,12

28:17,21,22

slashed 28:16

slide 221:4

slight 61:8 123:9

slightly 56:16

slow 15:8 87:1,2

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slowly 160:18

small 96:12

150:15

211:20,21

242:6,8

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259:11 270:19

smaller 250:11,14

257:14 258:18

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236:3

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social 37:17 39:20

software 80:22

137:1

solar 5:19

261:21,22

262:4,11

sold 48:22 81:15

215:16 248:20

sole 44:14

solicit 72:11

solve 44:18 125:5

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somebody 7:2,6

47:10 81:17

120:13 278:8

somehow 90:2

129:8

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101:13,14 104:2

113:6 116:12

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somewhat 127:12

138:8,9

somewhere 22:9

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182:6

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12:16 13:21

16:11,21 17:7

23:1 24:4 30:3

51:20 53:4,6

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90:7 91:12

123:22 132:8

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201:7 204:4

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222:18 223:19

225:8 228:8

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254:18,22 258:2

274:18

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37:12 50:8 70:3

90:22 97:3

154:11,16 156:3

172:20 196:18

252:18 254:6

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sounds 6:16 11:2

42:22 77:9

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90:20 162:17

167:8 217:5

245:20 257:13

273:19 275:6

sources 85:10

99:18 273:17

south 245:6 262:5

southern 237:17

244:18 247:6

southernmost

262:10

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space 19:19 20:9

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spaces 202:21,22

span 113:12,17

189:8

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212:5 213:5

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SPEAKER 16:18

25:2 27:18

30:19

31:9,10,12,20

39:7 41:3,5,8,13

46:1,4 52:5

53:11 56:1

62:20 66:13

69:1 98:14,21

99:4,7 104:7

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225:22 273:3,13

274:20 275:1

speaking 129:10

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special 65:6

specialty 92:17

specific 6:15,21

52:2 64:19

79:18 101:4
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142:1 181:10

200:12 231:22

237:9,20 251:16

252:1,14 262:8

263:11

specifically 13:8

71:16 82:5

136:2,16 158:7

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252:12,13,15

specifics 165:4

166:1 273:16

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specify 17:11

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speech 73:1

speed 277:4

spelling 11:9

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spent 55:16 254:3

spiel 228:20

spin 201:5

spins 234:15

split 7:12 11:14

12:17 152:7

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sponsored 165:7

spot 184:2 251:12

sprinkled 123:13

square 90:10

squeeze 251:6

squirrel 190:8

Stacey 3:7 23:17

30:20 40:14

101:6 102:12

103:3,8 130:20

178:7 197:13

262:13,15

staff 126:21

stand 201:2

standard 6:20

33:11 35:9

52:18,19 60:19

61:6 66:22 67:1

68:4,6 79:12

82:4,8 84:10

85:15 94:14

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106:11

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136:2,15

137:9,21

138:3,12 139:5

142:2,5,6

144:18 147:19

154:21 166:18

170:22 171:6,16

173:22 175:2

176:17 177:6

182:16 185:13

199:9 202:17

203:1 208:12

214:18

217:4,16,18,19

233:5 243:5

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33:22 52:11

60:12 82:6

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121:11 129:17

133:13 136:9,12

137:7 140:2

142:14 158:1,3

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171:7 177:18

196:13 209:7

217:9,12 233:22

251:9,17,20,21

254:13 255:14

259:7 261:4

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145:19

standing 21:11

standpoint 9:11

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stands 136:21

177:12 203:14

Star 23:19 40:19

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61:9,17 62:10

65:4 192:20

193:19

195:3,5,8,12

196:1 214:9

220:21 235:13

237:12 254:7

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233:14 235:14

257:20,22

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280:21 281:7

start 20:16 38:20

43:14 48:2,8,9

55:12 68:8 70:9

71:2,19 75:21

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97:16 106:5

111:13 120:18

124:15 130:4,14

135:16 140:4,15

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273:22 276:1

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70:17 71:17

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177:8 181:20

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116:14 129:7

165:10 170:2,19

206:15 207:13

231:16,17

233:3,6 234:5

245:6

statement 99:11

107:7,8
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states

148:12,13,19

195:10 197:20

198:4 233:6

239:1 246:21

258:19,21

statewide 212:15

statistics 48:21

status 58:8 169:8

statute 60:8,9

61:1 157:21

163:7,8 170:22

171:5,12

173:10,14,16,20

181:15,21

182:21 188:12

223:16,20

statutes 158:7

statutory 155:4

stay 93:15 96:20

242:7,16

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242:9,15 264:12

step 3:7 14:12

30:21 38:4,5,19

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130:21 262:16

steps 118:11,12

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stick 25:19

94:5,10 176:8

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stock 106:4

215:10,18

216:11 248:16

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stop 145:13,17,22

straight 5:14

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straight-line

172:19

strategy 10:18

straw 65:8 68:14

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stretch 43:20,21

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strictly 47:4 179:2

strike 14:2 39:7,8

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stringent 171:16

175:14 228:4

244:17 249:5

structural

13:13,14

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137:14 138:5

struggling 111:2

199:6 281:9

studies 12:7 88:10

101:11 119:12

147:21 165:5

168:18 169:21

stuff 20:15 53:9

77:1 78:12 80:9

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100:21 122:15

123:19 132:11

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stuffed 256:19

subcommittee

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64:9,11,20,21

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66:17,18,20

76:2 77:9,22

78:15 84:14

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119:1,2

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subheading 16:13

subject 112:8

178:10 274:5

submit 71:10

submitted 73:9

201:10

submitting 99:20

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sub-o's 275:12

subparts 8:11

subs 42:2

subsection 158:2

subsets 15:12 42:5

subsidize 262:20

subsidized 195:9

substantial 110:9

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subsume 13:22

Subway 8:3

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suggest 8:13 11:5

14:22 15:7

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suggestion 17:15

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summarizing

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summary 159:1

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summer 264:15

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supply 71:8 83:22

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suppose 15:16

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32:2,13,19 33:1

52:13 53:21

65:12,18 70:10

74:4 83:15 88:1

113:12 116:12
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117:14 118:14

128:5 129:5

134:7,15 135:14

142:19 154:8

158:19 165:1

171:11

184:14,17,18,20

186:5 190:6

191:10 193:16

196:11 198:4

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202:2 204:1

205:17 216:7

227:20 235:9

238:16,17

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surprised 105:5

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surveyed 73:12

suspect 89:5

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