To: File From: Michael Jensen, DOE GC-71 Date: July 28, 2010 Re: Ex parte discussi on with PFS Corporation

On July 28, 2010, Michael Jensen (GC-71), Harr y Indig (EE-2J), and Dave Conover (PNL) spoke with Matthew Weidner and Paul Tibbits, both of PFS Corporat ion, on their company's role as both a production inspection primary inspec tion agency (IPIA) and as a design approval primary inspection agency (DAPIA) under the U.S. Department of Housing and Urban Development (HUD) manufactured housing program.

First, Mr. Weidner explai ned how PFS conducts DAPIA- a nd IPIA-related reviews of manufactured homes. He estimated that ninety-f ive percent of manufacturers have the capability of applying certification labels. Mr. Weidner mentioned that alt hough there used to be a problem with manufacturers complying with the HUD sta ndards approximately ten to fifteen years ago, this has not been the case recently due, in part, to HUD's recent focus on improving quality assessment in plants. He explained that if a manu facturer is found not to be in compliance, either the whole plant or an individual station within a plant is place d on a more frequent inspection

schedule.

Mr. Weidner noted that PFS only performs onsite inspections of alternative construction and

ENERGY STAR homes. He e xplained that consumer comp laints usually focused on

construction-related issues where the manufacturer, dealer, or dist ributors were at fault for not following DAPIA instructions. He also noted no recent complaints involving energy-related

issues.

Mr. Weidner stated that manu facturers generally produce two types of homes: high and lowincome homes. He noted that less than one pe rcent of homes included renewable systems, but guessed that these systems likely were included post-occupancy.

Mr. Weidner also noted that many plants build ho mes that both meet, or come close to meeting,

ENERGY STAR standards. He mentioned that the inspection cost for inspection of an ENERGY STAR home is approximately $1,500 to $2,000 depending upon the home. He also noted that fees charged by DAPIAs and IPIAs we re fixed rates that al so account for travel

expenses.

Mr. Weidner next noted that PFS also inspec ts modular housing, and although both the modular and manufactured housing industrie s have been in decline in recent years, he has noted an increase in production this year. Regardi ng the possibility of DOE placing additional responsibilities on IPIAs and DAPIA s to conduct further energy-rela ted reviews, he noted that PFS inspectors could require additional training.

Mr. Weidner mentioned that homes destined fo r southern climates predominately used 2x4

constructions whereas homes destined for north ern climates largely used 2x6. He noted the difficulties of estimating what the typical window-to-wall ratio is among inspected homes, but that they usual use approximately 200 to 250 ft2 of glazing. Mr. We idner explained thatapproximately sixty percent of the manufactur ed homes that PFS inspects are doublewide homes, that less than five percent of homes are triple wide or quads, and that PFS does not typically inspect homes with trust roofs.

Finally, Mr. Weidner mentioned th at the last time HUD changed its code, it gave the industry a six-month interim period of optional compliance e ffective six months after promulgation of its regulations, after which time compliance became mandatory.

End of conversation.