# Manufactured Housing Working Group Summary



## Joseph Hagerman, DOE2 

# MH Working Group Charter

“The purpose of the working group (WG) was to discuss and, if possible, reach consensus on a proposed rule for the energy efficiency of manufactured homes (MH), as authorized by section 413 of the Energy Independence and Security Act of 2007 (EISA) .”

• The WG was instructed by ASRAC to complete the term sheet for a proposed rule by September 30, 2014

– One extension was granted which expired on October 31, 2014.



# • The WG convened 6 times over three months to accomplish its goal:

– Term Sheet, Appendix A: modifications to IECC to address MH, and a list of non

- binding recommendations3 

# Impacts of Terms Sheet and WG Recommendation

• Preliminary energy savings estimates resulting from the Term Sheet...

– Cumulative national energy savings of about 0.7 quads for new manufactured homes shipped over a 30 year period.

• Assumption include 60,000 manufactured homes are shipped annually and that each home is operated for 30 years

.
• DOE will refine the national energy savings calculation during development of the NOPR

.



## – Realizes 20

- 30% reduction in today’s manufactured housing annual energy consumption.

• Energy savings in a new MH resulting from the Term Sheet would be more cost

- effective than simply adhering to the 2015 IECC.



## • Recommendation: ASRAC accept the term sheet and provide it to the Secretary to use as the basis for a Notice of Proposed Rulemaking to the maximum extent possible consistent with the Agency's legal obligations.4 

# Working Group Recommendations: Term Sheet
Section 2: Applicable Aspects of the 2015 IECC

Recommendation Vote Outcome

Consensus (19

- yes; 1

- no; 2

- abstain): October 24, 2014 The WG reviewed the 2015 International Energy Conservation Code (IECC) for residential buildings for applicability to manufactured housing. The WG identified sections of the 2015 IECC that were not applicable, and modified other sections to make them more applicable to manufactured housing.



### Considerations : The WG reviewed the relevant sections of the 2015 IECC. DOE in its notice of proposed rulemaking (NOPR) process will likely need to review all IECC language to ensure no sections were missed

– to be all inclusive. 

# Appendix A of the Term Sheet contains a line by line review of the 2015 IECC and makes modifications to address the MH industry.5 

# Working Group Recommendations: Term Sheet

Section 3: Climate Zones

Recommendation Vote Outcome

Consensus (20

- yes; 1

- no; 1

- abstain): October 23, 2014 The WG recommends that the energy efficiency standards be based on the four climate zones depicted in Figure 3.1 below. DOE will determine zoning of Alaska , Hawaii, and US Territories when it develops a NOPR

. Consensus (20

- yes; 0

- no; 2

- abstain): October 24, 2014 The WG recommends using the naming convention of zone 1A, 1B, 2, and 3.

Figure 3.1 Climate Zone Map Considerations : Depending on the outcome of DOE’s SHGC analysis, zones 1A and 1B could have identical requirements. Some WG members expressed that the creation of two zones allow for the potential for different requirements as they felt the regional differentiation could help alleviate issues of affordability.6 

# Working Group Recommendations: Term Sheet
Section 4: Building Thermal Envelope Pathways to Compliance

Recommendation Vote Outcome

Consensus (20

- yes; 0

- no; 2

-

abstain): October 2, 2014 The WG recommends allowing both a prescriptive path option and a performance path ( U o ) option to ensure improved energy efficiency of a manufactured home’s building thermal envelope. Both building thermal envelope compliance pathways would also include additional mandatory requirements



### Considerations : The WG voted for 2 paths to provide a straightforward method without calculations (prescriptive) and a more flexible method for housing design that includes a U o 

### calculation (performance). The U o 

### method is the current method of compliance for the industry with Housing and Urban Development (HUD).7 

# Working Group Recommendations: Term Sheet
Section 5: Building Thermal Envelope Requirements: Prescriptive Path Option

Recommendation Vote Outcome

Consensus (20

- yes; 1

- no; 1

- abstain): October 23, 2014 The WG recommends the prescriptive measures associated with the 4 climate zones outlined in Table 5.1 below. These measures would apply to all manufactured homes regardless of size.

Climate Zone Ceiling ( R
- value) Wall ( R
- value) Floor ( R
- value) Window ( U
- value) Skylight ( U
- value) Door ( U
- value) Glazed Fenestration (SHGC ) 1A 30 13 13 0.35 .75 0.40 0.25 1B 30 13 13 0.35 .75 0.40 Pending DOE Analysis* 2 30 21 19 0.35 .55 0.40 Pending DOE Analysis* 3 38 21 30 0.32 .55 0.40 No Rating *The WG did not reach consensus on prescriptive specifications for SHGC in climate zones 1B and 2, and has recommended that DOE determine these values after further analysis when it develops a NOPR. T

able 5.1 Building Thermal Envelope Prescriptive Requirements



### Considerations : The WG reviewed the life

- cycle cost of several packages of requirements, and determined this package to be the most cost

- effective. SHGC values are pending DOE analysis of the impact of different window position and building orientation assumptions than used in the base case model.8 

# Working Group Recommendations: Term Sheet
Section 5: Building Thermal Envelope Requirements: Prescriptive Path Option

Recommendation Vote Outcome

Consensus (19

- yes; 1

- no; 2

- abstain): October 24, 2014 The WG recommends the following footnotes apply to the prescriptive requirements listed in the Table 5.1: 1. For conversion between units of length: 1 foot = 304.8 mm. 2. R

- values represent minimums; U

- values represent maximums. 3. Skylights with SHGC ≤ 0.30 may be excluded from building thermal envelope glazed fenestration SHGC requirements. 4. Floor R

- values assume R

- 21 batt + R

- 14 blanket values to account for compression areas in the floor in climate zone 3. 5. The wall R

- values column assumes a minimum truss heel height of 5.5 inches at the outside face of each exterior wall. 6. Each R

- values column reflects the insulation manufacturers’ published values. Uniform insulation thickness would not be mandatory as long as the required volume of insulation is installed with uniform density 

### Considerations : Definition of R

- values should be reviewed with the Federal Trade Commission (FTC) and its guidelines.9 

# Working Group Recommendations: Term Sheet
Section 5: Building Thermal Envelope Requirements: Prescriptive Path Option

Recommendation Vote Outcome

Consensus (20

- yes; 1

- no; 1

- abstain): October 24, 2014 The WG recommends DOE complete further analysis to determine U

- values for use as an alternative to the R

- values listed in Table 5.1. Under this U

- values approach, a manufacturer would need to comply with the window, skylight, and door U

- values, and the glazed fenestration SHGC specifications included in Table 5.1.

Climate Zone Ceiling ( U
- value) Wall ( U
- value) Floor ( U
- value)

1A Pending DOE Analysis* Pending DOE Analysis* Pending DOE Analysis*
1B Pending DOE Analysis* Pending DOE Analysis* Pending DOE Analysis*
2 Pending DOE Analysis* Pending DOE Analysis* Pending DOE Analysis*
3 Pending DOE Analysis* Pending DOE Analysis* Pending DOE Analysis* T

able 5.2 U
- Value Alternative for Ceiling, Wall, and Floor

*The WG did not reach consensus on the U

- values in Table 5.2 and has recommended DOE determine these values after further analysis when it develops a NOPR. 

### Considerations : The WG did not have enough time to reach a consensus on these values. Therefore, DOE needs to determine the R

- value to U

- value conversion for the NOPR, which may be different than the IECC equivalents. The conversion is dependent on manufactured home construction assumptions.10 

# Working Group Recommendations: Term Sheet
Section 6: Building Thermal Envelope Requirements : U o 

## Performance Path Option Recommendation Vote Outcome

Consensus (19

- yes; 1

- no; 2

- abstain): October 24, 2014 The WG recommends the U o values in Table 6.1. The SHGC requirement shall be met in addition to U o . An area weighted average S HGC shall satisfy the glazed fenestration SHGC requirements of Table 5.1.

T

able 6 .1 U o Values for Performance Path Climate Zone Single

- Section U o Multi

- Section U o 1A 0.087 0.084 1B 0.087 0.084 2 0.070 0.068 3 0.059 0.056 Consensus (20

- yes; 0

- no; 2

- abstain): October 24, 2014 The WG recommends that the calculation of U o follow the Battelle method. The Battelle method produces an area

- weighted average overall U

- value for a home based on the thermal qualities and areas of material assemblies used in the home’s construction.

Consensus (20

- yes; 1

- no; 1

- abstain): October 23, 2014



### Considerations : More members supported having separate U o 

### values for different sized homes than one U o 

### value for all homes. This approach does give a less stringent requirement for single

- section homes, which are the typical option for low

- income buyers

– some members of the WG felt that this approach also helped address affordability.11 

# Working Group Recommendations: Term Sheet
Section 7: Other Mandatory Requirements
– Envelope Sealing

Recommendation Vote Outcome

Consensus (15

- yes; 2

- no; 5

- abstain): September 23, 2014 To provide envelope tightness of 5 air changes per hour (ACH) when depressurized to 50 Pascals (Pa), the WG recommends that all manufactured homes would be required to ensure that: 1) A continuous air barrier is established upon installation of all building thermal envelope (i.e., ceiling, walls, doors, and floor) opaque components 2) Mating line surfaces (i.e., floor, exterior walls, and ceiling) are equipped with a continuous, durable gasket. 3) Gaps and penetrations in the ceilings, floors, and exterior surfaces of walls would be sealed with caulk, foam or gasket, or other suitable material. 4) Rough openings around windows and exterior doors are sealed with caulk or foam. 

### Considerations : DOE should conduct testing after the compliance date of standards to assess the effectiveness of these visual inspection requirements. Because of a lack of data/cost on this issue, the WG did not recommend direct testing of envelope sealing.12 

# Working Group Recommendations: Term Sheet
Section 7: Other Mandatory Requirements
– Envelope Sealing (continued)

Recommendation Vote Outcome

Consensus (15

- yes; 2

- no; 5

- abstain): September 23, 2014 To provide envelope tightness of 5 air changes per hour (ACH) when depressurized to 50 Pascals (Pa), the WG recommends that all manufactured homes would be required to ensure that (cont .): 5) Attic access panels and drop

- down stairs are equipped with gaskets (i.e., not caulked) to produce a continuous air seal. 6) Duct system register boots that penetrate the building thermal envelope and/or air infiltration barrier are sealed to the air barrier or interior finish materials. 7) Sealing methods between dissimilar materials allow for differential expansion and contraction



### Considerations : DOE should conduct testing after the compliance date of standards to assess the effectiveness of these visual inspection requirements. Because of a lack of data/cost on this issue, The WG did not recommend direct testing of envelope sealing.13 

# Working Group Recommendations: Term Sheet
Section 7: Other Mandatory Requirements
– Duct Sealing and Hot Water Pipe Insulation

Recommendation Vote Outcome

Consensus (19

- yes; 0

- no; 3

- abstain): September 22, 2014 The WG recommends that duct leakage must be no greater than 4 cubic feet per minute (CFM) per 100 square feet of floor area at a 25 Pa test pressure.

Consensus (17

- yes; 0

- no; 5

- abstain): September 23, 2014 The WG recommends that all hot water pipes outside conditioned space would be required to be insulated to at least R

- 3. In addition, all hot water pipes from a water heater to a distribution manifold would be required to be insulated to at least R

- 3.



### Considerations : The WG assumed duct leakage testing would be needed for all homes. Industry perceives the recall risk as too great if they ship a non

- compliant home.14 

# Back

- u p Slides

• Non

- binding Recommendations

• WG membership15 

# Non
- binding Working Group Recommendations (1)
Other Recommendations Outside the Scope of the Working Group

Recommendation
The WG recommends that DOE charter a new working group through ASRAC to develop recommendations regarding certification

- testing and enforcement. [DOE SUPPORTS]
The WG recommends that DOE modify the REScheck software application to specifically address manufactured housing. The WG observed that both inputs and calculation assumptions (e.g., the siting orientation of the home) would require modification to account for the factory construction of manufactured homes. The modified application also would provide recommendations for equipment sizing. [DOE SUPPORTS GIVEN FUNDING]
The WG recommends that DOE consider development of a duct sizing tool, potentially based on the Air Conditioning Contractors of America (ACCA) Manual D. [NO COMMENT] 

### The WG discussed and made notes on other recommendations, issues, concerns, and opportunities that DOE should consider as it begins to regulate the industry. All these topics are not binding to the terms sheet.16 

# Non
- binding Working Group Recommendations (2)
Other Recommendations Outside the Scope of the Working Group

Recommendation
The WG has three recommendations involving building thermal envelope sealing: [NO COMMENT] 1) DOE conduct testing to confirm an average ACH of 5 is achieved in practice with the 7 visual inspection envelope sealing requirements listed in section 7. This testing could inform future decisions regarding building thermal envelope sealing. 2) DOE conduct a WUFI analysis to assess potential moisture concerns of the proposed package on exterior walls. This analysis could inform future decisions and regulations regarding building thermal envelope sealing. 3) DOE consider approaches to address a scenario in which an exterior surface of a wall cannot be sealed, such as the case in which the exterior sheathing is also the structural sheathing, and the resulting impact to the recommendations from section 7. The WG recommends that DOE consider labeling approaches that provide (1) voluntary labeling for whole

- house performance information, (2) heating/cooling equipment sizing parameters capable of servicing a home with the highest expected heating and cooling load, and (3) additional information on building components and equipment

. [DOE SHOULD REVIEW THIS WITH THE APPROPRIATE PARTIES] The WG recommends DOE consider an education program on energy efficiency for potential owners of manufactured housing

. [NO COMMENT]17 

# Non
- binding Working Group Recommendations (3)
Other Recommendations Outside the Scope of the Working Group

Recommendation

The WG recommends DOE consider an education program on non - energy benefits for potential owners of manufactured housing including indoor air quality, comfort, and durability

. [NO COMMENT ]

The WG recommends DOE consider certain revisions to the HUD regulations at Subpart F of 24 CFR Part 3280. DOE should discuss these recommendations with HUD to address duplications and inconsistencies between the current 24 CFR Part 3280 and DOE’s eventual NOPR. [NO COMMENT ]



### Considerations : DOE will take into consideration these recommendations. The WG recommends that DOE consider government supports/grants/subsidies/etc. for energy efficiency, and that DOE consider increasing DOE R&D funding to a level commensurate with the role of manufactured housing in the nation’s housing mix. [NO COMMENT ]18 

# Working Group Members

Name
Joseph Hagerman
John Caskey

Bert Kessler
David Tompos
Emanuel Levy

Eric Lacey

Ishbel Dickens

Keith Dennis
Lois Starkey
Lowell Ungar

Manuel Santana Affiliation
Department of Energy ASRAC, National Electrical Manufacturers Association Palm Harbor Homes, Inc.
NTA, Inc.
System Building Research Alliance
Responsible Energy Codes Alliance
National Manufactured Home Owners Association (NMHOA) National Rural Electric Cooperative Association
Manufactured Housing Institute
American Council for an Energy

- Efficient Economy

Cavco Industries Mark Ezzo Name

Mark Weiss

Michael Lubliner

Michael Wade

Peter Schneider
Richard Hanger

Richard Potts

Rob Luter
Robin Roy

Scott Drake
Stacey Epperson
Clayton Homes, Inc. Affiliation Manufactured Housing Association for Regulatory Reform Washington State University Extension Energy Program
Cavalier Home Builders
Efficiency Vermont
Housing Technology and Standards Virginia Department of Housing and Community Development Lippert Components, Inc.

Natural Resources Defense Council
East Kentucky Power Cooperative
Next Step Network