Unreasonable Energy Standards for Manufactured Housing
The Department of Energy (DOE) has published a proposed rulemaking on energy standards for manufactured housing which, if finalized will eliminate manufactured housing as an affordable housing option for hundreds of thousands of potential homebuyers. The current DOE proposal is fundamentally flawed and must be completely rewritten to ensure manufactured homes remain an available option for American families.
The DOE proposal would dramatically increase the costs of manufactured homes, and in some areas of the country, will make the construction and transportation of homes nearly impossible. The proposal uses the 2021 International Energy Conservation Code (IECC), which was developed for commercial and site-built residential buildings and ignores all the construction aspects unique to manufactured housing. Requiring the industry to comply with a building code that was developed outside of the HUD Code makes no sense and will confuse and disrupt manufacturing across the country.
The law requires the DOE to establish energy standards for manufactured housing based on the most recent version of the IECC unless using such a code is found not to be cost effective. We need to tell the DOE that their proposal is absolutely not cost effective. The assumptions made by the DOE in assessing cost are fundamentally flawed. According to MHI’s analysis of their assumptions, only one of the locations cited by DOE would result in minimal cost savings for a customer. All other locations would result in increases in upfront costs with no breakeven point even after ten years of ownership – there is NO payback in energy savings for the customer. Cost is not the only issue with the proposal. Under the DOE’s proposal, logistically it would be near impossible to construct and transport homes built with the new requirements.
At a time when the Administration is looking to boost the supply of affordable homes through manufactured housing, this rule cannot stand. Join us to oppose the DOE rule.
It is critical that DOE hear from all sectors of the manufactured housing industry about how detrimental this proposal would be for homeowners. Please join MHI’s effort and tell DOE that their actions will place homeownership out of reach for many Americans.
To participate in the Call to Action click the button below and follow the simple steps on MHI’s website. The letter to DOE has already been composed – all you have to do is insert your home address and click submit.
If you have any questions, please contact MHI’s Policy Department at MHIgov@mfghome.org or 703-558-0675.