APRIL 23, 2025
TO: MHARR MANUFACTURERS
MHARR STATE AFFILIATES
MHARR TECHNICAL REVIEW GROUP (TRG)
FROM: MARK WEISS
RE: DOE EXTENDS COMPLIANCE DEADLINE FOR TIER 2
MANUFACTURED HOUSING “ENERGY” STANDARDS
The U.S. Department of Energy (DOE), in a News Release and draft Federal Register notice issued on April 22, 2025, has announced its intention to delay the compliance date for its “energy conservation” standards for Tier 2 (i.e., multi-section) manufactured homes to a date 180 days after the “publication of corresponding enforcement procedures.” The compliance date for Tier 1 (i.e., single-section) manufactured homes, will remain unchanged at 60 days after the publication of final enforcement regulations. A copy of the DOE News Release and draft Federal Register notice are attached.
While this delay is acceptable as a first step toward the retraction of the draconian and destructive DOE standards, it is not sufficient, in and of itself, to remedy the fatally flawed DOE standards development process that led to the May 31, 2022 “final” standards, or the disproportionate, discriminatory and excessive cost burdens that those standards (for both single and multi-section homes) would impose on both manufactured housing consumers and the industry. MHARR has been consistent in its position that the May 31, 2022 DOE standards are unreasonable, unnecessary and would needlessly exclude millions of Americans from the manufactured housing market and from homeownership altogether.
It is, therefore, encouraging that the DOE News Release states, in part, that “this action, taken in anticipation of further rollbacks of unnecessary regulations on the manufactured housing market, is the latest step toward the Trump Administration’s goal of restoring sensible energy conservation standards for American homes.” (Emphasis added).
Consistent with this statement, DOE should – as MHARR has long maintained – withdraw the fatally flawed and defective May 31, 2022 energy standards (for both single and multi-section homes) and replace them with appropriate and cost-effective measures as determined through the statutory Manufactured Housing Consensus Committee (MHCC) consensus-based process. That process, in turn, should focus on the unique construction and affordability of HUD Code manufactured housing, rather than an attempted clone of the International Energy Conservation Code (IECC), which is not appropriate for any type of manufactured housing and is inconsistent with the mandate – first set forth in the National Manufactured Housing Construction and Safety Standards Act of 1974, and later strengthened in the Manufactured Housing Improvement Act of 2000 – that manufactured housing regulation be reasonable and cost-effective for consumers in terms of the purchase price of the home.
As it already has with HUD, MHARR will continue to engage with senior leadership at DOE to seek the full withdrawal and disavowal of the May 31, 2022 “final” manufactured housing energy standards pertaining to all HUD Code manufactured homes.
MHARR will continue to keep you apprised of further developments affecting the DOE manufactured housing energy standards.
cc: Other Interested HUD Code Manufactured Housing Industry Members
Attachments
Mark Weiss
President & CEO
Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: MHARRDG@AOL.COM
Website: www.manufacturedhousingassociation.org
