DOE Takes Next Step Toward Drastic and Costly Manufactured Housing Energy Standards

DOE Takes Next Step Toward Drastic and Costly Manufactured Housing Energy Standards

DepartmentOfEnergyLOGOMHARRlogoDOETakesNextStepTowardDrasticCostlyManufacturedHousingEnergyStandardsManufacturedHousingAssocRegulatoryReformLogo

The U.S. Department of Energy (DOE), on August 26, 2021, formally published its “Supplemental Notice of Proposed Rulemaking” for manufactured housing energy standards in the Federal Register see, see, copy attached.

As has repeatedly been emphasized by MHARR, the proposed DOE standards would impose extreme and costly new energy mandates on manufactured homes, based – at least initially – on the 2021 version of the International Energy Conservation Code (IECC), a code developed, in its present form, without input from the HUD Code manufactured housing industry and without regard to the cost balancing and cost justification required by federal manufactured housing law. The sheer magnitude of these price increases – which will continue indefinitely into the future with each new iteration of the IECC if not stopped now – will totally change the price structure and marketability of mainstream, HUD Code manufactured homes, while excluding millions of lower and moderate-income American families from the manufactured housing market and from homeownership altogether.

Specifically, as MHARR has calculated based on a study of the 2021 IECC conducted by Home Innovation Labs, Inc. on behalf of the National Association of Homebuilders (NAHB):

  • The 2021 IECC standards would result in a minimum $7,958.00 retail level structural price increase for a single section manufactured home;
  • The 2021 IECC standards would result in a minimum $12,908.00 retail level structural price increase for a double-section manufactured home;
  • Cost increases of this magnitude would exclude 6,816,883 households from the manufactured housing market based on NAHB metrics developed in connection with DOE’s 2016 proposed energy standards rule for manufactured housing.
  • These figures do not include additional costs for testing, enforcement, and regulatory compliance; and
  • These figures do not capture the additional costs that would be incurred with each new iteration of the IECC, which the DOE standards would be required to track.

While MHARR has opposed such needless and destructive standards from day-one – often alone — and has been successful in stopping the baseless sabotage of the fundamental affordability of manufactured housing by “energy” special interests, this matter has reached a stage where forceful opposition by the entire industry will be necessary in order to prevent serious damage to the availability and affordability of manufactured housing in direct violation of federal law.

Comments in response to the “supplemental” proposed rule are due on or before October 25, 2021.  In addition, a public webinar, including an opportunity for public comment, will be held on September 28, 2021. MHARR urges all industry members to submit comments in opposition to these standards and to present opposing statements at the scheduled webinar. MHARR, as usual, will submit its comments in advance of the relevant deadlines, and make them available to the entire industry for use or reference.

Attached Copy

pdf-images.-2jpg
2021-17684doe.-pdf

The U.S. Department of Energy (DOE), on August 26, 2021, formally published its “Supplemental Notice of Proposed Rulemaking” for manufactured housing energy standards in the Federal Register see, see, copy attached.

As has repeatedly been emphasized by MHARR, the proposed DOE standards would impose extreme and costly new energy mandates on manufactured homes, based – at least initially – on the 2021 version of the International Energy Conservation Code (IECC), a code developed, in its present form, without input from the HUD Code manufactured housing industry and without regard to the cost balancing and cost justification required by federal manufactured housing law. The sheer magnitude of these price increases – which will continue indefinitely into the future with each new iteration of the IECC if not stopped now – will totally change the price structure and marketability of mainstream, HUD Code manufactured homes, while excluding millions of lower and moderate-income American families from the manufactured housing market and from homeownership altogether.

Specifically, as MHARR has calculated based on a study of the 2021 IECC conducted by Home Innovation Labs, Inc. on behalf of the National Association of Homebuilders (NAHB):

  • The 2021 IECC standards would result in a minimum $7,958.00 retail level structural price increase for a single section manufactured home;
  • The 2021 IECC standards would result in a minimum $12,908.00 retail level structural price increase for a double-section manufactured home;
  • Cost increases of this magnitude would exclude 6,816,883 households from the manufactured housing market based on NAHB metrics developed in connection with DOE’s 2016 proposed energy standards rule for manufactured housing.
  • These figures do not include additional costs for testing, enforcement, and regulatory compliance; and
  • These figures do not capture the additional costs that would be incurred with each new iteration of the IECC, which the DOE standards would be required to track.

While MHARR has opposed such needless and destructive standards from day-one – often alone — and has been successful in stopping the baseless sabotage of the fundamental affordability of manufactured housing by “energy” special interests, this matter has reached a stage where forceful opposition by the entire industry will be necessary in order to prevent serious damage to the availability and affordability of manufactured housing in direct violation of federal law.

Comments in response to the “supplemental” proposed rule are due on or before October 25, 2021.  In addition, a public webinar, including an opportunity for public comment, will be held on September 28, 2021. MHARR urges all industry members to submit comments in opposition to these standards and to present opposing statements at the scheduled webinar. MHARR, as usual, will submit its comments in advance of the relevant deadlines, and make them available to the entire industry for use or reference.

Attached Copy

pdf-images.-2jpg
https://manufacturedhousingassociationregulatoryreform.org/wp-content/uploads/2021/08/2021-17684doe.pdf

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