JANUARY 28, 2026
TO: HUD CODE MANUFACTURED HOUSING INDUSTRY MEMBERS
FROM: MHARR
RE: MHCC RECOMMENDS WITHDRAWAL OF DOE
“FINAL” ENERGY RULE BUT PROBLEMS REMAIN
The statutory Manufactured Housing Consensus Committee (MHCC), following a January 27-28, 2026 teleconference meeting called to formulate a response to the U.S. Department of Energy’s (DOE) September 3, 2025 Request for Input (RFI) regarding manufactured housing “energy conservation” standards, has called for DOE to withdraw its 2022 “final” manufactured housing energy standards rule, as well as its subsequent proposed manufactured housing energy standards enforcement rule.
While implementation of the DOE energy standards rule has been delayed by DOE, and DOE has yet to issue a final enforcement rule following its 2023 publication of a proposed rule, both actions remain pending and threaten to drastically increase the acquisition cost of manufactured homes – in return for speculative alleged “benefits” – at a time when the nation is facing an unprecedented affordable housing crisis, with a documented shortage of 7 million or more affordable “starter” homes.
MHARR, therefore, as it has consistently, since the inception of the DOE rulemaking, called upon and urged the MHCC to submit comments rejecting the bases, premises, analyses and alleged cost-benefit inputs underlying both DOE regulatory actions.
Consistent with this request and MHARR’s position, the MHCC’s comments call not only for the withdrawal of the DOE “final” standards and related proposed enforcement rule, but also make it unmistakably clear that any further activity regarding manufactured housing energy standards must be undertaken solely within the context of HUD’s manufactured housing standards development process, including full participation and involvement by the MHCC in accordance with the Manufactured Housing Improvement Act of 2000.
This latter point, as MHARR emphasized at the meeting, is particularly important in light of recent developments regarding manufactured housing legislation currently pending in Congress.
Specifically, a bill (H.R. 5184), filed by Rep. Erin Houchin – supported in its original form by MHARR – would have unequivocally repealed section 413 of the Energy Independence and Security Act of 2007 (EISA), which transferred manufactured housing energy regulation jurisdiction from HUD to DOE. That bill, however, was subsequently amended – and significantly watered down during the legislative process (an indication of the post-production sector’s weakness in Washington, D.C.) before it was passed by the House of Representatives. With the modified language, the bill would not repeal section 413 but, instead would authorize DOE to submit “recommended” manufactured housing energy conservation standards, subject to certain criteria and conditions. By preserving any element of DOE manufactured housing energy regulation authority, however, the modified bill leaves open the risk of further destructive DOE involvement regarding manufactured housing energy standards.
Given this unnecessary and inexplicable retention of any DOE jurisdiction over manufactured housing energy regulation, it was critical – and, indeed, imperative – that the MHCC, as a statutory panel of manufactured housing experts, thoroughly and completely reject both DOE proposals, and clearly state as well that DOE should exit this entire area of regulation in deference to HUD and the MHCC, and HUD’s statutory standards development process.
MHARR, for its part, has also submitted its own written comments in response to the DOE RFI, pointing out that a key input to DOE’s 2022 rule cost-benefit analysis – the federal “Social Cost of Carbon” metric – has been rejected by the Trump Administration, thereby rendering the entire cost-benefit basis for the 2022 “final” rule wholly void and illegitimate. Accordingly, multiple valid and compelling bases have been asserted for the withdrawal and repudiation of the 2022 DOE “final” standard and the 2023 proposed enforcement rule.
MHARR will, therefore, continue to carefully monitor this matter for further developments and will continue to oppose the baseless and destructive pending DOE standards.
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
