MHARRreiteratesCallForRepealOfDOEenergyRuleSecChrisWrightImgManufacturedHousingAssocRegulatoryReform

MHARR Reiterates Call for Repeal of DOE “Energy” Rule

FOR IMMEDIATE RELEASE                                                                     Contact: MHARR

                                                                                                                       (202) 783-4087

 

MHARRreiteratesCallForRepealOfDOEenergyRuleSecChrisWrightImgManufacturedHousingAssocRegulatoryReform

 

MHARR REITERATES CALL FOR REPEAL OF DOE “ENERGY” RULE

Washington, D.C., July 9, 2026 – The Manufactured Housing Association for Regulatory Reform (MHARR) has reiterated and reinforced its long-standing call for the U.S. Department of Energy (DOE) to repeal and repudiate its currently-deferred May 31, 2022 “final” manufactured housing “energy conservation” standards.

In a July 8, 2026 communication to DOE Secretary, Chris Wright (see, copy attached), MHARR asserts that DOE’s June 26, 2026 repudiation of the 2024 International Energy Conservation Code (IECC) – a closely-related iteration of the 2021 IECC version which forms the basis for the May 31, 2022 DOE manufactured housing standards – is a further independent, valid and sufficient basis for a parallel DOE repudiation of the manufactured housing standards. Furthermore, in repudiating the 2024 IECC, DOE cites Executive Order 14394 “Removing Regulatory Barriers to Affordable Home Construction” (EO). MHARR cited the same EO, in a March 25, 2026 communication to DOE likewise calling for the elimination of the May 31, 2022 Biden-era manufactured housing energy standards based on section 2 (c) of the EO, which states, in relevant part:

“The Secretary of HUD and the Secretary of Energy shall … take appropriate action to reform and where appropriate, eliminate unduly burdensome or costly energy-efficiency … requirements regarding housing … include[ing] …revising the Energy Conservation Program’s Energy Conservation Standards for Manufactured Housing.”

In addition, and as a further independent and sufficient basis for the repeal of the May 31, 2022 manufactured housing standards, MHARR cites DOE’s July 2, 2026 proposed rule to “permanently end” certain DOE home appliance and equipment energy mandates that have “restricted consumer choice and dr[iven] up costs,”

            MHARR’s communication asserts that there is no valid or legitimate legal or practical distinction between the energy mandates that the aforesaid actions would eliminate and the May 31, 2022 manufactured housing energy standards. MHARR thus calls upon DOE to repudiate and repeal those standards.

Such action, moreover, is essential, because the pending housing bill – the 21st Century ROAD to Housing Act – would not automatically or necessarily eliminate the May 31, 2022 DOE “final” standards. A previous bill filed by Rep. Erin Houchin (R-IN) would have done that, but was “compromised” into irrelevance and ineffectiveness for reasons that have never been fully – or even partially – explained. Instead, the ROAD Act would do nothing to repeal the mandate for manufactured housing energy standards set forth in the Energy Independence and Security Act of 2007 (EISA) and would specifically allow the DOE standards to go into effect if they were approved and adopted by HUD (a virtual certainty under a Post-Trump administration).

            In order to avoid such a scenario – and a major loophole incorporated within the ROAD Act – it is essential that DOE, under the current administration, take concrete action to eliminate the lingering existential threat posed by those baseless and needlessly costly regulations.

MHARR, therefore, will continue to pursue the full repeal of the May 31, 2022 DOE standards through all available means.

In addition, MHARR will continue to aggressively oppose any HUD manufactured housing energy standards that are in any way, based upon, derived from, related to, or based on the same statutory authority or external code provisions as the pending DOE standards. This further point is particularly important insofar as HUD has now published notice of a Manufactured Housing Consensus Committee (MHCC) meeting on July 23, 2026 specifically to “review the energy conservation standards for manufactured housing.” (Emphasis added).

In Washington, D.C., MHARR President and CEO Mark Weiss stated: “While Secretary Wright at DOE is actively implementing President Trump’s agenda (as set forth in Executive Order 14394) to reduce unnecessary, baseless and costly regulatory burdens on American homebuyers, including extremist-driven “energy” mandates, HUD is showing its utter contempt for both the HUD Code industry and hard-pressed lower and moderate-income consumers who would be priced out of the manufactured housing market – and the housing market altogether – by pursuing unneeded and unnecessary high-cost “energy” mandates. Even worse, it is clearly trying to railroad these standards into effect through absolutely minimal notice of the July 23, 2026 MHCC meeting and virtually no time for stakeholders to submit substantive comments. The Trump Administration can – and must – do better.”

The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.- based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.

Attachments

— 30 —

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

— —

July 8, 2026

VIA FEDERAL EXPRESS

Hon. Chris Wright
Secretary
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585

 

Re: Manufactured Housing Energy Conservation Standards

DOE Docket No. EERE-2009-BT-BC-0021

Dear Secretary Wright:

I write once again to ask that the U.S. Department of Energy (DOE) formally withdraw its “energy conservation” standards for manufactured homes final rule, published May 31, 2022,[1] but not yet implemented.[2]

As MHARR has demonstrated in multiple rounds of written comments submitted during the DOE rulemaking process, the DOE standards – contrary to baseless assertions set forth by disingenuous DOE staff in support of the “final” rule – would needlessly add thousands of dollars to the purchase price of a new manufactured home, with minimal or no corresponding benefits or, at most, benefits that would take years or decades to be realized. According to price sensitivity metrics provided by MHARR, such purchase price increases would exclude millions of Americans from homeownership and all of the benefits of homeownership, at a time of unprecedented demand and need for affordable housing.

Further, as you are aware, the DOE manufactured housing energy standards are based on – and were developed in accordance with – the International Energy Conservation Code (IECC) maintained and sponsored by the International Code Council (ICC).[3] It is thus highly relevant that, as in a News Release issued on June 26, 2026,[4] DOE, in accordance with Executive Order 14394, “Removing Regulatory Barriers to Affordable Home Construction,”[5] specifically repudiated the 2024 IECC Code and the ICC development process for the IECC, stating:

“[T]he 2024 IECC would increase residential housing costs by more than $9.2 billion annually compared to 2006 code levels, adding more than $127 billion in cumulative costs nationwide.”

Pursuant to these findings, you concluded and stated:

American families should not be forced to pay more for a home because nonsensical energy-related mandates. *** For too long, climate activists have pushed regulations that increase housing costs, reduce consumer choice, and make it harder for Americans to build and own a home. Thankfully President Trump will continue fighting for the American people so they can enjoy affordable energy access and the ability to buy the home they desire with the features they choose.”

(Emphasis added).

The exact same reasoning and rationale applies with equal – if not greater force – to the May 31, 2022 “final” DOE manufactured housing “energy conservation” standards. Those IECC-derived standards, as MHARR and other commenters have consistently demonstrated, would needlessly undermine the inherent affordability of manufactured homes, contrary to the express mandate of federal manufactured housing law and would deny safe, decent and affordable housing and homeownership to millions of lower and moderate-income American families that have historically relied on the unparalleled affordability of manufactured housing to become homeowners. Indeed, DOE’s reliance on the IECC as the basis for manufactured housing energy standards is even more egregious and unfounded than the example cited in the above-referenced News Release, insofar as the IECC was never developed for, or specifically adapted to, manufactured housing, and is totally inconsistent with the unique engineering, designs and construction of HUD Code manufactured homes.

Furthermore, the manufactured housing energy mandate and May 31, 2022 DOE standards  are legally, economically and practically indistinguishable from the DOE home appliance and equipment energy conservation mandates that DOE announced, on July 2, 2026, would be “permanently end[ed].” In that News Release, you again stated that:

“For too long, the American people [have] paid a price for [energy] mandates that restricted consumer choice and drove up costs. President Trump promised to end this nonsense and that is exactly what we are doing. The proposed rule will preserve the American people’s ability to choose home appliances and equipment that actually work – at prices they can afford. It’s called common sense.”

And once again, the same logic and rationale support – and demand – that DOE formally and finally withdraw its overblown, overdone, industry and home affordability-killing “energy conservation” standards for manufactured housing in order to eliminate and repudiate such unnecessary and destructive mandates pushed by the same cadre of “climate” radicals. The time has come to remove this extreme threat against the nation’s most affordable type of housing and the American consumers who rely on its purchase-price and operational affordability.

We thank you – and President Trump – for your affordability agenda, and again ask that you act to repeal the egregious May 31, 2022 DOE manufactured home “energy conservation” regulations and their underlying basis.

Sincerely,

 

Mark Weiss
President and CEO

cc:  Hon. Donald J. Trump
Hon. Scott Bessent
Hon. Scott Turner
Hon. Russell Vought
HUD Code Manufactured Housing Industry Members

[1] See, 87 Federal Register, No. 104, (May 31, 2022) “Energy Conservation Program: Energy Conservation Standards for Manufactured Homes,” at p. 32728, et seq.

[2] See, 90 Federal Register, No. 168 (September 3, 2025) “Public Input on Energy Conservation Standards for Manufactured Housing,” at pp. 42545-425546 for a summary of DOE regulatory actions regarding the compliance date for the subject standards.

[3] The May 31, 2022 DOE “final” manufactured housing standards were based on the 2021 iteration of the IECC. While the 2021 IECC is not identical to the 2024 IECC addressed by DOE’s June 26, 2026 News Release and supporting materials, it is very similar and is characterized by the same type of high-cost/zero (or minimal) benefit mandates that are contained in the 2024 IECC.

[4] See, copy attached.

[5] In a prior March 25, 2026 communication to you, MHARR specifically called for the withdrawal and repudiation of the May 31, 2022 DOE manufactured housing energy standards pursuant to section 2(c) of EO 14394, which states, in relevant part: “ The Secretary of [HUD] [and] the Secretary of Energy shall, within their respective authorities, take appropriate action to reform and where appropriate, eliminate unduly burdensome or costly energy-efficiency … requirements regarding housing, to the maximum extent practicable…. Such action shall include reviewing and revising … (i) the Energy Conservation Program’s Energy Conservation Standards for Manufactured Housing.” See, copy attached.

— —

MHARR’s press releases are available for re-publication in full (i.e.: without alteration or substantive modification) without further permission and with proper attribution and/or linkback to MHARR.

MHARR notes that the featured image was generated by artificial intelligence (AI) powered ChatGPT. This MHARR report was written using industry-expert human intelligence. 

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