MHI Comments on Department of Energy’s Advanced Notice of Proposed Rulemaking on Energy Conservation Standards for Manufactured Housing

On March 24, MHI submitted comments to the Department of Energy (DOE) Advanced Notice of Proposed Rulemaking (ANOPR) regarding Energy Conservation Standards for Manufactured Housing. Click here to review the comment letter.

In its comments, MHI challenged DOE to develop standards that utilize innovative, state of the art building technologies and materials to create life cycle cost savings for homebuyers and at the same time, keep manufactured housing as an affordable option for a large population of families. MHI urged DOE to keep the standards performance based, and take into consideration the historic success the industry has had in designing and building homes based on engineering practices that consider the entire envelope of the home and which result in maximum cost efficiencies. MHI suggested that DOE’s statutory mandate to utilize the latest version of the International Energy Conservation Code (IECC) would not be compatible with performance based standards used in the manufactured housing industry and using the IECC is inherently inconsistent with the goal of maintaining affordability.

MHI’s comments strongly urged the DOE to give HUD the authority to enforce the energy conservation standards, arguing that a dual enforcement system will cause confusion and increase costs. MHI urged DOE to coordinate closely with HUD, as there are many aspects of the HUD-Code that will be impacted by the new energy conservation standards. MHI also urged HUD to give the industry at least one year to meet the new standards once they are finalized.

For more information, and if you are an MHI member, please contact Lois Starkey at

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