On March 10, MHI and SBRA staff had a meeting with the Project Manager at the Department of Energy (DOE) who has oversight for the development of the proposed energy conservation standards for Manufactured Housing.
DOE is in the process of developing energy conservation standards as required by the Energy Independence and Security Act (EISA) of 2007. Under EISA, DOE is required to establish energy efficiency standards for manufactured housing based on the most recent version of the International Energy Conservation Code (IECC). EISA effectively removed jurisdiction of manufactured housing energy standards from HUD, and put them over at DOE.
MHI staff briefed DOE on the history of the industry, and the challenges and opportunities in the industry today. We emphasized that the new standards should:
- Be performance based providing for the maximum flexibility in design and construction methodology.
- Consider the financial constraints and income levels of the typical manufactured homebuyer who is particularly sensitive to purchase price increases resulting from additional energy conservation measures.
- Consider standards which take into consideration factory production across states lines, and the critical role of the retailer who is at arms length from the design and production process but who interfaces the buyer to choose energy efficient options.
- Consider voluntary energy programs such as Energy Star and current design and software technologies and methodologies used by the industry to provide consumers with energy efficient options.
DOE plans to propose energy conservation standards for manufactured homes in a Notice of Proposed Rulemaking (NOPR) in the next few months. Prior to publishing the proposed rule, DOE will issue a Notice of Public Meeting (NOPM) to discuss the proposed standards. On February 22, it published an Advanced Notice of Proposed Rulemaking (ANPR) asking for information and data to inform its efforts. MHI will submit comments and has been discussing the issue with the technical staff of several manufacturer members. Click here for a copy of the ANPR.
Please direct any comments our questions to Lois Starkey at email@example.com.