The MHI Board of Directors passed a resolution to support amendments to the Energy Independence and Security Act (EISA) of 2007 to require the Department of Energy (DOE) to consider affordability in its new energy standards for manufactured housing and to return enforcement and compliance with the energy standards to HUD.

Under EISA, DOE is required to establish standards for energy efficiency in manufactured housing that are comparable to the most recent version of the International Energy Conservation Code (IECC) for site built homes. DOE is currently in the process of developing proposed energy standards for manufactured homes, and is likely to publish a proposed rule late this year or early in 2011. The new standards will likely increase the costs of new manufactured homes and exclude many potential buyers from the market. It will also put manufactured housing at a competitive disadvantage with the site built housing since site builders will continue to be able to build to lower less stringent energy codes established by states and local jurisdictions.

MHI will ask Congress to amend EISA in order to ensure that affordability is taken into consideration in setting the new energy standards. It will also require HUD, not DOE, to enforce the new standards. As currently written the new standards would result in a dual compliance and enforcement by two federal agencies. The new DOE standards should be regulated by HUD under the same system as the HUD-Code.

MHI’s proposed amendments will require that the new DOE proposed energy standards be subject to review and comment by the Manufactured Housing Consensus Committee (MHCC). Finally, the proposed amendment will require DOE, in setting its proposed standards, to consider the lowest total costs to the purchaser of a manufactured home, and to consider down-payment, financing, resale value and construction as well as energy savings. As currently written, the law will exclude many potential homebuyers from the purchasing a manufactured home because they will not be able to qualify for a loan on the higher priced energy efficient home.

If you are a member and have questions, contact Lois Starkey at lstarkey@mfghome.org.