Public Comment on Energy Conservation Standards for Manufactured Housing

Manufactured homes
by Sofie E. Miller, Senior Policy Analyst
August 16, 2016

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The George Washington University Regulatory Studies Center improves regulatory policy through research, education, and outreach. As part of its mission, the Center conducts careful and independent analyses to assess rulemaking proposals from the perspective of the public interest. This comment on the Department of Energy’s (DOE or the Department) proposed rule establishing new energy efficiency standards for manufactured housing does not represent the views of any particular affected party or special interest, but is designed to evaluate the effect of DOE’s proposal on overall consumer welfare, including effects on low-income and elderly Americans.

Introduction

The Department of Energy’s proposed rule would establish new energy efficiency standards for manufactured housing, formerly known as mobile homes. Although the Department of Housing and Urban Development (HUD) already issues efficiency standards for manufactured housing, the Energy Independence and Security Act of 2007 (EISA) requires DOE to issue its own energy efficiency standards for manufactured housing (MH). The statute requires DOE to issue standards that reflect the practices outlined in the current International Energy Conservation Code (IECC). The 2015 IECC is a consensus-based model code for buildings—including site-built residential homes, commercial buildings, and modular homes—published by the International Code Council.[3]

The IECC does not specifically apply to manufactured housing.[4] DOE is proposing certain modifications to the 2015 IECC to account for the HUD code requirements, dimension limitations, optimization of interior space, and construction techniques that are unique to manufactured homes. In this proposed rule, DOE is establishing energy efficiency standards for manufactured homes that largely comport with the current IECC standards for thermostats and controls, and heating and cooling equipment sizing. DOE is also proposing both prescriptive and performance-based U factors and R-values for single-section and multi-section manufactured homes in four distinct climate zones that represent regions with differing climates throughout the U.S. The standards that DOE proposes would increase the price of manufactured homes in exchange for reduced long-term operating costs, primarily reductions in heating costs.

DOE estimates that the standards will save most manufactured homeowners money, in addition to reducing site emissions of carbon dioxide (CO2), nitric oxide and nitrogen dioxide (NOX), sulfur dioxide (SO2), methane (CH4), and nitrous oxide (N2O). DOE also estimates that, by reducing demand, the standards will reduce upstream emissions from energy production, extraction, processing, and transportation.[5]

This comment makes three distinct points:

  • DOE may be overestimating the benefits of its proposal by disregarding average MH tenant occupancy and resale market obstacles that prevent MH owners from recouping higher upfront costs from increased efficiency. Taking these factors into account suggests that a significant portion of the purchasers of single-section and multi-section manufactured homes will bear net costs instead of benefits.
  • Within Climate Zones 1 and 2, the higher costs of DOE’s proposal are less likely to provide compensating benefits in the form of reduced heating costs. These areas have relatively higher poverty rates, so that distributive impacts are important to consider as DOE finalizes efficiency standards for manufactured homes.
  • DOE should commit to retrospectively reviewing its standard to ensure there is no conflict or overlap with existing HUD regulations and to evaluate the rule’s effects on competition within the MH market and the availability of affordable housing.

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[3]    International Code Council. http://www.iccsafe.org/

[4]    81 FR 39766

[5]    81 FR 39759