The Department of Energy recently solicited information from experts and other interested parties that will help the agency develop energy efficiency standards for manufactured housing. It could be an interesting process, and perhaps a contentious one.
The DOE’s basic mandate is to comply with a provision (Section 413) of the Energy Independence and Security Act of 2007 that requires adapting the 2009 International Energy Conservation Code to manufactured-housing practices, but doing it in a way that also is compatible with factory-housing rules – known as HUD Code – and that are currently enforced by the Department of Housing and Urban Development.
This balancing act, not surprisingly, is complicated by the concerns of energy efficiency advocates, who see development of the standards as a prime opportunity to address what they say are manufactured housing’s woeful energy efficiency performance, and the concerns of the manufactured-housing industry, which is trying to control costs and revitalize its diminished market.
The DOE requested interested parties’ input in an “Advanced Notice of Proposed Rulemaking,” which it entered in the Federal Register on February 22. The response deadline was March 24.
A chance for transformation
One of the people sending comments to the DOE docket was Lane Burt, a construction engineer and the manager of building-energy policy for the Natural Resources Defense Council. In an NRDC blog post, Burt complained that “a manufactured home can come off the assembly line today and immediately be eligible for weatherization through the Weatherization Assistance Program. That means that the government could immediately be paying to retrofit this home to become more efficient when just months before it could have been done at the factory for pennies on the dollar. I can’t think of a single reason why it is acceptable for new manufactured homes to be weatherization candidates because the code is not up to par.”
Burt also cites a DOE analysis showing that manufactured homes use almost twice as much energy per square foot as site-built single-family homes.
Of course, cost – specifically the purchase price of a manufactured home – also is a principal issue for the Manufactured Housing Institute, an industry trade group.
In its comments to the DOE, the MHI cited a 2007 housing survey showing that the median annual income of a family living in manufactured housing was $28,343, and that 2008 Census Bureau data showed that the average price for a manufactured home was $64,900, excluding land. Financial pressures on manufactured housing’s customer base – which now represents about 14% of the market for new single-family homes, according to the MHI – are now especially severe; not long ago, the industry served about 20% of the market.
Beyond standards that won’t push purchase costs beyond the financial means of the industry’s customers, the MHI also advocates that the standards DOE imposes mesh smoothly with HUD’s supervision program for manufactured housing. Another priority for MHI is that the new standards rely on whole-house performance rather than prescriptive requirements for building components, and that they be compatible with the engineering, design, and material-management software commonly used in the industry.
MHI also recommends that the DOE allow a year after the rules are finalized before requiring compliance. The big issue for the industry, MHI repeated in its comments to DOE, is that the standards don’t push the purchase cost of a manufactured home so high that the likely cost of operating it becomes a moot issue.
The DOE says it will present a Notice of Proposed Rulemaking, containing the proposed standards, later this year, and will then invite public comments and also play host to a public meeting on the proposed rules. It could indeed be interesting.