U.S. Department of Energy (DOE) Publishes Final Environmental Impact Statement About Proposed Manufactured Home Energy Standards

Source: MHI (Manufactured Housing Institute) – The Department of Energy (DOE) has published its final Environmental Statement (EIS) which analyzes the potential environmental impacts associated with the DOE’s proposed rulemaking about manufactured housing energy efficiency standards. MHI has been engaging heavily with the White House, Department of Energy, HUD, and Congress about the DOE proposal.

The publication of the EIS is NOT the final energy standard for manufactured homes. That rule is expected next month. The EIS provides insight into what the final rule will contain and the impact of our efforts to make the final rule feasible. It appears that DOE has heard the industry concerns around the costs and feasibility of certain insulation requirements, and is providing some flexibility in that area. While DOE is still relying heavily on the IECC 2021 standard, the EIS reports that they have modified aspects of their rule to account “for the unique physical characteristics of manufactured housing.” The EIS also indicates that the DOE has opted for unitiered energy standard (same standards for all homes regardless of size or price).

The EIS still does not contain any information on testing compliance. MHI continues to believe that an accurate cost-benefit analysis cannot be completed without including testing compliance,  and enforcement and thus we reject the EIS’ contention that the rule is cost-effective. Further, the EIS also includes an analysis of the social cost of carbon, despite ongoing court action on the legality of utilizing the social cost of carbon in federal rulemaking. Finally, the EIS does not include details about the implementation of the new rules.

MHI submitted a detailed proposal that achieves the statutory requirements in EISA of property balancing energy efficiency and homeownership affordability. We have shared the industry’s alternative proposal with the Administration and our champions in Congress. We will continue using our voice and influence in Congress, the administration, DOE, and HUD to ensure the energy standards do not harm the industry.

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