By Lauren Urbanek, Natural Resources Defense Council
There may be some major changes afoot for the energy efficiency standards for manufactured homes, which house 20 million Americans, but it’s unclear whether they will actually save residents energy and money – and whether “alternative approaches” under consideration by the U.S. Department of Energy (DOE) would even be legal.
The DOE recently issued a request for information, or input, on whether instead of updating the mandatory standard, it should instead use a voluntary labeling program to alert consumers to the more efficient models. NRDC– along with the Energy Efficiency for All Coalition, Prosperity Now, and the Pennsylvania Utility Law Project– filed comments which advocate for the needs of the lower-income residents often served by this housing type.
The energy-saving standards for manufactured homes, which are assembled in factories and then transported to sites, were last updated in 1994 — during President Clinton’s first term.
By way of background, manufactured homes comprise about 6 percent of America’s housing stock and in 2015 (the latest year available), 70,519 manufactured homes were shipped, more than the number of single-family homes built in any state except Texas. Approximately 70 percent of all manufactured homes are located in rural areas, and in some regions they comprise more than 20 percent of the housing stock. Costing considerably less than site-built homes, manufactured homes can serve as affordable options for low- to moderate-income households.
The updated attempt that failed
Given that it had been 13 years since an updated, Congress in 2007 directed the DOE to set energy efficiency standards for manufactured homes, based on the most recent version of the voluntary International Energy Conservation Code (IECC), with a 2011 final rule deadline. After a great deal of work, a diverse committee of stakeholders representing manufacturers, efficiency groups, utilities, states, and others (including NRDC) came to a consensus in 2014 on a standard for manufactured housing that aligned with the 2015 IECC. This proposal was developed into a draft rule, received public comment, and then issued as a notice of proposed rulemaking in June 2016, nearly five years after the legal deadline.
In total, the proposal would have cumulatively cut energy use by up to 29.9 percent from 2017 to 2046, compared to a conventional manufactured home meeting the current standard. It would have saved owners about $4,000 on their energy bills during that period while avoiding about 18.1 million metric tons of carbon dioxide pollution from generating the extra electricity for a less-efficient model.
However, the proposed rule ultimately did not clear the federal government’s Office of Information and Regulatory Affairs (OIRA) process and was withdrawn by DOE on January 31, 2017. That’s all we heard about manufactured housing until a few months ago, when DOE issued a Request for Information. In the RFI, they describe “Alternative Approaches” to a standard, which do not appear to meet the statutory requirement that standards for manufacturing housing be based on the most recent version of the IECC. DOE instead describes options for compliance based on the costof the energy-saving options, not a uniform standard requiring a level of efficiency that will save homeowners money and energy. DOE also describes a labeling system that would provide customers information about the efficiency of a home, but would not provide a required minimum efficiency level.
While the details are extremely vague, a cost-based structure disguised as a “standard” is inherently inequitable. Lower-income families would likely choose the lowest-cost tier, which would result in them paying higher energy bills. Furthermore, this type of “standard” may not be an effective mechanism to move the market and lower construction costs over time, as manufacturers would not need to innovate or use better construction practices that would save energy. Furthermore, scrapping the work already completed on an updated energy efficiency standard and starting over is inexplicable and unnecessary, especially when DOE is already nearly eight years past the original deadline set by Congress.
Lower-income Americans are the ones who will be hurt the most by DOE’s failure to finalize the 2016 rule and the ideas outlined in DOE’s recent RFI. Most manufactured housing serves rural areas. Rural families face the highest energy burden of any household group in America, meaning they spend a higher percentage of their household income on energy bills. And residents living in manufactured housing have an even greater energy burden than the rural median. Manufactured homes unnecessarily waste energy and have fallen far behind traditionally-built homes when it comes to energy efficiency. Residents of manufactured homes have energy bills that are more than double that of the average traditionally-built single-family home, on a cost per square foot basis.
What’s clear is that this ongoing, unexplained lack of productive action by DOE, in spite of explicit direction from Congress more than a decade ago, compounds the issue of the housing affordability. While manufactured homes provide a more affordable purchasing option than a site-built home for many families, the costs to actually live in the home are anything but affordable due to the associated energy costs. Rather than reopening the process and starting from scratch, DOE should finalize its excellent proposal put forth in 2016. The quality of life and comfort of millions of Americans depends on responsible action by DOE.