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I write as a professional in the manufactured housing industry to ask you to cosponsor H.R. 7651, "The Manufactured Housing Affordability and Energy Efficiency Act," a bill that would ensure pending Department of Energy (DOE) energy efficiency standards for manufactured homes do not harm manufactured homeownership affordability.
The manufactured housing industry supports energy efficient manufactured homes. In fact, the vast majority of manufactured homes today are well-above the energy efficiency requirements in the manufactured housing construction code, known as the HUD Code. The number of manufactured homes that are Energy Star compliant homes continues to rise, and we recently witnessed the unveiling of a net-zero energy home.
Unfortunately, the Department of Energy has proposed and may soon finalize energy standards for manufactured homes that:
- Raise manufactured home prices and down payments on manufactured homes;
- Impose increased annual costs from these price increases that exceed the annual energy savings; and
- Will result in many prospective manufactured home buyers no longer qualifying for a mortgage loan.
Because the proposed standards do not take into consideration current construction methods and transportation requirements for homes built in a factory and transported to the site, the impact of the proposal is underestimated both with respect to increased costs and overall feasibility. In addition, promulgation and enforcement of these standards, including penalties against manufactured home manufacturers, without consideration of the 20-year-old statutory requirement that the HUD Code is the exclusive federal standard for manufactured housing construction and safety standards, including energy efficiency standards, is a serious problem. HUD should have jurisdiction over implementation and enforcement of all standards around manufactured home construction.
H.R. 7651, the "Manufactured Housing Affordability and Energy Efficiency Act" would address all these serious concerns, through language clarifying that before any new energy standards can take effect or be enforced, the DOE must: (1) engage in effective consultation with HUD, including consideration of affordability metrics, (2) document that the rule is cost-effective through use of such metrics, (3) fully take into consideration manufactured housing construction methods and transportation requirements, and (4) be adopted by HUD as part of the HUD Code, as is required under the 2000 Manufactured Housing Act.
Unless these requirements are met, the new DOE energy standards could significantly undermine the status of manufactured housing as the most affordable option for low- and moderate- income families and seniors.
Therefore, I strongly urge you to cosponsor H.R. 7651, "Manufactured Housing Affordability and Energy Efficiency Act."