May 04, 2022
Call to Action - Just Click and Send
THE ISSUE:

Tell Your Representative in Congress to Cosponsor H.R. 7651,
the “Manufactured Housing Affordability and Energy Efficiency Act”

Good afternoon THA Members & Interested Parties!

Representative David Kustoff (R-TN) has introduced a bill to ensure the Department of Energy’s (DOE) pending rule on new manufactured housing energy efficiency standards does not harm manufactured homeownership affordability.
 
Upon introducing the bill, Representative Kustoff said, “The Department of Energy (DOE)'s ill-advised energy efficiency standards for manufactured housing will price thousands of Americans out of the market and ultimately limit homeownership. My bill, The Manufactured Housing Affordability and Energy Efficiency Act, will promote affordable housing and ensure that the DOE’s energy efficiency standards are reasonable and cost-effective.”
 
As proposed, the DOE’s new manufactured home energy requirements are not cost-effective and will hurt the affordability of today’s manufactured homes. Because the proposed standards do not take into consideration current manufactured home construction methods and transportation requirements, the draft standards underestimate price increases and annual mortgage cost increases, as well as the number of potential manufactured homebuyers who will no longer qualify for a mortgage.
 
H.R. 7651, the “Manufactured Housing Affordability and Energy Efficiency Act,” addresses these concerns by requiring that before any new DOE energy standards can become effective or be enforced: (1) DOE must fully consult with HUD, (2) DOE must document that the rule is cost-effective based on the impact of homebuyer price and cost increases (3) the standards must fully take into consideration manufactured housing construction methods and transportation requirements, and (4) the standards must be adopted by HUD as part of the HUD Code.
 
MHI has been extensively engaging with the White House, the Department of Energy, HUD, and Congress about the DOE proposal, and MHI submitted a detailed proposal that achieves the statutory objectives of EISA of properly balancing energy efficiency and homeownership affordability. 

Join the Industry Effort and Act Now!
 
It is critical that your Representative hear from all sectors of the manufactured housing industry about cosponsoring this bill. As this bill was just introduced, please give this action your immediate attention – and send it along to others in your organization and everyone else you know in the industry urging them to do same.
 
To participate in the Call to Action, click the button below and follow the simple steps on MHI's website. The letter to your Representative has already been composed – all you have to do is insert your home address and click submit. 
 
Thank you for your participation in this critical effort!

Marla Y. McAfee
Executive Director
Here is the e-mail language which has been drafted and is pre-loaded on your action screen (accessed by the button above):

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:

  1. Raise manufactured home prices and down payments on manufactured homes;
  2. Impose increased annual costs from these price increases that exceed the annual energy savings; and
  3. 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."