MHI and Texas Manufactured Housing Association
Take Legal Action to Delay Implementation of DOE’s
“Energy Conservation Standards for Manufactured Housing”
Media Contact: Molly Boyle, (202) 777-3668, email@example.com
Statement from Lesli Gooch, Ph.D., Chief Executive Officer, Manufactured Housing Institute (MHI)
MHI and the Texas Manufactured Housing Association took legal action to delay implementation of the Department of Energy’s (DOE) “Energy Conservation Standards for Manufactured Housing,” which are scheduled to take effect on May 31.
MHI and its members prioritize environmental concerns and energy efficiency standards. The industry’s manufacturers are constantly developing new initiatives and technologies and the controlled environment of the factory-built process creates almost no waste. The vast majority of manufactured homes in production today far exceed the minimum required standards of energy efficiency contained in the HUD Code – the federal building code for manufactured homes.
America is facing an affordable housing crisis and the manufactured housing industry is focused on providing attainable homeownership through high-quality, energy efficient homes. However, the pending DOE Energy Standards will price thousands of Americans, primarily low-income families and minorities, out of the housing market.
DOE set an arbitrary and unrealistic 1-year deadline and the proposed requirements are not ready for implementation on May 31. DOE failed to consult with HUD, and the standards do not align with the HUD code, contain inaccurate cost estimates, do not take current manufactured home construction methods into consideration, and fail to address testing, inspection and certification.
The industry supports the Manufactured Housing Consensus Committee’s proposed updates to the energy efficiency requirements in the HUD Code, and HUD is currently in the process of updating the HUD Code with those recommendations. However, that process will not be completed by the DOE deadline and MHI is asking the court to, at a minimum, delay the Final Rule until HUD has completed their process to ensure DOE standards are aligned with HUD Code regulations.
As we have consistently demonstrated, the industry very much wants to work with DOE and HUD to find a workable and affordable solution but under the current status, we are being forced to possibly halt construction of homes in many regions or manufacture homes that cannot comply with the new DOE standards. With the deadline approximately 100 days away, and continued lack of clarity from DOE, legal action was the only option available.
Filing Documents and Exhibits
Plaintiffs’ Original Complaint Seeking Temporary and Permanent Declaratory and Stay-Injunctive Relief Under the APA
Plaintiffs’ Motion to Stay Agency Action and Request for Expedited Consideration and Hearing
Expert Report – Economic Impact Analysis
Expert Report – Engineering Report
Expert Report – Industry Expert
Manufactured Housing Consensus Committee Proposed Updates to Energy Requirements in HUD Code
MHI Comments to DOE Re: Proposed Energy Standards
TMHA Comments to DOE Re: Proposed Energy Standards
Molly Boyle, (202) 777-3668, firstname.lastname@example.org