MHCC Unanimously Adopts Recommendations on DOE’s Manufactured Housing Energy Standards

The Manufactured Housing Consensus Committee (MHCC) met January 27–28 to respond to the U.S. Department of Energy’s (DOE) effort to reconsider its 2022 Energy Conservation Standards for manufactured housing. DOE issued what it calls a “Request for Information,” essentially asking for feedback as the Administration reevaluates the flawed DOE Final Rule and the way DOE conducted its rulemaking and analysis. This review is a significant development for the industry, and the MHCC’s work this week will help shape HUD’s formal response back to DOE.

Throughout the two‑day meeting, MHI’s representatives on the MHCC and MHI’s Technical Activities Committee (TAC) leaders played a critical role, and MHI staff provided extensive information, technical analysis, and comments to support the Committee’s deliberations. Their engagement ensured that the MHCC had the full benefit of the industry’s real‑world experience with energy standards, construction feasibility, costs, consumer impacts, and HUD Code processes.

Despite changes in MHCC membership since 2022, the Committee’s position on DOE’s approach remained consistent and firm. In a unanimous vote, the MHCC adopted recommendations to HUD that clearly convey the industry’s longstanding concerns about DOE’s rule and emphasize HUD’s proper role as the nation’s manufactured housing regulator.

In its general comments to HUD, the MHCC stressed several core principles:

• Energy standards should be updated—but only through HUD’s regulatory process, with full MHCC review, as federal law requires.
• The International Energy Conservation Code (IECC) is not appropriate for manufactured housing, because it is unworkable, unaffordable, and incompatible with the factory‑built construction, transportation, and installation processes unique to the industry.
• DOE’s 2022 Final Rule still contains major analytical, enforcement, and feasibility deficiencies that fail to account for fundamental aspects of manufactured home design and production—areas where HUD and the MHCC have decades of proven expertise.
• Additional regulatory layers, such as separate DOE standards, unnecessarily increase home costs, directly undermining affordability for the very low‑, low‑, and moderate‑income families the industry serves.
• DOE’s process appeared to circumvent or misunderstand the established federal manufactured housing standards system, causing conflicts with the HUD Code and creating requirements that cannot be implemented at scale.

The MHCC’s feedback closely aligned with MHI’s detailed comments submitted to HUD in advance of the meeting. The MHCC relied heavily on MHI’s technical analysis and policy arguments in crafting its responses. Notably—yet again—DOE did not attend the MHCC’s public meeting, leaving critical questions about its understanding of manufactured housing and the HUD Code process unresolved.

MHI extends sincere thanks to our industry members serving on the MHCC, to the TAC leadership, and to all members who helped prepare for the meeting. Their expertise and commitment ensured that the industry’s voice was clearly, consistently, and unanimously reflected in the MHCC’s recommendations. MHI will continue to work with HUD, the MHCC, and policymakers to ensure any future energy standards for manufactured housing are achievable, affordable, and developed through the correct regulatory process.