What: On April 24, 2025, the Office of Energy Efficiency and Renewable Energy at the Department of Energy (DOE) published a notice of proposed rulemaking (NPRM) to amend the compliance date for its manufactured housing energy conservation standards.
Why: On May 31, 2022, DOE adopted new energy conservation standards for manufactured homes (“May 2022 Final Rule”). Relevant to this NPRM is Subpart B of the May 2022 Final Rule, which establishes new requirements for manufactured homes that relate to climate zones, the building thermal envelope, air sealing, and installation of insulation, based on certain provisions of the 2021 International Energy Conservation Code (“2021 IECC”). Under the May 2022 Final Rule, the requirements under subpart B are based on a tiered approach depending on the number of sections of the manufactured home. Accordingly, two sets of standards are established in subpart B: Tier 1 and Tier 2.
Both Tier 1 and Tier 2 incorporate building thermal envelope measures based on certain thermal envelope components subject to the 2021 IECC. Tier 1 applies these building thermal envelope provisions to single section manufactured homes but only includes components at stringencies that would increase the incremental purchase price. Tier 2 applies these same building thermal envelope provisions to multi-section manufactured homes but at higher stringencies specified for site-built homes. The May 2022 Final Rule imposed a compliance date of May 31, 2023. In a final rule published on May 30, 2023, the DOE amended the compliance date to July 1, 2025, for Tier 2 homes and 60 days after the issuance of enforcement procedures for Tier 1 homes.
Under this NPRM, the DOE is proposing to delay the Tier 2 compliance date to allow the DOE more time to consider the proposed enforcement procedures and to evaluate appropriate next steps that provide clarity for manufacturers and other stakeholders. More specifically, the DOE is proposing to require compliance with the Tier 2 standards beginning 180 days after publication of the DOEs final enforcement procedures. The existing compliance date for Tier 1 homes would remain as 60 days after publication of the DOE’s final enforcement procedures.
Action: Comments must be submitted no later than May 27, 2025.
FEDERAL REGISTER NOTICE(S):
Energy Conservation Program: Energy Conservation Standards for Manufactured Housing
CONTACT:
Shanerika Flemings
EMAIL:
TOPIC(S):
DOE
Is your small business or entity being impacted by a proposed rule? If yes, write a comment letter to the proposing agency.