Proposed DOE Rule for Manufactured Housing

Since 1976, energy conservation in manufactured housing has been regulated by HUD, but in 2007, the Energy Independence and Security Act directed the U.S. Department of Energy to establish and regulate energy conservation standards for manufactured housing.  This week, the DOE has released a pre-publication outlining their recommendations (you can find the entire pre-publication here).

The DOE’s authority for rulemaking is different than that of the HUD code. This means that EISA has given authority to the DOE to establish conservation standards without referencing the portions of the HUD code that already deal with energy conservation. In light of this, the DOE is seeking to make every effort to ensure that complying with the new DOE standards will not affect a manufacturer’s ability to comply with the HUD code.

One area of importance for manufacturers will be the part dealing with building thermal envelope requirements and Uo values. After careful review and collaboration with a manufactured housing working group, the DOE is proposing to present building thermal envelope requirements in term of Uo values of the entire envelope, to account for space limitations in ceiling assemblies.

These thermal envelope requirements would be based around four climate zones, instead of the three used by HUD or the eight used by IECC.

There are two options for compliance with the building thermal envelope requirements:
• Prescriptive requirements for components of the thermal envelope by R-value or U-factor

• Performance-based approach which requires a maximum Uo in addition to fenestration U-factor and SHGC rules.
These new standards will be part of the Code of Federal Regulations as 10 CFR 460, Subparts A, B and C, and manufacturers will be given a one-year lead time to have the new requirements in place. If you have any questions about the new regulations, or how they will affect you, feel free to contact NTA.