Transmitted via email and U.S. Mail   

March 14, 2014

Ms. Kathleen B. Hogan

Deputy Assistant Secretary for Energy Efficiency

U.S. Department of Energy

Room 6A‐067, Mail Stop EE‐1

100 Independence Avenue, S.W.

Washington, D.C. 20585

Dear Ms. Hogan:

On behalf of the Manufactured Housing Institute (MHI), the national trade association representing all

sectors of the manufactured housing industry, including manufacturers representing almost eighty

percent of the production, retailers, suppliers, lenders and community owners, I am writing to

respectfully request that Department of Energy (DOE) consider negotiated rulemaking for the

establishment of energy efficiency standards for manufactured housing.  As you know, a draft Notice of

Proposed Rulemaking (NOPR) has been pending at the Office of Management (OMB) since December,

2011.  In June, 2013, DOE published a Request for Information (RFI) seeking additional information

(Docket EERE–2009‐BT‐BC‐0021; RIN 1904–AC11).

DOE has established the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) to

provide advice and recommendations to address, among other thing, “specific issues of concern to DOE

as requested by the Secretary of Energy, the Assistant Secretary for Energy Efficiency and Renewable

Energy (EERE), and the Building Technologies Program Manager.” MHI believes ASRAC is an appropriate

mechanism to engage all stakeholders in a discussion of energy efficiency standards for manufactured

housing and to develop consensus recommendations for long overdue changes to the current energy

standards for manufactured homes.  It is a pragmatic approach that has the potential to achieve a timely

resolution to this issue.   

MHI and its members would be delighted to participate and support such an effort.  We have taken first

steps to achieve consensus on new energy standards by participating with other energy stakeholders in

the development of joint comments to DOE in response to its June RFI. We also strongly support efforts

to engage the Department of Housing and Urban Development (HUD) and the Manufactured Housing

Consensus Committee (MHCC).  The MHCC is the Federal Advisory Committee established to

recommend and consider all changes to the Manufactured Housing Construction Standards and

Regulations.  (42 U.S.C.5401et seq. and 114 Stat.2997 et. seq.).  As you know, HUD has regulatory

authority over the development and enforcement of the Manufactured Housing Construction and Safety

Standards, including energy efficiency standards.  

The ASRAC process would be the pragmatic and efficient  approach to establishing recommendations for

new energy efficiency standards for manufactured housing provided that DOE:

 Uses the process for effective communication and data gathering, and for seeking  general

consensus for key elements of a standard and regulatory framework.  

 Establishes a tight meeting schedule with a minimum of meetings.

 Considers using the draft NOPR and Technical Support Documents for opening discussion.
1655 N Fort Myer Dr. Suite 104 Arlington, VA 22209 Tel: 703.558.0400 Fax: 703.558.0401 

http://www.manufacturedhousing.org info@mfghome.org

 Commits a strong project leader and an ASRAC  subcommittee that is comprised of a balanced

group, who have the time and expertise to  serve in a meaningful capacity;   

 Appoints a strong facilitator to ensure the effective flow of information, and restrict time spent

on repetitive or non‐germane discussion,  and;  

 Provides prompt, effective lab analysis (e.g., running scenarios through their cost‐effectiveness,

national impacts and other models in advance of meetings).

Thank you in advance for your consideration of this request, and we look forward to hearing from you at

your earliest convenience.

Sincerely,

Lois Starkey, Vice President

Regulatory Affairs

CC:  Roland J. Risser, Office of Building Technologies Program