Appliance Standards and Rulemaking Federal Advisory Committee

Manufactured Housing Working Group

Term Sheet

October 2, 2014

Background

On June 13, 2014, DOE issued a Notice of Intent to establish a negotiated rulemaking working 

group under the Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC) in 

accordance with the Federal Advisory Committee Act (FACA) and the Negotiated Rulemaking 

Act (NRA) to negotiate proposed Federal standards for the energy efficiency of manufactured 

homes. The purpose of the working group will be to discuss and, if possible, reach consensus on 

a proposed rule for the energy efficiency of manufactured homes, as authorized by section 413 of 

the Energy Independence and Security Act of 2007 (EISA). The working group will consist of 

representatives of parties having a defined stake in the outcome of the proposed standards, and 

will consult as appropriate with a range of experts on technical issues. 79 FR 33873.

The working group consisted of 22 members, including one member from ASRAC and one DOE 

representative (see Appendix A).The working group met in-person during 5 sets of meetings held 

August 4-5, 2014, August 21-22, September 9-10, September 22-23 and October 1-2. The 

working group successfully reached consensus on proposed energy conservation standards for 

manufactured housing. This document includes the working group’s recommendations to 

ASRAC on new energy efficiency standards for manufactured housing. 

Scope

The purpose of the working group will be to discuss and, if possible, reach consensus on a 

proposed rule for the energy efficiency of manufactured homes, as authorized by section 413 of 

the Energy Independence and Security Act of 2007 (EISA). The working group shall complete 

work on the term sheet for a proposed rule by September 30, 2014, or either cease activities of 

the working group or request an extension, with date certain, from ASRAC.

Definitions 

(...if needed, such as what terms are needed to stay consistent with HUD that the WG needs to 

maintain through this term sheet, what terms are need to explain the difference in IECC usage vs 

MH usage, and what other terms are unique to this term sheet) 

Recommendation

Vote results

Climate Zones (e.g. use HUD or IECC or other)

Recommendation

Vote results

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Thermal Requirements (Performance, Uo-value, UA, etc)

Recommendation

Vote results

Thermal Requirements (Prescriptive, minimum performance levels for ceilings, walls, 

floors, windows, envelope air-leakage)

Recommendation

Vote results

Performance Requirements (non-thermal, water heating pipe insulation, duct leakage)

Recommendation

Vote results

Other Requirements

Recommendation

Vote results

This term sheet has been approved by the ASRAC manufactured housing working group by 

consensus (votes results on date XX).

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Appendix A: Members

U.S. Department of Energy—ASRAC

Manufactured Housing Negotiated Rulemaking Working Group

DOE and ASRAC Representatives

Joseph Hagerman – Department of Energy 

John Caskey - ASRAC, National Electrical Manufacturers Association

Other Selected Members

Bert Kessler - Palm Harbor Homes, Inc.

David Tompos - NTA, Inc.

Emanuel Levy - Systems Building Research Alliance

Eric Lacey - Responsible Energy Codes Alliance

Ishbel Dickens - National Manufactured Home Owners Association (NMHOA)

Keith Dennis - National Rural Electric Cooperative Association

Lois Starkey - Manufactured Housing Institute

Lowell Ungar - American Council for an Energy-Efficient Economy

Manuel Santana - Cavco Industries

Mark Ezzo - Clayton Homes, Inc.

Mark Weiss - Manufactured Housing Association for Regulatory Reform

Michael Lubliner - Washington State University Extension Energy Program

Michael Wade - Cavalier Home Builders

Peter Schneider - Efficiency Vermont

Richard Hanger - Housing Technology and Standards

Richard Potts - Virginia Department of Housing and Community Development

Rob Luter - Lippert Components, Inc.

Robin Roy - Natural Resources Defense Council

Scott Drake - East Kentucky Power Cooperative

Stacey Epperson - Next Step Network

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