851 S.W. Sixth Avenue, Suite 1100 Steve Crow 503-222-5161

Portland, Oregon 97204-1348 Executive Director 800-452-5161

www.nwcouncil.org Fax: 503-820-2370

Bruce A. Measure

Chair

Montana

Dick Wallace

Vice-Chair

Washington

Rhonda Whiting

Montana

W. Bill Booth

Idaho

James A. Yost

Idaho

Tom Karier

Washington

Melinda S. Eden

Oregon

Joan M. Dukes

Oregon

March 24, 2010

Ms. Brenda Edwards

US Department of Energy

Building Technologies Program, Mail Stop EE-2J

Energy Efficiency Standards for Manufactured Housing

Reference Docket #: EERE-2009-BT-BC-0021

1000 Independence Avenue, SW

Washington, DC 20585-0121

Comments of the Northwest Power and Conservation Council on the Advanced Notice of 

Proposed Rulemaking Energy Efficiency Standards for Manufactured Housing

Reference Docket #: EERE-2009-BT-BC-0021

March 23, 2010

The Northwest Power Planning Council (Council) is an interstate compact between the states of

Idaho, Montana, Oregon and Washington authorized by the Northwest Electric Power Planning 

and Conservation Act of 1980 (PL96-501).1 The Council’s role is to ensure that the Northwest’s 

electric power system will provide adequate and reliable energy at the lowest economic and 

environmental cost to its citizens. The Congress charged the Council with developing integrated 

electric power plans for the Northwest. These plans are to rely on cost-effective conservation as 

their first priority resource.2The Council appreciates the opportunity to comment on this 

important rulemaking. The Council has the following comments on the Advanced Notice of 

Proposed Rulemaking published in the February 22, 2010 Federal Register.

The Council recommends that the Department of Energy (Department) employ the 

analytical framework it now uses to establish appliance standards under the National 

Appliance Energy Conservation Act (NECA) to derive the efficiency standards for new 

manufactured homes.

The Department has developed a methodological framework that permits it to analyze a wide 

array of potential efficiency improvements across a range of financial input assumptions for use 

in setting appliance efficiency standards under NECA. This framework avoids having to select 

single values for assumptions (e.g., mortgage rate, energy cost, construction cost, etc.) which are 

 

1

16 United States Code Chapter 12H (1994 & Supp. I 1995). Act of Dec. 5, 1980, 94 Stat. 2697. Public Law No. 96-501, S. 885.

2 Northwest Power Act, §4(e)(1), 94 Stat. 2705.
known to vary over a broad range in order to derive either the initial cost of a more efficient 

home or its cost over its complete life cycle. The primary virtue of this framework is that it 

permits decision-makers and stakeholders to assess the “robustness” of any particular standard 

level. In the Council’s judgment, this framework is also applicable to the establishment of 

efficiency standards for new manufactured homes.3

The remainder of our comments directly responds to several of the issues the Department on 

which the Department has specifically requested comment. 

Issue 1 - Differences between site-built and factory-built construction techniques that may justify 

creating unique energy efficiency requirements for manufactured housing that are different from 

the requirements in the 2009 IECC.

Comment - There are no intrinsic differences between site-built and factory-built construction 

techniques that would limit the ability of HUD Code home manufacturers to attain the levels of 

efficiency called for in the 2009 IECC and beyond. HUD Code manufacturing plants in the 

Pacific Northwest have built more than 100,000 manufactured homes that meet or exceed the 

efficiency levels required by the 2009 IECC since 1989. Under the current PNW Energy 

Star/EcoRated Home specifications, manufacturers must meet a performance standard equivalent 

to the reference prescriptive requirements shown in Table 1. The thermal performance 

requirements of this specification meet the 2009 IECC prescriptive standards for the Northwest 

states.

Table 1 - Energy Star/EcoRated Home Specifications

Component Requirement

Ceiling R-40 Flat or vault

Walls R-21

Floor R-33

Windows U- 0.32

Hot Water .93 EF

Duct Testing 6% Floor. Area Total @ 50Pa )

Lighting 50% CFLs

Issue 2 - Specific construction cost data on manufactured home measures affecting energy 

efficiency such as insulation levels including associated construction impacts, fenestration 

 

3 Under the Northwest Electric Power Planning and Conservation Act (Act) the Council is charged with the 

promulgating Model Conservation Standards (MCS) for new residential construction. The MCS must be designed to 

achieve all regionally cost-effective energy savings that are economically feasible for consumers. In order to fulfill 

its obligations under the Act the Council’s uses a methodology identical to that employed by the Department. For a 

more complete description of the Council’s analytical approach and input assumptions, see Appendix G of the 6th

Northwest Power and Conservation Plan. Available at: 

http://www.nwcouncil.org/energy/powerplan/6/final/G_021010.pdf

The analytical model used by the Council to compare the first cost and life cycle cost of alternative energy 

efficiency improvements for new manufactured house is available at: 

http://www.nwcouncil.org/dropbox/MH_LCCModel.zip
(windows, skylights and doors), duct design and insulation, and permanent lighting, specifically 

any information on an increase or decrease in first cost to the home purchaser of designing and 

constructing manufactured homes consistent with the current IECC.

Comment - The Department should solicit cost data from both manufacturers and suppliers and 

adjust these with the appropriate manufacturer-to-dealer-to-consumer markups for overhead and 

profit. Cost data and markup from should assume that the measures are priced as part of the 

“base model” not as “optional upgrades.” Since 1989 when HUD Code manufacturers in the 

Northwest first began building to significantly higher levels of efficiency than called for my the 

HUD standards they have developed approaches to improve both the cost-efficiency and energy 

efficiency of their construction processes and designs. The Department should use cost data from 

these manufactures or others across the country that regularly incorporate advanced levels of 

efficiency in their design and production processes since their costs are more representative of 

the actual long-term cost increases that will be experienced by consumers. 

Cost data for HVAC equipment and appliances should be obtained from firms that supply the

manufactured housing industry. These costs should be compared to those developed by the 

Department through its HVAC and appliance standards rulemaking processes to ensure 

consistency.4

Table 2 below shows the incremental cost to consumers after both manufacturer and retailer 

markup used by the Council in its 6th Northwest Power and Conservation Plan. These are cost 

were collected from surveying manufacturers in the region.

Table 2 - Incremental Cost of New Manufactured Home Residential Space Heating 

Conservation Measures

Conservation Measure Incremental Installed Cost (2006$/sq.ft.)

Wall R19 Standard Framing Base

Wall R21 Standard Framing $0.17

Attic R19 Base

Attic R25 $0.10

Attic R30 $0.10

Attic R38 $0.15

Attic R49 $0.23

Vault R19 Base

Vault R25 $0.10

Vault R30 $0.10

Vault R38 $0.15

Underfloor R22 Base

Underfloor R33 $0.18

Underfloor R44 $0.18

 

4 The Council notes that the Department has rulemakings either near completion or currently underway for water 

heating, dishwashers, clothes washers, dryers, refrigerators, central air conditioners, heat pumps and furnaces. Data 

from these rulemakings should be readily accessible to the development of manufactured home efficiency standards.
Window Class 35 (U<0.35) Base

Window Class 30 (U<0.30) $0.89

Window Class 25 (U<0.25) $2.00

Exterior Door R5 $4.54

Issue 3 - Other economic parameters such as lending scenarios, interest rates, loan duration, 

energy costs, and recommended values and approaches for addressing financial considerations 

and life cycle costs.

Comment - If, as recommended by the Council, the Department employs the analytical 

framework used in its appliance standards rulemakings it should develop a distribution of interest 

rates and loan duration reflective of the share of real and personal property loans so that “chattel” 

loans are represented in proportion to their share of total sales market. Moreover, historical 

trends in the share of real vs. personal property loans should be used to forecast the share of 

these loans in the future. If the share of chattel loans has been declining, the Department should 

recognize this in its analysis. Historical real estate mortgage rate and term data are readily 

available from the Federal Housing Finance Agency.5

Issue 4 - Statistics associated with HVAC system and equipment type, window type, and 

insulation levels, provided in recently built new manufactured homes by state or region.

Comment - The Council recommends that the Department solicit this information from the 

manufactured housing industry. The Council has information on both Energy Star and nonEnergy Star manufactured homes sold in the Northwest.6

Issue 5 - Energy and/or operational cost savings estimates and/or metered data associated with 

different energy options for manufactured housing design and construction.

Comment - The Council recommends that the Department use a simulation model with input 

assumptions that have been calibrated to metered or billing analysis data for space conditioning, 

water heating and lighting (since the IECC requires 50% CFL lighting). The model must be 

capable of simulating changes in thermal integrity as well as HVAC system efficiency 

improvements. It must also be able to deal with the interactive impacts of increased lighting 

efficiency and space conditioning. While the Council uses the SEEM model calibrated to billing 

history and metered data, other models with similar capability could be used. However, in order 

to develop the database needed to implement the analytical framework recommended by the 

Council, the Department must select a model that is capable to creating thousands of alternative 

“efficiency packages” for testing with a reasonable level of effort.

Issue 7 - The manner in which applicable climatic differences should be addressed through a 

singular energy standard addressing manufactured homes.

 

5

http://www.fhfa.gov/Default.aspx?Page=252 

6

See reference 3 above for the link to an Excel spreadsheet containing this data.
Comment - The current HUD code establishes three climate zones for the entire country while 

the IECC sets forth eight zones. The Council recommends that the Department select locations 

in each of the IECC zones that represent their “boundary conditions,” (i.e., locations with TMY 3

weather data files with the minimum and maximum heating and cooling degree-days within each 

zone). To the extent practicable, these locations should also be representative of the boundary 

conditions of each of the three HUD code climate zones. The Department’s economic analysis 

will then be able to ascertain whether the level of energy efficiency that appears cost-effective 

for manufactured housing differs significantly between locations that fall within the same HUD 

climate zone and those required by the IECC for comparable climates. 

Issue 13 - Suggested sources, studies, and research results of other information considered 

relevant to DOE's effort to establish energy standards for manufactured housing.

Comment - The Council is aware that in all regulatory proceedings of this nature that the benefits 

of proposed increases in energy efficiency must be weighed against the burden placed on 

consumers by the increased first cost of higher efficiency requirements. Specifically, in the case 

of manufactured housing, that higher prices lead to reduced sales. While this is generally the 

case, the Department should note that an analysis of the experience in the Northwest did not 

show that cost increases associated with energy efficiency decreased sales of manufactured 

homes. In fact, the Northwest experience documented in a peer-reviewed paper found that more 

expensive, but more efficient manufactured homes tended to compete better against site built 

homes and gain market share.

7

Thank you for considering our comments on this important rulemaking.

Sincerely,

Tom Eckman

Manager, Conservation Resources

 

7 See, Eckman, Tom How A Midlife Fling with "Trailer Trash" Changed the Market Transformation Strategy for 

Manufactured Housing in the Northwest. ACEEE 2002 Summer Study. American Council for an Energy Efficient 

Economy, Washington, DC. Available at: http://www.nwcouncil.org/dropbox/ACEEEpaper.doc