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On September 17, APGA filed comments with the Department of Energy (DOE) regarding data related to certain aspects in developing energy conservation standards for manufactured housing.

APGA emphasized the need for DOE to be very cognizant of the impacts in increasing the costs associated with manufactured housing. APGA agrees with the Department of Housing and Urban Development’s (HUD) concerns over the adverse impacts on manufactured housing affordability that would likely follow if DOE were to adopt the approach laid out in its June 2016 proposal. The June 2016 proposal rule would have imposed a minimum 4.5 percent increase to the home’s initial price. This could be the difference between someone purchasing a new home or an older, less efficient manufactured home.

As noted in the notice of data availability (NODA), the Consumer Financial Protection Bureau’s 2014 “Manufactured-Housing Consumer Finance in the United States,” report states that, “Manufactured housing purchasers face substantial constraints compared to traditional home purchasers. In turn, these constraints may make purchasers of manufactured homes more price sensitive to potential changes that would impact the costs to construct (and purchase) a manufactured home.” By removing a company’s ability to offer their customers construction options, it will only further compound this issue.

For questions on this article, please contact Dan Lapato of APGA staff by phone at 202-464-2742 or by email at dlapato@apga.org.