Regulatory Submissions

On April 24, APGA submitted comments to the Department of Energy (DOE) supporting its proposal to extend the compliance date for its new energy conservation standards (ECS) for manufactured housing.

Through its comment letter, APGA supported the Manufactured Housing Institute (MHI) in its request for DOE to extend the implementation date of the new ECS.  Not only does the new ECS require fundamental changes to manufactured housing construction and design, but it also sets forth requirements that cannot currently be met by manufacturers.  Furthermore, the lack of testing, compliance, and enforcement provisions will pose significant hurdles to those in the industry if the implementation deadline is not postponed.  Of particular interest to APGA members is how the final ECS will impact consumers’ access to gas-fired HVAC appliances for manufactured housing.

APGA previously submitted a brief comment letter to DOE in response to its proposed ECS for manufactured housing.  While the proposed standards did not directly impact gas use in factory-made homes, they did consider the social cost of greenhouse gases (SC-GHG).  APGA’s letter referenced coalition comments APGA had joined prior that identified several concerns with how the preliminary SC-GHG values were derived and urged DOE to not use these values in any rulemaking moving forward until the concerns had been addressed.