[Federal Register Volume 81, Number 117 (Friday, June 17, 2016)]
[Proposed Rules]
[Pages 39756-39806]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-13547]
[[Page 39755]]
Vol. 81
Friday,
No. 117
June 17, 2016
Part II
Department of Energy
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10 CFR Part 460
Energy Conservation Standards for Manufactured Housing; Proposed Rule
Federal Register / Vol. 81 , No. 117 / Friday, June 17, 2016 /
Proposed Rules
[[Page 39756]]
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DEPARTMENT OF ENERGY
10 CFR Part 460
[Docket No. EERE-2009-BT-BC-0021]
RIN 1904-AC11
Energy Conservation Standards for Manufactured Housing
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking and public meeting.
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SUMMARY: The U.S. Department of Energy (DOE) is publishing a proposed
rule to implement the Energy Independence and Security Act of 2007,
which directs DOE to establish energy conservation standards for
manufactured housing. DOE proposes to establish energy conservation
standards for manufactured housing based on the negotiated consensus
recommendations of the manufactured housing working group (MH working
group). The MH working group's recommendations were based on the 2015
edition of the International Energy Conservation Code (IECC), the
impact of the IECC on the purchase price of manufactured housing, total
lifecycle construction and operating costs, factory design and
construction techniques unique to manufactured housing, and the current
construction and safety standards set forth by U.S. Department of
Housing and Urban Development.
DATES: DOE will accept comments, data, and information regarding this
proposed rule before and after the public meeting, but no later than
August 16, 2016 DOE will hold a public meeting on Wednesday, July 13,
2016 from 9:00 a.m. to 4:00 p.m. in Washington, DC.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 1E-245, 1000 Independence Avenue SW.,
Washington, DC 20585-0121. To attend, please notify Ms. Brenda Edwards
at (202) 586-2945. Please note that foreign nationals visiting DOE
Headquarters are subject to advance security screening procedures. Any
foreign national wishing to participate in the public meeting should
advise DOE as soon as possible by contacting Ms. Brenda Edwards at
(202) 586-2945 to initiate the necessary procedures.
Any comments submitted must identify the notice title, docket
number EERE-2009-BT-BC-0021, and/or the regulatory identifier number
(RIN) 1904-AC11. Comments may be submitted using any of the following
methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: ManufacturedHousing [email protected]. Include docket
number EE-2009-BT-BC-0021 and/or RIN 1904-AC11 in the subject line of
the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Program Mailstop EE-2J, 1000 Independence Avenue SW.,
Washington, DC 20585-0121.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, Suite 600, 950 L'Enfant Plaza
SW., Washington, DC 20024. Telephone: (202) 586-2945.
Due to potential delays in DOE's receipt and processing of mail
sent through the U.S. Postal Service, DOE encourages respondents to
submit electronically to ensure timely receipt.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V of this document
(``Public Participation'').
Docket: The docket is available for review at www.regulations.gov
and includes Federal Register notices, public comments, meeting
transcript summaries, and other supporting documents and materials. All
documents in the docket are listed in the regulations.gov index.
However, not all documents listed in the index may be publicly
available, such as information that is exempt from public disclosure.
A link to the docket Web page can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=97. This Web page contains a link to the docket
for this notice on the regulations.gov site. The regulations.gov Web
page also contains instructions on how to access all documents,
including public comments, in the docket. See section V of the
SUPPLEMENTARY INFORMATION for more information on how to submit
comments for this rulemaking through regulations.gov.
For further information on how to submit or review public comments,
participate in the public meeting, or view hard copies of the docket,
contact Ms. Brenda Edwards, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue SW., Washington, DC 20585-0121; (202) 586-
2945; [email protected].
FOR FURTHER INFORMATION CONTACT: Mr. Joseph Hagerman, U.S. Department
of Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program (EE-2J), 1000 Independence Avenue SW., Washington,
DC, 20585; (202) 586-4549; [email protected].
For information on legal issues presented in this document,
contact: Ms. Kavita Vaidyanathan, U.S. Department of Energy, Forrestal
Building, Office of the General Counsel (GC-33), 1000 Independence
Avenue SW., Washington, DC, 20585; (202) 586-0669;
[email protected].
DOE proposes to incorporate by reference into part 460 the
following industry standards:
(1) Manual J--Residential Load Calculation (8th Edition).
(2) Manual S--Residential Equipment Selection (2nd Edition).
Copies of Manual J and Manual S may be purchased from Air
Conditioning Contractors of America, Inc., (ACCA), 2800 S. Shirlington
Road, Suite 300, Arlington, VA 22206, 703-575-4477, http://www.acca.org/.
(3) Overall U-Values and Heating/Cooling Loads--Manufactured Homes.
Conner C.C., Taylor, Z.T., Pacific Northwest Laboratory, published
February 1, 1992.
You may purchase a copy of Overall U-Values and Heating/Cooling
Loads--Manufactured Homes from http://www.huduser.org/portal/publications/manufhsg/uvalue.html 800-245-2691.
For a further discussion of these standards, see section V.N of
this document.
SUPPLEMENTARY INFORMATION:
I. Synopsis of the Proposed Rule
A. The Proposed Regulations
B. Benefits and Costs to Purchasers of Manufactured Housing
C. Manufacturer Impact
D. Nationwide Impacts
E. Nationwide Environmental Benefits
F. Total Benefits and Costs
II. Introduction
A. Authority
B. Background
1. Current Regulation of Manufactured Housing
2. The International Energy Conservation Code
3. Development of the Proposed Rule
III. Discussion
A. The Basis for the Proposed Standards
B. Proposed Energy Conservation Requirements
1. Subpart A: General
2. Subpart B: Building thermal envelope
3. Subpart C: HVAC, service water heating, and equipment sizing
C. Other 2015 IECC Specifications
1. Section R302
2. Section R303.1
3. Section R401.3
4. Section R402.4
5. Section R403
[[Page 39757]]
6. Section R404
7. Section R405
8. Section R406
9. Chapter 5
10. Chapter 6
D. Crosswalk of Proposed Standards With the HUD Code
E. Compliance and Enforcement
IV. Economic Impacts and Energy Savings
A. Economic Impacts on Individual Purchasers of Manufactured
Homes
B. Manufacturer Impacts
C. Nationwide Impacts
D. Nationwide Environmental Benefits
E. Total Benefits and Costs
V. Regulatory Review
A. Executive Order 12866
B. Executive Order 13563
C. Regulatory Flexibility Act
D. Paperwork Reduction Act
E. National Environmental Policy Act
F. Executive Order 13132
G. Executive Order 12988
H. Unfunded Mandates Reform Act
I. Family and General Government Appropriations Act
J. Executive Order 12630
K. Treasury and General Government Appropriations Act
L. Executive Order 13211
M. Section 32 of the Federal Energy Administration Act of 1974
N. Materials Incorporated by Reference
VI. Public Participation
A. Attendance at Public Meeting
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of Public Meeting
D. Submission of Comments
1. Submitting Comments via Regulations.gov
2. Submitting Comments via Email, Hand Delivery, or Mail.
E. Issues on Which DOE Seeks Comment
VII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
A. The Proposed Regulations
The Energy Independence and Security Act of 2007 (EISA, Pub. L.
110-140) directs the U.S. Department of Energy (DOE) to establish
energy conservation standards for manufactured housing. EISA directs
DOE to base the standards on the most recent version of the
International Energy Conservation Code (IECC) and any supplements to
that document, except where DOE finds that the IECC is not cost-
effective or where a more stringent standard would be more cost-
effective, based on the impact of the IECC on the purchase price of
manufactured housing and on total lifecycle construction and operating
costs. See 42 U.S.C. 17071. In accordance with this statutory
directive, DOE is proposing energy conservation standards for
manufactured housing. These energy conservation standards would be
codified in a new part of the Code of Federal Regulations (CFR) under
10 CFR part 460 subparts A, B, and C.
Subpart A discusses generally the scope of the proposed rule and
provides proposed definitions of key terms. The subpart also would
provide manufacturers with a one-year lead time for compliance such
that the standards would apply to all manufactured homes manufactured
on or after one year following the publication of a final rule.
Subpart B would establish requirements related to climate zones and
the building thermal envelope of manufactured homes. DOE proposes to
base its energy conservation requirements on four climate zones, which
generally follow state borders, with some exceptions. Regarding the
building thermal envelope, DOE proposes two approaches to compliance.
The first is a prescriptive approach that would establish specific
requirements for component and fenestration thermal resistance (R-
value), thermal transmittance (U-factor), and solar heat gain
coefficient (SHGC). The second is a performance-based approach that
would establish a maximum overall thermal transmittance (Uo)
requirement for the building thermal envelope and additional U-factor
and SHGC requirements. Subpart B also would include provisions for
determining U-factor, R-value, SHGC, and Uo. Finally, subpart B would
establish prescriptive requirements for insulation and sealing the
building thermal envelope to limit air leakage.
Subpart C would establish requirements related to duct leakage;
heating, ventilation, and air conditioning (HVAC); service hot water
systems; mechanical ventilation fan efficacy; and heating and cooling
equipment sizing.
B. Benefits and Costs to Purchasers of Manufactured Housing
As explained in greater detail in section IV of this document and
in chapter 9 of the technical support document (TSD) accompanying this
proposed rule, DOE estimates that benefits to manufactured homeowners
in terms of lifecycle cost (LCC) savings and energy cost savings under
the proposed rule would outweigh the potential increase in purchase
price for manufactured homes. As presented in Table I.1, DOE estimates
that the average purchase price of a manufactured home under the
proposed rule would increase as much as $2,423 for a single-section and
$3,745 for a multi-section manufactured home as a result of the
increased construction costs associated with energy conservation
improvements.
Table I.1--National Average Manufactured Housing Purchase Price (and Percentage) Increases Under the Proposed
Rule
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Single-section Multi-section
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($) (%) ($) (%)
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Climate Zone 1.................................. 2,422 5.3 3,748 4.5
Climate Zone 2.................................. 2,348 5.1 3,668 4.4
Climate Zone 3.................................. 2,041 4.5 2,655 3.2
Climate Zone 4.................................. 2,208 4.8 2,877 3.4
National Average................................ 2,226 4.9 3,109 3.7
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As explained in more detail in section IV.A of this document and in
chapter 9 of the TSD, Table I.2 presents the estimated national average
LCC savings and energy savings that a manufactured homeowner would
experience under the proposed rule as compared to a manufactured home
constructed in accordance with the minimum requirements of the existing
HUD Code at 24 CFR part 3282. Table I.2 and Figure I.1 present the
nationwide average simple payback period (purchase price increase
divided by first year energy cost savings) under the proposed rule.
[[Page 39758]]
Table I.2--National Average Per-Home Cost Savings Under the Proposed
Rule
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Single- section Multi- section
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Lifecycle Cost Savings (30- $3,211............. $4,625.
Year Lifetime).
Annual Energy Cost Savings in $345............... $490.
2015 dollars.
Simple Payback................ 7.1 years.......... 6.9 years.
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[GRAPHIC] [TIFF OMITTED] TP17JN16.000
C. Manufacturer Impact
As discussed in more detail in section IV.B of this document and
chapter 12 of the TSD, the industry net present value (INPV) is the sum
of the discounted cash flows to the industry from the announcement year
(2016) through the end of the analysis period (2046). Using a real
discount rate of 9.2 percent, DOE estimates the base case INPV for
manufacturers to be $716.7 million. Under the proposed standards, DOE
expects that the INPV will be reduced by 0.7 to 6.8 percent. Industry
conversion costs are expected to total $1.6 million.
D. Nationwide Impacts
As described in more detail in section IV.C of this document and
chapter 11 of the TSD, DOE's national impact analysis (NIA) projects a
net benefit to the nation as a whole as a result of the proposed rule
in terms of national energy savings (NES) and the net present value
(NPV) of expected total manufactured homeowner costs and savings as
compared with manufactured homes built to the minimum standards
established in the HUD Code. As part of its NIA, DOE has projected the
energy savings, operating cost savings, incremental equipment costs,
and NPV of manufactured homeowner benefits for manufactured homes sold
in a 30-year period from 2017 through 2046. The NIA builds off the LCC
analysis discussed by the MH working group by aggregating results for
all affected shipments over a 30-year period. All NES and percent
energy savings calculations are relative to a no regulatory action
alternative, which would maintain energy conservation requirements at
the levels established in the existing HUD Code.
Table I.3 and Table I.4 illustrate the cumulative NES over the 30-
year analysis period under the proposed rule on a full-fuel-cycle (FFC)
energy savings basis. FFC energy savings apply a factor to account for
losses associated with generation, transmission, and distribution of
electricity, and the energy consumed in extracting, processing, and
transporting or distributing primary fuels. NES differ among the
different climate zones because of varying energy conservation
requirements and varying shipment projections in each climate zone. All
NES and percent energy savings calculations are relative to a no
regulatory action alternative, which would maintain energy conservation
requirements at the levels established in the existing HUD Code.
Table I.3--Cumulative National Energy Savings Including Full-Fuel-Cycle of Manufactured Homes Purchased 2017-
2046 With a 30-Year Lifetime
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Single-section quadrillion
British thermal units (BTUs) Multi-section quadrillion
(quads) BTUs (quads)
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Climate Zone 1...................................... 0.179 0.294
Climate Zone 2...................................... 0.130 0.245
Climate Zone 3...................................... 0.272 0.474
Climate Zone 4...................................... 0.303 0.416
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[[Page 39759]]
Total............................................. 0.884 1.428
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Table I.4--Percentage of Cumulative National Energy Savings Including Full-Fuel-Cycle of Manufactured Homes
Purchased 2017-2046 With a 30-Year Lifetime
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Single-section (%) Multi-section (%)
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Climate Zone 1...................................... 25.3 29.9
Climate Zone 2...................................... 25.4 30.6
Climate Zone 3...................................... 26.0 28.1
Climate Zone 4...................................... 25.4 26.6
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Total............................................. 25.6 28.3
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Table I.5 and I.6 illustrate the NPV of customer benefits over the
30-year analysis period under the proposed rule for a discount rate of
7 percent and 3 percent, respectively. The NPV of customer benefits
differ among the four climate zones because of differing initial costs
and corresponding operating cost savings, as well as differing shipment
projections in each climate zone. Under the proposed rule, all climate
zones have a positive NPV for both discount rates.
Table I.5--Net Present Value of Customer Benefits for Manufactured Homes Purchased 2017-2046 With a 30-Year
Lifetime at a 7% Discount Rate
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Single-section (billion Multi-section (billion
2015$) 2015$)
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Climate Zone 1...................................... 0.19 0.34
Climate Zone 2...................................... 0.16 0.35
Climate Zone 3...................................... 0.39 0.74
Climate Zone 4...................................... 0.52 0.74
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Total............................................. 1.26 2.18
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Table I.6--Net Present Value of Customer Benefits for Manufactured Homes Purchased 2017-2046 With a 30-Year
Lifetime at a 3% Discount Rate
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Single-section (billion Multi-section (billion
2015$) 2015$)
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Climate Zone 1...................................... 0.66 1.16
Climate Zone 2...................................... 0.54 1.10
Climate Zone 3...................................... 1.22 2.26
Climate Zone 4...................................... 1.60 2.24
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Total............................................. 4.03 6.75
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E. Nationwide Environmental Benefits
As discussed in section IV.D of this document and in the NIA
included in chapter 11 of the TSD accompanying this proposed rule,
DOE's analyses indicate that the proposed rule would reduce overall
demand for energy in manufactured homes. The proposed rule also would
produce environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases associated with electricity production.
DOE estimates that 18.1 million metric tons of carbon dioxide emissions
would be avoided through the end of 2030 as a result of the proposed
rule.
Emissions avoided under the proposed rule are related to the energy
savings that would be achieved within manufactured homes. DOE estimates
that, under the proposed rule, 2.3 quadrillion Btu (quads) of FFC
energy would be saved relative to manufactured homes constructed under
the minimum requirements of the HUD Code over a 30-year analysis
period. DOE estimates reductions in emissions of six pollutants
associated with energy savings: Carbon dioxide (CO2),
mercury (Hg), nitric oxide and nitrogen dioxide (NOX),
sulfur dioxide (SO2), methane (CH4), and nitrous
oxide (N2O). These emissions reductions are referred to as
``site'' emissions reductions. Furthermore, DOE estimates reductions in
emissions associated with the production of these fuels (including
extracting, processing, and transporting these fuels to power plants or
manufactured homes). These emissions reductions are referred to as
``upstream''
[[Page 39760]]
emissions reductions. Together, site emissions reductions and upstream
emissions reductions account for the FFC.
Table I.7 lists the emissions reductions under the proposed rule
for both single-section and multi-section manufactured homes.
Table I.7--Emissions Reductions Associated With Electricity Production
for Manufactured Homes Purchased 2017-2046 With a 30-Year Lifetime
------------------------------------------------------------------------
Single-
Pollutant section Multi- section
------------------------------------------------------------------------
Site Emissions Reductions
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CO2 (million metric tons)............... 56.5 91.1
Hg (metric tons)........................ 0.0904 0.146
NOX (thousand metric tons).............. 223 356
SO2 (thousand metric tons).............. 27.6 44.4
CH4 (thousand metric tons).............. 3.78 6.09
N2O (thousand metric tons).............. 0.632 1.02
------------------------------------------------------------------------
Upstream Emissions Reductions
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CO2 (million metric tons)............... 4.01 6.45
Hg (metric tons)........................ 0.000944 0.00153
NOX (thousand metric tons).............. 51.8 83.2
SO2 (thousand metric tons).............. 0.615 0.991
CH4 (thousand metric tons).............. 239 385
N2O (thousand metric tons).............. 0.0294 0.0474
------------------------------------------------------------------------
Total Emissions Reductions
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CO2 (million metric tons)............... 60.5 97.6
Hg (metric tons)........................ 0.0913 0.148
NOX (thousand metric tons).............. 275 439
SO2 (thousand metric tons).............. 28.2 45.4
CH4 (thousand metric tons).............. 243 391
N2O (thousand metric tons).............. 0.661 1.07
------------------------------------------------------------------------
Additionally, DOE has considered the estimated monetary benefits
likely to result from the reduced emissions of CO2 and
NOX that would be expected to result from the proposed rule.
DOE calculated the monetary values for each of these emissions
reductions using the social cost of carbon (SCC) model, which estimates
the monetized damages associated with an incremental increase in carbon
emissions within a given year. The SCC is intended to account for, but
is not limited to, changes in net agricultural productivity, human
health, property damages from increased flood risk, and the value of
ecosystem services.
Table I.8 provides the NPV of monetized emissions benefits from
CO2 and NOX under the proposed rule. DOE
estimates that the monetized benefits from emissions reductions
associated with the proposed rule would be $5,541.5 million ($4,731.4
million in CO2 emissions reductions plus $810.1 million in
NOX emissions reductions) over a 30-year analysis period at
the 3 percent discount rate and the CO2 cost associated with
the average SCC case.
Table I.8--Net Present Value of Monetized Benefits From CO2 and NOX Emissions Reductions Under the Proposed Rule
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Net present value (million
2015$)
Monetary benefits Discount rate -------------------------------
(%) Single-
section Multi- section
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CO2, Average SCC Case *......................................... 5 368.2 593.7
CO2, Average SCC Case *......................................... 3 1,810.9 2,920.5
CO2, Average SCC Case *......................................... 2.5 2,925.0 4,717.3
CO2, 95th Percentile SCC Case *................................. 3 5,581.5 9,001.5
NOX Reduction at $2,755/metric ton *............................ 3 311.5 498.6
7 119.8 191.9
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* The CO2 values represent global monetized values (in 2015$) of the social cost of CO2 emissions reductions for
manufactured homes shipped from 2017-2046 with a 30-year lifetime under several different scenarios of the SCC
model. The ``average SCC case'' refers to average predicted monetary savings as predicted by the SCC model.
The ``95th percentile case'' refers to values calculated using the 95th percentile impacts of the SCC model,
which accounts for greater than expected environmental damages. The value for NOX (in 2015$) is the average of
the low and high values used in DOE's analysis.
[[Page 39761]]
F. Total Benefits and Costs
As explained in greater detail in section IV of this document and
chapter 15 of the TSD, Table I.9 presents the total benefits and costs
to manufactured homeowners associated with the proposed rule, expressed
in terms of annualized values.\1\
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\1\ As stated in this preamble, DOE used a two-step calculation
process to convert the time-series of costs and benefits into
annualized values. First, DOE calculated a present value in 2015,
the year used for discounting the net present value of total
consumer costs and savings, for the time-series of costs and
benefits using discount rates of three and seven percent for all
costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates, as
shown in Table I.8. From the present value, DOE then calculated the
fixed annual payment over a 30-year period, starting in 2017 that
yields the same present value. The fixed annual payment is the
annualized value. Although DOE calculated annualized values, this
does not imply that the time-series of cost and benefits from which
the annualized values were determined would be a steady stream of
payments.
Table I.9--Total Annualized Benefits and Costs to Manufactured Homeowners Under the Proposed Rule
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Monetized (million 2015$/year)
Discount rate (%) -----------------------------------------------------------------------------------
Primary estimate ** Low estimate ** High estimate **
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Benefits *
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Operating (Energy) Cost Savings... 7............................... 516....................... 400....................... 688.
3............................... 843....................... 617....................... 1,191.
CO2, Average SCC Case ***......... 5............................... 63........................ 46........................ 85.
CO2, Average SCC Case ***......... 3............................... 241....................... 176....................... 331.
CO2, Average SCC Case ***......... 2.5............................. 365....................... 266....................... 503.
CO2, 95th Percentile SCC Case ***. 3............................... 744....................... 543....................... 1,022.
NOX Reduction at $2,755/metric ton 7............................... 25........................ 20........................ 32.
***. 3............................... 41........................ 31........................ 56.
Total (Operating Cost Savings, CO2 7 plus CO2 range................ 604 to 1,285.............. 466 to 962................ 805 to 1,742.
Reduction and NOX Reduction). 7............................... 783....................... 596....................... 1,052.
3............................... 1,126..................... 824....................... 1,578.
3 plus CO2 range................ 947 to 1,628.............. 694 to 1,191.............. 1,332 to 2,269.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Incremental Purchase Price 7............................... 220....................... 165....................... 285.
Increase. 3............................... 277....................... 192....................... 378.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits/Costs *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total (Operating Cost Savings, CO2 7 plus CO2 range................ 384 to 1,065.............. 301 to 797................ 520 to 1,457.
Reduction and NOX Reduction, 7............................... 563....................... 431....................... 767.
Minus Incremental Cost Increase
to Homes).
3............................... 849....................... 632....................... 1,200.
3 plus CO2 range................ 670 to 1,351.............. 502 to 999................ 954 to 1,891.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The benefits and costs are calculated for homes shipped in 2017-2046.
** The Primary, Low, and High Estimates utilize forecasts of energy prices from the 2015 AEO Reference case, Low Economic Growth case, and High Economic
Growth case, respectively.
*** The CO2 values represent global monetized values (in 2015$) of the social cost of CO2 emissions reductions over the analysis period under several
different scenarios of the SCC model. The ``average SCC case'' refers to average predicted monetary savings as predicted by the SCC model. The ``95th
percentile case'' refers to values calculated using the 95th percentile impacts of the SCC model, which accounts for greater than expected
environmental damages. The value for NOX (in 2015$) is the average of the low and high values used in DOE's analysis.
II. Introduction
A. Authority
Section 413 of EISA directs DOE to:
Establish standards for energy conservation in manufactured
housing;
Provide notice of and an opportunity for comment on the
proposed standards by manufacturers of manufactured housing and other
interested parties;
Consult with the Secretary of HUD, who may seek further
counsel from the Manufactured Housing Consensus Committee (MHCC); and
Base the energy conservation standards on the most recent
version of the IECC and any supplements to that document, except where
DOE finds that the IECC is not cost effective or where a more stringent
standard would be more cost effective, based on the impact of the IECC
on the purchase price of manufactured housing and on total lifecycle
construction and operating costs.
Section 413 of EISA also provides that DOE may:
Consider the design and factory construction techniques of
manufactured housing;
Base the climate zones under the proposed rule on the
climate zones established by HUD in 24 CFR part 3280 rather than the
climate zones under the IECC; and
Provide for alternative practices that, while not meeting
the specific standards established by DOE, result in net estimated
energy consumption equal to or less than the specific energy
conservation standards as proposed.
DOE is directed to update its standards not later than one year
after any revision to the IECC. Finally, section 413 of EISA authorizes
DOE to impose civil penalties on any manufacturer that violates a
provision of part 460.
B. Background
1. Current Regulation of Manufactured Housing
Section 413 of EISA provides DOE with the authority to regulate
energy conservation in manufactured housing, an area of the building
construction industry traditionally regulated by HUD.
[[Page 39762]]
HUD has regulated the manufactured housing industry since 1976, when it
first promulgated the HUD Code. The purpose of the HUD Code has been to
reduce personal injuries, deaths, property damage, and insurance costs,
and to improve the quality, durability, safety, and affordability of
manufactured homes. See 42 U.S.C. 5401(b).
The HUD Code includes requirements related to the energy
conservation of manufactured homes. Specifically, Subpart F of the HUD
Code, entitled ``Thermal Protection,'' establishes requirements for Uo
of the building thermal envelope. Uo is a measurement of the heat loss
or gain rate through the building thermal envelope of a manufactured
home; therefore, a lower Uo corresponds with a more insulated building
thermal envelope. The HUD Code contains maximum requirements for the
combined Uo value of walls, ceilings, floors, fenestration, and
external ducts within the building thermal envelope for manufactured
homes installed in different climate zones. See 24 CFR 3280.507(a).
The HUD Code also provides an alternate pathway to compliance that
allows manufacturers to construct manufactured homes that meet adjusted
Uo requirements based on the installation of high-efficiency heating
and cooling equipment in the manufactured home. See id. 3280.508(d).
Moreover, Subpart F of the HUD Code establishes requirements to reduce
air leakage through the building thermal envelope. See id. 3280.505.
Subpart H of the HUD Code, entitled ``Heating, Cooling and Fuel
Burning Systems,'' establishes requirements for sealing air supply
ducts and for insulating both air supply and return ducts. See id.
3280.715(a). R-value is the measure of a building component's ability
to resist heat flow (thermal resistance). A higher R-value represents a
greater ability to resist heat flow and generally corresponds with a
thicker level of insulation. The HUD Code contains no requirements for
fenestration SHGC, mechanical system piping insulation, or installation
of insulation.
It is important to note that the statutory authority for DOE's
rulemaking effort is different from the statutory authority underlying
the HUD Code. EISA directs DOE to establish energy conservation
standards for manufactured housing without reference to existing HUD
Code requirements that also address energy conservation. In development
of the proposed regulations, DOE seeks to make every effort to ensure
that compliance with this proposed requirements would not impinge a
manufacturer from complying with the requirements set forth in the HUD
Code.
Additionally, DOE is seeking to avoid any potential redundancy
between the proposed requirements and the HUD Code. Accordingly,
section III.D of this document charts the relationship between the
energy conservation requirements in the HUD Code and the proposed DOE
requirements. Given the level of detail required in analyzing all
aspects of energy conservation contained in both the proposed rule and
the HUD Code, DOE requests comment on any potential inconsistencies
that would result from promulgation of the proposed regulations.
2. The International Energy Conservation Code
The statutory authority for this rulemaking requires DOE to base
its standards on the most recent version of the IECC and any
supplements to that document, except where DOE finds that the IECC is
not cost-effective or where a more stringent standard would be more
cost-effective, based on the impact of the IECC on the purchase price
of manufactured housing and on total lifecycle construction and
operating costs. See 42 U.S.C. 17071. The IECC is a nationally
recognized model code, developed under the auspices of, and published
by, the International Code Council (ICC), which many state and local
governments have adopted in establishing minimum design and
construction requirements for the energy efficiency of residential and
commercial buildings, including site-built residential and modular
homes. The IECC is developed through a consensus process that seeks
input from industry stakeholders and is updated on a rolling basis,
with new editions of the IECC published approximately every three
years. The IECC was first published in 1998, and it has been updated
continuously since that time. The 2015 edition of the IECC (the 2015
IECC) was published in May 2014.
Chapter 4 of the 2015 IECC sets forth specifications for
residential energy efficiency, including specifications for building
thermal envelope energy conservation, thermostats, duct insulation and
sealing, mechanical system piping insulation, circulating hot water
system piping, and mechanical ventilation. Chapter 4 of the 2015 IECC
was developed for residential buildings generally and are not specific
to manufactured housing. To the extent that the HUD Code regulates
similar aspects of energy conservation as the 2015 IECC, the 2015 IECC
is generally considered to be more stringent than the corresponding
requirement in the HUD Code given that many areas of the HUD Code are
not updated as frequently as the IECC.
3. Development of the Proposed Rule
Manufactured housing accounts for approximately six percent of all
homes in the United States.\2\ Because the purchase price of
manufactured homes often is lower than similarly sized site-built
homes, manufactured homes serve as affordable housing options,
particularly for low-income families. Nevertheless, the operational
costs to the homeowner may not be reflected in the purchase price of
the home. Manufactured housing home owners often have higher utility
bills than comparably built site-built and modular homes in part due to
different criteria for energy conservation and variability among
building codes and industry practice.
---------------------------------------------------------------------------
\2\ See U.S. Census Bureau, American Housing Survey 2013--
National Summary Tables.
---------------------------------------------------------------------------
Establishing robust energy conservation requirements for
manufactured homes would result in the dual benefit of substantially
reducing manufactured home energy use and easing the financial burden
on owners of manufactured homes in meeting their monthly utility
expenses. Improved energy conservation standards are expected to
provide nationwide benefits of reducing utility energy production
levels that would in turn reduce greenhouse gas emissions and other air
pollutants.
On February 22, 2010, DOE published an advance notice of proposed
rulemaking (ANOPR) to initiate the process of developing energy
conservation standards for manufactured housing and to solicit
information and data from industry and stakeholders. See 75 FR 7556.
The ANOPR identified thirteen specific issue areas on which DOE sought
additional information. DOE received a total of twelve written comments
in response to the ANOPR, all of which are available for public viewing
at the regulations.gov Web page.\3\
---------------------------------------------------------------------------
\3\ The ANOPR comments can be accessed at: http://www.regulations.gov/#!docketDetail;D=EERE-2009-BT-BC-0021.
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DOE also has consulted with HUD in developing the proposed
requirements and in obtaining input and suggestions that would increase
energy conservation in manufactured housing while maintaining
affordability. In addition to meeting with HUD on multiple occasions,
DOE attended three MHCC
[[Page 39763]]
meetings, where DOE gathered information from MHCC members. DOE also
initiated further discussions with members of the manufactured housing
industry following the issuance of the ANOPR, including the
Manufactured Housing Institute and several of its member manufacturers,
the State of California Department of Housing and Community
Development, the State of Georgia Manufactured Housing Division, three
private sector third-party primary inspection agencies under the HUD
manufactured housing program, and one private sector stakeholder
familiar with manufactured housing. A summary of each meeting is
available at the regulations.gov Web page.
The following section provides a summary of comments DOE received
in response to the ANOPR. Generally, the comments can be grouped into
five main areas: Climate zones; the basis for the proposed standards;
specific building thermal envelope requirements; enforcement of DOE's
proposed energy conservation standards; and the need for, and scope of,
the proposed rule.
Regarding the issue of climate zones, DOE received comments
recommending that DOE define climate zones at the county level,
possibly based on the climate zones established in the IECC or on a
subset of those climate zones to align with the requirements for site-
built homes. Generally, these commenters stated that the IECC climate
zones are recognized and understood by the manufacturing and regulatory
sectors. Conversely, DOE received other comments indicating a
preference for retaining the three climate zones established in the HUD
Code. DOE also received comments suggesting that DOE consider more
refined climate zones in the southern United States, noting the
abundance of manufactured homes sold in that region of the country. As
discussed in section III.B.2.a) of the document, DOE proposes to base
its energy conservation standards on four climate zones. DOE requests
comment on the proposed use of four climate zones relative to adopting
the three HUD climate zones and whether there are any potential impacts
on manufacturing costs, compliance costs, or other impacts, in
particular in Arizona, Texas, Louisiana, Mississippi, Alabama, and
Georgia, where the agency has proposed two different energy efficiency
standards within the same state.
DOE received numerous comments suggesting that DOE base its
proposed energy conservation standards on the IECC rather than on the
energy conservation standards established by HUD. Specifically, one
commenter stated that IECC training and related support services would
be available if DOE based its energy conservation standards on the IECC
that would be absent if DOE used a different basis for the proposed
energy conservation standards. Another commenter suggested that the
proposed energy conservation standards should be at a minimum as
efficient as the requirements contained in the most recent edition of
the IECC or better where lifecycle cost effective. One commenter stated
that the IECC was not intended to apply to manufactured housing and
that DOE should consider altering IECC standards to be compatible with
manufactured housing building processes. However, another commenter
stated that there are no intrinsic differences between site-built and
factory-built construction techniques that would limit DOE from
proposing energy conservation standards to the level set forth in the
most recent edition of the IECC and beyond.
Other commenters discussed specific energy conservation
requirements that should be included in the proposed rule, including
requiring high-efficiency furnaces, boilers, and heat pump heating in
colder climate zones, high-efficiency air conditioners in warmer
climate zones, ENERGY STAR appliances, and improved lighting systems,
where cost-effective. Commenters also requested that DOE consider
requiring R-5 windows, passive solar design, and establishing
provisions to address barriers to future technology. Conversely, one
commenter stated that the HUD Code balances requirements related to
both air leakage and condensation. Other commenters requested that DOE
consider the National Fire Protection Association (NFPA) Standard on
Manufactured Housing in developing its proposed standards and that DOE
also consider certain applicable requirements contained in the
International Residential Code. Another commenter suggested that DOE
develop standards that would allow above-code programs, such as ENERGY
STAR, to build upon the requirements set forth by DOE. DOE also
received several comments that manufactured homes should be as energy
efficient as site-built and modular homes while asserting that DOE's
energy conservation standards be no more stringent than the
requirements for site-built housing. However, it also was suggested
that DOE consider establishing one or more performance tiers above the
minimum DOE energy conservation standards, with associated incentives
for manufacturers, to drive the market for high performance
manufactured housing.
As discussed further in section III.A of this document, DOE
proposes to base its energy conservation standards on the 2015 IECC
while accounting for the potential effects on purchase price, total
lifecycle construction and operating costs, and design and factory
construction techniques unique to manufactured homes.
With respect to the potential effects of the proposed rule on
purchase price and total lifecycle construction and operating costs,
DOE received comments providing specific information that assisted DOE
in its preliminary economic analyses for developing the proposed
requirements. Regarding the issue of home financing, commenters
recommended that DOE's economic analysis on financing assume terms of
loans similar to those for new site-built homes, accompanied by a three
percent discount rate. Other commenters suggested that DOE's economic
analyses assume terms of loans that reflect a mix of real estate and
personal property loans that are reflective of the market share of each
type of loan and that account for historical trends in loans for
manufactured housing. Another commenter suggested that DOE account for
conventional financing rates of five to seven percent and assume full
resale recovery, as recognized by the National Automobile Dealers
Association in appraisal value for ENERGY STAR-labeled manufactured
homes.
It was suggested that DOE account for volume procurement purchasing
prices, collect cost data from manufacturers and major suppliers
provided in manufactured homes by state and region, and use standard
industry mark-ups in conducting its economic analyses. Commenters also
stated that any increase in the purchase price of a manufactured home
could exacerbate the lack of affordable housing. Commenters further
stated that although manufacturers offer manufactured homes that exceed
the energy conservation requirements contained in the HUD Code,
financing the cost of those additional energy features often is an
obstacle to such homes being purchased. Accordingly, it was suggested
that DOE apply the same analytical framework that DOE uses for
developing energy efficiency standards for appliances in developing the
proposed energy conservation standards. Specifically, one commenter
suggested that DOE conduct parametric and statistical modeling analyses
accounting for various factors, including
[[Page 39764]]
single-wide versus multi-wide manufactured homes, differences among
fuel types, duct locations, eliminating various ``trade-offs,'' and
evaluating solar thermal and photovoltaic systems in establishing the
proposed standards.
With respect to design and construction techniques unique to
manufactured homes, DOE received several comments highlighting that the
manufactured housing industry has been producing manufactured homes
that exceed the energy conservation requirements contained in the HUD
Code. One commenter stated that since 1989, over 100,000 manufactured
homes had been built in the Pacific Northwest region of the United
States that have an energy efficiency level that complies with the most
recent version of the IECC. Another commenter provided specific
examples of manufactured homes that exceeded the energy conservation
requirements contained in the HUD Code. Indeed, DOE received comments
stating that 90 percent of manufactured housing builders had adopted
the U.S. Environmental Protection Agency (EPA) ENERGY STAR program for
manufactured housing. Another commenter suggested that DOE utilize
research results and information from the DOE Building America Program
and the Partnership for Advancing Technology in Housing program at HUD
in developing the proposed energy conservation standards and in
determining the costs and benefits of more stringent standards. It was
suggested that DOE also evaluate products such as foam wall sheathing,
innovative roof systems, and solar thermal and photovoltaic systems in
developing the proposed energy conservation standards, and to obtain
information from HVAC equipment manufacturers on available equipment
efficiencies specific to manufactured homes.
With respect to design and construction techniques unique to
manufactured homes, one commenter suggested that DOE adopt the energy
efficiency specifications contained in the IECC unless something unique
about the production of a manufactured home necessitated a different
standard. Another commenter stated that DOE should coordinate with HUD
on the development of the proposed rule and to make recommendations to
HUD on non-energy-related issues for HUD consideration in updating the
HUD Code. Specifically, it was suggested that DOE recognize exterior
height and width limitations of manufactured homes in its proposed
standards. DOE has attempted to address these comments by proposing
thermal performance requirements that are similar to the HUD Code,
while proposing other specific energy conservation requirements that
are based on the requirements set forth in the 2015 edition of the
IECC. DOE also has attempted to address unique aspects of manufactured
homes in the proposed rule that would not be addressed by the proposed
requirements for overall thermal performance.
Regarding specific building thermal envelope requirements, DOE
received a number of comments requesting that DOE retain the thermal
envelope performance approach set forth in the HUD Code, rather than
component prescriptive measures, in order to facilitate application and
use of innovative technology and materials. Another commenter suggested
that DOE consider HUD's U-factor calculation manual in developing the
proposed standards. As discussed in section III.B.2.b) of this
document, DOE proposes to establish thermal envelope requirements as a
function of the overall thermal transmittance of the building thermal
envelope of a manufactured home for consistency with the approach set
forth in the HUD Code. DOE also proposes prescriptive requirements as
an alternative to the Uo requirement.
Regarding compliance with, and enforcement of, DOE's proposed
energy conservation standards, DOE received a range of comments. First,
DOE received comments suggesting that DOE rely on HUD's existing
enforcement system rather than develop a separate DOE system of
enforcement. Specifically, one commenter suggested that DOE consider
using the existing HUD-approved third-party primary inspection agencies
to ensure compliance with both HUD and DOE requirements for
manufactured housing in order to avoid an increase in manufacturer fees
and the creation of a duplicative system of compliance certification.
Another commenter suggested that the HUD label be modified to reflect
compliance with both the HUD and DOE requirements. Secondly, DOE
received a comment that DOE develop a separate compliance certification
system that would be independent of the existing HUD certification
system. In this regard, it was suggested that DOE conduct in-plant and
onsite inspections and audits using the DOE Building America Program
and ENERGY STAR quality assurance protocols. It also was suggested that
DOE's certification system ``complement'' the existing HUD system and
that prospective DOE third-party certifiers receive adequate training
to ensure that inspections would be conducted properly. Another
commenter suggested that DOE rely on the EPA ENERGY STAR verification
and labeling program to ensure compliance with the DOE energy
conservation standards. One commenter suggested that DOE check the
quality of construction while asserting that HUD should enforce
violations of the DOE energy conservation standards. Furthermore, a
commenter suggested that all manufactured homes be labeled using the
DOE EnergySmart Home scale tool to demonstrate compliance with the
proposed energy conservation standards.
Finally, DOE received comments questioning the need for the
development of energy conservation standards, noting the state of the
housing market and the time and cost associated with the process to
develop such requirements. Conversely, DOE received other comments
indicating that more stringent energy conservation requirements are
``urgently needed'' to prevent lost opportunities for energy and
operating cost savings that are not currently being captured. DOE also
was asked to consider adopting various energy efficiency improvements
contained in the 2010 version of NFPA Standard 501. DOE received
further comments indicating that the manufactured housing industry is
in the unique position to meet national energy conservation goals while
preserving home affordability. One commenter stated that increases in
the purchase price of manufactured homes due to energy conservation
improvements could raise issues of affordability without government
subsidies or incentives. Another commenter similarly stated that
raising energy conservation standards too quickly could impact
manufacturers' ability to modify their in-plant production and site-
installation processes and procedures. Other commenters requested that
DOE delay the effective date of any energy conservation requirements
due to current economic conditions in order to give manufacturers
sufficient time to meet the new energy conservation standards. Finally,
commenters urged DOE to consult and collaborate with HUD, EPA, and the
manufactured housing industry in development of the proposed rule. DOE
notes that it is required by statute to set forth energy conservation
standards for manufactured homes, and DOE carefully has considered
comments regarding the scope of the proposed rule in developing the
energy conservation requirements proposed herein.
On June 25, 2013, DOE published a request for information (RFI)
seeking information on indoor air quality,
[[Page 39765]]
financing and related incentives, model systems of enforcement, and
other studies and research relevant to DOE's effort to establish
conservation standards for manufactured housing. (78 FR 37995) With
regard to indoor air quality, one commenter mentioned that reductions
in air leakage can lead to increased formaldehyde concentrations and
noted that increased mechanical ventilation also can increase moisture
infiltration in humid climates, potentially leading to deleterious
impacts such as mold growth. Several other commenters noted that there
have been no reported issues with occupant health in energy efficient
homes that have been sealed tightly to reduce air infiltration.
Moreover, commenters noted that a home that is equipped with proper
mechanical ventilation, such as the mechanical ventilation level
required by the HUD Code, is adequate to ensure indoor air quality. DOE
is preparing the draft EA in parallel with this rulemaking, and it will
be posted to the DOE Web site separately. This draft EA will discuss
the relationship among indoor air quality, air leakage, and occupant
health.
Comments on financing focused on the affordability of manufactured
housing and the potential impacts of the proposed rule on the ability
of purchasers of manufactured homes to qualify for financing.
Commenters noted that increased costs associated with more energy
efficient homes could have a negative impact on affordability in an
industry in which the majority of home purchasers are low-income
individuals and families. DOE has designed the proposed standards to
achieve greater energy conservation in manufactured housing while
accounting for the costs and benefits of the proposed standards on
manufactured homeowners. In this regard, DOE has analyzed the lifecycle
costs to low-income purchasers of manufactured homes (see chapter 9 of
the TSD) and potential changes in manufactured home shipments in
response to changes in purchase price (see chapter 10 of the TSD).
Commenters generally agreed that DOE should integrate a program of
compliance and enforcement into the existing structure utilized by HUD.
Commenters also noted, however, that DOE should maintain a role in
overseeing enforcement of its standards. Although DOE is not
considering compliance and enforcement in this proposed rule, DOE will
consider these comments in a future rulemaking if appropriate.
DOE received other comments and data, including information on the
average term of a manufactured housing loan. Another commenter stated
that DOE should establish requirements that achieve the greatest
possible energy conservation in manufactured housing, as the benefits
of potential energy savings would outweigh potential increased purchase
prices. Another commenter suggested that DOE develop standards that
match the IECC as closely as possible. Finally, a commenter suggested
that DOE abandon its rulemaking effort and begin the process anew while
a set of joint commenters urged DOE to expedite publishing of a
proposed rule. DOE has considered these comments in its analysis and
the development of this proposed rule.
After reviewing the comments received in response both to the ANOPR
and to the June 2013 RFI and other stakeholder input, DOE ultimately
determined that development of proposed manufactured housing energy
conservation standards would benefit from a negotiated rulemaking
process. On June 13, 2014, DOE published a notice of intent to
establish a negotiated rulemaking MH working group to discuss and, if
possible, reach consensus on a proposed rule. See 79 FR 33873. On July
16, 2014, the MH working group was established under ASRAC in
accordance with the Federal Advisory Committee Act and the Negotiated
Rulemaking Act. See 79 FR 41456; 5 U.S.C. 561-70, App. 2. The MH
working group consisted of representatives of interested stakeholders
with a directive to consult, as appropriate, with a range of external
experts on technical issues in development of a term sheet with
recommendations on the proposed rule. The MH working group consisted of
22 members, including one member from ASRAC and one DOE representative.
The MH working group met in person during six sets of public meetings
held in 2014 on August 4-5, August 21-22, September 9-10, September 22-
23, October 1-2, and October 23-24. See 79 FR 48097; 79 FR 59154.
On October 31, 2014, the MH working group reached consensus on
energy conservation standards in manufactured housing and assembled its
recommendations for DOE into a term sheet that was presented to ASRAC.
See public docket EERE-2009-BT-BC-0021-0107 (Term Sheet). ASRAC
approved the term sheet during an open meeting on December 1, 2014, and
sent it to the Secretary of Energy to develop a proposed rule.
On February 11, 2015, DOE published an RFI (the 2015 RFI)
requesting information that would aid in its determination of proposed
SHGC requirements for certain climate zones. (80 FR 7550) One commenter
indicated that DOE's negotiated rulemaking process was analytically
flawed and made many procedural errors in carrying out the rulemaking
process, including the operation of the MH working group and the
interpretation of the underlying statutory directive on accounting for
cost-effectiveness. This commenter also provided alternative cost data
for use in the cost-benefit analysis. DOE has included a more detailed
discussion of the comments received in response to the request for
information in section III.B of this document.
Following preparation and submission of the term sheet by the MH
working group, DOE engaged in further consultation with HUD regarding
DOE's proposed energy conservation standards. In addition to meeting
with HUD, DOE prepared two presentations to discuss the proposed rule
with the MHCC members, designed to gather information on the
development of the proposed standards.
DOE has considered all information ascertained from HUD, state
agencies, the manufactured housing industry, and the public in
developing the proposed rule. In an attempt to understand how certain
requirements included in DOE's proposed rule would impact other aspects
of the design and construction of manufactured homes, DOE also has
carefully reviewed the HUD Code to ensure that the proposed rule would
avoid unintended conflicts with HUD requirements both related and
unrelated to energy conservation.
The MH working group was established to negotiate energy
conservation standards for manufactured housing and did not address
options for systems of compliance and enforcement. DOE thus has not
included proposed compliance and enforcement provisions in this
document. DOE maintains its authority to address these issues in a
future rulemaking.
DOE also has not included proposed provisions related to waivers or
exception relief that would be available to manufacturers in achieving
compliance with this Part. Regarding waivers, DOE is interested in
receiving information on whether a process is warranted by which a
manufacturer could petition DOE for relief from an individual
requirement. DOE also seeks public input on whether to establish
proposed provisions for exception relief, which would be warranted in
instances in which compliance with the proposed regulations would
result in serious hardship, gross inequity, or unfair distribution of
burdens on the part of a
[[Page 39766]]
manufacturer. DOE may consider including proposed provisions in this
regard in a future rulemaking.
III. Discussion
A. The Basis for the Proposed Standards
EISA requires that DOE establish energy conservation standards for
manufactured housing that are ``based on the most recent version of the
[IECC] . . . , except in cases in which [DOE] finds that the [IECC] is
not cost-effective, or a more stringent standard would be more cost-
effective, based on the impact of the [IECC] on the purchase price and
on total life-cycle construction and operating costs.'' See 42 U.S.C.
17071(b). Given that the 2015 edition of the IECC (the 2015 IECC)
constitutes ``the most recent version of the IECC,'' the MH working
group based its recommendations on the specifications included in the
2015 IECC that are appropriate for manufactured homes, which DOE has
considered in developing the proposed rule.
As noted above, the 2015 IECC applies generally to residential
buildings, including site-built and modular housing, and is not
specific to the manufactured housing industry. Consistent with the
recommendations of the MH working group, DOE proposes standards that
are based on certain specifications included in the 2015 IECC and that
account for the unique aspects of manufactured housing. DOE carefully
considered the following aspects of manufactured housing design and
construction in developing the proposed standards:
Manufactured housing structural requirements contained in
the HUD Code;
External dimensional limitations associated with
transportation restrictions;
The need to optimize interior space within manufactured
homes; and
Factory construction techniques that facilitate sealing
the building thermal envelope to limit air leakage.
Based on these considerations, and consistent with the
recommendations of the MH working group, DOE is proposing certain
requirements that differ from similar provisions contained in the 2015
IECC. These include presenting the building thermal envelope
requirements in terms of Uo of the entire building thermal
envelope, accounting for space limitations in ceiling assemblies when
establishing insulation requirements and other revisions to ensure the
text is applicable to manufactured housing.
Additionally, the MH working group recommended, and DOE considered,
in developing this proposed rule the potential effects on purchase
price and total lifecycle construction and operating costs, design and
factory construction techniques unique to manufactured homes, and the
impacts of reliance on the climate zones established by HUD and as set
forth in the 2015 IECC. A detailed discussion of each of these issues
is contained in chapter 8 of the TSD and sections III.B and III.C of
this document.
The following section discusses in detail the proposed energy
conservation standards as set forth in the proposed rule. Subpart A as
proposed contemplates the scope of the proposed standards, proposed
definitions of key terms, and other commercial standards that would be
incorporated by reference into this part. The subpart also proposes a
compliance date of one year following the publication of the final
rule.
Proposed subpart B would include energy conservation requirements
associated with the building thermal envelope of a manufactured home
according to the climate zone in which the home is located. DOE
proposes to base its building thermal envelope energy conservation
standards on four climate zones, which generally follow state borders
with some exceptions. DOE proposes two options to ensure an appropriate
level of thermal transmittance through the building thermal envelope.
The first approach contemplates prescriptive requirements for
components of the building thermal envelope. The second is a
performance-based approach under which a manufactured home would be
required to achieve a maximum Uo in addition to fenestration
U-factor and SHGC requirements. Subpart B also would establish
prescriptive requirements for insulation and sealing the building
thermal envelope to limit air leakage.
Subpart C would include requirements related to duct leakage; HVAC
thermostats and controls; service water heating; mechanical ventilation
fan efficacy; and equipment sizing.
As noted in this preamble, EISA requires DOE to update its energy
conservation standards for manufactured housing not later than one year
after any revision to the IECC. Pursuant to this statutory direction,
DOE intends to update its energy conservation standards for
manufactured housing, if promulgated, within one year of the
publication of any revision to the 2015 IECC. This proposed rule
invites comments on all DOE proposals and issues presented herein, and
requests comments, data, and other information that would assist DOE in
developing a final rule.
B. Proposed Energy Conservation Requirements
1. Subpart A: General
(a) Sec. 460.1 Scope
Pursuant to section 413 of EISA, Congress directed DOE to establish
standards for energy conservation in manufactured housing. Section
460.1 would restate the statutory requirement and introduce the scope
of the proposed requirements. Section 460.1 also would require
manufactured homes that are manufactured on or after one year following
publication of the final rule to comply with the requirements
established in part 460.
DOE proposes a one-year period following publication of a final
rule to allow manufacturers to transition their designs, materials, and
factory operations and processes to comply with the finalized DOE
energy conservation standards and regulations. A one-year notice period
is common industry practice for amendments to the IECC and other
changes to building codes; however, DOE seeks input on whether these
standards are analogous to IECC or whether they would impose a
different level of manufacturer research and effort to comply. In
addition, DOE seeks comment on whether additional lead time is
necessary to harmonize compliance and enforcement with HUD's
manufactured housing program, redesign manufactured housing to meet the
standards, and test and certify the new designs. The agency also
requests comment on whether there are any particular timing
considerations that the agency should consider due to manufacturers
choosing to comply with either the prescriptive or thermal envelope
compliance paths. DOE requests comment on the scope and effective date
of the proposed rule and whether the proposed effective date would
provide manufacturers sufficient lead time to prepare to comply with
the standards.
(b) Sec. 460.2 Definitions
Section 460.2 would define key terms used throughout the proposed
regulations, many of which were derived from either the 2015 IECC or
the HUD Code, with modifications where further clarification was needed
in the context of manufactured housing. Proposed definitions based on
terms included in the 2015 IECC were developed in accordance with
recommendations from the MH working group. See Term Sheet at 1. DOE has
included a discussion of each of the
[[Page 39767]]
proposed definitions in the following paragraphs.
(a) Accessible. DOE proposes to adopt the definition of the term
``accessible'' from the 2015 IECC while clarifying that the definition
would allow access to certain labels or control interfaces that require
close approach upon inspection or repair.
(b) Air barrier. The term ``air barrier'' also would be based on
the definition of the same term in the 2015 IECC while clarifying that
an air barrier could consist of a single material or combination of
materials. DOE intends for the definition of this term to include the
materials involved in limiting air leakage to meet air sealing
requirements and requests comment on whether further clarification is
needed on the meaning in this regard.
(c) Automatic. DOE proposes to adopt the definition of the term
``automatic'' from the 2015 IECC. The terms ``automatic'' and
``manual'' would differentiate between controls that are operated by
impersonal (automatic) and personal (manual) influences.
(d) Building thermal envelope. DOE has derived the proposed
definition of ``building thermal envelope'' from the definition of the
same term in the 2015 IECC, with revisions that account for the manner
in which manufactured homes are designed and constructed. The proposed
definition does not include basement walls, for example, given the
unique construction of a manufactured home relative to a site-built
home.
(e) Ceiling. DOE proposes to define the term ``ceiling,'' which is
not defined in the 2015 IECC or the HUD Code, to ensure specificity
with the proposed prescriptive standards of part 460.
(f) Circulating hot water system. DOE would define the term
``circulating hot water system'' to be consistent with the 2015 IECC to
describe water distribution systems in a manufactured home that uses a
pump to circulate water between water-heating equipment and fixtures.
(g) Climate zone. DOE proposes to define the term ``climate zone''
in accordance with the term as defined in the 2015 IECC, with revisions
as applicable to the specific geographic regions set forth in the
proposed rule. The proposed rule establishes different energy
conservation standards for manufactured homes located in different
climate zones.
(h) Conditioned space. DOE would adopt the definition of the term
``conditioned space'' from the 2015 IECC to describe areas, rooms, or
spaces that are enclosed within the building envelope.
(i) Continuous air barrier. DOE proposes to adopt the definition of
the term ``continuous air barrier'' from the 2015 IECC to encompass the
material or combination of materials that limit air leakage through the
building thermal envelope.
(j) Door. DOE would define the term ``door,'' which is not defined
in the 2015 IECC or the HUD Code, to ensure specificity with the
proposed prescriptive standards of part 460.
(k) Dropped ceiling. DOE proposes to define the term ``dropped
ceiling,'' which is not defined in the 2015 IECC or the HUD Code, to
ensure specificity with the proposed standards under Sec. Sec.
460.103(a) and 460.104.
(l) Dropped soffit. DOE would define the term ``dropped soffit,''
which also is not defined in the 2015 IECC or the HUD Code, to ensure
specificity with the proposed prescriptive standards under Sec. Sec.
460.104(a) and 460.104.
(m) Duct. DOE proposes to adopt the definition of the term ``duct''
from the 2015 IECC to include tubes or conduits, except air passages
within a self-contained system, used for conveying air to or from
heating, cooling, or venting equipment.
(n) Duct system. DOE proposes to define the term ``duct system'' as
derived from the meaning of the term under the 2015 IECC to refer to a
continuous passageway for the transmission of air, composed of ducts
and other required accessories.
(o) Eave. DOE would define the term ``eave,'' which is not defined
in the 2015 IECC or the HUD Code, to ensure specificity with the
proposed prescriptive standards under Sec. Sec. 460.103(a) and
460.104.
(p) Equipment. DOE proposes to define the term ``equipment,'' which
is not defined in the 2015 IECC or the HUD Code, to add further
clarification to the meaning of the proposed prescriptive provisions of
this part.
(q) Exterior wall. DOE proposes to adopt the definition of the term
``exterior wall'' from the 2015 IECC and describes walls that enclose
conditioned space.
(r) Fenestration. DOE would derive the definition of the term
``fenestration'' from the 2015 IECC, which encompasses both vertical
fenestration and skylights. DOE requests comment on whether to amend
the definition of ``fenestration'' to include tubular daylighting
devices.
(s) Floor. DOE proposes to define the term ``floor,'' which is not
defined in the 2015 IECC or the HUD Code, to ensure specificity with
the proposed prescriptive standards of part 460.
(t) Glazed or glazing. DOE would define the terms ``glazed'' or
``glazing,'' which are not defined in the 2015 IECC or the HUD Code, to
ensure specificity with the proposed prescriptive standards of this
Part and for consistency with the meaning of the terms as used in the
National Fenestration Rating Council Standard 100-2004.
(u) Infiltration. DOE proposes to adopt the definition of the term
``infiltration'' from the 2015 IECC, which describes the uncontrolled
air leakage into a manufactured home.
(v) Insulation. DOE would define the term ``insulation'' to mean
material qualifying as ``insulation'' for consistency with the U.S.
Federal Trade Commission definition of insulation and to ensure
specificity with the proposed standards of part 460.
(w) Manufactured home. DOE proposes to adopt the same definition of
``manufactured home'' as used in the HUD Code in order to ensure
consistency among both agencies' regulations.
(x) Manufacturer. As discussed below, the underlying statutory
authority for this rulemaking does not define the term
``manufacturer.'' DOE proposes to adopt the definition of the term
under the HUD Code to mean any person engaged in the factory
construction or assembly of a manufactured home, including any person
engaged in import of a manufactured home for resale.
(y) Manual. DOE proposes to define the term ``manual'' to be
consistent with the 2015 IECC. As stated in this preamble, the terms
``automatic'' and ``manual'' would differentiate between controls that
are operated by impersonal (automatic) and personal (manual)
influences.
(z) R-value (thermal resistance). DOE would adopt the definition of
the term ``R-value'' from the 2015 IECC to refer to a defined
quantitative measure of the resistance to heat flow of a material or
assembly of materials.
(A) Rough opening. The term ``rough opening,'' which is not defined
in the 2015 IECC or the HUD Code, would identify the location
corresponding to the area of an assembly containing fenestration.
(B) Service hot water. DOE proposes to adopt the definition of the
term ``service hot water'' from the 2015 IECC to refer to the supply of
hot water for uses other than space or comfort heating, such as for
bathing.
(C) Skylight. DOE proposes to define the term ``skylight'' based on
the meaning of the term in the 2015 IECC, clarifying that the term
includes the entire assembly of glass or other transparent or
translucent glazing material and the frame, installed at a slope of
less than 60 degrees from the horizontal.
[[Page 39768]]
(D) Solar heat gain coefficient (SHGC). DOE would adopt the
definition of the term ``solar heat gain coefficient'' from the 2015
IECC. SHGC is an important property of transparent or translucent
fenestration that affects the heat gain and loss of the building
thermal envelope. The SHGC of a fenestration assembly is defined as the
ratio of the amount of solar heat gain transmitted or reradiated
through the assembly to the amount of incident solar radiation.
(E) State. The term ``state'' would include each of the 50 states,
the District of Columbia, the Commonwealth of Puerto Rico, Guam, the
U.S. Virgin Islands, and American Samoa.
(F) Thermostat. DOE proposes to adopt the definition of the term
``thermostat'' from the 2015 IECC to describe automatic control devices
used to maintain a given temperature.
(G) U-factor (thermal transmittance). DOE would adopt the
definition of the term ``U-factor'' from the 2015 IECC to refer to a
defined quantitative measure of the transmittance of heat of a material
or assembly of materials.
(H) Uo (overall thermal transmittance). DOE proposes to define the
term Uo (overall thermal transmittance), which is not defined in the
2015 IECC or HUD Code, as the coefficient of heat transmission (air to
air) through the entire building thermal envelope, equal to the time
rate of heat flow per unit area and unit temperature difference between
the warm side and cold side air films.
(I) Ventilation. DOE proposes to adopt the definition of the term
``ventilation'' from the 2015 IECC to refer to the supply or removal of
air from any space by natural or mechanical means.
(J) Vertical fenestration. DOE would adopt the definition of the
term ``vertical fenestration'' from the 2015 IECC to include materials,
such as windows and doors that may be glazed or opaque, installed at an
angle of greater than or equal to 60 degrees from horizontal.
(K) Wall. DOE proposes to define the term ``wall,'' which is not
defined in the 2015 IECC or the HUD Code, to ensure specificity with
the proposed standards under this Part.
(L) Whole-house mechanical ventilation system. DOE proposes to
adopt the definition of the term ``whole-house mechanical ventilation
system'' from the 2015 IECC to refer to a mechanical system that is
designed to exchange indoor air with outdoor air either periodically or
continuously.
(M) Window. DOE proposes to define the term ``window,'' which is
not defined in the 2015 IECC or the HUD Code, to ensure specificity
with the proposed standards under this part.
(N) Zone. DOE would adopt the definition of the term ``zone'' from
the 2015 IECC to apply to controls within a manufactured home and to
refer to a space or group of spaces within a manufactured home with
sufficiently similar requirements for heating and cooling that can be
maintained using a single controlling device.
DOE would not include certain definitions that are contemplated in
the 2015 IECC, including ``above-grade wall,'' ``addition,''
``alteration,'' ``approved,'' ``approved agency,'' ``basement wall,''
``building,'' ``building site,'' ``C-factor,'' ``code official,''
``commercial building,'' ``conditioned floor area,'' ``continuous
insulation,'' ``curtain wall,'' ``demand recirculation water,''
``DOE,'' ``energy analysis,'' ``energy cost,'' ``energy simulation
tool,'' ``energy rating index (ERI) reference design,'' ``fenestration
product,'' ``site-built,'' ``F-factor,'' ``heated slab,'' ``high-
efficacy lamps,'' ``historic building,'' ``insulating sheathing,''
``insulated siding,'' ``labeled,'' ``listed,'' ``low-voltage
lighting,'' ``proposed design,'' ``rated design,'' ``readily
accessible,'' ``repair,'' ``reroofing,'' ``residential building,''
``roof assembly,'' ``roof recover,'' ``roof repair,'' ``roof
replacement,'' ``standard reference design,'' ``sunroom,'' ``thermal
envelope,'' ``thermal isolation,'' ``ventilation air,'' and ``visible
transmittance.'' These terms are either not relevant to manufactured
housing or not relevant to the energy conservation requirements
proposed in this subpart.
DOE requests comment on each of the proposed definitions and seeks
input on the need for additional clarification to ensure consistency
among the HUD Code and general industry practice.
(c) Sec. 460.3 Materials Incorporated by Reference
DOE proposes to incorporate certain materials by reference in the
proposed rule, including Air Conditioning Contractors of America (ACCA)
Manual J; ACCA Manual S; and ``Overall U-Values and Heating/Cooling
Loads--Manufactured Homes'' by Conner and Taylor (the Battelle Method).
ACCA Manuals J and S would be incorporated by reference in accordance
with Sec. 460.205 of this subpart and would relate to the selection
and sizing of heating and cooling equipment. The Battelle Method is an
industry standard methodology for calculating the overall thermal
transmittance of a manufactured home. The Battelle method currently is
referenced in the HUD Code for calculation of overall thermal
transmittance. To maintain consistency with the practices of the
manufactured home industry, DOE has determined these materials are
appropriate for inclusion in the proposed rule.
2. Subpart B: Building Thermal Envelope
DOE proposes to establish energy conservation standards for
manufactured housing based on the size and geographic location of a
home, as doing so would allow DOE to capture a more accurate balance
between energy conservation and cost-effectiveness in developing its
standards. For example, manufactured homes frequently are identified by
size, including single-section and multi-section homes. Manufactured
homes of varying size are capable of reaching different levels of
energy conservation based on the ratio of floor square footage to
building thermal envelope surface area. A single energy conservation
standard for manufactured homes of all sizes thus would be more
difficult to achieve in a single-section homes as compared to a multi-
section home. Consistent with the recommendations of the MH working
group, DOE proposes to establish different standards for manufactured
homes located in different regions of the country and for manufactured
homes of different size. Subpart B reflects DOE's proposed approach in
this regard, and DOE requests comment in this regard.
(a) Sec. 460.101 Climate Zones
Pursuant to EISA, DOE may consider basing its energy conservation
standards on the climate zones established by HUD rather than on the
climate zones contained in the IECC. See 42 U.S.C. 17071(b)(2)(B). The
potential for climatic differences to affect energy consumption
supports an approach in which energy conservation standards account for
geographic differences in climate. For example, the appropriate level
of insulation for a manufactured home located in southern Florida would
not necessarily be appropriate for a manufactured home located in New
Hampshire.
As indicated in Figure III.1, the HUD Code divides the United
States into three distinct climate zones for the purpose of setting its
building thermal envelope requirements, the boundaries of which are
separated along state lines. Conversely, as indicated in Figure III.2,
section R301.1 of the 2015 IECC divides the country into eight climate
zones, the boundaries of which are separated along county lines. The
2015 IECC also provides requirements for three possible variants (dry,
moist, and marine) within
[[Page 39769]]
certain climate zones, as indicated in Figure III.2. The HUD Code
climate zones were developed to be sensitive to the manner in which the
manufactured housing industry constructed and placed manufactured homes
into the market. The 2015 IECC climate zones are separated along county
lines to reflect a more accurate overview of climate distinctions
within the United States and to facilitate state and local enforcement
of the IECC for residential and commercial buildings, including site-
built and modular construction.
[GRAPHIC] [TIFF OMITTED] TP17JN16.001
The 2015 IECC includes climate zone-specific prescriptive energy
conservation specifications for the building thermal envelope. In
accounting for the design and factory construction techniques for
manufactured homes, the MH working group recommended that DOE perform a
LCC analysis on various cities located in each of the 2015 IECC climate
zones. The MH working group also recommended that DOE incorporate into
[[Page 39770]]
its LCC analysis several alternatives to certain 2015 IECC prescriptive
specifications, including alternative levels of insulation in ceilings,
walls, and floors.
DOE calculated the LCC for various alternatives to the 2015 IECC
prescriptive specifications for 19 cities, representing a
geographically diverse set of climates, with at least one city in each
of the 2015 IECC climate zones. As discussed in greater detail in
section III.B.2.b of this document and chapters 6 and 8 of the TSD,
DOE's LCC analysis demonstrated that common building thermal envelope
requirements for multiple groups of cities proved to be most cost-
effective. After reviewing DOE's LCC analysis, the MH working group
recommended that DOE establish four climate zones that placed cities
with the same set of most-cost-effective building thermal envelope
requirements in the same climate zone. The MH working group found that
a four climate zone approach would improve upon the HUD Code climate
zones with regard to energy conservation by more accurately
distinguishing among regions with similar climates while simultaneously
minimizing the extensive subdivisions of states found in the 2015 IECC.
Consistent with the recommendations of the MH working group \4\ and as
illustrated in Figure III.3, Sec. 460.101 would establish a new
climate zone arrangement that reflects the advantages of both the HUD
Code and the 2015 IECC climate zones. See Term Sheet at 2.
---------------------------------------------------------------------------
\4\ The term sheet named the four climate zones 1A, 1B, 2, and
3. DOE proposes to rename these climate zones as 1 (former climate
zone 1A), 2, (former climate zone 1B), 3 (former climate zone 2),
and 4 (former climate zone 3).
[GRAPHIC] [TIFF OMITTED] TP17JN16.002
If DOE's proposed energy conservation standards adopted the eight
climate zones established in the 2015 IECC, 40 states would be divided
into two or more climate zones. Although the 2015 IECC climate zones
more precisely account for climatic conditions that affect energy use
in the United States, any loss of accuracy in addressing climatic
differences is negligible compared to the impracticality to the
manufactured housing industry of designing and constructing
manufactured homes that comply with eight different sets of climate
zone requirements and planning home shipments based on individual
states with multiple climate zones. A large number of climate zones,
particularly within a state, would burden the manufactured housing
industry because manufacturers are not always certain of the eventual
destination of a home during the manufacturing process. That is,
although some manufactured homes are custom orders where the
destination is known prior to manufacture, many other manufactured
homes are stocked as inventory with manufactured housing dealers. In
particular, manufactured housing dealers and installers in states with
multiple climate zones would encounter increased complexities
associated with ordering, stocking, selling, installing, and servicing
manufactured homes.
Although DOE generally prioritized establishment of a single
climate zone per state where appropriate, the size or varied climate of
certain states necessitated two climate zones in some instances. DOE's
proposed climate zones bifurcate Texas, Louisiana, Alabama,
Mississippi, Georgia, and Arizona. Data indicates that the inland
climate of Texas, Louisiana, Alabama, Mississippi, and Georgia varies
significantly from these states' coastal climates along the borders of
the Gulf of Mexico. Similarly, southwestern Arizona exhibits different
weather patterns from the rest of the state.
DOE requests comment on the proposal to establish four climate
zones as well as input with regard to categorization of states and
counties that comprise each climate zone. To the extent that a
particular approach is advocated, commenters also should provide
analyses and data on the potential impact to the costs and benefits of
the proposed rule. DOE also requests comment on the need for additional
training of state and local building officials who must be familiar
with the requirements of two rather than one climate zone.
[[Page 39771]]
(b) Sec. 460.102 Building Thermal Envelope Requirements
Section 460.102 would establish requirements related to the
building thermal envelope, which includes the materials within a
manufactured home that separate the interior conditioned space from the
exterior of the building or interior spaces that are not conditioned
space. As discussed in this preamble, Sec. 460.102(a) would establish
two approaches to ensure that the building thermal envelope would meet
more stringent energy conservation levels: A prescriptive option and a
maximum Uo option.
In developing recommendations under this section, the MH working
group carefully considered section R402.1 of the 2015 IECC, which sets
forth two primary compliance pathways. First, sections R402.1.2 and
R402.1.4 of the 2015 IECC contain climate zone-specific prescriptive
building thermal envelope component R-value requirements, prescriptive
fenestration U-factor requirements, and prescriptive SHGC requirements.
Second, section R402.1.5 of the 2015 IECC provides an alternate pathway
to compliance, which allows for a home to be constructed using a
variety of materials as long as the entire building thermal envelope
has a singular total UA value \5\ that is less than or equal to the sum
of the component U-factor requirements under section R402.1.4
multiplied by the surface area of the building thermal envelope
components. The first option is referred to as a ``prescriptive-based
approach'' and the second option is referred to as a ``performance-
based approach.''
---------------------------------------------------------------------------
\5\ Total UA is a metric that is very similar to Uo
that typically is used in the context of site-built construction.
Section R402.1.5 of the 2015 IECC uses the metric ``total UA,''
which denotes the sum of each building thermal envelope component's
U-factor multiplied by the assembly area of the component. This
metric is referred to as ``Uo'' in the manufactured
housing industry and serves the same function as ``total UA.''
---------------------------------------------------------------------------
DOE considered developing proposed requirements in line with either
a prescriptive-based approach or a performance-based approach for
specific assemblies that comprise the building thermal envelope.
Ultimately, however, and consistent with the recommendation of the MH
working group, DOE determined that allowing manufacturers to choose
between two pathways for compliance would realize cost-effective energy
savings for homeowners while providing for flexibility within the
manufactured housing industry. See Term Sheet at 3-4.
The prescriptive approach would establish specific component R-
value, U-factor, and SHGC requirements, providing a straightforward
option for construction planning. This pathway would facilitate the
ease of compliance but would restrict manufacturer flexibility in
making trade-offs, such as increasing insulation levels in some
building thermal envelope components while decreasing insulation levels
in other building thermal envelope components.
In contrast, the performance-based approach would allow a
manufactured home to be constructed using a variety of different
materials with varying thermal properties so long as the building
thermal envelope achieved a required level of overall thermal
performance. The performance-based approach thus would provide
manufacturers with greater flexibility in identifying and implementing
cost-effective approaches to building thermal envelope design. The
performance-based approach is familiar to the manufactured housing
industry, as this approach is the basis for the building thermal
envelope requirements under the HUD Code. The proposed performance-
based requirements would be intended to be functionally equivalent to
the prescriptive-based requirements in that both options would result
in manufactured homes with approximately the same amount of energy use.
DOE requests comment on the proposal to set forth prescriptive and
performance options for the purpose of compliance with the proposed
building thermal envelope requirements. In particular, DOE requests
comment on the requirements of each pathway as well as their
equivalency in terms of overall thermal performance.
The proposed prescriptive building thermal envelope requirements
under Sec. 460.102(b) are stated in terms of minimum R-value and
maximum U-factor and SHGC requirements. The MH working group
recommended the prescriptive values set forth in Table III.3 that DOE
has adopted in this rulemaking by assessing and revising the 2015 IECC
specifications to ensure cost-effectiveness based on the impact on the
purchase price of manufactured homes and on total lifecycle
construction and operating costs. See Term Sheet at 3.
Table III.1--Proposed Building Thermal Envelope Prescriptive Requirements
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ceiling R- Window U- Skylight U- Glazed fenestration
Climate zone value Wall R-value Floor R-value factor factor Door U-factor SHGC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1................................ 30 13 13 0.35 0.75 0.40 0.25.
2................................ 30 13 13 0.35 0.75 0.40 0.33.
3................................ 30 21 19 0.35 0.55 0.40 0.33.
4................................ 38 21 30 0.32 0.55 0.40 No Rating.
--------------------------------------------------------------------------------------------------------------------------------------------------------
As discussed in greater detail in chapter 6 of the TSD, DOE
developed the requirements included in Sec. 460.102(b), as illustrated
in Table III.1, by evaluating the cost-effectiveness of the 2015 IECC
building thermal envelope specifications and alternatives to these
specifications. DOE performed LCC analysis for all alternatives to the
2015 IECC specifications that were recommended by the MH working group,
in order to assist in the development of cost-effective standards under
this rule.
The MH working group requested that DOE evaluate variations in the
R-value requirement for ceilings, walls, and floors, and the U-factor
requirement for windows, to determine the impact on cost-effectiveness
relative to the 2015 IECC requirements. Upon analyzing a range of
ceiling insulation requirements from R-22 to R-38, wall insulation
requirements from R-13 to R-21, floor insulation requirements from R-13
to R-38, and window U-factor requirements from 0.40 to 0.31, DOE has
proposed the most cost-effective energy conservation requirement for
each climate zone, as included in Table III.1.
The MH working group also requested that DOE conduct sensitivity
analyses of window SHGC. See Term Sheet at 3. In climate zone 1, DOE
analyzed a range of window SHGC from 0.25 to 0.40. DOE is proposing the
most cost-effective
[[Page 39772]]
SHGC requirement for climate zone 1, as included in Table III.1. In
climate zone 4, the MH working group requested that DOE not run
sensitivity analyses for different SHGC options for most cities found
in climate zone 4. SHGC has a smaller impact on energy use in regions
dominated by heating rather than cooling loads. In these locations,
more stringent SHGC requirements can lead to increased energy
consumption by blocking the solar heating effects of sunlight. For
these reasons, the MH working group proposed to not modify the 2015
IECC specification of no requirement, and DOE is incorporating the 2015
IECC specification of no SHGC requirement for proposed climate zone 4.
Please see chapter 6 of the TSD for additional detail on DOE's SHGC
sensitivity analyses.
The MH working group also recommended that DOE perform a
sensitivity analysis of the total cost of ownership to determine the
most cost-effective SHGC for climate zones 2 and 3. See Term Sheet at
3. DOE recognizes that many variables affecting the selection of
recommended SHGC values were discussed by the MH working group over the
course of multiple public meetings. At the recommendation of the MH
working group, DOE studied the potential economic impacts of several
SHGC values with the intent of proposing prescriptive SHGC requirements
that provide the greatest economic benefit. Economic impact was the
primary decision tool used in proposing prescriptive SHGC values, and
DOE has prepared an economic analysis that supports different SHGC
requirements for climate zones 2 and 3. DOE specifically found that an
SHGC of 0.30 was the most cost-effective SHGC value based on a 10-year
cost of ownership savings calculation. See 80 FR 7550. In arriving at
this value, DOE placed all windows on one side of the manufactured
home, with the windows facing west. DOE used this window orientation in
its sensitivity analysis in order to arrive at SHGC values that would
have the greatest impact on energy savings. DOE sought public input on
this methodology and analysis in the 2015 RFI. See 80 FR 7550.
In response to the 2015 RFI, several commenters stated that factors
other than total cost of ownership should be considered when proposing
a prescriptive SHGC requirement. One commenter suggested that the total
cost of ownership analysis should not be the sole consideration for
choosing the SHGC requirement and that DOE should consider the 2015
IECC SHGC specifications, lifecycle costs, potential impacts on the
purchase price of manufactured housing, air conditioner down-sizing and
cost savings opportunities, reductions in peak electric loads, and
manufacturer benefits in harmonizing SHGC across climate zones. Another
commenter suggested that equipment downsizing, reduction in peak
demand, improved occupant comfort leading to behavioral changes in
adjusting a thermostat, synchronizing with the 2015 IECC, and lifecycle
costs should be considered as a basis for the proposed SHGC
requirements. The commenter also recommended that an SHGC of 0.25 in
climate zones 1, 2, and 3 would be beneficial, as doing so would
establish only two window requirements (SHGC of 0.25 in climate zones
1, 2, and 3; and no SHGC requirement for climate zone 4) and would
simplify and streamline the purchasing of windows for manufacturers of
manufactured homes.
Other commenters noted that placing all windows on one side of a
manufactured home with the assumption that all windows face west was an
atypical assumption. The commenters suggested that window orientation
should follow the same ``industry average'' convention used in all
other assumptions used in DOE's SHGC analysis. The commenters presented
analysis based on their assessment of industry averages to demonstrate
that such assumptions would support an SHGC requirement of 0.33;
however, this analysis included assumptions that differed from those
agreed upon by the MH working group, including window-to-floor area,
window shading, and window cost. The commenters also noted that a group
of windows with a weighted SHGC of 0.30 would require a mixture of
window products of dissimilar aesthetic. Finally, the commenters
believed that the likely industry response to a 0.30 SHGC requirement
would be to assemble manufactured homes with a single window product
SHGC value closer to 0.25. DOE also received a comment that supported
the window orientation that DOE employed in its analysis, recommending
that the analysis properly based SHGC assumptions on window orientation
that would experience the highest energy use.
In response to the aforementioned comments, DOE determined that the
window orientation assumption used in its SHGC analysis was
inconsistent with other analytical assumptions under the proposed rule,
as a more representative SHGC analysis would place windows uniformly on
all sides of a manufactured home. Although the assumption of all
windows facing west represents the highest energy use window
orientation, manufactured homes with other window orientations would
not experience as large an economic benefit. DOE also found no reason
to deviate from the other assumptions in the submitted analysis
(window-to-floor area, window shading, and window cost) that formed the
basis of the MH working group's deliberations and recommendations.
Finally, DOE notes that factors such as lifecycle costs, potential
impacts on the purchase price of manufactured housing are included in
its analysis.
DOE did not include air conditioner down-sizing and cost savings
opportunities in its SHGC analysis. Although in some instances a
manufacturer may be able to install a smaller air conditioner, for
example, leading to reduced energy costs and a lower purchase price,
this is not always possible. DOE did not prioritize peak electric load
reduction over lifecycle cost savings to individual manufactured
homeowners under its analysis. Finally, while equivalent SHGC
requirements across climate zones could simplify window procurement for
manufacturers, DOE notes that manufacturers could elect to use the same
window types for manufactured homes shipped to any climate zone in
accordance with the proposed rule.
DOE repeated its SHGC sensitivity analysis of climate zones 2 and 3
using a uniform window orientation to study the economic impacts of
SHGC values of 0.25, 0.30, and 0.33. This analysis indicated SHGC of
0.33 had the greatest total cost of ownership savings; therefore, DOE
proposes requiring SHGC of 0.33 in climate zones 2 and 3. Because the
sensitivity analysis performed for climate zone 1 during the negotiated
consensus process used the original assumption of uniform window
distribution, this analysis was not repeated for climate zone 1.
For skylight U-factor requirements, the MH working group did not
request that DOE evaluate the effect of variations of the 2015 IECC
requirements on cost-effectiveness. Because there were LCC savings
associated with the 2015 IECC requirements, DOE is proposing to adopt
the 2015 IECC U-factor requirements for skylights into the proposed
rule. This proposal is consistent with the recommendation of the MH
working group. See Term Sheet at 3.
For door U-factor requirements, DOE found that a manufactured home
with a U-factor of 0.40 was cost-effective. Therefore, DOE proposes a
prescriptive door U-factor requirement of 0.40 in all climate zones for
the proposed rule.
[[Page 39773]]
This proposal is consistent with the recommendation of the MH working
group. See Term Sheet at 3.
Section 460.102(b)(2) as proposed would require the truss heel
height to be a minimum of 5.5 inches at the outside face of each
exterior wall for the purpose of compliance with the prescriptive
ceiling insulation R-value requirement established under Sec.
460.102(b)(1). This minimum heel height requirement would ensure that a
minimum space is available in the eaves of the ceiling, allowing for
adequate insulation coverage near the eaves. This proposal is also
consistent with the recommendation of the MH working group. See Term
Sheet at 3.
Section 460.102(b)(3) would authorize manufacturers to install
ceiling insulation with either a uniform thickness or a uniform
density. In many cases, a ceiling may need to be filled with loose
blown insulation to a greater height at the center of the ceiling
relative to the edges near the eaves to meet average overall R-value
requirements. Although uniform insulation thickness is not required
under the proposed standard, the 5.5-inch minimum truss heel height
encourages a minimum insulation thickness at the eaves. This proposal
is also consistent with the recommendations of the MH working group.
See Term Sheet at 3.
Section 460.102(b)(4) would authorize manufacturers to use a
combination of R-21 batt insulation and R-14 blanket insulation in lieu
of R-30 insulation for the purpose of compliance with the climate zone
4 floor insulation R-value requirement under paragraph (b)(1) of this
section. This requirement would reflect industry practice in which
manufactured homes often do not have space in the floor to accommodate
R-30 insulation without compression. DOE thus proposes that R-21 batt
insulation plus R-14 blanket insulation would be deemed compliant with
the R-30 requirement in order to provide a prescriptive alternative for
space-constrained floors. This proposal is also consistent with the
recommendation of the MH working group. See Term Sheet at 3.
Section 460.102(b)(5) would authorize manufacturers to exclude from
the SHGC requirements under Sec. 460.102(a) any individual skylight
with an SHGC that is less than or equal to 0.30. This requirement
effectively would establish an exception for skylights to the SHGC
requirements in climate zone 1, setting forth a maximum skylight SHGC
requirement of 0.30. This exception is set forth in the 2015 IECC in
footnote ``b'' to Table R402.1.2. The MH working group recommended that
DOE retain this requirement, and DOE agrees with including this
exception in the proposed rule. See Term Sheet at 3.
DOE also considered the potential impact of adopting sections
R402.3.3 and R402.3.4 of the 2015 IECC in this rulemaking. Section
R402.3.3 specifies that 15 square feet of glazed fenestration may be
exempt from SHGC and U-factor requirements. DOE proposes not to adopt
this requirement because the prescriptive fenestration SHGC and U-
factor requirements would apply to all fenestration. Given that 15
square feet represents a large portion of the overall fenestration area
that comprises a manufactured home, adoption of this requirement
potentially would exclude from these requirements a significant source
of energy conservation. Section R402.3.4 of the 2015 IECC exempts one
side-hinged opaque door of up to 24 square feet in surface area from
the 2015 IECC U-factor requirements. DOE has not adopted section
R402.3.4 of the 2015 IECC, as excluding these types of doors from this
proposed rulemaking also would represent the loss of a significant
source of home energy conservation.
Section R402.5 of the 2015 IECC specifies maximum U-factor
requirements for sunroom fenestration. Because sunrooms are not
commonly offered in manufactured housing, DOE determined this section
was not applicable to manufactured housing and proposes not to include
sunroom fenestration requirements in this proposed rule.
Section 460.102(b)(6) would establish maximum U-factor values as
alternatives to the minimum R-value requirements established under
Sec. 460.102(a). See Term Sheet at 5. DOE determined each proposed U-
factor alternative by calculating the U-factor corresponding to a
building component (e.g., wall) with typical dimensions and
construction using the insulation material R-value specified in Table
III.1. More detail on establishing the proposed U-factor alternatives
is provided in chapter 7 of the TSD. DOE notes that the proposed U-
factor alternatives are based on a representative single-section
manufactured home, which are an average of 4.2 percent higher than the
corresponding calculations of U-factor alternatives using the
dimensions of a representative multi-section manufactured home.
DOE requests comment on the U-factor alternatives and their
equivalency with the R-value requirements for ceiling, wall, and floor
insulation. Specifically, DOE invites comment on the use of U-factor
alternatives for ceiling insulation based on a conversion calculation
using a representative single-section manufactured home.
Section 460.102(b)(7) would establish a maximum ratio of 12 percent
for glazed fenestration area to floor area. As discussed in further
detail in chapter 7 of the TSD, DOE used this ratio as a typical
housing characteristic in its analyses for determining the prescriptive
requirements. Manufactured homes with window to floor area greater than
12 percent would use more energy (all else held equal), because glazed
fenestration generally has a greater U-factor than other building
components (such as walls). Although this requirement limits the amount
of glazed fenestration in a manufactured home when a manufacturer is
using the prescriptive requirements for compliance with the proposed
rule, a manufacturer may instead follow the performance-based
requirements for compliance if they wish to increase the area of glazed
fenestration (in exchange for increasing the performance of other
building thermal envelope components).
The proposed performance-based requirements under Sec. 460.102(c)
are stated in terms of maximum Uo of the entire building thermal
envelope as a function of climate zone. The Uo requirements proposed in
Sec. 460.102(c) were determined by applying the proposed prescriptive
building thermal envelope requirements under Sec. 460.102(b) to
manufactured homes using typical dimensions and construction techniques
and then calculating the resultant Uo. See chapter 7 of the TSD for
more detailed information on the typical dimensions of manufactured
homes and the Battelle Method for more detailed information on the
calculation of Uo.
As discussed in chapter 7 of the TSD, the proposed maximum Uo for a
multi-section manufactured home was calculated by assuming a 1,568-
square-foot double-section manufactured home. The proposed maximum Uo
for a single-section manufactured home was calculated by assuming a
924-square-foot single-section manufactured home. Both multi- and
single-section home Uo values were calculated assuming manufactured
homes built with wood framing and a window area equal to 12 percent of
the floor area. DOE's proposed approach to determining Uo is consistent
with HUD's approach to determining Uo under the HUD Code (see 24 CFR
3280.507(a)), and is very similar to the ICC's approach to determining
total UA under section R402.1.5 of the 2015 IECC. DOE believes
[[Page 39774]]
that its approach to determining Uo would reduce the compliance burden
on manufacturers by avoiding the need for manufacturers to perform two
separate calculations under both the HUD Code and the DOE requirements.
Section R402.5 of the 2015 IECC includes specifications for maximum
allowable fenestration U-factors when following the performance-based
approach. The 2015 IECC specifies a maximum area-weighted average U-
factor of 0.48 in IECC climate zones 4 and 5 for vertical fenestration,
a maximum area-weighted average U-factor of 0.40 for IECC climate zones
6 through 8 for vertical fenestration, and a maximum area-weighted
average U-factor of 0.75 for skylights in IECC climate zones 4 through
8. Consistent with the recommendations of the MH working group (see
Term Sheet at 1), DOE proposes to adopt these requirements under
Sec. Sec. 460.102(c)(2) and 460.102(c)(3) by limiting area-weighted
vertical fenestration U-factor to 0.48 in climate zone 3, limiting
area-weighted vertical fenestration U-factor to 0.40 in climate zone 4,
and limiting area-weighted skylight U-factor to 0.75 in climate zones 3
and 4. Sections 460.102(c)(2) and 460.102(c)(3) would serve the purpose
of limiting the extent to which window performance can be traded off
for improved performance in other components of a manufactured home and
would prevent areas of a manufactured home that are located in close
proximity to vertical fenestration and skylights from being subject to
excessive rates of heat loss.
Finally, Sec. 460.102(c)(4) would require windows, skylights, and
doors containing more than 50 percent glazing by area to satisfy the
SHGC requirements under Sec. 460.102(a) on the basis of an area-
weighted average and seeks to ensure flexibility among manufacturers
that choose to use unique glazed fenestration products that otherwise
would not meet the SHGC requirement individually. This proposal is also
consistent with the recommendations of the MH working group. See Term
Sheet at 4.
DOE invites comment on proposal to include an area-weighted average
calculation of SHGC for compliance with Sec. 460.102(c). DOE also
requests comment on all other prescriptive and performance requirements
proposed in this section. To the extent that a commenter supports the
proposed requirements or suggests alternative building thermal envelope
criteria, DOE is specifically interested in data and calculations that
would support the commenter's position.
Section 460.102(d) would establish procedures for ensuring
compliance with the prescriptive building thermal envelope standards
under Sec. 460.102(b). As discussed in this preamble, however, the MH
working group did not address options for systems of compliance and
enforcement, and DOE has not included proposed compliance and
enforcement provisions in rule. In the event that DOE addresses
compliance assurance in a future rulemaking, paragraphs (d)(1), (d)(2),
(d)(4), (d)(5), and (d)(7) would be reserved to provide a methodology
for calculating the R-value of insulation; the R-value of non-
insulating materials; fenestration U-factor; the U-factor of walls,
ceilings, and floors; and glazed fenestration SHGC that would provide
for an accurate and repeatable procedure to determine compliance with
the standards proposed under Sec. 460.102(b).
Section 460.102(d)(3) would establish that the total R-value of a
component is the sum of the R-values of each layer of insulation that
compose the component. This proposed requirement is consistent with
section R402.1.3 of the 2015 IECC, which specifies that component
insulation materials installed in layers has a total R-value equal to
the sum of the R-values of each layer.
Sections 460.102(d)(6) and 460.102(d)(8) would authorize
manufacturers to determine U-factor or SHGC for certain fenestration
products and doors in accordance with the prescriptive default values
set forth in Tables 460.102-4, 460.102-5, and 460.102-6. DOE
anticipates that a manufacturer could rely on these prescriptive
default U-factor values to facilitate the ease of compliance with this
proposed rule. DOE has designed proposed Sec. 460.102(d)(6) for
consistency with Tables R303.1.3(1), R303.1.3(2), and R303.1.3(3) of
the 2015 IECC and in accordance with the MH working group's
recommendations. DOE has proposed conservative prescriptive default
values to provide an incentive to manufacturers to determine the actual
performance value of the windows, doors, or skylights installed in a
manufactured home. DOE expects the default tables would be used
primarily in instances in which the actual performance value of a
window, door, or skylight is unavailable or unknown.
Section 460.102(e) would establish procedures for ensuring
compliance with the building thermal envelope Uo standards under Sec.
460.102(c). As discussed in this preamble, the MH working group did not
address options for systems of compliance and enforcement, and DOE has
not included proposed compliance and enforcement provisions in this
proposed rule. In the event that DOE addresses compliance assurance in
a future rulemaking, paragraphs (e)(1)(i), (e)(1)(ii), and (e)(2) would
be reserved to provide a methodology for calculating the R-value of
insulation, the R-value of non-insulating materials, and glazed
fenestration SHGC that would provide for an accurate and repeatable
procedure to determine compliance with the standards proposed under
Sec. 460.102(c).
The MH working group recommended, however, that Uo be determined in
accordance with the ``Battelle Method.'' The Battelle Method is an
industry standard methodology for determining Uo and is commonly
utilized in the manufactured home industry. The Battelle Method's
methodology is based on recommendations in the ASHRAE Handbook of
Fundamentals but provides more specificity to determining Uo for
manufactured housing. The Battelle Method provides a step-by-step
process for calculating Uo by calculating the U-value of each unique
area of the building thermal envelope and by calculating a weighted
average. Both of these references serve as the basis for calculating
overall thermal transmittance under the HUD Code (see 24 CFR 3280.508)
while only the ASHRAE Handbook of Fundamentals is referenced in section
R402.1.5 of the 2015 IECC.
Finally, Sec. 460.102(e)(3) would authorize manufacturers to
determine the SHGC of certain glazed fenestration products in
accordance with the prescriptive default values set forth in Table
460.102-6 for consistency with the rationale accompanying Sec.
460.102(d)(8) of this section. Table 460.102-6 differentiates between
single- and double-pane windows, glazed block windows, as well as clear
and tinted glass. Single- and double-pane windows refer to the number
of panes of glass that are in the window assembly. A single-pane window
consists of one pane of glass while a double-pane window consists of
two panes of glass separated within the window assembly at a fixed
distance. The space between the two panes of glass serves to reduce
heat transfer through the window. A glazed block window refers to a
window assembly that consists of glass blocks that are arranged or laid
out like bricks. These types of windows cannot be opened and are
typically used in ground level or basement floors for security
purposes. The terms ``clear'' and ``tinted'' glass characterize the
light transmission properties of the glass. Clear glass is uncoated and
transparent,
[[Page 39775]]
admitting all light through its body. Tinted glass instead has an
altered chemical composition or surface coating that affects light
transmission and color. Different types of tinted glass block and
reflect different quantities and types of light. Table 460.102-6
provides proposed default SHGC values for these different types of
windows.
(c) Sec. 460.103 Installation of Insulation
Section 460.103(a) would require manufacturers to install
insulation according to both the insulation manufacturer's installation
instructions and the instructions set forth in Table 460.103. DOE
proposes to require manufacturers to comply with the insulation
manufacturer's installation instructions both for consistency with
section R303.2 of the 2015 IECC and to ensure that the intended
performance of the insulation is achieved. Unlike section R303.2 of the
2015 IECC, however, Sec. 460.103 would not require insulation to be
installed in accordance with the International Building Code or the
International Residential Code, as the HUD Code already sets forth
requirements in this regard. DOE also proposes additional insulation
requirements under Sec. 460.103(a) that are based in part on section
R402.4.1.1 of the 2015 IECC, with clarifications to account for the
unique design of manufactured homes, to ensure that insulation is able
to achieve its intended thermal performance.
Table 460.103 would include a general requirement that air-
permeable insulation must not be used as a material to establish the
air barrier. This proposed requirement is consistent with Table
R402.4.1.1 of the 2015 IECC, which the MH working group recommended
that DOE include this in the proposed rule. See Term Sheet at 1. DOE
proposes to adopt this requirement to improve energy conservation in
manufactured housing through the reduction of natural air infiltration
through the building thermal envelope.
Proposed Table 460.103 also includes insulation requirements for
access hatches, panels, and doors between conditioned space and
unconditioned space. Section 460.103(a) would require each access
hatch, panel, and door leading from conditioned space to unconditioned
space to be insulated to a level equivalent to the level of insulation
immediately adjacent to the access hatch, panel, and door. This
requirement would ensure that the thermal performance of the access
hatch, panel, or door would be identical to the surrounding ceiling and
would ensure that the ceiling insulation achieves the same level of
performance as ceiling insulation without an access hatch, panel, or
door. Section 460.103(a) also would require each access hatch, panel,
and door to provide access to all equipment without damaging or
compressing the insulation. Damaging or compressing the insulation
would reduce the performance of the insulation and increase the energy
losses associated with the ceiling. Finally, each access hatch, panel,
and door must be equipped with a wood-framed or equivalent baffle or
retainer when loose fill insulation is installed within a ceiling
assembly to retain the insulation on the access hatch, panel, or door.
That is, an access hatch, panel, or door must use baffles or a retainer
to prevent loose-fill insulation installed within a ceiling assembly
from spilling into the living space upon use of the access hatch,
panel, or door. Each of these requirements have been adopted from
section R402.2.4 of the 2015 IECC are consistent with the
recommendations of the MH working group, and seek to preserve the
performance of insulation within a manufactured home. See Term Sheet at
1.
Section R402.2.4 of the 2015 IECC also includes a specification for
vertical doors that provide access from conditioned to unconditioned
spaces to meet certain fenestration insulation requirements. The MH
working group recommended not adopting this specification in the
proposed rule because vertical doors that separate conditioned and
unconditioned spaces typically are not installed in manufactured homes.
Consistent with the recommendation of the MH working group, DOE
proposes not to include this requirement in this proposed rule. See
Term Sheet at 1.
Proposed Table 460.103 includes requirements for installing
insulation adjacent to baffles. Baffles must be constructed using a
solid material, maintain an opening equal or greater than the size of
the eave vent, and extend over the top of the attic insulation. Baffles
allow for air circulation from the exterior of the manufactured home to
the attic space between the ceiling insulation and the top of the roof.
The installation requirement would ensure proper attic ventilation and
that insulation would not interfere with a baffle's ability to
facilitate air circulation. The proposed requirements would be
consistent with section R402.2.3 of the 2015 IECC and the MH working
group's recommendations, and would help ensure proper ventilation in
attic spaces. See Term Sheet at 1.
Table 460.103 as proposed includes a requirement for installing
insulation in ceilings or attics. Specifically, the requirement states
that insulation installed in any dropped ceiling or dropped soffit must
be aligned with the air barrier. The requirement would ensure that
there would not be excessive air infiltration through the building
thermal envelope if a dropped ceiling or dropped soffit is present in a
manufactured home. This requirement is consistent with Table R402.4.1.1
in the 2015 IECC, and the MH working group recommended that DOE include
this requirement in the proposed rule. See Term Sheet at 1.
To address the unique practice of HVAC duct installation in
manufactured homes, Table 460.103 would require insulation to be
installed to maintain permanent contact with the underside of the rough
floor decking over which the finished floor, flooring material, or
carpet is laid, except where air ducts directly contact the underside
of the rough floor decking. This requirement is generally consistent
with section R402.2.8 of the 2015 IECC, which specifies that floor
insulation be installed in direct contact with the underside of the
subfloor decking. Given that HVAC ducts in manufactured homes generally
are located in the floor space between the insulation and the underside
of the subfloor decking, DOE would require the same floor insulation
requirements as the 2015 IECC while recognizing the need to insulate
around HVAC ducts. DOE requests comment on the proposed floor
insulation requirement and whether it would be consistent with industry
practice.
Table 460.103 as proposed includes an insulation installation
requirement associated with narrow cavities such that batts installed
in narrow cavities must be cut to fit or filled by insulation that upon
installation readily conforms to the available cavity space. This
requirement would ensure that all wall cavities are properly insulated,
even if they have a non-standard width. This type of narrow cavity
could occur in a wall area adjacent to a window frame. This requirement
would be consistent with Table R402.4.1.1 of the 2015 IECC, which the
MH working group recommended that DOE adopt in the proposed rule. See
Term Sheet at 1. DOE proposes to include this requirement in the
proposed rule because it ensures that all cavities are properly
insulated to achieve the expected thermal performance.
Table 460.103 also would require rim joists to be insulated. This
requirement would ensure that the entire floor assembly of a
manufactured home
[[Page 39776]]
achieves the desired thermal performance. The requirement is consistent
with Table R402.4.1.1 of the 2015 IECC, and the MH working group
recommended that DOE include this requirement in the proposed rule. See
Term Sheet at 1.
Table 460.103 includes an insulation installation requirement that
would require exterior walls adjacent to showers and tubs to be
insulated. This proposed requirement is consistent with Table
R402.4.1.1 of the 2015 IECC, which the MH working group recommended
that DOE adopt in the proposed rule. See Term Sheet at 1. DOE proposes
to include this requirement in the proposed rule because it would
ensure that all wall assemblies with showers and tubs would achieve the
expected thermal performance requirements established under Sec.
460.102.
Table 460.103 also would require air permeable exterior building
thermal envelope insulation for framed walls to completely fill the
wall cavity, including cavities within stud bays caused by blocking lay
flats or headers. The requirement clarifies the 2015 IECC requirement
for wall insulation installation found in Table R402.4.1.1. The MH
working group recommended that DOE modify the language of the 2015 IECC
requirement to account for the unique design of manufactured housing.
See 9/23 Working Group Transcript, EERE-2009-BT-BC-0021-0122 at p. 315.
DOE proposes to adopt this requirement, along with the recommended
modifications from the MH working group, to ensure that wall assemblies
in manufactured homes achieve the proposed thermal performance
requirements set forth under Sec. 460.102.
Finally, the 2015 IECC contemplates additional specifications for
insulating areas associated with the building thermal envelope that DOE
has not included in this proposed rule. For example, section R402.1.1
of the 2015 IECC specifies that wall assemblies in the building thermal
envelope comply with the vapor retarder requirements of section R702.7
of the International Residential Code or section 1405.3 of the
International Building Code. DOE has not incorporated this requirement
into this proposed rule, as this specification is a construction
requirement that was not addressed by the MH working group.
Section R402.2.13 of the 2015 IECC establishes sunroom insulation
specifications. Sunrooms typically are not commonly installed in
manufactured homes; accordingly, DOE has not incorporated this
provision of the 2015 IECC into this proposed rule. Similarly, section
R402.2.12 of the 2015 IECC specifies that insulation is not required on
the horizontal portion of the foundation that supports a masonry
veneer. Given that masonry veneers typically are not used in
manufactured homes, DOE has not incorporated this provision of the 2015
IECC into this proposed rule
The 2015 IECC also includes building thermal envelope
specifications for mass walls, steel-framed buildings, walls with
partial structural sheathing, basement and below-grade walls, slab-on
grade construction, and crawl space walls in sections R402.2.5,
R402.2.6, R402.2.7, R402.2.9, R402.2.10, R402.2.11, respectively. DOE
has not included these requirements in the proposed rule because they
are not directly relevant to manufactured housing.
(d) Sec. 460.104 Building Thermal Envelope Air Leakage
Section 460.104 would require manufacturers to seal manufactured
homes against air leakage in order to ensure the conservation of energy
within a manufactured home. Section 460.104 would establish both
general and specific requirements for sealing a manufactured home to
prevent air leakage, all of which are based on Table 402.4.1.1 of the
2015 IECC and related recommendations from the MH working group. See
Term Sheet at 5. Unlike the 2015 IECC, the proposed rule would not
establish maximum building thermal envelope air leakage rate
requirements. The MH working group recommended sealing requirements
that would ensure that a home can be tightly sealed with techniques
that can be visually inspected, thus minimizing the compliance burden
on manufacturers. The MH working group also recommended the adoption of
air leakage sealing requirements designed to achieve an overall air
exchange rate of 5 ACH within a manufactured home. See Term Sheet at 5.
The general requirements in Sec. 460.104 require that
manufacturers properly seal all joints, seams, and penetrations in the
building thermal envelope to establish a continuous air barrier and use
appropriate sealing materials to allow for differential expansion and
contraction of dissimilar materials. These requirements would ensure
that there would not be excessive air infiltration through the building
thermal envelope and that air seals would be durable through seasonal
changes in temperature. Because these requirements would result in
reduced energy use through proper air sealing in a manufactured home,
DOE proposes to adopt the MH working group's recommendations in the
proposed rule. DOE requests comment on the effectiveness of the
proposed prescriptive criteria of Sec. 460.104 for the purpose of
sealing the building thermal envelope to limit air leakage.
Table 460.104 also would include requirements for establishing an
air barrier for specific building components. The proposed requirements
included in Table 460.104 for ceilings or attics, duct system register
boots, recessed lighting, and windows, skylights, and exterior doors
are all consistent with Table R402.4.1.1 of the 2015 IECC. The MH
working group recommended that these 2015 IECC-based requirements also
be included in the proposed rule. See Term Sheet at 1. Because these
specifications reduce energy use by helping to ensure proper
installation of an air barrier for the applicable building components,
DOE proposes to adopt the 2015 IECC specifications as requirements in
the proposed rule.
The requirements of Table 460.104 for walls, floors, and electrical
boxes or phone boxes on exterior walls are based on specifications
included in Table R402.4.1.1 of the 2015 IECC with modifications based
on the recommendation of the MH working group. See Term Sheet at 1. The
2015 IECC specifications save energy by helping to ensure proper
installation of an air barrier, and the MH working group recommended
modifications to the specifications based on the unique nature of the
manufactured housing industry. Rather than use the term ``air sealed
boxes'' from the 2015 IECC, the MH working group described directly how
this could be achieved using the phrasing ``the air barrier must be
sealed around the box penetration.'' DOE thus proposes to adopt the
2015 IECC specifications, as amended, in the proposed rule.
Table 460.104 also would establish requirements for mating line
surfaces, as recommended by the MH working group. See Term Sheet at 5.
The proposed requirements would ensure proper sealing of the mating
line surface between the two sections of a multi-section manufactured
home and would reduce energy use by ensuring that multi-section
manufactured homes have a continuous air barrier.
The proposed requirements of Table 460.104 for rim joists, and
showers or tubs adjacent to exterior walls are consistent with the
specifications of Table R402.4.1.1 of the 2015 IECC. The MH working
group recommended that DOE adopt the 2015 IECC specifications
[[Page 39777]]
in the proposed rule given that they would result in additional energy
conservation within a manufactured home by helping to ensure a
continuous air barrier. See Term Sheet at 1.
Table R402.4.1.1 of the 2015 IECC also contains specifications for
air leakage sealing in crawl space walls, garage separation, plumbing
and wiring, and concealed sprinklers. The MH working group recommended
that DOE not propose these specifications in the proposed rule. See
Term Sheet at 1. Given that these requirements are not directly
applicable to manufactured home construction, DOE is not proposing to
include these requirements in the proposed rule.
The 2015 IECC includes specifications for air leakage of
fenestration and recessed luminaires that DOE has not included in this
proposed rule. In section R402.4.3 of the 2015 IECC, windows,
skylights, and sliding glass doors have a specified maximum air leakage
rate of 0.3 cubic feet per minute (cfm) and swinging doors have a
specified maximum air leakage rate of 0.5 cfm. Section R402.4.5 of the
2015 IECC specifies air leakage around recessed luminaires most be no
greater than 2.0 cfm when tested at a 75 pascal pressure differential.
The MH working group recommended not to include these requirements for
fenestration and recessed luminaire air leakage in order to reduce the
testing burden on manufacturers. See Term Sheet at 1. DOE agrees with
the MH working group's recommendation and has not proposed to include
air leakage requirements for fenestration and recessed luminaires, as
air leakage standards already are addressed generally at the building
thermal envelope level. Nevertheless, DOE has designed its proposed
prescriptive building thermal envelope air leakage standards, which
include requirements to seal the space between fenestration and framing
and between recessed luminaires and drywall, to achieve an air leakage
rate of five ACH.
DOE also reviewed section R402.4.4 of the 2015 IECC regarding rooms
containing fuel-burning appliances. Section R402.4.4 includes
specifications for the placement of fuel-burning appliances (outside of
conditioned space), for sealing of the room enclosing the appliance,
and for insulation of ducts and waterlines. Although these provisions
have potential to save energy, the HUD Code already specifies that the
combustion system for fuel burning devices must be completely separated
from the interior atmosphere of the manufactured home. See 24 CFR
3280.709(d). Therefore, DOE is not including these requirements in this
proposed rulemaking. However, DOE may consider the merits of including
R402.4.4 in future revisions of energy conservation standards for
manufactured housing. DOE requests comment on the fireplace
requirements based on section R402.4.2 of the 2015 IECC and the
proposal not to include insulation and air sealing requirements
pertaining to rooms containing fuel-burning appliances.
3. Subpart C: HVAC, Service Water Heating, and Equipment Sizing
(a) Sec. 460.201 Duct Sealing
Section 460.201(a) would require manufacturers to equip each
manufactured home with a duct system designed to limit total air
leakage to less than or equal to four cubic feet per minute per 100
square feet of conditioned floor area, when tested in accordance with
Sec. 460.201(b). Section R403.3.4 of the 2015 IECC specifies that the
total air leakage of duct systems is to be less than or equal to four
cubic feet per minute per 100 square feet of conditioned floor area
under a post-construction test. The 2015 IECC also includes
specifications for a rough-in test performed with or without an air
handler. The MH working group recommended that DOE consider only the
post-construction test 2015 IECC specifications in developing the
proposed standards given the unique nature of manufactured homes
relative to site-built housing. See 9/10 Working Group Transcript,
EERE-2009-BT-BC-0021-0133 at 227. DOE proposes to adopt the post-
construction test specifications of the 2015 IECC as it would be more
cost-effective to the manufactured housing industry.
Section R403.3.5 of the 2015 IECC specifies that building framing
cavities must not be used as plenums. A plenum is a space within a
building that facilitates the circulation of air. Building framing
cavities are typically not tightly sealed and do not provide an
adequate barrier to foreign bodies for air quality reasons. The use of
building framing cavities as ducts and plenums is generally considered
to be poor practice and is not a typical practice in the manufactured
housing industry. Therefore, consistent with the 2015 IECC and the
recommendation of the MH working group (see Term Sheet at p. 1), DOE
proposes to require that building framing cavities not be used as ducts
or plenums under Sec. 460.201(a).
Section 460.201(b) would establish procedures for ensuring
compliance with the duct system air leakage standard under Sec.
460.201(a). As discussed in this preamble, the MH working group did not
address options for systems of compliance and enforcement, and DOE has
not included proposed compliance and enforcement provisions in this
rule. In the event that DOE addresses compliance assurance in a future
rulemaking, paragraph (b) would be reserved to provide a methodology
for determining compliance with this standard that would provide for an
accurate and repeatable procedure.
The 2015 IECC also includes specifications associated with duct
systems that DOE has not included in this proposed rule. Section
R403.3.1 of the 2015 IECC specifies that supply ducts in attics shall
be insulated to a minimum of R-8 while all other ducts shall be
insulated to a minimum of R-6. The MH working group did not discuss
this section of the 2015 IECC. Because ducts are typically located
within the building thermal envelope in manufactured homes, DOE did not
include this IECC requirement. DOE requests comment on this proposal.
DOE also would not incorporate sections R403.3.2 and R403.3.2.1 of
the 2015 IECC, which specify that sealing of ducts, air handlers, and
filter boxes must be in accordance with the International Mechanical
Code or the International Residential Code. DOE believes that
additional sealing requirements are not needed in conjunction with the
proposed quantitative sealing requirements in Sec. 460.201(a). DOE
recognizes, however, that some manufacturers may choose to meet the
requirements of Sec. 460.201(a) in part by voluntarily following the
requirements of the International Mechanical Code or the International
Residential Code.
(b) Sec. 460.202 Thermostats and Controls
Section R403.1 of the 2015 IECC specifies that at least one
thermostat shall be provided for each separate heating and cooling
system. Section R403.1.1 of the 2015 IECC also specifies that the
thermostat controlling the primary heating or cooling system must be
capable of controlling the heating and cooling system on a daily
schedule to maintain different temperature set points at different
times of the day. The 2015 IECC further specifies that where the
primary heating system is a forced-air furnace, at least one thermostat
per dwelling unit must be capable of controlling the heating and
cooling system on a daily schedule to maintain different temperature
set points at different times of the day. The 2015 IECC also specifies
that this thermostat to have the capability of setting back, or
[[Page 39778]]
temporarily operating, the system to maintain zone temperatures as low
as 55 [deg]F or as high as 85 [deg]F.
DOE has adopted section R403.1 of the 2015 IECC into Sec.
460.202(a) without revision. DOE also has incorporated section R403.1.1
of the 2015 IECC into Sec. 460.202(b). As proposed, Sec. 460.202
would apply to any thermostat and controls installed by the
manufacturer. A thermostat is a necessary interface for establishing
desired temperature levels within a home, and already standard practice
currently. Programmable thermostats help consumers save energy by
providing the capability reduce energy use automatically during
predetermined times (generally times the home is not occupied). This is
also consistent with recommendations of the MH working group. See Term
Sheet at 1.
Moreover, section R403.1.2 of the 2015 IECC specifies that heat
pumps having supplementary electric-resistance heat to have controls
that, except during defrost, prevent supplemental heat operation when
the heat pump compressor can meet the heating load. Supplementary
electric-resistance heating equipment is less efficient and less cost-
effective as a heating method than heat-pump heating equipment.
Therefore, preventing supplementary electric-resistance heating except
for during defrost would reduce energy usage and manufactured home
energy bills. DOE notes that Sec. 3280.714(a)(1)(ii) of the HUD Code
establishes requirements for heat pumps. DOE is not aware of any
instances in which the proposed requirement, which provides that the
heating system be provided with controls that, except during defrost,
prevent supplemental heat operation when the heat pump compressor can
meet the heating load, would conflict with Sec. 3280.714(a)(1)(ii).
DOE thus proposes to include this requirement in this rule, as
recommended by the MH working group. See Term Sheet at 1.
DOE requests comment on the proposed requirements contained in
Sec. 460.202. Specifically, DOE requests comment and information on
the potential interaction between proposed Sec. 460.202(c) and Sec.
3280.714(a)(1)(ii) of the HUD Code.
(c) Sec. 460.203 Service Hot Water Systems
Section 460.203(a) would require manufacturers to install service
water heating systems according to the service water heating system
manufacturer's installation instructions. As proposed, Sec. 460.203
would apply to any service water heating system installed by a
manufacturer. In addition, Sec. 460.203 would require manufacturers to
provide maintenance instructions for the service water heating system
with the manufactured home. These requirements would promote the
correct installation and maintenance of service water heating equipment
and help to ensure that such equipment performs at its intended level
of efficiency.
Section 403.5.1 of the 2015 IECC specifies that automatic controls,
temperature sensors, and pumps related to service water heating must be
accessible and that manual controls be ``readily accessible.'' Sec.
460.203(b) would require any automatic and manual controls, temperature
sensors, pumps associated with service water heating systems to be
similarly accessible. This requirement would ensure that manufactured
homeowners would have adequate control over service water heating
equipment in order to achieve the intended level of efficiency
contemplated under part 460. This is also consistent with the
recommendation of the MH working group. See Term Sheet at 1.
Section 403.5.1.1 of the 2015 IECC specifies that (1) heated water
circulation systems be provided with a circulation pump, and the system
return pipe be a dedicated return pipe or cold water supply pipe; (2)
gravity and thermosyphon circulation systems are prohibited; (3)
controls for circulating hot water system pumps must start the pump
based on the identification of a demand for hot water within the
occupancy; and (4) the controls must automatically turn off the pump
when the water in the circulation loop is at the desired temperature
and when there is no demand for hot water. Heated water circulation
systems must have a circulation pump (if they are not of the gravity or
thermosyphon variety) to function properly. Moreover, gravity or
thermosyphon circulation systems are less efficient than those that use
a pump. Manufactured homeowners would benefit from the energy savings
associated with controls used to operate the circulation pump based on
demand from a user and that automatically turn off the pump when there
is no demand for hot water. Finally, controls that automatically turn
off the pump once the desired temperature is reached reduce energy use
relative to a system that runs the pump continuously. Accordingly, DOE
has incorporated each of these specifications into proposed Sec.
460.203(c) without change to ensure heated water circulation systems
are designed in an energy efficient manner.
Section R403.5.2 of the 2015 IECC includes specifications that are
related to demand recirculation systems. Conventional hot water systems
send cold water (hot water that has cooled) standing in the hot water
pipe down the drain when hot water is demanded by the home owner. After
the cold water is flushed out, hot water from the water heater reaches
the point of use. Demand recirculation systems differ from conventional
hot water systems in that any cold water standing in hot water pipes at
the time hot water is demanded is sent back to the hot water system
rather than being dumped down the drain. Given that these systems,
while technically feasible to install in manufactured housing, are not
currently in use by the industry, DOE proposes not to include any
requirements relating to demand recirculation systems in this proposed
rule; however, DOE requests comment on the potential benefits and
burdens of including demand recirculation system standards for
consideration in development of a final rule.
Section R403.5.4 of the 2015 IECC specifies standards and test
procedures for drain water heat recovery units. Given that these
devices typically are not used in manufactured homes, DOE proposes not
to include any requirements related to drain water heat recovery units
in this proposed rule; however, DOE requests comment on the potential
benefits and burdens of drain water heat recovery unit procedures for
consideration in development of a final rule.
DOE proposes that all hot water pipes outside conditioned space
would be required to be insulated to at least R-3, and that all hot
water pipes from a water heater to a distribution manifold would be
required to be insulated to at least R-3. Section R403.5.3 of the 2015
IECC specifies seven categories of hot water pipe (such as piping
outside the conditioned space) that must be insulated to at least R-3.
Section 460.203(e) has incorporated each of the categories of piping
listed under section R403.5.3 of the 2015 IECC that are relevant to
manufactured housing. Accordingly, DOE has not adopted specifications
related to piping under a floor slab, buried-in piping, and supply and
return piping in recirculation system other than demand recirculation
systems. Any piping located within conditioned space is unlikely to
affect energy use dramatically, as hot water eventually will reach room
temperature regardless of whether R-3 insulation is in place. Hot water
piping outside of conditioned space is exposed to a larger temperature
gradient and therefore
[[Page 39779]]
piping insulation would have a greater opportunity for energy
conservation within a manufactured home. This is also consistent with
the recommendations of the MH working group. See Term Sheet at 6.
(d) Sec. 460.204 Mechanical Ventilation Fan Efficacy
Table 403.6.1 of the 2015 IECC includes requirements for mechanical
ventilation system fan efficacy. Consistent with the recommendations of
the MH working group, and because DOE considers that there would be
significant potential energy savings benefits associated with fan
efficacy, DOE proposes to incorporate these specifications, without
change, into Table 460.204. See Term Sheet at 1.
Section 403.6.1 of the 2015 IECC specifies that if mechanical
ventilation fans are integral to tested and listed HVAC equipment, then
they must be powered with an electronically commutated motor. The MH
working group (see Term Sheet at 1) recommended that DOE include this
requirement in the proposed rule without change. Since electronically
commutated motors offer substantially increased energy conservation
over conventional induction motors, DOE proposes to include this
requirement in the proposed rule.
Section 3280.103(b) of the HUD Code establishes whole-house
ventilation requirements, including that a manufactured home must be
capable of providing 0.035 cubic feet (air volume) per minute per
square foot (floor area) of mechanical ventilation. Section 3280.103(b)
also requires that the flow rate of the system must be between 50 and
90 cubic feet per minute. In contrast, Sec. 460.204 would establish
requirements for the electrical efficiency of the fans providing the
ventilation. These regulations would not conflict, as HUD regulates the
``size'' of the ventilation system while DOE would regulate the
efficiency of the fans that provide ventilation.
(e) Sec. 460.205 Equipment Sizing
Section R403.7 of the 2015 IECC sets forth specifications on the
appropriate sizing of heating and cooling equipment within a
manufactured home, which the MH working group recommended for inclusion
in the proposed rule. See Term Sheet at 1. This section of the 2015
IECC requires the use of ACCA Manual S to select appropriately sized
heating and cooling equipment based on building loads calculated using
ACCA Manual J. The 2015 IECC also includes the option to use ``other
approved'' calculation methodologies and requires that new or
replacement heating and cooling equipment meet minimum energy
efficiency requirements as required by federal law. Section 460.205
would set forth specific requirements for the utilization of ACCA
Manuals S and Manual J for the purposes of selecting equipment size and
calculating building load. The ACCA manuals are industry standards that
DOE has determined are adequate for these calculations. DOE has not
approved any other calculation methodologies because no other
applicable, widely-used methodologies are currently available. DOE
requests comment on the applicability of ACCA Manual S and ACCA Manual
J for the purposes of heating and cooling equipment sizing.
Section R403.7 of the 2015 IECC also specifies that any replacement
heating or cooling equipment be compliant with federal law. DOE would
not adopt section R403.7 as there would be no need to remind
manufacturers of the requirement to comply with existing federal law.
C. Other 2015 IECC Specifications
The following section discusses certain specifications included in
the 2015 IECC that DOE has not included in the development of its
proposed energy conservation standards. DOE requests comment with
regard to each of these specifications, including whether DOE should
incorporate any of the specifications in development of a final rule.
1. Section R302
Section R302 of the 2015 IECC specifies interior design
temperatures that are to be used for heating and cooling load
calculations when using energy use modeling. Given that the proposed
rule does not include an option for compliance with the building
thermal envelope requirements that makes use of simulated performance
(see section R405 of the 2105 IECC), DOE has not included this
requirement in the proposed rule. DOE requests comment on the
practicality and functionality of using a simulated performance
alternative that contemplates the adoption of sections R302 and R405 of
the 2015 IECC.
2. Section R303.1
Section R303.1 of the 2015 IECC specifies how materials, systems,
and equipment are to be identified. DOE has not incorporated these
specifications in the proposed rule as the underlying statutory
authority provides no direction for DOE to impose requirements on
component manufacturers.
3. Section R401.3
Section R401.3 of the 2015 IECC specifies that a permanent
certificate be posted in a utility room that gives the performance
values of major building components and systems. Provisions related to
enforcement and compliance of the proposed DOE standards were not
contemplated by the MH working group and therefore are not included in
this proposed rule.
4. Section R402.4
Section R402.4.2 of the 2015 IECC specifies that wood-burning
fireplaces shall have tight fitting doors and outdoor combustion air.
The IECC also requires that the fireplace and tight fitting doors must
be listed and labeled in accordance with certain referenced standards.
DOE is proposing not to include these requirements in this rule because
they were not specifically addressed by the MH working group.
Section R402.4.5 of the 2015 IECC also specifies that recessed
luminaires must be IC-rated. DOE has not adopted section R402.4.5 as
fire safety was not contemplated by the MH working group.
5. Section R403
Section R403.2 of the 2015 IECC includes specifications for hot
water boiler outdoor temperature setback. Given that hot water boilers
used to supply building heat are not used in manufactured homes, DOE
has not adopted requirements based on section R403.2 of the 2015 IECC
under this proposed rule.
Section R403.5.1.2 of the 2015 IECC includes specifications for
electric heat trace systems. The IECC requires that these systems
comply with certain referenced standards. DOE is proposing not to
include this requirement because electric heat trace systems are not
commonly used in manufactured housing.
Section R403.4 of the 2015 IECC specifies a minimum of R-3
insulation on mechanical system piping capable of carrying fluids above
105 [deg]F or below 55 [deg]F. Section R403.4.1 of the 2015 IECC
specifies that mechanical system piping insulation exposed to weather
must be protected to prevent insulation degradation. These
specifications are intended to reduce heat loss or gain and improve the
energy efficiency of the piping delivery system. Mechanical systems
that require piping holding fluids in this temperature range are
unusual for manufactured housing. See Cavco, EERE-2009-BT-BC-0021-0133
at p. 63. Furthermore, DOE expects that the manufacturer of the
mechanical system would require piping insulation
[[Page 39780]]
of at least R-3 for proper installation. For the aforementioned
reasons, DOE is not proposing to include the requirements of section
R403.4 and R403.4.1 of the 2015 IECC. DOE requests comment on this
proposal.
Section R403.8 of the 2015 IECC includes specifications for systems
serving as multiple dwelling units. Consistent with the recommendation
of the MH working group (see Term Sheet at 1), and because a
manufactured home typically functions only as a single dwelling unit,
DOE has not adopted requirements related to section R403.8 of the 2015
IECC under this proposed rule.
Section R403.9 of the 2015 IECC includes specifications for
pavement snow- and ice-melting controls. Consistent with the
recommendation of the MH working group (see Term Sheet at 1), and
because the factory assembly of manufactured homes does not contemplate
driveway conditions, DOE has not adopted requirements related to
section R403.9 of the 2015 IECC in this proposed rule.
Sections R403.10, R403.11, and R403.12 of the 2015 IECC include
specifications associated with the energy consumption of pools,
permanent spas, and portable spas. Consistent with the recommendation
of the MH working group (see Term Sheet at 1), and because the factory
assembly of manufactured homes does not include pools and spas, DOE has
not adopted requirements related to these sections of the 2015 IECC in
this proposed rule.
6. Section R404
Section R404.1 of the 2015 IECC specifies either that a minimum of
75 percent of the lamps within each permanently installed lighting
fixture be high-efficacy lamps or that a minimum of 75 percent of the
permanently installed lighting fixtures contain only high-efficacy
lamps. The 2015 IECC defines high-efficacy lighting as (1) compact
fluorescent lamps; (2) T8 or smaller diameter linear fluorescent lamps;
or (3) lamps with a minimum efficacy of 60 lumens per watt for lamps
greater than 40 watts, 50 lumens per watt for lamps greater than 15
watts and less than or equal to 40 watts, and 40 lumens per watt for
lamps less than or equal to 15 watts. Consumer adoption of high-
efficacy lighting has increased over the past decade, as evidenced by
section 3.4.5 of the preliminary TSD associated with the DOE general
service lamp energy conservation standard. See 79 FR 73503 (Dec. 11,
2014). This ongoing rulemaking for general service lamps studies the
benefits and burdens of establishing nationwide minimum lamp efficacy
standards. DOE also completed a final rule adopting revised lamp
efficacy standards for general service fluorescent lamps on January 26,
2015. See 80 FR 4041. Given DOE's ongoing efforts in this regard, DOE
has not adopted requirements related to lighting in the proposed rule
and requests comment on whether DOE's other rulemaking efforts would be
insufficient to achieve lighting efficiency in manufactured housing.
Section R404.1.1 of the 2015 IECC includes specifications for fuel
gas lighting systems. Given that manufactured homes do not utilize fuel
gas lighting systems, DOE has not adopted requirements related to
section R404.1.1 of the 2015 IECC in this proposed rule.
7. Section R405
Section R405 of the 2015 IECC establishes criteria for compliance
using a simulated energy performance analysis, which involves
calculating expected building energy use and comparing that value to
the energy use of a standard reference building that complies with the
minimum specifications of the 2015 IECC. Although DOE believes that
simulated performance is a valid and technically feasible option, such
an option does not appear to offer additional flexibility in the design
of a manufactured home relative to the performance-based approach for
the building thermal envelope. Accordingly, DOE has not adopted
requirements associated with alternative performance under the proposed
rule. DOE requests comment on the practicality and functionality of
using a simulated performance alternative that contemplates the
adoption of sections R302 and R405 of the 2015 IECC.
8. Section R406
Section R406 of the 2015 IECC establishes criteria for compliance
using an energy rating index (ERI) that contemplates the use of
software to calculate the energy use of a building. Although DOE
believes that ERI analysis is a valid and technically feasible option,
such an option does not appear to offer additional flexibility in the
design of a manufactured home relative to the performance-based
approach for the building thermal envelope. Accordingly, DOE has not
adopted requirements associated with alternative performance under the
proposed rule. DOE requests comment on the practicality and
functionality of adopting an ERI alternative that contemplates the
adoption of section R406 of the 2015 IECC.
9. Chapter 5
Chapter 5 of the 2015 IECC includes specifications related to the
alteration, repair, addition, and change of occupancy of existing
buildings and structures. Given that the proposed rule contemplates the
energy conservation of newly constructed manufactured homes, DOE has
not adopted any of the specifications included in chapter 5 of the 2015
IECC.
10. Chapter 6
Chapter 6 of the 2015 IECC lists the industry standards referenced
in the 2015 IECC. Section 460.3 incorporates by reference only the
industry standards relevant to the proposals included in this proposed
rule, with specific modifications as applicable to manufactured
housing. Accordingly, DOE has not adopted the industry standards as
referenced in chapter 6 of the 2015 IECC.
D. Crosswalk of Proposed Standards With the HUD Code
As discussed in this preamble, DOE's intention in proposing energy
conservation standards for manufactured homes is that, if finalized,
there would be no conflict between the proposed requirements and the
construction and safety standards for manufactured homes as established
by HUD. That is, compliance with the proposed requirements would not
prohibit a manufacturer from complying with the HUD Code. Table III.2
lists the proposed energy conservation standards and discusses their
relationship to similar requirements contained in the HUD Code. As this
proposed approach requires careful analysis of all aspects of energy
conservation contained in both the proposed rule and in the HUD Code,
DOE requests comment on any inconsistencies that would result from this
proposed approach.
[[Page 39781]]
Table III.2--Crosswalk of Proposed Standards With the HUD Code
------------------------------------------------------------------------
DOE Proposed rule (10 CFR part HUD Code (24 CFR
460) part 3280) Notes
------------------------------------------------------------------------
Sec. 460.101 would establish Sec. 3280.506 HUD Code climate
four climate zones, which would establishes three zone 3 and the
be delineated by home size and climate zones northern portion
both state and county delineated by of HUD Code
boundaries. state boundaries. climate zone 2
The HUD Code cover a similar
establishes one region to climate
standard for zones 3 and 4 of
homes of all the proposed
sizes within a rule. HUD Code
climate zone. climate zones 1
and the southern
portion of HUD
Code climate zone
2 cover a similar
region to climate
zones 1, 2, and 3
of the proposed
rule.
Sec. 460.102(a) would Sec. 3280.506
establish building thermal establishes a
envelope prescriptive and performance
performance compliance options. approach.
Sec. 460.102(b) would set Sec. 3280.506
forth the prescriptive option establishes a
for compliance with the performance
building thermal envelope approach only.
requirements.
Sec. 460.102(b)(2) would No corresponding
establish a minimum truss heel requirement.
height.
Sec. 460.102(b)(3) would No corresponding
require ceiling insulation to requirement.
have uniform thickness and
density.
Sec. 460.102(b)(4) would No corresponding
establish an acceptable batt requirement.
and blanket insulation
combination for compliance with
the floor insulation
requirement in climate zone 4.
Sec. 460.102(b)(5) would No corresponding
identify certain skylights not requirements.
subject to SHGC requirements.
Sec. 460.102(b)(6) would No corresponding
establish U-factor alternatives requirements.
for the R-value requirements
under Sec. 460.102(b)(1).
Sec. 460.102(b)(7) would No corresponding
establish a maximum ratio of 12 requirements.
percent for glazed fenestration
area to floor area under the
prescriptive option.
Sec. 460.102(c)(1) would Sec. 3280.506(a) The proposed
establish maximum building establishes maximum building
thermal envelope Uo maximum building thermal envelope
requirements by home size and thermal envelope Uo requirements
climate zone. Uo requirements would be lower
by climate zone. than the
corresponding
maximum Uo
requirements
under Sec.
3280.506(a).
Compliance with
the proposed Uo
requirements
would achieve
compliance with
the Uo
requirements
under the HUD
Code.
Sec. 460.102(c)(2) would No corresponding
establish maximum area-weighted requirements.
vertical fenestration U-factor
requirements in climate zones 3
and 4.
Sec. 460.102(c)(3) would No corresponding
establish maximum area-weighted requirements.
average skylight U-factor
requirements in climate zones 3
and 4.
Sec. 460.102(c)(4) would No corresponding
authorize windows, skylights requirements.
and doors containing more than
50 percent glazing by area to
satisfy the SHGC requirements
of Sec. 460.102(a) on the
basis of an area-weighted
average.
Sec. 460.102(d)(1)............ .................. [Reserved].
Sec. 460.102(d)(2)............ .................. [Reserved].
Sec. 460.102(d)(3) would Sec. 3280.508(a)
establish a method of and (b) reference
determining total R-value where the Overall U-
multiple layers comprise a values and
component. Heating/Cooling
Loads--Manufactur
ed Homes method
and the 1997
ASHRAE Handbook
of Fundamentals.
Sec. 460.102(d)(4)............ .................. [Reserved].
Sec. 460.102(d)(5)............ .................. [Reserved].
Sec. 460.102(d)(6) would Sec. 3280.508(a)
establish prescriptive default and (b) reference
U-factor values. the Overall U-
values and
Heating/Cooling
Loads--Manufactur
ed Homes method
and the 1997
ASHRAE Handbook
of Fundamentals.
Sec. 460.102(d)(7)............ .................. [Reserved].
Sec. 460.102(d)(8) would No corresponding
establish prescriptive default requirements.
U-factor values.
Sec. 460.102(e)(1) would Sec. 3280.508(a)
establish a method of and (b) reference
determining Uo. the Overall U-
values and
Heating/Cooling
Loads--Manufactur
ed Homes method
and the 1997
ASHRAE Handbook
of Fundamentals.
Sec. 460.102(e)(2)............ .................. [Reserved].
[[Page 39782]]
Sec. 460.102(e)(3) would Sec. 3280.508(a) DOE's proposed
establish default fenestration and (b) reference default values
and door U-factor and the Overall U- originate from
fenestration SHGC values. values and the 2015 IECC.
Heating/Cooling These default
Loads--Manufactur values generally
ed Homes method result in lower
and the 1997 performance than
ASHRAE Handbook the HUD Code
of Fundamentals. values. DOE
These references expects
contain default compliance with
values. the proposed rule
to result in
compliance with
the HUD Code.
Sec. 460.103(a) would require No corresponding
insulating materials to be requirements.
installed according to the
manufacturer installation
instructions and the
prescriptive requirements of
Table 460.103.
Sec. 460.103(b) would No corresponding
establish requirements for the requirements.
installation of batt, blanket,
loose fill, and sprayed
insulation materials.
Sec. 460.104 would require Sec. 3280.505
manufactured homes to be sealed establishes air
against air leakage at all sealing
joints, seams, and penetrations requirements of
associated with the building building thermal
thermal envelope in accordance envelope
with the manufacturer's penetrations and
installation instructions and joints.
the requirements set forth in
Table 460.104.
Sec. 460.201(a) would require Sec.
each manufactured home to be 3280.715(a)(4)
equipped with a duct system establishes
that must be sealed to limit requirements for
total air leakage to less than airtightness of
or equal to 4 cfm per 100 supply duct
square feet of floor area when systems.
tested according to Sec.
460.201(b) and specifies that
building framing cavities are
not to be used as ducts or
plenums.
Sec. 460.201(b)............... .................. [Reserved].
Sec. 460.202(a) would require Sec. 3280.707(e) Both the proposed
at least one thermostat to be requires that rule and the HUD
provided for each separate each space Code would
heating and cooling system heating, cooling, require the
installed by the manufacturer. or combination installation of
heating and at least one
cooling system be thermostat that
provided with at is capable of
least one maintaining zone
adjustable temperatures.
automatic control
for regulation of
living space
temperature.
Sec. 460.202(b) would require No corresponding
that installed thermostats requirements.
controlling the primary heating
or cooling system be capable of
maintaining different set
temperatures at different times
of day.
Sec. 460.202(c) would require Sec. Both the proposed
heat pumps with supplementary 3280.714(a)(1)(ii rule and the HUD
electric resistance heat to be ) requires heat Code would
provided with controls that, pumps to be require heat
except during defrost, prevent certified to pumps with
supplemental heat operation comply with ARI supplemental
when the pump compressor can Standard 210/240- electric
meet the heating load. 89, heat pumps resistance heat
with supplemental to prevent
electrical supplemental heat
resistance heat operation when
to be sized to the heat pump
provide by compressor can
compression at meet the heating
least 60 percent load of the
of the calculated manufactured
annual heating home.
requirements of
the manufactured
home, and that a
control be
provided and set
to prevent
operation of
supplemental
electrical
resistance heat
at outdoor
temperatures
above 40 [deg]F.
Sec. 460.203(a) would No corresponding
establish requirements for the requirements.
installation of service water
heating systems.
Sec. 460.203(b) would require No corresponding
any automatic and manual requirement.
controls, temperature sensors,
pumps associated with service
water heating systems to be
accessible.
Sec. 460.203(c) would No corresponding
establish requirements for requirements.
heated water circulation
systems.
Sec. 460.203(d) would No corresponding
establish requirement for the requirements.
insulation of hot water pipes.
Sec. 460.204 would establish No corresponding HUD requirements
requirements for mechanical requirements. at Sec.
ventilation system fan efficacy. 3280.103(b) do
not overlap with
DOE's proposal.
DOE's proposal is
for fan
electrical
efficiency, while
HUD requirements
specify minimum
and maximum air
flow rates.
Sec. 460.205 would establish No corresponding
requirements for heating and requirements.
cooling equipment sizing.
------------------------------------------------------------------------
[[Page 39783]]
E. Compliance and Enforcement
Although DOE is not considering compliance and enforcement in this
proposed rule, DOE anticipates assessing compliance and enforcement
mechanisms in a future rulemaking. As a result, the costs and benefits
resulting from any compliance and enforcement mechanism are not
included in the economic impact analysis that is included in this
rulemaking. DOE anticipates it will provide a detailed analysis of the
costs and benefits resulting from compliance and enforcement activities
in its future rulemaking. A variety of possibilities may be considered
in that rulemaking process including, but not limited to, the three
options described in this paragraph. First, HUD could directly
administer a compliance and enforcement program for DOE's manufactured
housing regulations via the existing HUD system outlined at 24 CFR
3282. This option would require that HUD adopt the energy conservation
standards resulting from this rulemaking into its Manufactured Home
Construction and Safety Standards. Second, DOE could implement a
compliance and enforcement program mirroring HUD's system codified at
24 CFR 3282. Third, manufacturers could self-certify compliance to DOE
by submitting documentation attesting that manufactured homes are
compliant with DOE regulations. This third compliance option could be
paired with a variety of enforcement mechanisms ranging from
unannounced inspections and audits to a system mirroring HUD's
enforcement system at 24 CFR 3282.
By way of background, under HUD's compliance and enforcement
system, manufacturers are required to: (1) Contract for services with a
HUD accepted Design Approval Primary Inspection Agency (DAPIA) to
evaluate their designs and quality assurance manual for conformance
with the Standards and Regulations; and (2) contract for services with
a HUD accepted Production Inspection Primary Inspection Agency (IPIA)
to evaluate, through on-going surveillance of the production process,
that each plant is continuing to follow its DAPIA approved quality
assurance manual and quality control procedures and to verify that each
factory is continuing to produce homes in conformance with the
Standards. In addition, the actions of all primary inspection agencies
(DAPIAs, IPIAs) and State Administrative Agencies (SAAs) are monitored
to determine whether they are fulfilling their responsibilities under
HUD's regulatory system. In addition, manufacturers are also subject to
system of notification and correction procedures whenever they produce
homes that contain imminent safety hazards or failures to conform to
the HUD standards.
DOE seeks comment on potential options for compliance and
enforcement to be considered in a future rulemaking, including
information regarding the rationale for any recommended option. DOE
also seeks comment on the estimated costs (only direct compliance and
enforcement costs, not engineering costs for redesign) and time (design
review validation, inspection frequency and duration, administrative
procedures) associated with the potential options.
IV. Economic Impacts and Energy Savings
A. Economic Impacts on Individual Purchasers of Manufactured Homes
DOE used the LCC and payback period (PBP) analyses developed during
the MH working group negotiations to inform the development of the
proposed rule based on the economic impacts on individual purchasers of
manufactured homes. The LCC of a manufactured home refers to the total
homeowner expense over the life of the manufactured home, consisting of
purchase expenses (i.e., mortgage or cash purchase) and operating costs
(i.e., energy costs). To compute the operating costs, DOE discounted
future operating costs to the time of purchase and summed them over the
30-year lifetime of the home used for the purpose of analysis in this
rulemaking. The PBP refers to the estimated amount of time (in years)
for manufactured homeowners to recover the increased purchase cost
(including installation) of their homes through lower operating costs.
DOE calculates the PBP by dividing the incremental increase in purchase
cost by the reduction in average annual operating costs that would
result from this proposed rule.
The LCC analysis demonstrates that increased purchase prices would
be offset by the benefits manufactured homeowners would experience in
operating cost savings under the proposed rule. DOE has evaluated these
projected impacts on individual manufactured homeowners by analyzing
the potential impacts to LCC, energy savings, and purchase price of
manufactured homes under the proposed rule. For the purpose of this
economic analysis, DOE compared the purchase price and LCC for
manufactured homes built in accordance with the proposed rule relative
to a baseline manufactured home built in compliance with the minimum
requirements of the HUD Code. Specifically, DOE performed energy
simulations on manufactured homes located in 19 geographically diverse
locations across the United States, accounting for five common heating
fuel/system types and two typical industry sizes of manufactured homes
(single-section and double-section \6\ manufactured homes). Further
information on how DOE calculated LCC impacts and energy savings for
the alternative efficiency levels discussed here is included in chapter
8 of the TSD. DOE requests comment on the methodology and results of
the LCC analysis.
---------------------------------------------------------------------------
\6\ Double-section manufactured homes were used to represent all
multi-section homes. Double-section manufactured homes have the
largest market share by shipments (about 98 percent) of all multi-
section homes.
---------------------------------------------------------------------------
Table IV.1 provides the preliminary average purchase price
increases to manufactured homes associated with the proposed rule under
each of the proposed climate zones. These costs are based on estimates
for the increased costs associated with more energy efficient
components, as provided by the MH working group. See EERE-2009-BT-BC-
0021-0091. These costs are discussed in further detail in chapter 5 and
chapter 9 of the TSD.
Table IV.1--Average Manufactured Home Purchase Price and Percentage Increases Under the Proposed Rule by Climate
Zone
----------------------------------------------------------------------------------------------------------------
Single-section Multi-section
---------------------------------------------------------------
$ % $ %
----------------------------------------------------------------------------------------------------------------
Climate Zone 1.................................. 2,422 5.3 3,748 4.5
Climate Zone 2.................................. 2,348 5.1 3,668 4.4
[[Page 39784]]
Climate Zone 3.................................. 2,041 4.5 2,655 3.2
Climate Zone 4.................................. 2,208 4.8 2,877 3.4
National Average................................ 2,226 4.9 3,109 3.7
----------------------------------------------------------------------------------------------------------------
Although DOE preliminarily has determined that the proposed
standards would result in increased purchase prices of manufactured
homes, manufactured homeowners, on average, would realize significant
LCC savings and energy savings as a result of the proposed rule. DOE
requests comment on affordability with respect to the projected average
increase in purchase cost (see Table IV.1 below) on the ability of low-
income consumers to obtain credit and financing to purchase a
manufactured home. DOE also requests comments on affordability in
context of the potential for reduced operating costs (energy bills) and
total LCC.
Figure IV.1 illustrates the average annual energy cost savings for
space heating and air conditioning for the first year of occupation by
geographic location under the proposed rule based on the estimated fuel
costs provided in chapter 8 of the TSD. Heating cost savings are
generally higher than cooling cost savings, so locations with cold
climates would have higher amounts of energy cost savings because of
the reduced heating energy use.
[GRAPHIC] [TIFF OMITTED] TP17JN16.003
Figure IV.2 illustrates the average 30-year LCC savings by
geographic location (averaged across the five different heating fuel/
system types) associated with the proposed rule for both single-section
and multi-section manufactured homes. As discussed in detail in chapter
9 of the TSD, Figure IV.2 accounts for LCC savings and impacts over a
30-year period of analysis, including energy cost savings and mortgage
payment increases discounted to a present value using the discount
rates discussed in chapter 4 of the TSD. These preliminary results also
are based on the costs associated with energy conservation
improvements, as discussed in chapter 5 of the TSD.
[[Page 39785]]
[GRAPHIC] [TIFF OMITTED] TP17JN16.004
The estimated LCC impacts under Figure IV.2 vary by location for
three primary reasons. First, each geographic location analyzed is
situated in one of four proposed climate zones and therefore would be
subject to different energy conservation requirements. Second,
geographic locations within the same climate zone would experience
different levels of energy savings. For example, both El Paso and
Baltimore would be situated in climate zone 3. However, a manufactured
home in Baltimore that meets the proposed climate zone 3 requirements
would experience greater savings than a manufactured home in El Paso
that meets the proposed climate zone 3 requirements because cooler
climates would have greater energy cost savings as a result of greater
reductions in heating costs. Finally, the level of energy cost savings
depends on the type of heating system installed and fuel type used in a
manufactured home. As discussed in chapter 8 of the TSD, DOE has
accounted for regional differences in heating systems and fuel types
commonly installed in manufactured housing.
Table IV.2 provides the preliminary national average LCC savings
under the proposed rule and annual energy cost savings associated with
the proposed rule for space heating and air conditioning (and percent
reduction in space heating and cooling costs), both of which are
measured against a baseline manufactured home constructed in accordance
with the HUD Code. As discussed in further detail in chapter 9 of the
TSD, each geographic location preliminary has been determined to result
in LCC savings and energy savings, on average.
Table IV.2--National Average Per-Home Savings Under the Proposed Rule
------------------------------------------------------------------------
Single- Multi-
section section
------------------------------------------------------------------------
Lifecycle Cost Savings (30 Years)................... $3,211 $4,625
Annual Energy Cost Savings.......................... 345 490
------------------------------------------------------------------------
Table IV.3 shows the benefits and costs to the manufactured
homeowner associated with the proposed rule, expressed in terms of
annualized values.
Table IV.3--Annualized Benefits and Costs to Manufactured Homeowners Under the Proposed Rule
----------------------------------------------------------------------------------------------------------------
Monetized (million 2015$/year)
Discount Rate -----------------------------------------------
(%) Primary Low estimate High estimate
estimate ** ** **
----------------------------------------------------------------------------------------------------------------
Benefits *
----------------------------------------------------------------------------------------------------------------
Operating (Energy) Cost Savings................. 7 516 400 688
3 843 617 1,191
----------------------------------------------------------------------------------------------------------------
Costs *
----------------------------------------------------------------------------------------------------------------
Incremental Purchase Price Increase............. 7 220 165 285
3 277 192 378
----------------------------------------------------------------------------------------------------------------
Net Benefits/Costs *
----------------------------------------------------------------------------------------------------------------
7 296 235 403
3 566 425 813
----------------------------------------------------------------------------------------------------------------
* The benefits and costs are calculated for homes shipped in 2017-2046.
** The Primary, Low, and High Estimates utilize forecasts of energy prices from the 2015 AEO Reference case, Low
Economic Growth case, and High Economic Growth case, respectively.
[[Page 39786]]
Figure IV.3 illustrates the nationwide average simple payback
period (purchase price increase divided by first year energy cost
savings) under the proposed rule. The estimated simple payback periods
under Figure IV.3 vary by geographic location based on the different
climate zone requirements for manufactured housing, geographic climatic
differences within climate zones, and the type of heating system
installed and fuel type used in a manufactured home.
[GRAPHIC] [TIFF OMITTED] TP17JN16.005
B. Manufacturer Impacts
DOE performed a manufacturer impact analysis (MIA) to estimate the
potential financial impact of energy conservation standards on
manufacturers of manufactured homes. The MIA relied on the Government
Regulatory Impact Model (GRIM), an industry cash-flow model used to
estimate changes in industry value as a result of energy conservation
standards. The key GRIM inputs are data on: Industry financial metrics,
manufacturer production cost estimates, shipments forecasts, conversion
expenditures estimates, and assumptions about manufacturer markups. The
primary output of the GRIM is industry net present value (INPV), which
is the sum of industry annual cash flows over the analysis period
(2016-2046), discounted using the industry weighted average cost of
capital. The GRIM has a slightly different analysis period than the NIA
and LCC because it takes into account the conversion period, the time
between the announcement of the standard and the effective date of the
standard, since manufacturers may need to make upfront investments to
bring their covered products ahead of the standard going into effect.
The GRIM estimates the impacts of more-stringent energy conservation
standards on a given industry by comparing changes in INPV and domestic
manufacturing employment between a base case and the standards case. To
capture the uncertainty relating to manufacturer pricing strategy
following new standards, the GRIM estimates a range of possible impacts
under different markup scenarios. Each of the inputs and output is
discussed in chapter 12 of the NOPR TSD. DOE used the GRIM to calculate
cash flows using standard accounting principles and to compare changes
in INPV between a base case and a standards case. The percent change in
INPV between the base and standards cases represents the financial
impact of new energy conservation standards on manufacturers of
manufactured homes. Additional detail on the GRIM can be found in
Appendix 12A.
DOE conducted the MIA analysis in three phases. In Phase 1 of the
MIA, DOE analyzed the upfront investments, conversation costs,
manufacturers would need to make to bring their products into
compliance with the new energy conservation standards. These upfront
investments include product conversion costs and capital conversion
costs. Product conversion costs are one-time investments in research,
development, labeling updates, and other costs necessary to make
product designs comply with energy conservation standards. Capital
conversion costs are one-time investments in property, plant and
equipment to adapt or change existing production lines to fabricate and
assemble new product designs that comply with the energy conservation
standards.
DOE calculated that the proposed rule would result in an average
upfront investment, or conversion cost, of $37,500 per manufacturer.
This figure includes $32,500 per manufacturer for product conversion
costs and $5,000 per manufacturer for capital conversion costs. DOE
assumed in its analysis that manufacturers would incur all upfront
costs in the year following publication of the final rule. Additional
detail on the conversion costs can be found in chapter 12 of the TSD.
In Phase 2 of the MIA, DOE analyzed the effect the proposed
standards would have on manufacturer production costs. To be
conservative in its analysis, DOE assumed that all units sold are at
the HUD minimum. Thus, the analysis does not account for the reduced
impact on units sold that may exceed the HUD minimum. Based on this
analysis, DOE estimates average manufacturer production costs would
increase by $1,321 for each single-section unit and by $1,840 for each
multi-section unit. The estimated increases in manufacturer production
costs are derived from the estimated increases in purchase price,
[[Page 39787]]
the retail markup and the manufacturer markup on these units. As a
starting point, DOE used the retail prices of manufactured homes in 19
cities that include all four proposed climate zones. The retail prices
were for the base case in each city and the standard case in each city.
Using public sources of information, including company SEC 10-K filings
\7\ and corporate annual reports, DOE applied a consistent manufacturer
markup of 1.25 and a retail markup of 1.30 for the base cases and
standards cases. DOE used these two markups, and along with a sales tax
multiplier, to back-calculate the manufacturer production cost for each
city. Details on the derivation of the sales tax multiplier, retail
markup, manufacturer markup, and manufacturer production cost for each
city can be found in chapter 12 of the NOPR TSD. DOE requests comments
on whether other manufacturer and retailer markups for base case and
standards cases should be considered (e.g., a combined mark-up of 2.30
has historically been used in the past by HUD to assess combined
manufacturer and retailer mark-ups to determine potential first cost
impacts on consumers).
---------------------------------------------------------------------------
\7\ U.S. Securities and Exchange Commission. Annual 10-K
Reports. Various Years. <http://sec.gov.
---------------------------------------------------------------------------
In Phase 3 of the MIA, DOE modeled two scenarios that reflect
changes in the manufacturer's ability to pass on their upfront
investments and increases in production costs to the customers. As
manufacturer production costs increase, manufacturers may need to
adjust their markup structure. For the MIA, DOE modeled two standards
case markup scenarios for manufactured homes to represent the
uncertainty regarding the potential impacts on prices and profitability
for manufactured home manufacturers following the implementation of the
proposed rule. DOE modeled a high and a low scenario for a manufacturer
to pass on their upfront investments and increases in production costs
to the customer: (1) A preservation of gross margin percentage markup
scenario; and (2) a preservation of operating profit markup scenario.
These scenarios lead to different markup values that, when applied to
the inputted manufacturer production costs, result in varying revenue
and cash flow impacts on the manufacturer.
Under the preservation of gross margin percentage markup scenario,
manufacturers maintain their current average markup of 1.25 even as
production costs increase. Manufacturers are able to maintain the same
amount of profit as a percentage of revenues, suggesting that they are
able to pass on the costs of compliance to their customers. DOE
considers this scenario the upper bound to industry profitability.
In the preservation of per unit operating profit scenario,
manufacturer markups are set so that operating profit one year after
the compliance date of the amended energy conservation standard is the
same as in the base case on a per unit basis. Under this scenario, as
the costs of production increase under a standards case, manufacturers
are generally required to reduce their markups. The implicit assumption
behind this markup scenario is that the industry can only maintain its
operating profit in absolute dollars per unit after compliance with the
new standard is required. Therefore, operating margin is reduced
between the base case and standards case. This markup scenario
represents a lower bound to industry profitability under an amended
energy conservation standard.
DOE calculated an industry average discount rate of 9.2% based on
SEC filings for public manufacturers of manufactured homes. This
discount rate was used to estimate the time-value of money when
discounting future cash flows. The INPV is the sum of the discounted
cash flows over the analysis period, which begins in 2016 and ends in
2046. When applying the two different markup scenarios, DOE is able to
estimate a range of potential impacts to INPV and the industry. DOE
compares the INPV of the base case to that of the proposed level. The
difference between INPV in the base case and INPV at the proposed level
is an estimate of the economic impacts on the industry.
Table IV.4--INPV Results: Preservation of Gross Margin Percentage Scenario *
----------------------------------------------------------------------------------------------------------------
Single-section Multi-section Total industry
----------------------------------------------------------------------------------------------------------------
Base Case INPV (million 2015$).................................. 229.0 487.8 716.7
Standards Case INPV (million 2015$)............................. 227.9 485.8 713.6
Change in INPV (million 2015$).................................. (1.1) (2.0) (3.1)
Change in INPV (%).............................................. -0.5% -0.4% -0.4%
-----------------------------------------------
Total Conversion Costs (million 2015$)...................... 0.5 1.1 1.6
----------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative values.
Table IV.5--INPV Results: Preservation of Operating Profit Markup Scenario *
----------------------------------------------------------------------------------------------------------------
Single-section Multi-section Total industry
----------------------------------------------------------------------------------------------------------------
Base Case INPV (million 2015$).................................. 229.0 487.8 716.7
Standards Case INPV (million 2015$)............................. 215.0 465.0 680.0
Change in INPV (million 2015$).................................. (14.0) (22.8) (36.8)
Change in INPV (%).............................................. -6.1% -4.7% -5.1%
-----------------------------------------------
Total Conversion Costs (million 2015$)...................... 0.5 1.1 1.6
----------------------------------------------------------------------------------------------------------------
* Values in parentheses are negative values.
For single-section units, the base case INPV is $229.0 million. The
proposed standard could result in a drop of industry value ranging from
-0.5 percent to -6.1 percent, or a loss of $1.1 million to $14.0
million. For multi-section units, the base case INPV is $487.8 million.
The proposed standard could result in a drop of industry value
[[Page 39788]]
ranging from -0.4 percent to -4.7 percent, or a loss of $2.0 million to
$22.8 million. For the industry as a whole, the base case INPV is
$716.7 million. The proposed standard could result in a drop in INPV of
-0.4 percent to -5.1 percent, or a loss of $3.1 million to $36.8
million. Industry conversion costs total $1.6 million at the proposed
level.
Though DOE's analysis assumes all manufactured homes are sold at
the HUD minimum level (analyzed as the baseline in this rulemaking),
select manufactured homes are available in the market at higher
efficiencies. If a manufacturer currently produces homes that are more
efficient than the HUD minimum level, the impacts associated with that
manufacturer will be reduced. For example, the incremental manufacturer
production cost would be smaller for a manufacturer already producing
homes above the minimum level. If a manufacturer already produces homes
compliant with the proposed level, then the manufacturer would
experience no conversion costs or increases in production costs for
those models.
DOE requests comment on the conversion costs for proposed standard.
DOE welcomes additional data regarding the cost to redesign model plans
to meet the proposed standard and the capital expenditures that the
proposed standard would require.
DOE also requests comment on the average manufacturer markup for
single-section and multi-section homes, including any differences in
markup between minimally compliant homes and homes with upgrades that
improve energy performance. Additionally, DOE requests comment on the
average retail markup in the industry.
C. Nationwide Impacts
DOE's NIA projects a net benefit to the nation as a whole as a
result of the proposed rule in terms of NES and the NPV of total
customer costs and savings that would be expected as a result of the
proposed rule in comparison with the minimum requirements of the HUD
Code. DOE calculated the NES and NPV based on annual energy consumption
and total construction and lifecycle cost data from the LCC analysis
(developed during the MH working group negotiation process) described
in section IV.A of this SUPPLEMENTARY INFORMATION and shipment
projections. DOE projected the energy savings, operating cost savings,
equipment costs, and NPV of customer benefits sold in a 30-year period
from 2017 through 2046. The analysis also accounts for costs and
savings for a manufactured home lifetime of 30 years. A detailed
description of the NIA methodology is provided in chapter 11 of the
TSD. DOE requests comment on the methodology and initial findings of
the NIA.
DOE developed a shipments model to forecast the shipments of
manufactured homes during the analysis period. DOE first gathered
historical shipments spanning 1990-2013 from a report developed and
written by the Institute for Building Technology and Safety and
published by the Manufactured Housing Institute.\8\ Then, using the
growth rate (1.8 percent) in new residential housing starts from the
AEO 2015, DOE projected the number of manufactured housing shipments
from 2014 through 2046 in the base case (no new standards adopted by
DOE). For the standards case shipments, DOE used this same growth rate
estimate (1.8 percent), but also applied an estimate for price
elasticity of demand. Price elasticity of demand (price elasticity) is
an economic concept that describes the change of the quantity demanded
in response to a change in price. DOE used the price elasticity value
of -0.48 (a 10-percent price increase would translate to a 4.8-percent
reduction in manufactured home shipment) based on a study published in
the Journal of Housing Economics \9\ for estimating standards case
shipments.
---------------------------------------------------------------------------
\8\ See Manufactured Home Shipments by Product Mix (1990-2013),
Manufactured Housing Institute (2014).
\9\ See Marshall, M.I. & Marsh, T.L. Consumer and investment
demand for manufactured housing units. J. Hous. Econ. 16, 59-71
(2007).
---------------------------------------------------------------------------
In a second sensitivity analysis, DOE also considered a standards
case shipment scenario in which the price elasticity is -2.4 (instead
of -0.48) This would project a 2.4 percent reduction in shipments based
on the projected cost increases in the proposed rule. DOE based this
sensitivity case on previous HUD estimates of -2.4 price elasticity
based on a 1992 paper written by Carol Meeks.\11\ This would translate
to a 12 percent reduction in shipments based on a 5 percent increase in
price as forecasted in the proposed rule.
---------------------------------------------------------------------------
\11\ Meeks, C., 1992, Price Elasticity of Demand for
Manufactured Homes: 1961-1989.
---------------------------------------------------------------------------
A detailed description of the shipments methodology is provided in
chapter 10 of the TSD. DOE requests comment on the methodology and
initial findings of the shipments analysis.
Table IV.6 and Table IV.7 reflect the NES results over a 30-year
analysis period under the proposed rule on a primary energy savings
basis. Primary energy savings apply a factor to account for losses
associated with generation, transmission, and distribution of
electricity. Primary energy savings differ among the different climate
zones because of differing energy conservation requirements in each
climate zone and different shipment projections in each climate zone.
Table IV.6--Cumulative National Energy Savings of Manufactured Homes
Purchased 2017-2046 With a 30-Year Lifetime
------------------------------------------------------------------------
Single-
section Multi- section
(quads) (quads)
------------------------------------------------------------------------
Climate Zone 1.......................... 0.171 0.281
Climate Zone 2.......................... 0.124 0.234
Climate Zone 3.......................... 0.259 0.449
Climate Zone 4.......................... 0.279 0.382
-------------------------------
Total............................... 0.833 1.346
------------------------------------------------------------------------
[[Page 39789]]
Table IV.7--Cumulative National Energy Savings of Manufactured Homes
Purchased 2017-2046 With a 30-Year Lifetime
------------------------------------------------------------------------
Single- Multi- section
section (%) (%)
------------------------------------------------------------------------
Climate Zone 1.......................... 25.3 29.9
Climate Zone 2.......................... 25.4 30.6
Climate Zone 3.......................... 26.0 28.1
Climate Zone 4.......................... 25.4 26.5
-------------------------------
Total............................... 25.6 28.4
------------------------------------------------------------------------
Table IV.8 and Table IV.9 illustrate the cumulative NES over the
30-year analysis period under the proposed rule on a FFC energy savings
basis. FFC energy savings apply a factor to account for losses
associated with generation, transmission, and distribution of
electricity, and the energy consumed in extracting, processing, and
transporting or distributing primary fuels. NES differ amongst the
different climate zones because of differing energy efficiency
requirements in each climate zone and different shipment projections in
each climate zone.
Table IV.8--Cumulative National Energy Savings, Including Full-Fuel-
Cycle of Manufactured Homes Purchased 2017-2046 With a 30-Year Lifetime
------------------------------------------------------------------------
Single-
section Multi- section
(quads) (quads)
------------------------------------------------------------------------
Climate Zone 1.......................... 0.179 0.294
Climate Zone 2.......................... 0.130 0.245
Climate Zone 3.......................... 0.272 0.474
Climate Zone 4.......................... 0.303 0.416
-------------------------------
Total............................... 0.884 1.428
------------------------------------------------------------------------
Table IV.9--Cumulative National Energy Savings, Including Full-Fuel-
Cycle of Manufactured Homes Purchased 2017-2046 With a 30-Year Lifetime
------------------------------------------------------------------------
Single- Multi- section
section (%) (%)
------------------------------------------------------------------------
Climate Zone 1.......................... 25.3 29.9
Climate Zone 2.......................... 25.4 30.6
Climate Zone 3.......................... 26.0 28.1
Climate Zone 4.......................... 25.4 26.6
-------------------------------
Total............................... 25.6 28.3
------------------------------------------------------------------------
Table IV.10 and Table IV.11 illustrate the NPV of customer benefits
over the 30-year analysis period under the proposed rule for a discount
rate of 7 percent and 3 percent respectively. The NPV of manufactured
homeowner benefits differ among the different climate zones because
there are different up-front costs and operating cost savings
associated with each climate zone and different shipment projections in
each climate zone. All climate zones have a positive NPV for both
discount rates under this proposed rule.
Table IV.10--Net Present Value of Manufactured Homes Purchased 2017-2046
With a 30-Year Lifetime at a 7% Discount Rate
------------------------------------------------------------------------
Single-
section Multi- section
(billion (billion
2015$) 2015$)
------------------------------------------------------------------------
Climate Zone 1.......................... 0.19 0.34
Climate Zone 2.......................... 0.16 0.35
Climate Zone 3.......................... 0.39 0.74
Climate Zone 4.......................... 0.52 0.74
-------------------------------
Total............................... 1.26 2.18
------------------------------------------------------------------------
[[Page 39790]]
Table IV.11--Net Present Value of Manufactured Homes Purchased 2017-2046
With a 30-Year Lifetime at a 3% Discount Rate
------------------------------------------------------------------------
Single-
section Multi- section
(billion (billion
2015$) 2015$)
------------------------------------------------------------------------
Climate Zone 1.......................... 0.66 1.16
Climate Zone 2.......................... 0.54 1.10
Climate Zone 3.......................... 1.22 2.26
Climate Zone 4.......................... 1.60 2.24
-------------------------------
Total............................... 4.03 6.75
------------------------------------------------------------------------
DOE considered two sensitivity analyses relating to shipments.
First, DOE considered a shipment scenario in which the growth rate is
6.5 percent (instead of 1.8 percent) based on the trend in actual
manufactured home shipments from 2011 to 2014. This growth rate applies
to both the base case and standards case shipments. DOE's primary
scenario is based on the residential housing start data from AEO 2015.
The sensitivity analysis calculates the increase in NES and NPV
associated with a much larger future market for manufactured homes. See
Table IV.12 for results of the sensitivity analysis. A detailed
description of the sensitivity analysis is provided in appendix 11A of
the TSD. DOE requests comment on the shipment growth rate assumption
used in the shipments analysis.
Table IV.12--Shipments Growth Rate Sensitivity Analysis NES and NPV Results
----------------------------------------------------------------------------------------------------------------
National Net present Net present
energy value 3% value 7%
savings (full discount rate discount rate
fuel cycle (billion (billion
quads) 2015$) 2015$)
----------------------------------------------------------------------------------------------------------------
1.8% Shipment Growth (primary scenario)......................... 2.3 10.93 3.47
6.5% Shipment Growth............................................ 5.8 26.19 7.38
----------------------------------------------------------------------------------------------------------------
In a second sensitivity analysis, DOE considered a standards case
shipment scenario in which the price elasticity is -2.4 (instead of -
0.48). HUD has used an estimate of -2.4 in analysis of revisions to its
regulations \10\ promulgated at 24 CFR 3282 based on a 1992 paper
written by Carol Meeks.\11\ DOE's primary scenario is based on a study
published in 2007 in the Journal of Housing Economics. The sensitivity
analysis calculates the decrease in NES and NPV associated with a
larger decrease in shipments resulting from the more negative price
elasticity value. Price elasticity of -2.4 would translate to a 12
percent reduction in shipments based on a 5 percent increase in price
as projected by the proposed rule. Price elasticity of -0.48 would
project a 2.4 percent reduction in shipments based on the projected
cost increases in this proposed rule. See Table IV.13 for results of
the sensitivity analysis. A detailed description of the sensitivity
analysis is provided in appendix 11A of the TSD. DOE requests comment
on the price elasticity assumption used in the standards case shipments
analysis.
---------------------------------------------------------------------------
\10\ For example, see http://www.regulations.gov/#!documentDetail;D=HUD-2014-0033-0001.
\11\ Meeks, C., 1992, Price Elasticity of Demand for
Manufactured Homes: 1961 to 1989.
Table IV.13--Price Elasticity of Demand Sensitivity Analysis NES and NPV Results
----------------------------------------------------------------------------------------------------------------
National Net present Net present
energy value 3% value 7%
savings (full discount rate discount rate
fuel cycle (billion (billion
quads) 2015$) 2015$)
----------------------------------------------------------------------------------------------------------------
-0.48 Price Elasticity (primary scenario)....................... 2.3 10.93 3.47
-2.4 Price Elasticity........................................... 2.1 10.04 3.19
----------------------------------------------------------------------------------------------------------------
D. Nationwide Environmental Benefits
DOE's analyses indicate that this proposed rule would reduce
overall demand for energy in manufactured housing. The proposed rule
also would produce environmental benefits in the form of reduced
emissions of air pollutants and greenhouse gases associated with
electricity production. Emissions avoided under the proposed rule would
be directly proportional to energy savings that would be achieved. DOE
has based these estimates on a 30-year analysis period of manufactured
home shipments, accounting for a 30-year home lifetime. DOE's analysis
estimates reductions in emissions of six pollutants associated with
energy savings: Carbon dioxide (CO2), mercury (Hg), nitric
oxide and nitrogen dioxide (NOX), sulfur dioxide
(SO2), methane (CH4), and nitrous oxide
(N2O). These reductions are referred to as ``site''
emissions reductions. Furthermore, DOE estimated reductions in
emissions associated with the production of these fuels (extracting,
processing, transporting to power plants or homes). Such reductions are
referred to as
[[Page 39791]]
``upstream'' emissions reductions. Together, site emissions reductions
and upstream emissions reductions account for the FFC. In accordance
with DOE's FFC Statement of Policy (see 76 FR 51282 (Aug. 18, 2011), 77
FR 49701 (Aug. 17, 2012)), the FFC analysis includes impacts on
emissions of CH4 and N2O, both of which are
recognized as greenhouse gases (GHGs).
The emissions reduction estimates are based on emission intensity
factors for each pollutant, which depend on the type of fuel associated
with energy savings (electricity, natural gas, liquefied petroleum gas,
fuel oil). These emission intensity factors were derived from data in
the AEO 2015 \12\ and from the EPA GHG Emissions Factors Hub.\13\ Full
details of this methodology are described in chapter 13 of the TSD.
Table IV.14 reflects the emissions reductions for both single-section
and multi-section manufactured homes. DOE requests comment on the
methodology and initial findings of the emissions analysis.
---------------------------------------------------------------------------
\12\ See Energy Information Administration, Annual Energy
Outlook 2015 with Projections to 2040 (2015), available at http://www.eia.gov/forecasts/aeo/pdf/0383(2015).pdf.
\13\ See U.S. Environmental Protection Agency, Emissions Factors
for Greenhouse Gas Inventories (2014), available at http://www.epa.gov/climateleadership/documents/emission-factors.pdf.
Table IV.14--Emissions Reductions as a Result of the Proposed Rule
------------------------------------------------------------------------
Single- Multi-
Pollutant section section
------------------------------------------------------------------------
Site Emissions Reductions
------------------------------------------------------------------------
CO2 (million metric tons)......................... 56.5 91.1
Hg (metric tons).................................. 0.0904 0.146
NOX (thousand metric tons)........................ 223 356
SO2 (thousand metric tons)........................ 27.6 44.4
CH4 (thousand metric tons)........................ 3.78 6.09
N2O (thousand metric tons)........................ 0.632 1.02
------------------------------------------------------------------------
Upstream Emissions Reductions
------------------------------------------------------------------------
CO2 (million metric tons)......................... 4.01 6.45
Hg (metric tons).................................. 0.000944 0.00153
NOX (thousand metric tons)........................ 51.8 83.2
SO2 (thousand metric tons)........................ 0.615 0.991
CH4 (thousand metric tons)........................ 239 385
N2O (thousand metric tons)........................ 0.0294 0.0474
------------------------------------------------------------------------
Total Emissions Reductions
------------------------------------------------------------------------
CO2 (million metric tons)......................... 60.5 97.6
Hg (metric tons).................................. 0.0913 0.148
NOX (thousand metric tons)........................ 275 439
SO2 (thousand metric tons)........................ 28.2 45.4
CH4 (thousand metric tons)........................ 243 391
N2O (thousand metric tons)........................ 0.661 1.07
------------------------------------------------------------------------
Additionally, DOE considered the estimated monetary benefits likely
to result from the reduced emissions of CO2 and
NOX that would be expected to result from the proposed rule.
In order to make this calculation similar to the calculation of the net
present value of consumer benefit, DOE considered the reduced emissions
expected to result over the lifetime of products shipped in the
analysis period (2017-2046) under the proposed rule. DOE has calculated
the monetary values for each of these emissions using the social cost
of carbon (SCC) methodology, which estimates the monetized damages
associated with an incremental increase in carbon emissions within a
given year. The SCC is intended to account for, but is not limited to,
changes in net agricultural productivity, human health, property
damages from increased flood risk, and the value of ecosystem services.
SCC estimates are given in terms of dollars per metric ton of
CO2 emitted.
The SCC is comprised of monetization estimate results from three
different integrated assessment models, which have different
methodologies for calculating the damages associated with
CO2 emissions. The SCC values used for this rulemaking were
generated using the most recent versions of the three integrated
assessment models that have been published in peer-reviewed
literature.\14\ As a result, four SCC estimates of emitted
CO2 value are available, representing different aggregation
of these three models and utilization of a variety of discount rates.
Three sets of the monetization factors utilize the average impacts
projected by the three assessment models that comprise the SCC. The
fourth set of monetization factors utilizes the 95th percentile impacts
of the three assessment models and is intended to capture higher than
expected impacts. For the purposes of capturing the uncertainty of
emitted CO2 value, the interagency group recommends
including all four sets of available SCC values. Full details of this
methodology are described in chapter 14 of the TSD. These estimates
have been developed by an interagency process and are presented with an
acknowledgement of uncertainty. These results should be treated as
revisable, as the estimates of emitted CO2 monetary value
evolve with improved scientific and economic understanding.
---------------------------------------------------------------------------
\14\ See Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866, Interagency
Working Group on Social Cost of Carbon, United States Government.
May 2013; (revised November 2013), available at www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
---------------------------------------------------------------------------
DOE also has estimated monetary benefits for NOX
emissions under the proposed rule. Estimates of the monetary value of
reducing NOX from stationary sources range from $489 to
$5,023 per metric ton (2015$). DOE calculated monetary benefits using
an intermediate value for NOX emissions of $2,755 per metric
ton (in 2015$), and real discount rates of 3 and 7 percent. DOE is
evaluating appropriate monetization of avoided SO2 and Hg
emissions in energy conservation standards rulemakings and has not
included such monetization in the current analysis. DOE has similarly
not included monetization of reductions in emissions of CH4
or N2O. DOE requests comments on the methodology and results
of the monetization of emissions reductions benefits analysis. Table
IV.15 provides the NPVs from the savings of reduced CO2 and
NOX emissions resulting from manufactured homes built in
accordance with the proposed rule.
[[Page 39792]]
Table IV.15--Net Present Value of Monetized Benefits From CO2 and NOX Emissions Reductions Under the Proposed
Rule
----------------------------------------------------------------------------------------------------------------
Net present value (million
Discount rate 2015$)
(%) -------------------------------
Single-section Multi-section
----------------------------------------------------------------------------------------------------------------
Monetary Benefits
----------------------------------------------------------------------------------------------------------------
CO2, Average SCC Case........................................... 5 368.2 593.7
CO2, Average SCC Case........................................... 3 1,810.9 2,920.5
CO2, Average SCC Case........................................... 2.5 2,925.0 4,717.3
CO2, 95th Percentile SCC Case................................... 3 5,581.5 9,001.5
NOX Reduction................................................... 3 311.5 498.6
7 119.8 191.9
----------------------------------------------------------------------------------------------------------------
E. Total Benefits and Costs
As explained in greater detail in section IV of this SUPPLEMENTARY
INFORMATION and in chapter 15 of the TSD, Table IV.16 reflects the
total benefits and costs (from the manufactured homeowner's
perspective) associated with the proposed rule, expressed in terms of
annualized values.\15\
---------------------------------------------------------------------------
\15\ As stated above, DOE used a two-step calculation process to
convert the time-series of costs and benefits into annualized
values. First, DOE calculated a present value in 2015, the year used
for discounting the net present value of total consumer costs and
savings, for the time-series of costs and benefits using discount
rates of three and seven percent for all costs and benefits except
for the value of CO2 reductions. For the latter, DOE used
a range of discount rates, as shown in Table IV.16. From the present
value, DOE then calculated the fixed annual payment over a 30-year
period, starting in 2017 that yields the same present value. The
fixed annual payment is the annualized value. Although DOE
calculated annualized values, this does not imply that the time-
series of cost and benefits from which the annualized values were
determined would be a steady stream of payments.
Table IV.16--Total Annualized Benefits and Costs to Manufactured Homeowners Under the Proposed Rule
--------------------------------------------------------------------------------------------------------------------------------------------------------
Monetized (million 2015$/year)
---------------------------------------------------------------------------------------------------------------------
Discount rate (%) Primary estimate ** Low estimate ** High estimate **
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Operating (Energy) Cost Savings... 7............................... 516....................... 400....................... 688.
3............................... 843....................... 617....................... 1,191.
CO2, Average SCC Case ***......... 5............................... 63........................ 46........................ 85.
CO2, Average SCC Case ***......... 3............................... 241....................... 176....................... 331.
CO2, Average SCC Case ***......... 2.5............................. 365....................... 266....................... 503.
CO2, 95th Percentile SCC Case ***. 3............................... 744....................... 543....................... 1,022.
NOX Reduction at $2,773/metric ton 7............................... 25........................ 20........................ 32.
***.
3............................... 41........................ 31........................ 56.
Total (Operating Cost Savings, CO2 7 plus CO2 range................ 604 to 1,285.............. 466 to 962................ 805 to 1,742.
Reduction and NOX Reduction). 7............................... 783....................... 596....................... 1,052.
1,126..................... 824....................... 1,578.
2............................... 947 to 1,628.............. 694 to 1,191.............. 1,332 to 2,269.
3 plus CO2 range................
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Incremental Purchase Price 7............................... 220....................... 165....................... 285.
Increase.
3............................... 277....................... 192....................... 378.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits/Costs *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total (Operating Cost Savings, CO2 7 plus CO2 range................ 384 to 1,065.............. 301 to 797................ 520 to 1,457.
Reduction and NOX Reduction, 7............................... 563....................... 431....................... 767.
Minus Incremental Cost Increase 849....................... 632....................... 1,200.
to Homes).
3............................... 670 to 1,351.............. 502 to 999................ 954 to 1,891.
3 plus CO2 range................
--------------------------------------------------------------------------------------------------------------------------------------------------------
* The benefits and costs are calculated for homes shipped 2017-2046.
** The Primary, Low, and High Estimates utilize forecasts of energy prices from the 2015_AEO Reference case, Low Economic Growth case, and High Economic
Growth case, respectively.
*** The CO2 values represent global monetized values (in 2015$) of the social cost of CO2 emissions reductions over the analysis period under several
different scenarios of the SCC model. The ``average SCC case'' refers to average predicted monetary savings as predicted by the SCC model. The ``95th
percentile case'' refers to values calculated using the 95th percentile impacts of the SCC model, which accounts for greater than expected
environmental damages. The value for NOX (in 2015$) is the average of the low and high values used in DOE's analysis.
[[Page 39793]]
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in
the future global climate and the potential resulting damages to the
world economy continues to evolve rapidly. Thus, any value placed in
this proposed rulemaking on reducing CO2 emissions is
subject to change. DOE, together with other federal agencies, will
continue to review various methodologies for estimating the monetary
value of reductions in CO2 and other GHG emissions. This
ongoing review will consider any comments on this subject that are part
of the public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this proposed
rulemaking the most recent values and analyses resulting from the
ongoing interagency review process.
Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating savings are domestic U.S.
consumer monetary savings that would occur as a result of market
transactions, while the value of CO2 reductions is based on
a global value. Second, the assessments of operating cost savings and
CO2 savings are performed with different methods that use
quite different time frames for analysis. The national operating cost
savings is measured for the lifetime of manufactured homes shipped in
the 30-year period after the compliance date. The SCC values, on the
other hand, reflect the present value of future climate-related impacts
resulting from the emission of one ton of CO2 in each year.
These impacts would go well beyond 2100.
V. Regulatory Review
A. Executive Order 12866
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that this proposed standards address are as follows:
(1) Under current federal standards, manufactured homes typically
conserve less energy than comparably built site-built and modular
homes, and.
(2) There are external benefits resulting from improved energy
conservation in manufactured housing. These benefits include
externalities related to environmental protection and energy security
that are not reflected in energy prices, such as reduced emissions of
greenhouse gases.
DOE has determined that this regulatory action is an ``economically
significant regulatory action'' under section 3(f)(1) of Executive
Order 12866. Accordingly, section 6(a)(3) of the Executive Order
requires that DOE prepare a regulatory impact analysis (RIA) on this
proposed rule and that the Office of Information and Regulatory Affairs
(OIRA) in OMB review this proposed rule. DOE has presented the proposed
rule and supporting documents, including the RIA, to OIRA for review
and has included these documents in the rulemaking record. The
assessments prepared pursuant to Executive Order 12866 can be found in
chapter 11 of the TSD for this rulemaking. They are available for
public review in the Resource Room of DOE's Building Technologies
Program, 950 L'Enfant Plaza SW., Suite 600, Washington, DC 20024, (202)
586-2945, between 9:00 a.m. and 4:00 p.m., Monday through Friday,
except federal holidays.
DOE also has reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011).
Executive Order 13563 is supplemental to and reaffirms the principles,
structures, and definitions governing regulatory review established in
Executive Order 12866. To the extent permitted by law, federal agencies
are required by these Executive Orders to, among other things:
(1) Propose or adopt a regulation only upon a reasoned
determination that its benefits justify its costs (recognizing that
some benefits and costs are difficult to quantify);
(2) Tailor regulations to impose the least burden on society,
consistent with obtaining regulatory objectives, taking into account,
among other things, and to the extent practicable, the costs of
cumulative regulations;
(3) Select, in choosing among alternative regulatory approaches,
those approaches that maximize net benefits (including potential
economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity);
(4) To the extent feasible, specify performance objectives, rather
than specifying the behavior or manner of compliance that regulated
entities must adopt; and
(5) Identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
For the reasons stated in the chapter 11 of the TSD and in section
III of the document, DOE believes that this proposed rule is consistent
with these principles.
B. Executive Order 13563
DOE has also reviewed this regulation pursuant to Executive Order
13563 (see 76 FR 3281, Jan. 21, 2011), which is supplemental to, and
explicitly reaffirms the principles, structures, and definitions
governing regulatory review established in Executive Order 12866. To
the extent permitted by law, agencies are required by Executive Order
13563 to: (1) Propose or adopt a regulation only upon a reasoned
determination that its benefits justify its costs (recognizing that
some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes that Executive Order 13563 requires agencies ``to
use the best available techniques to quantify anticipated present and
future benefits and costs as accurately as possible.'' In its guidance,
the Office of Information and Regulatory Affairs has emphasized that
such techniques may include ``identifying changing future compliance
costs that might result from technological innovation or anticipated
behavioral changes.'' This proposed rule is consistent with these
principles, including that, to the extent permitted
[[Page 39794]]
by law, agencies adopt a regulation only upon a reasoned determination
that its benefits justify its costs and select, in choosing among
alternative regulatory approaches, those approaches that maximize net
benefits.
C. Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (Aug. 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's Web site (www.energy.gov/gc/office-general-counsel). DOE has
prepared the following IRFA for small manufacturers of manufactured
homes that are the subject of this proposed rulemaking.
For the manufacturers of manufactured homes, the Small Business
Administration (SBA) has set a size threshold, which defines those
entities classified as ``small businesses'' for the purposes of the
statute. DOE used the SBA's small business size standards to determine
whether any small entities would be subject to the requirements of the
rule. 65 FR 30836, 30848 (May 15, 2000), as amended at 65 FR 53533,
53544 (Sept. 5, 2000) and codified at 13 CFR part 121. The size
standards are listed by NAICS code and industry description and are
available at http://www.sba.gov/content/table-small-business-size-standards. The covered manufacturers are classified under NAICS 321991,
``Manufactured Home (Mobile Home) Manufacturing.'' The SBA sets a
threshold of 500 employees or less for an entity to be considered as a
small business for this category.
DOE reviewed the potential standards considered in this NOPR under
the provisions of the Regulatory Flexibility Act and the procedures and
policies published on February 19, 2003. To better assess the potential
impacts of this rulemaking on small entities, DOE conducted a more
focused inquiry of the companies that could be small business
manufacturers of manufactured homes. During its market survey, DOE used
available public information to identify potential small manufacturers.
DOE's research involved industry trade association membership
directories, information from previous rulemakings, individual company
Web sites, and market research tools (e.g., Hoover's reports) to create
a list of companies that manufacture or sell manufactured homes covered
by this rulemaking.
To assess the potential impacts of this rulemaking on small
entities, DOE conducted a focused inquiry of the companies that could
be small business manufacturers of manufactured homes. During its
market survey, DOE used available public information to identify
potential small manufacturers. DOE's research involved individual
company Web sites and market research tools (e.g., Hoovers reports
\16\) to create a list of companies that manufacture homes covered by
this rulemaking. DOE also asked stakeholders and industry
representatives if they were aware of any other small manufacturers.
---------------------------------------------------------------------------
\16\ Hoovers. http://www.hoovers.com/.
---------------------------------------------------------------------------
DOE identified forty-six manufacturers of manufactured homes. Of
the forty-six, DOE identified twenty-five manufacturers that qualified
as small businesses. All small manufacturers identified are domestic
manufacturers. DOE contacted all 25 identified manufactured home
manufacturers for interviews. DOE spoke with two small manufacturers.
During discussions with small manufacturers, DOE asked
participating companies to describe their major concerns with regard to
the rulemaking. The primary concern cited by small manufacturers was
the potential for an energy conservation standard to result in a
shrinking market for manufactured homes. Manufacturers noted two
possible reasons. First, they were concerned that the standard would be
set at a level where the economics do not make sense for the home
purchaser. One manufacturer specifically requested the Department
perform an analysis that showed the proposed level would result in
cost-savings for the home owner. Second, the manufacturers noted the
possibility that cost increases for the baseline homes could
potentially price out some consumers, specifically lower income
consumers. One of the small manufacturers noted that the market for the
minimally compliant homes is dominated by much larger manufacturers. In
particular, they noted Clayton Homes is the biggest player in that
market with roughly half of the overall market for manufactured homes.
Based on HUD data, research reports, and SEC filings, as described
in section IV.C and chapter 12 of the TSD, DOE understands the retail
prices, markups, and manufacturer production costs used in its
manufacturer impact analysis are representative of the industry. DOE
estimates that the proposed rule would reduce INPV by 0.4 to 5.1
percent. DOE did not receive sufficient quantitative data to conclude
that small manufacturer would experience impacts that are substantially
different from the industry-at-large.
Since the proposed standards could cause competitive concerns for
small manufacturers, DOE cannot certify that the proposed standards
would not have a significant impact on a substantial number of small
businesses. DOE requests additional information and data regarding the
number and market share of domestic small manufacturers of manufactured
homes. DOE also requested information on the conversion costs small
manufacturers would face and on other potential small business impacts
related to the proposed energy conservation standards.
D. Paperwork Reduction Act
This rulemaking does not include any information collection
requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C.
3501 et seq.).
E. National Environmental Policy Act
DOE is preparing a draft Environmental Assessment (EA) pursuant to
the Council on Environmental Quality's Regulations for Implementing the
Procedural Provisions of the National Environmental Policy Act (40 CFR
parts 1500-1508), the National Environmental Policy Act of 1969, as
amended (42 U.S.C. 4321 et seq.), DOE's National Environmental Policy
Act (NEPA) Implementing Procedures (10 CFR part 1021), and DOE Order
451.1B. DOE is preparing the draft EA in parallel with this rulemaking,
and it will be posted to the DOE Web site separately. Reduced emissions
of air pollutants and greenhouse gases associated with electricity
production and fuel usage are discussed in section IV.D of this
SUPPLEMENTARY INFORMATION.
F. Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4,
1999), imposes certain requirements on agencies formulating and
implementing policies or regulations that preempt state law or that
have federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the states and
to carefully assess the necessity for such actions. The
[[Page 39795]]
Executive Order also requires agencies to have a process to ensure
meaningful and timely input by state and local officials in the
development of regulatory policies that have federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations (65 FR 13735).
DOE has examined this action and has determined that it will not
pre-empt State law. This action impacts energy efficiency requirements
for manufacturers of manufactured homes. Accordingly, no further action
is required by Executive Order 13132.
G. Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' 61 FR 4729 (February 7, 1996), imposes on
Executive agencies the general duty to adhere to the following
requirements: (1) Eliminate drafting errors and ambiguity; (2) write
regulations to minimize litigation; and (3) provide a clear legal
standard for affected conduct, rather than a general standard, and
promote simplification and burden reduction. Regarding the review
required by section 3(a), section 3(b) of Executive Order 12988
specifically requires that Executive agencies make every reasonable
effort to ensure that the regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly specifies any effect on existing
federal law or regulation; (3) provides a clear legal standard for
affected conduct, while promoting simplification and burden reduction;
(4) specifies the retroactive effect, if any; (5) adequately defines
key terms; and (6) addresses other important issues affecting clarity
and general draftsmanship under any guidelines issued by the Attorney
General. Section 3(c) of Executive Order 12988 requires Executive
agencies to review regulations in light of applicable standards in
sections 3(a) and 3(b) to determine either that those standards are met
or it is unreasonable to meet one or more of them. DOE has completed
the required review and preliminarily has determined that, to the
extent permitted by law, this proposed rule meets the relevant
standards of Executive Order 12988.
H. Unfunded Mandates Reform Act
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each federal agency to assess the effects of federal
regulatory actions on state, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For an amended regulatory action likely to result in a rule that may
cause the expenditure by state, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
See 2 U.S.C. 1532(a), (b). The UMRA also requires a federal agency to
develop an effective process to permit timely input by elected officers
of state, local, and Tribal governments on a ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. See 62 FR 12820. DOE's
policy statement is also available at http://energy.gov/gc/office-general-counsel.
This proposed rule does not contain a federal intergovernmental or
private sector mandate, as those terms are defined in UMRA.
I. Family and General Government Appropriations Act
Section 654 of the Family and General Government Appropriations Act
of 1999 (Pub. L. 105-277) requires federal agencies to issue a Family
Policymaking Assessment for any proposed rule that may affect family
well-being. This proposed rule would not have any impact on the
autonomy or integrity of the family as an institution. Accordingly, DOE
has preliminarily concluded that it is not necessary to prepare a
Family Policymaking Assessment.
J. Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights,'' 53 FR 8859 (March 18, 1988), that this proposed rule would
not result in any takings that might require compensation under the
Fifth Amendment to the U.S. Constitution.
K. Treasury and General Government Appropriations Act
Section 515 of the Treasury and General Government Appropriations
Act of 2001 (44 U.S.C. 3516, note) provides for agencies to review most
disseminations of information to the public under guidelines
established by each agency pursuant to general guidelines issued by
OMB. OMB's guidelines were published at 67 FR 8452 (February 22, 2002),
and DOE's guidelines were published at 67 FR 62446 (October 7, 2002).
DOE has reviewed this proposed rule under the OMB and DOE guidelines
and preliminarily has concluded that it is consistent with applicable
policies in those guidelines.
L. Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires federal agencies to prepare and submit to OIRA
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgates or is expected to lead to promulgation of a
final rule or regulation, and that: (1) Is a significant regulatory
action under Executive Order 12866, or any successor order; and (2) is
likely to have a significant adverse effect on the supply,
distribution, or use of energy; or (3) is designated by the
Administrator of OIRA as a significant energy action. For any proposed
significant energy action, the agency must give a detailed statement of
any adverse effects on energy supply, distribution, or use should the
proposal be implemented, and of reasonable alternatives to the action
and their expected benefits on energy supply, distribution, and use.
DOE preliminarily has concluded that this regulatory action, which
sets forth energy conservation standards for manufactured homes, is not
a significant energy action because the proposed standards are not
likely to have a significant adverse effect on the supply,
distribution, or use of energy, nor has it been designated as such by
the Administrator at OIRA. Accordingly, DOE has not prepared a
Statement of Energy Effects for this proposed rule.
M. Section 32 of the Federal Energy Administration Act of 1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91), DOE must comply with section 32 of the Federal Energy
Administration Act of 1974, as amended by the Federal Energy
Administration Authorization Act of 1977 (15 U.S.C. 788). Section 32
provides in part that, where a proposed rule contains or involves use
of commercial standards, the rulemaking
[[Page 39796]]
must inform the public of the use and background of such standards.
The rule proposed in this notice incorporates testing methods
contained in the following commercial standards: The ACCA ``Manual J--
Residential Load Calculation (8th Edition)'' (ACCA Manual J); the ACCA
``Manual S--Residential Equipment Selection (2nd Edition)'' (ACCA
Manual S); and the PNNL ``Overall U-Values and Heating/Cooling Loads--
Manufactured Homes'' (Overall U-Values and Heating/Cooling Loads--
Manufactured Homes).
DOE has evaluated these standards and is unable to conclude whether
they fully comply with the requirements of section 32(b) of the Federal
Energy Administration Act of 1974, as amended. DOE will consult with
the Attorney General and the Chairman of the Federal Trade Commission
before prescribing a final rule concerning the impact on competition of
requiring manufacturers to use the methods contained in these standards
to test various components of manufactured homes.
N. Materials Incorporated by Reference
In this NOPR, DOE proposes to incorporate by reference the test
standard published by ACCA, titled ``Manual J--Residential Load
Calculation (8th Edition).'' ACCA Manual J is an industry accepted
standard for calculating the heating and cooling load associated with a
building. DOE proposes requiring building heating and cooling loads to
be calculated (for purposes of equipment sizing) in accordance with
ACCA Manual J. ACCA Manual J is readily available on ACCA's Web site at
http://www.acca.org/.
DOE also proposes to incorporate by reference the test standard
published by ACCA, titled ``Manual S--Residential Equipment Selection
(2nd Edition).'' ACCA Manual S is an industry accepted standard for
calculating the appropriate heating and cooling equipment size for a
building. DOE proposes requiring building heating and cooling equipment
to be sized in accordance with ACCA Manual S. ACCA Manual S is readily
available on ACCA's Web site at http://www.acca.org/.
DOE also proposes to incorporate by reference the test standard
titled ``Overall U-Values and Heating/Cooling Loads--Manufactured
Homes'' written by Conner C.C., Taylor, Z.T. of Pacific Northwest
Laboratory. This test standard (often referred to as the Battelle
Method) is an industry accepted method for calculating the overall
thermal transmittance of a manufactured home. DOE proposes requiring
manufactured housing manufacturers to calculate the overall thermal
transmittance of a manufactured home in accordance with this test
standard. This test standard is readily available on the U.S.
Department of Housing and Urban Development's Web site at http://www.huduser.org/portal/publications/manufhsg/uvalue.html.
VI. Public Participation
A. Attendance at Public Meeting
The time, date, and location of the public meeting are listed in
the DATES and ADDRESSES sections at the beginning of this document. If
you plan to attend the public meeting, please notify Ms. Brenda Edwards
at (202) 586-2945 or [email protected]. As explained in the
ADDRESSES section, foreign nationals visiting DOE Headquarters are
subject to advance security screening procedures.
B. Procedure for Submitting Prepared General Statements for
Distribution
Any person who has plans to present a prepared general statement
may request that copies of his or her statement be made available at
the public meeting. Such persons may submit requests, along with an
advance electronic copy of their statement in PDF (preferred),
Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to
the appropriate address shown in the ADDRESSES section at the beginning
of this notice. The request and advance copy of statements must be
received at least one week before the public meeting and may be
emailed, hand-delivered, or sent by U.S. mail. DOE prefers to receive
requests and advance copies via email. Please include a telephone
number to enable DOE staff to make follow-up contact, if needed.
C. Conduct of Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also use a professional facilitator to aid discussion. A court
reporter will be present to record the proceedings and prepare a
transcript. DOE reserves the right to schedule the order of
presentations and to establish the procedures governing the conduct of
the public meeting. After the public meeting, interested parties may
submit further comments on the proceedings as well as on any aspect of
the rulemaking until the end of the comment period.
The public meeting will be conducted in an informal, conference
style. DOE will present summaries of comments received before the
public meeting, allow time for prepared general statements by
participants, and encourage all interested parties to share their views
on issues affecting this rulemaking. Each participant will be allowed
to make a general statement (within time limits determined by DOE),
before the discussion of specific topics. DOE will permit, as time
permits, other participants to comment briefly on any general
statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly and comment on
statements made by others. Participants should be prepared to answer
questions by DOE and by other participants concerning these issues. DOE
representatives also may ask questions of participants concerning other
matters relevant to this rulemaking. The official conducting the public
meeting will accept additional comments or questions from those
attending, as time permits. The presiding official will announce any
further procedural rules or modification of the above procedures that
may be needed for the proper conduct of the public meeting.
A transcript of the public meeting will be included in the docket,
which can be viewed as described in the DOCKET section at the beginning
of this proposed rulemaking. In addition, any person may buy a copy of
the transcript from the transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. Interested parties may submit comments using any of the methods
described in the ADDRESSES section at the beginning of this proposed
rule.
1. Submitting Comments via Regulations.gov
The regulations.gov Web page will require you to provide your name
and contact information. Your contact information will be viewable to
DOE Building Technologies staff only. Your contact information will not
be publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
[[Page 39797]]
However, your contact information will be publicly viewable if you
include it in the comment or in any documents attached to your comment.
Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
comment. Persons viewing comments will see only first and last names,
organization names, correspondence containing comments, and any
documents submitted with the comments.
Do not submit to regulations.gov information for which disclosure
is restricted by statute, such as trade secrets and commercial or
financial information (hereinafter referred to as Confidential Business
Information (CBI)). Comments submitted through regulations.gov cannot
be claimed as CBI. Comments received through the Web site will waive
any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section
below.
DOE processes submissions made through regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that regulations.gov
provides after you have successfully uploaded your comment.
2. Submitting Comments via Email, Hand Delivery, or Mail
Comments and documents submitted via email, hand delivery, or mail
also will be posted to regulations.gov. If you do not want your
personal contact information to be publicly viewable, do not include it
in your comment or any accompanying documents. Instead, provide your
contact information on a cover letter. Include your first and last
names, email address, telephone number, and optional mailing address.
The cover letter will not be publicly viewable as long as it does not
include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. Email submissions are
preferred. If you submit via mail or hand delivery, please provide all
items on a CD, if feasible. It is not necessary to submit printed
copies. No facsimiles (faxes) will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, written in English, and are free of any defects or
viruses. Documents should not contain special characters or any form of
encryption and, if possible, they should carry the electronic signature
of the author.
Campaign Form Letters
Please submit campaign form letters by the originating organization
in batches of between 50 to 500 form letters per PDF or as one form
letter with a list of supporters' names compiled into one or more PDFs.
This reduces comment processing and posting time.
Confidential Business Information
According to 10 CFR 1004.11, any person submitting information that
he or she believes to be confidential and exempt by law from public
disclosure should submit via email, postal mail, or hand delivery two
well-marked copies: one copy of the document marked confidential
including all the information believed to be confidential, and one copy
of the document marked non-confidential with the information believed
to be confidential deleted. Submit these documents via email or on a
CD, if feasible. DOE will make its own determination about the
confidential status of the information and treat it according to its
determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items, (2) whether and why such items are customarily treated as
confidential within the industry, (3) whether the information is
generally known by or available from other sources, (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality, (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure, (6) when such information might lose its
confidential character due to the passage of time, and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. Relationship With the HUD Code
Potential inconsistencies or conflicts between the proposed rule
and the HUD Code, as discussed in detail in section II.B.1 of this
document.
2. Scope and Effective Date
The scope and effective date of the proposed rule, as discussed in
section III.B.1.a) of the document. DOE requests comment on whether a
one-year compliance period would be sufficient for manufacturers to
transition their designs, materials, and factory operations and
processes in order to comply with the finalized DOE energy conservation
standards and for DOE to develop and implement regulations to enforce
its standards. DOE also requests comments on what additional lead time
should be allowed if it elects to use HUD's existing enforcement
system, which would require HUD to adopt the energy standards resulting
from this rulemaking. The agency also requests comment on whether there
are any particular timing considerations that the agency should
consider due to manufacturers choosing to comply with either the
prescriptive or thermal envelope compliance paths.
3. Definitions
Proposed additions, exclusions, modifications, and potential
inconsistencies among the definitions proposed under this rule, the HUD
Code, and the 2015 IECC, as discussed in section III.B.1.b) of this
document.
4. Air Barrier
Potential clarification on the meaning of the term ``air barrier,''
as discussed in section III.B.1.b) of this document.
5. Tubular Daylighting Devices
Whether to include tubular daylighting devices in the definition of
the term ``fenestration,'' as discussed in section III.B.1.b) of this
document.
6. Climate Zones
The proposal to establish four climate zones and the specific
categorization of states and counties included in each climate zone, as
discussed in section III.B.2.a) of this SUPPLEMENTARY INFORMATION and
chapter 4 of the TSD. DOE also requests comment on the proposed use of
four climate zones relative to adopting the three HUD climate zones and
whether there are any potential impacts on manufacturing costs,
compliance costs, or other impacts, in particular in Arizona, Texas,
Louisiana, Mississippi, Alabama, and
[[Page 39798]]
Georgia, where the agency has proposed two different energy efficiency
standards within the same state.
7. Home Size
The proposal to establish separate requirements for single- and
multi-section manufactured homes, as discussed in section III.B.2.a) of
this document.
8. Paths for Compliance With the Building Thermal Envelope Standards
The proposal to establish prescriptive and performance options for
achieving compliance with the proposed building thermal envelope
requirements, the requirements of each option, and their equivalency in
terms of overall thermal performance, as discussed in section
III.B.2.b) of this SUPPLEMENTARY INFORMATION and chapter 6 of the TSD.
9. Insulated Siding
The proposal to include a requirement similar to section R402.1.3
of the 2015 IECC while excluding the insulated siding specification, as
discussed in section III.B.2.b) of this document.
10. U-Factor Alternatives
11. The proposed U-factor alternatives and their equivalency with the
prescriptive R-value requirements for ceiling, wall, and floor
insulation, as discussed in section III.B.2.b) of this document.
12. Calculation of Average SHGC
The proposal to include an area-weighted average calculation of
SHGC for compliance with Sec. 460.102(c), as discussed in section
III.B.2.b) of this document.
13. Insulation Installation Requirements for Floors
Whether the insulation installation requirements in Sec. 460.103,
including installation of insulation in floors, may be readily
implemented by the manufactured housing industry, as discussed in
section III.B.2.c) of this document.
14. Design Criteria for Envelope Sealing
The effectiveness of the prescriptive building thermal envelope
sealing requirements, as discussed in section III.B.2.d) of this
SUPPLEMENTARY INFORMATION.
15. Impact of Envelope Sealing on Indoor Air Quality
The potential impacts associated with the reduction in levels of
natural air infiltration (through sealing leaks in the building thermal
envelope), if any, relative to the minimum requirements of the HUD Code
on reduced indoor air quality, the importance of natural air
infiltration for whole-house ventilation strategies in manufactured
housing, the relationship between the proposed standards and the
mechanical ventilation requirements under the HUD Code, the basis by
which the ICC determines a whole-house ventilation strategy is safe,
and the minimum total air flow (in ACH units) through a manufactured
home that is required to adequately protect public health and safety,
as discussed in section V.E of this document.
16. Duct Sealing
The proposed duct sealing and duct leakage requirements, as
discussed in section III.B.3.a) of this document.
17. Thermostats and Controls
The proposed requirements for thermostats and controls, and any
potential inconsistencies with the HUD Code, as discussed in III.B.3.b)
of this document.
18. Demand Recirculation Systems
The initial decision not to propose requirements related to demand
recirculation systems in this rule, as discussed in section III.B.3.c)
of this document.
19. Drain Water Heat Recovery Units
The initial decision not to propose requirements related to drain
water heat recovery units, as discussed in section III.B.3.c) of this
document.
20. Equipment Sizing
The proposed requirements for equipment sizing and the
applicability of ACCA Manuals S and J, as discussed in section
III.B.3.e) of this document.
21. Lighting Equipment Standards
The initial determination not to propose lighting equipment
standards specific to manufactured housing, as discussed in section
III.C.6 of this document.
22. Simulated Performance Alternative
The exclusion of a simulated performance alternative as a pathway
to compliance, as discussed in section III.C.7 of this document.
23. Waivers and Exception Relief
A process for authorizing manufacturers to obtain waivers or
exception relief from the energy conservation requirements, as
discussed in section II.B.3 of this document.
24. Compliance and Enforcement Program Options
The potential options DOE may consider in a future rulemaking
regarding compliance and enforcement, as discussed in section III.E of
this document.
25. Compliance and Enforcement Program Costs and Time Requirements
The estimated costs (only direct compliance and enforcement costs,
not engineering costs for redesign) and time (design compliance review,
inspection frequency and duration, administrative procedures)
associated with the potential compliance and enforcement options, as
discussed in section III.E of this document.
26. Increased Costs of Components
The assumptions underlying DOE's analyses associated with the
increased costs of manufactured home components, as discussed in
section IV.A of this document.
27. Lifecycle Cost Analysis
The methodology and initial findings of the lifecycle cost
analysis, as discussed in IV.A of this SUPPLEMENTARY INFORMATION and
chapter 8 of the TSD.
28. Affordability
The affordability of the proposed rule, with respect to the
increased purchase cost, reduced operating costs (energy bills), and
total lifecycle cost, as discussed in IV.A of this SUPPLEMENTARY
INFORMATION and chapter 8 of the TSD.
29. Manufacturer Impacts Analysis--Markups
Whether manufacturer and retailer mark-ups for the base-case and
standards case other than the primary estimate should be considered.
(e.g., a combined mark-up of 2.30 has historically been used in the
past to assess combined manufacturer and retailer mark-ups to determine
potential first cost impacts on consumers), as discussed in IV.B of
this SUPPLEMENTARY INFORMATION and chapter 12 of the TSD.
30. Shipments Analysis
The methodology and initial findings of the shipments analysis, as
discussed in section IV.B of this SUPPLEMENTARY INFORMATION and chapter
10 of the TSD.
31. Shipment Growth Rate
The estimate of the future growth rate of manufactured home
shipments, as discussed in section IV.C of this SUPPLEMENTARY
INFORMATION and chapter 10 and appendix 11A of the TSD.
32. Price Elasticity
The estimate of the price elasticity of demand of manufactured
homes, as
[[Page 39799]]
discussed in section IV.C of this SUPPLEMENTARY INFORMATION and chapter
10 and appendix 11A of the TSD.
33. National Impacts Analysis
The methodology and initial findings of the national impacts
analysis, as discussed in section IV.C of this SUPPLEMENTARY
INFORMATION and chapter 11 of the TSD.
34. Emissions Analysis
The methodology and results of the emissions analysis and the
proper monetization of emissions, as discussed in section IV.D of this
SUPPLEMENTARY INFORMATION and chapter 13 of the TSD.
VII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this notice of
proposed rulemaking.
List of Subjects in 10 CFR Part 460
Administrative practice and procedure, Buildings and facilities,
Energy conservation, Housing standards, Incorporation by reference,
Reporting and recordkeeping requirements.
Issued in Washington, DC, on May 20, 2016.
David Friedman,
Principal Deputy Assistant Secretary, Energy Efficiency and Renewable
Energy.
For the reasons stated in the preamble, DOE proposes to add part
460 of title 10 of the Code of Federal Regulations as set forth below:
PART 460--ENERGY CONSERVATION STANDARDS FOR MANUFACTURED HOMES
Subpart A--General
Sec.
460.1 Scope.
460.2 Definitions.
460.3 Materials incorporated by reference.
Subpart B--Building Thermal Envelope
460.101 Climate zones.
460.102 Building thermal envelope requirements.
460.103 Installation of insulation.
460.104 Building thermal envelope air leakage.
Subpart C--HVAC, Service Water Heating, and Equipment Sizing
460.201 Duct systems.
460.202 Thermostats and controls.
460.203 Service water heating.
460.204 Mechanical ventilation fan efficacy.
460.205 Equipment sizing.
Authority: 42 U.S.C. 17071; 42 U.S.C. 7101 et seq.
Subpart A--General
Sec. 460.1 Scope.
This subpart establishes energy conservation standards for
manufactured homes. A manufactured home that is manufactured on or
after the date one year following issuance of the final rule must
comply with all applicable requirements of this part.
Sec. 460.2 Definitions.
As used in this part--
Accessible means admitting close approach as a result of not being
guarded by locked doors, elevation, or other effective means.
Air barrier means material or materials assembled and joined
together to provide a barrier to air leakage through the building
thermal envelope.
Automatic means self-acting or operating by its own mechanism when
actuated by some impersonal influence.
Building thermal envelope means exterior walls, floor, ceiling or
roof, and any other building elements that enclose conditioned space or
provide a boundary between conditioned space and unconditioned space.
Ceiling means an assembly that supports and forms the overhead
interior surface of a building or room that covers its upper limit and
is horizontal or tilted at an angle less than 60 degrees (1.05 rad)
from horizontal.
Circulating hot water system means a water distribution system in
which one or more pumps are operated in the service hot water piping to
circulate heated water from the water heating equipment to fixtures and
back to the water heating equipment.
Climate zone means a geographical region identified in Sec.
460.101.
Conditioned space means an area, room, or space that is enclosed
within the building thermal envelope and that is directly heated or
cooled, or an area, room, or space that has a fixed opening directly
into an adjacent area, room, or space that is enclosed within the
building thermal envelope and that is directly heated or cooled.
Continuous air barrier means a combination of materials and
assemblies that restrict or prevent the passage of air from conditioned
space to unconditioned space.
Door means an operable barrier used to block or allow access to an
entrance of a manufactured home.
Dropped ceiling means a secondary nonstructural ceiling, hung below
the main ceiling.
Dropped soffit means a secondary nonstructural ceiling that is hung
below the ceiling and that covers only a portion of the ceiling.
Duct means a tube or conduit, except an air passage within a self-
contained system, utilized for conveying air to or from heating,
cooling, or ventilating equipment.
Duct system means a continuous passageway for the transmission of
air that, in addition to ducts, includes duct fittings, dampers,
plenums, fans, and accessory air-handling equipment and appliances.
Eave means the edge of the roof that overhangs the face of a wall
and normally projects beyond the side of the manufactured home.
Equipment includes material, appliances, devices, fixtures,
fittings, or accessories both in the construction of, and in the
plumbing, heating, cooling, and electrical systems of, a manufactured
home.
Exterior wall means a wall that separates conditioned space from
unconditioned space.
Fenestration means vertical fenestration and skylights.
Floor means a horizontal assembly that supports and forms the lower
interior surface of a building or room upon which occupants can walk.
Glazed or glazing means an infill material, including glass,
plastic, or other transparent or translucent material, used in
fenestration.
Infiltration means the uncontrolled air leakage into a manufactured
home caused by the pressure effects of wind and/or the effect of
differences in the indoor and outdoor air density.
Insulation means material deemed to be insulation under 16 CFR
460.2.
Manufactured home means a structure, transportable in one or more
sections, which in the traveling mode is 8 body feet or more in width
or 40 body feet or more in length or which when erected on-site is 320
or more square feet, and which is built on a permanent chassis and
designed to be used as a dwelling with or without a permanent
foundation when connected to the required utilities, and includes the
plumbing, heating, air conditioning, and electrical systems contained
in the structure. This term includes all structures that meet the above
requirements except the size requirements and with respect to which the
manufacturer voluntarily files a certification pursuant to 24 CFR
3282.13 and complies with the construction and safety standards set
forth in 24 CFR part 3280. The term does not include any self-propelled
recreational vehicle. Calculations used to determine the number of
square feet in a structure will be based on the structure's exterior
dimensions, measured at the largest horizontal projections when erected
on
[[Page 39800]]
site. These dimensions will include all expandable rooms, cabinets, and
other projections containing interior space, but do not include bay
windows. Nothing in this definition should be interpreted to mean that
a manufactured home necessarily meets the requirements of the U.S.
Department of Housing and Urban Development Minimum Property Standards
(HUD Handbook 4900.1) or that it is automatically eligible for
financing under 12 U.S.C. 1709(b).
Manufacturer means any person engaged in the factory construction
or assembly of a manufactured home, including any person engaged in
importing manufactured homes for resale.
Manual means capable of being operated by personal intervention.
R-value (thermal resistance) means the inverse of the time rate of
heat flow through a body from one of its bounding surfaces to the other
surface for a unit temperature difference between the two surfaces,
under steady state conditions, per unit area (h [middot] ft\2\ [middot]
[deg]F/Btu).
Rough opening means an opening in the wall or roof, sized for
installation of fenestration.
Service hot water means supply of hot water for purposes other than
comfort heating.
Skylight means glass or other transparent or translucent glazing
material, including framing materials, installed at an angle less than
60 degrees (1.05 rad) from horizontal.
Solar heat gain coefficient (SHGC) means the ratio of the solar
heat gain entering a space through a fenestration assembly to the
incident solar radiation. Solar heat gain includes directly transmitted
solar heat and absorbed solar radiation that is then reradiated,
conducted, or convected into the space.
State means each of the 50 states, the District of Columbia, the
Commonwealth of Puerto Rico, Guam, the U.S. Virgin Islands, and
American Samoa.
Thermostat means an automatic control device used to maintain
temperature at a fixed or adjustable set point.
U-factor (thermal transmittance) means the coefficient of heat
transmission (air to air) through a building component or assembly,
equal to the time rate of heat flow per unit area and unit temperature
difference between the warm side and cold side air films (Btu/h
[middot] ft\2\ [middot] [deg]F).
Uo (overall thermal transmittance) means the coefficient of heat
transmission (air to air) through the building thermal envelope, equal
to the time rate of heat flow per unit area and unit temperature
difference between the warm side and cold side air films (Btu/h
[middot] ft\2\ [middot]; [deg]F).
Ventilation means the natural or mechanical process of supplying
conditioned or unconditioned air to, or removing such air from, any
space.
Vertical fenestration means windows (fixed or moveable), opaque
doors, glazed doors, glazed block and combination opaque and glazed
doors composed of glass or other transparent or translucent glazing
materials and installed at a slope of greater than or equal to 60
degrees (1.05 rad) from horizontal.
Wall means an assembly that is vertical or tilted at an angle equal
to greater than 60 degrees (1.05 rad) from horizontal that encloses or
divides an area of a building or room.
Whole-house mechanical ventilation system means an exhaust system,
supply system, or combination thereof that is designed to mechanically
exchange indoor air with outdoor air when operating continuously or
through a programmed intermittent schedule.
Window means glass or other transparent or translucent glazing
material, including framing materials, installed at an angle greater
than 60 degrees (1.05 rad) from horizontal.
Zone means a space or group of spaces within a manufactured home
with heating or cooling requirements that are sufficiently similar so
that desired conditions can be maintained using a single controlling
device.
Sec. 460.3 Materials incorporated by reference.
(a) General. We incorporate by reference the following standards
into part 460. The material listed has been approved for incorporation
by reference by the Director of the Federal Register in accordance with
5 U.S.C. 552(a) and 1 CFR part 51. Any subsequent amendment to a
standard by the standard-setting organization will not affect the DOE
regulations unless and until amended by DOE. Material is incorporated
as it exists on the date of the approval and a notice of any change in
the material will be published in the Federal Register. All approved
material is available for inspection at the National Archives and
Records Administration (NARA). For information on the availability of
this material at NARA, call 202-741-6030 or go to http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. This material also is available for inspection at
U.S. Department of Energy, Office of Energy Efficiency and Renewable
Energy, Building Technologies Office, 6th Floor, 950 L'Enfant Plaza
SW., Washington, DC 20024, 202-586-2945, between 9 a.m. and 4 p.m.,
Monday through Friday, except Federal holidays. Standards can be
obtained from the sources listed.
(b) ACCA. Air Conditioning Contractors of America, Inc., 2800 S.
Shirlington Road, Suite 300, Arlington, VA 22206, 703-575-4477, http://www.acca.org/.
(1) Manual J--Residential Load Calculation (8th Edition). IBR
approved for Sec. 460.205 of subpart C.
(2) Manual S--Residential Equipment Selection (2nd Edition). IBR
approved for Sec. 460.205 of subpart C.
(c) HUD. U.S. Department of Housing and Urban Development, http://www.huduser.org/portal/publications/manufhsg/uvalue.html, 800-245-2691.
(1) Overall U-Values and Heating/Cooling Loads--Manufactured Homes.
Conner C.C., Taylor, Z.T., Pacific Northwest Laboratory, published
February 1, 1992, IBR approved for Sec. 460.102 of subpart B.
(2) Reserved.
Subpart B--Building Thermal Envelope
Sec. 460.101 Climate zones.
Manufactured homes must comply with the requirements applicable to
one or more of the climate zones set forth in Figure 460.101 and Tables
460.101-1 and 460.101-2 of this section.
[[Page 39801]]
[GRAPHIC] [TIFF OMITTED] TP17JN16.006
Table 460.101-1--U.S. States and Territories With One Climate Zone
----------------------------------------------------------------------------------------------------------------
Zone 1 Zone 2 Zone 3 Zone 4
----------------------------------------------------------------------------------------------------------------
Florida.............................. South Carolina......... Arkansas............... Alaska.
Hawaii............................... ....................... Delaware............... Colorado.
American Samoa....................... ....................... District of Columbia... Connecticut.
Guam................................. ....................... Kansas................. Idaho.
The Commonwealth of Puerto Rico...... ....................... Kentucky............... Illinois.
U.S. Virgin Islands.................. ....................... Maryland............... Indiana.
Missouri............... Iowa.
New Mexico............. Maine.
North Carolina......... Massachusetts.
Oklahoma............... Michigan.
Tennessee.............. Minnesota.
Virginia............... Montana.
West Virginia.......... Nebraska.
Nevada.
New Hampshire.
New Jersey.
New York.
North Dakota.
Ohio.
Oregon.
Pennsylvania.
Rhode Island.
South Dakota.
Utah.
Vermont.
Washington.
Wisconsin.
Wyoming.
----------------------------------------------------------------------------------------------------------------
Table 460.101-2--U.S. States With More Than One Climate Zone
--------------------------------------------------------------------------------------------------------------------------------------------------------
State Zone Counties Counties Counties Counties Counties
--------------------------------------------------------------------------------------------------------------------------------------------------------
Alabama.......................... 1 Baldwin............. Mobile..............
2 Autauga............. Barbour............. Bibb................ Blount............. Bullock.
Butler.............. Calhoun............. Chambers............ Cherokee........... Chilton.
Choctaw............. Clarke.............. Clay................ Cleburne........... Coffee.
Colbert............. Conecuh............. Coosa............... Covington.......... Crenshaw.
Cullman............. Dale................ Dallas.............. DeKalb............. Elmore.
Escambia............ Etowah.............. Fayette............. Franklin........... Geneva.
Greene.............. Hale................ Henry............... Houston............ Jackson.
Jefferson........... Lamar............... Lauderdale.......... Lawrence........... Lee.
Limestone........... Lowndes............. Macon............... Madison............ Marengo.
Marion.............. Marshall............ Monroe.............. Montgomery......... Morgan.
Perry............... Pickens............. Pike................ Randolph........... Russell.
[[Page 39802]]
St. Clair........... Shelby.............. Sumter.............. Talladega.......... Tallapoosa.
Tuscaloosa.......... Walker.............. Washington.......... Wilcox............. Winston.
Arizona.......................... 1 La Paz.............. Maricopa............ Pima................ Pinal.............. Yuma.
3 Apache.............. Cochise............. Coconino............ Graham............. Greenlee.
Mohave.............. Navajo.............. Santa Cruz.......... Yavapai............
Georgia.......................... 1 Appling............. Atkinson............ Bacon............... Baker.............. Berrien.
Brantley............ Brooks.............. Bryan............... Camden............. Charlton.
Chatham............. Clinch.............. Colquitt............ Cook............... Decatur.
Echols.............. Effingham........... Evans............... Glynn.............. Grady.
Jeff Davis.......... Lanier.............. Liberty............. Long............... Lowndes.
McIntosh............ Miller.............. Mitchell............ Pierce............. Seminole.
Tattnall............ Thomas.............. Toombs.............. Ware............... Wayne.
2 Baldwin............. Banks............... Barrow.............. Bartow............. Ben Hill.
Bibb................ Bleckley............ Bulloch............. Burke.............. Butts.
Calhoun............. Candler............. Carroll............. Catoosa............ Chattahoochee.
Chattooga........... Cherokee............ Clarke.............. Clay............... Clayton.
Cobb................ Coffee.............. Columbia............ Coweta............. Crawford.
Crisp............... Dade................ Dawson.............. DeKalb............. Dodge.
Dooly............... Dougherty........... Douglas............. Early.............. Elbert.
Emanuel............. Fannin.............. Fayette............. Floyd.............. Forsyth.
Franklin............ Fulton.............. Gilmer.............. Glascock........... Gordon.
Greene.............. Gwinnett............ Habersham........... Hall............... Hancock.
Haralson............ Harris.............. Hart................ Heard.............. Henry.
Houston............. Irwin............... Jackson............. Jasper............. Jefferson.
Jenkins............. Johnson............. Jones............... Lamar.............. Laurens.
Lee................. Lincoln............. Lumpkin............. McDuffie........... Macon.
Madison............. Marion.............. Meriwether.......... Monroe............. Montgomery.
Morgan.............. Murray.............. Muscogee............ Newton............. Oconee.
Oglethorpe.......... Paulding............ Peach............... Pickens............ Pike.
Polk................ Pulaski............. Putnam.............. Quitman............ Rabun.
Randolph............ Richmond............ Rockdale............ Schley............. Screven.
Spalding............ Stephens............ Stewart............. Sumter............. Talbot.
Taliaferro.......... Taylor.............. Telfair............. Terrell............ Tift.
Towns............... Treutlen............ Troup............... Turner............. Twiggs.
Union............... Upson............... Walker.............. Walton............. Warren.
Washington.......... Webster............. Wheeler............. White.............. Whitfield.
Wilcox.............. Wilkes.............. Wilkinson........... Worth.
Louisiana........................ 1 Acadia.............. Allen............... Ascension........... Assumption......... Avoyelles.
Beauregard.......... Calcasieu........... Cameron............. East Baton Rouge... East Feliciana.
Evangeline.......... Iberia.............. Iberville........... Jefferson.......... Jefferson Davis.
Lafayette........... Lafourche........... Livingston.......... Orleans............ Plaquemines.
Pointe Coupee....... Rapides............. St. Bernard......... St. Charles........ St. Helena.
St. James........... St. John the Baptist St. Landry.......... St. Martin......... St. Mary.
St. Tammany......... Tangipahoa.......... Terrebonne.......... Vermilion.......... Washington.
West Baton Rouge.... West Feliciana......
2 Bienville........... Bossier............. Caddo............... Caldwell........... Catahoula.
Claiborne........... Concordia........... De Soto............. East Carroll....... Franklin.
Grant............... Jackson............. LaSalle............. Lincoln............ Madison.
Morehouse........... Natchitoches........ Ouachita............ Red River.......... Richland.
Sabine.............. Tensas.............. Union............... Vernon............. Webster.
West Carroll........ Winn................
Mississippi...................... 1 Hancock............. Harrison............ Jackson............. Pearl River........ Stone.
2 Adams............... Alcorn.............. Amite............... Attala............. Benton.
Bolivar............. Calhoun............. Carroll............. Chickasaw.......... Choctaw.
Claiborne........... Clarke.............. Clay................ Coahoma............ Copiah.
Covington........... DeSoto.............. Forrest............. Franklin........... George.
Greene.............. Grenada............. Hinds............... Holmes............. Humphreys.
Issaquena........... Itawamba............ Jasper.............. Jefferson.......... Jefferson Davis.
Jones............... Kemper.............. Lafayette........... Lamar.............. Lauderdale.
Lawrence............ Leake............... Lee................. Leflore............ Lincoln.
Lowndes............. Madison............. Marion.............. Marshall........... Monroe.
Montgomery.......... Neshoba............. Newton.............. Noxubee............ Oktibbeha.
Panola.............. Perry............... Pike................ Pontotoc........... Prentiss.
Quitman............. Rankin.............. Scott............... Sharkey............ Simpson.
Smith............... Sunflower........... Tallahatchie........ Tate............... Tippah.
Tishomingo.......... Tunica.............. Union............... Walthall........... Warren.
Washington.......... Wayne............... Webster............. Wilkinson.......... Winston.
Yalobusha........... Yazoo...............
Texas............................ 1 Anderson............ Angelina............ Aransas............. Atascosa........... Austin.
Bandera............. Bastrop............. Bee................. Bell............... Bexar.
Bosque.............. Brazoria............ Brazos.............. Brooks............. Burleson.
Caldwell............ Calhoun............. Cameron............. Chambers........... Colorado.
[[Page 39803]]
Comal............... Coryell............. DeWitt.............. Dimmit............. Duval.
Edwards............. Falls............... Fayette............. Fort Bend.......... Freestone.
Frio................ Galveston........... Goliad.............. Gonzales........... Grimes.
Guadalupe........... Hardin.............. Harris.............. Hays............... Hidalgo.
Hill................ Houston............. Jackson............. Jasper............. Jefferson.
Jim Hogg............ Jim Wells........... Karnes.............. Kenedy............. Kinney.
Kleberg............. La Salle............ Lavaca.............. Lee................ Leon.
Liberty............. Limestone........... Live Oak............ Madison............ Matagorda.
Maverick............ McLennan............ McMullen............ Medina............. Milam.
Montgomery.......... Newton.............. Nueces.............. Orange............. Polk.
Real................ Refugio............. Robertson........... San Jacinto........ San Patricio.
Starr............... Travis.............. Trinity............. Tyler.............. Uvalde.
Val Verde........... Victoria............ Walker.............. Waller............. Washington.
Webb................ Wharton............. Willacy............. Williamson......... Wilson.
Zapata.............. Zavala..............
3 Andrews............. Archer.............. Armstrong........... Bailey............. Baylor.
Blanco.............. Borden.............. Bowie............... Brewster........... Briscoe.
Brown............... Burnet.............. Callahan............ Camp............... Carson.
Cass................ Castro.............. Cherokee............ Childress.......... Clay.
Cochran............. Coke................ Coleman............. Collin............. Collingsworth.
Comanche............ Concho.............. Cooke............... Cottle............. Crane.
Crockett............ Crosby.............. Culberson........... Dallam............. Dallas.
Dawson.............. Deaf Smith.......... Delta............... Denton............. Dickens.
Donley.............. Eastland............ Ector............... Ellis.............. El Paso.
Erath............... Fannin.............. Fisher.............. Floyd.............. Foard.
Franklin............ Gaines.............. Garza............... Gillespie.......... Glasscock.
Gray................ Grayson............. Gregg............... Hale............... Hall.
Hamilton............ Hansford............ Hardeman............ Harrison........... Hartley.
Haskell............. Hemphill............ Henderson........... Hockley............ Hood.
Hopkins............. Howard.............. Hudspeth............ Hunt............... Hutchinson.
Irion............... Jack................ Jeff Davis.......... Johnson............ Jones.
Kaufman............. Kendall............. Kent................ Kerr............... Kimble.
King................ Knox................ Lamar............... Lamb............... Lampasas.
Lipscomb............ Llano............... Loving.............. Lubbock............ Lynn.
McCulloch........... Marion.............. Martin.............. Mason.............. Menard.
Midland............. Mills............... Mitchell............ Montague........... Moore
Morris.............. Motley.............. Nacogdoches......... Navarro............ Nolan.
Ochiltree........... Oldham.............. Palo Pinto.......... Panola............. Parker.
Parmer.............. Pecos............... Potter.............. Presidio........... Rains.
Randall............. Reagan.............. Red River........... Reeves............. Roberts.
Rockwall............ Runnels............. Rusk................ Sabine............. San Augustine.
San Saba............ Schleicher.......... Scurry.............. Shackelford........ Shelby.
Sherman............. Smith............... Somervell........... Stephens........... Sterling.
Stonewall........... Sutton.............. Swisher............. Tarrant............ Taylor.
Terrell............. Terry............... Throckmorton........ Titus.............. Tom Green.
Upshur.............. Upton............... Van Zandt........... Ward............... Wheeler.
Wichita............. Wilbarger........... Winkler............. Wise............... Wood.
Yoakum.............. Young.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Sec. 460.102 Building thermal envelope requirements.
(a) Compliance options. The building thermal envelope of a
manufactured home must meet either the prescriptive requirements of
paragraph (b) of this section or the performance requirements of
paragraph (c) of this section.
(b) Prescriptive requirements. (1) The building thermal envelope
must meet the minimum R-value, and the maximum U-factor and SHGC,
requirements set forth in Table 460.102-1.
Table 460.102-1--Building Thermal Envelope Prescriptive Requirements
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ceiling Wall Floor
Climate zone insulation R- insulation R- insulation R- Window U- Skylight U- Door U-factor Glazed fenestration
value value value factor factor SHGC
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................... 30 13 13 0.35 0.75 0.40 0.25
2............................... 30 13 13 0.35 0.75 0.40 0.33
3............................... 30 21 19 0.35 0.55 0.40 0.33
4............................... 38 21 30 0.32 0.55 0.40 Not Applicable
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 39804]]
(2) For the purpose of compliance with the ceiling insulation R-
value requirement of paragraph (b)(1) of this section, the truss heel
height must be a minimum of 5.5 inches at the outside face of each
exterior wall.
(3) Ceiling insulation must have either a uniform thickness or a
uniform density.
(4) A combination of R-21 batt insulation and R-14 blanket
insulation may be used for the purpose of compliance with the floor
insulation R-value requirement of Sec. 460.102(b)(1) for climate zone
4.
(5) An individual skylight that has an SHGC that is less than or
equal to 0.30 is not subject to the glazed fenestration SHGC
requirements established in Table 460.102-1.
(6) U-factor alternatives to R-value requirements. Compliance with
paragraph (b)(1) of this section may be determined using the maximum U-
factor values set forth in Table 460.102-2, which reflect the thermal
transmittance of the component, excluding fenestration, and not just
the insulation of that component, as an alternative to the minimum R-
value requirements set forth in Table 460.102-1.
(7) The total area of glazed fenestration must be no greater than
12 percent of the area of the floor.
Table 460.102-2--U-Factor Alternatives to R-Value Requirements
----------------------------------------------------------------------------------------------------------------
Ceiling U-
Climate zone factor Wall U-factor Floor U-factor
----------------------------------------------------------------------------------------------------------------
1............................................................... 0.0446 0.0943 0.0776
2............................................................... 0.0446 0.0943 0.0776
3............................................................... 0.0446 0.0628 0.0560
4............................................................... 0.0377 0.0628 0.0322
----------------------------------------------------------------------------------------------------------------
(c) Performance requirements. (1) The building thermal envelope
must have a Uo that is less than or equal to the value specified in
Table 460.102-3.
Table 460.102-3--Building Thermal Envelope Performance Requirements
------------------------------------------------------------------------
Single- Multi-
Climate zone section section
Uo Uo
------------------------------------------------------------------------
1................................................. 0.087 0.084
2................................................. 0.087 0.084
3................................................. 0.070 0.068
4................................................. 0.059 0.056
------------------------------------------------------------------------
(2) Area-weighted average vertical fenestration U-factor must not
exceed 0.48 in climate zone 3 or 0.40 in climate zone 4.
(3) Area-weighted average skylight U-factor must not exceed 0.75 in
climate zone 3 and climate zone 4.
(4) Windows, skylights and doors containing more than 50 percent
glazing by area must satisfy the SHGC requirements established in Table
460.102-1 on the basis of an area-weighted average.
(d) Determination of compliance with paragraph (b) of this section.
(1)-(2) [Reserved].
(3) The total R-value of a component is the sum of the R-values of
each layer of insulation that comprise the component.
(4)-(5) [Reserved].
(6) The U-factor for certain fenestration products and doors may be
determined in accordance with the prescriptive default values set forth
in Tables 460.102-4 and 460.102-5.
(7) [Reserved].
(8) The SHGC of certain glazed fenestration products may be
determined in accordance with the prescriptive glazed fenestration
default values set forth in Table 460.102-6.
(e) Determination of compliance with Sec. 460.102(c). (1) Uo must
be determined in accordance with Overall U-Values and Heating/Cooling
Loads--Manufactured Homes (incorporated by reference; see Sec. 460.3)
with the following exceptions:
(i)-(ii) [Reserved].
(iii) The U-factor for certain fenestration products and doors may
be determined in accordance with the prescriptive default values set
forth in Tables 460.102-4 and 460.102-5 of this section.
(2) [Reserved].
(3) The SHGC of certain glazed fenestration products may be
determined in accordance with the prescriptive glazed fenestration
default values set forth in Table 460.102-6.
Table 460.102-4--Default Glazed Fenestration U-Factor Values
----------------------------------------------------------------------------------------------------------------
Skylight U-factor
Frame type Window U- Window U- -------------------------------
factor factor Single pane Double pane
----------------------------------------------------------------------------------------------------------------
Metal........................................... 1.20 0.80 2.00 1.30
Metal with Thermal Break........................ 1.10 0.65 1.90 1.10
Nonmetal or Metal Clad.......................... 0.95 0.55 1.75 1.05
---------------------------------------------------------------
Glazed Block.................................... 0.60
----------------------------------------------------------------------------------------------------------------
Table 460.102-5--Default Door U-Factor Values
------------------------------------------------------------------------
Door type U-factor
------------------------------------------------------------------------
Uninsulated Metal....................................... 1.20
Insulated Metal......................................... 0.60
Wood.................................................... 0.50
Insulated, nonmetal edge, maximum 45 percent glazing, 0.35
any glazing double pane................................
------------------------------------------------------------------------
[[Page 39805]]
Table 460.102-6--Default Glazed Fenestration SHGC Values
----------------------------------------------------------------------------------------------------------------
Single pane Double pane
---------------------------------------------------------------- Glazed block
Clear Tinted Clear Tinted
----------------------------------------------------------------------------------------------------------------
SHGC............................ 0.8 0.7 0.7 0.6 0.6
----------------------------------------------------------------------------------------------------------------
Sec. 460.103 Installation of insulation.
Insulating materials must be installed according to the insulation
manufacturer's installation instructions and the requirements set forth
in Table 460.103.
Table 460.103--Installation of Insulation
------------------------------------------------------------------------
Component Installation requirements
------------------------------------------------------------------------
General........................... Air-permeable insulation must not be
used as a material to establish the
air barrier.
Access hatches, panels, and doors. Access hatches, panels, and doors
between conditioned space and
unconditioned space must be
insulated to a level equivalent to
the insulation of the surrounding
surface, must provide access to all
equipment that prevents damaging or
compressing the insulation, and
must provide a wood-framed or
equivalent baffle or retainer when
loose fill insulation is installed
within a ceiling assembly to retain
the insulation both on the access
hatch, panel, or door and within
the building thermal envelope.
Baffles........................... Baffles must be constructed using a
solid material, maintain an opening
equal or greater than the size of
the vents, and extend over the top
of the attic insulation.
Ceiling or attic.................. The insulation in any dropped
ceiling or dropped soffit must be
aligned with the air barrier.
Eave vents........................ Air-permeable insulations in vented
attics within the building thermal
envelope must be installed adjacent
to eave vents.
Floors............................ Floor insulation must be installed
to maintain permanent contact with
the underside of the rough floor
decking over which the finished
floor, flooring material, or carpet
is laid, except where air ducts
directly contact the underside of
the rough floor decking.
Narrow cavities................... Batts in narrow cavities must be cut
to fit or narrow cavities must be
filled by insulation that upon
installation readily conforms to
the available cavity space.
Rim joists........................ Rim joists must be insulated.
Shower or tub adjacent to exterior Exterior walls adjacent to showers
wall. and tubs must be insulated.
Walls............................. Air permeable exterior building
thermal envelope insulation for
framed walls must completely fill
the cavity, including within stud
bays caused by blocking lay flats
or headers.
------------------------------------------------------------------------
Sec. 460.104 Building thermal envelope air leakage.
Manufactured homes must be sealed against air leakage at all
joints, seams, and penetrations associated with the building thermal
envelope in accordance with the component manufacturer's installation
instructions and the requirements set forth in Table
460.104. Sealing methods between dissimilar materials must allow for
differential expansion and contraction and must establish a continuous
air barrier upon installation of all opaque components of the building
thermal envelope. All gaps and penetrations in the ceiling, floor, and
exterior walls,
including ducts, flue shafts, plumbing, piping, electrical wiring,
utility penetrations, bathroom and kitchen exhaust fans, recessed
lighting fixtures adjacent to unconditioned space, and light tubes
adjacent to unconditioned space, must be sealed with caulk, foam,
gasket or other suitable material.
Table 460.104--Air Barrier Installation Criteria
------------------------------------------------------------------------
Component Air barrier criteria
------------------------------------------------------------------------
Ceiling or attic.................. The air barrier in any dropped
ceiling or dropped soffit must be
aligned with the insulation and any
gaps in the air barrier must be
sealed with caulk, foam, gasket, or
other suitable material. Access
hatches, panels, and doors, drop
down stairs, or knee wall doors to
unconditioned attic spaces must be
weatherstripped or equipped with a
gasket to produce a continuous air
barrier.
Duct system register boots........ Duct system register boots that
penetrate the building thermal
envelope or the air barrier must be
sealed to the air barrier or the
interior finish materials with
caulk, foam, gasket, or other
suitable material.
Electrical box or phone box on The air barrier must be installed
exterior walls. behind electrical or communication
boxes or the air barrier must be
sealed around the box penetration
with caulk, foam, gasket, or other
suitable material.
Floors............................ The air barrier must be installed at
any exposed edge of insulation. The
bottom board may serve as the air
barrier.
Mating line surfaces.............. Mating line surfaces must be
equipped with a continuous and
durable gasket.
Recessed lighting................. Recessed light fixtures installed in
the building thermal envelope must
be sealed to the drywall with
caulk, foam, gasket, or other
suitable material.
Rim joists........................ The air barrier must enclose the rim
joists.
Shower or tub adjacent to exterior The air barrier must separate
wall. showers and tubs from exterior
walls.
Walls............................. The junction of the top plate and
the ceiling, and the junction of
the bottom plate and the floor,
along exterior walls must be sealed
with caulk, foam, gasket, or other
suitable material.
Windows, skylights, and exterior The rough openings around windows,
doors. exterior doors, and skylights must
be sealed with caulk or foam.
------------------------------------------------------------------------
[[Page 39806]]
Subpart C--HVAC, Service Water Heating, and Equipment Sizing
Sec. 460.201 Duct system.
(a) Each manufactured home must be equipped with a duct system,
which may include air handlers and filter boxes, that must be sealed to
limit total air leakage to less than or equal to four (4) cubic feet
per minute per 100 square feet of conditioned floor area when tested
according to paragraph (b) of this section. Building framing cavities
must not be used as ducts or plenums.
(b) [Reserved].
Sec. 460.202 Thermostats and controls.
(a) At least one thermostat must be provided for each separate
heating and cooling system installed by the manufacturer.
(b) Programmable thermostat. Any thermostat installed by the
manufacturer that controls the heating or cooling system must--
(1) Be capable of controlling the heating and cooling system on a
daily schedule to maintain different temperature set points at
different times of the day;
(2) Include the capability to set back or temporarily operate the
system to maintain zone temperatures down to 55 [deg]F (13 [deg]C) or
up to 85 [deg]F (29 [deg]C); and
(3) Be programmed with a heating temperature set point no higher
than 70 [deg]F (21 [deg]C) and a cooling temperature set point no lower
than 78 [deg]F (26 [deg]C).
(c) Heat pumps with supplementary electric-resistance heat must be
provided with controls that, except during defrost, prevent
supplemental heat operation when the heat pump compressor can meet the
heating load.
Sec. 460.203 Service water heating.
(a) Service water heating systems installed by the manufacturer
must be installed according to the service water heating manufacturer's
installation instructions. Where service water heating systems are
installed by the manufacturer, the manufacturer must ensure that any
maintenance instructions received from the service water heating system
manufacturer are provided with the manufactured home.
(b) Any automatic and manual controls, temperature sensors, pumps
associated with service water heating systems must be accessible.
(c) Heated water circulation systems must--
(1) Be provided with a circulation pump;
(2) Ensure that the system return pipe is a dedicated return pipe
or a cold water supply pipe;
(3) Not include any gravity or thermosyphon circulation systems;
(4) Ensure that controls for circulating heated water circulation
pumps start the pump based on the identification of a demand for hot
water within the occupancy; and
(5) Ensure that the controls automatically turn off the pump when
the water in the circulation loop is at the desired temperature and
when there is no demand for hot water.
(d) All hot water pipes--
(1) Outside conditioned space must be insulated to a minimum R-
value of R-3; and
(2) From a service water heating system to a distribution manifold
must be insulated to a minimum R-value of R-3.
Sec. 460.204 Mechanical ventilation fan efficacy.
(a) Whole-house mechanical ventilation system fans must meet the
minimum efficacy requirements set forth in Table 460.204.
Table 460.204--Mechanical Ventilation System Fan Efficacy
------------------------------------------------------------------------
Minimum
Fan type description efficacy (cfm/
watt)
------------------------------------------------------------------------
Range hoods (all air flow rates)........................ 2.8
In-line fans (all air flow rates)....................... 2.8
Bathroom and utility room fans (10 cfm <= air flow rate 1.4
<90 cfm)...............................................
Bathroom and utility room fans (air flow rate >=90 cfm). 2.8
------------------------------------------------------------------------
(b) Mechanical ventilation fans that are integral to heating,
ventilating, and air conditioning equipment must be powered by an
electronically commutated motor.
Sec. 460.205 Equipment sizing.
Sizing of heating and cooling equipment installed by the
manufacturer must be determined in accordance with ACCA Manual S
(incorporated by reference; see Sec. 460.3) based on building loads
calculated in accordance with ACCA Manual J (incorporated by reference;
see Sec. 460.3).
[FR Doc. 2016-13547 Filed 6-16-16; 8:45 am]
BILLING CODE 6450-01-P