Affordable HOMES Act Nullifies 2022 Energy Rules, Prioritizing Low Initial Cost Over Long-Term Efficiency

The Affordable Housing Over Mandating Efficiency Standards Act, or the Affordable HOMES Act, is shaking up how the federal government handles energy efficiency for manufactured homes. This bill zeroes in on balancing the upfront cost of these homes against their long-term energy performance, but it does so by explicitly wiping out a specific set of rules already on the books.

The core of the bill is a new process for updating energy standards. It allows the Secretary of Energy to recommend revisions to the Secretary of Housing and Urban Development (HUD), but only if those recommendations meet strict criteria (SEC. 2). These criteria require the proposed standard to be cost-effective, meaning the revised standard must justify its cost by considering the total life cycle costs of construction and operation. Crucially, the recommendations must also include estimates of how the change would affect the initial purchase price of a manufactured home. This is the bill’s signal: keep the sticker price low.

The Great Regulatory Reset: What Got Canceled?

The biggest immediate impact of the Affordable HOMES Act is found in the final clause of Section 2: it declares that the Department of Energy’s final rule on energy conservation standards for manufactured housing, published on May 31, 2022, “shall have no force or effect.” That 2022 rule was designed to boost the energy performance of new manufactured homes, which would have meant lower utility bills down the road for owners. By nullifying it, the bill removes those standards entirely. For manufacturers, this removes a regulatory hurdle and potentially keeps their production costs lower. For a prospective buyer, this means the home they purchase today might be cheaper upfront, but it’s going to be less energy efficient than a home built under the now-canceled 2022 rules, locking them into higher monthly electricity or gas bills for the life of the home.

Efficiency vs. Affordability: The Trade-Off

The bill sets up a new framework that seems designed to prioritize the initial purchase price of manufactured homes. The new criteria require the Secretary of Energy to explicitly consider factory construction limitations, climate zones, and the estimated payback periods for any added costs. This is good news for manufacturers, as the standards must be practical for their factory lines. It’s also good news for people struggling to afford a down payment, as the focus on initial purchase price might keep those costs lower.

However, this focus creates a potential long-term problem. Manufactured housing is often an affordable path to homeownership, but the owners of these homes are frequently those who can least afford high utility bills. By making “cost-effective” and “initial purchase price” the primary drivers of energy standards, there’s a risk that the new rules will be set too low. If a standard that costs $1,000 extra to install saves the homeowner $200 a year in energy, its payback period is five years. While that’s a great return on investment, the manufacturer might argue that the $1,000 increase in the initial price tag makes the home less “affordable” to buy. This bill gives significant weight to that argument, potentially sacrificing long-term operational savings for short-term purchase price relief.