Energy Conservation Program: Energy Conservation Standards for Manufactured Housing: Availability of Provisional Analysis

Federal RegisterOct 26, 2021

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DEPARTMENT OF ENERGY

10 CFR Part 460

[EERE-2009-BT-BC-0021]

RIN 1904-AC11

Energy Conservation Program: Energy Conservation Standards for Manufactured Housing: Availability of Provisional Analysis

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Supplemental notice of proposed rulemaking; reopening of public comment period and notification of data availability (NODA).

SUMMARY:

The U.S. Department of Energy (DOE) is reopening the public comment period for the supplemental notice of proposed rulemaking (“SNOPR”) regarding proposals to amend energy conservation standards for manufactured housing. DOE published the SNOPR in the

Federal Register

on August 26, 2021. DOE is also publishing a notice of data availability (NODA) for the manufactured housing energy conservation standards rulemaking announcing the availability of updated analyses and results, and is giving interested parties an opportunity to comment on these analyses and submit additional data.

DATES:

The comment period for the SNOPR which published on August 26, 2021 (86 FR 47744), is reopened. DOE will accept comments, data, and information regarding the SNOPR and NODA received no later than November 26, 2021. See section IX, “Public Participation,” for details.

ADDRESSES:

Any comments submitted must identify the NODA for Energy Conservation Standards for Manufactured Housing and provide docket number EERE-2009-BT-STD-0021 and/or regulatory information number (RIN) number 1904-AC11. Submit electronic comments in WordPerfect, Microsoft Word, PDF, or ASCII file format, and avoid the use of special characters or any form of encryption.

Although DOE has routinely accepted public comment submissions through a variety of mechanisms, including postal mail and hand delivery/courier, the Department has found it necessary to make temporary modifications to the comment submission process in light of the ongoing Covid-19 pandemic. DOE is currently suspending receipt of public comments via postal mail and hand delivery/courier. If a commenter finds that this change poses an undue hardship, please contact Appliance Standards Program staff at (202) 586-1445 to discuss the need for alternative arrangements. Once the Covid-19 pandemic health emergency is resolved, DOE anticipates resuming all of its regular options for public comment submission, including postal mail and hand delivery/courier.

No telefacsimilies (faxes) will be accepted. For detailed instructions on submitting comments and additional information on the rulemaking process, see section IX.A of this document.

Docket:

The docket for this activity, which includes

Federal Register

notices, comments, and other supporting documents/materials, is available for review at

www.regulations.gov.

All documents in the docket are listed in the

www.regulations.gov

index. However, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.

The docket web page can be found at

www.regulations.gov/docket?D=EERE-2009-BT-BC-0021.

The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section IX.A for information on how to submit comments through

www.regulations.gov.

FOR FURTHER INFORMATION CONTACT:

Mr. John Cymbalsky, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program (EE-2J), 1000 Independence Avenue SW, Washington, DC 20585; 202-287-1692;

john.cymbalsky@ee.doe.gov.

Mr. Matthew Ring, U.S. Department of Energy, Office of the General Counsel (GC-33), 1000 Independence Avenue SW, Washington, DC 20585; 202-586-2555;

matthew.ring@hq.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Background

II. Summary of the Analyses Performed by the Department of Energy

III. Summary of the Updated Inputs Since the August 2021 MH SNOPR

A. 2021 CFPB Manufactured Housing Finance Report

B. 2020 Manufactured Housing Survey

C. AEO 2021

D. 2020 Shipments

IV. Summary of Updated SNOPR Analysis Results

V. Sensitivity Analysis Results—Alternate Size-Based Tier Threshold For the Tiered Standard

VI. Sensitivity Analysis Results—Alternate R-21 Exterior Wall Insulation for Climate Zone 2 and 3 for Tier 2 and Untiered Standards

A. Sensitivity Analysis Results—Alternate R-21 Exterior Wall Insulation for Climate Zone 2 and 3 Combined With Alternate Size-Based Tier Threshold for Tiered Standard

VII. Comparison of the August 2021 MH SNOPR and NODA Results

VIII. Reopening of Comment Period

IX. Public Participation

A. Submission of Comments

X. Approval of the Office of the Secretary

I. Background

DOE published a supplemental notice of proposed rulemaking (“SNOPR”) proposing amended energy conservation standards for manufactured housing on August 26, 2021 (“August 2021 MH SNOPR”). 86 FR 47744. In the August 2021 MH SNOPR, DOE's primary proposal was the “tiered” approach, based on the 2021 IECC, wherein a subset of the energy conservation standards would be less stringent for certain manufactured homes in light of the cost-effectiveness considerations required by statute. Under the tiered proposal, two sets of standards would be established in proposed 10 CFR part 460, subpart B (

i.e.,

Tier 1 and Tier 2). Tier 1 would apply to manufactured homes with a manufacturer's retail list price of $55,000 or less, and also incorporate building thermal envelope measures based on certain thermal envelope components subject to the 2021 IECC, but would limit the incremental purchase price increase to an average of approximately $750. Tier 2 would apply to manufactured homes with a manufacturer's retail list price

above $55,000, and incorporate building thermal envelope measures based on certain thermal envelope components and specifications of the 2021 IECC (

i.e.,

the Tier 2 requirements would be the same as those under the proposed single, “untiered” set of standards). 86 FR 47744, 47746.

As noted in the August 2021 MH SNOPR, several data sources that served as inputs to the August 2021 MH SNOPR have since been updated to include more recent data that DOE did not incorporate in its analyses in the August 2021 MH SNOPR. 86 FR 47758. DOE sought comment on the use of these data sources for this rulemaking. Further, based on comments and consultations with the U.S. Department of Housing and Urban Development (HUD), DOE conducted a sensitivity analysis using an alternate tier threshold based on size (

e.g.,

single-section vs. multi-section homes) for the tiered proposal. DOE also performed a sensitivity analysis with alternate wall insulation requirements for climate zones 2 and 3 for both the tiered and the untiered standards. This notice of data availability (NODA) announces the availability of these updated inputs and corresponding analyses results and invites interested parties to submit comments on these analyses or provide any additional data. DOE will consider the updated inputs and corresponding analyses, as well comments on the inputs and analyses, as part of this rulemaking. DOE may further revise the analysis presented in this rulemaking based on any new or updated information or data it obtains. DOE encourages stakeholders to provide any additional data or information that may inform the analysis.

II. Summary of the Analyses Performed by the Department of Energy

DOE conducted analyses of manufactured housing for both the August 2021 MH SNOPR and this NODA in the following areas: (1) Life-cycle cost (“LCC”) and payback period (“PBP”), (2) national impacts, and (3) emissions impacts.

DOE conducts LCC and PBP analyses to evaluate the economic impacts on individual consumers of energy conservation standards for manufactured housing. The LCC is the total consumer expense of a manufactured home over the life of that home, consisting of total installed cost plus total operating costs. To compute the total operating costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the product (or another specified period).

1

The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost of a more-efficient manufactured home through lower operating costs.

1

In the August 2021 SNOPR, DOE performed LCC analyses for a 30-year period, based on the assumed lifetime of manufactured homes. 86 FR 87744, 87791-87792. Additionally, based on comments received, to measure the LCC of the first homeowner of a manufactured home, DOE also performed LCC analyses for a 10-year period.

Id.

Analyses for both a 30-year and 10-year period are presented in this NODA.

DOE conducts the national impact analysis (“NIA”) to assess the national energy savings (“NES”) and the national net present value (“NPV”) from a national perspective of total consumer costs and savings that would be expected to result from new or amended standards. DOE calculates the NES and NPV based on projections of annual product shipments, along with the annual energy consumption and total incremental cost data from the LCC analyses.

Finally, DOE estimates environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases associated with electricity production. DOE bases these estimates on a 30-year analysis period of manufactured home shipments and includes the reductions in emissions that accrue over the 30-year home lifetime. DOE's analysis estimates reductions in emissions of six pollutants associated with energy savings: Carbon dioxide (CO

2

), mercury (Hg), nitric oxide and nitrogen dioxide (NO

X

), sulfur dioxide (SO

2

), methane (CH

4

), and nitrous oxide (N

2

O). These reductions are referred to as “site” emissions reductions. Furthermore, DOE estimates reductions due to “upstream” activities in the fuel production chain. These upstream activities comprise extraction, processing, and transporting fuels to the site of combustion. Together, site emissions reductions and upstream emissions reductions account for the FFC. Further, DOE calculates the value of the reduced emissions of CO

2

, CH

4

, and N

2

O (collectively, greenhouse gases or GHGs) using a range of values per metric ton of pollutant, consistent with the interim estimates issued in February 2021 under Executive Order 13990. Separately, DOE also estimates the monetary benefits from the reduced emissions of NO

X

and SO

2

.

III. Summary of the Updated Inputs Since the August 2021 MH SNOPR

As noted in the August 2021 MH SNOPR, several data sources that served as inputs to the August 2021 MH SNOPR have since been updated to include more recent data that DOE did not incorporate in its analyses in the August 2021 MH SNOPR. 86 FR 47758. Table III.1 presents a summary of the updated inputs and the analyses that are impacted because of the updates to the data. DOE will consider the updated inputs and corresponding analyses, as well comments on the inputs and analyses, as part of this rulemaking. DOE may further revise the analysis presented in this rulemaking based on any new or updated information or data it obtains. DOE encourages stakeholders to provide any additional data or information that may inform the analysis.

Table III.1—Updated Inputs to the Analysis Conducted for the Energy Conservation Standards

SNOPR

NODA

Analyses impacted

2014 Consumer Finance Protection Bureau (CFPB) Manufactured Housing Finance Report

2021 CFPB Manufactured Housing Finance Report

Impacts the LCC, PBP and NIA analyses.

2019 Manufactured Housing Survey (MHS)

2020 MHS

Determines the manufacturer's retail list price threshold for the tiered proposal, and affects shipments for NIA and emissions analyses.

Annual Energy Outlook (AEO) 2020

AEO 2021

Impacts the LCC, PBP, NIA and emissions analyses.

2019 Shipments

2020 Shipments

Impacts the NIA and emissions analyses.

2015 Energy Star Shipments

2020 Energy Star Shipments

Sections III.A through III.D provide a summary of the input updates for this NODA. Sections IV through VI provide the LCC, PBP, national and emissions impacts results based on the input updates discussed in this section.

A. 2021 CFPB Manufactured Housing Finance Report

The CFPB manufactured housing (“MH”) report analyzes the differences between mortgage loans used for site-built homes, and mortgage loans and chattel loans used for manufactured homes.

2

For the August 2021 MH SNOPR, the proposed manufacturer's retail list price tier threshold for the tiered standard was developed using loan data derived from the 2014 CFPB report,

3

and purchase price data derived from the MHS 2019 Public Use File (“PUF”) data.

4

86 FR 47744, 47760. In this NODA, DOE maintained the same analysis as the August 2021 MH SNOPR, but updated the CFPB MH report source to the latest version, which is the 2021 CFPB MH report. Section III.B provides the discussion regarding the updated purchase price data using MHS 2020 PUF data.

2

Manufactured Housing Finance: New Insights from the Home Mortgage Disclosure Act;

https://www.consumerfinance.gov/data-research/research-reports/manufactured-housing-finance-new-insights-hmda/.

3

CFPB report, 2014.

https://files.consumerfinance.gov/f/201409_cfpb_report_manufactured-housing.pdf.

4

Manufactured Housing Survey, Public Use File (PUF) 2019.

https://www.census.gov/data/datasets/2019/econ/mhs/puf.html.

To calculate the tier threshold for the tiered standard, DOE considered that low-income purchasers of manufactured homes would mostly likely use chattel loans, or similar loans that are high-priced.

5

The 2014 CFPB MH report explicitly stated that high-priced manufactured housing loans (including chattel loans) account for roughly 68 percent of total manufactured housing loans.

6

5

The Consumer Finance Protection Bureau (CFPB) generally describes a higher-priced mortgage loan as a loan with an annual percentage rate, or APR, higher than a benchmark rate called the Average Prime Offer Rate. The requirements for this loan can be found in 12 CFR 1026.35.

6

2014 CFPB MH report; See page 6.

The 2021 CFPB MH report no longer reports this information. Instead, the 2021 CFPB MH report lists the proportion of loans that are chattel loans, as well as the proportion of chattel and non-chattel loans that are high-priced loans. The 2021 CFPB MH report states that 42 percent of all manufactured home loans are chattel loans; accordingly, DOE determined that the remaining (58 percent) would be non-chattel loans. Of the chattel loans, the 2021 CFPB MH report states that 93.8 percent are high-priced loans. Similarly, of the non-chattel loans, the 2021 CFPB MH report states that 52.4 percent are high-priced loans. Using these data, DOE estimates that approximately 70 percent (42% * 93.8% + 58% * 52.4% = 70%) of all manufactured housing loans (

i.e.,

chattel and non-chattel loans) were high-priced loans. Accordingly, for this NODA, DOE assumed that high-priced manufactured housing loans (including chattel loans) account for roughly 70 percent of total manufactured housing loans. This percentage is used to determine the updated manufacturer's retail list price tier threshold, which is discussed further in section III.B.

Additionally, the 2021 CFPB MH report also lists the median chattel loan term as 23 years, which differs from the 15-year value that DOE assumed in the August 2021 MH SNOPR, which was based on suggestions from the MH working group. 86 FR 47744, 47793. For this NODA, DOE assumes a chattel loan term of 23 years, which is consistent with the 2021 CFPB MH report. The impact of the longer loan on the analysis is that it increased LCC savings and decreased NPV at 3 percent discount rate.

B. 2020 Manufactured Housing Survey

The MHS, which is sponsored by HUD and collected by the Census Bureau, provides data on shipments, prices and characteristics of new manufactured housing.

7

Specifically, the MHS PUF data provide estimates of average sales prices for new manufactured homes sold or intended for sale by geographical region and size of home.

7

Manufactured Housing Survey;

www.census.gov/programs-surveys/mhs.html.

As discussed in section III.A, for the August 2021 MH SNOPR, the purchase price data used to determine the manufacturer's retail list price tier threshold was derived from the MHS 2019 PUF data. 86 FR 47744, 47760. In this section, DOE discusses the updates based on the latest MHS data, which is the MHS 2020 PUF data.

8

8

Manufactured Housing Survey, Public Use File (PUF) 2020.

https://www.census.gov/data/datasets/2020/econ/mhs/puf.html.

The MHS 2020 PUF data set provides data that relates Census region (the U.S. Census Bureau divides the country into four census regions) with sales price. Table III.2 summarizes the average, minimum and maximum sales prices based on census region and number of sections. In general, the data indicate that average sales price (specifically for single-section homes) does not differ significantly based on census region.

Table III.2—MHS PUF 2020 Census Region and Sales Price Data

Census region

Single-section sales price

(2020$)

Average

Minimum

Maximum

Dual-section sales price*

(2020$)

Average

Minimum

Maximum

Northeast

$57,916

$35,600

$95,000

$107,951

$56,000

$233,000

Midwest

56,983

33,200

79,000

104,987

54,000

184,000

South

56,798

31,400

79,000

106,942

58,000

170,000

West

61,748

34,100

117,000

118,282

64,000

236,000

All

57,233

31,400

117,000

108,583

54,000

236,000

* The MHS PUF 2020 dataset provides multi-section home sales price separately for dual-section homes and triple-section (or larger) homes; however the triple-section (or larger) homes data is not differentiated by census region. Therefore, DOE only presents the dual-section data in this table, which should generally represent the sales price for multi-section homes (triple-section or larger represent 1 percent of the market in 2020 based on the MHS PUF 2020 dataset).

Further, the MHS also summarizes average manufactured home sales price by state.

9

Table III.3 presents the average sales prices in 2020 per HUD climate zone based on the MHS data discussed previously and manufactured

home shipments published by Manufactured Housing Institute.

10

9

Manufactured Housing Survey, Annual Tables of New Manufactured Homes: 2014-2020;

https://www.census.gov/data/tables/time-series/econ/mhs/annual-data.html.

10

Manufactured Housing Institute, Annual Production and Shipment Data;

https://www.manufacturedhousing.org/annual-production/.

Table III.3—MHS Average Sales Price Data by HUD Climate Zone

HUD

climate

zone

Single-section average sales price

(2020$)

Dual-section average sales price

(2020$)

1

$57,124

$107,003

2

57,290

111,208

3

56,207

109,147

To determine the updated manufacturer's retail list price tier in a similar manner to what was considered in the August 2021 MH SNOPR, DOE assumed that price-sensitive, low-income purchasers rely on high-priced loans, given the inability to qualify for conventional loans. Based on the analysis in section III.A, the 70th percentile manufactured housing price gives an estimate for the upper bound for a manufactured home sales price that a price-sensitive low-income purchaser could afford. If people typically receive one primary loan, the percentage of high-priced loans used should be roughly equivalent to the percentage of people receiving high-priced loans (

e.g.,

70 percent). DOE considered that low-income purchasers would mainly purchase single-section homes that are, on average, at a lower sales price than multi-section homes. Applying the 70th percentile for single-section manufactured homes using the MHS PUF 2020 data yields a sales price of approximately $63,000 (in real 2020$).

Using the updated tier threshold at $63,000 (in real

2020$

) and the MHS PUF 2020 data set, DOE determined the shipment breakdown based on tier and climate zone using the same methodology as presented in the August 2021 MH SNOPR. 86 FR 47744, 47809-47810. This included applying a “substitution effect”

11

to 20 percent of homes within $1,000 of the price threshold ($63,001-$64,000) that would shift to less stringent standards,

i.e.,

from Tier 2 to Tier 1.

Id.

Accordingly, Table III.4 presents the corresponding percentage of total manufactured homes placed/sold applicable to each tier based on climate zone and size using the updated inputs. Compared to the August 2021 MH SNOPR, a higher percentage of single-section manufactured home shipments are in Tier 1,

i.e.,

Climate zone 1 or 2: 73.85 percent in this document vs. 53.58 percent in the August 2021 MH SNOPR; Climate zone 3: 73.28 percent in this document vs. 57.32 percent in the August 2021 MH SNOPR). Further, a portion of multi-section manufactured home shipments will also be in Tier 1.

11

DOE considered that a percentage of manufactured homes placed/sold would shift to less stringent standards,

i.e.,

a percentage of homes from Tier 2 would shift to Tier 1. The inclusion of this shift in the market is to more accurately estimate energy savings (and other downstream results).

Table III.4—Shipment Breakdown Based on Tier and Proposed Climate Zone

Climate zone 1 or 2

Single-section

(%)

Multi-section

(%)

Climate zone 3

Single-section

(%)

Multi-section

(%)

Combined

climate zone

(%)

Tier 1 Standard

74

5

73

3

35

Tier 2 Standard

26

95

27

97

65

Total

100

100

100

100

100

C. AEO 2021

The

AEO

presents long-term annual projections of energy supply, demand, and prices. The projections, focused on U.S. energy markets, are based on results from DOE Energy Information Administration's (“EIA”) National Energy Modeling System (“NEMS”). NEMS enables EIA to make projections under internally consistent sets of assumptions. DOE used

AEO

projections as inputs into several analyses for the August 2021 MH SNOPR, which are discussed in more detail in this section.

For the August 2021 MH SNOPR, DOE used inputs from

AEO 2020

for establishing energy prices, escalation rates, inflation rates and housing starts. 86 FR 47744, 47794. In this NODA, DOE maintains the same source as the August 2021 MH SNOPR, but updated the

AEO

source to the latest version, which is

AEO 2021.

12

Further, DOE updated the electricity prices from the EIA

Short-Term Energy Outlook.

13

Specifically, DOE used electricity prices from 2020 quarter 2 and quarter 3 for summer electricity prices, and quarter 4 of 2020 and quarter 1 of 2021 for winter electricity prices. Table III.5 presents a comparison of the August 2021 MH SNOPR and NODA fuel prices and escalation rates.

12

Energy Information Administration. Annual Energy Outlook 2021 with Projections to 2050. (2021).

13

Energy Information Administration. Short-Term Energy Outlook: Real Prices Viewer. Available at:

www.eia.gov/forecasts/steo/realprices/

.

Table III.5—AEO 2021 Fuel Prices and Escalation Rates Updates

SNOPR

Price

Escalation rate

(%)

NODA

Price

Escalation rate

(%)

Electricity:

Summer

13.3 cents/kWh

2.3

13.3 cents/kWh

2.2

Winter

12.9 cents/kWh

13.2 cents/kWh

Natural gas

10.3 $/MBtu

2.8

10.1 $/Mbtu

2.8

Liquid petroleum gas (LPG)

21.6 $/Mbtu

4.1

17.3 $/Mbtu

3.7

Oil

22.8 $/Mbtu

3.3

17.8 $/Mbtu

3.8

To forecast the nominal price increase of manufactured homes, DOE used the inflation forecast rate built into the

AEO 2021

at 2.28 percent, compared to the August 2021 MH SNOPR inflation based on

AEO 2020

at 2.33 percent. To forecast shipments into the future, DOE used a 5-year-average projection for growth in new housing starts from

AEO 2021

resulting in a 0.42 percent growth per year compared to the August 2021 MH SNOPR projection for growth based on

AEO 2020

at 0.3 percent growth per year.

For the August 2021 MH SNOPR, DOE derived annual average site-to-power plant factors based on the version of the NEMS that corresponds to AEO 2020. DOE calculated primary energy savings (power plant consumption) from site electricity savings by applying a factor to account for losses associated with the generation, transmission, and distribution of electricity. DOE computed the full-fuel cycle (“FFC”) by encompassing the energy consumed in extracting, processing, and transporting or distributing primary fuels, which we refer to as “upstream” activities. 86 FR 47744, 47814. In this NODA, DOE updated the same inputs to

AEO 2021.

Table III.6 presents a comparison of the August 2021 MH SNOPR (based on

AEO 2020

) and NODA (based on

AEO 2021

) primary energy and FFC factors.

Table III.6—Primary Energy and FFC Factors, 2020-2050

Factor type

Fuel type

Dimensionless factor

2020

2030

2040

2050

SNOPR

Primary

Electricity

2.881

2.669

2.650

2.653

FFC

Electricity

1.049

1.044

1.044

1.041

Natural Gas

1.109

1.114

1.112

1.107

LPG/Oil

1.174

1.172

1.176

1.180

NODA

Primary

Electricity

2.845

2.714

2.698

2.677

FFC

Electricity

1.044

1.039

1.037

1.037

Natural Gas

1.101

1.098

1.098

1.099

LPG/Oil

1.169

1.171

1.179

1.185

For the August 2021 MH SNOPR, DOE also used the

AEO 2020

to derive the power sector marginal emissions intensity factors for CO

2

, NO

X

, SO

2

, and Hg. 86 FR 47744, 47814. For this NODA, DOE updated the emissions factors to

AEO 2021.

Finally, in the August 2021 MH SNOPR, DOE also proposed that under the tiered proposal the manufacturer's retail list price thresholds would be adjusted for inflation (for the applicable year of compliance) using the most recently available AEO GDP deflator time series, which at the time was

AEO 2020.

86 FR 47744, 47761. As such, in Table III.7, DOE provides the updated AEO 2021 GDP deflator series.

Table III.7—AEO 2021 GDP Deflator

GDP deflator

2020

1

2025

1.0756

2030

1.2203

2035

1.3702

2040

1.5208

2045

1.7038

2050

1.9527

D. 2020 Shipments

The Institute for Building Technology and Safety (“IBTS”) provides yearly shipments of manufactured homes, which is also published by the Manufactured Housing Institute (“MHI”).

14

For the August 2021 MH SNOPR, DOE considered the 2019 shipment data provided through MHI as the latest data available at the time of the analysis. 86 FR 47744, 47798. For the August 2021 MH SNOPR, DOE only received historical shipment data of ENERGY STAR certified manufactured homes categorized by state from 2001 to 2015. Chapter 10 of the August 2021 MH SNOPR Technical Support Document (“TSD”). Further, DOE did not account for ENERGY STAR homes for the no-standard shipments and therefore excluded any ENERGY STAR shipments to avoid overestimating energy savings. 86 FR 47744, 47808.

14

See Manufactured Home Shipments by Product Mix, 2019, Manufactured Housing Institute.

www.manufacturedhousing.org/annual- production/.

In this NODA, DOE updated the August 2021 MH SNOPR analysis by considering the 2020 shipment data provided through MHI.

15

Further, DOE also received updated 2020 ENERGY STAR shipment data, albeit not separated by size (

i.e.,

single-section vs. multi-section). DOE notes that there are more ENERGY STAR shipments in 2020 than projected in the August 2021 MH SNOPR, which reduces the total number of shipments applicable for the no-standards case and standards case compared to the August 2021 MH SNOPR, in turn reducing the net present value (NPV) for both the untiered and tiered standards. Finally, as discussed in section III.C, DOE also updated the housing starts (shipment growth rate) to be consistent with

AEO 2021.

Table III.8 and Table III.9 presents the single-section and multi-section manufactured home shipments considered in the August 2021 MH SNOPR and this NODA.

15

See Manufactured Home Shipments by Product Mix, 2020, Manufactured Housing Institute.

www.manufacturedhousing.org/annual- production/.

Table III.8—Single-Section Manufactured Homes Shipments

Year

No-Standards case

SNOPR

NODA

Tiered standard

SNOPR

NODA

Untiered standard

SNOPR

NODA

2025

41,304

36,855

40,610

36,388

40,041

35,642

2030

41,923

37,632

41,225

37,155

40,640

36,395

2035

42,558

38,429

41,853

37,938

41,255

37,164

2040

43,198

39,243

42,481

38,744

41,876

37,950

2045

43,853

40,074

43,128

39,565

42,507

38,754

2050

44,514

40,927

43,768

40,403

43,153

39,579

Table III.9—Multi-Section Manufactured Homes Shipments

Year

No-Standards case

SNOPR

NODA

Tiered standard

SNOPR

NODA

Untiered standard

SNOPR

NODA

2025

48,268

43,045

47,247

42,069

47,247

42,038

2030

48,999

43,952

47,961

42,965

47,961

42,924

2035

49,738

44,886

48,685

43,869

48,685

43,836

2040

50,489

45,836

49,421

44,800

49,421

44,768

2045

51,249

46,803

50,163

45,752

50,163

45,710

2050

52,019

47,798

50,919

46,727

50,919

46,681

IV. Summary of Updated SNOPR Analysis Results

This section provides the results for the LCC and PBP, NIA and Emissions analyses based on the updates discussed in section III.

Table IV.1—Average Manufactured Housing Purchase Price (and Percentage) Increases Under the Tiered Standard

[2020$]

Tier 1

Single-section

$

%

Multi-section

$

%

Tier 2

Single-section

$

%

Multi-section

$

%

Climate Zone 1

$627

1.2

$897

0.9

$2,567

4.8

$4,131

4.0

Climate Zone 2

627

1.2

897

0.9

4,806

9.0

6,149

5.9

Climate Zone 3

719

1.4

700

0.7

4,645

8.7

5,822

5.6

National Average

660

1.2

839

0.8

3,902

7.3

5,267

5.1

Table IV.2—Average Manufactured Housing Purchase Price (and Percentage) Increases Under Untiered Standard

[2020$]

Untiered

Single-section

$

%

Multi-section

$

%

Climate Zone 1

$2,567

4.8

$4,131

4.0

Climate Zone 2

4,806

9.0

6,149

5.9

Climate Zone 3

4,645

8.7

5,822

5.6

National Average

3,902

7.3

5,267

5.1

Table IV.3—Average Manufactured Home LCC Savings (30 Years) Under the Tiered Standard by Climate Zone

[2020$] *

Tier 1

Single-section

Multi-section

Tier 2

Single-section

Multi-section

Climate Zone 1

$1,042

$1,601

$2,427

$3,844

Climate Zone 2

1,143

1,705

1,156

1,983

Climate Zone 3

2,560

3,550

2,311

3,056

National Average

1,606

2,205

2,045

3,023

* No cities exhibit negative LCC savings in Tier 1. San Francisco is the only city that exhibits negative LCC savings in Tier 2.

Table IV.4—Average Manufactured Home LCC Savings (30 Years) Under the Tiered Standard by Climate Zone

[2020$] *

Climate zone

City

Tier 1

Single-section

Multi-section

Tier 2

Single-section

Multi-section

1

Miami

$460

$850

$1,345

$2,336

1

Houston

931

1,541

2,231

3,747

1

Atlanta

1,532

2,481

3,258

5,468

1

Charleston

1,093

1,773

2,494

4,176

1

Jackson

1,312

2,104

2,989

4,968

1

Birmingham

1,317

2,101

2,895

4,806

2

Phoenix

616

1,026

665

1,763

2

Memphis

1,493

2,364

1,491

2,743

2

El Paso

990

1,547

1,106

2,185

2

San Francisco

543

812

(387)

(68)

2

Albuquerque

1,089

1,719

1,074

2,096

3

Baltimore

2,422

3,678

2,002

3,164

3

Salem

1,475

2,191

411

822

3

Chicago

2,443

3,738

2,018

3,239

3

Boise

1,682

2,562

890

1,558

3

Burlington

2,503

3,798

2,193

3,439

3

Helena

2,441

3,631

2,431

3,631

3

Duluth

3,917

5,794

5,013

7,256

3

Fairbanks

5,851

8,516

9,307

13,065

National Average

1,606

2,205

2,045

3,023

* Negative values in parenthesis.

Table IV.5—Average Manufactured Home LCC Savings (30 Years) Under the Untiered Standard by Climate Zone

[2020$] *

Single-section

Multi-section

Climate Zone 1

$2,154

$3,409

Climate Zone 2

863

1,573

Climate Zone 3

1,942

2,583

National Average

1,733

2,585

* San Francisco is the only city that exhibits negative LCC savings in the untiered standard results.

Table IV.6—Average Manufactured Home LCC Savings (30 Years) Under the Untiered Standard by Climate Zone

[2020$] *

Climate zone

City

Single-section

Multi-section

1

Miami

$1,142

$1,998

1

Houston

1,971

3,318

1

Atlanta

2,931

4,928

1

Charleston

2,217

3,719

1

Jackson

2,680

4,459

1

Birmingham

2,592

4,308

2

Phoenix

403

1,368

2

Memphis

1,176

2,286

2

El Paso

817

1,766

2

San Francisco

(585)

(349)

2

Albuquerque

781

1,674

3

Baltimore

1,662

2,696

3

Salem

167

495

3

Chicago

1,667

2,751

3

Boise

614

1,183

3

Burlington

1,822

2,929

3

Helena

2,053

3,118

3

Duluth

4,462

6,501

3

Fairbanks

8,478

11,933

National Average

1,733

2,585

* Negative values in parenthesis.

Table IV.7—Average Manufactured Home Simple Payback Period Under the Tiered Standard by Climate Zone

Tier 1

Single-section

Multi-section

Tier 2

Single-section

Multi-section

Climate Zone 1

4.7

4.5

8.5

8.5

Climate Zone 2

4.5

4.4

13.3

12.5

Climate Zone 3

2.9

2.1

11.5

11.3

National Average

3.7

3.5

11.0

10.6

Table IV.8—Average Manufactured Home Simple Payback Period Under the Tiered Standard by Climate Zone

Climate zone

City

Tier 1

Single-section

Multi-section

Tier 2

Single-section

Multi-section

1

Miami

7.4

6.5

10.8

10.5

1

Houston

5.1

4.6

8.8

8.6

1

Atlanta

3.7

3.3

7.3

7.1

1

Charleston

4.6

4.2

8.4

8.2

1

Jackson

4.1

3.8

7.6

7.5

1

Birmingham

4.1

3.8

7.8

7.6

2

Phoenix

6.5

6.0

14.5

12.9

2

Memphis

3.7

3.5

12.6

11.4

2

El Paso

4.9

4.6

13.3

12.1

2

San Francisco

7.2

7.0

18.5

17.1

2

Albuquerque

4.8

4.5

13.9

12.7

3

Baltimore

2.9

2.0

11.5

10.7

3

Salem

4.3

3.2

15.8

15.1

3

Chicago

3.0

2.1

12.1

11.2

3

Boise

3.9

2.8

14.4

13.6

3

Burlington

3.0

2.1

12.2

11.3

3

Helena

3.0

2.1

11.4

10.7

3

Duluth

2.0

1.4

8.4

7.8

3

Fairbanks

1.4

1.0

5.7

5.3

National Average

3.7

3.5

11.0

10.6

Table IV.9—Average Manufactured Home Simple Payback Period Under the Untiered Standard by Climate Zone

Single-section

Multi-section

Climate Zone 1

8.5

8.5

Climate Zone 2

13.3

12.5

Climate Zone 3

11.5

11.3

National Average

11.0

10.6

Table IV.10—Average Manufactured Home Simple Payback Period Under the Untiered Standard by Climate Zone

Climate zone

City

Single-section

Multi-section

1

Miami

10.8

10.5

1

Houston

8.8

8.6

1

Atlanta

7.3

7.1

1

Charleston

8.4

8.2

1

Jackson

7.6

7.5

1

Birmingham

7.8

7.6

2

Phoenix

14.5

12.9

2

Memphis

12.6

11.4

2

El Paso

13.3

12.1

2

San Francisco

18.5

17.1

2

Albuquerque

13.9

12.7

3

Baltimore

11.5

10.7

3

Salem

15.8

15.1

3

Chicago

12.1

11.2

3

Boise

14.4

13.6

3

Burlington

12.2

11.3

3

Helena

11.4

10.7

3

Duluth

8.4

7.8

3

Fairbanks

5.7

5.3

National Average

11.0

10.6

Table IV.11—National Average Per-Home Cost Savings *

Single-section

Multi-section

Tier 1 Standard

Lifecycle Cost Savings (30-Year Lifetime)

$1,606

$2,205

Lifecycle Cost Savings (10-Year Lifetime)

$726

$1,015

Annual Energy Cost Savings in 2020$

$176

$238

Simple Payback Period

3.7

3.5

Tier 2 Standard

Lifecycle Cost Savings (30-Year Lifetime)

$2,045

$3,023

Lifecycle Cost Savings (10-Year Lifetime)

$78

$235

Annual Energy Cost Savings in 2020$

$354

$496

Simple Payback Period

11.0

10.6

Untiered Standard

Lifecycle Cost Savings (30-Year Lifetime)

$1,733

$2,585

Lifecycle Cost Savings (10-Year Lifetime)

($57)

$50

Annual Energy Cost Savings in 2020$

$354

$496

Simple Payback Period

11.0

10.6

* Negative values in parenthesis.

Table IV.12—Cumulative Full-Fuel-Cycle National Energy Savings of Manufactured Homes Purchased 2023-2052 with a 30-Year Lifetime

Single-section

quadrillion Btu

(quads)

Multi-section

(quads)

Tiered Standard

Climate Zone 1

0.163

0.526

Climate Zone 2

0.139

0.475

Climate Zone 3

0.274

0.435

Total

0.576

1.436

Untiered Standard

Climate Zone 1

0.276

0.542

Climate Zone 2

0.249

0.489

Climate Zone 3

0.370

0.439

Total

0.894

1.470

Table IV.13—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime at a 7% Discount Rate *

Single-section

billion 2020$

Multi-section

billion 2020$

Tiered Standard

Climate Zone 1

$0.15

$0.31

Climate Zone 2

0.08

(0.01)

Climate Zone 3

0.33

0.18

Total

0.56

0.48

Untiered Standard

Climate Zone 1

$0.16

$0.30

Climate Zone 2

(0.06)

(0.04)

Climate Zone 3

0.11

0.16

Total

0.21

0.42

* Negative values in parenthesis.

Table IV.14—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime at a 3% Discount Rate

Single-section

billion 2020$

Multi-section

billion 2020$

Tiered Standard

Climate Zone 1

$0.45

$1.15

Climate Zone 2

0.29

0.45

Climate Zone 3

0.99

0.86

Total

1.73

2.47

Untiered Standard

Climate Zone 1

$0.57

$1.11

Climate Zone 2

0.09

0.35

Climate Zone 3

0.62

0.78

Total

1.28

2.23

Table IV.15—Emissions Reductions Associated With Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime

Pollutant

Tiered standard

Single-section

Multi-section

Untiered standards

Single-section

Multi-section

Site Emissions Reductions

CO

2

(million metric tons)

23.7

55.1

35.7

56.2

Hg (metric tons)

0.037

0.097

0.058

0.0995

NO

X

(thousand metric tons)

12.9

27.5

18.8

28.0

SO

2

(thousand metric tons)

8.8

20.9

13.4

21.3

CH

4

(thousand metric tons)

1.28

3.16

1.97

3.24

N

2

O (thousand metric tons)

0.26

0.58

0.383

0.591

Upstream Emissions Reductions

CO

2

(million metric tons)

2.4

5.2

3.52

5.3

Hg (metric tons)

1.84E-04

4.52E-04

2.84E-04

4.63E-04

NO

X

(thousand metric tons)

30.4

66.6

44.8

68

SO

2

(thousand metric tons)

0.24

0.48

0.343

0.49

CH

4

(thousand metric tons)

155

362

234

370

N

2

O (thousand metric tons)

0.013

0.027

0.019

0.028

Total Emissions Reductions

CO

2

(million metric tons)

26.2

60.3

39.3

61.5

Hg (metric tons)

0.037

0.097

0.059

0.1

NO

X

(thousand metric tons)

43

94.1

64

96

SO

2

(thousand metric tons)

9.1

21.4

13.7

21.8

CH

4

(thousand metric tons)

156

365

236

373

N

2

O (thousand metric tons)

0.27

0.61

0.40

0.62

Table IV.16—Net Present Value of Monetized Benefits From GHG and Emissions Reductions

Discount rate

%

Net present value

million 2020$

Tiered standard

Single-section

Multi-section

Untiered Standard

Single-section

Multi-section

GHG Reduction (using avg. social costs at 5% discount rate) *

5

254.2

587.8

382.2

600.7

GHG Reduction (using avg. social costs at 3% discount rate) *

3

1,074.3

2,481.0

1,614.1

2,535.2

GHG Reduction (using avg. social costs at 2.5% discount rate) *

2.5

1,763.2

4,069.6

2,648.5

4,158.4

GHG Reduction (using 95th percentile social costs at 3% discount rate) *

3

3,229.0

7,454.7

4,850.7

7,617.5

NO

X

Reduction **

3

114.5

233.6

165.0

243.1

7

39.9

81.6

57.5

84.9

SO

2

Reduction **

3

176.2

373.2

257.2

389.0

7

62.0

132.3

90.8

137.9

* Estimates of SC-CO

2

SC-CH

4

, and SC-N

2

O are calculated using a range of discount rates for use in regulatory analyses. Three sets of values are based on the average social costs from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth set, which represents the 95th percentile of the social cost distributions. calculated using a 3-percent discount rate, is included to represent higher-than-expected impacts from climate change further out in the tails of the social cost distributions. The social cost values are emission year specific. See section IV.D of the August 2021 MH SNOPR for more details.

** The benefits from NO

X

and SO

2

were based on the low estimate monetized value.

V. Sensitivity Analysis Results—Alternate Size-Based Tier Threshold for the Tiered Standard

For this NODA, DOE also considered a sensitivity analysis where the tier threshold for the tiered standard would be based on the manufactured home size instead of the manufacturer's retail list price. Specifically, the Tier 1 standard would apply to all single-section homes, and the Tier 2 standard would apply to all multi-section homes. Table V.1 presents the updated shipments breakdown for this sensitivity analysis using the MHS 2020 PUF data set.

Table V.1—Shipment Breakdown Based on Tier Under the Alternate Size-Based Threshold

All climate zones

Single-section

(%)

Multi-section

(%)

Total

(%)

Tier 1 Standard

100

0

45

Tier 2 Standard

0

100

55

Total

100

100

100

The following tables present the results for the NIA and emissions analyses results based on the alternate size-based tier threshold for the tiered standard only. DOE notes that the LCC and PBP analyses results presented in section IV for both the tiered and untiered standards would not change for this sensitivity analysis. This is because the LCC and PBP analysis evaluates the economic impacts on individual consumers of energy conservation standards for manufactured housing, not the entire nation. Further, the NIA and emissions results presented in section IV for the untiered standard would also not change for this sensitivity analysis because the tier threshold does not apply.

Table V.2—Cumulative Full-Fuel-Cycle National Energy Savings of Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime Under the Alternate Size-Based Threshold

Tiered standard

Single-section

(quads)

Multi-section

(quads)

Climate Zone 1

0.123

0.542

Climate Zone 2

0.100

0.489

Climate Zone 3

0.239

0.439

Total

0.462

1.470

Table V.3—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime Under the Alternate Size-Based Threshold

Tiered Standard

7% discount rate

Single-section

billion 2020$

Multi-section *

billion 2020$

3% discount rate

Single-section

billion 2020$

Multi-section *

billion 2020$

Climate Zone 1

$0.15

$0.31

$0.40

$1.17

Climate Zone 2

0.13

(0.03)

0.35

0.44

Climate Zone 3

0.40

0.17

1.10

0.85

Total

0.68

0.45

1.85

2.46

* Negative values in parenthesis.

Table V.4—Emissions Reductions Associated for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime Under the Alternate Size-Based Threshold

Tiered Standard

Pollutant

Single-section

Multi-section

Site Emissions Reductions

CO

2

(million metric tons)

19.5

56.2

Hg (metric tons)

0.0292

0.0995

NO

X

(thousand metric tons)

10.9

28.0

SO

2

(thousand metric tons)

7.2

21.3

CH

4

(thousand metric tons)

1.03

3.24

N

2

O (thousand metric tons)

0.21

0.59

Upstream Emissions Reductions

CO

2

(million metric tons)

2.0

5.3

Hg (metric tons)

1.48E-04

4.63E-04

NO

X

(thousand metric tons)

25.4

68.0

SO

2

(thousand metric tons)

0.21

0.49

CH

4

(thousand metric tons)

127

370

N

2

O (thousand metric tons)

0.011

0.028

Total Emissions Reductions

CO

2

(million metric tons)

21.5

61.5

Hg (metric tons)

0.029

0.100

NO

X

(thousand metric tons)

36.3

96

SO

2

(thousand metric tons)

7.4

21.8

CH

4

(thousand metric tons)

128

373

N

2

O (thousand metric tons)

0.23

0.62

Table V.5—Net Present Value of Monetized Benefits From GHG and Emissions Reductions Under the Alternate Size-Based Threshold

Tiered standard

Monetary benefits

Discount rate

%

Net present value

million 2020$

Single-section

Multi-section

GHG Reduction (using avg. social costs at 5% discount rate) *

5

208.5

600.7

GHG Reduction (using avg. social costs at 3% discount rate) *

3

881.3

2,535.2

GHG Reduction (using avg. social costs at 2.5% discount rate) *

2.5

1,446.6

4,158.4

GHG Reduction (using 95th percentile social costs at 3% discount rate) *

3

2,648.9

7,617.5

NO

X

Reduction **

3

96.4

243.1

7

33.5

84.9

SO

2

Reduction **

3

147.2

389.0

7

51.7

137.9

* Estimates of SC-CO

2

SC-CH

4

, and SC-N

2

O are calculated using a range of discount rates for use in regulatory analyses. Three sets of values are based on the average social costs from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth set, which represents the 95th percentile of the social cost distributions calculated using a 3-percent discount rate, is included to represent higher-than-expected impacts from climate change further out in the tails of the social cost distributions. The social cost values are emission year specific. See section IV.D of the August 2021 MH SNOPR for more details.

** The benefits from NO

X

and SO

2

were based on the low estimate monetized value.

VI. Sensitivity Analysis Results—Alternate R-21 Exterior Wall Insulation for Climate Zone 2 and 3 for Tier 2 and Untiered Standards

For this NODA, DOE also conducted a sensitivity analysis using less stringent measures for exterior wall insulation for the Tier 2 and untiered standards. Specifically, the component requirements proposed in the August 2021 MH SNOPR for the prescriptive path for Climate Zone 2 and 3 require that exterior walls be sealed using R-20+5 exterior wall insulation. DOE proposed this requirement based on the 2021 IECC without modification. The “+5” involves using “continuous insulation,” which is insulation that runs continuously over structural members and is free of significant thermal bridging. DOE's proposal requires continuous insulation only for the exterior wall insulation component. 86 FR 47744, 47772.

Accordingly, in this NODA, DOE considered a sensitivity analysis wherein DOE analyzed a less stringent exterior wall insulation requirement for the Tier 2/untiered standard instead. In this sensitivity analysis, DOE considered an R-21 exterior wall insulation as opposed to the proposed R-20+5, which would require continuous insulation. At R-20+5, the incremental cost relative to the baseline is $2,500, versus $850 for R-21. For this analysis, DOE maintained the NODA-updated manufacturer tier threshold (at $60,000 in real

2020$

) for the tiered standard.

The following tables present the results based on the alternate wall insulation for climate zone 2 and 3 for the Tier 2 and untiered standards only. DOE notes that the Tier 1 results presented in section IV would not change for this sensitivity analysis.

Table VI.1—Average Manufactured Housing Purchase Price (and Percentage) Increases Under Tier 2 of the Tiered Standard and the Untiered Standard

[2020$]

Tier 2/untiered

Single-section

$

%

Multi-section

$

%

Climate Zone 1

$2,567

4.8

$4,131

4.0

Climate Zone 2

3,082

5.8

4,438

4.3

Climate Zone 3

2,921

5.5

4,111

4.0

National Average

2,830

5.3

4,222

4.1

Table VI.2—Average Manufactured Home LCC Savings (30 Years) by Climate Zone

[2020$] *

Tier 2 standard

Single-section

Multi-section

Untiered standard

Single-section

Multi-section

Climate Zone 1

$2,427

$3,844

$2,154

$3,409

Climate Zone 2

2,401

3,238

2,105

2,826

Climate Zone 3

3,333

4,101

2,977

3,639

National Average

2,740

3,727

2,432

3,291

* No cities exhibit negative LCC savings in Tier 1 or Tier 2.

Table VI.3—Average Manufactured Home LCC Savings (30 Years) by Climate Zone

[2020$]

Climate zone

City

Tier 2 standard

Single-section

Multi-section

Untiered standard

Single-section

Multi-section

1

Miami

$1,345

$2,336

$1,142

$1,998

1

Houston

2,231

3,747

1,971

3,318

1

Atlanta

3,258

5,468

2,931

4,928

1

Charleston

2,494

4,176

2,217

3,719

1

Jackson

2,989

4,968

2,680

4,459

1

Birmingham

2,895

4,806

2,592

4,308

2

Phoenix

1,987

3,076

1,718

2,674

2

Memphis

2,718

3,967

2,402

3,508

2

El Paso

2,353

3,431

2,061

3,008

2

San Francisco

951

1,274

745

985

2

Albuquerque

2,306

3,325

2,012

2,902

3

Baltimore

3,053

4,211

2,723

3,752

3

Salem

1,582

1,992

1,341

1,668

3

Chicago

3,079

4,291

2,738

3,814

3

Boise

2,001

2,669

1,732

2,301

3

Burlington

3,230

4,468

2,872

3,970

3

Helena

3,381

4,583

3,021

4,087

3

Duluth

5,778

8,015

5,258

7,290

3

Fairbanks

9,600

13,363

8,831

12,291

National Average

2,740

3,727

2,432

3,291

Table VI.4—Average Manufactured Home Simple Payback Period by Climate Zone

Tier 2/untiered standard

Single-section

Multi-section

Climate Zone 1

8.5

8.5

Climate Zone 2

9.3

9.6

Climate Zone 3

8.1

8.6

National Average

8.5

8.9

Table VI.5—Average Manufactured Home Simple Payback Period by Climate Zone

Climate zone

City

Tier 2 standard/untiered

standard

Single-section

Multi-section

1

Miami

10.8

10.5

1

Houston

8.8

8.6

1

Atlanta

7.3

7.1

1

Charleston

8.4

8.2

1

Jackson

7.6

7.5

1

Birmingham

7.8

7.6

2

Phoenix

10.1

9.8

2

Memphis

8.8

8.7

2

El Paso

9.3

9.3

2

San Francisco

13.0

13.2

2

Albuquerque

9.7

9.7

3

Baltimore

8.1

8.2

3

Salem

11.2

11.6

3

Chicago

8.5

8.5

3

Boise

10.3

10.5

3

Burlington

8.6

8.7

3

Helena

8.1

8.2

3

Duluth

5.9

5.9

3

Fairbanks

4.0

4.1

National Average

8.5

8.9

Table VI.6—National Average Per-Home Cost Savings

Single-section

Multi-section

Tier 2 Standard

Lifecycle Cost Savings (30-Year Lifetime)

$2,740

$3,727

Lifecycle Cost Savings (10-Year Lifetime)

$632

$788

Annual Energy Cost Savings in 2020$

$331

$475

Simple Payback Period

8.5

8.9

Untiered Standard

Lifecycle Cost Savings (30-Year Lifetime)

$2,432

$3,291

Lifecycle Cost Savings (10-Year Lifetime)

$518

$622

Annual Energy Cost Savings in 2020$

$331

$475

Simple Payback Period

8.5

8.9

Table VI.7—Cumulative Full-Fuel-Cycle National Energy Savings of Manufactured Homes Purchased 2023-2052 with a 30-Year Lifetime

Single-section

(quads)

Multi-section

(quads)

Tiered Standard

Climate Zone 1

0.163

0.526

Climate Zone 2

0.134

0.451

Climate Zone 3

0.265

0.405

Total

0.562

1.382

Untiered Standard

Climate Zone 1

0.276

0.542

Climate Zone 2

0.231

0.463

Climate Zone 3

0.336

0.408

Total

0.843

1.414

Table VI.8—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime at a 7% Discount Rate

Single-section

billion 2020$

Multi-section

billion 2020$

Tiered Standard

Climate Zone 1

$0.15

$0.31

Climate Zone 2

0.12

0.21

Climate Zone 3

0.37

0.33

Total

0.65

0.85

Untiered Standard

Climate Zone 1

0.16

0.30

Climate Zone 2

0.10

0.20

Climate Zone 3

0.29

0.32

Total

0.55

0.82

Table VI.9—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime at a 3% Discount Rate

Single-section

billion 2020$

Multi-section

billion 2020$

Tiered Standard

Climate Zone 1

$0.45

$1.15

Climate Zone 2

0.37

0.89

Climate Zone 3

1.07

1.16

Total

1.90

3.20

Untiered Standard

Climate Zone 1

0.57

1.11

Climate Zone 2

0.43

0.83

Climate Zone 3

0.96

1.10

Total

1.96

3.03

Table VI.10—Emissions Reductions for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime

Pollutant

Tiered standard

Single-section

Multi-section

Untiered standard

Single-section

Multi-section

Site Emissions Reductions

CO

2

(million metric tons)

23.1

52.7

33.5

53.8

Hg (metric tons)

0.036

0.094

0.055

0.096

NO

X

(thousand metric tons)

12.6

26.1

17.4

26.6

SO

2

(thousand metric tons)

8.6

20.0

12.5

20.4

CH

4

(thousand metric tons)

1.25

3.04

1.86

3.11

N

2

O (thousand metric tons)

0.25

0.55

0.36

0.57

Upstream Emissions Reductions

CO

2

(million metric tons)

2.35

5.0

3.3

5.1

Hg (metric tons)

1.79E-04

4.35E-04

2.67E-04

4.45E-04

NO

X

(thousand metric tons)

29.6

63.5

41.7

64.8

SO

2

(thousand metric tons)

0.24

0.46

0.318

0.47

CH

4

(thousand metric tons)

151

347

219

354

N

2

O (thousand metric tons)

0.013

0.026

0.017

0.026

Total Emissions Reductions

CO

2

(million metric tons)

25.5

57.7

36.8

58.9

Hg (metric tons)

0.036

0.094

0.056

0.096

NO

X

(thousand metric tons)

42

90

59

91

SO

2

(thousand metric tons)

8.9

20.4

12.9

20.9

CH

4

(thousand metric tons)

152

350

221

357

N

2

O (thousand metric tons)

0.26

0.58

0.38

0.59

Table VI.11—Net Present Value of Monetized Benefits From GHG and Emissions Reductions

Monetary benefits

Discount rate

%

Net present value

million 2020$

Tiered standard

Single-section

Multi-section

Untiered standard

Single-section

Multi-section

GHG Reduction (using avg. social costs at 5% discount rate) *

5

247.8

563.0

358.0

574.9

GHG Reduction (using avg. social costs at 3% discount rate) *

3

1,047.3

2,375.8

1,511.8

2,426.0

GHG Reduction (using avg. social costs at 2.5% discount rate) *

2.5

1,718.8

3,896.9

2,480.4

3,979.1

GHG Reduction (using 95th percentile social costs at 3% discount rate) *

3

3,147.6

7,138.5

4,543.0

7,289.0

NO

X

Reduction **

3

111.4

221.8

153.2

230.8

7

38.8

77.5

53.4

80.7

SO

2

Reduction **

3

171.6

355.4

239.6

370.5

7

60.4

126.0

84.6

131.4

* Estimates of SC-CO

2

SC-CH

4

, and SC-N

2

O are calculated using a range of discount rates for use in regulatory analyses. Three sets of values are based on the average social costs from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth set, which represents the 95th percentile of the social cost distributions calculated using a 3-percent discount rate, is included to represent higher-than-expected impacts from climate change further out in the tails of the social cost distributions. The social cost values are emission year specific. See section IV.D of the August 2021 MH SNOPR for more details.

** The benefits from NO

X

and SO

2

were based on the low estimate monetized value.

A. Sensitivity Analysis Results—Alternate R-21 Exterior Wall Insulation for Climate Zone 2 and 3 Combined With Alternate Size-Based Tier Threshold for Tiered Standard

DOE also considered the same sensitivity analysis using the alternate R-21 exterior wall insulation for climate zone 2 and 3, but using the alternate size-based tier threshold (as discussed in section V) instead of the manufacturer's retail list price tier threshold (as discussed in section III.B).

The following tables present the results for the NIA and emissions analyses results based on this sensitivity for the tiered standard only. The LCC and PBP results for Tier 1 presented in section IV and Tier 2/untiered standard presented in section VI would remain unchanged for this sensitivity analysis. The NIA and emissions analysis results for the untiered standard presented in section VI would remain unchanged for this sensitivity analysis.

Table VI.12—Cumulative Full-Fuel-Cycle National Energy Savings of Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime Under the Alternate Size-Based Threshold

Tiered standard

Single-section

(quads)

Multi-section

(quads)

Climate Zone 1

0.123

0.542

Climate Zone 2

0.100

0.463

Climate Zone 3

0.239

0.408

Total

0.462

1.414

Table VI.13—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime Under the Alternate Size-Based Threshold

Tiered standard

7% discount rate

Single-section

billion 2020$

Multi-section

billion 2020$

3% discount rate

Single-section

billion 2020$

Multi-section

billion 2020$

Climate Zone 1

$0.15

$0.31

$0.40

$1.17

Climate Zone 2

0.13

0.20

0.35

0.89

Climate Zone 3

0.40

0.33

1.10

1.15

Total

0.68

0.84

1.85

3.22

Table VI.14—Emissions Reductions Associated With Electricity Production for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime Under the Alternate Size-Based Threshold

Tiered standard

Pollutant

Single-section

Multi-section

Site Emissions Reductions

CO

2

(million metric tons)

19.5

53.8

Hg (metric tons)

0.0292

0.096

NO

X

(thousand metric tons)

10.9

26.6

SO

2

(thousand metric tons)

7.2

20.4

CH

4

(thousand metric tons)

1.03

3.11

N

2

O (thousand metric tons)

0.21

0.57

Upstream Emissions Reductions

CO

2

(million metric tons)

2.0

5.1

Hg (metric tons)

1.48E-04

4.45E-04

NO

X

(thousand metric tons)

25.4

64.8

SO

2

(thousand metric tons)

0.21

0.47

CH

4

(thousand metric tons)

127

354

N

2

O (thousand metric tons)

0.011

0.026

Total Emissions Reductions

CO

2

(million metric tons)

21.5

58.9

Hg (metric tons)

0.029

0.0964

NO

X

(thousand metric tons)

36.3

91.4

SO

2

(thousand metric tons)

7.4

20.9

CH

4

(thousand metric tons)

128

357

N

2

O (thousand metric tons)

0.23

0.59

Table VI.15—Net Present Value of Monetized Benefits From GHG and Emissions Reductions Under the Alternate Size-Based Threshold

Tiered standard

Monetary Benefits

Discount rate

%

Net present value

million 2020$

Single-section

Multi-section

GHG Reduction (using avg. social costs at 5% discount rate) *

5

208.5

574.9

GHG Reduction (using avg. social costs at 3% discount rate) *

3

881.3

2,426.0

GHG Reduction (using avg. social costs at 2.5% discount rate) *

2.5

1,446.6

3,979.1

GHG Reduction (using 95th percentile social costs at 3% discount rate) *

3

2,648.9

7,289.0

NO

X

Reduction **

3

96.4

230.8

7

33.5

80.7

SO

2

Reduction **

3

147.2

370.5

7

51.7

131.4

* Estimates of SC-CO

2

SC-CH

4

, and SC-N

2

O are calculated using a range of discount rates for use in regulatory analyses. Three sets of values are based on the average social costs from the integrated assessment models, at discount rates of 5 percent, 3 percent, and 2.5 percent. The fourth set, which represents the 95th percentile of the social cost distributions calculated using a 3-percent discount rate, is included to represent higher-than-expected impacts from climate change further out in the tails of the social cost distributions. The social cost values are emission year specific. See section IV.D of the August 2021 MH SNOPR for more details.

** The benefits from NO

X

and SO

2

were based on the low estimate monetized value.

VII. Comparison of the August 2021 MH SNOPR and NODA Results

This section provides summary tables that compare the results from the August 2021 MH SNOPR to all the scenarios presented in this NODA, including the sensitivity analyses. As such, each table presents results for the: (1) August 2021 MH SNOPR analysis; (2) NODA updated SNOPR analysis (section IV); (3) NODA sensitivity—alternate size-based tier threshold (section V); (4) NODA sensitivity—alternate R-21 wall insulation for climate zone 2 and 3 for Tier 2 and untiered (section VI); and (5) NODA sensitivity—alternate R-21 wall insulation for climate zone 2 and 3 and alternate size-based tier threshold (section VI.A).

In the August 2021 MH SNOPR, DOE estimated the SNOPR would result in a decrease in shipments of about 53,329 homes (single section and multi-section combined) for the tiered standard and about 71,290 homes (single section and multi-section combined) for untiered standards based on a price elasticity of demand of -0.48 for the 30 year analysis period (2023-2052). 86 FR 47744, 47758. Table VII.1 presents the same results for the NODA and sensitivity analyses.

Table VII.1—Change In Shipments for Tiered and Untiered Standards

Reduction in shipments (total)

Tiered

Untiered

August 2021 MH SNOPR

53,329

71,290

NODA Updated SNOPR

45,562

70,203

Sensitivity—Alternate Size-Based Tier Threshold

38,288

N/A

Sensitivity—Alternate R-21 Wall Insulation

36,648

53,185

Sensitivity—Alternate R-21 Wall Insulation and Size-Based Tier Threshold

31,956

N/A

The following tables present the NPV results for the August 2021 MH SNOPR and all the scenarios presented in this NODA, including the sensitivity analyses.

Table VII.2—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime at a 7% Discount Rate

[In

billion 2020$

] *

Climate zone

August 2021 MH SNOPR

NODA

updated

SNOPR

Sensitivity—

alternate size-

based tier

threshold

Sensitivity—

alternate R-21

wall insulation

Sensitivity—

alternate R-21

wall insulation

and size-

based tier

threshold

Tiered Standard (

Single-section + Multi-section

)

1

$0.69

$0.46

$0.46

$0.46

$0.46

2

0.16

0.07

0.10

0.33

0.33

3

0.78

0.51

0.57

0.70

0.73

Total

1.62

1.04

1.13

1.50

1.52

Untiered Standard (

Single-section + Multi-section

)

1

0.70

0.46

N/A

0.46

N/A

2

0.06

(0.10)

N/A

0.30

N/A

3

0.61

0.27

N/A

0.61

N/A

Total

1.36

0.63

N/A

1.37

N/A

* Negative values in parenthesis.

Table VII.3—Net Present Value of Consumer Benefits for Manufactured Homes Purchased 2023-2052 With a 30-Year Lifetime at a 3% Discount Rate

[In billion 2020$] *

Climate zone

August 2021 MH SNOPR

NODA updated SNOPR

Sensitivity—

alternate size-based tier threshold

Sensitivity—

alternate R-21

wall insulation

Sensitivity—

alternate R-21

wall insulation

and size-

based tier

threshold

Tiered Standard (

Single-Section + Multi-Section

)

1

$2.39

$1.60

$1.57

$1.60

$1.57

2

1.17

0.74

0.79

1.26

1.24

3

2.84

1.85

1.95

2.23

2.25

Total

6.40

4.20

4.31

5.10

5.07

Untiered Standard (

Single-Section + Multi-Section

)

1

2.48

1.68

N/A

1.68

N/A

2

1.02

0.44

N/A

1.26

N/A

3

2.56

1.40

N/A

2.06

N/A

Total

6.06

3.51

N/A

4.99

N/A

Table VII.4—Net Present Value of Monetized Benefits From GHG and Emissions Reductions

Monetary benefits

Discount rate

%

Net present value

million 2020$

August 2021 MH SNOPR

NODA updated SNOPR

Sensitivity—

alternate size-based tier threshold

Sensitivity—

alternate R-21

wall insulation

Sensitivity—

alternate R-21

wall insulation

and size-

based tier

threshold

Tiered Standard

GHG

5

$1,075.4

$842.1

$809.2

$810.8

$783.4

3

4,525.0

3,555.4

3,416.5

3,423.1

3,307.2

NO

X

3

446.0

348.1

339.5

333.1

327.2

7

157.2

121.5

118.5

116.3

114.2

SO

2

3

734.7

549.5

536.2

527.0

517.7

7

259.3

194.3

189.6

186.4

183.1

Untiered Standard

GHG

5

1,190.5

982.9

N/A

932.9

N/A

3

5,009.4

4,149.4

N/A

3,937.7

N/A

NO

X

3

491.7

408.1

N/A

384.0

N/A

7

173.3

142.5

N/A

134.1

N/A

SO

2

3

811.0

646.2

N/A

610.1

N/A

7

286.3

228.7

N/A

216.0

N/A

VIII. Reopening of Comment Period

For the August 2021 MH SNOPR, comments were originally due no later than October 25, 2021. In light of this NODA, DOE has determined that it is appropriate to reopen the comment period to allow additional time for interested parties to prepare and submit comments. Therefore, DOE is reopening the comment period and will accept comments, data, and information on the August 2021 MH SNOPR and this NODA on and before November 26, 2021. Accordingly, DOE will consider any comments received by this date to be timely submitted.

IX. Public Participation

While DOE is not requesting comments on specific portions of the analysis, DOE is interested in receiving comments on all aspects of the data and analysis presented in the NODA and supporting documentation that can be found at:

www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=64.

A. Submission of Comments

DOE will accept comments, data, and information regarding this supplemental notice of proposed rulemaking 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, data, and other information using any of the methods described in the

ADDRESSES

section at the beginning of this document.

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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).

X. Approval of the Office of the Secretary

The Secretary of Energy has approved publication of this supplemental notice of proposed rulemaking; reopening of comment period and notification of data availability.

Signing Authority

This document of the Department of Energy was signed on October 19, 2021, by Kelly Speakes-Backman, Principal Deputy Assistant Secretary and Acting Assistant Secretary for Energy Efficiency and Renewable Energy, pursuant to delegated authority from the Secretary of Energy. That document with the original signature and date is maintained by DOE. For administrative purposes only, and in compliance with requirements of the Office of the Federal Register, the undersigned DOE Federal Register Liaison Officer has been authorized to sign and submit the document in electronic format for publication, as an official document of the Department of Energy. This administrative process in no way alters the legal effect of this document upon publication in the

Federal Register

.

Signed in Washington, DC, on October 20, 2021.

Treena V. Garrett,

Federal Register Liaison Officer, U.S. Department of Energy.

[FR Doc. 2021-23188 Filed 10-25-21; 8:45 am]

BILLING CODE 6450-01-P

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