The Environmental Protection Agency (EPA) has proposed changes to the Energy Star Manufactured New Homes program which far exceed the current requirements. According to EPA, these changes are being proposed to address the DOE’s new energy efficiency standards for manufactured homes and would go into effect on June 1, 2023. In formal comments to the agency, MHI urged the EPA to align the effective date of these changes to the implementation date for the new energy efficiency standards implementation date which could potentially change and/or be extended. Further, MHI called on EPA to include a compliance outline for homes with both gas and electric heating units; the proposed revisions establish compliance pathways for both all-electric homes and all-gas homes. Finally, MHI requested clarification on a number of other topics including the elimination of water fixture requirements and a definition of “fully buried” for ducts located in attics.