It goes with the insanity of today’s U.S. housing affordability crisis that two rights can make a wrong. Two federal policies — each designed to lower the lifetime operating cost of owning a home — can instead combine to raise the barrier to entry so high that millions of households never get through the front door in the first place.
The technical terms for these lose-lose-lose, vicious circle redtape riddles? You can’t make this s*** up.
The latest proof point came January 10, when the U.S. House of Representatives passed the Affordable HOMES Act (H.R. 5184) by a bipartisan vote of 263–147. The bill repeals a 2022 Department of Energy rule that would have imposed site-built energy-efficiency standards on manufactured homes, restoring sole regulatory authority to the Department of Housing and Urban Development under the HUD Code.
On its face, this looks like a narrow manufactured-housing fix. It isn’t. It is a case study — and an opening chapter — in a much larger story about how regulatory overlap, sequencing failures, and well-intended mandates quietly account for nearly 25% of the cost of a single-family home, even as policymakers profess urgency about affordability.
The pyramid Washington keeps ignoring
To understand why first costs and operating costs are linked, start with the National Association of Home Builders’ 2025 Housing Affordability Pyramid.
According to NAHB’s priced-out analysis, 94 million U.S. households — about 70% — cannot afford a $400,000 home.
The estimated median price of a new home in 2025 is closer to $460,000. At the bottom of the pyramid are 52.9 million households that can afford homes priced under $200,000. Yet only about 22 million owner-occupied homes exist in that price range.
This is the surreal mismatch at the heart of the crisis: the largest cohort of potential buyers lives in areas with the least supply. Any policy that raises the upfront price of a home by even a few thousand dollars does not merely make housing “slightly less affordable.” It erases entire households from eligibility.
That is where two rights can add up to a wrong.
Manufactured housing: the missing rung
Manufactured housing occupies a unique place in this pyramid. It accounts for about 5% of the nation’s occupied housing stock and roughly 9–10% of new single-family production in recent years. It is the largest source of unsubsidized affordable homeownership in America.
The math is straightforward. New manufactured homes average about $87 per square foot, compared with roughly $166 per square foot for site-built homes, excluding land. Monthly ownership costs — including utilities — are far lower. The demographic reality is equally stark: median household income for manufactured-home residents is around $40,000, compared with $85,000 for site-built homeowners.
This is precisely why manufactured housing sits at the center of the Affordable HOMES Act debate — and why the policy failure it addresses matters far beyond a single segment.
One product, two blueprints
At the heart of the conflict is a regulatory contradiction that should never have existed.
In 2007, Congress amended the Energy Independence and Security Act to give the Department of Energy parallel authority to establish energy efficiency standards for manufactured housing — a product that, since 1974, has been governed by a single, preemptive federal building code administered by HUD.
The result was not progress. It was paralysis.
As Lesli Gooch, CEO of the Manufactured Housing Institute, put it in an exclusive interview with The Builder’s Daily:
“This is all about regulatory efficiency, because you cannot build a house with two different blueprints.”
She explained that what followed was years in which neither agency could effectively update standards because DOE’s site-built framework conflicted with the realities of factory construction, transportation, and on-site installation — all core to the HUD Code.
“The reason that you haven’t seen an update in our underlying standards at HUD… is that you had another regulator also charged with doing the same thing, and you ended up having paralysis,” Gooch said.
The DOE’s 2022 rule sought to break that logjam by applying site-built energy standards to manufactured homes. Even the administration acknowledged it could not implement the rule as written. Builders were left staring at two incompatible compliance regimes.
“You cannot, as a builder, build and adhere to a HUD standard… and then build to another standard that’s in conflict,” Gooch said. “So what would a builder do? They would no longer build to that code; they’d all become modular, which would increase the price.”
That is the “wrong” created by two “rights”: energy-efficiency goals colliding with housing expertise, which raise first costs and suppress supply.
This is not an energy efficiency rollback
One of the most persistent mischaracterizations of the Affordable HOMES Act is that it weakens energy standards. Gooch rejects that framing outright.
“There’s no energy standard that got rolled back,” she said. “Nothing has been implemented by the Department of Energy or by HUD… This is about cleaning up a failed government process.”
In reality, the industry has continued to improve energy performance despite the regulatory stalemate. More than half of newly manufactured homes are ENERGY STAR certified, and overall energy use compares favorably with that of site-built housing.
“We are among the most energy-efficient homes being produced today,” Gooch said. “That has nothing to do with the underlying standard that we agree needs to be updated. But that standard should be updated through our regulator.”
Clayton, the nation’s largest producer of manufactured housing, made the same point in a statement responding to House passage of the bill:
“Modern manufactured homes represent one of the most scalable solutions for expanding attainable homeownership and creating wealth-building opportunities for families across the country.”
Clayton emphasized that restoring HUD’s authority is not a retreat from efficiency:
“The Affordable HOMES Act represents an important statutory clarification… not a rollback of the industry’s commitment to energy efficiency.”
First costs vs. lifetime costs
The deeper lesson here is about sequencing.
Energy efficiency can lower long-term operating costs. But when mandates raise purchase prices beyond what households can qualify for, the savings never materialize — because the buyer never becomes an owner.
DOE’s own estimates showed that its rule would add from hundreds to thousands of dollars to the price of manufactured homes, depending on configuration. For households clustered at the bottom of the affordability pyramid, those increases matter far more than projected energy savings a decade later.
This is the policy blind spot: protecting hypothetical future homeowners while disqualifying real ones today.
Resilience, insurance, and the modern reality
Affordability is no longer just about price and mortgage rates. Insurance availability and climate resilience now sit squarely in the cost equation.
Here again, perception lags reality.
Gooch pointed to regular HUD Code updates, improved anchoring systems, and installation standards — including recent changes addressing shifting wind-risk patterns — as evidence that manufactured housing has evolved far beyond the outdated stereotypes that still shape local resistance.
“We don’t need the government to tell us,” she said. “We’re paying attention to performance. We want consumers to feel comfortable living in our houses.”
That evolution matters as insurers reassess risk and communities confront disaster exposure. Homes built to modern codes — factory-controlled, inspected, and installed to current standards — increasingly outperform older site-built stock that predates today’s requirements.
Beyond manufactured housing
The Affordable HOMES Act passed the House because it fixed a discrete, definable failure. But its implications are much broader.
NAHB has warned Congress that regulations now account for nearly one-quarter of the cost of a single-family home, and more than 40% of the cost of a typical apartment development. Energy mandates tied to federal financing, domestic sourcing rules, prevailing wage requirements, and duplicative permitting processes all layer on costs — often without regard to cumulative impact.
Manufactured housing simply made the contradiction visible.
As Gooch put it:
“The reason manufactured housing has, over time, been the most affordable form of housing is that it combines regulatory efficiency with the factory-built process.”
Lose that efficiency, and the entire affordability proposition collapses.
Next up
The Affordable HOMES Act now moves to the Senate, where it will be considered alongside a broader package of housing legislation addressing financing, zoning, and definitions of manufactured housing. The outcome will determine whether this fix becomes part of a coherent affordability strategy — or remains an isolated correction.
Either way, the lesson should be clear.
When 53 million households can only afford homes under $200,000, policies that raise first costs in the name of future savings are not neutral. They are exclusionary.
This is the first installment in a series examining how well-intended regulations quietly account for a growing share of housing costs — and what it will take to reverse that trend without sacrificing safety, efficiency, or resilience.
Because until policymakers confront the arithmetic of the affordability pyramid head-on, two rights will keep making a wrong.
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