HUD is currently taking public comments regarding requiring all homes receiving a HUD loan to meet IRC 2021 Energy Rules without any amendments. This would be detrimental to the overall cost of housing in Oklahoma and across the country. Here are few reasons why:
- Significant Upfront Cost Increases: Compliance with 2021 energy codes can add $5,000 to $20,000+ to the construction cost of a single-family home, depending on location and design, pricing many buyers out of the market.
- Disproportionate Impact on Affordable Housing: These codes impose uniform standards that don’t account for the limited margins of affordable housing projects, potentially making them financially unviable.
- Limited Return on Investment for Buyers: Many homebuyers, particularly low-income, will not see immediate or meaningful savings on energy bills to offset the added mortgage or rent costs.
- Barriers to Entry for First-Time Buyers: Increased construction costs raise down payments and monthly payments, blocking first-time and working-class families from homeownership.
- Minimal Emissions Impact in Some Markets: In regions already using cleaner energy or efficient homes, the incremental environmental benefits may not justify the economic burden imposed by strict code requirements.
- Discourages Small Builders and Rural Development: Smaller builders and rural developers often lack the economies of scale or resources to meet strict code demands, reducing rural housing options.
Thank you for taking time to help!
Ryan Martinez Executive Officer, OKHBA
Please click the link below to leave your comment! I have also included a draft comment that you can copy and paste into the comment section if you so desire!
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Draft Comment Below:
I am writing to express serious concern regarding HUD’s potential requirement that new housing comply with the 2021 International Residential Code (IRC) energy provisions in order to qualify for HUD-insured loans. While I support energy efficiency and sustainability in principle, implementing this mandate without adequate consideration of cost implications would significantly increase the overall cost of housing, particularly for low and moderate income families—the very populations HUD is intended to serve.
According to industry estimates and recent analyses, the 2021 IRC energy code mandates can increase construction costs by thousands of dollars per unit, often without a clear or immediate return on investment for homeowners. These requirements include higher insulation standards, upgraded mechanical systems, and costly building envelope improvements that may not be feasible in all climates or economic conditions. For many builders and developers, especially those producing affordable housing, this added burden could reduce production and eliminate marginal projects altogether.
The unintended consequence of this well-intentioned rule may be a reduction in housing supply, increased home prices, and further restricted access to homeownership and rental opportunities—particularly in underserved rural and urban communities. It could also disproportionately affect first-time buyers and communities of color.
HUD’s role is critical in ensuring access to affordable, quality housing. Imposing costly new mandates without appropriate consideration could undermine this mission at a time when the country is already facing a housing affordability crisis.
