oversight

Home Energy Assistance for Low-Income Occupants of Manufactured Homes

Published by the Government Accountability Office on 2012-08-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

United States Government Accountability Office
Washington, DC 20548



           August 24, 2012

           The Honorable Jeff Bingaman
           Chairman
           Committee on Energy and Natural Resources
           United States Senate

           The Honorable Jon Tester
           United States Senate

           Subject: Home Energy Assistance for Low-Income Occupants of Manufactured
           Homes


           According to the Energy Information Administration (EIA), 1 the nation’s approximately 130
           million housing units account for about 23 percent of total energy consumption in the United
           States. Approximately 2 million of these housing units are manufactured homes (i.e., mobile
           homes) that were built prior to 1976, when new standards for energy efficient construction
           became effective. 2 These older manufactured homes are generally considered to have
           some of the poorest energy efficiency of all housing units. Many of the occupants of these
           homes qualify for federal assistance to help pay their energy bills through the U.S.
           Department of Health and Human Services’ (HHS) Low Income Home Energy Assistance
           Program (LIHEAP). LIHEAP helps cover home energy expenditures— key components of
           which are home heating and, in some cases, cooling expenditures. In 2009, LIHEAP
           covered about 8.3 million low-income households through payments to homeowners,
           occupants, landlords, or others. LIHEAP is a federally funded block grant program in which
           funds are provided to grantees, including states, territories, and tribes and tribal

           1
             EIA in the U.S. Department of Energy collects, analyzes, and disseminates a wide range of information and data
           products covering energy production, stocks, demand, imports, exports, and prices. EIA then prepares analyses
           and special reports on topics of current interest.
           2
             In 1976, as a result of the National Manufactured Home Construction and Safety Standards Act of 1974 (Pub. L.
           No. 93-383, as amended, 42 U.S.C. § 5401 et seq.), the U.S. Department of Housing and Urban Development
           (HUD) began to issue and enforce standards for the construction, design, performance and installation of
           manufactured homes to ensure that they were more energy efficient, among other things. Consistent with these
           standards, for the purposes of this report, we consider manufactured homes to include any home that is
           constructed, and then transported to a site where it is occupied as a permanent residence. These definitions are
           consistent with the federal building code administered by HUD and the definitions used by EIA to collect
           information on housing. These codes and definitions do not consider prefabricated structures that are assembled
           on site to be manufactured homes.


                                                                     GAO-12-848R Home Energy Assistance
organizations, based on a number of factors, such as climate and income. Grantees then
provide LIHEAP funds to eligible beneficiaries. To be eligible, household income must be
below varying thresholds set by the federal government. In fiscal year 2012, Congress
appropriated about $3.5 billion for LIHEAP nationwide.

Questions have been raised about whether improving the energy efficiency of older
manufactured homes or replacing them with newer, more energy-efficient models would
save the federal government money by reducing LIHEAP costs. A portion of LIHEAP funds
can be used to improve the energy efficiency of these homes but, in many cases, because
of the ways these homes were built and their sometimes poor condition, improving their
energy efficiency cannot be accomplished cost effectively. LIHEAP funds are statutorily
prohibited from being used for new construction, which includes replacing existing homes.

You asked us to review available data on energy use by and LIHEAP assistance for
occupants of manufactured homes––particularly those built before 1976. Our objectives for
this report were to determine (1) the amount occupants of older manufactured homes paid
for energy and how it compared with the amount paid by occupants of detached homes, (2)
how the amount of LIHEAP assistance occupants of older manufactured homes received
and the amount of their energy expenditures this assistance covered compared with such
assistance received and expenditures covered for occupants of detached homes, and (3)
the proportion of total LIHEAP funding used to assist occupants of older manufactured
homes. 3

To address these objectives, we analyzed the EIA Residential Energy Consumption Survey
(RECS) data for 2005—the most recent year for which data were available. 4 In addition,
the 2005 RECS data were divided into manufactured homes, site-built detached homes,
site-built attached homes, and apartments of any size. 5 HHS signed an interagency
agreement with EIA for use of the RECS data to match with state and local LIHEAP


3
  We also have ongoing work examining how some states or localities have leveraged private, state, local, and
other funds to replace older manufactured homes with newer, more energy-efficient models and the extent to
which doing so may result in cost savings. We expect to issue a separate report on these findings in early 2013.
4
 EIA administers RECS every 4 years to a nationally representative sample of housing units to collect energy
characteristics on the housing unit, usage patterns, and household demographics. RECS seeks information
primarily about primary residential housing units—excluding unoccupied housing and secondary housing units
such as vacation homes—including questions about housing types and year of construction, as well as questions
related to household income. Data on home energy expenditures includes heating and cooling bills from the
following energy sources: electricity, natural gas, fuel oil, kerosene, propane, wood, coal, or solar.
5
 EIA defines detached homes as single-family houses as long as they are not divided into more than one
housing unit and have an independent outside entrance. A single-family house is contained within walls
extending from the basement (or the ground floor, if there is no basement) to the roof. Townhouses, rowhouses,
and duplexes are considered single-family attached housing units as long as there is no household living above
another one within the walls extending from the basement to the roof to separate the units.


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beneficiaries. 6 We used the resulting matched data to determine the average income, size,
energy expenditures, as well as information on LIHEAP payments by housing type and year
of construction. Because the sample size in RECS for households that received LIHEAP
assistance was relatively small, estimates using these data should be considered a midpoint
within a range rather than an exact estimate. To assess the reliability of the 2005 RECS
data and the matched HHS data, we compared the data with other EIA documents,
electronically tested the data for consistency, and discussed the data with knowledgeable
EIA officials; we determined that the data were sufficiently reliable for the purposes of this
report. 7 We surveyed LIHEAP grantees––including all 50 states and the District of
Columbia, 152 tribes and tribal organizations, and 5 U.S. territories––to determine the extent
to which they collect data on LIHEAP recipients’ housing types and years of construction. 8
We received responses from 141 grantees––about a 68 percent response rate. In addition,
we met with officials from HHS and EIA, as well as state officials from Maine and Montana––
because these states have conducted pilot programs to replace older manufactured homes
with newer, more energy-efficient models. We also interviewed officials from organizations
and agencies that conduct research or represent the interests of LIHEAP officials and
grantees, including the National Energy Assistance Directors’ Association, National
Consumer Law Center, NeighborWorks America, Apprise Inc., and the American Gas
Association. A more detailed description of our objectives, scope, and methodology is
provided in enclosure I.


We conducted this performance audit from November 2011 to August 2012 in accordance
with generally accepted government auditing standards. Those standards require that we
plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.


In summary, in 2005, the most recent year for which complete data were available,
occupants of older manufactured homes paid over twice as much on average per square
foot for energy—$1.75 per square foot as compared with $0.87—as was paid by occupants

6
  According to HHS officials, the purpose of the administrative records matching initiative was to improve the
quality of data for LIHEAP recipients, including the validity of the recipient’s data, the quality of the information on
the types and amount of LIHEAP assistance received, and information on both LIHEAP recipients and LIHEAP
eligible nonrecipients.
7
  For purposes of this report, we refer to these data as 2005 RECS data.
8
  The U.S. territories include American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S.
Virgin Islands.


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of detached homes. 9 Annual energy expenditures for older manufactured homes––about
906 square feet on average––were about $1,369, compared with detached homes––about
2,919 square feet on average—were about $2,060. Energy expenditures—both per square
foot and annually—varied significantly by region reflecting regional differences in the types
and costs of fuels commonly used to heat and cool homes, income levels, and climate,
among other things. In 2005, LIHEAP provided more assistance on a per square foot
basis—about $0.33 per square foot—to occupants of older manufactured homes than to
those of detached homes—about $0.20 per square foot. However, this assistance covers
slightly less of the annual energy expenditures of occupants of older manufactured homes
than occupants of detached homes—15 and 17 percent, respectively. Based on our
analysis of EIA’s RECS data, we estimate that about 3 percent of LIHEAP funds—about $57
million—spent in 2005 were used to assist occupants of older manufactured homes.


Background
A manufactured home is constructed almost entirely in a factory and transported to the site
where it will be occupied, in contrast to a site-built home, which is constructed at the site
where it will be occupied. Many manufactured homes are rectangular, wood-framed,
aluminum-sided, single-story structures––commonly known as "mobile homes" or “house
trailers”––built on a metal frame that can be placed on wheels or on the back of a
commercial-grade truck and transported to sites where they are generally permanently
installed. Camping or travel trailers—typically smaller structures that can be pulled by car or
small truck––are another type of manufactured home but are generally designed to be
temporary dwellings rather than permanent residences.


To implement the National Manufactured Housing Construction and Safety Standards Act of
1974, the Department of Housing and Urban Development (HUD) began to issue and
enforce standards for the construction, design, performance, and installation of
manufactured homes to ensure their quality, durability, affordability, and safety. HUD may
enforce these standards directly, or they may be enforced at the state level. These
standards preempt state and local laws that are not identical to the federal standards and
apply to all manufactured homes produced after June 15, 1976.


Prior to 1976, there were few provisions for ensuring the safety or quality of manufactured
homes. Many of these older homes were built with little or no insulation, thin walls and

9
 Due to significant size differences between older manufactured homes and detached homes, we calculated
energy expenditures on a per square foot basis for purposes of comparison.


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roofs, uninsulated heating and cooling systems, and inefficient louvered windows (known as
jalousie windows). Further, over time many of these older manufactured homes have
deteriorated to the point that their windows and doors no longer seal tightly to protect the
interior from the weather. According to the Maine Housing Authority, which conducted a
study in 2007 of pre-1976 manufactured homes, many of these older manufactured homes
have depreciated to the point where they have no market value. In addition, housing and
weatherization experts have stated that some pre-1976 manufactured homes may be
unsuitable for weatherization (i.e., making long-term energy efficiency improvements). For
example, these homes typically have roofs made of thin metal sheets seamed together and
walls built with 2-inch by 2-inch studs; therefore, neither the ceilings nor the walls can
accommodate insulation. 10 In addition, most of these older manufactured homes are beyond
the scope of federal and state weatherization programs; 11 that is, officials responsible for
implementing these programs have generally determined that such homes are too
deteriorated to warrant weatherization or are unsafe for weatherization crews to work on.
Approximately 80 percent of older manufactured homes are in the South and West U.S.
Census Regions as are approximately 84 percent of newer manufactured homes. 12 Figure
1 presents an example of a manufactured home that was built prior to 1976,




10
   Standards for homes built after 1976 require 2-inch by 6-inch wall studs.
11
   DOE’s Weatherization Assistance Program was created in 1976 under Title IV of the Energy Conservation and
Production Act. By making long-term energy efficiency improvements, such as installing insulation, sealing
leaks, and modernizing heating and air conditioning equipment, the weatherization program aims to, among
other things, increase the energy efficiency of homes owned or occupied by low-income persons, reduce their
total residential energy expenditures, improve their health and safety, and reduce the burden of energy prices.
DOE makes weatherization program funds available through formula-based grants to agencies in the 50 states,
the District of Columbia, U.S. territories, and American Indian tribes and tribal organizations.
12
   The U.S. Census Bureau divides the United States into four regions. Each region includes several states:
Northeast Region (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, Connecticut, New York,
New Jersey, and Pennsylvania); Midwest Region (Ohio, Indiana, Illinois, Michigan, Wisconsin, Minnesota, Iowa,
Missouri, North Dakota, South Dakota, Nebraska, and Kansas); South Region (Delaware, Maryland, District of
Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia, Florida, Kentucky, Tennessee,
Alabama, and Mississippi, Arkansas, Louisiana, Oklahoma, and Texas); and West Region (Montana, Idaho,
Wyoming, Colorado, New Mexico, Arizona, Utah, Nevada, Washington, Oregon, California, Alaska, and Hawaii).


Page 5                                                    GAO-12-848R Home Energy Assistance
Figure 1: Pre-1976 Manufactured Home




Title XXVI of the Omnibus Budget Reconciliation Act of 1981 established LIHEAP to help
low-income households––particularly those with the lowest incomes that pay a high
proportion of household income on home energy expenditures––pay their home heating and
cooling costs. 13 LIHEAP is a federal block grant program that provides funding grants to
states and other entities that, in turn, provide the funds to eligible households. States,
territories, and tribes and tribal organizations that wish to assist low-income households in
meeting home energy expenditures may apply for a LIHEAP block grant. These grantees
then provide payments on behalf of the eligible households directly to homeowners,
occupants, landlords or others. Grantees provide LIHEAP assistance to eligible
beneficiaries up to the maximum eligible payment for that beneficiary as determined by the
grantee. Grant funds are distributed in this manner until the grantees’ annual funding has
been entirely expended or the fiscal year has ended. LIHEAP funding, adjusted for inflation,
was highest from 1981-1986 and from 2009-2011, witnessing a decline in real terms in the
years in between (see fig. 2). For 2012, LIHEAP allocated to state grantees funding that
ranged from about $6.1 million, for Hawaii, to about $375.5 million, for New York. For 2012,
LIHEAP allocated to U.S. territory grantees funding that ranged from about $58.7 thousand,
for the Northern Mariana Islands, to about $4.2 million, for Puerto Rico and for all tribes and
tribal organizations funding of about $38.4 million. Enclosure II includes detailed LIHEAP
funding by state, territory, and tribes or tribal organizations for 2012.




13
 Pub. L. No. 97-35, 95 Stat. 357 (1981).




Page 6                                             GAO-12-848R Home Energy Assistance
Figure 2: LIHEAP Funding History




LIHEAP statutes establish overall LIHEAP guidelines, within which each grantee operates
its own program. For example, HHS guidelines specify that a LIHEAP-eligible household’s
income generally must not exceed the greater of 150 percent of the poverty level or 60
percent of the state’s median income. These guidelines also stipulate that LIHEAP grantees
may not set their maximum income threshold for applicants below 110 percent of the
poverty level, but they may give priority to those households with the highest home energy
expenditures or needs in relation to income. LIHEAP grantees may set additional criteria for
allocating LIHEAP funding to recipients. For example, they may give priority to households
with vulnerable occupants, which HHS defines as those who are at least 60 years old,
disabled, or 5 years old or younger.




Page 7                                          GAO-12-848R Home Energy Assistance
LIHEAP does not require grantees to match federal funds, but some grantees choose to
supplement funds. Grantees also have the flexibility to use up to 15 percent of their LIHEAP
funds––or up to 25 percent under certain circumstances––for state weatherization programs
that provide funds to improve home energy efficiency, typically by upgrading insulation and
heating and cooling equipment. 14 However, both LIHEAP and the weatherization funds are
precluded from being used for new construction, which would also preclude replacing
existing homes with newer, more efficient models.



Occupants of Older Manufactured Homes Paid More Than Twice as Much per
Square Foot for Energy than Occupants of Detached Homes in 2005

In 2005, the most recent year for which complete data were available, occupants of older
manufactured homes paid, on average, more than twice as much for energy per square foot
than did occupants of detached homes. 15 Specifically, according to our analysis of EIA’s
2005 RECS data, annual energy expenditures for older manufactured homes averaged
about $1.75 per square foot compared to $0.87 for detached homes. However, because
manufactured homes tend to be smaller than detached homes, these differences do not
necessarily translate to higher annual energy expenditures. Based on the 2005 RECS data,
we estimated that annual energy expenditures for an older manufactured home were $1,369
per year, with energy expenditures ranging from $353 to $4,659. The average size of these
homes was about 906 square feet. In contrast, average annual energy expenditures for
detached homes were about $2,060 per year, with energy expenditures ranging from $57 to
$10,346. 16 The average size of these homes was about 2,919 square feet. Figure 3
compares the average energy expenditures per square foot and annually for older
manufactured and detached homes. Additional information on energy expenditures and
home size by housing type––including apartments and attached homes––as well as by year
of construction can be found in tables 4 and 5 in enclosure III.




14
  HHS evaluates states’ requests to use up to 25 percent of LIHEAP funds for weatherization programs.
15
  Due to significant size differences between older manufactured homes and detached homes, we calculated
energy expenditures on a per square foot basis for purposes of comparison.
16
  These averages were separately derived from the 2005 RECS database. There is a direct relationship between
energy expenditures and household square footage. As such, the ratio of these averages (average energy
expenditures divided by average square footage) will not equal the average of their ratio (average of the ratio of
energy expenditures to square footage).


Page 8                                                     GAO-12-848R Home Energy Assistance
Figure 3: Average Energy Expenditures per Square Foot and Annually for Older
Manufactured Homes and Detached Homes, 2005




We also analyzed energy expenditures for occupants of all housing types by the nine U.S.
Census divisions and found that the average energy expenditures per square foot ranged
from about $0.92 in the East North Central Division (Ohio, Indiana, Illinois, Michigan, and
Wisconsin) to about $1.45 in the New England Division (Maine, New Hampshire, Vermont,
Massachusetts, Rhode Island, and Connecticut). 17 Average annual energy expenditures
ranged from $1,421 in the Pacific Division (Washington, Oregon, California, Alaska, and
Hawaii) to $2,428 in the New England Division (see table 1). These differences in energy
expenditures reflect a number of factors including regional differences in the type and costs
of fuels commonly used to heat and cool homes, income levels, and climate.




17
 EIA calculates energy expenditures per square foot using a different method than we used in our analysis.
However, EIA acknowledged that both methods are valid, and our method is appropriate for our analysis.


Page 9                                                    GAO-12-848R Home Energy Assistance
Table 1: Average Energy Expenditures and Home Size for Occupants of All Housing Types by U. S.
Census Division, 2005
U.S. Census division            Average energy              Average annual energy         Average home size
                            expenditures per square        expenditures (in dollars)       (in square feet)
                                foot (in dollars)
New England                                        $1.45                       $2,428                      2,529
Middle Atlantic                                     1.44                        2,279                      2,376
East North Central                                  0.92                        1,808                      2,628
West North Central                                  0.93                        1,735                      2,424
South Atlantic                                      0.99                        1,704                      2,370
East South Central                                  0.98                        1,674                      2,254
West South Central                                  1.17                        1,903                      2,184
Mountain                                            1.01                        1,644                      2,149
Pacific                                            $0.95                       $1,421                      1,878
Source: GAO analysis of EIA’s RECS data.

Note: The U.S. Census Bureau divides the United States into nine divisions. Each division includes several
states: New England Division (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, and
Connecticut); Middle Atlantic Division (New York, New Jersey, and Pennsylvania); East North Central Division
(Ohio, Indiana, Illinois, Michigan, and Wisconsin); West North Central Division (Minnesota, Iowa, Missouri, North
Dakota, South Dakota, Nebraska, and Kansas); South Atlantic Division (Delaware, Maryland, District of
Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia, and Florida); East South Central
Division (Kentucky, Tennessee, Alabama, and Mississippi); West South Central Division (Arkansas, Louisiana,
Oklahoma, and Texas); Mountain Division (Montana, Idaho, Wyoming, Colorado, New Mexico, Arizona, Utah,
and Nevada); Pacific Division (Washington, Oregon, California, Alaska, and Hawaii). U. S. Census divisions
differ from the four U. S. Census regions.



In addition, we analyzed RECS data to determine how many occupants have incomes below
150 percent of states’ varying poverty levels—one of the thresholds for qualifying for
LIHEAP assistance––by housing type. We found that, in 2005, about 55.0 percent of
occupants living in older manufactured homes had incomes that met this threshold, and
about 18.5 percent of occupants living in detached homes met it (see fig. 4). Additional
information on occupants whose incomes were below this threshold by housing type and
year of construction can be found in table 7 in enclosure III.




Page 10                                                    GAO-12-848R Home Energy Assistance
Figure 4: Percentage of Occupants with Incomes below 150 Percent of the Poverty
Level by Housing Type, 2005




LIHEAP Provided More Assistance per Square Foot to Occupants of Older
Manufactured Homes Than to Occupants of Detached Homes in 2005

In 2005, LIHEAP provided more assistance per square foot to occupants of older
manufactured homes than to occupants of detached homes, but this assistance covered
slightly less of the annual energy expenditures for occupants of older manufactured homes
as compared with occupants of detached homes. However, LIHEAP assistance provided
less annual support for occupants living in older manufactured homes than for those living in
detached homes, in part, because these manufactured homes are smaller. Specifically,
occupants of older manufactured homes received about $0.33 per square foot in LIHEAP
assistance, or about $214 per year, covering about 15 percent of their annual energy
expenditures. In contrast, occupants of detached homes received about $0.20 per square
foot in LIHEAP assistance, or about $345 per year, which covered about 17 percent of their
annual energy expenditures. 18 The range of LIHEAP assistance for older manufactured
homes was $0.10 to $1.55 per square foot, or $60 to $776 annually. The range of LIHEAP
assistance for detached homes was $0.01 to $1.43 per square foot, or $14 to $975 annually.

18
 Average LIHEAP payments per square foot were derived by dividing each individual household’s LIHEAP
payment by its square footage then averaging the result. This will yield a different result from dividing the
average LIHEAP payment for all households by the average total square footage because LIHEAP payments
and square footage are related to each other.


Page 11                                                    GAO-12-848R Home Energy Assistance
Figure 5 shows average LIHEAP assistance per square foot by type of home. Additional
information about energy expenditures and LIHEAP assistance by housing type and year of
construction, including information on housing size, can be found in table 8 in enclosure III.

Figure 5: Average LIHEAP Assistance per Square Foot, 2005




LIHEAP assistance also varied across U.S. Census divisions in 2005. For instance, LIHEAP
assistance per square foot ranged from about $0.16 in the Middle Atlantic Division (New
York, New Jersey, and Pennsylvania) to $0.42 in the New England Division, or $262 and
$476 total LIHEAP assistance per year, respectively (see table 2). Such variations can
result from a number of different factors including climate, the ways various states
implement their block grant programs, and differences in the types and costs of fuel used to
heat and cool homes.




Page 12                                           GAO-12-848R Home Energy Assistance
Table 2: Average LIHEAP Assistance for Occupants of All Housing Types by U.S. Census Division, 2005
U.S. Census division              Average LIHEAP               Average LIHEAP            Average annual LIHEAP
                                  assistance as a            assistance per square        assistance (in dollars)
                                 percentage of total            foot (in dollars)
                                energy expenditures
New England                                         25.26                       $0.42                          $476
Middle Atlantic                                     15.19                         0.16                          262
East North Central                                  18.62                         0.22                          296
West North Central                                  21.48                         0.24                          285
                                                         a
South Atlantic                                                                    0.21                          250
East South Central                                  16.84                         0.17                          192
                                                         a                           a
West South Central                                                                                              526
                                                         a
Mountain                                                                          0.21                          285
Pacific                                             29.72                       $0.35                          $231
Source: GAO analysis of EIA’s RECS data.

Note: The U.S. Census Bureau divides the United States into nine divisions. Each division includes several
states: New England Division (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, and
Connecticut); Middle Atlantic Division (New York, New Jersey, and Pennsylvania); East North Central Division
(Ohio, Indiana, Illinois, Michigan, and Wisconsin); West North Central Division (Minnesota, Iowa, Missouri, North
Dakota, South Dakota, Nebraska, and Kansas); South Atlantic Division (Delaware, Maryland, District of
Columbia, Virginia, West Virginia, North Carolina, South Carolina, Georgia, and Florida); East South Central
Division (Kentucky, Tennessee, Alabama, and Mississippi); West South Central Division (Arkansas, Louisiana,
Oklahoma, and Texas); Mountain Division (Montana, Idaho, Wyoming, Colorado, New Mexico, Arizona, Utah,
and Nevada); Pacific Division (Washington, Oregon, California, Alaska, and Hawaii). U. S. Census divisions
differ from the four U. S. Census regions.
a
 Calculated value is not reliable because either (1) the relative standard error was less than 2, or (2) the number
of observations used to calculate the mean estimate was less than 10.



About 3 Percent of LIHEAP Funds in 2005 Were Used to Assist Occupants of Older
Manufactured Homes

We estimate that about 3 percent of LIHEAP funds—about $55 million—in 2005 were used
to assist occupants of older manufactured homes, even though older manufactured homes
represented about 1.7 percent of the primary, occupied housing units in the United States. 19
The data and methodology used by EIA in RECS limit our ability to definitively determine
certain aspects of the LIHEAP assistance occupants of older manufactured homes
received. 20 However, it appears that occupants of older manufactured homes were more
likely to receive LIHEAP assistance than occupants of detached homes, since they received



19
  We developed this estimate using 2005 RECS data because HHS and LIHEAP grantees do not routinely
collect data that would allow us to determine the percentage of LIHEAP funding annually used to help occupants
of older manufactured homes. We derived the $55 million by multiplying the portion of LIHEAP funds spent in
2005 to assist occupants of older manufactured homes–– about 3 percent––by the $1.88 billion in total
distributed LIHEAP funds in fiscal year 2005.
20
  The sample size for households that received LIHEAP assistance was too small to provide reliable estimates to
project to some subcategories such as housing types and year of construction. For more details, see enclosure I.


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a disproportionate share of the assistance relative to the share of the universe of housing
stock, even though they generally received smaller payments.


Because LIHEAP is a federal block grant program focused on assisting low-income
households, HHS collects data from LIHEAP grantees on the number of households
receiving assistance, their income, and the number of their households with vulnerable
occupants; 21 however, it does not require grantees to collect information on LIHEAP
recipients’ housing type or year of construction. As a result, we surveyed grantees (i.e., 50
states and the District of Columbia, 152 tribes and tribal organizations, and 5 U.S. territories)
to identify how many collected information on housing type and year of construction from
LIHEAP recipients. Of the 141 grantees that responded to our survey of state and tribal
grantees, we found that 7 grantees collect this information. In the absence of detailed
information from HHS or LIHEAP grantees, we developed an estimate of the percentage of
LIHEAP funding provided to occupants of older manufactured homes based on an analysis
that HHS undertook that matched 2005 RECS data with LIHEAP recipient rolls. For the
2009 RECS survey—expected to be released later this year—EIA has worked with HHS to
incorporate questions related to improving the data available regarding low-income housing
units.


Agency Comments

We provided a draft of this report for review and comment to HHS. HHS provided technical
and clarifying comments, which we incorporated as appropriate.


                                                   -----


We are sending copies of this report to the appropriate congressional committees, the
Secretary of Health and Human Services, the Secretary of Energy, and other interested
parties. In addition, this report is available at no charge on the GAO website at
http://www.gao.gov.




21
 HHS defines vulnerable occupants as an occupant who is 60 year old or older, disabled, or 5 years old or
younger. LIHEAP requires states to report these data on these occupants annually.




Page 14                                                   GAO-12-848R Home Energy Assistance
If you or your staff members have any questions about this report, please contact me at
(202) 512-3841 or ruscof@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this report. GAO staff
who made key contributions to this report are listed in enclosure IV.




Frank Rusco
Director, Natural Resources and Environment

Enclosures




Page 15                                         GAO-12-848R Home Energy Assistance
Enclosure I: Objectives, Scope, and Methodology

This report examines energy expenditures and Low Income Home Energy
Assistance Program (LIHEAP) assistance for occupants of manufactured homes––
particularly those built before 1976—and detached homes. Our objectives for this
report were to determine (1) the amount occupants of older manufactured homes
paid for energy and how it compared with the amount paid by occupants of detached
homes, (2) how the amount of LIHEAP assistance occupants of older manufactured
homes received and the amount of their energy expenditures this assistance
covered compared with such assistance received and expenditures covered for
occupants of detached homes, and (3) the proportion of total LIHEAP funding used
to assist occupants of older manufactured homes. 22

In conducting our work, we reviewed relevant laws including Title XXVI of the
Omnibus Budget Reconciliation Act of 1981 and the National Manufactured Home
Construction and Safety Standards Act of 1974. We also reviewed Health and
Human Services’ (HHS) reports to Congress and LIHEAP Home Energy
Notebooks. 23 We met with officials from HHS, the Department of Energy’s Energy
Information Administration (EIA), 24 and the LIHEAP Clearinghouse––an aggregator
of LIHEAP data. We also met with state officials from the states of Maine and
Montana because these states have conducted pilot programs to replace pre-1976
manufactured homes with newer, more energy-efficient models. In addition, we
interviewed officials from organizations and agencies that conduct research or
represent the interests of LIHEAP officials and grantees including the National
Energy Assistance Directors’ Association, National Consumer Law Center,
NeighborWorks America, Apprise Inc., and the American Gas Association.




22
   We also are doing ongoing work examining how some states or localities have leveraged private, state, local,
and other funds to replace older manufactured homes with newer, more energy-efficient models and the extent
to which doing so may result in cost savings. We expect to issue a separate report on these findings in early
2013.
23
  HHS publishes the LIHEAP Home Energy Notebook, as a supplement to their report to Congress. This
publication provides LIHEAP grantees and other interested parties the most recent data on home energy usage,
consumption, and expenditures for all, low income, non-low income, and LIHEAP recipient households.
24
  EIA collects, analyzes, and disseminates a wide range of information and data products covering energy
production, stocks, demand, imports, exports, and price; and prepares analyses and special reports on topics of
current interest.


Page 16                                                   GAO-12-848R Home Energy Assistance
To determine how much occupants of older manufactured homes pay for energy and the
proportion of LIHEAP funding used to assist occupants of older manufactured homes, we
analyzed data from EIA’s Residential Energy Consumption Survey (RECS) from 2005,
which was the most recent year for which complete data were available. 25 RECS is
conducted periodically from a random sample of primary, occupied housing units in the
United States. The “Household Survey” phase of the 2005 RECS was conducted in late
2005. EIA supplemented its 2005 RECS data with data from a separate RECS “Energy
Supplier Survey,” conducted in 2006, which collected energy expenditure data from
responding households. The RECS data on the year homes were built are available in 10-
year increments; therefore, we relied on RECS data from 1979 and before as a proxy for
pre-1976 housing in our analysis of older manufactured homes. Because manufactured
homes built from 1977 through 1979 were subject to higher energy efficiency standards than
were pre-1976 manufactured homes, the inclusion of data on homes built in these 3 years
likely creates a downward bias in our estimates of energy expenditures of pre-1976
manufactured homes. However, because the stock of pre-1976 manufactured homes is
large relative to the inclusion of homes built in these 3 years, this bias is likely small. In
addition, the 2005 RECS data were divided into manufactured homes, site-built detached
single-family homes (detached homes), site-built attached single-family homes (attached
homes), and apartments of any size. 26


For the 2005 RECS, EIA interviewed a sample of occupants of homes in the United States
and asked respondents questions about housing unit types, year of construction, and
household income, among other things. These occupants were selected using a nationwide
random sample. HHS signed an interagency agreement with EIA for use of the RECS data
to match with state and local LIHEAP beneficiaries. According to HHS officials, the purpose
of the administrative records matching initiative was to improve the quality of data for
LIHEAP recipients, including

        •    validity of the recipient’s data,
        •    quality of the information on the types and amount of LIHEAP assistance
             received, and
        •    information on both LIHEAP recipients and LIHEAP eligible nonrecipients.

25
  EIA administers RECS to a nationally representative sample of housing units to collect energy characteristics
on the housing unit, usage patterns, and household demographics. RECS includes questions about housing unit
types and year of construction, as well as questions related to household income.
26
  Detached homes are considered single-family houses as long as they are not divided into more than one
housing unit and have an independent outside entrance. A single-family house is contained within walls
extending from the basement (or the ground floor, if there is no basement) to the roof. Townhouses, rowhouses,
and duplexes are considered single-family attached housing units, as long as there is no household living above
another one within the walls extending from the basement to the roof to separate the units.


Page 17                                                   GAO-12-848R Home Energy Assistance
We used the resulting matched data to determine the average income, size, and energy
expenditures, as well as information on LIHEAP payments by housing type and year of
construction. The 2005 RECS uses a complex sampling design which, after applying
weights to the observations, allowed us to project to all households. However, the sample
size for households that received LIHEAP assistance was 434––a relatively small sample
size, particularly when these data are divided into categories such as housing types and
year of construction. Although the sample sizes were too small to provide reliable results
for us to project to a few subcategories, the data for LIHEAP recipients of manufactured
homes built in 1979 and before were reliable; but due to their small sizes, we have primarily
drawn broad aggregative conclusions about this subcategory. Because of the relatively
small sample size, in cases where we examine characteristics of LIHEAP recipients, our
estimates may have a higher standard error and should therefore be considered a midpoint
within a range rather than an exact estimate of the actual value. In general, we present only
those estimates for all housing classifications that meet EIA’s criteria for reporting an
estimate using the 2005 RECS data. Specifically, these criteria are: (1) that the mean of
each variable divided by its standard error is at least 2 and (2) the number of observations
used to calculate the mean estimate should be at least 10. We used these criteria to
determine the reliability of our calculations. To assess the reliability of the 2005 RECS data
and the matched HHS data, we compared the data with other EIA documents, electronically
tested the data for consistency, and discussed the data with knowledgeable EIA officials.
Overall, we determined that these data were sufficiently reliable for the purposes of this
report.



To determine the proportion of LIHEAP funding used to assist occupants of older
manufactured homes, we used the matched HHS data. Since the results were very broad
aggregative estimates, we also surveyed LIHEAP grantees––including all 50 states and the
District of Columbia, 152 tribes and tribal organizations, and 5 U.S. territories––to determine
the extent to which they collect data on LIHEAP recipients’ housing types and years of
construction. 27 To ensure the reliability and validity of the questions, we pretested the survey
with two state officials. We received responses from 141 grantees including 49 states, the
District of Columbia, 86 tribes and tribal organizations, and all 5 U.S. territories, 28—about a


27
  The U.S. territories include American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S.
Virgin Islands.
28
  Louisiana declined to respond to our survey, citing resource constraints.


Page 18                                                  GAO-12-848R Home Energy Assistance
68 percent response rate. However, HHS and LIHEAP grantees did not routinely collect
data that would allow us to determine the percentage of LIHEAP funding annually used to
help occupants of older manufactured homes; therefore, we derived our estimate by
multiplying the portion of LIHEAP funds spent in 2005 to assist occupants of older
manufactured homes–– about 3 percent––by the $1.88 billion in total distributed LIHEAP
funds in fiscal year 2005.


We conducted this performance audit from November 2011 to August 2012 in accordance
with generally accepted government auditing standards. Those standards require that we
plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.




Page 19                                         GAO-12-848R Home Energy Assistance
Enclosure II: LIHEAP Funding Allocations by State, Territory, and Tribe and
Tribal Organization, 2012

                                      Total LIHEAP
States                                  allocations
                                                   a
                                       (in dollars)
Alabama                                $47,081,144
Alaska                                  10,641,099
Arizona                                 21,904,148
Arkansas                                28,537,364
California                             153,259,035
Colorado                                47,308,286
Connecticut                             79,531,964
Delaware                                11,956,809
District of Columbia                    10,687,141
Florida                                 78,019,715
Georgia                                 61,702,366
Hawaii                                   6,107,011
Idaho                                   19,577,889
Illinois                               185,683,819
Indiana                                 79,998,845
Iowa                                    54,812,821
Kansas                                  32,118,334
Kentucky                                46,423,070
Louisiana                               43,421,576
Maine                                   38,520,365
Maryland                                69,790,309
Massachusetts                          132,678,036
Michigan                               172,428,540
Minnesota                              116,838,721
Mississippi                             31,530,677
Missouri                                68,231,128
Montana                                 19,915,857
Nebraska                                30,207,576
Nevada                                  11,202,561
New Hampshire                           26,055,007
New Jersey                             136,745,901
New Mexico                              15,715,158
New York                               375,509,667
North Carolina                          81,534,565
North Dakota                            20,554,636
Ohio                                   165,463,488
Oklahoma                                32,787,515
Oregon                                  36,012,085
Pennsylvania                           209,548,185
Rhode Island                            23,175,439
South Carolina                          36,269,889
South Dakota                            17,507,368
Tennessee                               55,405,327
Texas                                  129,832,056
Utah                                    24,100,402



Page 20                                   GAO-12-848R Home Energy Assistance
    Vermont                                               19,529,156
    Virginia                                              80,436,332
    Washington                                            57,967,554
    West Virginia                                         29,699,517
    Wisconsin                                            105,171,626
    Wyoming                                                9,501,674
    Total LIHEAP funding allocations to states        $3,398,638,753

    Total LIHEAP funding allocations to tribes
    and tribal organizations                             $38,428,998

    Territories
    American Samoa                                           $77,107
    Guam                                                     169,052
    Northern Marianas                                         58,717
    Puerto Rico                                            4,196,331
    Virgin Islands                                           159,857
    Total LIHEAP funding allocations to U.S.
    territories                                           $4,661,064


 Total LIHEAP funding                                 $3,471,672,115
Source: LIHEAP Clearinghouse.
a
 This total does not include rescission that was retained by HHS for training and technical assistance, as well as
various grants distributed during the year.




Page 21                                                     GAO-12-848R Home Energy Assistance
Enclosure III: Energy Expenditures and LIHEAP Assistance for Manufactured,
Detached, Attached and Apartment Homes

This enclosure provides information on energy expenditures and LIHEAP assistance
to supplement the data represented in figures and tables in the report. 29 Table 3
provides energy expenditures and home size for occupants of all types of housing,
including homes whose occupants who did not receive LIHEAP assistance. Tables
4 and 5 provide energy expenditures by housing types, year of construction, and
size. Table 6 provides LIHEAP assistance by housing types and year of
construction. Table 7 provides the percentage of occupants with incomes below 150
percent of the poverty level by housing types and year of construction. Table 8
provides LIHEAP recipients’ energy expenditures and amounts of LIHEAP
assistance for occupants of manufactured, detached, attached, and apartment
homes, as well as home size. Table 9 provides energy expenditures and LIHEAP
assistance by rural and nonrural areas. Table 10 provides average LIHEAP
assistance for recipients for various income ranges.
Table 3: Average Energy Expenditures and Home Size for Occupants of All Types of Housing, 2005
Occupants                  Average energy              Average annual energy       Average home size (in
                           expenditures per            expenditures                square feet)
                           square foot
That received LIHEAP                           $1.43                     $1,756                       1,671
assistance
That did not receive                           $1.06                     $1,812                       2,324
LIHEAP assistance
Source: GAO analysis of EIA’s RECS data.




29
  According to EIA, energy expenditures consist of money spent for the energy used in, or delivered to, a
housing unit during a given period of time. For the RECS tables and analyses, all expenditure statistics are
presented on an annual basis. The total dollar amount includes state and local taxes but excludes merchandise,
repairs, or special service charges. Electricity and natural gas expenditures are for the amount of those energy
sources consumed. Fuel oil, kerosene, and liquefied petroleum gas expenditures are for the amount of fuel
purchased, which may differ from the amount of fuel consumed. For households that do not pay their fuel
supplier directly, the expenditures for fuels are estimated.


Page 22                                                    GAO-12-848R Home Energy Assistance
Table 4: Average Energy Expenditures and Home Size for All Occupants of Manufactured, Detached,
Attached, Apartments and All Homes by Year of Construction, 2005
Types of homes and year of              Average energy           Average annual          Average home size
construction                            expenditures per         energy expenditures     (in square feet)
                                        square foot (in          (in dollars)
                                        dollars)
Manufactured         Built 1979 and                      $1.75                 $1,369                  906
homes                before
                     Built after 1979                     1.54                  1,583                 1,158
Detached homes       Built 1979 and                       0.92                  1,996                 2,631
                     before
                     Built after 1979                     0.79                  2,161                 3,372
Attached homes       Built 1979 and                       1.11                  1,690                 1,978
                     before
                     Built after 1979                     0.84                  1,482                 2,182
Apartments           Built 1979 and                       1.71                  1,339                  929
                     before
                     Built after 1979                     1.27                  1,053                  943
All homes            Built 1979 and                       1.14                  1,802                 2,133
                     before
                     Built after 1979                    $0.97                 $1,822                 2,562
Source: GAO analysis of EIA’s RECS data.

Table 5: Average Energy Expenditures and Home Size for Occupants of Manufactured, Detached,
Attached, Apartments for Homes of Any Age, 2005
Types of homes            Average energy                  Average annual energy         Average home size
                          expenditures per square foot    expenditures (in dollars)     (in square feet)
                          (in dollars)
All types of homes                              $1.07                        $1,810                   2,307
Manufactured homes                                1.62                        1,501                   1,062
Detached homes                                    0.87                        2,060                   2,919
Attached homes                                    0.99                        1,598                   2,069
Apartments                                      $1.54                        $1,228                    935
Source: GAO analysis of EIA’s RECS data.




Page 23                                                  GAO-12-848R Home Energy Assistance
Table 6: Average LIHEAP Assistance by LIHEAP Recipients’ Type of Home and Year of Construction,
2005
                             Average LIHEAP                Average LIHEAP                Average annual LIHEAP
                             assistance (% energy          assistance per square         assistance (in dollars)
                             expenditures)                 foot (in dollars)
All types of homes           21.89                                              $0.26                          $302
                             a                                                       a
Manufactured homes                                                                                              329
Detached homes               20.50                                                0.20                          345
Attached homes               20.57                                                0.18                          306
Apartments                   23.74                                                0.32                          230
All homes built in 1979      20.43                                                0.24                          300
or before
All homes built after        26.03                                              $0.30                          $307
1979
Source: GAO analysis of EIA’s RECS data.
a
 Calculated value is not reliable because either (1) the relative standard error was less than 2, or (2) the number
of observations used to calculate the mean estimate was less than 10.

Table 7: Percentage of Occupants with Income below 150 Percent of the Poverty Level by Housing Type
and Year of Construction, 2005
Types of homes                                              Percentage of occupants below poverty threshold
Manufactured homes

Built in 1979 and before                                                                                       55.0
Built after 1979                                                                                               42.0
All                                                                                                            47.0
Detached homes

Built in 1979 and before                                                                                       23.5
Built after 1979                                                                                               10.6
All                                                                                                            18.5
Attached homes

Built in 1979 and before                                                                                       38.7
Built after 1979                                                                                               22.5
All                                                                                                            31.6
Apartments

Built in 1979 and before                                                                                       45.5
Built after 1979                                                                                               39.4
All                                                                                                            39.4
Source: GAO analysis of EIA’s RECS data.




Page 24                                                     GAO-12-848R Home Energy Assistance
Table 8: Average Energy Expenditures, Home Size, and Assistance for LIHEAP Recipients in
Manufactured, Detached, Attached, and Apartment Homes, 2005


                           Average           Average            Average    Average            Average        Average
                           energy            annual             home       LIHEAP             LIHEAP         annual
                           expenditures      energy             size (in   assistance         assistance     LIHEAP
                           per square        expenditures       square     (% energy          per square     assistance
                           foot (in          (in dollars)       feet)      expenditures)      foot (in       (in dollars)
                           dollars)                                                           dollars)
                                                                                        a               a
Manufactured      All               $1.97            $1,708         946                                            $329
homes
                  Built              2.02             1,386         710            19.60            $0.33            214
                  in
                  1979
                  and
                  before
Detached          All                1.09             2,020       2,311            20.50             0.20            345
homes
Attached          All                0.97             1,723       2,046            20.57             0.18            306
homes


Apartments        All                1.96             1,415         818            23.74             0.32            230


All homes         Built              1.44             1,831       1,757            20.43             0.24            300
                  in
                  1979
                  and
                  before
                  Built             $1.39            $1,541       1,428            26.03            $0.30          $307
                  after
                  1979
Source: GAO analysis of EIA’s RECS data
a
 Calculated value is not reliable because either (1) the relative standard error was less than 2, or (2) the number
of observations used to calculate the mean estimate was less than 10.


Table 9: Average Energy Expenditures, Home Size, and Assistance for LIHEAP Recipients in All Housing
Types in Rural and Nonrural Areas, 2005
                  Average          Average           Average      Average          Average          Average
                  energy           annual            home         LIHEAP           LIHEAP           annual
                  expenditures     energy            size (in     assistance       assistance       LIHEAP
                  per square       expenditures      square       (% energy        per square       assistance
                  foot (in         (in dollars)      feet)        expenditures)    foot (in         (in dollars)
                  dollars)                                                         dollars)
Rural                      $1.07            $1,761      2,235              20.56            $0.24           $288
                                                                               a                a
Non-rural                  $1.07            $2,005      2,595                                               $376
Source: GAO analysis of EIA’s RECS data.

Note: The U.S. Census Bureau defines homes as rural if they are located outside of core census block groups or
blocks that have a population density of at least 1,000 people per square mile and surrounding census blocks
that have an overall density of at least 500 people per square mile. However, 2005 RECS figures on rural and
nonrural homes are based on respondents reporting whether they live in a rural or nonrural area on the survey.
a
  Calculated value is not reliable because either (1) the mean of each variable divided by its standard error was
less than 2, or (2) the number of observations used to calculate the mean estimate was less than 10.




Page 25                                                       GAO-12-848R Home Energy Assistance
Table 10: Average Annual LIHEAP Assistance by Annual Household Income Ranges, 2005
                                                 Average annual
Annual income ranges                          LIHEAP assistance
                                                     (in dollars)
Less than $5,000                                            $298
$5,000 to $7,499                                             250
$7,500 to $9,999                                             318
$10,000 to $14,999                                           262
$15,000 to $19,999                                           364
$20,000 to $24,999                                           310
$25,000 to $29,999                                           301
$30,000 to $34,999                                           382
$35,000 or more                                             $314
Source: GAO analysis of EIA’s RECS data.




Page 26                                          GAO-12-848R Home Energy Assistance
Enclosure IV: GAO Contact and Staff Acknowledgments

GAO Contact
Frank Rusco, (202) 512-3841 or ruscof@gao.gov


Staff Acknowledgments
In addition to the individual named above, key contributors to this report were Jon
Ludwigson, Assistant Director; Michael Kendix; Alison O’Neill; Kelly Rubin; James W.
Turkett; and Jarrod West. Important assistance was also provided by Jonathan Kucskar,
Armetha Liles, and Christine San.




(361352)




Page 27                                       GAO-12-848R Home Energy Assistance
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