A Weatherization Auditor Counts the Eight Gaps Between a Cooling Law and a Cool Home

Burl Coldwell is not a real person, though he is, unfortunately, a real type. Every weatherization sub-grantee office in Maricopa County has someone like him: a former tradesman who pivoted into energy auditing, who has opened more manufactured-home electrical panels than he can count, and who has developed a particular facial expression for the moment he has to explain that a federal assistance program cannot help the home that needs it most. We constructed Burl from documented program realities, published technical standards, and the operational logic of Arizona's Weatherization Assistance Program, because the professional perspective he represents is essential context for understanding what Arizona's cooling-rights statute actually delivers to a resident in an aging manufactured home.

We met him, hypothetically, at a Denny's on Bell Road in North Phoenix, ten minutes from a cluster of 55-and-older manufactured home parks. He ordered coffee and a Grand Slam. He brought a clipboard.

You've been doing weatherization assessments in manufactured homes across Maricopa County for sixteen years. When you walk into an older unit in a 55-and-older park, what are you looking at first?

Burl: Panel box. Always the panel box. Everything else is academic until I know what the home can actually draw. You'd be amazed — well, you wouldn't, but your readers might — how many of these units are running 100-amp service. Some of the real old ones, the pre-'76 mobile homes that don't even have the red HUD certification label, I've seen 50-amp panels.¹ Fifty amps. That's your entire electrical budget for the home. Lights, fridge, water heater, washer if they've got one. Now you want to add air conditioning? Where exactly is that power coming from?

And 100 amps won't get you whole-home cooling?

Burl: A hundred amps is workable for a smaller single-wide if you've got gas heat and modest habits. But there's zero headroom. You start adding window units to multiple rooms, you're doing arithmetic on the back of an electric bill hoping you don't trip breakers. Or worse.² Most new manufactured homes ship with 200-amp panels standard. But the homes I'm assessing aren't new. They're twenty, thirty, sometimes forty-plus years old. Nobody was planning for "run the AC all day from April through October" when these panels went in.

What else are you finding beyond the panel?

Burl: The park's infrastructure. This is the part nobody thinks about. Your home panel is one thing. But the pedestal — that's the utility connection post on your pad — and the feeder cable running from the park's distribution system, those might be rated for a load that was calculated before everyone in Arizona decided they needed to survive summer indoors. Some of these parks were under-engineered from the start, especially for a climate like this one.³

And here's the fun part: manufactured homes aren't allowed to have multiple feeders. So if you need to upgrade, you're upgrading the panel, the pedestal, and the feeder assembly. That pedestal belongs to the park operator, not the resident.⁴ You're asking someone else's permission to fix your own problem.

Arizona passed a statute — A.R.S. §33-1452 — that says park operators can't prohibit residents from installing "reasonably necessary commercial cooling methods." Does that solve what you're describing?

Burl: It solves a problem. It solves the problem where a park manager says "no, you can't put that in." That happened. That was real. But the statute doesn't upgrade the pedestal. It doesn't add amps to the feeder. It doesn't insulate the ceiling.

Look, I'm glad the law exists. But I've never had a walk-through where I said, "Well, the only thing standing between this resident and whole-home cooling is the park operator's attitude." Not once. It's the infrastructure. It's the home itself. The law removed a gate, and that matters. But there's a whole obstacle course behind it.

You mentioned insulation. What are you actually finding inside these walls?

Burl: Homes built to no federal standard — the pre-'76 units — and homes built to HUD Subpart F thermal standards that were, let's say, optimistic about what constituted adequate.⁵ Arizona is HUD Thermal Zone 1, hot-arid, which actually has the least stringent insulation requirement because the code was more worried about heating than cooling. So you've got thin insulation, single-pane windows, ductwork running through the attic where up to 30 percent of your cooled air escapes before it reaches a room.⁶

What happens — and I've seen this hundreds of times — the resident puts a window unit in the bedroom. That room gets cold. The rest of the home doesn't. Heat from the unconditioned spaces keeps bleeding through the walls, the ceiling, the floor. By July, that bedroom is the home. They eat in there. They watch TV in there. The kitchen is for quick trips. The living room is basically storage.

Is "one defended room" a term you use in your assessments?

Burl: No, I just — there's no clinical term for it. I don't write it on the form. But it's what I see. Over and over.

Let's talk about the weatherization program itself. You assess homes for WAP eligibility. What happens when you find problems that prevent you from doing the work?

Burl: Deferral. That's the industry term. If I find a pre-existing health or safety condition — asbestos-like materials, unsafe wiring, mold, failed combustion safety testing — I can't proceed.⁷ The program is designed to weatherize homes, not remediate hazardous conditions. So I write the deferral, and the home goes back in the pile.

Nationally, somewhere between 10 and 30 percent of income-eligible clients get deferred, and the rate's been climbing.⁸ The thing that keeps me up at night — well, not literally, I sleep fine, I'm very tired — is that the homes most likely to be deferred are the homes that need weatherization the most. The worst-condition homes. The oldest units with the worst wiring and the most degraded envelopes. The program can't touch them until someone fixes the pre-existing problems, and fixing those problems runs $5,000 to $20,000 per job.⁹ There's often no funding stream for that remediation. Arizona doesn't have a systematic weatherization-barriers program the way some Northeastern states have tried to build.¹⁰

So a resident gets deferred. Then what?

Burl: Then nothing. I mean — there's the LIHEAP crisis pathway, the Energy-Related Repair component, which can cover a cooling system that's failed or poses a health hazard. But that's capped at $500 in Arizona.¹¹ Five hundred dollars. You're patching. You're keeping someone alive through August. You're not solving anything underneath.

And I should say — the whole LIHEAP program is under some uncertainty right now. There were federal budget proposals to eliminate it entirely, staff layoffs at the federal level.¹² Arizona's allocation is still there for FY2026, but anyone telling you the program's future is secure is selling something.

One more barrier. SRP's home energy audit rebate program.

Burl: Excludes mobile homes. Explicitly. It's right on their website.¹³ So if your park is in SRP territory — and plenty of North Phoenix parks are — the utility rebate program that your neighbor in the site-built house across the street uses to get an energy audit? You can't access it. You're in a different housing classification. Same sun beating down on both roofs. Different category of person, apparently.

If you could explain one thing to a state legislator who voted for the cooling-rights statute, what would it be?

Footnotes

1. Homes built before June 15, 1976, predate the HUD Manufactured Home Construction and Safety Standards (24 CFR Part 3280) and were constructed outside any federal regulatory framework. https://www.mcmcommunities.com/blog/what-every-buyer-should-know-about-hud-code-manufactured-homes ↩

2. 100-amp service provides no room for future upgrades and can lead to tripped breakers; 200-amp service is now standard for new manufactured homes. https://manufacturedhousingconsultants.com/mobile-home-electric-service-guide/ ↩

3. Some mobile home parks were under-engineered for hot climates, increasing risk of electrical fire or power loss. https://inspectapedia.com/Manufactured_Homes/Mobile-Home-Electrical-Wiring.php ↩

4. Mobile homes cannot have multiple feeders; upgrading requires upgrading the main panel, the park pedestal, and the feeder assembly. https://forums.mikeholt.com/threads/mobile-home-service-upgrade.73758/ ↩

5. HUD Code Subpart F thermal protection standards establish overall heat-loss/gain rates (Uo values) for manufactured housing, with Thermal Zone 1 (hot-arid) carrying the least stringent insulation requirements. https://www.energy.gov/eere/buildings/articles/issuance-2016-05-20-energy-conservation-standards-manufactured-housing ↩

6. Up to 30% of cooled air can escape through attic ductwork in manufactured homes. https://sunnyenergyrx.com/glossary/energy-audit-arizona ↩

7. Health and safety conditions including asbestos, unsafe wiring, mold, and failed combustion safety testing prevent participation in weatherization programs. https://e4thefuture.org/wp-content/uploads/2022/04/E4-EFG_Weatherization-Barriers-Toolkit-4-7-2022.pdf ↩

8. Nationally, 10-30% of income-eligible weatherization clients are deferred due to health and safety issues, with deferral rates increasing. E4TheFuture Weatherization Barriers Toolkit, April 2022. ↩

9. Pre-weatherization remediation costs range from $5,000 to $20,000+ per job, based on state program data from Virginia and Connecticut. E4TheFuture Weatherization Barriers Toolkit, slides 17 and 53. ↩

10. Arizona does not appear among states with systematic weatherization-barrier remediation programs documented in the E4TheFuture toolkit. ↩

11. Arizona's LIHEAP Energy-Related Repair crisis assistance is capped at $500 per household. https://liheapch.acf.hhs.gov/profiles/Arizona.htm ↩

12. Federal FY2026 budget proposals included eliminating LIHEAP funding; LIHEAP staff were reported let go April 1, 2025. Program status should be verified against primary federal records. https://des.az.gov/sites/default/files/media/Draft-Low-Income-Home-Energy-Assistance-LIHEAP-State-Plan-FFY-2026.pdf ↩

13. SRP's Home Energy Audit Rebate program is available to single-family, attached, or apartment/condo residences; mobile homes are explicitly excluded. https://www.srpnet.com/energy-savings-rebates/home/home-energy-savings-audit ↩