Posts Tagged ‘DOE’

U.S. Department of Energy Proposed Rulemaking Could Impact Manufactured Housing

February 13th, 2019 Comments off


The Department of Energy was established during the administration of President Jimmy Carter.


The creation of the DOE was a throwback to the drama of lines at U.S. gas stations arguably sparked by policies from the Organization of the Petroleum Exporting Countries or OPEC.




Decades of American involvement in Middle Eastern affairs was just part of the ebb and flow of oil, energy, terror, or geopolitical issues.




Fast-forward to the 2019.  A generation has grown up that has no experience much less memory of those episodes from the 1970s.  The U.S. says it is now the top oil and gas producer in the world. Texas, per reports, is now producing more oil and gas than at any other time in its history.

And from the great state of Texas comes former Governor Rick Perry, who is now the Secretary of the Department of Energy.

With that brief backdrop, is this press release to the Daily Business News on MHProNews from the Manufactured Housing Association for Regulatory Reform or MHARR.



FEBRUARY 13, 2019


TO:                  MHARR MANUFACTURERS

                        MHARR STATE AFFILIATES

                        MHARR TECHNICAL REVIEW GROUP (TRG)


FROM:             MHARR





The U.S. Department of Energy (DOE) has published a new proposed rule in the February 13, 2019 Federal Register (copy attached) that would significantly modify its procedures for developing new or revised energy conservation standards and related test procedures for consumer products, “appliances,” and certain commercial and industrial equipment.

While the proposed rule, as published, does not specifically reference standards development and/or test procedures under section 413 of the Energy Independence and Security Act of 2007 (42 U.S.C. 17071) directly pertaining to manufactured homes, the proposed rule does, by its terms, apply to DOE’s Appliance Standards Program — the same program under which the original proposed DOE manufactured housing energy standards rule (published June 17, 2016) was developed and subsequently modified by DOE pursuant to a Notice of Data Availability (NODA) published in the Federal Register on August 3, 2018. Industry members will recall that the manufactured housing energy rule had not substantially progressed at DOE until a segment of the industry, together with energy special interests (and DOE) in 2014, sought and engineered an illegitimate, truncated, dysfunctional “negotiated rulemaking” under DOE’s “appliance” rulemaking process, as a fig-leaf designed to achieve a pre-ordained result.

Given that the proposed (and still pending) DOE manufactured housing standards were developed under DOE Appliance Standards Program procedures that are addressed by the changes proposed in the February 13, 2019 DOE Notice, MHARR will file comments with DOE seeking to have the procedural modifications noted in the proposed rule applied to the manufactured housing proceeding, which would constitute yet another basis (among many others previously detailed by MHARR) for the withdrawal of any and all previously-proposed versions of the DOE manufactured housing standards – developed under or derived from — the inherently tainted DOE “negotiated rulemaking” process, and the ultimate development of a new rule based on a legitimate and lawful standards-development process consistent with the regulatory policies of the Trump Administration.

Among other things, the February 13, 2019 proposed rule would: (1) expand various procedural protections to test procedure rulemakings for regulated products; (2) define “a significant energy savings threshold that must be met before DOE will update an energy conservation standard;” and (3) “clarify DOE’s commitment to publish a test procedure six months before a related standards [Notice of Proposed Rulemaking].”  This is particularly significant in relation to DOE’s proposed manufactured housing energy standards, insofar as proposed test procedures were not published by DOE until after publication of the June 17, 2016 proposed rule, as was pointed out by MHARR at the time.

Written comments on the proposed rule are due by April 15, 2019.  MHARR will submit comprehensive comments (and participate in related meetings) in advance of the April 15, 2019 deadline and will make its comments available for reference by industry members.

As always, MHARR shall keep you apprised of any new developments in this matter.


cc:  Other Interested HUD Code Industry Members


— end of MHARR release —


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MHARR vs. MHI on DOE Energy Rule, Pushback Pay$ Off?


Manufactured Housing Institute (MHI) Shifts on DOE Regulatory Rule, Report, Analysis


NAHB Report – High Cost of Regulations Impact Housing – and Manufactured Housing


HUD Comment Letter – FR-6075-N-01 Regulatory Review of Manufactured Housing Rules

Report: Manufactured Housing Institute (MHI) Follows Prior MHProNews Lead

Court Hands DOE Procedural Victory in Potentially Costly Manufactured Housing Energy Standards Case

MHARR to DOE: Only Three Choices for MH Energy Rule – Abandon, Complete Start-Over, Or Face Legal Action

Electrifying Price Hikes Threatened; Manufactured Housing DOE Energy Rule Controversies Heat Up



After Persistent MHARR Push-Back, DOE Proposed Manufactured Housing Energy Rule Deemed “Inactive”


Revival Of DOE Energy Rule May Require Legal Action










Steve Nadel, Executive Director of ACEEE, Marking “Energy Efficiency Day”

October 5th, 2017 Comments off
E:\MH\Daily Business News\6.20.2017\National Home Ownership Month\NationalHomeOwnershipMonthSunshineHomesRedBayALPostedDailyBusinessNewsMHProNews.png

Photo credit, Sunshine Homes, Red Bay, AL. Photo from the Digital Journal, but also found on dozens of other mainstream media and special interest websites.

Today is the second annual Energy Efficiency Day, a time to celebrate the incredible benefits of saving energy,” said Steve Nadel Executive Director of the American Council for an Energy-Efficient Economy (ACEEE).

Energy efficiency is the cheapest, quickest way to meet our energy needs, lower consumer bills, reduce pollution, and boost community resilience,” Nadel told MHProNews in a statement today. “Plus, it’s an economic engine, supporting at least 2.2 million US jobs in manufacturing, construction, and other fields.”


MHProNews – along with our sister trade media site, MHLivingNews – have promoted the benefits of energy savings, and “green” construction in manufactured homes for years.  Editorially, we’ve also noted and respected the rationale of the Manufactured Housing Association for Regulatory Reform (MHARR), which has pointed out the need for consumers and the marketplace – not federal officials – to determine what level of energy savings vs. initial costs makes sense for a given household.

Green, Energy Star HUD Code Builders

There are numerous HUD Code manufactured home producers – such sponsor Sunshine Homes, of Red Bay, AL – that build Energy Star ® rated homes.  Sunshine boasts building only homes that meet those higher standards, while offering residential style homes that are about half the cost of conventional building in the markets they serve.


Other, like the report linked here, are promoting solar units, which are more pricey, but still are finding a market niche.


Photo credits are as shown above, collage and text credits, All third party content is shown under fair use guidelines.

Millennials prefer green, but studies make it clear that there is no age or demographic group that is looking to pay more for utilities.

Hundreds of organizations and companies from around the world are participating in today’s event. More than a dozen cities, counties, and states—from coast to coast—have officially declared October 5th as Energy Efficiency Day,” Nadel said. ## (News, commentary, analysis.)

(Image credits are as shown above, and when provided by third parties, are shared under fair use guidelines.)

SoheylaKovachManufacturedHomeLivingNewsManufacturedHousingIndustryDailyBusinessNewsMHProNews-Submitted by Soheyla Kovach to the Daily Business News on

MHARR on Tariffs, DOE, and, Federalized Installation – Exclusive Report and Analysis

May 1st, 2017 Comments off

Credit: MHARR, Wikipedia.

The Manufactured Housing Association for Regulatory Reform (MHARR) has released its latest Washington Update, an exclusive report and analysis that addresses key issues with the U.S. Department of Housing and Urban Development (HUD).

Covered in this MHARR report:


  • HUD Installation Power Grab Intensifies


  • MHARR To FHFA: Stop GSEs’ Discrimination Against MH and


  • U.S. Tariff Imposed on Canadian Lumber


MHARR has received numerous inquiries from industry members and other HUD program stakeholders regarding a rapidly-widening power grab by program administrators to effectively federalize installation regulation in all 50 states,” says MHARR in the report.

HUD, and some uninformed elements within the industry, excuse this gross over reach as a consequence of the structure and language of the Manufactured Housing Improvement Act of 2000.”

The report also provides insight on the Canadian lumber tariffs.

After threatening to impose trade duties on goods imported from China and Mexico during the presidential election campaign in 2016, the administration announced its first new tariff on imported goods in a statement issued by Commerce Secretary Wilbur Ross on April 24, 2017,” says MHARR in the report.

( Mark Weiss, JD, President and CEO, MHARR. Credit: MHProNews)

While the imposition of the Canadian lumber tariff caps a period of serious economic uncertainty for the residential construction industry, increases in home prices driven by higher supply costs for basic raw materials, such as wood, will have a magnified impact on the highly-priced sensitive manufactured housing market.”

The full MHARR report and analysis is available for Daily Business News readers here. ##


(Image credits are as shown above, and when provided by third parties, are shared under fair use guidelines.)



RC Williams, MHProNews.

Submitted by RC Williams to the Daily Business News for MHProNews.

MHARR on HUD, DOE, Chattel and Powergrabs – Exclusive Report and Analysis

April 19th, 2017 Comments off

Collage credit, MHProNews.

The Manufactured Housing Association for Regulatory Reform (MHARR) has released its April 2017 Washington Update, an exclusive report and analysis that addresses key issues with the U.S. Department of Housing and Urban Development (HUD).

Covered in this MHARR report:


  • HUD Defines President Trump’s Regulatory Reforms
  • MHARR Highlights Urgent Need for Securitized Chattel
  • DOE Manufactured Housing Energy Rule Takes Another Hit

In a re-play of its well-documented institutional resistance to the full and proper implementation of the program reforms mandated by Congress in the Manufactured Housing Improvement Act of 2000, mounting evidence indicates that the HUD manufactured housing program, with its management team of Obama Administration holdovers, is openly defying the regulatory reform agenda of the new Trump Administration,” MHARR says in the report.

The report also provides insight on HUD program funding.

With the HUD program continuing to seek ever-higher funding levels from Congress in order to fund an unnecessary expansion of in-plant regulation via contractor make-work activity, MHARR is urging Congress to continue exercising strict oversight of the HUD program budget, in order to curb needless and costly contractor-driven paperwork and red tape.”

The full MHARR report and analysis is available for Daily Business News readers here. ##


(Image credits are as shown above.)



RC Williams, for Daily Business News, MHProNews.

Submitted by RC Williams to the Daily Business News for MHProNews.

MHARR to Secretary Perry: Withdraw Unnecessary MH Energy Rule

March 13th, 2017 Comments off

Credits: DOE, MHARR.

The Manufactured Housing Association for Regulatory Reform (MHARR) tells MHProNews that it has formally called upon the Secretary of the U.S. Department of Energy (DOE), Gov. Rick Perry, to withdraw its proposed manufactured housing energy rule.

MHARR says that the proposed rule is “rooted in climate change activism and advanced by energy special interests through an illegitimate and scandal-plagued regulatory process, threatens to needlessly destroy the affordability of manufactured homes” and “simultaneously excludes millions of consumers from the manufactured housing market – and from home-ownership altogether.

According to MHARR, the proposed rule could increase the retail cost of an average multi-section manufactured home by $6,000.00 or more because regulatory compliance, testing and enforcement-related costs were never considered by DOE in developing the rule.


DOE Secretary Rick Perry. Credit: Wikipedia.

MHARR has been on the record as an opponent of both the proposed DOE rule and the “fundamentally-tainted administrative process” that led to its adoption.

In a November 2016 letter, the organization called for the DOE “to cease and desist from any further activity on the proposed manufactured housing rule pursuant to Congress’ November 15, 2016 warning to all federal agencies against finalizing any pending rules or regulations in the Obama Administration’s last days.


M. Mark Weiss. Credit: MHProNews.

The DOE manufactured housing ‘energy’ rule is a textbook example of a destructive, big government ‘solution’ in search of a problem. Manufactured homes, comprehensively regulated by the U.S. Department of Housing and Urban Development, already have median energy operating costs that are less than, or comparable to, other types of housing, according to the U.S. Census Bureau,” said MHARR President and CEO Mark Weiss.

To single out manufactured homes and their mostly lower and moderate-income buyers for what amounts to a huge, regressive tax that would devastate both them and the industry in order to satisfy special interests, is incomprehensible, indefensible and precisely the type of baseless, damaging federal regulation that President Trump has vowed to eliminate.

The full letter from Weiss to Secretary Rick Perry is linked here. ##


(Image credits are as shown above.)



RC Williams, for Daily Business News, MHProNews.

Submitted by RC Williams to the Daily Business News for MHProNews.

MHARR Calls for Congressional Review, Rejection of DOE Rule

January 10th, 2017 Comments off

Credit: MHARR, Wikipedia.

Washington, D.C – The Manufactured Housing Association for Regulatory Reform (MHARR), tells MHProNews that it has now formally called on Congress to review and reject the panned final regulation adopted by DOE under the Congressional Review Act (CRA).

In a January 6, 2017 communication to the Chairmen of the Senate Energy and Natural Resources Committee and the House Energy and Commerce Committee, MHARR – citing extensive independent evidence, urged Congress to exercise its authority under the CRA to prevent any final DOE manufactured housing energy rule from taking effect.

Such a vote by Congress, would under the express terms of CRA, bar the DOE from reissuing the rule “in substantially the same form,” or issuing a new rule “that is substantially the same” as the rejected rule, “unless the reissued or new rule is specifically authorized by a law enacted after the date of the joint congressional resolution disapproving the original rule.

M_Mark_Weiss_MHARR_president__mhpronews__credit postedDailyBusinessNewsMHProNews

MHARR president and CEO M. Mark Weiss. Credit: MHProNews. For an in-depth interview with Mark Weiss, click here.

MHARR says that this prohibition, in light of changes in the composition of Congress and the election of a new president in November 2016, could well end the threat of destructive and debilitating DOE manufactured housing energy regulation for an indefinite period.

The association represents the interests of independent HUD Code producers, among others.

MHARR says that congressional rejection of a final DOE manufactured housing “energy” rule would fulfill President-Elect Trump’s pledge to “eliminate” wasteful and unnecessary federal regulations “which kill jobs and do not improve public safety  It would also put teeth behind Congress’ November 15, 2016 warning to all federal agencies to refrain from “finalizing pending rules or regulations in the [Obama] Administration’s last days.

In that warning memorandum, the congressional leadership promised to scrutinize any such midnight rules and if appropriate, overturn them, pursuant to the Congressional Review Act.

Manufactured homes ready for shipment-credit=wikipedia-postedDailyBusinessNewsMHProNews

Manufactured homes ready for shipment. Image credit – Wikipedia.

For the full statement from MHARR, click here.

For the full MHARR Congressional review request, click here. ##

(Image credits are as shown above.)


RC Williams, for Daily Business News, MHProNews.

Submitted by RC Williams to the Daily Business News for MHProNews.

SBA, George Washington University, Blast Proposed DOE Energy Rule for Manufactured Housing

September 26th, 2016 Comments off

Logos and photo are the respective property of each organization as shown, and are used here under Fair Use Guidelines.

It does not appear that DOE grasps the unique challenges that small manufacturers encounter.”

— U.S. Small Business Administration, Office of Advocacy

A controversial proposal by the U.S. Department of Energy (DOE) for manufactured housing has drawn support as well as growing opposition.

An arm of the United States Small Business Administration (SBA) and a policy analyst at George Washington University have weighed in on the DOE proposal. Both organizations are expressing concerns that mirror and amplify those advanced by the Manufactured Housing Association for Regulatory Reform (MHARR).

The Digital Journal is one of several hundred news and special interest sites that have carried word of how proposed energy efficiency standards could harm manufactured housing producers, businesses and consumers.

Reasoned Opposition Grows

Written comments to the DOE by both the SBA and George Washington University’s regulatory research program echo the vigorous objections of MHARR, which has led the opposition to the proposed rule.


Image credits, Digital Journal.

Comments filed on August 16th from the SBA’s Office of Advocacy note the DOE proposal does not comply with federal requirements than an agency quantify or describe the economic impact that its proposed regulation might have on small businesses.”

A separate public comment letter submitted the same day from Sofie E. Miller, a senior policy analyst at George Washington University’s Regulatory Studies Center, note that the DOE’s calculations overestimate the benefits of its proposed rule in several key respects.

Miller particularly notes the adverse impact on prospective low-income purchasers.

“…mandatory, across-the-board increases in efficiency will price many low-income consumers
out of the market for manufactured homes entirely.”

— The George Washington University Regulatory Studies Center

As MHProNews has previously reported, MHARR has been highly critical of the proposal.

Highlighting serious – and in MHARR’s view, “fatal” defects in the rule and the rulemaking process – which the Washington-based association says has been troubled by leaks, discrepancies and a lack of transparency.

The MH industry organization has called the DOE’s cost-benefit analysis a sham,” they say is driven by special interests.

mharr logo

MHARR logo, used here under Fair Use guidelines.

The George Washington University (GWU) analysis, stated the Digital Journal, “citing MHARR materials published in the industry trade journal, MHProNews – echoes serious concerns over anti-competitive effects resulting from the DOE proposal.

Executive Order, Third Party Research

MHARR says that of particular interest is an Executive Order issued by the President on April 15, 2016, in which the Center calls on DOE to pay particular attention to the prospective effects of its proposed rule on competition within the MH market.” 

According to recommendations from the GWU Center, “The DOE should commit to retrospectively reviewing its standard to ensure there is no conflict or overlap with existing HUD regulations and to evaluate the rule’s effects on competition within the MH market and the availability of affordable housing.”

In its comments, the SBA’s Office of Advocacy also focused on the proposal’s adverse impacts on competition, noting that the rule would have significantly disproportionate economic impacts on small manufactured home manufacturers if finalized.”

The comments called on DOE to adopt a regulatory alternative to the proposed standard that will minimize the economic impact to small manufacturers.”

MHARR commended these highly respected, independent organizations for filing comments on the proposed MH energy rule.

The cost-benefit analysis for the rule is skewed to the point of being arbitrary at best and deceitful at worst.”

— Manufactured Housing Association for Regulatory Reform (MHARR)

There are rumors that the Daily Business News is aware of that suggest that if the DOE continues on its proposed course of action without correction, “other legal measures” may be taken beyond written and verbal protest.

For the complete MHARR briefing on this issue, including the reports cited above, click here. ##

(Image credits are as shown above.)


RC WIlliams, for Daily Business News, MHProNews.

Submitted by RC Williams to the Daily Business News, MHProNews.

Champion Home Builders crafts Net-Zero-Energy home

September 8th, 2016 Comments off

Photo credit, Builder.

Champion Home Builders recently finished the construction of a net-zero demonstration home, reports Builder’s Jennifer Goodman.

The home is located at the Pine Tree Manufactured Home Park in Eatontown, NJ.  The plan is to gather data during the next 18 months, as a way to encourage the construction of more homes that will be more efficient, sustainable and yet affordable.

Data will initially be collected for six months while the home is unoccupied.  Information on energy use will continue for a year once the home has residents. Those results will then be used to help refine the design, with the goal of reducing the costs of future net-zero homes.

To reach net-zero-energy levels, the team applied an integrated design approach. It combined high insulation levels with a highly efficient heating and cooling systems, along with an innovative ductless air-moving system.


The home’s photovoltaic solar panel system allows the house to achieve net-zero-energy on an annual basis.

This project was a team effort.  Participants included the U.S. Department of Energy (DOE), Building America Program. Support also came from the Manufactured Housing Institute (MHI), the Systems Building Research Alliance (SBRA) and The Levy Partnership, Inc. (TLP).

The home is going to be one of the few to garner the DOE Zero Energy Ready Home (ZERH) designation, and the first manufactured home located in a cold climate to receive the honor.

The DOE believes the ZERH designation will symbolize a new level of home performance that’s the result of stringent requirements that will ensure high levels of comfort, durability, comfort and health.

To reach net zero energy we need to make sure every component of the home is extremely efficient,” The Levy Partnership president – and SBRA’s – Emanuel Levy told Builder.

As manufactured home professionals know, Champion is currently the number 3 producer of HUD Code manufactured homes in the U.S.


Emanuel Levy, credit,

Champion Home Builders was founded in 1953 and reports having produced over the years more than 1.7 million factory-built pre-HUD Code mobile homes, post HUD Code manufactured homes and modular homes or buildings throughout the United States, in the United Kingdom and western Canada. ##

Editor’s Note: for a related story on the DOE and their pending, controversial proposed changes for manufactured housing, please click here. ###

(Image credits, Builder/Champion, Dreamstime and


Joe Dyton, for the Daily Business News, MHProNews.

Submitted by Joe Dyton to the Daily Business News, MHProNews.

Precarious Position vs. Federal Power – DOE, CFPB, SEC, AGs v. ITT Institutes – takeaways for MH?

September 7th, 2016 Comments off

Photo credit, WPXI, text graphic credit, MHProNews.

Less than a week after federal official decided to ban ITT Technical Institute from enrolling new students using federal aid, the for-profit schools opted to stop enrolling students at more than 130 campuses in 38 states, according to the Springfield, IL  State Journal-Record.

On Aug. 25, the U.S. Department of Education announced that ITT Tech was banned from enrolling new students using federal financial aid.

Illinois U.S. Senator Dick Durbin (D) stated that ITT Tech is under investigation by numerous state AGs.  Indeed some 19 state attorneys generals (AGs), including Illinois’, have taken action.  The charges include misleading and deceptive practices.

ITT is also being sued by the Consumer Financial Protection Bureau (CFPB) and the Securities and Exchange Commission (SEC).

As stated in our public 8-K filing on Aug. 25, we are evaluating the additional sanctions and requirements, as well as all options available to us,” Nicole Elam, ITT spokeswoman, said in an e-mail to The State Journal-Register.We have voluntarily suspended all new student enrollment as we assess our options. This is our only comment at the moment.”

ITT student Niel Smith, per the Indy Star, said he could have finished his degree at ITT Tech in less than a year.

Is there going to be any way for me to finish my degree? What’s happening here?”

The Indy Star says that Smith, 27, now has $30,000 in student loan debt, and is concerned his class credits may not transfer over to another school or college.

When I took out those loans, my goal was to get a degree,” he said. “It wasn’t my goal to stop halfway through and have to pay back something that I have nothing to show for.”

One report says that the U.S. Department of Education has ordered ITT to aside $247.3 million in case the school went out of business. ITT blamed their closure on those sanctions, saying they were “unwarranted,” “inappropriate” and “unconstitutional.”

However, some experts believe that ITT may have brought the issue on themselves, as they’ve been under investigation by one or more state AGs since 2002.

Takeaway for Manufactured Housing?


Political cartoon by MHProNews, CFPB spoof logo credit, Plus1Properties.

Industry professionals may wonder why a story that has no direct connection to manufactured housing is being featured in the Daily Business News.  But are there any warning signs in ITT’s experience for MH industry professionals and the associations that represent them?

From time to time, manufactured housing is also negatively in the news, for example, over finance related or community related issues.

From time to time, similar MH related issues arise in one jurisdiction that have also occurred in others.

While this does not presently rise to the level of what ITT seems to be facing, what if an aggressive regulator or administration comes into office in Washington, D.C.?

Thus, there is a need to publicly refute the misleading and often false claims that may make it into the media, while industry professionals must also be willing to publicly tackle those instances when something truly troubling has occurred.

Absent the industry routinely defending and policing itself, what would happen if one or more federal departments – perhaps in concert with state attorney generals – decided that various entities in manufactured housing were engaging in deceptive or unfair tactics? How far could they go in shutting down significant portions of our industry?

Note that ITT, per their website, is a $17+billion a year enterprise. That’s some 3 times the volume of all new manufactured home sales. Don’t forget, a rogue regulator in New York has reportedly said that he wants to put manufactured housing out of business in his state within ten years. ##

(Image credit, WPIX.)


L. A. ‘Tony’ Kovach is the publisher of and

Article submitted by L. A. “Tony” Kovach, for the Daily Business News, MHProNews.

MHI and MHARR Respond Differently to DOE’s Proposed Energy Standards

June 20th, 2016 Comments off

dept_of_energy__u_s__their_creditIn response to the Department of Energy’s proposed rules on energy standards for manufactured housing in the Federal Register, the Manufactured Housing Institute (MHI) says it worked closely with the DOE to try and avoid excessive costs to consumers that will outweigh benefits.

The DOE based their recommendations on the Manufactured Housing Working Group:

The MH Working Group’s recommendations were based on the 2015 edition of the International Energy Conservation Code (IECC), the impact of the IECC on the purchase price of manufactured housing, total lifecycle construction and operating costs, factory design and construction techniques unique to manufactured housing, and the current construction and safety standards set forth by U.S. Department of Housing and Urban Development.”

MHI further says that these regulatory efforts should be in keeping with HUD’s role as the prime regulator of manufactured housing, and “to ensure that these regulations are consistent with the HUD Code. MHI plans to submit written comments during the written comment period. The Manufactured Housing Consensus Committee (MHCC) will also be evaluating the impact of the rule on MH.

Meanwhile, the Manufactured Housing Association for Regulatory Reform (MHARR) says the proposed rule will add thousands to the cost of MH, depriving many in the moderate to lower-income housing market away of potential homeownership, as well as harming smaller players in the MH industry.

The rule began in 2011 with a selective leak of the proposed rule to the Manufactured Housing Institute (MHI), the industry’s largest trade organization, and others of interest, until the Office of Management and Budget demanded they re-start the rulemaking process.

The fresh start became an alleged collusion between MHI, the Department of Energy and other special interests to ram a proposed rule through an obscure committee while the DOE “awarded multiple lucrative contracts to MHI-connected ‘research’ entities to, among other, things, tout DOE manufactured housing energy regulation and break-down industry opposition to any ultimate DOE rule.”

MHARR says the DOE then provided a copy of the proposed rule in advance of the official publication date to MHI in an attempt to possibly soften opposition to the rule.

MHARR says the rule offers a solution to a non-existent problem: According to the U. S. Census Bureau, manufactured homes are already energy efficient, comparable, and sometimes lower in energy use, than site built homes.

According to DOE Manufactured Housing Working Group data, the rule would add an average of at least $2,226 to the price of a single-section MH, while adding $3,109 retail to the price of a multi-section home.

MHARR says, however, the cost will likely be closer to $4,000 for a single-section and $6,000 for a multi-section MH, although these do not include testing, enforcement or any compliance costs, and basically amount to a regressive tax that hurts those at the lower end of the economic spectrum, the very demographic affordable, manufactured homes are designed to help.

The DOE would basically impose energy measures on manufactured homes that are already available as options homebuyers can choose from, or not, measures that are not even mandated for million dollar site-built homes in most states.

MHARR says in addition to consumers, the greatest negative jolt will be on smaller HUD Code businesses who do not have the cushion to absorb the up front impact of the proposal.

MHARR says: “Thus, the industry’s largest corporate conglomerates – and their national representative MHI – have not only ‘gone along’ with DOE, but appear to have worked publicly and behind the scenes to advance government action that will disproportionately harm smaller competitors. This, together with a level of industry domination that either does – or will — exceed half the national manufactured housing market, raises antitrust questions that should and will be explored further.”

The DOE did not offer to allow the Manufactured Housing Consensus Committee (MHCC) the opportunity to consider the proposed rule or the ramifications of its cost.

MHARR has subsequently filed Freedom of Information Act (FOIA) requests because of the closed door collaboration of MHI, Dow and other parties; and seeks documents that show DOE payments to MHI-connected entities and individuals.

MHARR will submit comments to the DOE before Aug. 16, when discussion is closed; and if there are not substantive changes to the rule, MHARR says it may seek legal action.

For the DOE proposal in the Federal Register, please click here. For the link to MHARR’s full statement to MHProNews, please click here. The full download of the NAHB’s priced out study – which reflects the numbers of prospective home buyers lost per each $1000 in price increase – is found in the article linked here##

(Image credit: U. S. Department of Energy)

matthew-silver-daily-business-news-mhpronews-comArticle submitted by Matthew J Silver to Daily Business News-MHProNews.