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“Potentially Enormous Costs” “Proposed DOE Manufactured Housing Energy Standards” Exposed as HUD PD&R “Whitewash”

March 20th, 2019 Comments off

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The Department of Housing and Urban Development (HUD) periodically commissions research on various topics.  That research may be dubbed “Policy Development and Research” or PD&R.

 

As an example of a useful HUD PD&R, one established some years ago that manufactured homes and conventional housing – sited side-by-side in urban areas – witnessed that both types of housing appreciated in value. That useful PD&R research demonstrated that insight from not one, but several cities in various parts of the country.

So, some HUD PD&Rs are good and useful ‘wheat.’ But others, are the chaff that must be separated from wheat, which is to be tossed out and rejected as unfit for human consumption.

In a new analysis, the Manufactured Housing Association for Regulatory Reform (MHARR) informs the Daily Business News on MHProNews of research that their analysis reveals is problematic for most in manufactured housing, and for the industry’s potential consumers.  That is the work that a production-focused association is supposed to be doing.

 

 

Producers and Non-Producers

The work that MHARR does is a living example of the distinction between the work of production focused and post-production related issues.  Both kinds of trade associations – production and post-production – are essential for a successful and properly functioning industry.  One could say that pre-production is yet another segment, but that is closely allied with producers of factory built housing.

Yet, some manufactured home industry bloggers and writers – who are blindly agenda driven by whomever will give them the most money, attention, or whatever else – have attempted to blur that distinction between the production – the HUD Code factory-builders – and the post-production, which are the items that occur after the home leave the ‘production center’ or ‘factory.’

It isn’t MHARR’s ‘job’ as a production focused trade group – so to speak – to weigh in on community related issues, per se, as but one of many possible examples. Communities or retailing are 2 of several post-production matters.

With that tee up, let’s dive into the review by MHARR of what their analysis says is a looming risk for the industry. That risk is for potentially far higher costs caused by pending federal rule-making.

Note that MHARR cites 2 other sources, the Small Business Administration (SBA) and George Washington University Regulatory Studies Center, which were part of the strategic alliance that MHARR was engaged with that foiled the Manufactured Housing Institute (MHI) multi-year counter-effort to drive the HUD Code manufactured housing industry into federal mandates that could have been $6000 or more higher per unit. After years of push back, MHI relented.

More on MHARR and production vs. post-production associations after their release and attached document.

 

 

MHARR ANALYSIS EXPOSES HUD PD&R ENERGY COSTS “WHITEWASH”

 

Washington, D.C., March 19, 2019 – The Manufactured Housing Association for Regulatory Reform (MHARR) has filed an analysis and comments (copy attached) with the federal Manufactured Housing Consensus Committee (MHCC) exposing a blatant whitewash of supposed manufactured housing energy regulation costs developed at the request of the MHCC by the Department of Housing and Urban Development’s Office of Policy Development and Research (PD&R).

PD&R’s ostensible “analysis” of U.S. Department of Energy (DOE) cost/benefit data initially developed as part of a fundamentally tainted and contrived DOE “negotiated rulemaking” process, not only fails to provide the independent fact-finding regarding the potentially enormous costs of proposed DOE manufactured housing energy standards sought by the MHCC, but constitutes a cover-up and attempt to legitimate, after-the-fact, a brazenly-contrived DOE rulemaking process (and related alleged cost-benefit inputs) that wererejected by the Office of Management and Budget and its Office of Information and Regulatory Affairs (OIRA) not once, but twice.

To the extent that DOE’s most recent regulatory proposals, contained in the August 2018 “Notice of Data Availability” (NODA) allegedly “analyzed” by PD&R, expressly rest-upon and are admittedly derived from those earlier illegitimate data inputs – thoroughly deconstructed and disproven by MHARR, the George Washington University Regulatory Studies Center and the U.S. Small Business Administration — there is absolutely no valid basis for the NODA proposals, and PD&R’s alleged “analysis” of that data is completely baseless and factually worthless.  As a result, MHARR’s comments call for a completely new standards development process for any new manufactured housing energy standards, if any such standards (which are unnecessary as shown by U.S. Census Bureau energy cost information) are, in fact, developed.

The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing

 Download of Report – linked here

— 30 —

 

This is an apt and timely example of what production focused work looks like.

In terms of an MHProNews analysis, MHARR over a decade ago began to pay more attention to a specific post-production issues, which involved financing and capital access.  Mindful of what occurred that drove thousands of industry independents out of business, and took several producers with them, MHARR added to their plate efforts to help industry independents gain better access to other financing options.

The historic risk is arguably documented by those in Omaha and Knoxville, linked here.  MHI arguably didn’t lift a finger while that assault on industry independents took place.

While MHARR was working to get the Duty to Serve mandate passed into law through the Housing and Economic Recovery Act (HERA) – to protect independent producers by protecting independent retailers of manufactured housing – the Manufactured Housing Institute (MHI) somehow allowed the same HERA bill to pass into law the SAFE Act, which eventually became part of the regulations administered by the Dodd-Frank created Consumer Financial Protection Bureau (CFPB).

Rephrased, MHARR was doing its job, and more.  By contrast, Tim Williams, speaking as Chairman of MHI admitted in a meeting that the “horse has left the barn” on the SAFE Act, and Dodd-Frank too.

MHI claims to be representing “all segments of factory-built housing.”  While they can voice that claim, they could just as easily claim to be superman, and assert that they are able to leap tall buildings in a single bound.  The better question is, what is the MHI track record on production or post-production issues?  After all, it is Warren Buffett who stresses the importance of looking into the rearview mirror.

 

InBusinessWorldRearViewMirroIsAlwaysClearerThantheWindshieldWarrenBuffettMHProNews

 

The short answer is a sobering one.  MHI’s track record in the last 15 years since Berkshire Hathaway has entered the industry through various acquisitions has been poor. Who said so?

Consider what Nathan Smith said on camera when he was Chairman of MHI.  Smith asserted that the industry – meaning MHI – had to admit that it has failed to be pro-active to problems.  Tim Williams admitted as much.  Richard ‘Dick’ Jennison said so on stage at Louisville, also caught on MHProNews’ cameras.

When MHI’s own elected and salaried leaders admit that the Arlington, VA based organization has failed time and again, why is it that the industry’s independents follow it so readily?

 

That answer is complex, but equally sobering.  The MHProNews analysis, after years of input from industry professionals within and outside of MHI, reveals this harsh conclusion.

n  Some are members because they want to be, and they may in fact benefit.

n  Others, are members like the MHI member linked here admit that they have never benefited from being a member.

n  Then some are members out of fear of reprisal.

n  Non-MHI members – or those who resisted for a time – have told MHProNews that they are being ‘bullied and intimidated’ into becoming MHI members.

 

Each of these points raises different legal as well as ethical questions.

 

n  Is MHI a de facto protection racket?

n  Is MHI guilty of making false and deceptive claims, that violate federal as well as state laws?

n  Has MHI aided and abetted the consolidation of the industry into ever fewer hands of ‘big boy’ companies – borrowing MHI award-winner Marty Lavin’s phrase – and if so, are they deceiving the industry when they claim that they represent all segments of factory built housing?

 

These will be among the items that will be examined publicly at Tunica on March 28th, after the main event is concluded.  Watch for the time and date for that meeting, which MHI leaders, Clayton Homes, and 21st Mortgage, and their attorneys – among others – are being invited to attend.

 

To learn more about that Tunica meeting, see the two links that follow the by line, notices and email head-line news, and business developments offers.

 

Once a problem(s) is/are identified, the next thing that must occur is steps to solve the problem(s) must be acted upon. RSVPs to attend the solution-focused discussion are already coming in.

 

The time to form a new post-production association that represents the interest of non-producers, and which can complement the work of MHARR for producers of HUD Code manufactured homes is now. It must be said that MHARR, which could have gone into direct competition with MHI, voted to stay as a producer group, but encouraged the industry to create their own post-production group, that they want to work with.

The place to begin that process is Tunica, MS.  See the related reports, further below.

 

That’s this morning’s MH “Industry News, Tips, and Views That Pros Can Use” © where “We Provide, You Decide.” © (News, analysis, and commentary.)

 

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Related Reports:

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

October 5th, 2017 Comments off
E:\MH Merchandiser.com\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.”

StevenNadelExecDirectorACEEEpostedDailyBusinessNewsMHProNews

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.

JohnBostickPresidentSunshineHomesRedBayAL-OurIndustryProvidesGreenAppealingOptionsWeeksNotMonths-DailyBusinessNews-MHProNews

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

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Photo credits are as shown above, collage and text credits, MHProNews.com. 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 MHProNews.com.

NRDC, ACEEE on DOE Energy Rule Proposals – Analysis – Helpful or Harmful for Consumers, Manufactured Housing Industry?

September 2nd, 2016 Comments off
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Logo collage, each logo is the property of their respective organization, and is used here under fair use guidelines. Photo, Dennis Raper, chain saw artist and supervisor at Sunshine Homes, with Energy Star home under construction in the background (credit, still from video on MHLivingNews.com).

Lauren Urbanek, writing for the Natural Resources Defense Council (NRDC), is among the recent writers and policy advocates expressing their support for the Department of Energy (DOE) proposed revised standards for manufactured housing (MH).

Building on a report on the American Council for an Energy-Efficient Economy (ACEEE) done by Senior Policy Advisor Lowell Ungar, Ph.D., Urbanek mimics Ungar’s findings in touting projected benefits for manufactured housing and its potential home owners.

LauraUrbanek-credit-NRDC-postedDailyBusinessNews-MHProNews-But who is the NRDC?  How accurate is the information (ACEEE) that they’re basing their claims on about manufactured homes?  Are there facts that have been glossed over, ignored or overlooked by NRDC, ACEEE, the DOE and others?

And will this specific type of media attention harm or help manufactured housing and its recovery from the bottom hit in 2009?

NRDC’s Self-Description

From the NRDC’s website, “We combine the power of more than two million members and online activists with the expertise of some 500 scientists, lawyers, and policy advocates across the globe to ensure the rights of all people to the air, the water, and the wild.”

Headquartered in New York City, NY, they have other offices in:

  • Washington, D.C.
  • Chicago, IL
  • Bozeman, MT
  • San Francisco, CA
  • Beijing, China

Clearly, this is a significant organization shining its light on the manufactured housing industry, and the energy efficiency of our HUD Code MH producers’ homes.

But the sheer scope of this organization doesn’t mean that clean air, less-waste and thus greener and energy-saving manufactured home professionals should be intimidated by their influence.

Rather, their scope ought to be a call to action to by professionals to engage this group, and encourage them and others to take a closer look.  Only by truly understanding the realities of what today’s HUD Code manufactured homes already are, can move advocacy groups from being skeptics or critics and advance to becoming natural allies (pun intended) for the MH Industry, and millions of potential homeowners.

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Collage from ACEEE article by Lowell Unger, Ph.D. Text graphic by MHProNews.

Non-Profits, Media and Manufactured Housing

MH Industry professionals have seen this kind of non-profit pushed, media-geared promotional efforts before.  One vivid example is the Housing and Economic Recovery Act (HERA 2008), which gave the nation and manufactured housing the SAFE Act as well as “Duty to Serve.”  How did that work out for the MH Industry and its professionals?

The Washington, D.C. based Manufactured Housing Association for Regulatory Reform (MHARR) has repeatedly raised the warning flags against this DOE proposal.

Initially embraced by members of the Manufactured Housing Institute (MHI), more recently that Arlington, VA based group have said in their soon-to-be-retired communications email, the Week in Review, that they too are now urging restraint on the Department of Energy (DOE – see their letter, linked here).

The NRDC’s headline is the first clue that advocacy is at play, “Standards for Manufactured Housing Will Mean Higher Quality and Better Comfort.” But that misses a key fact. Manufactured housing has had performance-based federal standards for over 40 years.

StandardsManufacturedHousingHigherQualityBetterComfort=NRDC-postedDailyBusinessNewsMHProNews-

Collage from NRDC, text graphic, by MHProNews.

LowellUngerSeniorPolicyAdvisor-credit-ACEEE-postedDailyBusinessNews-MHProNews-Ungar’s ACEEE pro-DOE proposal post fails to cite sources or to use proper terminology.  When someone who has had the rigorous academic training needed to obtain a doctorate fails to get the basics correct, what is to be expected of the rest of Unger’s work?

Dr Harold Hunt, Ph.D, in an article found on MHLivingNews, has cast a favorable light on modern manufactured housing, its green features, including energy savings. See Hunt’s report, linked here.

DrHaroldHuntPhDTXAMResearchEconomist-postedDailyBusinessNews-MHProNews

Collage above is from the article posted on MHLivingNews, by Dr. Harold Hunt. To see the article, click here or the image above.

A review by MHProNews’ Daily Business News of what is going understated by these advocacy-driven media reports is this; that the estimated costs for implementing these rules are higher than is expected to be recouped in a typical 7- to 10-year ownership period common for most homebuyers.

To rephrase, the cost-benefit numbers are upside-down for potential buyers. The ROI may be there after 12 to 20 years of ownership, but they are often lacking for 10 years or less. During that long window of time, what advances might occur that makes the current proposal or needs obsolete?

Also underplayed or ignored are those MH Industry voices that say that this proposed regulation, as is true of any other, will fall disproportionately harder on smaller, independent builders.

formaldehydefreeInsulationBlownBattsManufacturedHousingUnderConstructionSunshineHomes-MHLivingNewsVideo-postedMHProNews-

Formaldehyde-free insulation is being used in the Energy Star rated home shown, still from video below. This producer is now building only to Energy Star standards.

The Daily Business News recently reported on the National Association of Home Builders’ (NAHB) in-depth study on the impact of regulations on their builders, see that link here, which includes a link to the NAHB’s so-called Priced-Out Report.

The NAHB Priced Out report demonstrates that hundreds of thousands of prospective home buyers would be knocked out of the opportunity to buy, in this case, all in the name of an energy plan that does not pay for itself in a timely fashion.

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Jerry and his wife Karen McKibben are featured in the video shown below. Jerry is an engineer by trade, and both praised the construction, quality, appeal and the energy savings in their manufactured home. They previously owned an conventional house, as well as a pre-HUD Code mobile home.

What Do Manufactured Home Owners say?

Perhaps no one in manufactured housing today has done more third-party video interviews with manufactured home owners than is found in the Inside MH Road Show series, found on MHLivingNews.com.  One of the common questions interviewed homeowners are asked about is regarding their utility bills.  How does the manufactured home they now own compare to their prior housing in energy costs?

MH homeowners routinely report that they are paying less for their utility bills then when they owned conventional, site-built housing.

 

 

Such points ought to lead objective researchers to what appears to be a critical oversights by each of these well-meaning advocates who are pushing the DOE proposed rule on manufactured housing.

Perhaps the biggest fallacy of this entire DOE proposal is that it doesn’t respect the consumers right to choose.  Energy Star rated manufactured homes are already available. Some manufacturers specialize in energy saving, and some even offer “net zero” factory-built homes. Upgraded insulation can already be ordered from almost any producer by any consumer who wants it.

Why not let the consumer choose for himself? Isn’t that the American Way?

Going into this Labor Day weekend, manufactured housing ought to tout itself for what it already is – greener than conventional, on-site housing construction, and often half the cost of conventional building, backed by warranties and federal performance and state/federal installation standards.

When even frugal millionaires are buying manufactured homes, doesn’t that speak volumes?

The NRDC, ACEEE and others ought to revisit their report in the light of a better, more global understanding of what manufactured housing has already accomplished for some 20 (+/-) million Americans. The DOE in turn should heed the concerns of manufactured housing industry professionals. The proposed cure could cost the industry and potentially tens of thousands of renters and housing shoppers every month a golden opportunity at becoming homeowners.  ##

(Image credits as shown above).

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

(Editor’s Note: As the insightful report yesterday by Joe Dyton reflects, MHProNews is welcoming periodic guest writers. ICYMI, Matthew Silver is taking some much needed and well-earned time off, and L. A. “Tony” Kovach will be helping fill the Daily Business News role in the interim).

Article submitted by L. A. ‘Tony’ Kovach to the Daily Business News, MHProNews.com.

 

MHARR says the DOE is Seeking Support for New Manufactured Home Energy Standards

June 11th, 2015 Comments off

mharr logoThe Manufactured Housing Association for Regulatory Reform (MHARR) tells MHProNews a Department of Energy (DOE) contractor, Navigant Consulting, is contacting producers of manufactured housing, especially smaller manufacturers, to obtain feedback on new proposed energy standards for manufactured housing. MHARR maintains the new standards are unnecessary and excessively costly, although they are supported by larger manufacturers.

The recommendations resulted from the Working Group process of last year and may form the basis for a DOE rule which is expected soon. MHARR says because of its vehement opposition to these new standards, the DOE is seeking feedback from individual producers that will support its position in establishing these new rules. MHARR wants to be notified if and when Navigant attempts to contact manufactured home producers. ##

(Image credit: Manufactured Housing Association for Regulatory Reform)

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

Energy Department Seeking Comment on Air Quality Standards

June 28th, 2013 Comments off

The U. S. Dept. of Energy is developing energy standards for manufactured housing, as required by the Energy Independence and Security Act of 2007 (EISA), and wants input from interested parties. The focus is on the relationship between energy efficiency and indoor air quality, incentives to install energy-saving devises in manufactured homes, and methods of enforcement. Published in the Office of the Federal Register, MHProNews has learned the deadline for comments is July 25, 2013. For more information, click here.

(Photo credit: seacoastonline–Ken Cantara, energy auditor)