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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.

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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.

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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.