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

February 13th, 2019 Comments off

USDeptOfEnergyProposedRuleMakingCouldImpactManufacturedHousing

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.

 

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

 

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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.

 MHARRNEWSheaderDailyBusinessNewsMHProNews

 

FEBRUARY 13, 2019

 

TO:                  MHARR MANUFACTURERS

                        MHARR STATE AFFILIATES

                        MHARR TECHNICAL REVIEW GROUP (TRG)

 

FROM:             MHARR

 

RE:                  NEW PROPOSED ENERGY STANDARDS RULE SHOULD 

                        APPLY TO MANUFACTURED HOUSING ENERGY RULEMAKING

 

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 —

 

See the related reports, below the byline, business development opportunities, and notices.  “We Provide, You Decide.” © ## (News, analysis, and commentary.)

 

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Rapid Acceptance of Energy Star Rated, Residential-Style Manufactured Homes Proves Need, Value as Affordable Housing Solution

 

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

 

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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

http://www.mhpronews.com/blogs/daily-business-news/doe-rfi-closed-but-issue-impact-still-looms-over-manufactured-housing-homebuyers/

 

 

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

 

Revival Of DOE Energy Rule May Require Legal Action

 

 

 

 

 

 

 

 

 

MHARR to Secretary Perry: Withdraw Unnecessary MH Energy Rule

March 13th, 2017 Comments off
MHARRtoSecretaryPerryWithdrawUnnecessaryMHEnergyRulecreditNuclearTownHall-postedtothedailybusinessnewsmhpronewsmhlivingnews

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.

MHARRtoSecretaryPerryWithdrawUnnecessaryMHEnergyRulecreditWikipedia-RickPerry-postedtothedailybusinessnewsmhpronewsmhlivingnews

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.

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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.)

 

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RC Williams, for Daily Business News, MHProNews.

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

MHARR Calls for Federal Moratorium On Critical Regulations

November 23rd, 2016 Comments off
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Credit: MHARR.

The Manufactured Housing Association for Regulatory Reform (MHARR) has joined with President-elect Trump and leaders in Congress in calling for federal agencies to place a moratorium on pending regulatory actions during the final days of the Obama Administration.

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MHARR president and CEO M. Mark Weiss. Credit: MHProNews.

MHARR tells the Daily Business News that they are calling on the heads of three agencies specifically – The U.S. Department of Energy (DOE), the U.S. Department of Housing and Urban Development (HUD) and the Federal Housing Finance Agency (FHFA) to defer further action on pending controversial rules or actions that could have a severely negative impact on both the manufactured housing industry and American consumers of affordable housing.

MHARR will closely monitor all regulatory activity affecting manufactured housing during the remaining term of the Obama Administration, and will keep the industry apprised – and take further steps — as warranted.

For additional details on MHARR’s call for a moratorium, including the official news release and letters sent to regulators and public officials, click here.

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MHARR member builders include Sunshine Homes, which produced the Energy-Star rated single sectional manufactured home shown above.  Photo credits from a still of an Inside MH video on MHLivingNews.com, Sunshine Homes and ManufacturedHomes.com

As long-time Daily Business News readers know. MHARR represents independent producers of federally-regulated HUD Code manufactured homes.##

(Image credits are as shown above.)

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RC Williams, for Daily Business News, MHProNews.

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

Solar Decathlon Modular Home Aimed at Farmworkers

September 9th, 2015 Comments off

Solar_decathlon_home_Department_of_Energy_slash_flickrWhile many of the collegiate entries in the U. S. Department of Energy’s Biennial Solar Decathlon are cost-effective, energy efficient and attractive homes targeted to baby boomers and growing middle-class families, the University of California, Davis (UC Davis) team is targeting migrant farm workers, as mnn tells MHProNews, with a net-zero modular home.

It’s appropriate for the university, which was founded in 1905 as a rural farm school with an emphasis on agriculture, forestry and veterinary sciences, and is located in an area west of Sacramento known for tomato production.

Robert Good, a civil engineering graduate who serves as the team’s project manager, said, We’re dedicating the design to the needs of farmworkers or agricultural workers. The engineering, the architecture, and the entire focus of our team are dedicated to achieving this goal while achieving an affordable price point.

Many farm workers live in over-crowded conditions with limited plumbing, and heating and cooling facilities, often because they cannot afford anything better.

Termed Aggie Sol, straw bales provide insulation in the 14-inch, wood-framed walls of the modular home, and an outdoor decontamination room with a shower allows field workers to wash pesticides and other contaminants from their clothes and bodies before entering the home. Inside is a multipurpose great room combining the kitchen, living and dining rooms.

The limited number of windows keeps the hot sun out, while solar tubes bring in natural light, and a butterfly-shaped roof provides rainwater collection. An innovative heating and cooling system keeps utility bills down, and solar panels on the roof provide electricity.

As Gail Wadsworth, executive director of the California Institute for Rural Studies, wrote, “As long as the people who work in the fields where our food is produced live in unhealthy and unsafe conditions, our food system will never be sustainable. ##

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

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

New Energy-efficiency Standards for MH on Tap

June 17th, 2014 Comments off

The Natural Resources Defense Council reports the U. S. Department of Energy (DOE) has assembled a working team to develop new energy-efficient standards for manufactured homes (MH) to replace the current ones that are over 20 years old. Noting the existence of nine million manufactured homes nationwide providing affordable housing for 20 million people, MHProNews understands the DOE estimates that introducing new guidelines for manufactured housing built over the next 30 years could save 200 billion kilowatt-hours of electricity as well as curtail carbon-dioxide emissions by 40 million metric tons. Consumers not only would enjoy greater comfort but also save nearly $500 million annually, according to the newsletter from the Manufactured Housing Institute (MHI). ##

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

Modular Entry from Solar Decathlon on Display in Albuquerque

December 17th, 2013 Comments off

Combining forces, the University of New Mexico and Arizona State University entered a solar modular home in the U. S. Dept. of Energy (DOE)s’ Solar Decathlon held in Oct. at Irvine, California, winning first prize in the “energy balance” category and in the top ten in other categories. “SHADE (Solar Homes Adapting for Desert Equilibrium) pays tribute to the interdependence of desert plant life while maximizing occupant comfort and flexibility,” according to what the organizers related to bizjournals.com. The house features rainwater cachement tanks, modular furniture, solar canopies, capillary radiant heating and a “whole-house” control system. MHProNews has learned the modular home will be on display at Mesa del Sol in south Albuquerque, New Mexico through March.

(Photo credit: Joanie Griffin/bizjournals.com—SHADE)

Energy Report on “Not Your Grandfather’s Trailer House”

November 7th, 2013 Comments off

While many buyers of manufactured homes (MH) are more concerned with affordability and, say, the kitchen cabinetry than energy efficiency, the MH industry is offering more energy efficient features that can save the homeowner anywhere from $30 to $70 month. Ronnie Richards, vice president of marketing for American Homestar Corporation, builder of Oak Creek and Platinum brand manufactured homes, says it’s not easy for consumers to imagine saving energy expenses. “Lifestyle and local electricity rates will vary as well, so it’s hard for buyers to calculate the exact amount of utility savings they would receive,” he notes. Harold D. Hunt, PhD with the Texas A&M Real Estate Center, tells manufacturedhomelivingnews.com the EnergyStar label, a joint effort of the U. S. Dept. of Energy (DOE) and the Environmental Protection Agency (EPA), is well recognized as a symbol of energy efficiency, and realizes approximately 30 percent energy savings from the HVAC in a manufactured home. While most manufactured home producers offer EnergyStar as an option, Charley Boyer of Oak Creek Homes says his company is considering building only those homes. Cavco Industries offers their own energy efficient package, EnerGmiser, available on some Palm Harbor homes, and Power Saver option on their Masterpiece line. Charlie Hill, of Palm Harbor Homes says, “The EnerGmiser package is actually standard on the majority of our home models. On an approximate 1,400-square-foot home it would add about $400 to the cost.” The Oregon Office of Energy says Energy Star features add on average $8 to the mortgage but save $30 on monthly heating and cooling bills. As DJ Pendleton, Executive Director of the Texas Manufactured Housing Association points out, Texas accounts for 20 percent of all the HUD Code homes produced in the nation, but only a few states offer incentives of one type or another for EnergyStar certified manufactured homes: North and South Carolina, New Mexico and California. MHProNews understands in Tennessee, the Tennessee Valley Authority (TVA) offers a $1,450 incentive to home manufacturers for EnergyStar HUD Code models. Clayton Homes provides and distributes EnergyStar homes in the six-state TVA region. For the complete article, click here.

(Photo credit: WBIR-TV/TVA)

Austria Takes Top Prize at Solar Decathlon

October 14th, 2013 Comments off

Austrian students from Vienna University of Technology won top honors at the U S. Department of Energy’s (DOE) Solar Decathlon, besting 18 other entries from around the world for “designing, building, and operating the most cost-effective, energy-efficient and attractive solar-powered house.” The modular wooden frame home, Austria’s first ever entry in the competition, is totally solar-powered and made to be quickly assembled as well as easily dis-assembled. The service core houses the bathroom, bedroom and all the technical equipment for the house while textile shades open and close up areas for gathering. As archdaily.com reports, a floor system regulates heating, cooling and fresh air to create a comfortable indoor environment, while a shower tray recovers thermal energy from drain water through a heat exchanger, reducing net energy consumption in the modular home. As MHProNews has learned, University of Nevada at Las Vegas took second place, followed by Czech Technical University in third.

((Photo credit: Jason Flakes/U. S. Dept. of Energy Solar Decathlon)

Governor to grace Solar Decathlon team send off

August 28th, 2013 Comments off

vermont-governor-oeter-shumlin-posted-daily-business-news-manufactured-housing-pro-news-mhpronews-com-Norwich University and Middlebury College will co-host a send-off event for their student-teams competing in October in the international U.S. Department of Energy Solar Decathlon in Irvine, California. Governor Peter Shumlin will be the keynote speaker at the Statehouse event in Montpelier on Tuesday, Sept. 10. Norwich University President Richard Schneider and Middlebury College President Ronald Liebowitz will also speak at the event, which is set for from 10:00 a.m. – 12:30 p.m., along with speakers who are student-team members. Unique aspects of their designs will be showcased and celebrated with complimentary refreshments and live music. The biennial solar home design competition will be held at the Orange County Great Park in Irvine, CA. Oct. 3-13. The vtdigger tells MHProNews that Norwich’s home is named the DeltaT-90, while Middlebury’s is dubbed the InSite. ##

(Photo credit, Governor Peter Shumlin: VT.gov)

University of Calgary Begins Work on Solar Modular

January 28th, 2012 Comments off

Solar Modular CalgaryA student-led team from the University of Calgary has been chosen to take part in the U.S. Department of Energy Solar Decathlon for the third consecutive time, pitting its unique housing concept against another Canadian team and entries from across the United States and around the world. Team Alberta’s concept is based on addressing the housing needs that are so pressing in remote communities and industrial camps such as those in the Fort McMurray region. The team intends to produce a modular home that is easy to transport and assemble and is affordable for working Families, as well as for remote working populations. The U.S. Department of Energy announced Thursday the 20 collegiate teams selected to compete in the biannual competition to design, build and operate a highly efficient and sustainable house. Teams are required to compete in ten different categories – ranging from best architecture and engineering to energy production for heating and cooling – while gaining valuable real-world experience in a growing global industry. Next year’s contest will take place in Irvine, California, in the first Solar Decathlon held outside of Washington D.C. Teams will assemble and operate their homes while on public display at Orange Country Great Park.

(Image Credit: University of Calgary)