“Solar for Manufactured Homes” – Assessment of Opportunities and Challenges – Clayton, MHI Ties – Reaction by Manufactured Housing Association for Regulatory Reform, Analysis plus Manufactured Home Market Updates

CESACleanEnergyStatesAllianceSolarManufacturedHomesOpportunitiesChallengesClaytonMHILogosTiesReactionManufacturedHousingAssocRegulatoryReformAnalysisManufacturedHomeMarketsMHProNews

Facts matter. Evidence matters, as do fact-checks and informed analysis. “Solar for Manufactured Homes – An Assessment of the Opportunities and Challenges in 14 States” is a two-volume publication by the Clean Energy States Alliance (CESA). A 2019 press release by CESA indicates that they have been given some $1.1 million dollars in grant money by the Department of Energy (DOE).  There are at least 13 references to “Clayton” Homes found in CESA Volume 1, per a word search of that document, which was provided by CESA to MHProNews. There is a reference by CESA to the Manufactured Housing Institute (MHI), which will be noted further below. Then, there were over 130 references in Volume 1 and Volume 2 of CESA’s to Datacomp, an MHI member. By contrast, there were no references to the Manufactured Housing Association for Regulatory Reform (MHARR). When Warren Leon, Executive Director of Clean Energy States Alliance (CESA) was asked specific questions about the organization and its engagement with manufactured housing, part of his reply was in response to MHARR’s claim that they are a “special interest group.” Leon denied that characterization.

But CESA own LinkedIn profile page on 5.26.2021 said: The Clean Energy States Alliance (CESA) is a national nonprofit coalition of public agencies and organizations working together to advance clean energy. CESA members include many of the most innovative, successful, and influential public funders of clean energy initiatives in the country.”

Oxford Languages defines a special interest as: “a group of people or an organization seeking or receiving special advantages, typically through political lobbying.” Doesn’t what CESA says about themselves on LinkedIn clearly sound like advocacy, and thus fit the definition of a special interest group?

Like that or not,

  • CESA said in a post that left-leaning Facebook is one of their donors.
  • Their website says that “THE CLEAN ENERGY STATES ALLIANCE IS MANAGED BY CLEAN ENERGY GROUP.”
  • Influence Watch notes that the “Clean Energy Group” has as a major donor the “Kresge Foundation.”
  • The Kresge Foundation has ties to the old S.S. Kresge Company, which evolved into Kmart. The Kresge Foundation “organization now funds organizations that promote liberal and left-of-center issues,” specifying: “support causes such as illegal immigration, aggressive environmentalism, and race issues.”
  • Among the apparent ties to Warren Buffett is their mutual support for the left-leaning Tides nonprofit, which Buffett and George Soros have been the leading donors of for years. The Tides in turn supports MHAction, as regular readers know.

With that brief array of facts and evidence as a backdrop, here is what the Washington, D.C.-based Manufactured Housing Association for Regulatory Reform (MHARR) had to say about CESA in a press-release to MHProNews on 5.26.2021.

 

MainstreamMediaSpotlightsMHARR_LettersHUDDana WadeFHFA-MarkCalabriaManufacturedHousingAssocRegulatoryReformLogoMHProNews

Subject: MHARR NEWS ITEM — MHARR ISSUES STRONG WARNING AGAINST SOLAR ENERGY MANDATES FOR MANUFACTURED HOMES

FOR IMMEDIATE RELEASE                                                                     Contact: MHARR

(202) 783-4087

 

MHARR ISSUES STRONG WARNING AGAINST SOLAR

ENERGY MANDATES FOR MANUFACTURED HOMES

 

Washington, D.C., May 26, 2021 – The Manufactured Housing Association for Regulatory Reform (MHARR) has issued a strong warning to a special interest group against any effort to seek solar energy mandates for federally-regulated manufactured homes.

On May 4, 2021, the group – the “Clean Energy States Alliance” (CESA) – published a two-volume report specifically addressing the utilization of solar energy in manufactured homes as part of a “Scaling-Up Solar for Under-Resourced Communities” project supported by the U.S. Department of Energy (DOE). Not coincidentally, as MHARR has previously reported, DOE is under a federal court order to develop and adopt “energy efficiency” standards for manufactured homes pursuant to the so-called Energy Independence and Security Act of 2007 (EISA), by no later than February 14, 2022.

In its May 21, 2021 communication to CESA, (see, copy attached), MHARR states that while it has no objection to the voluntary utilization of solar power and solar power devices by manufactured homeowners as a matter of choice within their sole and exclusive discretion, or conversely, to manufactured home retailers and/or producers offering solar energy packages as an option for homebuyers who might wish to purchase such a system for a new home, it will aggressively oppose any effort to seek or promote any type of governmental mandate (under any guise) for the utilization of solar power or solar power devices in HUD Code manufactured homes as a primary energy source. This would similarly apply to any effort to seek or promote construction-related government mandates for frame, structural, or other components of new HUD Code manufactured homes related to solar power and/or devices.

Throughout its existence, MHARR has consistently opposed efforts by special interest groups to strip American consumers of their free choice to the full range of features and amenities that manufactured homes can offer with unparalleled affordability, and instead coerce them via legislation or regulation into costly “one-size-fits-all” approaches favored by the special interests. And nowhere in the current-day regulatory environment, is this a more pressing concern than with respect to energy and energy-related measures.

Put simply, it is – and should be – up to homebuyers, within their sole and exclusive judgment and discretion, to decide what type(s) of energy sources or devices they wish to use in their home, based on their own wants and desires, their own financial capabilities, and their own needs. As a federally-regulated industry, current laws are designed to foster and protect this type of free-choice for manufactured home purchasers, and MHARR is wholly dedicated to ensuring that these good laws are fully and faithfully followed in order to protect and advance the interests of HUD Code consumers, as well as the smaller businesses that constitute the traditional core of the HUD Code industry.

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.

— 30 —

Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: 
MHARR@MHARRPUBLICATIONS.COM
Website: manufacturedhousingassociation.org

 

Additional Information, MHProNews Analysis and Initial Commentary

As was alluded to the above, MHProNews reached out to Warren Leon, Executive Director of the Clean Energy States Alliance, and others at CESA. To Leon’s credit, he personally and promptly responded to our inquiries and follow-up messages several times.

The bulk of Leon’s first reply read as follows.

WarrenLeonPhotoCleanEnergyStatesAllianceLogoMHProNewsFactCheckAnalysis

QuoteMarkMHProNewsThanks for reaching out to us about the press release from MHARR that refers to the Clean Energy State Alliance’s recent report on Solar for Manufactured Homes. I have not seen that press release and would appreciate it if you could forward it to me.

I have enclosed below the press release that announced our report. It includes a link so that you can download it.

I obviously cannot comment on the MHARR press release, because I have not seen it, but let me make the following points:

  • Our report focuses primarily on existing manufactured homes rather than on new manufactured home construction.
  • The report does not advocate for a mandate requiring solar to be incorporated into new manufactured homes. In fact, the report does not even discuss or mention the possibility of such a federal mandate.
  • Although CESA is not advocating for a new mandate for solar in manufactured homes, we are interested in encouraging manufacturers of manufactured homes to produce some models that are capable of accommodating rooftop solar installations and to offer solar as an option.
  • Our report was developed with input from an advisory committee of experts. See https://cdn.cesa.org/wp-content/uploads/Solar-Advisory-Committee.pdf

Please let me know if you have any follow-up questions or there is any way in which I can be of assistance. Please send me your completed story when you publish it.

Thanks,

Warren

Warren Leon
Executive Director
Clean Energy States Alliance

##

 

Note that several of those in his list of “experts” Leon provided have financial ties, albeit via dark money channels, to Warren Buffett-funded organizations.

For instance.

  • One of the experts is from ROC USA, an MHI member that has ties to Clayton Homes and channel dark-money Buffett bucks.
  • Prosperity Now says: “Prosperity Now and four partners launched ROC USA.”
  • Influence Watch notes that related “NON-PROFITS” to Prosperity Now include the “National Manufactured Home Owners Association (NMHOA)” and the “The Indivisible Project (Indivisible).”
  • The Indivisible Project gets funding from the Tides, which gets millions in funding from Warren Buffett and other left-leaning mega-donors.
  • Indivisible, says the Capital Research Center (CRC) linked Influence Watch, was “created in late 2016 as a response to the election of President Donald Trump. The Indivisible Project was established to provide liberals a practical guide for “Resisting the Trump Agenda.””

Via a follow up message, MHProNews pressed Leon on ties to other groups. Our inquiry said in part that our questions are:

QuoteMarkMHProNewsnot about MHARR, we know their position. My question is who else in manufactured housing have you already engaged with on these topics? For instance:

  • Manufactured Housing Institute?
  • Next Step U.S.?
  • One or more of the Clayton Homes brands?
  • Prosperity Now?

…”

 

In response, Leon said:

 

QuoteMarkMHProNewsTony,

Thank you for sending this information [i.e. the MHARR press release, linked here and shown above]. Here are a few additional comments:

  • Let me reiterate that our report focused primarily on the existing housing stock, not on new construction. You can see our main recommendation about new manufactured homes on page 73 of volume 1 of our report.
  • We focused on solar, not on energy efficiency. Because we were not addressing energy efficiency, the report does not discuss the court order requiring DOE to develop and adopt energy efficiency standards.
  • We spoke to several people from Clayton in preparing the report and include quotes from them indicating that they have produced models for the California market that can support a rooftop solar installation.
  • I wouldn’t call CESA a “special interest group”. CESA is a nonprofit membership organization composed of public agencies, primarily state energy agencies.

Warren” …

 

Words have meaning. Words can be used sincerely and/or in a fashion that may fit the definition of spin, deception, or misdirection. It may be true in a technical sense that the CESA “report focused primarily on the existing housing stock…” It may also be technically true that “We focused on solar, not on energy efficiency.”

However, their report was sprinkled with photos of new or newer Clayton Homes and pictures of Clayton Homes in the factory being built. That at least points toward the notion of having promoting the use of solar in manufactured homes.

Additionally, their own report also references the phrase “energy efficiency” in manufactured homes 21 times in Volume 1 alone. The word “energy” is used about 164 times, per a word search of their document on 5.27.2021.

They then make this claim on page 10, with the italics in the original: manufactured homes housing stock is relatively energy inefficient. nearly half of these homes use electricity for heating/cooling systems and other energy needs. this means that they have a large electric load that could be served by solar generation.”

They have at least two footnoted references to the American Council for an Energy-Efficient Economy (ACEEE) in volume 1 of their solar pitch.

Those factoids noted, here is the reference Leon provided to Page 73.

“7. Support Efforts to Incorporate Solar into New Homes

As discussed in Chapter Three, the cost of making new manufactured homes solar ready is not large. And adding solar to a home in the factory is usually easier and cheaper than a later onsite installation. If the price of the PV installation is included in a mortgage, the transaction is easy for the customer and can even lead to cost savings from day one. States and utilities should consider outreach to home dealers and manufacturers, as well as offer modest subsidies for LMI customers to incentivize these types of installations. The purchasers of new homes are more likely to have moderate incomes than low ones, but it is still a demographic well worth reaching. If just one percent of the new manufactured homes produced each year were built with installed solar, it would be nearly 1,000 installations. Of course, a higher percentage of the new homes could be targeted.”

 

Additionally, CESA’s document makes this reference.

J. Gavin Mabe, director of engineering and technology for Clayton, states that Clayton has been producing models for ten years that are structurally able to support solar. However, those models are not available in all locations, and the company produces more of them in California than elsewhere. Mabe indicated that a solar-compatible home, with a disconnect for the inverter and either a truss with additional capacity or added blocking for a standard truss to support the weight of solar panels, adds approximately $500–$1,000 to the cost of a new home. 64 Clayton produces about 40 percent of all new manufactured homes.”

Those points will be even more important than may first seem to be the case to newer MHProNews readers.  Why? Because for whatever reason CESA published a market share claim about Clayton that is demonstrably not accurate, understating Clayton’s market share. That may be one of several pieces of evidence that Clayton’s agenda in this project is nuanced and subtle to the under-informed. Their market share is not 40 percent, it is about 50 percent. That’s a 25 percent error. What other errors are in their report?

 

MarketShareClaytonHomesSkylineChampionCavcoIndustriesStaisticalSurveysOctober2019MHProNews

 

So, in relatively rapid form, MHARR’s concerns about this are underscored by this deeper dive into CESA provided information. CESA’s experts include But there is more.

As was noted earlier in this report and analysis, Leon initially replied promptly several times. But suddenly, with this following follow up inquiry, Leon stopped replying at all. In the message to Warren Leon from MHProNews was the following.

Thanks, Warren. Any contact with MHI or Next Step US? You to them, or them to you? It is a pretty tight circle, once Clayton is involved. They have obvious ties to them, as well as Prosperity Now.

Do tell, thanks for the prompt turn around and added insights. I’ll look at page 73.”

 

Some 18 hours later, after a series of initially swift replies and follows ups, CESA and Leon have given no reply to the above.

 

That could be coincidental. But given that they had ducked the MHI inquiry in prior messages, it may suggest that for whatever reason, they have tried to obscure or avoid that connection. Yet, MHI was referenced in one of their footnotes.

Perhaps more importantly, Datacomp, which has several ties beyond membership to MHI, was referenced well over 100 times by CESA.

There may be some interesting – and potentially useful – insights from their federally funded research that has been paid for by taxpayer dollars. But some of that useful research may have been provided with an agenda in mind. For instance: from footnote #33  “A 2012 study by the AMERICAN COUNCIL for an Energy-Efficient Economy included an estimate that 22 percent of manufactured homes were older than 1976, but since then older homes have continued to be retired and new homes manufactured. See Jacob Talbot, Mobilizing Energy Efficiency in the Manufactured Homes Sector (American Council For An Energy-Efficient Economy, July 2012), p. 4, https://www.aceee.org/sites/default/files/ publications/researchreports/a124.pdf.

Now, that conflates terminology (i.e. pre-HUD Code mobile homes with post-HUD Code manufactured homes). But that noted, if true, 2012 research claimed then that 78 percent of all such factory-built homes are HUD Code manufactured homes, and only 22 percent were mobile homes. That share of the market, quite correctly, continues to shift in favor of more manufactured homes vs. old mobile homes.

That data point actually cuts against some of the energy efficiency arguments. Additionally, another point CESA made also paradoxically mitigates against using solar in existing manufactured homes. It was Mabe speaking for Clayton that obliquely made that point. Namely, that “states that Clayton has been producing models for ten years that are structurally able to support solar.” Part of how manufactured housing maintains affordability is by providing sufficient structural integrity for the purposes and design intended, without overbuilding. A home has to be designed or retrofitted to receive an array of post-construction add-ons. Those add-ons could be solar, a carport, garage, whatever. Manufacturers specifically advise customers not to do add-ons unless they have checked first.

  • Sara Birmingham, Senior Director, State Affairs, Solar Energy Industries Association;
  • Melanie Santiago-Mosier Director of Access and Equity Program Vote Solar;
  • and Miguel Yanez, Project Associate, Environmental and Energy Study Institute are just a few examples of the “experts” that CESA themselves listed.
  • Thus, the CESA solar manufactured homes project do represent the definition that fits the term “special interest groups,” in contrast to Leon’s denial to MHProNews.

The points and takeaways are many. Some of the more obvious ones, in no particular order of importance, are the following.

  • MHARR was correct to wave the warning flag and advise CESA to be cautious in pursing mandator installations of solar on new manufactured homes. Why?

As an email to Leon said in part:

 

QuoteMarkMHProNews“…while MHARR is an advertiser, we do not speak for MHARR, only ourselves.

There have been several front and back door efforts for several years to mandate standards on new manufactured homes that would effectively drive up costs and “price out” significant numbers of potential buyers, per periodic NAHB “priced out” reports and updates. If MHARR is inviting direct engagement, I’d say that would be prudent.

My question then is not about MHARR, we know their position. My question is who else in manufactured housing have you already engaged with on these topics? For instance:

  • Manufactured Housing Institute?
  • Next Step U.S.?
  • One or more of the Clayton Homes brands?
  • Prosperity Now?

There are others, but that gives you a sense of the type of insight I’m looking for to frame a report. Another prompt turn around is valued.”

 

Entirely separate from MHARR, MHProNews reported in February 202o the following.

 

SierraClubDeptEnergyEELegalInstituteLogoWarrenBuffettMichaelBloombergPhotoManufacturedHomeProNews
https://www.manufacturedhomepronews.com/masthead/energy-environment-institute-big-donors-conflicts-warren-buffett-mike-bloomberg-undermine-manufactured-housing-via-sierra-club-lawsuit/

 

As MHProNews reported, it was pressure from MHARR and added heat from MHProNews reporting that caused MHI to do a u-turn on their prior push for more costly manufactured housing with higher energy mandates. Those mandates would have priced hundreds of thousands of potential buyers out, per NAHB – hardly a pro-manufactured housing source.

 

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

 

It isn’t just energy costs that Clayton-backed MHI has pushed problematic and more costly forms of HUD Code housing. The fiasco known as CrossModTM is another example.

 

Todd M. Richardson HUD, Builders, NAHB, Innovative Housing Showcase, Operation Breakthrough – Systematic Aristotle Thomistic Testing – James Schmitz Claims of Sabotaging Monopolies, HUD PDR Analysis

 

While many more points could be made, one relevant bottom line conclusion is this. MHARR is correct in saying that consumers should have the right to choose. They should be allowed to select between higher energy standards, solar, or whatever.

But each of these are arguably examples of the Buffett-moat at work. By making manufactured housing more costly or complex, the larger firms can handle that easier than smaller independents. Put differently, this is by accident or design a tool of consolidation in several respects spelled out in the linked reports and those that flow from them.

As is so often the case,

  • MHARR is protecting the interests of consumers and independents. By contrast, MHI’s recent email ‘news and updates’ to members is mute on this same issue. Once more the contrast is stark and clearly favors MHARR’s credibility and ‘big boy’ dominated MHI looks poor by comparison.
  • MHInsider, the MHI connected mouthpiece and purported bootlick publication, is attached to Datacomp. Datacomp is referenced so often that they obviously knew that this CESA work in process, was also silent on this in recent weeks. Doesn’t that obliquely make it clear that they too are on the side of the consolidators?

Given that Leon repeatedly ducked fairly innocent questions, that by itself raises questions about the true agenda behind these reports and who they are meant to serve. Some 21 hours after our last follow up, and noting that Leon invited follow up questions – there is no answer to several of those MHProNews inquiries shown above. Given the other items discovered and reported in the fact-check with analysis above of volume 1 and volume 2 of their taxpayer dollar supported pitch for solar manufactured homes, these only add to the concerns raised by MHARR. These flags are more than enough to merit the maxim, “caveat emptor.” “Let the buyer beware.”

MHProNews plans to monitor this issue and report as deemed necessary.

 

Market transition notice: While the layout of this business daily report has recently been modified, several elements of the basic concepts used previously are still the same. The headlines that follow below can be reviewed at a glance to save time while providing insights across the left-right media divide. Additionally, those headlines often provide clues as to possible ‘market moving’ reports.

 

Market Indicator Closing Summaries – Yahoo Finance Closing Tickers on MHProNews…

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Headlines from left-of-center CNN Business = evening of 5.26.2021

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Manufactured Housing Industry Investments Connected Closing Equities Tickers

Some of these firms invest in manufactured housing, or are otherwise connected, but may do other forms of investing or business activities too.

                          • NOTE: The chart below includes the Canadian stock, ECN, which purchased Triad Financial Services, a manufactured home industry lender
                          • NOTE: Drew changed its name and trading symbol at the end of 2016 to Lippert (LCII).
                          • NOTE: Deer Valley was largely taken private, say company insiders in a message to MHProNews on 12.15.2020, but there are still some outstanding shares of  the stock from the days when it was a publicly traded firm.  Thus, there is still periodic activity on DVLY.
ManufacturedHomeCommunitiesMobileHomeParksFactoriesProductionSuppliersFinanceStocksEquitiesClosingInfoYahooFinanceLogo5.26.2021a
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Per sources, the model shown above could be built as a HUD Code manufactured home or as a state-coded modular home. It was built years before the Manufactured Housing Institute (MHI) backed CrossModTM initiative. https://www.manufacturedhomepronews.com/march-2021-manufactured-housing-production-shipment-data-reveals-big-uptick-unpacking-the-facts-trends-evidence-news-analysis/
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Spring 2021

Berkshire Hathaway is the parent company to Clayton Homes, 21st Mortgage, Vanderbilt Mortgage and other factory built housing industry suppliers.
· LCI Industries, Patrick, UFPI, and LP each are suppliers to the manufactured housing industry, among others.
· AMG, CG, and TAVFX have investments in manufactured housing related businesses. For insights from third-parties and clients about our publisher, click here.
Enjoy these ‘blast from the past’ comments.

MHProNews. MHProNews – previously a.k.a. MHMSM.com – has celebrated our 11th year of publishing, and is starting our 12the year of serving the industry as the runaway most-read trade media.

TimWilliams21stMortgageCorpPriorMHIChairmanPraisingMHLivingNewsMHProNewsTonyKovach

Sample Kudos over the years…

It is now 11+ years and counting

Learn more about our evolutionary journey as the industry’s leading trade media, at the report linked below.

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Disclosure. MHProNews holds no positions in the stocks in this report.

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That’s a wrap on this installment of “News Through the Lens of Manufactured Homes and Factory-Built Housing” © where “We Provide, You Decide.” © (Affordable housing, manufactured homes, stock, investing, data, metrics, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) (See Related Reports, further below. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

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Notice, this photo was taken before several on Fox News took a turn away from more right-leaning reporting to more left-leaning or anti-Trump views.

By L.A. “Tony” Kovach – for MHLivingNews.com.
Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing. For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com. This article reflects the LLC’s and/or the writer’s position, and may or may not reflect the views of sponsors or supporters.

LATonyKovach.

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