As we have previously reported, the Manufactured Housing Consensus Committee (MHCC) will hold its second 2010 in-person meeting next week in Washington, D.C. Although currently not a voting member of the MHCC, MHARR representatives will attend the meeting and will provide information and input to the MHCC (with feedback to the industry) as appropriate.
Attached for your review and information, is a copy of the MHCC meeting agenda. We ask you to carefully review this documents and would specifically call to your attention three major issues.
First, the agenda includes no regulatory or enforcement matters. At a time when manufacturers are being bedeviled by an unprecedented expansion of in-plant regulation under a system that is literally being made up on the fly by HUD regulators, the program monitoring contractor and PIAs, not a single regulatory issue is being brought to the MHCC, showing that HUD is gradually trying to read all of section 604(b) (giving the MHCC authority to review new and changed program regulations and practices) out of the law.
Second, HUD will likely press for approval of its proposed federal fire sprinkler standard – misleadingly marketed as beneficial to the industry and backed by some of the industry’s larger manufacturers – which is actually totally unnecessary to trigger federal preemption. MHARR opposes any such standard as unnecessary, an extremely costly burden on consumers and will forcefully reiterate all of these points at the meeting.
Third, HUD continues to downgrade the role, authority and independence of the MHCC, having adopted – without MHCC consideration or consent – an MHCC charter and bylaws that give the Department nearly complete control of the MHCC, it procedures and its organization. Indeed, a respected consumer member of the MHCC cited these specific actions as a factor in his decision to resign from the MHCC earlier this week (See below). Again, MHARR will address this effort to turn the MHCC into a rubber-stamp clone of the defunct National Manufactured Housing Advisory Council at the meeting.
The above issues, among several others, will be addressed at MHARR’s upcoming Board of Directors meeting for specific decisions on actions to reverse current trends.
cc: Other Interested HUD Code Industry Manufacturers
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: mharrdg@aol.com
October 22, 2010
Mr. Karl Braun
Dear Karl:
I am sorry to get word that you are resigning from MHCC. The MHCC needs more members like you, not fewer. I personally appreciate the fact that without a preconceived agenda you, as a consumer member of the Committee, were always willing to listen to all sides of an issue and fairly consider the concerns of all program stakeholders. Sometimes we would agree on an issue and sometimes we would not, but I always knew that the concerns of the mostly medium and smaller manufacturers that MHARR represents would get a fair hearing from you.
That said, it is sad and ultimately to the detriment of the industry and consumers that the total industry has failed to protect the MHCC – as the centerpiece reform of the 2000 law – from being politicized, downgraded and stripped of much of its role, authority and independence by HUD regulators, as is reflected by your point about the MHCC bylaws and charter.
While MHARR has fought very hard, for years, to maintain the role of the MHCC and the integrity of its process against constant efforts by HUD to turn the MHCC into a clone of the toothless National Manufactured Housing Advisory Council that Congress disbanded in the 2000 law, our efforts have gotten little if any help from the rest of the industry. Nevertheless, we will continue and even intensify our efforts going forward, because we know how important the MHCC is and what Congress wanted and intended the MHCC to be.
Karl, all the best to you and yours for the future. Please know that your thoughts and insights will always be welcome here at MHARR.
All the best,
Danny
Danny D. Ghorbani, President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: mharrdg@aol.com
