The Washington, D.C. based national HUD Code manufactured home producers trade group, the Manufactured Housing Association for Regulatory Reform (MHARR), provided MHProNews with the following advanced copy of a press release. As the illustration below reflects, on the issue of the Department of Energy (DOE) pending energy regulations for manufactured housing, the modest sized producers group MHARR is revealed by the Google search below to be the “big dog” on the block. Entirely absent from the search below is the Manufactured Housing Institute (MHI), with its far larger budget and membership.
This MHARR release will be followed by additional information and analysis provided by MHProNews.
FOR IMMEDIATE RELEASE Contact: MHARR
(202) 783-4087
DOE PROPOSES BASELESS, EXTREME AND DISCRIMINATORY
ENERGY STANDARDS TARGETING MANUFACTURED HOMES
Washington, D.C., August 16, 2021 – The U.S. Department of Energy (DOE) has released a “prepublication” version of its second round of proposed “energy conservation” standards for HUD Code manufactured homes. (See, communication attached). Publication of the Supplemental Notice of Proposed Rulemaking in the Federal Register will follow. Earlier proposed DOE manufactured housing energy standards, put forward as an attempted “midnight regulation” during the waning days of the Obama Administration in 2016, were ultimately withdrawn by President Trump, following forceful opposition by MHARR.
The new proposed standards, based on the 2021 version of the International Energy Conservation Code (IECC) maintained by the International Code Council (ICC), are an outgrowth of the Energy Independence and Security Act of 2007, which essentially transferred responsibility for the development of manufactured housing energy standards from the U.S. Department of Housing and Urban Development (HUD) – which regulates all other aspects of manufactured housing construction and safety – to DOE, an agency heavily influenced by energy special interests, including extremist “climate” ideologues and product suppliers seeking to enhance sales via self-serving, abusive regulatory mandates.
MHARR, which spearheaded industry opposition to the 2016 proposed DOE manufactured housing energy standards developed through a contorted, illegitimate and deceitful DOE “negotiated rulemaking” process – which it alone opposed from day-one — will once again aggressively oppose these proposed standards, which are unnecessary, needlessly-costly, discriminatory, and would ultimately exclude millions of lower and moderate-income American families from the manufactured housing market, from homeownership altogether, and from all of the social and economic benefits of homeownership.
As MHARR has already demonstrated in preliminary “scoping” comments submitted to DOE on August 3, 2021, high-cost energy standards for manufactured homes are totally unnecessary, insofar as whole-home energy usage by manufactured homes and related consumer costs – as confirmed by the most recent U.S. government data – already fall well below energy operating costs for all other types of housing for all types of home energy sources tracked (i.e., fuel oil, electricity and natural gas). Furthermore, based on 2021 IECC purchase price and market-exclusion metrics developed by the National Association of Home Builders (NAHB), the IECC 2021-based DOE proposed standards could increase the cost of double-section manufactured homes by nearly $13,000.00 per home (without even considering the impact of testing, regulatory compliance and enforcement costs), while excluding nearly 7 million American families from the mainstream HUD Code manufactured housing market. This exclusionary impact, moreover — again as shown by U.S. government data — would fall most heavily on racial and other minorities who, according to a 2021 Consumer Financial Protection Bureau (CFPB) report, are “overrepresented” among potential chattel-based manufactured home borrowers already rejected at a rate disproportionately-higher than sit-built loan applicants. Such a racially-disparate impact would fly in the face of Biden Administration Executive Orders and policies mandating the consideration of “racial equity” and “economic justice” in all such matters.
Even worse, the new energy standards, as required by EISA, would become progressively more stringent and costly, excluding ever-growing numbers of Americans from the manufactured housing market and from homeownership altogether, while undermining the purchase price affordability of manufactured housing, in direct violation of existing federal law. Furthermore, while proponents of excessive and destructive energy regulation seek to attribute alleged “life-cycle” cost savings to such standards, the fact of the matter is that there are – and will be – no “life-cycle” savings of any kind (and, indeed, no “life-cycle” at all) for the millions of Americans totally excluded from the market by exploding purchase price increases attributable to the new “standards.” Any claim of “life-cycle” cost savings for this massive cohort of excluded consumers would be fraudulent and deceitful.
Written comments in response to the DOE proposed rule will be due within 60 days of the proposal’s publication in the Federal Register. MHARR encourages all industry members and organizations to submit comments opposing these draconian and destructive proposed standards. MHARR’s comments, as usual, will be filed in advance of the [insert] deadline and will be available for reference or citation by other commenters.
In Washington, D.C., MHARR President and CEO, Mark Weiss, stated: “DOE’s proposed manufactured housing energy standards would slam the door shut on homeownership for millions of Americans, including millions of lower and moderate-income families and members of minority communities who rely on the affordability of mainstream manufactured housing the most. This harsh, cruel and needless attack by the Administration on hard-working American families – who already pay less for energy in manufactured homes than other types of homes – seeks to combat “climate change” on the backs of the working poor, denying them one of the fundamental basics of life, a decent home, while ‘woke’ climate elitists spew greenhouse pollutants from private jets, huge estates and energy-guzzling vehicles, among other things. With an affordable housing crisis already underway, needlessly putting homeownership beyond the reach of millions more Americans is not smart, is not legitimate and is morally indefensible. MHARR has – and will continue — to oppose this callous mandate through all available means.” ##
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.
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Additional Information, and More MHProNews Related Facts, Analysis
The roughly DOE’s 334-page document referred to by MHARR and the DOE proposed rulemaking plan for manufactured housing is linked here.
The DOE media statement associated with their hefty report that is also referenced by MHARR is shown below.
The U.S. Department of Energy (DOE) has issued a pre-publication Federal Register supplemental notice of proposed rulemaking (SNOPR) to establish energy conservation standards for manufactured housing pursuant to the Energy Independence and Security Act of 2007 (EISA). EISA directs DOE to base the standards on the latest version of the International Energy Conservation Code (IECC), which is currently the 2021 version. DOE also considered comments received during interagency consultation with the U.S. Department of Housing and Urban Development, as well as from stakeholders. DOE’s proposal includes a set of “tiered” standards based on the manufacturer’s retail list price for the manufactured home and incorporates the 2021 IECC-based standards for manufactured homes as required by EISA. DOE estimates the energy savings from the proposed rule to reach 2.32 quads over 30 years, which amounts to a reduction of 109 million metric tons of carbon dioxide emissions. DOE is welcoming comments from stakeholders on its proposed rule during the open comment period as well as at the public webinar.
- DOE will accept comments, data, and information regarding this SNOPR until 60 days after the notice has published in the Federal Register. DOE will send a follow-up email to announce the closing date once the notice has published.
- Interested persons may submit comments identified by docket number EERE-2009-BT-STD-0021, by email (Manufactured_Housing@ee.doe.gov)or Federal eRulemaking portal (http://www.regulations.gov).
- DOE will also hold a webinar to gather input from interested parties on Tuesday, September 28, 2021, from 11:00 a.m. to 4:00 p.m.
- Click hereto register for the webinar.
- Foreign Nationals interested in participating in this webinar, must be screened by DOE Headquarters Security prior to being granted access. Please email Washington@ee.doe.govto complete the necessary documentation at least two weeks prior to scheduled meeting date.
- Additional webinar registration information, participant instructions, and information about the capabilities available to webinar participants will be published on DOE’s website: https://energy.gov/eere/buildings/public-meetings-and-comment-deadlines
- To find out more information on the manufactured housing rulemaking, please visit: Manufactured Housing.
This email is part of an effort by DOE to notify all interested persons of recently issued Federal Register notices and other significant program developments under the Appliance and Equipment Standards Program. ##
MHProNews has previously noted that on the previous round of the DOE’s push for these damaging rules that would undermine access by potentially millions of potential manufactured home customers has been reported in the reports linked below. They include the arguably duplicitous support by the Manufactured Housing Institute (MHI) for these rules, until consistent hammering by MHARR, plus the Small Business Administration, George Washington University, MHProNews, and others finally caused MHI to pivot and relent on their previous stance.
MHI has not challenged the claim that they have been factually documented to use a method known as “paltering” that appears to say one thing, but when closely examined is a case of “deception and misdirection.” So, in pondering these prior reports, it is wise for MHI members and their state association affiliates to ignore their posturing via form letters, and focus on the obvious fact that Warren Buffett could have a secretary call Joe Biden and have this matter dealt with promptly. The fact that such has not occurred spells out the sobering reality of MHI’s so called advocacy.
The truth is hiding in plain sight. MHARR has been successful on this effort multiple times. The history reflects that MHI and its ‘big boy’ backers have routinely been on the wrong side of this issue, until MHARR and others force them to pivot.
To learn more, see the recent and related reports.
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By L.A. “Tony” Kovach – for MHProNews.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.
Connect on LinkedIn: http://www.linkedin.com/in/latonykovach
Related References:
The text/image boxes below are linked to other reports, which can be accessed by clicking on them.
