Attached for your review and information is a copy of a communication sent to federal manufactured housing program Administrator Pamela Danner on November 12, 2014.
As was discussed in greater detail and approved at the MHARR Board of Directors meeting last week, this communication represents the initial step in an effort by MHARR to target and advance the roll-back of unwarranted and unnecessarily costly expansions of the HUD regulatory system. These expanded regulatory activities, many of which were initiated by the first program administrator, William Matchneer, III, have been reinvigorated and intensified even further since the current Administrator took office in March 2014.
Listed below are the seven items addressed in this communication with the program Administrator. It should be noted that two of these (i.e., items 6 and 7) involve critical issues where the Administrator has committed to taking the proper course of action under the 2000 reform law, which MHARR fully supports, encourages – and thanks the Administrator:
1. Unwarranted and discriminatory restrictions on the use of manufactured homes
2. Unnecessary and unnecessarily costly expanded in-plant regulation
3. Unnecessary and unnecessarily costly monthly IPIA Subpart I record inspections
4. Misuse of additional label fee revenues contrary to congressional intent
5. Unjustified retroactive Subpart I treatment for attached garages
6. Necessary regulatory reform for the separation of manufactured homes and RVs
7. Costly and discriminatory Department of Energy standards for HUD Code homes
All of this expanded regulatory activity indicates that the HUD program remains – and continues to progress — seriously “off-track,” veering away from the main focus and objectives of the 2000 reform law and necessitating an intensified effort to roll-back such activities.
We will provide you with relevant information as this effort unfolds.
copy of a communication sent to federal manufactured housing program Administrator Pamela Danner on November 12, 2014.
