On May 9, 2022, the Manufactured Housing Association for Regulatory Reform (MHARR) filed an amicus – “friend of the court” – brief with the U.S. Supreme Court. The MHARR brief was filed in support of a coalition of some 10 states that support a petition filed by ten states, which is found below. The MHARR court filing appears on the SCOTUS (Supreme Court of the United States) public portal, which means that the Manufactured Housing Institute (MHI) was likely advised of this filing within hours of it going online, because MHI for years have touted that they pay for a service that tracks such activities. Following the MHARR news release to MHProNews is the actual brief. That is followed by additional information, and an MHProNews analysis in brief. Our Daily Business News market report and related content wraps up today’s MHProNews report.

 

 

MHARR FILES SUPREME COURT BRIEF TO

REINSTATE SOCIAL COST OF CARBON INJUNCTION

 

Washington, D.C., May 16, 2022 – In its continuing effort to either block or substantially modify a destructive, unnecessary and unnecessarily costly U.S. Department of Energy (DOE) manufactured housing energy standards rule, which is in its final stages, the Manufactured Housing Association for Regulatory Reform (MHARR), has filed an Amicus Curiae or “Friend of the Court” brief and related Motion for Leave (copy attached) with the United States Supreme Court.

MHARR’s filing is in support of a petition filed by ten states, seeking the reinstatement of a United States District Court injunction against the federal government’s use of the so-called “Social Cost of Carbon” (SCC) metric in connection with pending federal rulemaking activity. The nationwide injunction against reliance on the SCC metric in federal rulemaking was originally entered on February 11, 2022 by the United States District Court for the Western District of Louisiana, but was subsequently stayed by the U.S. Fifth Circuit Court of Appeals. The states’ Supreme Court Petition seeks a termination of that stay and a reinstatement of the injunction pending final determination of the federal government’s Fifth Circuit appeal.

MHARR’s brief addresses a key issue underlying the Fifth Circuit’s stay of the District Court preliminary injunction by showing, among other things, that the SCC metric has – and is — being relied-upon in the DOE manufactured housing energy standards rulemaking including, most particularly, DOE’s recently-published “final” Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act (NEPA) in support of its imminent manufactured housing energy standards rule. That rule, as MHARR has consistently maintained, and as is detailed in the brief, would add thousands of dollars to the retail cost of new manufactured homes and needlessly exclude millions of Americans from homeownership altogether.

Indeed, MHARR continues to assert that section 413 of the Energy Independence and Security Act of 2007 (EISA) — the basis for the DOE standard — has essentially been hijacked by “climate change” extremists and energy special interests to target the only segment of the housing industry that is federally-regulated and then extend such regulatory “overkill” to the rest of the housing industry. MHARR’s latest filing, therefore, is just the most recent in a longstanding effort to either stop or substantially modify DOE energy standards proposals that would crush the HUD Code market and undermine any hope of achieving the American Dream for millions of lower and moderate-income families. This stands in contrast with some in the industry, who have sought to compromise-with or otherwise accommodate DOE and/or its extremist supporters with dead-end technical proposals and inconsequential legislative activity.

MHARR’s brief accordingly, asks the Supreme Court to vacate the stay entered by the Fifth Circuit Court of Appeals and thereby reinstate the injunction entered by the District Court pending the resolution of the Fifth Circuit appeal. By taking this action, MHARR is fulfilling its pledge to oppose the discriminatory and destructive pending DOE manufactured housing energy rule by all reasonable means.

The DOE rule, based on DOE’s own cost estimates, which do not include regulatory compliance and enforcement costs and are, therefore, necessarily incomplete, would needlessly harm millions of lower and moderate-income Americans. Allowing that rule to go into effect without aggressive opposition would cause irreparable harm to the industry’s consumers.  It would also reward DOE for its deceitful and duplicitous conduct throughout the rulemaking process, including but not limited to its sham “negotiated rulemaking” and, more recently, its “bait and switch” in jettisoning — after the conclusion of all public comment — its “tiered” standards approach to allegedly limit disastrous cost impacts on the industry’s lowest-income purchasers.

MHARR, therefore, will continue to adamantly oppose the impending DOE rule. In that regard, it is important to note that regardless of the outcome of the current Supreme Court appeal, the industry would still have the opportunity and, indeed, the obligation, to seek legal relief specifically targeting the DOE manufactured housing energy rule at an appropriate time of its choosing.

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 —

The Supreme Court of the United States (SCOTUS) Brief filed by attorneys for MHARR is as follows. Blank spaces are in the original, likely for pagination purposes. The segments of the document are often requirements for such filings. The PDF of the SCOTUS filing below is at this link here. Note that the PDF version is the ‘definitive’ version of this document, as WordPress (the backbone to MHProNews’ publishing infrastructure) may inadvertently change spacing, and other formatting details.  That disclaimer noted, the text of the SCOTUS filing of the MHARR amicus brief is as follows.

 

No. 21A658

_________________________________________________

IN THE

SUPREME COURT OF THE UNITED STATES __________

STATE OF LOUISIANA, et al.,

Applicants,

v.

JOSEPH R. BIDEN, JR., in his official capacity as

President of the United States, et al.,

Respondents.    

___________                                                                               

ON APPLICATION TO VACATE AN ORDER OF

THE UNITED STATES COURT OF APPEALS FOR

THE FIFTH CIRCUIT STAYING AN INJUNCTION

ISSUED BY THE UNITED STATES DISTRICT

COURT FOR THE WESTERN DISTRICT OF

LOUISIANA PENDING APPEAL

____________

MOTION FOR LEAVE TO FILE AND BRIEF OF

MANUFACTURED HOUSING ASSOCIATION

FOR REGULATORY REFORM AS AMICUS

CURIAE IN SUPPORT OF APPLICANTS

_____________

 

1. SCOTT NEWTON

BAKER DONELSON BEARMAN

CALDWELL & BERKOWITZ, PC

100 Vision Drive, Suite 400

Jackson, Mississippi 39211

(601) 351-2400 snewton@bakerdonelson.com  MOTION FOR LEAVE TO FILE

BRIEF AS AMICUS CURIAE

 

 Pursuant to Supreme Court Rule 37.2(b), the Manufactured Housing Association for Regulatory Reform (MHARR) moves for leave to file the accompanying brief in support of the application to vacate the United States Court of Appeals for the Fifth Circuit’s stay pending appeal of the preliminary injunction entered by the United States District Court for the Western District of Louisiana.

Due to the Court’s expedited briefing schedule, MHARR asks for leave without the regularly required 10 days’ advance notice to the parties, normally required by Supreme Court Rule 37.2(a).  Applicants consent to the filing of MHARR’s brief.  Respondents advised that MHARR should refer its request to the Court for action.

 

MHARR is a Washington, D.C.-based national trade organization representing the views and interests of producers of manufactured housing regulated by the United States Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974 (1974 act), as amended by the Manufactured Housing

Improvement Act of 2000 (42 U.S.C. 5401, et seq.) (2000 reform law), and subject to energy-related regulation by the United States Department of Energy (DOE) pursuant to Section 413 of the Energy Independence and Security Act of 2007 (EISA).

MHARR was founded in 1985 and its members include independent producers of manufactured housing from all regions of the United States.

 

MHARR seeks leave to file the accompanying brief in support of the application because Executive Order 13990 and the Social Cost of Greenhouse Gas Estimates, which are being used by DOE in rulemaking, will impose increased costs for MHARR’s members and, as a direct result, low and moderate-income consumers of manufactured homes.

 

MHARR therefore respectfully requests leave of Court to file the accompanying brief, which it believes will aid the Court in ruling on the application.

 

Respectfully submitted,

 

1.                              SCOTT NEWTON

BAKER DONELSON BEARMAN

CALDWELL & BERKOWITZ, PC    100 Vision Drive, Suite 400

Jackson, Mississippi 39211                         (601) 351-2400

snewton@bakerdonelson.com

 

                                     Counsel for Manufactured 

                                          Housing Association for  

                         Regulatory Reform

 

Dated:  May 9, 2022

 

No. 21A658

_________________________________________________

IN THE

SUPREME COURT OF THE UNITED STATES __________

STATE OF LOUISIANA, et al.,

Applicants,

JOSEPH R. BIDEN, JR., in his official capacity as

President of the United States, et al.,

Respondents.    

___________                                                                               

ON APPLICATION TO VACATE AN ORDER OF

THE UNITED STATES COURT OF APPEALS FOR

THE FIFTH CIRCUIT STAYING AN INJUNCTION

ISSUED BY THE UNITED STATES DISTRICT

COURT FOR THE WESTERN DISTRICT OF

LOUISIANA PENDING APPEAL

____________

BRIEF OF MANUFACTURED HOUSING

ASSOCIATION FOR REGULATORY REFORM

AS AMICUS CURIAE IN SUPPORT OF

APPLICANTS

____________

 

1. SCOTT NEWTON

BAKER DONELSON BEARMAN

CALDWELL & BERKOWITZ, PC

100 Vision Drive, Suite 400

Jackson, Mississippi 39211

(601) 351-2400 snewton@bakerdonelson.com

 

TABLE OF CONTENTS

PAGE

TABLE OF AUTHORITIES ……………………………….. ii

 

INTEREST OF AMICUS CURIAE ……………………… 1

 

ARGUMENT …………………………………………………….. 3

 

1. DOE has and is Currently Using the SC-GHG

Estimates in Rulemaking …………………………. 3

 

1. DOE’s Proposed            Energy            Conservation Standards for Manufactured Housing, Which

Rely on the SC-GHG Estimates, Will Impose Increased Costs for MHARR’s Members and, as a Direct Result, Low and Moderate-Income Consumers of Manufactured Homes ………….. 8

 

CONCLUSION ………………………………………………… 15

TABLE OF AUTHORITIES

PAGE(S)

Cases  

Bob Marshall Alliance v. Hodel,

852 F.2d 1223 (9th Cir. 1988) ………………………… 10 Calvert Cliffs’ Coordinating Committee, Inc. v.

United States Atomic Energy Commission,

449 F.2d 1109 (D.C. Cir. 1971) …………….. 10, 11, 13 Children’s Hospital of the King’s Daughters, Inc. v.

Azar, 896 F.3d 615 (4th Cir. 2018) ……………………. 5

Louisiana v. Biden,

No. 2:21-cv-01074 (W.D. La. Feb. 11, 2022) ………. 7

Sierra Club v. Sigler,

695 F.2d 957 (5th Cir. 1983) ……………………………. 8

United States v. Riccardi,

989 F.3d 476 (6th Cir. 2021) ……………………………. 5

Executive Orders and Statutes

Executive Order 12866 …………………………………… 8, 9

Executive Order 13990 ………………………………………. 1

5 U.S.C. 601 ………………………………………………………. 1

42 U.S.C. 5401 …………………………………………………… 1

42 U.S.C. 5402(6) ………………………………………………. 1

Other

Consumer Financial Protection Bureau’s Office of

Research and Mortgage Markets, Manufactured Housing Finance – New Insights from the Home

Mortgage Disclosure Act Data (May 2021) ….. 13-14

Energy Conservation Program: Energy Conservation

Standards for Manufactured Housing, Notice of

Data Availability (October 26, 2021) …….. 12, 14-15

Energy Conservation Program: Energy Conservation

Standards for Manufactured Housing, Supplemental Notice of Proposed Rulemaking

(August 26, 2021) ………………………….. 3-5, 11-12, 14

Final Environmental Impact Statement for Proposed Energy Conservation Standards for Manufactured

Housing (April 2022) ………………………………. 5-8, 11

Politifact, HUD Secretary Says a Homeless Person

Costs Taxpayers $40,000 a year

(March 12, 2012) ………………………………………. 14-15

 

INTEREST OF AMICUS CURIAE¹

The Manufactured Housing Association for Regulatory Reform (MHARR) is a Washington, D.C. based national trade organization representing the views and interests of producers of manufactured housing regulated by the United States Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974 (1974 Act),² as amended by the National Manufactured Housing Improvement Act of 2000 (42 U.S.C. 5401, et seq.) (2000 reform law), and subject to energy-related regulation by the United States Department of Energy (DOE) pursuant to Section 413 of the Energy Independence and Security Act of 2007 (EISA).  MHARR was founded in 1985 and its members include independent producers of manufactured housing from all regions of the United States.^[1]

 

• No counsel for any party authored this brief in any part, and no person or entity other than amicus made a monetary contribution to fund its preparation or submission.

 

• The 1974 Act defines a “manufactured home” as “a structure, transportable in one or more sections, which, in travelling mode, is eight body feet or more in width or forty body feet or more in length, or, when erected on site, is three hundred twenty or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes plumbing, heating, air conditioning and electrical systems contained therein . . . .” 42 U.S.C. 5402(6).

 

MHARR has an interest in the application because Executive Order 13990 (EO13990) and the Social Cost of Greenhouse Gas Estimates (SC-GHG Estimates), which are being used by DOE in rulemaking, will impose increased costs on MHARR’s members and, as a direct result, low and moderate-income consumers of manufactured homes.

ARGUMENT

I.             DOE has and is Currently Using the SC GHG  Estimates in Rulemaking.

 

            In response to Applicants’ challenge of

EO13990 and the SC-GHG Estimates in the United

States District Court for the Western District of

Louisiana, Respondents argued that the SC-GHG

Estimates were not being used and, if they were, the SC-GHG Estimates had no material impact on any regulatory process.  In other words, Respondents claimed that the SC-GHG Estimates—if used—were for only informational purposes despite EO13990’s use directive.^[2]   Considering, however, that DOE has and is currently using the SC-GHG Estimates in rulemaking, Respondents’ previous representations are verifiably false.

 

On August 26, 2021, DOE published a

Supplemental Notice of Proposed Rulemaking (SNPR) in the Federal Register, to establish for the first time, “Energy Conservation Standards for Manufactured Housing” pursuant to Section 413 of the Energy Independence and Security Act of 2007 (EISA).  In the SNPR, DOE provides that it

“estimates the monetized benefits of the reduction in emissions of CO₂, CH₄, and N₂O by using a measure of the social cost . . . of each pollutant (e.g., SC-CO₂).”

See     Energy     Conservation          Program:         Energy

Conservation Standards for Manufactured Housing,

 

Supplemental Notice of Proposed Rulemaking, https://www.govinfo.gov/content/pkg/FR-2021-0826/pdf/2021-17684.pdf (August 26, 2021). DOE writes the following:

 

DOE used the estimates for the social cost of greenhouse gases (SC-GHG) from the most recent update of the Interagency Working Group on Social

Cost of Greenhouse Gases, United States Government (IWG) working group from ‘‘Technical Support Document: Social Cost of Carbon,

Methane, and Nitrous Oxide Interim

Estimates under Executive Order 13990.’’ (February 2021 TSD). DOE has determined that the estimates from the February 2021 TSD, as described more [fully] below, are based upon sound analysis and provide well founded estimates for DOE’s analysis of the impacts of the reductions of emissions anticipated from the proposed rule.

The SC-GHG estimates in the February 2021 TSD are interim values developed under Executive Order (E.O.) 13990 for use until an improved estimate of the impacts of climate change can be developed based on the best available science and economics. The SC-GHG estimates used in this analysis were developed over many years, using a transparent process, peer-reviewed methodologies, the best science available at the time of that process, and with input from the public.⁵

Id. at 47815 (emphasis added).

On April 4, 2022, DOE published its final environmental impact statement (EIS) analyzing the impacts related to DOE’s proposed energy conservation standards for manufactured homes. See Final Environmental Impact Statement for Proposed Energy Conservation Standards for Manufactured

Housing, https://www.energy.gov/sites/default/files/20 22-04/final-eis-0550-energy-conservatin-standardsmanufactured-housing-2022-04.pdf (April 2022).  In the EIS, DOE writes the following related to greenhouse gases (GHG):

With regard to GHGs, current emissions provided a baseline against which reductions associated with the proposed energy conservation standards

 

⁵ Notably, DOE does not assert that the SC-GHG Estimates were subject to public comment, which is required given that the SC-GHG Estimates constitute a “legislative rule” in that EO13990 directs agencies—such as DOE—to employ specific numerical values (i.e., the SC-GHG Estimates) in rulemaking.  See United States v. Riccardi, 989 F.3d 476, 487 (6th Cir. 2021) (action dictating a “specific numeric amount” is a legislative rule) (collecting cases); see also Children’s Hospital of the King’s Daughters, Inc. v. Azar, 896 F.3d 615, 623 (4th Cir. 2018) (concluding that “[b]ecause the policy amounts to a legislative rule, the APA required that agency promulgate the policy through notice-and-comment rulemaking”).  Rather than comply with the law, EO13990 pulled an “end around” that resulted in the issuance of the SC-GHG Estimates despite no (1) statutory authority, (2) notice-and-comment procedures, or

(3) pre-enforcement judicial review.

can be compared.  To support such an analysis, the benefits of reducing GHG emissions can be monetized by using a measure of the social cost (SC), which represents the monetary value of the net harm to society associated with a marginal increase in GHG-specific emissions in a given year, or the benefit of avoiding that increase. Estimates of the social costs of greenhouse gases (SC-GHG) provide an aggregated monetary measure (in current U.S. dollars) of the future stream of damages associated with an incremental metric ton of emissions and associated physical damages (e.g., temperature increase, sea level rise, infrastructure damage, health effects) in a particular year. In this way, SC-GHG estimates can help the public and Federal agencies understand or contextualize the potential impacts of GHG emissions and, along with information on other potential environmental impacts, can inform a comparison of alternatives.

In principle, the SC-GHG includes the value of all climate change impacts, including (but not limited to) changes in net agricultural productivity, human health effects, property damage from increased flood risk and natural disasters, disruption of energy systems, risk of conflict, environmental migration, and the value of ecosystem services. The SC-GHG reflects the societal value of reducing emissions of the gas in question by one metric ton. The Interagency Working Group on the

Social Cost of Greenhouse Gases (IWG SCGHG 2021) has published estimates of the global social benefits of CO2, CH4, and N2O reductions in its

Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive Order 13990. The values used in DOE’s analyses to estimate SC-

CO2, SC-CH4, and SC-N2O were generated using the values in that report, which represents the latest interagency update.

The SC-GHG estimates used to contextualize potential impacts of DOE’s proposal are presented in

Figures 3.2-2, 3.2-3, and 3.2-4.

 

Id. at 3-13 through 3-14 (emphasis added).  DOE also specifically notes in the EIS that “[o]n March 16, 2022, the Fifth Circuit Court of Appeals (No. 2230087) granted the federal government’s emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in Louisiana v. Biden, No. 21-cv-1074-JDC-KK (W.D. La.).”  See Id. at n. 40.  The DOE thereafter writes that it “will revert to its approach prior to the injunction and present monetized benefits where appropriate and

permissible under law.”  Id. (emphasis added).⁶

 

Considering the foregoing, DOE, contrary to Respondents’ previous representations, has and is currently      using the SC-GHG       Estimates     in rulemaking.

 

1. DOE’s Proposed Energy Conservation      Standards for Manufactured Housing, Which Rely on the SC-GHG Estimates,

          Will     Impose      Increased Costs             for

 MHARR’s  Members and, as a Direct  Result, Low and Moderate-Income  Consumers of Manufactured Homes.

In support of the application, Applicants argue that the SC-GHG Estimates, by design, “drive up the cost side of every regulatory action even touching greenhouse gas emissions” and specifically mention “the design of manufactured housing” as a

 

⁶ DOE’s use of the SC-GHG Estimates to, in its words, “present monetized benefits,” clearly reflects—contrary to Respondents’ claim—that the SC-GHG Estimates are not merely for informational purposes but are playing a material part in federal agency decision-making.  See Sierra Club v. Sigler, 695 F.2d 957, n. 16 (5th Cir. 1983) (cost-benefit analysis “has become a common tool in legislative and administrative decision[-]making”) (emphasis added); see also Executive Order 12866 at Section I(b)(6) (“Each agency shall assess both the costs and the benefits of the intended regulation and, recognizing that some costs benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned determination that the benefits of the intended regulation justify its costs.”).

sector that will experience “new hidden costs.”  See Application to Vacate at 18.  The argument is absolutely correct.  DOE’s proposed energy conservation standards for manufactured housing, which rely on the SC-GHG Estimates, will impose increased costs for MHARR’s members and, as a direct result, low and moderate-income consumers of manufactured homes.  So, there is a real “social cost” associated with the SC-GHG Estimates and, absent court intervention, it will be disproportionately paid by millions of America’s working poor and minorities by denying them access to affordable housing.^[3]

In developing the proposed energy conservation standards for new manufactured housing, DOE considered three approaches that are referred to as “action alternatives” in the EIS.  See Final Environmental Impact Statement for Proposed Energy Conservation Standards for Manufactured

Housing, https://www.energy.gov/sites/default/files/20 22-04/final-eis-0550-energy-conservatin-standardsmanufactured-housing-2022-04.pdf (April 2022) at 21.  Additionally, DOE purportedly evaluated “the alternative of taking no action” only in accordance with National Environmental Policy Act (NEPA).  Id.^[4]    These “action alternatives” are described by DOE as follows:

 

• Alternative A: Tiered standards based on price.  Tier 1 standards would apply to homes at or below a manufacturer’s retail list price threshold; Tier 2 standards would apply to homes priced above the threshold.

 

• Alternative B: Tiered standards based on size. Tier 1 standards would apply to single-section homes; Tier 2 standards would apply to multi-section homes.

 

• Alternative C: Untiered standards. These standards would apply to all homes regardless of price or size.

 

• Alternative D: No action. No change from the existing HUD Code.

 

Id.  Under “action alternatives” A, B, and C, DOE would establish energy conservation standards that are specific to, inter alia, the following climate zones:

alternatives can be compared.”  See id. at 2-1.  NEPA requires that federal agencies consider alternatives to recommended actions, including “no action” at all.  See Bob Marshall Alliance v. Hodel, 852 F.2d 1223, 1228 (9th Cir. 1988) (citing Calvert Cliffs’ Coordinating Committee, Inc. v. United States Atomic Energy Commission, 449 F.2d 1109, 1114 (D.C. Cir. 1971)).  Compared to the other alternatives, DOE appears to have given little, if any, actual consideration to Alternative D, which, as noted infra at n. 9, is admittedly the only approach that does not result in a cost increase for purchasers of manufactured homes.

Id.  While DOE allegedly evaluated all of the alternative actions, it has identified Alternative C (the untiered standards) as the preferred alternative.

See id. at C-6.⁹ Assuming DOE adopts Alternative C, MHARR’s members and consequently low and moderate-income consumers of manufactured homes will be directly harmed by way of price increases that will exclude millions of households from the

⁹ Alternative A and B would likewise result in cost increases for MHARR’s members and low and moderate-income consumers of manufactured homes.  The cost increases would only be less depending on the purchase price of the manufactured home (under Alternative A) or whether the manufactured home is a single section or double section (under Alternative B).  Only under Alternative D (no action) would the purchase price not increase for manufacture homes.  See Final Environmental Impact Statement for Proposed Energy Conservation Standards                for      Manufactured                              Housing, consequences of the proposed energy conservation standards, which, again, rely on the SC-GHG Estimates, including (but not limited to) a higher degree of homelessness in the United States.  In this regard, HUD has previously estimated the cost of homelessness to taxpayers to be approximately $40,000 per homeless person, per year.  See Politifact, HUD Secretary Says a Homeless Person Costs Taxpayers $40,000 a Year, https://www.politifact.com/factchecks/2012/mar/12/shaundonovan/hud-secretary-says-homeless-person-costs-taxpayers/ (March 12, 2012).

https://www.energy.gov/sites/default/files/2022-04/final-eis0550-energy-conservatin-standards-manufactured-housing2022-04.pdf (April 2022) at 4-64 (noting that under Alternative D, “[t]he purchase price for manufacture homes would not increase because of energy conservation standards, and the availability and demand for manufactured homes would not decrease due to energy conservation standards”) (emphasis added).

 

manufactured housing market and thus from homeownership altogether.  Indeed, based on DOE’s August 26, 2021 Supplemental Notice of Proposed Rulemaking (SNPR) in the Federal Register, a consumer can expect the following purchase price increases for a manufactured home under Alternative C, depending on his or her climate zone:¹⁰

 

ZONE 1:	$4,143.00
ZONE 2:	$6,167.00
ZONE 3:	$5,839.00
NATIONAL AVERAGE	$5,289.00

 

 Based on the DOE’s October 26, 2021 Notice of Data Availability (NODA) in the Federal Register, a consumer can expect the following purchase price increases for a manufactured home under Alternative C, depending on his or her climate zone:^[5]

¹⁰ The amounts calculated by DOE are attributable to the alleged retail level purchase price impact of the proposed standards themselves.  They do not include and do not attempt to estimate either: (1) the cost and purchase price impact of regulatory compliance costs resulting from the amended energy standards, including but not limited to costs of testing, enforcement and other regulatory compliance expenses; or (2) the increased cost of financing all such additional costs. Increased financing costs will fluctuate, but generally will be highest for lower-income/higher-risk borrowers.

 

ZONE 1:	$4,131.00
ZONE 2:	$6,149.00
ZONE 3:	$5,822.00
NATIONAL AVERAGE	$5,267.00

           

 Importantly, because of these crippling price increases, millions of low to moderate-income consumers will be unable to afford a manufactured home and presumably homeownership all together.  To be sure, as recently as August 2014, the National Association of Home Builders (NAHB) estimated that increasing the price of a single section manufactured home by $1,000 would “price out” 347,901 households.  NAHB further estimated that increasing the price of a double section manufactured home by $1,000 would “price out” 315,585 households.  Id.¹²  Applying these numbers

¹² This price increase will impact minority communities the hardest. May 2021 data published by the Consumer Financial Protection Bureau (CFPB) shows that “only a minority (27 percent) of consumers who applied for a loan to purchase a manufactured home succeeded in obtaining financing” and that 50 percent of chattel (i.e., manufactured home titled as personal property) purchase loan applications “were denied.” See Consumer Financial Protection Bureau’s Office of Research and Mortgage Markets, Manufactured Housing Finance – New Insights from the Home Mortgage Disclosure Act Data, https://files.consumerfinance.gov/f/documents/cfpb_manufactur ed-housing-finance-new-insights-hmda_report_2021-05.pdf (May 2021).  Moreover, the 50 percent rejection level for manufactured home personal property loans – representing nearly 80 percent of the entire manufactured housing new home market according to the United States Census Bureau statistics – disproportionately affected minority communities.  As noted by CFPB, “Black and African American borrowers are the only racial group that are . . . overrepresented in chattel lending compared to site-built.”  Id.  With “Black and African to the price increase imposed under Alternative C, the number of households that will be excluded from purchasing a manufactured home is staggering.

Based on DOE’s August 26, 2021 SNPR, the following number of households will be excluded from purchasing a manufacturing home (either single section or double section) based on the price increases imposed under Alternative C, depending on his or her climate zone:

 

                                 Single             Double

ZONE 1	895,497	1,306,640
ZONE 2	1,676,883	1,944,979
ZONE 3	1,620,871	1,841,533
NATIONAL AVERAGE	1,361,684	1,668,071

 

 Based on DOE’s October 26, 2021 NODA, the following number of households would be excluded from purchasing a manufacturing home (either single section or double section) based on the price increases imposed under Alternative C, depending on his or her climate zone:^[6]

American borrowers” already subject to disproportionately-high purchase loan rejection rates within the manufacturing housing market, purchase price increases will inevitably result in (1) even higher loan rejection rates for personal property loans; (2) even greater disproportion in loan rejection rates for minority communities and specifically Black and African Americans; and (3) a corresponding decrease in homeownership for minority communities and particularly Black and African Americans.

 

                                                                          Single                                                                                                  Double

ZONE 1	893,062	1,302,855
ZONE 2	1,672,012	1,939,302
ZONE 3	1,616,000	1,836,171
NATIONAL AVERAGE	1,357,510	1,661,133

 

Considering the foregoing, the proposed energy conservation standards for manufactured housing, which rely on the SC-GHG Estimates, will impose increased costs on MHARR’s members and, as a direct result, low and moderate-income consumers of manufactured homes.  Additionally, due to the increased costs, millions of consumers will be denied access to affordable housing.

 

CONCLUSION

 For the reasons set forth in the application and those stated herein, the Court should grant the application and vacate the United States Court of Appeals for the Fifth Circuit’s stay pending appeal of the preliminary injunction entered by the United States District Court for the Western District of Louisiana.

Respectfully submitted,

 

1.                              SCOTT NEWTON

BAKER DONELSON BEARMAN

CALDWELL & BERKOWITZ, PC    100 Vision Drive, Suite 400

Jackson, Mississippi 39211                         (601) 351-2400

snewton@bakerdonelson.com

 

                                     Counsel for Manufactured 

                                 Housing Association for                     Regulatory Reform

 

Dated:  May 9, 2022

[1] MHARR’s members include “small businesses” as defined by the United States Small Business Administration and “small entities” for purposes of the Regulatory Flexibility Act (5 U.S.C. 601, et seq.).

[2] It goes without saying that Respondents, which are the source of the SC-GHG Estimates, should know whether the SC-GHG Estimates are being used and, if so, in what way.

[3] MHARR does not necessarily dispute that there is a “cost of carbon.”  However, that cost—whatever it may be—should not be recouped in such a way that it disparately impacts low and moderate-income consumers.

[4] DOE notes that “[i]n accordance with NEPA, [it] is also evaluating the alternative of taking no action, which serves as the baseline against which potential consequences of the action

[5] See Energy Conservation Program: Energy Conservation Standards for Manufactured Housing, Notice of Data

Availability, https://www.govinfo.gov/content/pkg/FR-2021-1026/pdf/2021-23188.pdf (October 26, 2021).

[6] There will undoubtedly be societal and other “downstream”

Additional Information, More MHProNews Analysis and Commentary

First, to be balanced and objective in providing information related to this advancing DOE manufactured housing energy rule, the National Housing Conference (NHC), which reportedly has the Manufactured Housing Institute (MHI) as a member and which MHI has periodically bragged about NHC as being part of ‘their’ housing coalition, issued the following report on 5.16.2022.

“Last week, the Manufactured Housing Affordability and Energy Efficiency Act of 2022 was introduced into the House of Representatives by David Kustoff (R-TN) and Larry Bucshon (R-IN). The bill seeks to clarify the process and standards for rulemaking establishing standards for energy efficiency in manufactured housing. The bill would also mandate that the Department of Housing and Urban Development be more involved with discussions surrounding energy efficiency for manufactured homes.”

That factoid noted, this MHI backed initiative is not only apparently too little, too late, but it fails one of the most basic tests of smart legislative initiatives. Namely, there are no Democratic backers to the bill. Without Democratic support, and with a ‘green’ minded Joe Biden sitting in the Oval Office, the MHI bill is an obvious fig leaf they can and have used with their members as cover.

Here is how MHI described their own bill, as compared to how the NHC reported on that piece of legislation, which is all but assured of going nowhere.

Call for Action

Tell Your House Representative to Cosponsor H.R. 7651, “The Manufactured Housing Affordability and Energy Efficiency Act”

To date, almost 200 industry professionals have called on their House Representatives to cosponsor, H.R. 7651, “The Manufactured Housing Affordability and Energy Efficiency Act” introduced by Representative David Kustoff (R-TN), which ensures the Department of Energy’s (DOE) pending rule on new manufactured housing energy efficiency standards does not harm manufactured homeownership affordability.

As proposed, the DOE’s new manufactured home energy requirements are not cost-effective and will hurt the affordability of today’s manufactured homes. Because the proposed standards do not take into consideration current manufactured home construction methods and transportation requirements, the draft standards underestimate price increases and annual mortgage cost increases, as well as the number of potential manufactured homebuyers who will no longer qualify for a mortgage.

H.R. 7651, the “Manufactured Housing Affordability and Energy Efficiency Act,” addresses these concerns by requiring that before any new DOE energy standards can become effective or be enforced: (1) DOE must fully consult with HUD, (2) DOE must document that the rule is cost-effective based on the impact of homebuyer price and cost increases, (3) the standards must fully take into consideration manufactured housing construction methods and transportation requirements, and (4) the standards must be adopted by HUD as part of the HUD Code.

It is critical that your Representatives hear from all sectors of the manufactured housing industry about cosponsoring this bill. …” ##

Note: several MHI connected tips have been received from MHI connected sources. Look for an upcoming report on a different issue that MHI is trying to claim some accomplishment, but without offering what fits their own attorneys definition of measurable results.

Analysis & Commentary

Does MHI recall their multi-year and multi-million dollars spent in a failed effort to enact the Preserving Access to Manufactured Housing Act? Do their members recall the frank admission made by former VP Jason Boehlert to MHProNews that is quoted below? MHI’s former VP Boehlert proved to be accurate; their Preserving Access legislation never progressed into law. The reason this is relevant to their H.R. 7651, the “Manufactured Housing Affordability and Energy Efficiency Act” is similar. Democrats are in charge. the DOE push is supported by Democrats. It is utterly unlikely that enough Democrats would switch their belief in ‘going green’ to make this MHI-backed bill go anywhere beyond file 13.

Furthermore, given that thoughtful, rationale, and objective manufactured housing professionals and advocates should keep in mind various zoning, placement, and financing laws that are not being properly implemented. Even if by some miracle, if MHI could get this Johnny-come-lately effort passed into law while ‘green’ minded Democrats are in charge of the Congress and White House.

Let’s note that this amicus brief, as in any legal effort, is not guaranteed to be successful. But MHARR is clearly making the effort. Why didn’t MHI? Recall Nathan Smith’s pledge to MHI members about a decade ago to no longer allow problematic legislation and regulation to get past MHI? Just another admission of past errors, couple with another broken MHI promise?

But the key concerns with respect to MHI and this looming regulation are the behind-the-scenes as well as ‘in your face’ efforts by MHI to support the DOE effort. To see those insights, check out the reports linked below.

 

 

 

Whatever occurs on this DOE manufactured housing energy rule, MHI’s behavior on this topic has been methodically documented by MHProNews. For those considering legal action against MHI for falsely claiming to represent “all segments” of manufactured housing, these items could well provide useful to your plaintiff’s attorney(s).

 

Next up is our daily business news recap of yesterday evening’s market report, related left-right headlines, and manufactured housing connected equities.

The Business Daily Manufactured Home Industry Connected Stock Market Updates.  Plus, Market Moving Left leaning CNN and Right-leaning (Newsmax) Headlines Snapshot. While the layout of this daily business report has been evolving over time, several elements of the basic concepts used previously are still the same. For instance. 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’ news items.

 

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

Headlines from left-of-center CNN Business – from the evening of 5.16.2022

• The internet’s Wild West
• People gather outside the police tape at Tops Friendly Market at Jefferson Avenue and Riley Street on Sunday, May 15, 2022 in Buffalo, NY. The fatal shooting of 10 people at a grocery store in a historically Black neighborhood of Buffalo by a young white gunman is being investigated as a hate crime and an act of racially motivated violent extremism, according to federal officials.
• Buffalo massacre spotlights a hate-filled website where users post anonymously
• The Fed has a new plan to avoid recession: Party like it’s 1994
• The Fed’s slow response to inflation was a mistake, says ex-chair Ben Bernanke
• $5 gas could become widespread as prices hit another record
• 4 reasons the economy looks like it’s crumbling — and what to do about it
• Goldman Sachs gives top bankers unlimited vacation days
• JetBlue launches hostile takeover for Spirit
• McDonald’s is leaving Russia altogether
• Walmart has a new way to turn college grads into store managers
• Pizza has a delivery problem
• How early traumas can affect your relationship with money
• What shape might the next recession take?
• Why people hated shopping carts when they first came out
• Here’s what the Outback Steakhouse of the future looks like
• Traders work on the floor of the New York Stock Exchange (NYSE) in New York City, U.S., May 12, 2022.
• Stocks could fall a lot further
• A Boeing 737 Ryanair plane taking off at the Leonardo da Vinci airport in Fiumicino, Italy on October 11th, 2021.
• Ryanair CEO launches expletive-ridden tirade against Boeing
• A chef turns a piece of fried fish in the fryer as it gets cooked, at Captain’s Fish and Chip shop in Brighton on March 25, 2022. – Britain’s fish and chip shops have weathered the storm of Brexit and Covid, and are fighting the tide of rising inflation but thousands could be sunk by the war in Ukraine. At Captain’s in the seaside resort of Brighton, on England's south coast, owner Pam Sandhu is not one to normally complain. Yet the shelves of her large freezers are empty when they should be full of white fish ready to be dipped in batter and deep fried, then served to hungry customers with piping hot chips. “With the war in Ukraine, there’s no fish left, only a small amount,” she told AFP. “And prices have doubled since last year.”
• This iconic British meal survived WWII. Today’s war may kill it
• IN THE SKY
• A United Airlines plane departs behind a Boeing office building in Arlington, Virginia, U.S., on Thursday, May 5, 2022. Boeing Co. confirmed today that its Arlington campus just outside Washington will serve as the companys global headquarters. Photographer: Eric Lee/Bloomberg via Getty Images
• Boeing is losing the plane race. So it packed up and left for Washington
• Southwest is set to return to profitability
• After two years of losses, airlines expect record revenue
• Fatigue is starting to put safety at risk, pilots say
• Delta says hiking fares can help it turn a profit
• MEDIA NEWS
• WASHINGTON, DC – MAY 9: White House Press Secretary Jen Psaki speaks during the daily press briefing at the White House May 9, 2022 in Washington, DC. Psaki fielded a wide range of questions, including the Russian invasion of Ukraine, the Supreme Court and abortion, and inflation.
• Jen Psaki signs off: ‘Thank you for making me better’
• Slain journalist was ‘voice of Palestinian suffering’
• Disney avoids Netflix’s fate as subscriptions grow
• Tom Brady announced what he will do after he retires
• Three journalists killed in Mexico in past week

Headlines from right-of-center Newsmax 5.16.2022

• Supreme Court Limits How Illegals Can Appeal Deportation Rulings
• Guatemalan immigrants deported from the United States arrive on a ICE deportation flight in Guatemala City, Guatemala. The charter jet, carrying 135 deportees, arrived from Texas. (Getty Images)
• Russian Invasion of Ukraine
• Turkey: No to Sweden, Finland Joining NATO
• Ukraine Repairing Damaged Russian Tanks, Using Them in War
• Gorka: Putin Will Not Stop With Ukraine
• Russia Closely Following Progress of Finnish, Swedish NATO Bids: Kremlin
• Finland to Seek NATO Entry in ‘New Era’ Amid Russia’s War
• US Could Ratify Finnish NATO Membership Before August: Senate Republican Leader
• Russia Will Not ‘Simply Put Up With’ NATO’s Nordic Expansion
• McDonald’s to Exit Russia After 30 Years
• Flood Saves Ukrainian Village from Russian Occupation
• Britain Says Russia Has Lost a Third of Its Forces in Ukraine
• Ukrainian Official: Putin Now Aims for ‘Long Lasting War’
• NATO Assures Ukraine Open-Ended Military Support
• More Russian Invasion of Ukraine
• Newsmax TV
• Doug Mastriano: I’m Not ‘Too Extreme’ to Be Pa. Gov | video
• Oz: ‘Outsider Spending’ a Problem in Last Hours Before Primary | video
• Ronny Jackson: Dems Must Admit Biden Is Declining | video
• Texas AG Paxton: Trump Keeps Border in News | video
• Blackburn: SCOTUS Marshal ‘Very Close’ to Finding Leaker | video
• Tenney: ‘Reporting Problem’ at Issue in Buffalo Shootings | video
• Van Drew: I Support Ukraine, but Control Spending | video
• More Newsmax TV
• Newsfront
• US Can Waive Trucking Rules for Formula Deliveries If Needed: Buttigieg
• S. Transportation Secretary Pete Buttigieg said on Monday that his department can waive hours of service rules for truck drivers to deliver infant formula if needed…. [Full Story]
• Buffalo Shooting Suspect Planned to Continue Rampage Outside: Police
• The suspected gunman in the Buffalo, New York, supermarket shooting [Full Story]
• Related
• ‘Hero’ Guard, Shoppers Among Buffalo Shooting Victims
• Biden Urges Unity to Stem Racial Hate after Buffalo Shooting
• Gunman Who Killed 10 in NY Supermarket Attack Was on Authorities’ Radar
• Pelosi: Social Media Has ‘Some Responsibility’ for Buffalo Hate-Fueled Mass Shooting
• Taliban Dissolve Afghanistan’s Human Rights Commission, Other Key Bodies
• Taliban authorities in Afghanistan dissolved five key departments of [Full Story]
• Authorities: Hate Against Taiwanese Led to Church Attack
• A gunman in deadly attack at California church was Chinese immigrant [Full Story]
• First Durham Trial: Former Clinton Campaign Lawyer Sussmann’s Case Starts
• A lawyer who worked on Hillary Clinton’s 2016 presidential campaign [Full Story]
• What Happens if Iran Launches a Nuclear Strike on Israel or Egypt?
• What would happen if Iran gets – or already has – a nuclear weapon [Full Story] | Platinum Article
• Florida Gov. DeSantis Suggests State Will Take Over Disney’s Reedy Creek District
• Florida Gov. Ron DeSantis hinted Monday thestate might take [Full Story]
• SCOTUS Limits How Illegal Immigrants Can Appeal Deportation Rulings
• Illegal immigrants have only limited grounds to appeal deportation [Full Story]
• Judge: California’s Women on Boards Law Is Unconstitutional
• A Los Angeles judge has ruled that California’s landmark law [Full Story]
• Cotton’s Forthcoming Book Has Eyes on 2024
• Tom Cotton, R-Ark., is publishing a book about foreign policy [Full Story]
• Biden to Redeploy Troops to Somalia
• President Joe Biden is set to resend U.S. troops to fight the Islamic [Full Story]
• Trump Supports Rep. Cawthorn: ‘Give Madison a Second Chance’
• President Donald Trump is supporting embattled GOP lawmaker Madison [Full Story]
• Gallup: Americans Split on Mask Mandate for Flights
• When it comes to flying, Americans are split on whether the [Full Story]
• Survey: Nearly 90 Percent of Voters Want Companies to Remain Apolitical
• S. voters are inclined to stop buying andusing products of companies [Full Story]
• Incredible $89 Portable AC is Taking United States by Storm
• Incredible $89 Portable AC is Taking United States by Storm
• Arctos Portable AC
• CNBC Host to Buttigieg: Raising Corporate Tax Rates ‘Not How You’re Going to Solve Inflation’
• The Biden administration’s proposal to raise taxes on the wealthiest [Full Story]
• Liberal Speakers Dominate University Commencement Addresses: Report
• Progressive speakers will dominate the commencement addresses at [Full Story]
• Gorka: Putin Will Not Stop With Ukraine
• Disinformation is rife at a time of war. This is true in every [Full Story]
• Bernanke Warns US Could Experience ‘Stagflation’
• Former Federal Reserve chairman Ben Bernanke told The New York Times [Full Story]
• New Poll Shows Dr. Oz Takes Lead Over Barnette, McCormick
• A new poll released Sunday shows Trump-endorsed candidate Mehmet Oz [Full Story]
• Related
• Trump-Backed Dr. Oz Confident About Win Despite ‘Bigoted’ Attacks |video
• NATO Chief: ‘Ukraine Can Win This War’ Against Russia
• Ukraine can win the war against Russia, NATO Secretary-General Jens [Full Story]
• Ricketts: Nebraska Will ‘Do More to Protect Preborn Babies” If Roe Overturned
• If the Supreme Court overturns Roe v. Wade, Nebraska Gov. Pete [Full Story]
• Supreme Court Rules for Sen. Cruz in Campaign Finance Case
• The Supreme Court Monday sided with Republican Sen. Ted Cruz of Texas [Full Story]
• SEC Filing Indicates Trump Could Return to Twitter
• A new federal securities filing indicated that former President [Full Story]
• Elon Musk Praises Netflix for Telling Employees to Quit If They Don’t Like Content
• Billionaire Elon Musk praised Netflix for telling employees to quit [Full Story]
• Russia Seen Moving Nuclear Missiles Toward Finnish Border
• Russia has deployed nuclear missiles toward its border with Finland [Full Story]
• Ukrainian Band Kalush Orchestra Wins Eurovision Amid War
• Ukrainian band Kalush Orchestra won the Eurovision Song Contest, a [Full Story] | video
• White House Releases Plan to Increase Housing Supply
• The Biden administration on Monday announced a plan aimed at [Full Story]
• Uyghur County in China Has Highest Prison Rate in the World
• Nearly one in 25 people in a county in the Uyghur heartland of China [Full Story]
• Democrat Leaders Back Pro-life Cuellar to Keep House Majority
• Political strategists say that House Democrat leadership’s ardent [Full Story] | Platinum Article
• Biden: Time to ‘Fund the Police’
• S. President Joe Biden said on Sunday that police officers must [Full Story]
• Ukraine Repairing Damaged Russian Tanks, Using Them in War
• Ukrainian mechanics in Kharkiv have been repairing battle-damaged [Full Story]
• Removing Moles and Skin Tags Has Never Been Easier (Just Do This!)
• Trending Stories
• More Newsfront
• Finance
• McDonald’s to Exit Russia After 30 Years
• McDonald’s Corp. said on Monday it had initiated a process to sell its business in Russia after 30 years of operating its restaurants in the country, following Moscow’s invasion of Ukraine. In March, McDonald’s closed all its restaurants in Russia including its iconic Pushkin…… [Full Story]
• US Can Waive Trucking Rules for Formula Deliveries If Needed: Buttigieg
• RPT-JPMorgan’s Dimon Faces Shareholder Advisory Vote on $52.6M Retention Award
• JetBlue Launches Hostile Takeover Bid for Spirit Airlines
• FDA Chief Califf: Agency Likely to OK Abbott’s Baby Formula Plant Reopening
• More Finance
• Health
• Biden Administration Considers Rationing COVID Vaccines Amid Funding Impasse
• Biden administration officials have discussed deep cuts to their COVID-19 operation as doubts grow about Congress’ willingness to fund related programs, Politico reported…. [Full Story]
• US Considers Importing Baby Formula, Re-Opening Plant, Amid Nationwide Shortage
• Planning a COVID-Safe Event
• Living Near Wildfires Linked to Increased Cancer Risk
• Flesh-Eating Bacteria a Hazard of Summer Swimming: How to Protect Yourself

MHProNews has pioneered in our profession several reporting elements that keep our regular and attentive readers as arguably the best informed in the manufactured housing industry. Among the items shared after ‘every business day’ (when markets are open) is our left-right headline recap summary. At a glance in two to three minutes, key ‘market moving’ news items are covered from left-of-center CNN Business and right-of-center Newsmax. “We Provide, You Decide.” ^© Additionally, MHProNews provides expert commentary and analysis on the issues that others can’t or won’t cover that help explain why manufactured housing has been underperforming during the Berkshire era while an affordable housing crisis and hundreds of thousands of homeless in America rages on. These are “Industry News, Tips, and Views Pros Can Use” ^© features and others made and kept us the runaway #1 in manufactured housing trade publisher for a dozen years and counting. 

 

Manufactured Housing Industry Investments Connected Equities Closing 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.

Manufactured Home Communities (a.k.a. ‘Mobile Home Parks’ – SIC) – Exploring UMH Properties; Fellow Manufactured Housing Institute Member Yes! Communities Suits and Settlements; plus MH Markets Updates

‘Announcing!’ ‘Manufactured Community Owners’ Association of America’ ‘Finally Bringing Fight To Manufactured Home Community Sector of the Industry’ – plus Sunday Weekly Manufactured Housing Headlines Review  

 

• • 2022 …Berkshire Hathaway is the parent company to Clayton Homes, 21^st 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 have completed over a dozen years of serving the industry as the runaway most-read trade media.

Sample Kudos over the years…

It is now 12+ years and counting…

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

· For expert manufactured housing business development or other professional services, click here.
· To sign up in seconds for our industry leading emailed headline news updates, click here.

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

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.)

By L.A. “Tony” Kovach – for MHProNews.
Tony earned a journalism scholarship along with numerous awards in history. There have been several awards and honors and also recognition 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.