Washington, D.C., March 13, 2017 – The Manufactured Housing Association for Regulatory Reform (MHARR) has formally called upon the newly-confirmed Secretary of the U.S. Department of Energy (DOE), Gov. Rick Perry, to withdraw, in toto, the proposed manufactured housing “energy” rule published by DOE in the Federal Register on June 17, 2016.
In a March 10, 2017 communication to the Secretary (copy attached), MHARR states that the proposed rule, “rooted in ‘climate change’ activism and advanced by ‘energy’ special interests through an illegitimate and scandal-plagued regulatory process, threatens to needlessly destroy [the] affordability [of manufactured homes] and simultaneously exclude millions of consumers from the manufactured housing market – and from home-ownership altogether.”
The proposed rule, which could increase the retail cost of an average multi-section manufactured home by $6,000.00 – and ultimately more, because regulatory compliance, testing and enforcement-related costs were never considered by DOE in developing the rule – would not result in energy cost savings for manufactured homebuyers and, according to comments filed in the DOE rulemaking by the independent George Washington University Regulatory Studies Center (copy attached), could actually result in net energy life-cycle operating cost increases that would “affect a large market share of manufactured homes.”
MHARR, unlike some industry organizations, has been a fierce and consistent opponent of both the proposed DOE rule and the fundamentally-tainted administrative process that led to its adoption. Thus, in a November 2016 post-election communication to DOE, MHARR called for the Department to cease and desist from any further activity on the proposed manufactured housing rule pursuant to Congress’ November 15, 2016 warning to all federal agencies against “finalizing [any] pending rules or regulations in the [Obama] Administration’s last days.” Subsequently, in a January 6, 2017 communication to the chairmen of the relevant committees in both houses, MHARR urged Congress to review and reject the pending DOE rule and/or any final manufactured housing rule, if, in fact any is ultimately published, under the Congressional Review Act of 1996.
Strong action by the DOE Secretary, though, to withdraw the egregious proposed rule, would avoid the need for congressional intervention.
In Washington, D.C., MHARR President and CEO Mark Weiss stated, “The DOE manufactured housing ‘energy’ rule is a textbook example of a destructive, big government ‘solution’ in search of a problem. Manufactured homes, comprehensively regulated by the U.S. Department of Housing and Urban Development, already have median energy operating costs that are less than, or comparable to, other types of housing, according to the U.S. Census Bureau. To single out manufactured homes and their mostly lower and moderate-income buyers for what amounts to a huge, regressive tax that would devastate both them and the industry in order to satisfy special interests, is incomprehensible, indefensible and precisely the type of baseless, damaging federal regulation that President Trump has vowed to eliminate. This horrendous proposal, developed through an equally horrendous and illegitimate process, needs to go.”
