HARR, on March 13, 2015, filed comments (see, copy attached) in response to a U.S. Department of Energy (DOE) Request for Information (RFI) in connection with DOE’s development of manufactured housing energy standards under the Energy Independence and Security Act of 2007.
The DOE-RFI, published in the Federal Register on February 11, 2015, sets forth DOE’s analysis of Solar Heat Gain Coefficient (SHGC) values for potential inclusion in any such standards and seeks public comment on: (1) DOE’s conclusion that “an SHGC requirement of 0.30” would be appropriate for “climate zones 1B and 2,” and (2) “whether to include an SHGC requirement of 0.30 for climate zones 1B and 2 in the development of the proposed rule.” As the RFI notes, this particular issue was left to DOE for “additional analysis” by the manufactured housing “Working Group” established by DOE in July 2014.
Insofar as MHARR has objected to the entire DOE rulemaking in this matter as fundamentally tainted by DOE’s impermissible selective leak of a draft proposed energy rule to parties in interest and other subsequent procedural abuses, including its failure to materially comply with an Office of Management and Budget (OMB) directive to begin its rulemaking over again from the start, MHARR’s comments object to any SHGC analysis or determinations. Instead, MHARR calls on DOE to terminate the present rulemaking and return this matter to Congress for reconsideration based on full hearings and participation by all interested stakeholders.
Based on the sustained record of procedural irregularities in this rulemaking, as well as the extreme cost and negative market impact of the standards recommended by the DOE manufactured housing Working Group – notwithstanding the fact that manufactured homes already have energy operating costs that are equal to or less than other types of housing –MHARR voted against the standards as a member of the DOE Working Group and has pledged to oppose any such standards in every available forum.
This critical matter will be discussed in greater detail at MHARR’s upcoming Board of Directors meeting.
