The Federal Advisory Committee Act requires published notices to be at least 15 calendar days prior to an advisory committee meeting. It is also right before the deadline to comment to the DOE on the energy standards. Moreover, MHARR calls it “to be little more than window dressing to whitewash yet another violation of applicable law in a DOE rulemaking process that has been ‘“rigged”’ from the start by large industry manufacturers represented by MHI, energy special interests, and HUD Code industry competitors.”
MHARR says the Energy Independence and Security Act of 2207 required DOE to establish manufactured housing energy standards in consultation with HUD’s Secretary, who would in turn consult with the MHCC about the proposal. But MHARR says DOE waited until after the rule was drawn up to spring it on the industry. Furthermore, when asked about the content of the consultations between HUD and DOE, “At the August 2015 and January 2016 MHCC meetings, the HUD program Administrator refused to disclose any information or documents regarding the occurrence, timing or content of any such “’consultations.’”
While DOE claims to have presented on three occasions at an MHCC meeting, MHARR insists, having attended every MHCC meeting since its inception, one time DOE presented summary numbers at a meeting, but that was it. The bottom line is the MHCC was never given an opportunity to provide input into making the rule, as it is supposed to do.
MHARR claims this new standard that will add $6,000 to the cost of a new manufactured home is the result of a collaboration of DOE, the MH program at HUD, MHI and other special interest groups to the detriment of lower income consumers and smaller producers in the industry.
MHARR is urging those in the industry to oppose this energy proposal. ##
(Image credit: Manufactured Housing Industry for Regulatory Reform)
