AssociationWarnsStunningConsumersBizImpactDOEenergyRegulatoryStanceHUDcodeManufacturedHomesDOE.SecEnergyJenniferM.GranholmRemarksFacts-AnalysisMobileManufacturedHomeMHLivingNews

Association Warns ‘Stunning’ Consumers-Business Impacts by DOE Energy Regulatory Stance for HUD Code Manufactured Homes – DOE Secretary of Energy Jennifer M. Granholm Remarks – Facts/Analysis

The Department of Energy (DOE) asserts new regulations will save low-to-moderate-income households money. But a Manufactured Housing Association on 12.12.2023 called the pending regulations “Stunning and Unworkable” -asserting that they impacts will cost more than savings claimed by the DOE.

 

[Note: the following is adapted by ManufacturedHomeLivingNews.com (MHLivingNews.com) from a press release].

WASHINGTON, D.C., UNITED STATES, December 14, 2023

On 5.18.2023 the U.S. Department of Energy (DOE) announced: “new energy standards for manufactured housing — commonly referred to as single-section and multi-section mobile homes — that will help consumers save hundreds of dollars on their annual utility bills…” “DOE’s new energy efficiency rules will help the 17 million Americans million Americans residing in mobile homes up to $475 per year on average on their utility bills,” said U.S. Secretary of Energy Jennifer M. Granholm. “The rules will hold manufacturers of these U.S. homes to cost-saving efficiency standards, giving residents more comfortable living environments and a much-needed break on their annual utility costs…”

Critics quickly pointed out that mobile/manufactured homeowners won’t save a dime because of pending DOE regulations. Regulations only apply to new construction, not existing manufactured homes.

DOE’s remarks oddly misused federal terminology while misstating how many millions live in pre-HUD Code mobile homes and manufactured homes (per U.S. Census Bureau estimates: 21.2 to 22 million people).

Perhaps millions qualified to buy a manufactured home would be ‘priced out’ of buying a new manufactured home according to the National Association of Home Builders (NAHB) “priced out” calculator.

Per DOE’s release: “According to DOE estimates from the final rule, individuals can expect to save on average $177 per year in single-section homes and $475 per year in multi-section homes on their utility bills.”

Realizing the cost per new single section or multi-sectional manufactured home would rise if their pending regulations are implemented, DOE also announced an initiative to reduce the lending costs for buyers.

But per a Bing AI search reported by Manufactured Home Pro News (MHProNews.com) some 18 months after the DOE announcement (circa June 2022), there is no evidence that announced initiative for lower cost loans has worked. That noted, DOE announced: “DOE prioritizes access to energy-efficient and affordable housing for all Americans, including the more than 20 million Americans who live in manufactured homes.” “DOE is launching the Manufactured Housing Energy Efficiency and Affordability Initiative to assist states and other partners in improving access to energy-efficient manufactured homes across the United States by creating lower cost financing options for chattel loans.”

Critics noted that DOE again failed to get their own two releases to agree on how many millions live in manufactured homes. Nor did DOE correctly explain how existing mobile and manufactured homes aren’t impacted by any new standards DOE puts into effect.

Utility Dive reported: “DOE’s new rules have been criticized by both efficiency advocates…and home manufacturers, who say it will drive up costs.”

Per Bing AI: “Based on my search, I found no publicly available information on the Manufactured Housing Institute’s website regarding the DOE Energy Rule. It appears that they only have member-only items.”

 

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https://manufacturedhousingassociationregulatoryreform.org/stunning-and-unworkable-does-extreme-energy-enforcement-regulations-would-destroy-affordable-manufactured-homes/

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In contrast, the search tool on the Manufactured Housing Association for Regulatory Reform (MHARR) website reveals about 16 pages – dozens of reports – publicly available on their website regarding the DOE’s pending manufactured home energy rule. MHARR President and CEO Mark Weiss, J.D., and NAR’s Scholastica Cororaton asserted that manufactured homes are already energy-saving per federal law.

MHARR reported that at the link below the following. “Just three months prior to the scheduled May 31, 2023 implementation date for the destructive U.S. Department of Energy (DOE) final manufactured housing “energy conservation” standards rule, the Manufactured Housing Institute (MHI) and the Texas Manufactured Housing Association (TMHA) have filed a court action against the DOE final rule in the U.S. District Court for the Western District of Texas. The lawsuit, filed on February 14, 2023, seeks a stay of the impending implementation of the DOE final rule and other related relief. In both substance and approach, this court action tracks steps specifically urged by MHARR in August 2022.

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In the August 2022 MHARR Issues and Perspectives column, entitled “Why the DOE Energy Rule Should be DOA” (see, copy attached), MHARR called on MHI to use its resources to file a court action against DOE seeking an injunction against the May 31, 2023 implementation of the DOE final rule.”

https://manufacturedhousingassociationregulatoryreform.org/legal-action-filed-on-does-manufactured-housing-energy-rule/

Per MHARR: “At a time when the entire nation and governments at all levels are desperately seeking to find ways and means to provide affordable housing for American homebuyers, the U.S Department of Energy (DOE)…published a stunning and unworkable energy enforcement regulation that would undermine…affordable unsubsidized manufactured homes.”

https://manufacturedhousingassociationregulatoryreform.org/stunning-and-unworkable-does-extreme-energy-enforcement-regulations-would-destroy-affordable-manufactured-homes/

Attorneys for the Manufactured Housing Institute (MHI) and Texas Manufactured Housing Association (TMHA) filed suit to stop the proposed standards from going into effect. The MHI-TMHA litigation is Case No. 23-cv-00174. MHARR’s remarks seems to agree with what MHI-TMHA attorneys previously said asserting that the DOE regulations would cause “irreparable harm” to manufactured housing. From those pleadings, found at the link below, are the quoted remarks.

https://www.manufacturedhomepronews.com/masthead/crow-time-manufactured-housing-institute-mhi-texas-manufactured-housing-association-tmha-file-suit-v-does-mh-energy-rule-regs-case-no-23-cv-00174-docs-mharr-factor-analysi/

“DOE actually agrees that the interim relief sought by Plaintiffs—postponement of the Final Rule’s May 31, 2023 compliance date—is warranted. DOE, in its recent Notice of Proposed Rulemaking (“NOPR”), asserts that delaying the compliance date until after it has promulgated enforcement procedures is “necessary,” would provide “clarity to manufacturers,” and would remedy the current “absence of a clear, workable enforcement framework for manufacturers [which] jeopardizes the full realization of the [Final Rule’s] consumer benefits.”

“Third, DOE’s failure to consider testing, compliance and enforcement in the Final Rule was improper, which DOE effectively concedes in the NOPR.” [Note: NOPR is notice for proposed rulemaking.]

Fourth, DOE’s failure to account for the extraordinary economic environment in which it conducted its rulemaking is not saved by its purported “corroboration” with other obsolete cost and interest rate data.

Seventh, DOE—which, after eight months, has still not responded to Plaintiffs’ FOIA requests—has failed to show “some evidence” of its consultation with HUD related to the Final Rule.

Eighth, Plaintiffs’ members will suffer irreparable harm in the event DOE does not delay compliance in accordance with the NOPR because such an administrative about-face would leave manufacturers incapable of complying by the current deadline.”

 

More from MHARR on DOE:

https://manufacturedhousingassociationregulatoryreform.org/mhpronews-qa-with-danny-ghorbani/duty-to-serve-mh/#fifth

More from MHProNews/MHLivingNews on DOE energy rule:

https://www.manufacturedhomepronews.com/irreparable-harm-public-interest-legal-defects-doe-seeks-to-avoid-judicial-review-cited-by-mhi-tmha-attorneys-v-dept-of-energ/

https://www.manufacturedhomepronews.com/stunning-and-unworkable-does-extreme-energy-enforcement-regulations-would-destroy-affordable-manufactured-homes-per-manufactured-home-assoc-added-info-with-exclusive-insights-and-analysis-plus/

https://www.manufacturedhomelivingnews.com/double-digit-2023-manufactured-home-production-slide-continues-per-national-manufactured-housing-association-more-new-manufactured-home-living-facts/

https://www.manufacturedhomelivingnews.com/realtor-university-the-market-for-manufactured-homes-research-by-scholastica-cororaton-certified-business-economist-highlights/

L. A. “Tony” Kovach
MHProNews.com/MHLivingNews.com

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Mobile Home Living News, Manufactured Home Living News, (MHLivingNews.com) provides third-party research and other resource collections and reports not found on other sites. It is the widely acknowledged best source for authentic news on mobile and manufactured home living, as well as the policies that impact this segment of housing that provides 22 million Americans with good, surprisingly appealing living.

 

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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, 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.)

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How quickly they grow! Our son is about the same height as dad now. On that occasion recalled by this photo, all on Capitol Hill were welcoming and interested in the discussion of manufactured housing-related issues in our 12.3.2019 meetings. But Texas Congressman Al Green’s office was tremendous in their hospitality. Our son’s hand is on a package that included a copy of the Constitution of the United States and other goodies. MHLivingNews and MHProNews has worked with people and politicos across the left-right divide.

By L.A. “Tony” Kovach – for MHLivingNews.com.

Tony earned a journalism scholarship and earned numerous awards in history and 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.

http://latonykovach.com

Connect on LinkedIn: http://www.linkedin.com/in/latonykovach

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