WhyManufacturedHomeIndustryMembersAdvocatesMustCommentOnTheDOE-ManufacturedHousingEnergyRuleDemandItsDelayAndWithdrawalPerManufacturedHousingAssociationMHLivingNews

Why Manufactured Home Industry Members and Advocates Must Comment on the DOE Manufactured Housing Energy Rule to Demand its Delay and Withdrawal, per Manufactured Housing Association

Mobile and Manufactured Home Living News (MHLivingNews) recently reported on the statement from pro-manufactured home Senator Tim Scott (SC-R). Scott’s letter to DOE and our MHLivingNews analysis and commentary are linked here. Manufactured homes have been mandated by law to have money saving energy saving standards since June 15, 1976.

 

From the Regulations.gov website the Department of Energy (DOE) makes the following interesting admission.

 

QuoteMarksLeftSideMHLivingNewsNeed To Amend Compliance Date

DOE has not yet issued procedures for reviewing and enforcing against noncompliance with the manufactured housing energy conservation standards in 10 CFR part 460. While manufacturers are capable of complying with the DOE standards as they are with minimal efforts, DOE nevertheless recognizes that enforcement procedures would help provide clarity to manufacturers that are new to DOE’s regulatory program.

Accordingly, DOE will establish enforcement procedures in the coming months. This will provide clarity to manufacturers and consumers regarding DOE’s means of enforcing the standards and how DOE will evaluate compliance. A delay of the current May 31, 2023, compliance date is therefore necessary to ensure that DOE can receive and incorporate meaningful stakeholder feedback into its enforcement procedures prior to the Rule’s compliance date.”

Imagine, regulations are put in place and no compliance mechanism is stated?

 

On 4.12.2023, the Manufactured Housing Association for Regulatory Reform provided the following information and attached insights.

 

APRIL 12, 2023

 

TO:                  HUD CODE MANUFACTURED HOUSING INDUSTRY MEMBERS

 

FROM: MHARR

 

RE:                   WHY INDUSTRY MEMBERS MUST COMMENT

ON THE DOE MANUFACTURED HOUSING ENERGY

RULE TO DEMAND ITS DELAY AND WITHDRAWAL

 

As promised in its March 28, 2023 memorandum, entitled “DOE Delays Energy Rule – Industry Must Now Demand Total Revocation of Destructive Regulation,” attached for your information and use, in whole or in part, if you so wish, is a copy of MHARR comments to the U.S. Department of Energy (DOE) supporting not only a delay in the enforcement of its May 31, 2022 “final” manufactured housing “energy conservation” standards, but, more importantly, seeking once again, the complete withdrawal of those standards and DOE’s return “to the drawing board” to completely re-start its standards development process in full compliance with the requirements of both the Energy Independence and Security Act of 2007 (EISA) and relevant parts of the Manufactured Housing Improvement Act of 2000 (2000 Reform Law).

As MHARR has asserted and stated from the outset of the DOE rulemaking process, 15 years ago, DOE’s development of manufactured housing energy standards has been and continues to be in complete defiance of the most important provisions of EISA – i.e., its cost-benefit mandate and, even more importantly, its requirement for the development of manufactured housing energy standards in full cooperation, coordination and consultation with both HUD and the statutory Manufactured Housing Consensus Committee (MHCC). As industry members are fully aware, however, DOE has never engaged with HUD and the MHCC regarding the substance, cost or enforcement of such standards, but instead has resorted to a sham “negotiated rulemaking” process and other subterfuges, which have now resulted in a destructive and totally unacceptable standard that would devastate the manufactured housing market and destroy the housing choices of the lower and moderate-income Americans who rely the most on the genuine affordability of today’s modern manufactured housing.

MHARR, accordingly, strongly encourages all industry members to submit comments (due by April 24, 2023) to DOE addressing both the delay of the implementation/enforcement date of the DOE manufactured housing energy standards, as well as the full withdrawal of these inappropriate and unlawful standards combined with a return to the “drawing board” for a complete and total “re-do” of the standards in full cooperation, coordination and consultation with both HUD and the MHCC as required by EISA and federal manufactured housing law. In doing so, please feel free to cite or reference MHARR’s attached comments.

MHARR will continue to closely monitor this rulemaking which has extremely serious implications for the industry and its consumers.

Attachment (MHARR April 13, 2023 comments to DOE)

Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: 
MHARR@MHARRPUBLICATIONS.COM
Website: manufacturedhousingassociation.org

 ##

The attachment from MHARR is linked here.

 

Additional Information with More MHLivingNews Analysis and Commentary in Brief

 Any American can comment on the proposed DOE energy regulations. Certainly, the Regulations.gov comments advice makes it clear that merely copying and pasting a message is NOT recommended, this is not a ‘vote.’ What DOE is asking for are public feedback that could (perhaps should) site sources for remarks, but is unique.

MHLivingNews submitted the comments linked here to the Regulations.gov comments center found at this link here.

The following are from the page linked here and are useful references in submitted comments.

 

Comments Close:

04/24/2023

Document Type:

Proposed Rule

Document Citation:

88 FR 17745

CFR:
10 CFR 460

Agency/Docket Number:

EERE-2009-BT-BC-0021

RIN:

1904-AC11

Document Number:

2023-05873

 

Most any American can provide remarks. If comments are being made on behalf of another or an organization, that should be disclosed. Comments can be submitted anonymously (for those that do, don’t put your address or name in the body of your comments). Regulations.gov does NOT recommend ‘cut and paste’ style mass email campaign comments, explaining that it is the quality of the comments, not the number of comments that is more important.

QuoteMarksLeftSideMHLivingNewsSubmitting comments via email. Comments and documents submitted via email also will be posted to www.regulations.gov. If you do not want your personal contact information to be publicly viewable, do not include it in your comment or any accompanying documents. Instead, provide your contact information in a cover letter. Include your first and last names, email address, telephone number, and optional mailing address. The cover letter will not be publicly viewable as long as it does not include any comments.

 

Comments can be posted online via this link below. That portal allows for uploading attached remarks.

https://www.regulations.gov/commenton/EERE-2009-BT-BC-0021-2003

Clearly, there are supporters of and opposition to the DOE manufactured housing energy rule. Among the points that MHARR has made is that once these regulations go into effect, they will be updated according to a process that is designed for conventional housing, not for manufactured homes.  So, besides the increased costs, the costs will likely continue to rise every few years.

There is an old saying that the ‘road to hell’ is paved with ‘good intentions.’ It isn’t intent, but the practical impact that matters the most.

Concerns that motivate opposition to the rule include, but are not limited, to the following.

  • Hundreds of thousands, perhaps millions of Americans will be ‘priced out’ of manufactured housing.
  • You can’t ‘recoup’ through claims of possible energy savings a cost that is so high that you can’t buy the new manufactured home in the first place.
  • Those who are priced out of a new manufactured home may end up buying an older manufactured home or mobile home that won’t be as energy efficient. Or they may end up buying a fixer upper old conventional house that is a ‘money pit’ that is also not energy efficient.
  • Put differently, large numbers of consumers are going to be denied options. What happened to the notion of ‘choice’ in a free marketplace?
  • As MHARR has suggested, once this regulatory regimen is in place, supporters of conventional housing might use the regulations to so effectively limit manufactured housing that it could end up killing off the industry.
  • Manufactured home buyers have had the option with most, if not all, manufacturers to upgrade insulation or energy saving features. Meaning, those buyers who want to invest more in saving already have that option.

A survey by the CATO Institute indicated that the average American is willing to pay a fee of less than $10 a month to pay for ‘climate change.’ “The survey found overwhelming majorities of Americans opposed paying the fee to combat climate change if it cost: $10 a month, 68% opposed. $20 a month, 69% opposed.” The changes proposed by the DOE are simply excessive by those standards. As was noted, you or others can’t ‘recoup’ through a hopefully lower utility bills a cost that keeps you or others from buying a home in the first place.

Again, the comments submitted by this writer are found at this link here. While the feds often like to see a certain format in their remarks, everyone is at liberty to write their comments in their own words and own style. Common sense tells us that one shouldn’t cuss out public officials that they want to influence, but beyond that, say what you mean and feel. Those who want to sound off can email or post at the links above.  The deadline is April 24, just before midnight. ###

 

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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.)

CongRepAlGreenDeskTamasKovachLATonyKovachPhoto12.3.2019ManufacturedHomeProNews
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. 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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