FOR IMMEDIATE RELEASE Contact: MHARR
(202) 783-4087
MHARR INTENSIFIES DEMAND FOR REPEAL OF DOE MANUFACTURED
HOUSING “ENERGY” REGULATIONS BASED ON NEW EXECUTIVE ORDER
Washington, D.C., March 30, 2026 – The Manufactured Housing Association for Regulatory Reform (MHARR) has renewed and amplified its longstanding call for the repudiation and retraction of draconian, discriminatory and excessive U.S. Department of Energy (DOE) “energy conservation” regulations for manufactured homes, based on a new Executive Order issued by President Trump. The ill-conceived and unnecessary DOE regulatory mandates, which would add thousands of dollars to the purchase cost of a new federally-regulated manufactured home and exclude millions of lower and moderate-income Americans from access to the nation’s most affordable source of homeownership in the midst of national housing crisis, were adopted by the Biden Administration DOE as a “final” rule on May 31, 2022. Although the DOE “standards” have not been enforced by the Trump Administration, they have not been formally withdrawn and remain a major continuing threat to both the industry and American consumers of affordable mainstream manufactured homes.
In a March 25, 2026 communication to DOE Secretary Chris Wright (copy attached) and U.S. Department of Housing and Urban Development (HUD) Secretary Scott Turner, MHARR asserts Executive Order 14394 (EO), issued by President Trump on March 13, 2026, as an independent and compelling basis for the repeal and retraction of:
(1) DOE’s May 31, 2022 “final” energy regulations;
(2) DOE’s December 26, 2023 proposed (and still pending) manufactured housing energy standards enforcement rule; and
(3) any corresponding energy regulation/enforcement proposals (based on the DOE standards or any derivative thereof) pending at HUD.
As emphasized by MHARR in its March 25, 2026 correspondence, the March 13, 2026 EO – designed to address and alleviate the nation’s unprecedented shortfall in the supply and availability of affordable single-family housing — specifically directs both DOE and HUD to “take appropriate action to … eliminate unduly burdensome or costly energy efficiency … requirements regarding housing, including manufactured housing, to the maximum extent practicable….” (Emphasis added).
The MHARR communication points out that in previous comments filed in relation to the DOE energy regulations, “MHARR has demonstrated, with specific documented evidence, that the May 31, 2022 DOE” standards are “not designed – or appropriate for – affordable HUD Code manufactured housing;” are “not needed insofar as energy costs for HUD Code manufactured homes are already lower than those for other types of single-family homes;” “would result in excessive and unnecessary price increases which would exclude millions of Americans from all of the benefits of homeownership;” “are not and would not be cost-beneficial for purchasers;” are based on invalid cost-benefit metrics derived from or impacted by the Social Cost of Carbon construct which has since been withdrawn and repudiated by the Trump Administration; and is otherwise “arbitrary and capricious in violation of the federal Administrative Procedure Act.” (Emphasis in original).
Such action by DOE and HUD – to withdraw and repudiate the May 31, 2022 DOE “final” manufactured housing energy regulations and any and all other pending manufactured housing energy regulations or standards based upon or related to the May 31, 2022 DOE “final” rule – is essential because a potential legislative remedy has been weakened and arguably nullified for reasons that are not readily apparent and have not been explained by the Manufactured Housing Institute (MHI) which has promoted and touted this and other pending housing legislation in both houses of Congress. (Indeed, MHI continues to prominently support pending House and Senate housing bills which, as MHARR has pointed out – other than their removable/optional chassis provisions, which are long overdue – do not address or resolve the zoning exclusion or consumer chattel financing bottlenecks that have throttled industry production for years and, if not remedied, will continue to haunt the industry and its consumers for years to come).
Apparently caught-up in this legislative wrangling, and as reported previously by MHARR, a bill originally filed by Rep. Erin Houchin (R-IN), would have repealed the May 31, 2022 DOE standards rule and would also have repealed the underlying statutory authorization for those standards, i.e., section 413 of the Energy Independence and Security Act of 2007 (EISA). In the housing bill recently passed by the House of Representatives, however (i.e., H.R. 6644, the “Housing for the 21st Century Act”) , that clear and unequivocal repeal command has been reduced to a provision which gives HUD final authority over manufactured housing “energy efficiency” standards developed by any other “federal agency.” Like its Senate counterpart, however, this provision would do absolutely nothing to prevent the imposition of draconian manufactured housing “energy efficiency” standards in the future, insofar as any HUD Secretary in a presidential administration that would bring forward such regulations from any other “federal agency” would presumably be totally aligned with the ideological views of that presidential administration and all of its other cabinet/department Secretaries. Put differently, it would be totally unrealistic to expect a HUD Secretary to veto or substantially change or reject energy mandates put forward by another cabinet secretary or department head within the same presidential administration.
Even worse, H.R. 6644 includes a provision which would affirmatively require HUD to “not later than 1 year after the date of enactment of this Act, adopt minimum energy efficiency standards for manufactured homes; and not less frequently than once every 3 years after adopting the standards under clause (i), update those standards.” Why such a provision is needed or would be beneficial for consumers or the industry has never been explained or addressed. Regardless, however, the May 31, 2022 DOE standards cannot, should not and must not be left “on the table” as a potential standard for re-enactment, validation, recognition or adoption by HUD (or any other agency).
Consequently, the aforesaid pending legislation – in its present form – makes it even more critical that the May 31, 2022 DOE standards be eliminated, repudiated and effectively “wiped from the books” to prevent them from being revived in any manner by the provisions noted above.
In Washington, D.C., MHARR President and CEO Mark Weiss stated: “The President’s Executive Order makes it clear that baseless and destructive DOE ‘energy efficiency’ regulations, adopted to satisfy climate radicals and extremists, and with virtually no regard for actual manufactured housing consumers, should be eliminated once and for all. If not, they will remain a ‘sword’ hanging over the head of the industry and consumers, with potential economically-deadly consequences under a future presidential administration.”
The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.- based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.
— 30 —
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: MHARRDG@AOL.COM
Website: www.manufacturedhousingassociation.org
— Attachment —
March 25, 2026
VIA FEDERAL EXPRESS
Hon. Chris Wright
Secretary
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585
Re: Manufactured Housing Energy Conservation Standards
DOE Docket No. EERE-2009-BT-BC-0021
Dear Secretary Wright:
The following supplemental comments are submitted on behalf of the Manufactured Housing Association for Regulatory Reform (MHARR). MHARR is a Washington, D.C.-based national trade association representing the views and interests of producers of manufactured housing regulated by the U.S. Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5401, et seq.) as amended by the Manufactured Housing Improvement Act of 2000 and subject to potential energy-related regulation by the U.S. Department of Energy (DOE) pursuant to section 413 of the Energy Independence and Security Act of 2007 (EISA) (42 U.S.C. 17071). MHARR previously submitted multiple written comments in this docket, including comments on DOE’s September 3, 2025 Request for Information (RFI) dated November 24, 2025 and December 1, 2025. MHARR submits the additional comments herein based on a significant new development concerning this rulemaking, which should be expressly addressed by DOE in the official administrative record of this matter.
Specifically, on March 13, 2026, President Trump issued Executive Order 14394 (EO), titled “Removing Regulatory Barriers to Affordable Home Construction.”[1] Designed to address the unprecedented national shortage of affordable housing and homeownership, Section 1 of that Executive Order states, in relevant part:
“Layers of unnecessary regulatory barriers … and onerous mandates at all levels of government have delayed construction, restricted development and driven up the costs of new housing. These constraints have made housing less affordable for many Americans. It is the policy of my Administration to reduce regulatory barriers to building homes….”
(Emphasis added).
Among the particularly destructive federal regulatory burdens specifically identified and addressed by the EO, are the impending, draconian and unnecessarily costly Biden-era DOE “energy conservation” standards for manufactured homes.[2] In relevant part, Section 2 (c) of EO 14394 states:
“[T]he Secretary of Housing and Urban Development [and] the Secretary of Energy shall, within their respective authorities, take appropriate action to reform and, where appropriate, eliminate unduly burdensome or costly energy-efficiency … requirements regarding housing, including manufactured housing, to the maximum extent practicable…. Such action shall include reviewing and revising … (i) the Energy Conservation Program’s Energy Conservation Standards for Manufactured Housing.”
(Emphasis added).
In its prior comments filed in this docket (and consistently since the inception of this matter), MHARR has demonstrated, with specific documented evidence, that the May 31, 2022 DOE manufactured housing energy conservation standards, currently in abeyance,[3] are not designed – or appropriate for – affordable HUD Code manufactured housing,[4] are not needed insofar as energy costs for HUD Code manufactured homes are already lower than those for other types of single-family homes,[5] would result in excessive and unnecessary purchase price increases which would exclude millions of Americans (primarily lower and moderate-income families, newlywed persons and senior citizens) from all the benefits of homeownership,[6] are not and would not be cost-beneficial for purchasers,[7] are based, in substantial part, on cost-benefit metrics derived from or impacted by the federal “Social Cost of Carbon” metric which has since been withdrawn and repudiated by the Trump Administration,[8] are arbitrary and capricious in violation of the federal Administrative Procedure Act (APA) (5 U.S.C. 706),[9] and are otherwise not in accordance with law.
Given the extreme cost impacts of the May 31, 2022 “final” DOE energy standards and the absence of any evidence in the administrative record showing a legitimate need for such extreme, high-cost “standards” within the context of an unprecedented national shortage and shortfall of affordable single-family homes, the May 31, 2022 Biden-era DOE manufactured housing “energy conservation standards, in accordance with EO 14394, should be “eliminated” through the formal withdrawal and repudiation of those standards by DOE, as previously sought by MHARR in written comments filed in the administrative docket herein. Simultaneously, and again in accordance with EO 14394, pending manufactured housing energy standards at HUD must also be withdrawn from consideration and repudiated by that agency, insofar as they represent a needless, discriminatory and unduly burdensome regulatory and cost burden on both the manufactured housing industry and American consumers of affordable manufactured housing.
In summary, the May 31, 2022 DOE standards developed by DOE and rushed into “final” status without proper adherence to APA requirements and without full and proper DOE “consultation” with HUD, as required by the underlying authorizing statute, in order to meet artificial time deadlines resulting from litigation filed by climate activist and extremist groups should be withdrawn and rejected in accordance with EO 14394. Simultaneously, and for the same fundamental reasons, DOE’s proposed Biden-era manufactured housing energy conservation standards enforcement rule, published on December 26, 2023,[10] — and all corresponding manufactured housing energy conservation regulation proposals at HUD — must also be withdrawn and rejected.
In accordance with the foregoing, we will contact your office soon to schedule a meeting to more fully address this matter. Thank you in advance for your consideration.
Sincerely,
Mark Weiss
President and CEO
cc: Hon. Donald J. Trump
Hon. Scott Turner
Hon. Russell Vought
Hon. Kelly Loeffler
Mr. Lou Hrkman (DOE)
HUD Code Manufactured Housing Industry Members and Consumers
Attachments
[1] See, 91 Federal Register, No.52 (March 18, 2026) “Removing Regulatory Barriers to Affordable Home Construction” at p. 13207, et seq..
[2] See, 87 Federal Register No. 104, (May 31, 2022) “Energy Conservation Program: Energy Conservation Standards for Manufactured Homes” at p. 32728, et seq..
[3] See, 90 Federal Register, No. 168, (September 3, 2025) “Public Input on Energy Conservation Standards for Manufactured Housing” at pp. 42545-42546 for a summary of DOE regulatory actions regarding the compliance date for the subject standards.
[4] See, e.g., MHARR October 25, 2021 Comments to DOE on “Energy Conservation Standards for Manufactured Housing” attached hereto as Attachment 1, at pp. 14-18.
[5] See, e.g., Attachment 1 hereto at pp. 5-7.
[6] See, e.g., Attachment 1 hereto at pp. 7-12.
[7] See, e.g., Attachment 1 at pp. 15-24.
[8] See, MHARR November 24, 2025 and December 1, 2025 Comments on “Request for Information – Manufactured Housing Energy Conservation Standards, attached hereto as Attachments 2 and 3 hereto.
[9] See, e.g., Attachment 1 hereto at pp. 28-32.
[10] See, 88 Federal Register, No. 246 (December 26, 2023) “Energy Conservation Standards for Manufactured Housing: Enforcement” at p. 88844, et seq.
