Washington, D.C.
TO: HUD CODE MANUFACTURED HOUSING INDUSTRY PRODUCERS
FROM: MHARR
RE: MHARR AMPLIFIES CALL FOR ADMINISTRATIVE REPEAL OF
DISCRIMINATORY AND EXCESSIVE MANUFACTURED HOUSING “ENERGY” STANDARDS
Attached for your information and review is a May 5, 2026 MHARR communication to U.S. Department of Energy (DOE) Secretary, Chris Wright and U.S. Department of Housing and Urban Development (HUD) Secretary, Scott Turner, amplifying MHARR’s call for the withdrawal and repeal of DOE’s discriminatory and excessive May 31, 2022 “final” manufactured housing “energy conservation” standards and the termination of any and all administrative procedures at DOE and HUD relating to those standards or any variant thereof.
This communication is based upon – and cites – HUD’s May 1, 2026 recission (i.e., withdrawal) of an April 26, 2024 “Final Determination” pursuant to the Energy Independence and Security Act of 2007 (EISA), finding that energy standards derived from the 2021 edition of the International Energy Conservation Code (IECC) would “not negatively affect the affordability or availability” of new single-family homes (other than manufactured homes) financed through HUD and U.S. Department of Agriculture (USDA) programs. MHARR maintains in its communication, that this recission, based on a January 20, 2025 Trump Administration directive to all federal agencies to “pursue ‘appropriate actions to lower the cost of housing and expand housing supply’” is legally and factually indistinguishable from the fatal flaws underlying the May 31, 2022 DOE manufactured housing energy standards (also derived from the 2021 IECC), and that those standards (and all related administrative proceedings) must similarly be withdrawn pursuant to the same authority, logic and precedent.
The administrative repeal of the DOE standards and termination of any parallel HUD rulemaking is essential because a bill by Rep. Erin Houchin (R-IN) – supported by MHARR – which would have fully repealed not only the 2022 DOE “final” manufactured housing energy standards, but also the EISA statutory mandate for such standards, has been significantly and incomprehensibly weakened in the pending housing legislation promoted by the Manufactured Housing Institute. Under the current pending House legislation, the 2022 DOE final standards would not be automatically eliminated. Instead, the pending legislation would simply require any such standards to be adopted by HUD pursuant to its statutory consensus process. Even worse, the pending legislation would affirmatively require the adoption of “minimum” manufactured housing energy standards within one year of passage, with revisions on a three-year cycle. Why any industry group would accept such a one-sided “compromise” is unfathomable.
MHARR will continue to closely monitor the DOE/HUD energy standards and will take further action as warranted and required.
cc: Other Interested HUD Code Manufactured Housing Industry Members
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
MHARR’s news reports are available for re-publication in full (i.e.: without alteration or substantive modification) without further permission and with proper attribution and/or linkback to MHARR.
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Appendix
Per Gemini.
The Path to Market Restoration
The logic suggests that without administrative intervention, production will remain suppressed by “man-made” regulatory bottlenecks.
| Factor | Current Status | MHARR Position / Impact |
| DOE Energy Rule | “In abeyance” but still on the books. | Must be repealed to ensure long-term affordability. |
| HUD Code Production | ▼ 8.9% YTD (2026) | Suppressed by cumulative regulatory “layers.” |
| DTS Coverage | Omitted for chattel in new bills. | Starves the 70% of the market using home-only loans. |
| Enhanced Preemption | Not mandated in current legislation. | Allows local zoning bans to continue blocking supply. |
Key Takeaways
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Production Decline: Manufactured housing production has dropped 8.9% in early 2026 compared to 2025, signaling a deepening supply crisis.
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Energy Rule Repeal: MHARR is using President Trump’s Executive Order 14394 as a legal basis to force the repeal of costly DOE energy mandates.
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Bottleneck Warning: MHARR warns that modernization of the HUD Code is meaningless without addressing discriminatory zoning and the lack of chattel loan financing.
Best SEO Keywords & Phrases
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