MHARR Washington Updates

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Federal Preemption – Fire Sprinklers in Maryland

[vc_row][vc_column][vc_column_text] As promised in MHARR’s memorandum dated August 28, 2017 (“MHEC Installation Conference Call”), MHARR has sent a communication (copy attached) to the Director of Maryland Codes Administration, Mr. Norman Wang, strongly objecting to his assertion, set forth in an August 11, 2017 memorandum to Maryland local building code officials, that the federal preemption provision …

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HUD Program Ramping-Up More MH Regulation

[vc_row][vc_column][vc_column_text]At a time when federal rulemaking has reached historically-low levels, reflecting the regulatory policies of the Trump Administration, the HUD manufactured housing program, under its current administrator, continues to churn out new and amended regulatory requirements at an aggressive pace. In addition to the pending “Interpretative Bulletin” for manufactured home foundations in freezing climates and …

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MHEC Installation Conference Call

[vc_row][vc_column][vc_column_text]For those who participated in the August 25, 2017 Manufactured Housing Executives Council (MHEC) conference call regarding HUD interaction with the International Code Council (ICC) concerning Appendix E of the International Residential Code (IRC) (or could not participate), it was extremely disappointing that the format and conduct of the call did not allow for a …

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MHARR Calls for Withdrawal of HUD “Frost-Free” IB

[vc_row][vc_column][vc_column_text] Washington, D.C., August 17, 2017 – In written comments submitted to the U.S. Department of Housing and Urban Development (HUD) on August 17, 2017 (copy attached), the Manufactured Housing Association for Regulatory Reform (MHARR) has called on the Department to withdraw a proposed “Interpretative Bulletin” (IB) concerning “frost-free” manufactured home foundations, which violates multiple provisions of the National Manufactured …

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Actions and Abuses Of The Current HUD Manufactured Housing Program Administrator That Warrant Her Reassignment and Replacement

[vc_row][vc_column][vc_column_text]The current HUD manufactured housing program administrator, Pamela Danner – “parachuted” into that position on a career basis in violation of section 620(a)(1)(C) of the Manufactured Housing Improvement Act of 2000 — has engaged in multiple actions and abuses over the course of her nearly four-year tenure that have needlessly, baselessly, and unnecessarily harmed the …

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Re-Assignment And Replacement Of Current HUD Manufactured Housing Program Administrator

[vc_row][vc_column][vc_column_text] Attached for your review and information are two self-explanatory communications sent by MHARR to HUD on July 27, 2017 regarding the HUD manufactured housing program and, specifically, the re-assignment and replacement of the current program Administrator, Pamela Danner. These communications were sent to Ms. Maren Kasper, the White House liaison to HUD, questioning Ms. Danner’s latest …

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MHARR to DOE: Reject Or Withdraw Baseless And Scandalous Manufactured Housing Proposed “Energy” Rule

[vc_row][vc_column][vc_column_text]Washington, D.C., July 17, 2017 – The Manufactured Housing Association for Regulatory Reform (MHARR) has called on the U.S. Department of Energy (DOE) to either reject or withdraw its June 17, 2016 proposed “energy efficiency” rule for manufactured homes, pursuant to Executive Orders issued by the Trump Administration which seek to “alleviate unnecessary regulatory burdens …

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MHARR Duty to Serve Comments Expose True Story Of GSE’S Resistance To Secondary Market Support For HUD Code Homes

[vc_row][vc_column][vc_column_text]Washington, D.C., July 11, 2017 – The Manufactured Housing Association for Regulatory Reform (MHARR) has filed written comments with the Federal Housing Finance Agency (FHFA), the federal regulator of the two Government Sponsored Enterprises (GSEs) – Fannie Mae and Freddie Mac – addressing the Duty to Serve Underserved Markets (DTS) “implementation” plans filed by the …

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HUD Code Industry Manufacturers, Retailers and Communities

[vc_row][vc_column][vc_column_text]MHARR has called on HUD Secretary, Dr. Benjamin Carson, to withdraw – pending further review and follow-up action – a proposed “Interpretive Bulletin” (IB) concerning “frost-free” and frost-protected manufactured housing foundations in freezing climates, issued by the HUD manufactured housing program on June 23, 2017. Citing the regulatory “freeze” order issued by the Trump Administration …

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HUD Power-Grab – “Frost-Free” Interpretive Bulletin

[vc_row][vc_column][vc_column_text]The HUD manufactured housing program, on June 21, 2017, published a proposed “Interpretive Bulletin” (IB) in the Federal Register (copy attached) that would effectively change the substance of the current federal installation standards (24 C.F.R. 3285.312(b)) for “frost-free or “frost-protected” manufactured housing foundations used in “freezing  climates.” This proposal, which MHARR has explained and detailed …

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