DOE Resorts to Deception and Misdirection to Advance Its Flawed Energy Rule for Manufactured Housing

DOE Resorts to Deception and Misdirection to Advance Its Flawed Energy Rule for Manufactured Housing

DOEResortsToDeceptionAndMisdirectionToAdvanceItsFlawedEnergyRuleForManufacturedHousingManufacturedHousingAssociationForRegulatoryReformMHARRLogo

Washington, D.C., May 24, 2022 – The U.S. Department of Energy (DOE), in a reprehensible news release announcing the publication of its baseless and destructive energy standards for HUD Code manufactured homes (copy attached), resorts to deception and distortion in a futile attempt to rationalize a rule that will needlessly add thousands of dollars to the cost of the nation’s leading source of affordable housing, and simultaneously exclude millions of lower and moderate-income Americans from the manufactured housing market and from homeownership altogether.

The Manufactured Housing Association for Regulatory Reform (MHARR) has been a consistent opponent of these fundamentally-flawed and baseless standards, as well as previous iterations proposed by DOE. Having refuted, moreover, the semblance of any basis whatsoever for such draconian mandates, MHARR once again calls on DOE to withdraw its final manufactured housing energy standards rule and consider significant revisions based on a legitimate process.

For the present, however, unable to legitimately claim that its standards will benefit manufactured homebuyers (or anyone other than its special interest allies), DOE’s deceitful May 18, 2022 “news” release, instead invents a non-existent “strawman” caricature of today’s modern, affordable and energy-efficient manufactured housing, which it proceeds to attack with an assortment of knowingly false and misleading assertions.

Most fundamentally, the DOE “news” release, in its title and elsewhere, intentionally and repeatedly mischaracterizes today’s modern manufactured homes as “mobile homes.” This despite the fact that HUD Code homes, under existing federal law, are specifically denominated and defined as “manufactured homes,” and have been referred-to as “manufactured homes” for decades. Modern, affordable “manufactured homes,” however, as reported by the U.S. Census Bureau, have lower energy consumption costs, on a whole home basis, than other types of homes. Consequently, to bootstrap its outrageous assertions and equally outrageous standards, DOE instead attacks a class of homes that has not existed for decades and that the industry, through hard work and millions of dollars in investment, has successfully surpassed.

Yet another “big lie” inherent in the disgraceful DOE “news” release is its willful failure to address the massive level of market exclusion that will result from purchase cost increases driven by its final standard. The DOE release, in a comment attributed to DOE Secretary, Jennifer Granholm, thus states: “DOE’s new energy efficiency rules will help save 17 million Americans residing in mobile homes up to $475 per year on … their utility bills.” Aside from the fact that significantly more than 17 million Americans currently reside in HUD Code manufactured homes, and the DOE energy standards, by law, have nothing to do with the existing homes owned by those residents, the reality is that millions of Americans who heretofore would have been able to afford and finance a manufactured home, will henceforth be excluded from the market due to the excessive cost and purchase price impact of the DOE standards. For these millions of Americans, quite simply, there will be – and by definition could not be – any utility cost savings whatsoever, because the purchase cost impact of the DOE standards will prevent them from ever being homeowners in the first place. DOE, however, chooses to willfully ignore this fact and intentionally seeks to distract from it in its “news” release.

Worse yet, and as predicted by MHARR, DOE, having now acted to undermine the inherent purchase price affordability of HUD Code manufactured homes, instead calls in its “news” release for at least part of that new cost burden to be borne by American taxpayers. The “news” release notes that DOE supports “legislative and administrative policies” and “the establishment of credit enhancement mechanisms, such as loan-loss reserves,” to “increase access to affordable housing.” So, having acted to undermine the inherent affordability of manufactured housing, DOE now seeks to impose those costs on American taxpayers in a manner that is wholly inconsistent with both the letter and intent of federal manufactured housing law.

The May 18, 2022 DOE “news” release thus confirms every negative element and consequence of the DOE “final” manufactured housing energy rule previously documented by MHARR (and vindicates MHARR’s consistent opposition to that rule), while seeking to mislead Americans, denigrate manufactured housing and expand homelessness, all in order to peddle baseless and disproven “climate” alarmism. This sham rule, having now been imposed by DOE without any valid basis, and pursuant to an illegitimate and corrupted process, must now be opposed by the industry through all appropriate means including, but not limited to targeted legal action.

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.

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

pdf-images.-2jpg
DOE-updates-mobile-home-efficiency-standards-lower-household-energy-bills.pdf

Washington, D.C., May 24, 2022 – The U.S. Department of Energy (DOE), in a reprehensible news release announcing the publication of its baseless and destructive energy standards for HUD Code manufactured homes (copy attached), resorts to deception and distortion in a futile attempt to rationalize a rule that will needlessly add thousands of dollars to the cost of the nation’s leading source of affordable housing, and simultaneously exclude millions of lower and moderate-income Americans from the manufactured housing market and from homeownership altogether.

The Manufactured Housing Association for Regulatory Reform (MHARR) has been a consistent opponent of these fundamentally-flawed and baseless standards, as well as previous iterations proposed by DOE. Having refuted, moreover, the semblance of any basis whatsoever for such draconian mandates, MHARR once again calls on DOE to withdraw its final manufactured housing energy standards rule and consider significant revisions based on a legitimate process.

For the present, however, unable to legitimately claim that its standards will benefit manufactured homebuyers (or anyone other than its special interest allies), DOE’s deceitful May 18, 2022 “news” release, instead invents a non-existent “strawman” caricature of today’s modern, affordable and energy-efficient manufactured housing, which it proceeds to attack with an assortment of knowingly false and misleading assertions.

Most fundamentally, the DOE “news” release, in its title and elsewhere, intentionally and repeatedly mischaracterizes today’s modern manufactured homes as “mobile homes.” This despite the fact that HUD Code homes, under existing federal law, are specifically denominated and defined as “manufactured homes,” and have been referred-to as “manufactured homes” for decades. Modern, affordable “manufactured homes,” however, as reported by the U.S. Census Bureau, have lower energy consumption costs, on a whole home basis, than other types of homes. Consequently, to bootstrap its outrageous assertions and equally outrageous standards, DOE instead attacks a class of homes that has not existed for decades and that the industry, through hard work and millions of dollars in investment, has successfully surpassed.

Yet another “big lie” inherent in the disgraceful DOE “news” release is its willful failure to address the massive level of market exclusion that will result from purchase cost increases driven by its final standard. The DOE release, in a comment attributed to DOE Secretary, Jennifer Granholm, thus states: “DOE’s new energy efficiency rules will help save 17 million Americans residing in mobile homes up to $475 per year on … their utility bills.” Aside from the fact that significantly more than 17 million Americans currently reside in HUD Code manufactured homes, and the DOE energy standards, by law, have nothing to do with the existing homes owned by those residents, the reality is that millions of Americans who heretofore would have been able to afford and finance a manufactured home, will henceforth be excluded from the market due to the excessive cost and purchase price impact of the DOE standards. For these millions of Americans, quite simply, there will be – and by definition could not be – any utility cost savings whatsoever, because the purchase cost impact of the DOE standards will prevent them from ever being homeowners in the first place. DOE, however, chooses to willfully ignore this fact and intentionally seeks to distract from it in its “news” release.

Worse yet, and as predicted by MHARR, DOE, having now acted to undermine the inherent purchase price affordability of HUD Code manufactured homes, instead calls in its “news” release for at least part of that new cost burden to be borne by American taxpayers. The “news” release notes that DOE supports “legislative and administrative policies” and “the establishment of credit enhancement mechanisms, such as loan-loss reserves,” to “increase access to affordable housing.” So, having acted to undermine the inherent affordability of manufactured housing, DOE now seeks to impose those costs on American taxpayers in a manner that is wholly inconsistent with both the letter and intent of federal manufactured housing law.

The May 18, 2022 DOE “news” release thus confirms every negative element and consequence of the DOE “final” manufactured housing energy rule previously documented by MHARR (and vindicates MHARR’s consistent opposition to that rule), while seeking to mislead Americans, denigrate manufactured housing and expand homelessness, all in order to peddle baseless and disproven “climate” alarmism. This sham rule, having now been imposed by DOE without any valid basis, and pursuant to an illegitimate and corrupted process, must now be opposed by the industry through all appropriate means including, but not limited to targeted legal action.

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.

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

pdf-images.-2jpg
DOE-updates-mobile-home-efficiency-standards-lower-household-energy-bills.pdf

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