JULY 27, 2026
TO: HUD CODE MANUFACTURED HOUSING INDUSTRY MEMBERS
FROM: MHARR
RE: MHI / ROAD ACT SNATCH DEFEAT FROM JAWS OF VICTORY
REGARDING MANUFACTURED HOUSING ENERGY STANDARDS
Urged on by the Manufactured Housing Institute (MHI) in order to comply with a supposed requirement of the MHI-supported 21st Century ROAD to Housing Act (ROAD Act) – which became law without the signature of President Trump on July 11, 2026 – the Manufactured Housing Consensus Committee (MHCC), at a hastily-called July 23, 2026 “virtual” meeting, voted to recommend to HUD, without significant change and with no consideration of present-day cost or anti-competitive impacts, recommendations for manufactured home “energy conservation” standards first developed by the MHCC in 2022 under the gun of the then-looming May 31, 2022 draconian U.S. Department of Energy (DOE) manufactured housing “energy conservation” standards.
While the ROAD Act, to some degree (although not completely), abated the immediate threat of the May 31, 2022 DOE standards by providing that any energy efficiency standards for manufactured homes adopted by a federal agency other than HUD can have no legal effect “unless and until adopted by HUD,” the same law inexplicably requires HUD to “not later than 1 year after enactment of” the ROAD Act, “adopt minimum energy efficiency standards for manufactured homes” and, further, to “update those standards” no “less frequently than once every 3 years” thereafter. Why MHI – as an erstwhile “industry” organization —would have supported such a foreseeably costly and discriminatory mandate, singling out manufactured homes for disproportionately harsh regulation compared to other types of homes, is utterly inexplicable on any legitimate grounds.
Nevertheless, based on this ROAD Act provision, MHI, at the meeting, pushed the MHCC and HUD to move forward with the 2022 MHCC recommendations. Those recommendations, developed essentially as an alternative to the horrific DOE standards, nevertheless incorporate, in multiple provisions, elements of the DOE “final” manufactured housing energy standards, and were approved by the MHCC with no specific, evidence-based analysis or consideration of their likely cost and market impacts.
Worse yet, the July 23, 2026 vote to advance those standards to HUD also came with no consideration whatsoever of their present-day consumer purchase price or market impacts, contrary to the express mandate of the Manufactured Housing Improvement Act of 2000, that both HUD AND THE MHCC consider the cost impact of any recommended standard.
MHARR at the meeting and in written comments filed in advance of the meeting, strenuously opposed the summary bootstrapping of the 2022 standards developed by the MHCC under duress and instead urged the MHCC to revisit the energy standards issue from the “ground up” — free from the threat of the looming disastrous DOE standards, and to conduct a full cost-benefit analysis of any new or further standards that it recommended.
MHARR made this recommendation in light of Executive Order 14394, “Removing Regulatory Barriers to Affordable Home Construction,” issued by President Trump in March 2026 (EO). That EO directs the Secretary of HUD and the Secretary of Energy to, among other things, “reform and, where appropriate, eliminate unduly burdensome or costly energy-efficiency … requirements regarding housing, including manufactured housing. *** Such action shall include … the Energy Conservation Program’s Energy Conservation Standards for Manufactured Housing.” (Emphasis added).
MHARR asserted in its written comments and in verbal statements at the meeting, that the Committee should not be considering any new or further energy standards that would increase the acquisition cost of manufactured homes, particularly at a time when the nation faces an unprecedented shortage of affordable new homes.
MHI, by contrast, urged the Committee to effectively rubber-stamp the 2022 MHCC recommendations made under the threat and duress of a truly destructive DOE “final” energy standard, with no further consideration of either present-day cost impacts on consumers, possible market exclusion due to acquisition price increases and also potential anti-competitive impacts of such new and additional standards, especially to smaller, independent HUD Code producers. As has been demonstrated by U.S. Small Business Administration (SBA) research, smaller business entities are disproportionately impacted by additional regulatory costs and burdens. Under pressure from MHI, however, the MHCC fell in line.
In part, the MHCC’s failure to act as a bulwark against new and excessive regulation, at a time when the Trump Administration is actively seeking to reduce regulatory burdens and promote the availability of affordable housing, is a function of years of HUD manipulation of the composition of the MHCC – excluding MHARR staff representatives and tightly restricting non-MHI small industry business representation – while simultaneously prohibiting MHARR participation in MHCC debates while such debates are in progress. This, together with repeated appointments of the same members – over and over again — has reduced the MHCC to a clone of the hapless, toothless and irrelevant Manufactured Housing Advisory Council established by the original National Manufactured Housing Construction and Safety Standards Act of 1974, rather than the legitimate, independent body envisioned by the 2000 Reform Law. Indeed, HUD has even appointed Committee members with no apparent connection to manufactured housing, who appear to actually be COMPETITORS of industry members.
This debasement of the MHCC and the diversion of its mission and function to be a rubber-stamp for HUD and/or the interests of the industry’s largest corporate conglomerates – and its parallel manipulation – will ultimately erase the gains that the industry has made over the course of decades, including those of the 2000 Reform Law. Indeed, much of the broader industry has been silent as HUD has failed to fully and properly implement certain key reforms of that law, including enhanced federal preemption. But rather than demand remedies to those failure – either by HUD itself or through corrective legislation – MHI appears to be fixated on promoting and advancing the industry’s most costly homes, rather than its traditional, affordable core.
ALL of this is UNACCEPTABLE, and will be aggressively dealt with by MHARR at appropriate levels and by appropriate means going forward.
cc: Other Interested Affordable Housing Proponents
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
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.
MHARR’s report is 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.
— Featured image was generated by artificial intelligence using ChatGPT. The text was written using human intelligence. —
