NOVEMBER 12, 2024
TO: HUD CODE MANUFACTURD HOUSING INDUSTRY MEMBERS
FROM: MHARR
RE: MHARR CALLS FOR URGENT ACTION BY PRESIDENT TRUMP
TO WITHDRAW AND REPEAL DOE MH ENERGY REGULATIONS
Upon the election of Donald J. Trump as the 47th President of the United States, the Manufactured Housing Association for Regulatory Reform (MHARR) has taken immediate action, urging the President and his transition team to prioritize the repeal and withdrawal of pending U.S. Department of Energy (DOE) manufactured housing “energy” regulations that would needlessly undermine the inherent affordability of mainstream HUD Code manufactured homes.
In a November 7, 2024 communication to the President-Elect (copy attached), MHARR states: “… it is imperative that your new Administration take action at the earliest possible date to prevent the implementation of the pending DOE manufactured housing “energy” standards and withdraw or repeal those standards.”
MHARR’s communication stresses that a repeal of the pending 2022 manufactured housing energy standards and 2024 proposed enforcement procedures rule is not only essential for the continued affordability of mainstream manufactured housing, but would be fully consistent with President Trump’s withdrawal of an earlier iteration of the DOE manufactured housing “energy” standards upon assuming office for his first term in 2017. Such an action by the incoming administration would potentially moot the need for further litigation against the DOE rule in the pending federal court case.
Because of the fundamental importance of this issue to the entire industry – and consumers of HUD Code manufactured housing as well – MHARR strongly urges and encourages all industry members and all state associations in particular, to join in the effort to encourage President Trump to repeal and withdraw these destructive pending regulations before they can inflict real and irreparable damage on both the industry and consumers. Simply put, at a time when homeownership is increasingly out of reach for lower and moderate-income Americans, and younger Americans in particular, the availability of affordable homeownership via manufactured housing should not be mortally wounded by needless, unnecessary regulation driven by climate extremists and their allied special interests.
For its part, MHARR will continue to take strong action to oppose the DOE standards and remove and eliminate the threat that they pose to both the industry and American consumers of affordable housing.
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November 7, 2024
VIA FEDERAL EXPRESS AND FIRST-CLASS MAIL
Hon. Donald J. Trump
President-Elect
1100 S. Ocean Boulevard
Palm Beach, Florida 33480
Re: Urgent Manufactured Housing Transition Issue
Dear President Trump:
On behalf of the Manufactured Housing Association for Regulatory Reform (MHARR) and its members, please accept our congratulations on your election as the 47th President of the United States.
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). MHARR’s members – like the vast majority of the manufactured housing industry – are primarily smaller businesses.
We are writing to inform you of an urgent, time-sensitive regulatory issue affecting our industry, that we hope your incoming administration will address and resolve on an expedited basis.
Specifically, the Biden Administration, through the U.S. Department of Energy (DOE), is on the verge of implementing destructive “energy conservation” regulations for manufactured homes that will destroy the inherent affordability of the industry’s mainstream homes. At a time when the cost of homeownership is at record highs, when the supply of affordable homes (and particularly affordable “starter” homes) is millions of units below existing demand, and the number of first-time homebuyers stands at a record low due, in substantial part, to home price inflation, the implementation of these new “climate change” standards – which would needlessly add thousands of dollars to the retail cost of new manufactured homes – would price hundreds-of-thousands of lower and moderate-income manufactured homebuyers out of the market (and out of homeownership altogether) while delivering a death blow to many industry businesses and smaller businesses in particular.
It is important to stress that these impending standards – an earlier iteration of which was rejected and withdrawn by your first Administration in 2017 – would not only be economically disastrous, but are also totally unnecessary. As MHARR has consistently demonstrated in the DOE rulemaking proceedings that culminated in the rejected 2016/2017 proposed rule and the impending 2022 final rule, manufactured housing energy consumption costs for homeowners and renters, according to official U.S. Census Bureau data, are already (and long have been) lower than or equal to those for other more costly types of housing.
Consequently, the impending DOE standards do not respond to or address any proven consumer need or any legitimate alleged deficiency in today’s modern manufactured housing, but instead are a product of the phony “climate change” agenda and represent an effort by “climate change” extremists to insinuate their destructive demands within the multi-billion dollar housing market by first infecting the comprehensively federally-regulated manufactured housing sector as a regulatory “Trojan Horse.”
While the manufactured housing industry faces other headwinds that are preventing it from truly fulfilling its enormous potential to help solve the nation’s affordable housing crisis – including discriminatory zoning exclusion and a complete lack of federal support for the manufactured housing consumer finance market in violation of existing law – all issues that we will seek to address and rectify with your Administration in due course, it is imperative that your new Administration take action at the earliest possible date to prevent the implementation of the pending DOE manufactured housing “energy” standards and withdraw or repeal those standards. Materials providing additional relevant details regarding the DOE standards are attached for your reference.
On behalf of MHARR and its member manufacturers, we appreciate your attention to this matter and look forward to working with your incoming Administration to Make America Great Again.
Thank you and please accept our best wishes.
Sincerely,
Mark Weiss
President & CEO
cc: Ms. Linda McMahon
Mr. Howard Lutnick
Hon. Mike Johnson
Hon. Patrick McHenry
Hon. Tim Scott
Mr. Danny Ghorbani (MHARR Founding President and CEO)
MHARR Manufacturers
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