Washington, D.C. JULY 14, 2026.
TO: HUD CODE MANUFACTURED HOUSING INDUSTRY MANUFACTURERS
FROM: MHARR
RE: MHARR CALLS ON MHCC TO SHELVE ANY NEW OR
FURTHER MANUFACTURED HOUSING “ENERGY” STANDARDS
Following the July 8, 2026 publication of a Federal Register notice of an upcoming July 23, 2026 Manufactured Housing Consensus Committee (MHCC) meeting to consider and address “the Energy Conservation Standards for Manufactured Housing” (emphasis added), MHARR has filed written comments with the MHCC (copy attached) urging it to reject any new, further or additional (discriminatory) “energy” standards for HUD-regulated manufactured homes.
While the MHCC meeting notice itself is unclear and ambiguous as to which – or what – manufactured housing “energy” standards the MHCC will be asked to consider (e.g., either the May 31, 2022 U.S. Department of Energy (DOE) “final” standards that the MHCC has previously rejected, or some other set of not-previously-disclosed or published proposed standards), MHARR’s comments assert that any such standards – regardless of their source or derivation – must be rejected by the MHCC (and by HUD), based specifically on President Trump’s Executive Order (EO) 14394, “Removing Regulatory Barriers to Affordable Home Construction,” issued on March 13, 2026.
That EO, in relevant part, directs the Secretary of HUD and the Secretary of DOE, to “eliminate unduly burdensome or costly energy-efficiency … requirements regarding housing, including manufactured housing, to the maximum extent practicable … [including] … Energy Conservation Standards for Manufactured Housing.” (Emphasis added).
What this EO makes clear – and as MHARR asserts in its written comments – is that at a time when there is an unprecedented national shortage of affordable homes numbering in the millions of units, neither HUD nor any other federal agency should be adopting, developing or even considering the development or adoption of new, further, or additional “energy” standards that would needlessly add to the purchase cost of new homes and exclude even more Americans from all of the multiple benefits of homeownership.
While this should have been made crystal clear in the 21st Century ROAD to Housing Act (legislation fully embraced by the Manufactured Housing Institute) that just became law without President Trump’s signature – it is not – in that the ROAD Act fails to either per se eliminate the May 31, 2022 “final” DOE manufactured housing energy standards or revoke their statutory basis (i.e., section 413 of the Energy Independence and Security Act of 2007). Meanwhile, a separate bill filed by Rep. Erin Houchin (R-IN) which would have definitively revoked and repealed both those DOE standards and their statutory basis, has been “compromised” into near total irrelevance by unknown groups or persons, effectively leaving both the industry and consumers at the mercy of HUD/DOE regulators and energy/climate extremists going forward.
Thus, despite the fact that the MHCC meeting notice is impermissibly and misleadingly vague and ambiguous – and apparently deliberately so – there is absolutely no basis under EO 14394, for the MHCC to be considering any new or further energy standards that would needlessly increase the acquisition cost of HUD-regulated manufactured homes.
In accordance with these comments, MHARR will strongly object to the discussion, consideration or debate of any new or further manufactured housing energy standards at this time. MHARR similarly encourages all HUD Code manufacturers to file comments with the MHCC opposing the development or consideration of any such new or further discriminatory manufactured home energy standards going forward.
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
— Text from attachment. —
July 13, 2026
VIA FEDERAL EXPRESS AND ELECTRONIC SUBMISSION
Manufactured Housing Consensus Committee
C/O Home Innovation Research Labs
Administering Organization
400 Prince George’s Boulevard
Upper Marlboro, Maryland 20774
Re: Manufactured Housing Consensus Committee Meeting July 23, 2026
Energy Conservation Standards for Manufactured Housing
Dear Members of the Manufactured Housing Consensus Committee:
The Manufactured Housing Association for Regulatory Reform (MHARR) submits the following comments in connection with the Manufactured Housing Consensus Committee’s (MHCC) consideration of certain “Energy Conservation Standards for Manufactured Housing” as set forth in a U.S. Department of Housing and Urban Development (HUD) Federal Register notice published on July 8, 2026.[1] That notice states, in relevant part, that the “tentative agenda” for the meeting will include a “review” of “the Energy Conservation Standards for Manufactured Housing.”[2] (Emphasis added). The said notice – affirmatively required by statute[3] – does not further elaborate for the information of regulatory stakeholders, other interested parties, or the public, exactly which (or what) “Energy Conservation Standards for Manufactured Housing” are being referred to. This and other more fundamental failures pertaining to this action are addressed in detail below. Ultimately, however – and in accordance with Executive Order 14394, “Removing Regulatory Barriers to Affordable Home Construction”[4] — the MHCC should reject the development and/or adoption of any new or further manufactured housing energy standards absent a specific, compelling and detailed showing by HUD of the need for any such standards at the time of an unprecedented shortage of affordable housing and homeownership.
COMMENTS
- THE MEETING NOTICE FAILS TO PROVIDE INTERESTED
PARTIES A VALID AND LEGITIMATE OPPORTUNITY TO COMMENT
As a federal advisory committee subject to the Federal Advisory Committees Act (FACA)[5], the MHCC plays an important and vital role in the development and review of HUD Manufactured Housing Construction and Safety Standards. In that role, the MHCC must have access to and must receive and consider the views, interests and concerns of all affected stakeholders and the public at large, In order to ensure that federal advisory committees such as the MHCC can receive and consider such input at a relevant stage – and in a relevant manner – during its proceedings, federal regulations issued pursuant to FACA require, among other things, that an agency conducting such a meeting, provide:
“(a) A notice in the Federal Register [which] must be published at least 7 calendar days prior to an advisory committee meeting, which includes: ***
(4) A summary of the agenda, and/or topics to be discussed and instructions on how to access meeting materials.”
In the case of the present MHCC meeting, the notice provided in the July 8, 2026 Federal Register is wholly and completely inadequate to meet the requirements and purpose of this mandate.
The FACA regulations are clearly designed to allow stakeholders, interested parties and the public a legitimate and valid opportunity to comment — in advance and at the time of the meeting – on the subject matter that will be addressed by the federal advisory committee in question, in this case the MHCC. The publication of a meeting notice, however, referencing only “the Energy Conservation Standards for Manufactured Housing,” without further specifying whether those standards are the U.S. Department of Energy (DOE) “final” standards published on May 31, 2022, or some other alleged “standards” that have not previously been published, proposed or provided to the public, is to effectively provide no notice at all, and is a is a de facto and de jure denial of the Due Process (and statutory) right of stakeholders and other interested parties to comment.
Accordingly, the ambiguity of the purported MHCC meeting notice and its failure to properly identify the specific subject matter to be addressed at the meeting is a fatal flaw and defect in this proceeding and MHARR reserves its right to pursue all applicable legal remedies to address this deliberate violation of FACA, federal manufactured housing law and Due Process.
- THERE IS NO VALID OR LEGITIMATE BASIS FOR HUD TO CONSIDER ANY
NEW OR FURTHER ENERGY MANDATES FOR MANUFACTURED HOMES
While the Federal Register notice for the July 23, 2026 MHCC meeting is fatally ambiguous and deficient in that it fails to identify which – or what – manufactured housing “Energy Conservation” standards the MHCC will be “considering” at its meeting, that failure, ultimately, is substantively irrelevant, insofar as neither the MHCC nor HUD should be considering any new or further manufactured housing construction and safety standards regarding “energy conservation” absent a specific and compelling showing of need and cost-justification in the context of a multi-million unit affordable housing shortage. And no such showing has been made – or could be made.
Any action by either the MHCC or HUD to consider new or further energy conservation standards for manufactured homes, is subject to the directives set out by President Trump in Executive Order 14394, “Removing Regulatory Barriers to Affordable Home Construction,” issued on March 13, 2026 (EO). That EO states, in relevant part:
“Layers of unnecessary regulatory barriers … and onerous mandates at all levels of government have … driven up the costs of new housing. These constraints have made housing less affordable for many Americans. It is the policy of my Administration to reduce regulatory barriers to building homes and to … promot[e] housing affordability.”
(Emphasis added).
And so as to leave no doubt whatsoever that this directive includes and embraces manufactured home energy conservation standards, EO 14394 further states, specifically:
“[T]he Secretary of Housing and Urban Development [and] the Secretary of Energy … shall, within their respective authorities, take appropriate action to reform and, where appropriate, eliminate unduly burdensome or costly energy-efficiency … requirements regarding housing, including manufactured housing, to the maximum extent practicable…. Such action shall include … (i) the Energy Conservation Program’s Energy Conservation Standards for Manufactured Housing.”
(Emphasis added).
From this EO, it is clear that instead of reviewing, developing or considering the development and/or adoption of new or further manufactured home energy standards, any such development activity should be terminated and abandoned and the MHCC should not be presented with or asked to consider any such new or further standards. This includes not only the moribund and officially-deferred DOE May 31, 2022 “final” manufactured home energy standards, but also the development of any possible new or further HUD Manufactured Housing Construction and Safety Standards pertaining to “energy conservation” absent a compelling and evidentiary-based showing of need – of which there has been none.
Any action by HUD – via the Office of Manufactured Housing Programs (OMHP) or otherwise – to advance any such standards would violate EO 14394 and would be aggressively opposed through any and all means necessary by MHARR.
Instead of allowing program-level personnel to violate and undermine the public policy priorities of President Trump designed to foster the availability and utilization of affordable housing and promote homeownership – the same federal purposes as the Manufactured Housing Improvement Act of 2000[6] — HUD Secretary Scott Turner should and must ensure that needless, unnecessary and discriminatory high-cost energy regulations are not imposed on HUD-regulated manufactured housing. In this respect, Secretary Turner should act in a manner consistent with the policy model set by DOE Secretary Chris Wright who, consistent with EO 14394, has acted in recent weeks: (i) to repudiate the 2024 International Energy Conservation Code (IECC) – and earlier iteration of which forms the basis and underpinning for the May 31, 2022 “final” DOE manufactured housing “energy” standards; and (ii) to “permanently end” unnecessary energy mandates for home appliances and equipment.
Rather than allowing President Trump’s goal of housing affordability and availability to be undermined by OMHP, HUD Secretary Turner – and the MHCC – must ensure that inherently affordable manufactured homes and homebuyers are not needlessly burdened and excluded from homeownership by baseless, unnecessary, discriminatory and unduly onerous fraudulent “energy” mandates.
This same analysis applies, moreover, regardless of whether the present MHCC meeting has been noticed for further consideration of the DOE standards or for consideration of some other – as yet undisclosed – proposed energy mandates.
CONCLUSION
For all of the foregoing reasons, the MHCC should – and must – reject any new and/or further HUD manufactured housing “energy conservation” standards that: (i) are identical to or in any way derived from, based upon, or in any way related to the “final” DOE manufactured housing energy conservation standards published on May 31, 2022; or (ii) have not been developed in toto, and from the outset, through an independent, legitimate and consensus-based statutory development process based on specific, credible evidence regarding the purchase price, market and competitive impacts of any such standards. Instead, in accordance with Executive Order 14394, the MHCC should reject the imposition of any new or further unnecessary and costly energy mandates on manufactured homes via the HUD Code unless and until a valid and legitimate cost-justified basis for any such new or further standards is demonstrated with valid, credible and compelling evidence.
While the MHCC, at its January 2026 meeting, (again) rejected the DOE May 31, 2022 manufactured housing energy standards stating:
“The most constructive path forward is for HUD and the MHCC to develop energy efficiency improvements that are specifically designed for manufactured housing that account for the unique aspects of factory-built construction, that preserve the affordable housing mission of the industry and … maintain reasonable consumer choice,”[7]
those comments were made prior to the issuance of EO 14394 and its specific directive to “eliminate” “to the maximum extent practicable” “unduly burdensome or costly” energy-efficiency requirements regarding housing, specifically including “Energy Conservation Standards for Manufactured Housing.”
In accordance with EO 14394, neither the MHCC nor HUD should be developing, considering, evaluating or adopting any new “energy conservation” standards that would needlessly increase the purchase acquisition costs of manufactured housing during an unprecedented affordable housing crisis. Any such effort to impose unnecessary new or further regulations on manufactured homes should be fully and completely rejected.
Sincerely,
Mark Weiss
President and CEO
cc: Hon. Donald J. Trump
Hon. Scott Turner
Hon. Scott Bessent
Hon. Kelly Loeffler
Hon. Russell Vought
HUD Code Manufactured Housing Industry Manufacturers
[1] See, 91 Federal Register No.129, (July 8, 2026), “Notice of a Federal Advisory Committee Meeting: Manufactured Housing Consensus Committee (MHCC)” at p. 42210.
[2] Id.
[3] See, 42 U.S.C. 5403(a)(3)(G)(i): “The consensus committee shall provide advance notice of each meeting of the consensus committee … and cause to be published in the Federal Register advance notice of each such meeting.” Further, pursuant to 42 U.S.C. 5403(a)(3)(A)(iv), the MHCC is deemed a federal advisory committee subject to the Federal Advisory Committees Act.
[4] See, 91 Federal Register, No. 52, (March 15, 2026) “Removing Regulatory Barriers to Affordable Home Construction” at p. 13207, et seq., attached hereto.
[5] See, 5 U.S.C. App. 1001, et seq.
[6] See, 42 U.S.C. 5401(b)(2): “The purposes of this chapter are — *** (2) to facilitate the availability of affordable manufactured homes and to increase homeownership for all Americans.
[7] See, Meeting Minutes, Manufactured Housing Consensus Committee, January 27 & 28, 2026, Appendix C at p. 2.
— Featured image was generated by artificial intelligence ChatGPT. The text was written using human intelligence. —
