June 2, 2025
TO: MHARR MANUFACTURERS
MHARR STATE AFFILIATES
MHARR TECHNICAL REVIEW GROUP (TRG)
FROM: MHARR
RE: MHARR CONTINUES TO ADDRESS CRITICAL INDUSTRY ISSUES
The Manufactured Housing Association for Regulatory Reform (MHARR) continues to address critical manufactured housing industry issues with disproportionate potential impacts for smaller industry businesses.
MHARR, in recent days, has engaged with Congress extensively regarding multiple pending and draft bills that could have serious repercussions if not addressed and corrected properly.
Most recently, MHARR held meetings in the House of Representatives regarding draft bills that:
(1) would make optional the current “permanent chassis” requirement; and
(2) require the approval of the HUD Secretary for manufactured housing standards (such as the U.S. Department of Energy – DOE- manufactured housing “energy conservation” standards) emanating from a federal agency other than HUD.
While MHARR supports the purpose and intent of each of these bills, it nevertheless has serious concerns with certain aspects of their language that could potentially undermine those beneficial purposes for both the industry and consumers.
Accordingly, MHARR advised the House subcommittee considering these bills, that the Association will soon submit proposed language to correct these issues and ensure that the final bills will not have negative side-effects and/or other deficiencies.
MHARR will continue to keep members and the broader industry advised of its activities on these and other pending legislative matters.
On a related matter, MHARR was present in federal court in the Western District of Texas on May 28, 2025, as the court held a status conference in the litigation over the pending DOE May 31, 2022 manufactured housing “energy conservation” standards.
Although DOE has already indicated that the implementation of these standards will be delayed beyond their originally-scheduled dates, the principal revelation to emerge from the judicial status conference is that DOE now plans to re-open (within the next 90 days), the rulemaking on the energy standards themselves, in order to receive further public comment and input on their substance.
While this is a positive development and MHARR will submit further comments on the standards emphasizing their lack of any positive cost-benefit for manufactured housing consumers, MHARR will also continue to seek the total withdrawal and repudiation of the May 31, 2022 standards by both DOE and HUD.
As it has continually, MHARR will closely monitor all of these proceedings and take further steps to protect, defend and advance the interests of smaller industry businesses.
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
