MHARR Memo to Manufactured Home Producers, Retailers, Communities – Initial Comments On Proposed DOE Manufactured Housing “Energy” Standards
Attached, for your information, are initial comments submitted by the Manufactured Housing Association for Regulatory Reform (MHARR) to the federal Manufactured Housing Consensus Committee (MHCC) in connection with the MHCC’s upcoming September 23, 2021 meeting to consider – and provide comments on – the latest U.S. Department of Energy (DOE) proposed “energy conservation” standards for manufactured housing. The September 23, 2021, meeting will be the first in a series of three scheduled MHCC conference calls to address the proposed DOE standards, which were published in the Federal Register on August 26, 2021. The subsequent MHCC meetings are currently slated to be held on October 8, 2021 and October 20, 2021, just five days ahead of the current DOE comment deadline of October 25, 2021.
Given the compressed MHCC timetable necessitated by the current 60-day DOE comment deadline, MHARR’s initial comments address principally policy and cost issues arising from the DOE proposal which – like its earlier 2016 proposed manufactured housing energy standards rule – would impose destructive, unnecessary and discriminatory cost burdens on both manufactured homebuyers and the industry, with particularly damaging and disproportionate impacts on smaller industry businesses. Further comments that MHARR plans to submit in connection with the scheduled October MHCC meetings – as well as its comprehensive comments to DOE – will address other and additional aspects of the proposed rule, including technical aspects of various proposed provisions.
In light of the likely severe impacts of this proposed rule on both the industry and consumers, MHARR – again – urges all industry members to submit individual comments to both the MHCC and, even more importantly, to DOE, opposing this regulatory overreach, in advance of the comment deadline. To facilitate such comments, MHARR will continue to make its comments available to the entire industry in advance of the relevant MHCC and DOE deadlines.
MHARR Memo to Manufactured Home Producers, Retailers, Communities – Initial Comments On Proposed DOE Manufactured Housing “Energy” Standards
Attached, for your information, are initial comments submitted by the Manufactured Housing Association for Regulatory Reform (MHARR) to the federal Manufactured Housing Consensus Committee (MHCC) in connection with the MHCC’s upcoming September 23, 2021 meeting to consider – and provide comments on – the latest U.S. Department of Energy (DOE) proposed “energy conservation” standards for manufactured housing. The September 23, 2021, meeting will be the first in a series of three scheduled MHCC conference calls to address the proposed DOE standards, which were published in the Federal Register on August 26, 2021. The subsequent MHCC meetings are currently slated to be held on October 8, 2021 and October 20, 2021, just five days ahead of the current DOE comment deadline of October 25, 2021.
Given the compressed MHCC timetable necessitated by the current 60-day DOE comment deadline, MHARR’s initial comments address principally policy and cost issues arising from the DOE proposal which – like its earlier 2016 proposed manufactured housing energy standards rule – would impose destructive, unnecessary and discriminatory cost burdens on both manufactured homebuyers and the industry, with particularly damaging and disproportionate impacts on smaller industry businesses. Further comments that MHARR plans to submit in connection with the scheduled October MHCC meetings – as well as its comprehensive comments to DOE – will address other and additional aspects of the proposed rule, including technical aspects of various proposed provisions.
In light of the likely severe impacts of this proposed rule on both the industry and consumers, MHARR – again – urges all industry members to submit individual comments to both the MHCC and, even more importantly, to DOE, opposing this regulatory overreach, in advance of the comment deadline. To facilitate such comments, MHARR will continue to make its comments available to the entire industry in advance of the relevant MHCC and DOE deadlines.
