AUGUST 11, 2025
TO: MHARR MANUFACTURERS
MHARR STATE AFFILIATES
MHARR TECHNICAL REVIEW GROUP (TRG)
FROM: MHARR
RE: MHARR REITERATES CALL FOR WITHDRAWAL OF DOE “ENERGY” STANDARDS AND REGULATIONS FOR MANUFACTURED HOMES
As a follow-up to its July 1, 2025 meeting with U.S. Department of Energy (DOE) Principal Deputy Assistant Secretary for Energy Efficiency and Renewable Energy, Lou Hrkman, where it called (as it has consistently) for the withdrawal and repeal of DOE’s May 31, 2022 “energy conservation” standards and December 26, 2023 proposed enforcement regulations, MHARR in an August 7, 2025 communication to DOE Secretary Chris Wright (copy attached), has cited yet another specific and compulsory basis for the repudiation of those destructive and illegitimate mandates.
Following a complete review and analysis, MHARR, in that communication, asserts that the DOE manufactured housing energy standards (and related proposed regulations) must be withdrawn in accordance with guidance issued by the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB), implementing President Trump’s disavowal of the Social Cost of Carbon (SCC) construct.
Under that guidance, mandatory cost-benefit analyses of federal regulations, required by statute and/or presidential executive orders, cannot rely upon or include consideration of SCC metrics. As stated in the guidance, “this is because the uncertainties in performing monetized impacts quantifications are too great. Use of monetized impact quantifications would … result in flawed decision making due to overreliance on balancing highly uncertain dollar figures against more concrete costs and benefits that can be appropriately quantified.”
And that is exactly what occurred with the DOE manufactured housing standards (and regulations). In that case, SCC metrics were applied in DOE’s cost-benefit analyses to offset specific and concrete cost impacts on manufactured housing consumers, as was conceded by DOE itself in federal court litigation challenging the validity of the SCC metric (Louisiana v. Biden, 2:21-cv-01074, W.D. La. 2022). Given that admission, DOE cannot try to claim now that the SCC metrics were somehow not applied to the manufactured housing energy standards and enforcement regulations.
As a result, the DOE standards (and proposed enforcement regulations) violate the OIRA guidance and must be totally withdrawn, not just delayed, as DOE has done thus far.
MHARR will continue to follow-up on this matter and will keep you apprised of further developments as warranted.
cc: Other Interested HUD Code 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
