MHARR Succeeds in Getting Extension For Energy Rule Comments From DOE

MHARR Succeeds in Getting Extension For Energy Rule Comments From DOE

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The U.S. Department of Energy (DOE), in a notice issued on October 20, 2021 see, copy attached has granted an MHARR request for an extension of the deadline for the submission of written comments in connection with DOE’s August 26, 2021 Supplemental Notice of Proposed Rulemaking (SNPR) concerning manufactured housing energy conservation standards.

The original deadline for comments as published in the SNPR was August 26, 2021.  MHARR, however, in a September 24, 2021 request to DOE Secretary Jennifer Granholm, requested an extension of the deadline in order to allow stakeholders to address the “complex and multi-faceted” issues raised by the SNPR and its proposed rule, based on the 2021 International Energy Conservation Code (IECC).  With the extension being granted by DOE, final comments on the proposed manufactured housing energy rule will now be due by November 26, 2021. In addition, the DOE Notice also includes a pre-publication Notice of Data Availability (NODA) with respect to the August 26, 2021 proposed rule, allegedly incorporating “updated analyses and results.” A copy of the NODA can be accessed through a link contained in the notice.

With this extension of the DOE comment period now obtained, MHARR will redouble its efforts for the remainder of this week and over the coming weekend, to fully-complete its  comprehensive comments opposing the proposed rule as fatally-flawed and unduly costly, to submit to DOE on October 25, 2021. It will then prepare further, additional and supplemental comments addressing such other and further issues as are necessary and appropriate, prior to the extended November 26, 2021 deadline – thus providing MHARR, industry members and the public a “second bite” at this atrocious proposal and corresponding mandate that MHARR has been fighting now for 14 years. Indeed, MHARR has been the only industry representative to oppose DOE manufactured housing energy standards consistently since day-one.

This latter point is particularly important as industry members appear to now understand the extreme damage that this proposed rule would do to the industry and to the lower and moderate-income consumers who rely on affordable manufactured housing. That damage has been consistently and fully-documented by MHARR in its comments and continuing opposition to this DOE action, as well as the effort by part of the industry in 2014 to subject this entire matter to a tainted DOE “negotiated rulemaking” process that ever since has been an albatross for the industry and the interests of industry members.

MHARR will provide industry members with a copy of its comprehensive (and consistent) comments early next week and encourages industry members to utilize these comments in connection with their own submissions to DOE.

Attachment

pdf-images.-2jpg
doeextensionnotice.pdf

The U.S. Department of Energy (DOE), in a notice issued on October 20, 2021 see, copy attached has granted an MHARR request for an extension of the deadline for the submission of written comments in connection with DOE’s August 26, 2021 Supplemental Notice of Proposed Rulemaking (SNPR) concerning manufactured housing energy conservation standards.

The original deadline for comments as published in the SNPR was August 26, 2021.  MHARR, however, in a September 24, 2021 request to DOE Secretary Jennifer Granholm, requested an extension of the deadline in order to allow stakeholders to address the “complex and multi-faceted” issues raised by the SNPR and its proposed rule, based on the 2021 International Energy Conservation Code (IECC).  With the extension being granted by DOE, final comments on the proposed manufactured housing energy rule will now be due by November 26, 2021. In addition, the DOE Notice also includes a pre-publication Notice of Data Availability (NODA) with respect to the August 26, 2021 proposed rule, allegedly incorporating “updated analyses and results.” A copy of the NODA can be accessed through a link contained in the notice.

With this extension of the DOE comment period now obtained, MHARR will redouble its efforts for the remainder of this week and over the coming weekend, to fully-complete its  comprehensive comments opposing the proposed rule as fatally-flawed and unduly costly, to submit to DOE on October 25, 2021. It will then prepare further, additional and supplemental comments addressing such other and further issues as are necessary and appropriate, prior to the extended November 26, 2021 deadline – thus providing MHARR, industry members and the public a “second bite” at this atrocious proposal and corresponding mandate that MHARR has been fighting now for 14 years. Indeed, MHARR has been the only industry representative to oppose DOE manufactured housing energy standards consistently since day-one.

This latter point is particularly important as industry members appear to now understand the extreme damage that this proposed rule would do to the industry and to the lower and moderate-income consumers who rely on affordable manufactured housing. That damage has been consistently and fully-documented by MHARR in its comments and continuing opposition to this DOE action, as well as the effort by part of the industry in 2014 to subject this entire matter to a tainted DOE “negotiated rulemaking” process that ever since has been an albatross for the industry and the interests of industry members.

MHARR will provide industry members with a copy of its comprehensive (and consistent) comments early next week and encourages industry members to utilize these comments in connection with their own submissions to DOE.

Attachment

pdf-images.-2jpg
doeextensionnotice.pdf

 

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