MHARR Supplemental Comments Urge MHCC to Intensify Opposition to DOE Energy Rule

MHARR Supplemental Comments Urge MHCC to Intensify Opposition to DOE Energy Rule

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Comments submitted to the statutory Manufactured Housing Consensus Committee (MHCC) by the Manufactured Housing Association for Regulatory Reform (MHARR) see, copy attached urge the MHCC to redouble its already-stated opposition to the proposed manufactured housing “energy conservation” rule published by the U.S. Department of Energy (DOE) on August 26, 2021 and a related Notice of Data Availability (NODA) published on October 26, 2021.

MHARR’s comments to the MHCC concerning the DOE NODA, filed on November 12, 2021, are in advance of an MHCC meeting scheduled for November 19, 2021, to consider additional information and analysis set forth in the NODA, allegedly in further support of the DOE-proposed energy standards that could add more than $12,000 to the retail cost of a new double-section manufactured home, without even considering the cost impact of new and additional testing, enforcement and regulatory compliance requirements that would be necessitated by the new standards.

MHARR, for its part, has consistently opposed DOE energy standards for manufactured homes since the matter was first broached in 2007 (the only industry organization to do so), as representing an unnecessary, destructive and discriminatory burden on lower and moderate-income Americans that will needlessly exclude millions of potential purchasers from the manufactured housing market and from homeownership (with all of its attendant benefits) altogether.

In addition to the comments provided to the MHCC on the October 26, 2021 NODA, MHARR will also file separate supplemental comments with DOE to address the specific assertions set forth in the NODA. Those comments will be filed, as usual, in advance of the November 26, 2021 comment deadline and made available to industry members for use or reference in their own comments.

As it has previously, MHARR urges other industry organizations and members to submit their own comments in opposition to the DOE proposed rule and NODA as a needless, destructive and extreme act of regulatory overreach. Ultimately, however, as MHARR has emphasized previously, court action by the industry may be necessary to stop this baseless attack on the industry’s homes and American consumers of affordable housing – an attack that threatens to eliminate mainstream, affordable manufactured housing as it exists today.

Attachment

pdf-images.-2jpg
mharr.mhccdoenov12.2021comments.pdf

Comments submitted to the statutory Manufactured Housing Consensus Committee (MHCC) by the Manufactured Housing Association for Regulatory Reform (MHARR) see, copy attached urge the MHCC to redouble its already-stated opposition to the proposed manufactured housing “energy conservation” rule published by the U.S. Department of Energy (DOE) on August 26, 2021 and a related Notice of Data Availability (NODA) published on October 26, 2021.

MHARR’s comments to the MHCC concerning the DOE NODA, filed on November 12, 2021, are in advance of an MHCC meeting scheduled for November 19, 2021, to consider additional information and analysis set forth in the NODA, allegedly in further support of the DOE-proposed energy standards that could add more than $12,000 to the retail cost of a new double-section manufactured home, without even considering the cost impact of new and additional testing, enforcement and regulatory compliance requirements that would be necessitated by the new standards.

MHARR, for its part, has consistently opposed DOE energy standards for manufactured homes since the matter was first broached in 2007 (the only industry organization to do so), as representing an unnecessary, destructive and discriminatory burden on lower and moderate-income Americans that will needlessly exclude millions of potential purchasers from the manufactured housing market and from homeownership (with all of its attendant benefits) altogether.

In addition to the comments provided to the MHCC on the October 26, 2021 NODA, MHARR will also file separate supplemental comments with DOE to address the specific assertions set forth in the NODA. Those comments will be filed, as usual, in advance of the November 26, 2021 comment deadline and made available to industry members for use or reference in their own comments.

As it has previously, MHARR urges other industry organizations and members to submit their own comments in opposition to the DOE proposed rule and NODA as a needless, destructive and extreme act of regulatory overreach. Ultimately, however, as MHARR has emphasized previously, court action by the industry may be necessary to stop this baseless attack on the industry’s homes and American consumers of affordable housing – an attack that threatens to eliminate mainstream, affordable manufactured housing as it exists today.

Attachment

 

pdf-images.-2jpg
mharr.mhccdoenov12.2021comments.pdf

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