Washington, D.C., December 22, 2025 – The Manufactured Housing Association for Regulatory Reform (MHARR), in a December 17, 2025 communication to U.S. Small Business Administration (SBA) Administrator Kelly Loeffler (see, copy attached), has called on SBA to invalidate the U.S. Department of Energy’s (DOE) May 31, 2022 manufactured housing “energy conservation” standards rule. This action follows SBA’s announcement, on December 15, 2025 (see, News Release attached), of the establishment of a new “Deregulation Strike Force,” dedicated to “identifying and eliminating excessive Biden-era regulations that have disproportionately increased costs for America’s small businesses and consumers.” (Emphasis added). Significantly, the new SBA deregulation strike force is particularly focused on cutting regulations on small businesses in the “housing and construction” industry.
As MHARR’s communication points out, it is beyond dispute that the DOE “final” energy conservation standards would impose a crushing regulatory burden on the HUD Code manufactured housing industry’s smaller businesses, as well as American consumers of affordable housing, who would see manufactured home purchase prices increase by thousands of dollars. Combined with relatively high interest rates – particularly for market-dominant personal property loans that have not been supported by Fannie Mae and Freddie Mac in violation of the Duty to Serve mandate – the draconian DOE standards would needlessly exclude millions of Americans from the HUD Code market and from any type of homeownership whatsoever.
MHARR, accordingly, has consistently opposed the DOE standards process from day-one, the only national industry organization to do so. Further, SBA itself recognized the dangers posed by DOE manufactured housing “energy conservation” regulation, when it noted in August 16, 2016 comments filed in the DOE rulemaking docket that industry “small businesses cannot absorb the added cost to comply with the [DOE regulations] and remain competitive in the manufactured housing market.”
Consequently, there is ample basis and reason for SBA to invalidate the May 31, 2022 DOE manufactured housing “energy” standards as a baseless exercise in climate alarmism, while action is pending to eliminate the statutory underpinning for DOE jurisdiction and a return of that authority to HUD.
In Washington, D.C., MHARR President and CEO Mark Weiss stated: “As is widely known, Washington, D.C. is a graveyard for bad laws and bad regulations, and both are implicated with respect to the DOE manufactured housing ‘energy’ standards. Before this draconian ‘solution’ to a non-existent ‘problem’ torpedoes the availability of the nation’s most affordable housing, amid an unprecedented affordable housing shortage, SBA should take strong action to invalidate the DOE May 31, 2022 standards pursuant to its deregulatory initiative, if DOE itself does not do so first.”
The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.- based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.
MHARR’s report is available for re-publication in full (i.e., without alteration or substantive modification) without further permission and with proper attribution and/or linkback to MHARR.
