Costly Threats Increase Manufactured Home Industry Concerns, Federal Documents Tip Reveal Previously Undisclosed Facts on Manufactured Housing “Advocacy” – Another “Smoking Gun?!”


The National Association of Home Builders (NAHB) is an obvious competitor to HUD Code manufactured housing. Third-party researchers have said that NAHB has been working for decades to undermine a greater acceptance and placement of manufactured homes.  So, when data from the NAHB is cited, it should be viewed with those evidence-based claims in mind. It is the NAHB that has done periodic “priced out” studies. Based on NAHB research, every $1,000 of increased retail costs “prices out” some 127,560 potential buyers, per their 2019 graphic, from their report linked here.

The 2019 Priced Out research is found at this link here.

It is against the above data points that the Department of Energy (DOE) proposed Energy Rule for manufactured housing must be examined. Because if the costs are as severe as is claimed, hundreds of thousands of Americans of modest means will have their shot at home ownership eliminated.  That means that the market for HUD Code manufactured homes is also being narrowed for sellers and producers.

These facts are part of the reason why the Manufactured Housing Association for Regulatory Reform (MHARR) has fought this rule for about 14 years. In fairness, the Manufactured Housing Institute (MHI) also claims to be fighting this rule too. That said:

  • Another reason this looming threat is troubling is because the DOE rule is a cure in search of a nonexistent problem. Manufactured homes are already energy efficient, by law and per third-party research.
  • But an additional issue exists that bears mention, which will be part of a planned follow up. Namely, while this debate plays out, it is one more topic that appears to make manufactured housing ‘look bad’ to those who don’t dig into the facts and evidence deeply enough. Millions do not read beyond a headline. The phrasing of a headline or article can cause those who might consider a manufactured home to look elsewhere for a housing solution.

With this background, a new Q&A style interview linked below, Mark Weiss, J.D. answers 14 different questions posed by MHProNews.


That should be read in conjunction with the following documents that was obtained from the Department of Energy (DOE). These two documents demonstrate that MHI, on two separate occasions, had been working for some years to promote an adoption of a DOE rule that they now claim to their members and readers to be ‘fighting.’

For evidence, see the two documents below the linked related reports.


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The first letter below was previously examined in the report linked above.

Instead of opposing the rule, MHI’s then Vice President of Regulatory Affairs, Lois Starkey, wrote the DOE asking for “negotiated rulemaking.” That’s an apparent request to do an agreed upon rule, rather than an action to oppose a rule. Note: depending on your browser or device, many images in this report can be clicked to expand. Click the image and follow the prompts

The key portion of the first letter, previously published and unpacked in the report linked above, is as follows. These portions of the letter on MHI letterhead and signed by an MHI vice president makes it clear that MHI initiated an outreach to DOE. Part of that outreach asked to have this process accelerated. See the letters below.

With that backdrop, here are both documents obtained via a tip. These documents were in the possession of the DOE and were given to MHProNews from an informed source. Said differently, they originated from an insider at the DOE. The snippet above is from the first letter shown below.   The illustrations below are added by MHProNews for the sake of those not familiar with the technical points being examined. Note that a check of MHI emails at that time did not reflect any evidence that MHI presented these to their members, a point noted in the MHProNews added orange callout text in more detail on the documents.

Page 1 of a 2 page letter on MHI letterhead is above, the second page is below. Note: the illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo. Use your browsers back key to return to the article.
The illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo. Use your browsers back key to return to the article.

The second of these letters documents that MHI teamed up with some of the same groups that are still pressing this costly energy rule. Note the language used that MHI has signed  onto. “We are pleased,” “express our support,” “accelerating the process,” “long overdue changes to the current standards.” While MHARR was opposing the DOE rule, MHI was cooperating, supporting, asking to accelerate, “long overdue changes.” Besides the attempted impact with DOE, this letter MHI signed onto needlessly handed ammunition to competitors of the HUD Code manufactured home industry.  It was arguably inexcusable for MHI to do this and the letter above.


Someone may presume that the reason that a tipster provided these two documents is because they either suspect and/or KNOW that MHI is still working against the industry’s own interests. Newcomers must keep in mind that evidence of MHI doing similarly on other issues exists. Among that evidence is another document drop that makes it clear that MHI’s Lesli Gooch was working for another housing trade group, that would be contrary to the interests of manufactured housing. When that document drop was revealed, MHI’s board apparently did nothing to Gooch. Meaning, there are other pieces of documentary as well as historic evidence, trends, behavior patterns that make it plausible that MHI is working to limit the production of HUD Code manufactured homes. Note 2: Note: depending on your browser or device, many images in this report can be clicked to expand. Click the image and follow the prompts.


Restated, at a minimum, these DOE obtained documents are factual evidence of MHI’s apparently problematic role in reviving the DOE energy rule process during the Obama-Biden Administration. Note the PDF download of both documents, without comments or illustrations, are found at this link here.

Efforts by MHARR – effectively supported by independent reporting from MHProNews that highlighted the various nuances of these issues from MHI, MHARR, and a range of other sources – made it plain that MHI was ‘caught’ on the wrong side of this matter. While MHI finally pivoted, as MHProNews exclusively reported below, it was only after they were first exposed for apparently corrupt and misleading behavior.


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Given the history, it is entirely logical to ponder this notion. Is MHI – which publicly opposes these standards, and repeatedly says as much to their readers or in public comments letters – are they just posturing? Are they still de facto trying to promote the rule while claiming to be fighting it?

  • Where, for example, is there evidence that MHI would sue in order to stop this rule, if necessary?


Additional Information, More MHProNews Analysis and Commentary in Brief

It must be noted that MHI claims to have hundreds of industry members that have submitted what amounts to a form letter to the DOE opposing this rule. That may be examined in a separate report in the near term.

That said, MHProNews has previously reported what federal regulators have openly said. Such form letters, or ‘astroturfing’ are not like a ‘vote.’ 100 or 500 largely identical letters don’t necessarily impact the regulatory review process. By contrast, one good letter may cause regulators to consider facts and evidence that could forestall or change an outcome. Again, to stress that point, it is not an opinion, but is rather based on what federal officials have publicly stated about the comments process.

As a disclosure, while MHProNews team members have in the past participated in MHI form letters too. But once the dynamics per federal officials were learned, MHProNews comments pivoted to unique statements that may reference others, but are not a carbon copy of them. So, for instance, if someone wants to reference comments by MHI or MHARR via a link, that’s potentially useful IF they are followed or bracketed by unique comments that shed light those others may or may not have done.

Note on a potentially related topic. A source on the west coast is telling MHProNews that they believe that evidence exists that MHI is working to undermine the industry’s own affordability.  MHProNews has been receiving several pieces of evidence from that source which claims knowledge. MHProNews may report on that in the foreseeable future, as the evidence develops.

Be it the DOE energy rule, financing, zoning and placement, or image issues, MHI is time and again taking stances that may posture effort but when carefully examined is often contradicted by published statements by their publicly traded corporate members. Those dominating corporate members may well have their own reasons for MHI to posture efforts without actually effectively delivering on them. After all, if consolidation is a goal, then limiting the production and acceptance of affordable manufactured homes makes that more attainable.  The evidence and logical meaning of the evidence may be too troubling for some to accept, but others – per sources – are ‘waking up’ to what is occurring at MHI and/or at their state affiliates.

Once more, with this backdrop, the new one-on-one interview with Mark Weiss, J.D., president and CEO of MHARR will shed additional light on these hot-button topics. ##

A prior report with whistleblower documents, set in the context of Gooch’s history that MHI has not highlighted.
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All on Capitol Hill were welcoming and interested with the discussion of manufactured housing related issues on our 12.3.2019 meetings. But Texas Congressman Al Green’s office was tremendous in their hospitality. Our son’s hand is on a package that included a copy of the Constitution of the United States and other goodies. MHProNews has worked with people and politicos across the left-right divide.

By L.A. “Tony” Kovach – for

Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing.

For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and

This article reflects the LLC’s and/or the writer’s position, and may or may not reflect the views of sponsors or supporters.

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