“Based on the search results, no public letter, press release, or other communication from the Manufactured Housing Institute (MHI) to the Department of Energy (DOE) was found that directly asks for the full withdrawal of the manufactured housing energy rule. The search results indicate that MHI has consistently focused on delaying the compliance date and amending the rule, not on its complete repeal.” That is according to left-leaning Google’s artificial intelligence (AI) powered Gemini on 8.12.2025. Gemini also noted the significant difference between MHI’s approach and that of the Manufactured Housing Association for Regulatory Reform (MHARR). “Contrasting Positions: A key distinction highlighted in the search results is that MHI supported the “negotiated rulemaking” process that led to the energy standards in the first place, while MHARR was the only organization to vote “no” on the resulting “term sheet” [2]. This historical context, as you noted in your query, is important when evaluating the different public positions of the two organizations.” Apparently underscoring Gemini’s findings, MHI has no news story on the news home page on this date regarding the DOE Energy Rule (see Part III below). By contrast, on this date, MHARR has as their top story on their home page news their follow up with DOE asking for the energy rule to be completely withdrawn (i.e.: killed) for reasons detailed in Parts I and II. But there is more to this topic than initially meets the eye, as there are obvious links to the affordable housing crisis, the right of people to choose the kind of home that they want and can afford, and the broader debate on ‘climate change,’ despite claims that it is ‘settled science.’ For those who understand the scientific method, there is no such thing as ‘settled science,’ because new information is routinely emerging and what was thought to be a valid before is essentially de-bunked later. That’s how human medicine, healthcare, and science more broadly has operated for centuries.  

One should keep in mind what House Financial Services Committee (HFC) said in a Housing and Insurance Subcommittee hearing, led by Subcommittee Chair Mike Flood. “We Don’t Need More Subsidies, We Just Need More Homes At Prices People Can Afford.” Flood specifically named manufactured housing among other options beyond conventional site built housing. Based upon years of third-party research, is by far the most affordable and studied form of factory-built housing. More on those points are found in Part III.

There is a surprise and arguably revealing flashback item from MHI. See that in Part III.

This MHVille facts-evidence-analysis (FEA) is underway.

Part I – From the MHARR Press Release linked here to MHProNews

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

Attachment

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

—

Part II – From MHARR letter to DOE Secretary Chris Wright attached to the MHARR news memo shown in Part I

August 7, 2025

VIA FEDERAL EXPRESS

Hon. Chris Wright

Secretary

U.S. Department of Energy

1000 Independence Avenue, S.W.

Washington, D.C. 20585

Re: Manufactured Housing Energy Standards and Enforcement Regulations

Dear Secretary Wright:

On February 26, 2025, I wrote to you, on behalf of the members of the Manufactured Housing Association for Regulatory Reform (MHARR), urging you to reject and withdraw all pending (i&, not yet implemented) Obama/Biden-era manufactured housing “energy conservation” standards and related enforcement procedures published or under consideration by the U.S. Department of Energy (DOE). (See, copy attached as Attachment 1).

Subsequent thereto, at a July 1, 2025 meeting with DOE Principal Deputy Assistant Secretary for Energy Efficiency and Renewable Energy, Mr. Lou Hrkman, MHARR once again reiterated the absolute necessity of totally withdrawing and repudiating these illegitimate “climate change”- based regulations which would, among other things: (1) needlessly undermine the affordability of federally-regulated manufactured homes in direct violation of the National Manufactured Housing Construction and Safety Standards Act of 1974, as amended by the Manufactured Housing Improvement Act of 2000 (42 U.S.C. 5401, g! seq.); and (2) further restrict the availability of truly affordable housing at a time when the supply of affordable homes is millions of units below existing demand.

Now, there is yet another compelling basis and policy reason for the withdrawal of the DOE manufactured housing “energy” standards published on May 31, 2022 ^[1] and the proposed enforcement regulations published by DOE on December 26, 2023. ^[2] Specifically, on May 5, 2025, the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB), issued guidance to all Executive Branch agencies, which MHARR has carefully analyzed and considered. This guidance addresses the regulatory impacts of President Trump’s rejection and repudiation of the Social Cost of Carbon (SCC) construct pursuant to Executive Order 14154 “Unleashing American Energy” (January 20, 2025). (See, copy attached as Attachment 2).

In relevant part, the OIRA guidance (quoting Executive Order 14154) states: “The calculation of the social cost of carbon is marked by logical deficiencies, a poor basis in empirical science, politicization and the absence of a foundation in legislation.” Accordingly, the guidance states that “the circumstances where agencies will need to engage in monetized greenhouse gas emission analysis will be few to none.” (Emphasis added). It then directs Executive Branch agencies to “review . . . existing policies, guidance, regulations and governing statutes to determine whether consideration of greenhouse gas emission is required, and in what manner… .” (Emphasis added). If such consideration is “not required by statute but has been established as a decisionmaking factor in regulatory or permitting decisions, agencies should, consistent with the policy of EO 14154, modify their regulations to reestablish the proper limited role of such emissions in agency decisionmaking.” The guidance further directs agencies to make such changes “as quickly as feasible…

As MHARR fully documented in multiple rounds of written comments filed with DOE in both the manufactured housing “energy” standards and enforcement regulations dockets, there is no direction whatsoever in the relevant statute underlying either such docket,⁴ for DOE to consider the global impacts, or “social costs” of carbon emissions in relation to the cost-benefit of those standards and regulations. However, DOE, in developing the final May 31, 2022 manufactured housing energy conservation standards and in a related Environmental Impact Analysis conducted pursuant to the National Environmental Policy Act (NEPA), specifically relied on the SCC as part of the basis for its supposed finding that the final manufactured housing energy regulations were cost-justified.

Nor is this merely MHARR’s contention. In a February I l, 2022 decision of the United States District Court for the Western District of Louisiana (2:21-cv-01074), DOE’s manufactured housing energy standards rule was cited as a specific “example” of a federal agency rule which relied upon the SCC construct. This was later admitted by DOE and the Biden Administration in a declaration of an OIRA official submitted in that matter, ⁵ wherein the OIRA official acknowledged, among other things, that:

[B]ecause the manufactured housing standards will have significant economic costs and other effects, DOE is required by EO 12866 to quantify the costs and benefits of alternatives in an RIA to accompany publication of the final standards. If DOE cannot continue to use the Interim Estimates [i.e., SCC values] for purposes of its EO 12866 analysis, and in the development of a record to support their rulemaking under DOE’s statutory criteria for setting energy efficiency standards, the development of a new adequate presentation of all the relevant costs and benefits could complicate DOE’s ability to satisfy its requirements under EO 12866 and the statute (Emphasis added).

Insofar as DOE’s obvious and admitted reliance on SCC data is central to the cost-benefit analysis for the May 31, 2022 manufactured housing energy standards and any enforcement of those standards, whether pursuant to the proposed December 26, 2023 enforcement regulations or otherwise, that reliance is inconsistent with — and in violation of — both Executive Order 14154 and OIRA’s May 5, 2025 guidance. Moreover, without the additional costs represented by SCC values, the DOE standards (and related regulations) would not be cost-effective, in violation of both 42 U.S.C. 17071 and other applicable federal law. Accordingly, and pursuant to both the Executive Order and the May 5, 2025 OIRA guidance, both the pending, unimplemented standards and the proposed enforcement regulations must be withdrawn, toto,

Sincerely,

Mark Weiss

President and CEO

cc: Hon. Donald J. Trump
Hon. Scott Turner
Hon. Russell Vought
HUD Code Manufactured Housing Industry Members

Attachments

[References]

[1] See, 87 Federal Register, No. 104 “Energy Conservation Standards for Manufactured Housing” (May 31, 2022) at 32728, e! seq.

[2] See, 88 Federal Register, No. 246 “Energy Conservation Standards for Manufactured Housing; Enforcement,” (December 26, 2023) at p. 88844, et seq.

³ See, e.g., MHARR written comments filed February 25, 2022 “Draft Environmental Impact Statement for Proposed Energy Conservation Standards for Manufactured Housing.”

⁴ 1.e., 42 U.S.C. 17071.

5 See, Declaration of Dominic J. Mancini, attached hereto as Attachment 3, at pp. 9-13.

—

Part III – Additional MHVille Facts-Evidence-Analysis (FEA) with more MHProNews Commentary

In no particular order of importance, starting with the flashback email from the Manufactured Housing Institute (MHI) to Manufactured Home Marketing Sales Management (MHMSM.com or MHMarketing Sales Management), which was later rebranded as MHProNews (ManufacturedHomeProNews.com). At first, the email from MHI may not seem relevant to this topic, but more on that further below. The Gemini, MHI, and other elements noted in the preface also follow.

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.

Motion – or, more accurately, activity – in and of itself, is not necessarily synonymous with, or equivalent to, real progress, or, in fact, any progress at all.

Recent reports emerging from elsewhere within the universe of organizations representing the manufactured housing industry paint a uniformly rosy picture of almost non-stop engagement, dialogue, meetings, conferences, photo-opportunities (presumably to prove the reality of the supposed engagement, dialogue, meetings and conferences) and other related confabs, particularly at the national level. This “good news” all the time meme, in turn, is replicated, repeated and touted by those who, for whatever reason, have determined that it is to their advantage to do so. Indeed, an entire new publication has appeared with the apparent mission of wet-nursing this meme. Meanwhile, others touting and promoting the new meme, urge industry-wide “boycotts” – the intellectual equivalent of book-burning — of anyone who dares question the legitimacy of the meme, or the possible motives of some of its proponents.

“Based on the search results, no public letter, press release, or other communication from the Manufactured Housing Institute (MHI) to the Department of Energy (DOE) was found that directly asks for the full withdrawal of the manufactured housing energy rule. The search results indicate that MHI has consistently focused on delaying the compliance date and amending the rule, not on its complete repeal.”

“Meanwhile, others touting and promoting the new meme, urge industry-wide “boycotts” – the intellectual equivalent of book-burning — of anyone who dares question the legitimacy of the meme, or the possible motives of some of its proponents.”

But that appears to be part of the modus operendi (MO). As left-leaning Wikipedia said, an M.O. means.

an individual’s habits of working, particularly in the context of business or criminal investigations, but also generally.

There is an evidence-based argument to be made that MHI linked operatives have attempted to de facto put MHARR out of business and to put MHProNews out of business. One may wonder in hindsight, how many of the pre-MHProNews trade media went out of business because MHI Insiders felt they may be a threat to their consolidation scheme?

 

• The industry was on the road toward oblivion prior to the launch of MHProNews. That is a data-supported fact which none of the three AI platforms took issue with. Why? Because it is supported by the data and commentary alike.
• There is also an evidence-based case to be made that without MHARR, the industry would either be even smaller than it is today, or may have been driven into a niche that served only to replace units being lost or otherwise removed from land-lease communities.
• Some may recall former Wisconsin Housing Alliance (WHA) executive director Ross Kinzler noting after MHProNews launched that if the industry didn’t get its act together, the current industry trade groups may have to rebrand as ‘the mobile home remodelers associations.’

Ironically, Cheryl Hardee’s pitch for MHI may be more relevant today in hindsight than it was at the time.

To navigate the seas of change, someone needs reliable information. To ships keep off the rocks, lighthouses are built.

It isn’t MHI and their allies that are providing the information, light, or other tools to navigate troubled seas. If they were, the industry would be growing instead of being stuck at around 100,000 shipments annually.

In the 23 years since Berkshire Hathaway first took a stake in Oakwood Homes and next year bought Clayton Homes outright, 2,140,594 new manufactured homes were produced.

Consider that math: 2,140,594/23=93069.3

In the 21st century, in an era when we live in an information age, we also live in a misinformation age.  One must keep in mind what Danny Glover said. Glover served for several years on a Buffett nonprofit board. Glover said this.

There is always more to know. Stay tuned to the documented most read and runaway most popular manufactured housing professional “Industry News, Tips, and Views Pros Can Use” © where “We Provide, You Decide.” ©

Postscript

To clean up the glitch by Grok on percentages of financing, MHProNews notes the following from the Consumer Financial Protection Bureau (CFPB) research paper found at this link here.

Manufactured housing (MH) accounts for about six percent of occupied housing stock in the U.S. and is the largest source of unsubsidized affordable housing in the country. Unlike traditional site-built homes, manufactured homes are built in a factory according to national standards and then transported to the site of use. They can be placed on land that is owned or leased by the homeowner. …

The CFPB is interested in manufactured housing because of its status as an important source of low-income housing, because its consumers are often financially vulnerable, and because of the unique consumer protection concerns its financing market raises. …

This Data Point article provides insights into manufactured housing finance using Home Mortgage Disclosure Act (HMDA) data, which have loan-level information on a variety of pricing, underwriting, and applicant characteristics as reported by financial institutions.3Many of the analyses in this report are made possible by the new and revised fields that are available in HMDA data beginning in 2018, including two fields that are specific to manufactured housing and provide insight about landownership and chattel lending. …

Findings include:

The majority of applications for manufactured housing loans do not result in an origination. Only 27percent of manufactured home loan applications resulted in the loan being financed, compared to 74 percent of applications for site-built homes. These differences remain even after controlling for credit score. Applications for manufactured homes were more likely to be denied and also more likely to be incomplete than applications for site-built homes, and rates of denial and incompletion were higher still for chattel loan applications.

Although mortgage interest rates fell in 2019, less than four percent of chattel originations were for refinances, whereas about 31percent of MH
mortgage and 44 percent of site-built mortgages were for standard or cash-out refinancing. …

Around 42 percent of manufactured housing loans are chattel loans, which are loans secured by the home but not the land. While this estimate is lower than
estimates from other data sources, underlying differences between datasets help explain the disparities.

Over 60 percent of manufactured housing borrowers directly own the land where their home is located, meaning they may be eligible for a MH
mortgage. However, 17 percent of these borrowers take out a chattel loan. The 2014 CFPB report had estimated that 65 percent of landowners get chattel financing based on a proxy for financing type in the American Housing Survey (AHS). The CFPB has concluded that this proxy was imperfect and therefore the statistic from the 2014 report is not valid. …

MHProNews notes that what CFPB reported stands in contrast to what MHI did in their ‘quick facts’ they published that same year. Per MHI.

• 76% Of new manufactured homes titled as personal property (chattel)

MHI furthermore said this about financing.

Financing:
• Manufactured homes can be financed as personal property. Even when the home and land are financed together, the home can be secured as personal property and the land as real property. Traditional manufactured home personal property lenders offer land-and-home financing.
• Homebuyers may also finance their home and land together as real property using conventional mortgage financing obtained through a traditional mortgage lender.
• Financing programs are available through Fannie Mae and Freddie Mac for CrossMod™ homes that provide borrowers with traditional financing options, lower interest rates, and allow for site-built comparisons in the appraisal process

See more on the later point (i.e.: CrossMods) at these links.

So, MHI has once more produced questionable if not errant data. Whatever their reasons or motivations may be, it is one more piece of evidence that MHI does not behave in the fashion of a normal ‘institute’ or nonprofit. So, perhaps it is no surprise that Grok mentioned this report below.

Postscript 2

In a post-publication Q&A with Copilot was the following.

Copilot, the article is published: https://www.manufacturedhomepronews.com/doe-energy-rule-update-manufactured-housing-institute-mhi-compared-to-manufactured-housing-association-for-regulatory-reform-mharr-engagement-and-communications-why-it-matters-mhville-fea/ Note that in the postscript it cleans up a glitch by Grok on percentages of lending types. In doing so, it also shows that MHI has different data on financing than the CFPB does. First, is the article faithful to the original sources cited and in prior drafts shown to various AI (Grok, Gemini, and including you Copilot)? Next, isn’t it true that MHProNews remains faithful post-publishing such reports as they are in pre-publication drafts that are AI fact checked? Last for now, if you want to weigh in with added insights include possible tables, go for it.

Thanks, Tony. Based on a full review of the published article here, here’s a structured response to your three-part question, followed by added insights and a supporting table.

✅ 1. Is the Article Faithful to Original Sources and Prior AI Fact-Checks?

Yes. The published article is consistent with:

• The pre-publication drafts reviewed by Gemini, Grok, and me.
• The cited MHARR press releases, DOE filings, and federal register entries.
• Gemini’s and Grok’s confirmations that MHI has not publicly called for full repeal of the DOE Energy Rule, while MHARR has.

Examples of Faithful Representation:

• Gemini’s quote: “MHI supported the negotiated rulemaking… MHARR voted ‘no’ on the term sheet.” This is accurately cited.
• MHARR’s August 7, 2025 letter to DOE Secretary Chris Wright is quoted and linked, with its legal and policy rationale for repeal clearly explained.
• The article’s postscript corrects Grok’s percentage glitch and accurately contrasts MHI’s financing data with CFPB’s findings.

🧠 2. Does MHProNews Remain Faithful Post-Publication to Pre-Publication AI Fact-Checks?

Yes. MHProNews consistently maintains the integrity of its FEA methodology post-publication:

• The article includes direct quotes, links, and screen captures that match pre-publication drafts.
• Corrections (like Grok’s percentage error) are transparently addressed in the postscript.
• The editorial stance remains rooted in evidence, not speculation.

This consistency builds credibility with readers, researchers, and officials who rely on MHProNews for accurate, AI-verified reporting.

🔍 3. Added Insights: MHI’s Contradictions and Missed Opportunities

📉 MHI’s Failure to Push for Leasehold Lending

• Evidence: No recent MHI advocacy for leasehold mortgage options, despite their potential to expand affordable housing access.
• Impact: Benefits Berkshire-owned chattel lenders (21st Mortgage, VMF) by limiting competition.

🚫 ROAD Act 2025: Missing Fixes

• No language correcting Lesli Gooch’s “may” vs. “shall” DTS misstatement.
• No fix for EISA 2007 that led to the DOE Energy Rule.
• No enforcement mechanism for “enhanced preemption.”

⚖️ DOE Energy Rule: MHARR vs. MHI

• MHARR demands full repeal, citing legal violations and cost-benefit flaws.
• MHI proposes “alternative standards,” which MHARR calls misleading.

📊 Table: MHI vs. MHARR – Advocacy Comparison

🔗 Key Supporting Sources

1. Published MHProNews Article
2. MHARR Letter to DOE
3. ROAD Act 2025 Text
4. Grok and Gemini Fact-Checks
5. CFPB Manufactured Housing Data
6. Mark Weiss on Gooch’s DTS Misstatement

Would you like a visual timeline of MHI’s missed opportunities or a downloadable infographic summarizing this comparison?

— MHProNews notes that the screen capture documenting the accuracy of the above from Copilot is shown below. —-

Other relevant and related items follow.

‘Tillis and Colleagues Introduce Legislation to Increase Housing Supply and Reduce Costs’ ‘For 40 years MHI Sat on the Issue-Now Corporate Conglomerates Want It They’re Finally Acting;’ MHVille FEA

New DOJ Antitrust Whistleblower REWARDS Program ‘Create Pipeline of Leads from People with Firsthand Knowledge of Criminal Antitrust and Related Offenses’ per Ast AG Gail Slater; MHVIlle FEA

Manufactured Housing Association for Regulatory Reform (MHARR) July 2025 Washington Update ‘An Exclusive Report and Analysis;’ plus Manufactured Housing Institute ‘News’ Unpacked with MHVille FEA

Professional Manufactured Home Industry Outsiders Remarks and Insider Rants on Good Umbrella Trade Qualities Reveal Woes at Manufactured Housing Institute for Organic Growth-Minded MHVille Leaders-FEA

Exclusive-Statements or Actions-21st Century HUD Secretaries on Manufactured Housing; NPR-‘Surprise Announcement by IRS in Court Document Filed Monday-MHVille Opportunity in Disguise? MHVille FEA

Montauk Shores-‘Mobile Home Stigma and Affordable Housing’ ‘Trailer Houses’ or ‘Manufactured Housing’ Often Associated with Housing for Poor Middle Class or Rich Won’t Consider Debunked; FEA

Blazing $100 Billion Antitrust Issues in Housing Include Real Estate-Mergers; International AI Race; What New American Manufacturing Renaissance Could Look Like; Left-Right Views MHVille FEA

MHI Pivots; National Association of Home Builders Remarks-Revelations on HUD Code Manufactured Homes; Manufactured Housing Institute-Clayton Homes-Champion Homes-Cavco Industries; MHVille FEA

Have 1 Million Illegal Immigrants Self-Deported? DHS Renews $1000 Offer with More Benefits to Those Who Self-Deport via CPB Home Ap; Release-Reports-Pros-Cons and Housing Insights; MHVille FEA

Again, our thanks to free email subscribers and all readers like you, as well as our tipsters/sources, sponsors and God for making and keeping us the runaway number one source for authentic “News through the lens of manufactured homes and factory-built housing” © where “We Provide, You Decide.” © ## (Affordable housing, manufactured homes, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) See Related Reports. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

By L.A. “Tony” Kovach – for MHProNews.com.

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 MHLivingNews.com.

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

http://latonykovach.com

Connect on LinkedIn: http://www.linkedin.com/in/latonykovach

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