Manufactured Housing Association for Regulatory Reform

  APRIL 28, 2011 VIA FEDERAL EXPRESS Regulations DivisionOffice of General CounselU.S. Department of Housing and Urban DevelopmentRoom 10276451 Seventh Street, S.W.Washington, D.C. 20410-0500 Re:  Docket No. FR-5506-N-01 Reducing Regulatory Burden — Retrospective Review Under E.O. 13563 Dear Sir or Madam: The following comments are submitted on behalf of the

  05-04-2011 TO:               MHARR MANUFACTURERS MHARR STATE AFFILIATES FROM:          MHARR RE:               INCREDIBLY BIASED AND MISLEADING JOINT HUD-CDC “REPORT” NOW BEING CIRCULATED As you may be aware, a joint “report” issued by the Department of Housing and Urban Development and the Centers for Disease Control (CDC), entitled “Safety and Health in

  MAY 6, 2011 by Danny Ghorbani — Capping a process that began a decade ago with an MHARR Petition for Rulemaking, HUD has published proposed revisions to its Subpart I notice and correction regulations.  That proposal, which is the subject of comprehensive MHARR comments, presents, at best, a mixed

  APRIL 14, 2011 TO:    MHARR  MANUFACTURERS MHARR TECHNICAL REVIEW GROUP (TRG) MHARR AFFILIATED STATES FROM:    DANNY D. GHORBANI RE:    MHARR COMMENTS ON HUD PROPOSED SUBPART I RULE Attached for your review and information is a copy of MHARRs comprehensive comments on HUDs February 15, 2011 proposed rule to amend

by Danny Ghorbani — HUD’s recently released Fiscal Year 2012 budget and appropriations request for the federal manufactured housing program shows why Congress needs to carefully scrutinize program spending and demand accountability from HUD regulators for the misdirection of funds previously appropriated by Congress. The time for the industry to press for such intervention, moreover, is now, when all aspects of the program budget are subject to oversight by Congress based on section 620 of the Manufactured Housing Improvement Act of 2000, and not later, during a HUD administrative rulemaking on higher label fees, when the only issue will be the amount of the increase and industry objections are unlikely to receive any kind of hearing.

Washington, D.C., April 7, 2011 — According to official statistics complied on behalf of the U.S. Department of Housing and Urban Development (HUD), manufactured housing production has continued to significantly decline in 2011.  In January 2011, 2,796 HUD Code homes were produced, down from 3,210 homes in January 2010, representing a year-over-year decline of 12.89%.  This trend continued in February 2011 with 2,892 HUD Code homes produced, down from 3,463 homes in February 2010, representing a year-over-year decline of 16.5%.  To date, therefore, 2011 production has declined by an average of 15%.  This follows on the heels of record low annual production of 49,275 homes in 2010, a decline of .8% below the previous record low of 49,683 units in 2009.  This represents a drop of almost 90% since 1998, when nearly 374,000 manufactured homes were produced, and the 13th consecutive year of production declines for the only segment of the housing industry that is comprehensively regulated by the federal government.