The following comments letter was sent to the Department of Energy on the date shown. It should be read in conjunction with the observations made linked here and below.
Ms. Jennifer M. Granholm, Secretary
U.S. Department of Energy (DOE)
1000 Independence Ave. SW
Washington, DC 20585
Re: Energy Conservation Program: Energy Conservation Standards for Manufactured Housing (EERE-2009-BT-BC-0021)
Secretary Granholm and DOE Staff,
A) ‘Tell them what you will say. Say it with convincing evidence. Tell them what you told them.’ Paraphrase of junior high school tip in English class on how to write a good paper or article.
B) “Forget what they told you. [If] You want the truth, follow the money.” – Roxanne Bland, author.
C) “The system is rigged.” – Senator Bernie Sanders (VT-DS), Donald J. Trump (as candidate and as the 45th President of the United States, R), Senator Elizabeth Warren (MA-D), along with a host of other candidates, officials, and pundits.
D) “Propaganda works” on “most Americans.” – Guy Benson, author.
E) “If you tell a lie big enough and keep repeating it, people will eventually come to believe it. The lie can be maintained only for such time as the State can shield the people from the political, economic and/or military consequences of the lie. It thus becomes vitally important for the State to use all of its powers to repress dissent, for the truth is the mortal enemy of the lie, and thus by extension, the truth is the greatest enemy of the State.” – Joseph Goebbels, Jewish Virtual Library.
F) “The best way to control the opposition is to lead it ourselves.” —Vladimir Lenin.
G) “Paltering is theactive use of truthful statements to convey a misleading impression. Across 2 pilot studies and 6 experiments, we identify paltering as a distinct form of deception.” Harvard (2017). “Paltering is the active use of selective truthful statements to mislead. The term as applied in psychology and mediation studies was developed by researchers at the John F. Kennedy School of Government in the late 2000s. The first known use of palter to describe acting insincerely or deceitfully was in the 1580s.” – Wikipedia.
H) “Facts are stubborn things.” More specifically: “Facts are stubborn things; and whatever may be our wishes, our inclinations, or the dictates of our passion, they cannot alter the state of facts and evidence.” ― John Adams, GoodReads.
- Against that prologue, let’s apply tip A.
J) Each of those principles and pull quotes shed light on the pending DOE energy standards for manufactured housing. Indeed, when the facts, evidence, proven principles are examined in the light of common sense, the only conclusion that can be drawn by objective thinkers is that the DOE can and must reject the pending standards and ‘start over’ or recognize that these proposed standards are the proverbial solution in search of a nonexistent problem. Indeed, when someone finishes this factual evidence-, historical- and reason-based analysis they may come to realize the meaning of three quotes from public officials from both major parties, each quite knowledgeable about the so-called rigged system.
- “The nine most terrifying words in the English language are: I’m from the Government, and I’m here to help.” – Ronald Reagan (35thS. President) Reagan Foundation (R-GOP).
- “You are entitled to your opinion. But youare not entitled to your own facts.” – Daniel Patrick Moynihan (NY-D), GoodReads.
- “There are no coincidences in Washington” [D.C.] and “Follow the money” are the keys to understanding American politics, attributed to Senator William Proxmire (WI-D)
K) Why should the proposed manufactured housing energy standards be scrapped? Certainly, both the Arlington, VA based Manufactured Housing Institute (MHI) and the Washington, D.C. based Manufactured Housing Association for Regulatory Reform (MHARR) provide ample legal and practical reasons for doing so. Their comments, along with all other linked items should be considered as part of my comments submission.
- Note that linking a comment or quoting a source should not be construed as a blanket endorsement of what a person or group has said or done. A quote and/or reference are to be understood herein as used for the purposes of illustrating one or more specific points.
L) But there are other reasons that are not bluntly stated by MHI and/or MHARR. They include the following, in no particular order of importance.
- 1) There are several apparent conflicts of interest involved, which will be explored below.
- 2) There are apparent examples of corruption involved in this process. That purported corruption includes, but is not necessarily limited to, corporate, nonprofits, and public officials, to name but 3 categories. Examples will be provided.
- 3) There are clearly self-contradictory statements and behaviors involved in this process, some of which MHI and MHARR have identified.
- 4) To the Lenin quote and paltering issues raised by the quotes above, Clayton Homes and MHI have clear financial and other ties to Next Step U.S. While MHI makes some compelling arguments, which often mirror points raised by MHARR, they fail to make specific points that suggest that they are posturing and paltering.
- 5) Quotes by Warren Buffett, Kevin Clayton, Tom Hodges, Nick Hanauer, Carol Roth – among others that will be used herein – demonstrate that this exercise is part of a ‘rigged’ process which benefits a few insiders at modest- to significant-harm to most others.
- 6) There are constitutional issues that arguably bar the DOE’s proposed rule. Ours is a system of limited government, not unlimited government. This rule fails to explore the constitutionality of this DOE energy rule process, which arguably is a form of taxation and regulation without representation.
- 7) This is yet another example of Washington, D.C. sadly wasting time and money that harms most taxpayers and millions of affordable housing seekers while demonstrably benefiting a few insiders. Some of the very people this is rule is supposed to benefit are the ones that will be the most harmed. Who said? MHI did, when they correctly pointed out that racial equity and housing affordability housing for the masses are not being served.
- 8) But perhaps what is the most revealing point that this process is a “sham,” as MHARR President and CEO Mark Weiss, J.D. said in an interview linked here. It is a classic example of paltering by MHI. That’s demonstrated several ways herein. But one is ironically highlighted by MHI, and has been repeatedly indicated by MHARR. That is that MHI has not indicated that they will take any or all necessary legal action to stop this “sham” process, if in fact one of the proposed DOE energy standards for manufactured housing is implemented. Yet, MHI themselves noted earlier this week in an email that the OSHA vax mandate rule was stopped by lawsuits. Those lawsuits, when examined, included nonprofits that sued OSHA on behalf of their members as well as state AGs that sued OSHA. Why doesn’t MHI connect the dots on their own report and state to their members that they too will sue if DOE implements this rule that MHI admits is harmful?
- 9) There are genuine questions of science and its evidence in this mix. Questions of science, constitutional and other law – so long as they are not authentically unresolved – make any new ‘rule’ or ‘mandates’ worse than moot. More on those topics and other topics will follow herein.
- M) The bottom line will be this. There are documentable examples of conflicts of interests. There are several examples of apparent violations of law. There are examples of contradictory behaviors that defy common sense. It is demonstrably counterproductive for these proposals at DOE to move ahead.
- N) This is a solution in search of a problem. Manufactured homes are already less costly in their energy usage than other housing options. The ones who will be most harmed by these perhaps well intended but nevertheless misguided planned DOE rules will be the most economically marginal citizens of all colors and creeds. This process should be halted. The proposed rules scrapped.
- O) A fresh start based on accurate information that is free from conflicts of interest and apparent corruption must be utilized before any rule of any kind is explored.
I) Exploring the Reasoning and Motivations of Those who Favor the Proposed DOE Energy Rule for HUD Code Manufactured Housing.
- A) Per Next Step Network’s letter to the DOE, is the following comment. To the point about following the money trail in the prologue (B) and controlling your own opposition (F), it is a matter of record that Next Step is supported by Clayton Homes, which is a Berkshire Hathaway owned dominating brand at MHI. Clayton Homes’ general counsel happens to be MHI’s chairman, Tom Hodges.
Our donation will help families across America that deserve to own a beautiful new home of their own.” Clayton and Next Step have worked closely …”
Furthermore, Next Step is an MHI member (see page 2, linked here).
- B) A word search of the 14 page Next Step comments letter reveals the following.
- 1) There is no apparent use by Next Step of the word “disclosure” – such as “as a disclosure of a potential conflict of interest,” that then states their ties to Clayton Homes or the Manufactured Housing Institute (MHI).
- 2) Clayton Homes is not mentioned in their letter, despite sizable donations that make their advocacy suspect.
- 3) MHI spelled out in their comments letter once, but not as a disclosure.
- 4) These pieces of evidence from the money trail, documents, and Next Step’s letter, plus what follows, will make what MHARR alleged to be a ‘shell game’ that is a ‘sham process’ spring to life.
- C) That noted, “Next Step participated in and supported the negotiated rulemaking in 2015, which resulted in a 2016 draft standard that DOE never finalized. Therefore, we applaud you for issuing the draft standard.”
- D) What is not clearly disclosed is that MHI and Next Step, per documents provided by the DOE, were engaged in advocacy on behalf of having the energy rule put into place. This contradicts their current statements, but that can be explained by the notion of “paltering.” MHI arguably knows that they have a checkered history at best in this process. See the reports linked below for details, and then the following documents obtained from DOE.
- E) So, MHI asked for negotiated rule making. Next Step recent letter confirms that they were part of that negotiated rule making process that involved MHI. These are not disclosed. It is logically part of a sham, posturing via paltering.
- F) The above is another letter obtained from the DOE. It lists several nonprofits, some of which have similar beliefs and/or similar connections with Next Step.
- G) This document and the other ones, both linked here, make it clear that MHI supported what they now claim to oppose. Note again that while MHI and MHARR’s letters are similar in several respects, MHARR makes clear that they believe that litigation may be necessary to stop this proposed energy rule. So, given MHI’s far deeper pockets and resources, if they are serious (instead of posturing or paltering) about stopping this energy rule, then why didn’t they say they will sue as needed to stop this rule?
- H) Page 2 of the letter above is shown below.
- I). There are several such conflicts of interest, not just those shown. These conflicts are routinely undisclosed. This alone makes the point that MHARR’s president aptly made to MHProNews that this is a sham process. This alone is reason enough to nullify this entire rulemaking process as hopelessly tainted and corrupted.
- J) During the Trump Administration, this process was effectively stopped until a lawsuit by the Sierra Club effectively restarted this process. But Berkshire and Buffett bucks, including from allied players such as Michael Bloomberg, are documented to be behind the Sierra Club. Note that these points are supported by well documented, third-party research linked and examined in the report linked below.
- K) Again, MHI, Next Step, Berkshire, Clayton, and others have not made appropriate disclosures. These are factual, historic, and empirical evidence of a corrupted process. These are reasons enough to stop this energy rule from causing the harm that MHI and MHARR both correctly argue will result if the rules are put into effect.
- L) Logically, that begs the question. Why would Berkshire and Buffett owned and backed brands or nonprofits try to subtly undermine manufactured housing when they are involved in that business? Longtime Buffett ally, William “Bill” Gates III, via the quote below, shed light on that topic.
- M) There are numerous third-party researchers that span the left-right media divide. They routinely mentioned the pernicious ways that Buffett’s “Castle and Moat” method undermines markets in a manner that protects their own brands while making worse disadvantages for competitors. Some examples follow.
- GuruFocus said “Warren Buffett Can’t Escape Unethical Strategic Moats,” their specific points are linked here.
- The Nation called it “The Dirty Secret Behind Warren Buffett’s Billions…” and specifies Clayton Homes among those using the strategic moat in ‘dirty’ ways.
- The Seattle Times in “Minorities exploited by Warren Buffett’s mobile home empire Clayton Homes” said that “Clayton’s grip on the lending market verges on monopolistic…”
- The Jacksonville Florida Times Unions summarized the connection between the John Oliver viral hit video dubbed “Mobile Homes,” MHI, Clayton Homes, and their related lenders. That op-ed was first fact-checked by an editor, before it was published in multiple Florida newspapers.
- The Atlantic, without specifying how the monopolization was being accomplished, noted that the independent retailers in manufactured housing were being rapidly eliminated/consolidated, that report is linked here.
- Forbes has an article that focuses on the racial bias and predatory businesses practices too. It is entitled “Warren Buffett’s Exploitative Mobile Home Investment.” Rephrased, there are sources across the left-right media divide that have highlighted problems with Clayton Homes, their business and lending practices for several years. Several of those have included a monopolistic angle.
- N) Keep in mind that Carol Roth, featured for her business and economic insights on networks that span the left-right media divide, aptly made the following observation.
- O) So, while it may seem on the surface to hurt all manufactured housing producer brands to allow this energy rule to go into effect, there are subtle advantages to those who adhere to this castle and moat, “durable competitive advantages” stratagem. The illustration below makes the point.
- P) Arguably by limiting the manufactured housing market, Clayton has surged in its market share during the Berkshire era of the industry.
- Q) By limiting the market, Clayton and their key allies at MHI have grown to a dominating position.
- R) This makes the point that Gates made about what became his buddy and ally, Warren Buffett. MHI magically posturers year after year for their trusting members that they are trying to stop or limit harmful regulations, when in fact they benefit from the status quo in terms of market share.
- S) Let’s take a peek at what Samuel “Sam” Strommen at Knudson Law said to dot the i and cross the t.
- T) Given repeated opportunities to dispute, debunk, or others disprove these facts and other evidence-based allegations, Berkshire Hathaway, Clayton, MHI and related attorneys have stayed silent.
- U) Let’s close out this segment with some pull quotes that illustrate the points made. While these may not have a direct relationship to DOE, they nevertheless shed light on the pattern of behavior.
- V) https://www.manufacturedhomepronews.com/masthead/marketplaces-s2as-insights-september-2021-manufactured-housing-production-shipment-data-pesky-fact-potential-promise-penetrating-analysis/
II) Moats, Paltering, Evidence of Corruption, “Sabotaging Monopolies,” and Pitchfork Economics in the Manufactured Housing DOE Energy Rule Process.
- A) While the DOE energy rule was not the focus of the research by Samuel Strommen at Knudson Law into manufactured housing, he made a heavily footnoted case that MHI and their dominating brands are engaged in a scheme to monopolize the industry.
- B) Then there is a distinctive but similarly insightful third-party research by James A. “Jim” Schmitz Jr. and his colleagues that include others at the Minneapolis Federal Reserve and beyond.
- C) Schmitz and others have been arguing against the pernicious impacts of monopolization. They explore several professions, including manufactured housing in a periodic series of research reports.
D) Keep in mind the quotes from Bill Gates on finding the weaknesses in markets and taking advantages of them, plus Warren Buffett on moats. Schmitz and his colleagues have thus far focused on the harm caused by builders, their nonprofit front, and HUD. One must recall that Clayton Homes has been increasing their footprint in conventional housing for years. So, Clayton is in several ways once more on both sides of what might look like battles over regulations, but which Clayton is apt to benefit from when the market is minimized.
E) While the dominating brands don’t come out and directly say that they are deliberately limiting the market, the underperformance of manufactured housing is a ‘barrier for entry,’ a barrier for persistence, and a barrier for exit.
F) What the publicly traded members of MHI do say in their investor pitch-desk is this. They aim to consolidate the industry. This consolidation would not be as easy if the industry was growing robustly.
III) “The Science” Behind the DOE Rules and Several of the Rules Advocates.
- There are broadly speaking two general types of comments on the pending Manufactured Housing Notice of Proposed Rulemaking (NOPR).
- #1) Those who seem to strongly support the DOE proposal, perhaps to a different degree, but who nevertheless support new energy standards for HUD Code manufactured homes.
- #2) Those comments, largely from manufactured housing industry professionals, that strong oppose the manufactured home energy rule proposals.
- Category #1 comments, often from special interest groups that have direct or oblique ties to various “climate change” and energy advocacy related concerns, could to a certain degree be taken at face value. Category #1 will be examined below.
- Category #2 comments tend to come from those which are connect to the Manufactured Housing Institute (MHI), but also from their often-smaller rival trade group, the Manufactured Housing Association for Regulatory Reform (MHARR). Category #2 comments, on the surface, seem similar in nature. That noted, Category #2 comments will also be examined herein below.
- Let’s begin with Category #1. There are logically 3 broad possibilities.
- 1) The concerns about the risks from man-made climate change are authentic, based upon good science, and are thus valid. If humanity is truly facing an existential crisis, then surely every effort should be made to mitigate that threat. Thus, manufactured home energy standards imposed by the DOE could in some sense be considered reasonable, necessary, and good. But that notion would be contingent upon the notion of the science behind ‘man made climate change’ being valid.
- 2) However, if concerns about man-made climate change are not a matter of broad popular consensus, as well as of sound scientific consensus, then the question should be asked. Are such energy standards a solution in search of a problem?
- 3) There is a possibility that something between those two poles could exist that are closer to reality.
- 4) Additionally, there is a question of just how much the public is willing to pay for the mitigation of climate-related ‘threats.’
- What the objective evidence suggests is that there is climate change.
- Indeed, the evidence suggests that climate change is ongoing on a daily, seasonally, and over the course of centuries and millennia. Note this below from Wikipedia is not provided as ‘fact checked,’ but rather as an example of the type of illustration that is used to support the concerns over ‘man made’ climate change.
- That noted, the question is to what extend is climate change being caused by humanity? The answer is far simpler than some may think.
- Centuries and millennia before the industrial revolution and the purported harms caused by human activity to the climate, geology provides clear evidence of the rising and falling of the seas. The map of Florida through the ages is an apt illustration of this point.
- For sincere Category #1A thinkers and believers, as common as the belief in manmade climate change may be, common beliefs have been disproven by science in the past. The flat earth theory is a common example. Or the sun revolving around the earth was once a common belief, but it was later disproven.
2. Next, to the point made by the broad quote by Roxanne Bland – “Forget what the told you. If you want the truth, follow the money.” There is clear evidence that deep corporate and/or ultra-wealthy pockets are tied to the litigation that brought the DOE and manufactured housing interests back to this present status.
3) That MHProNews Masthead report should be considered as part of this writer’s comments. It includes third-party research evidence.
4) There is no known evidence that this concern has been properly brought before the DOE by the various advocacy groups previously referenced herein. This and the graphic at the right are reasons to entirely scrub this manufactured housing energy rule process, pending an independent investigation of the concerns being raised.
5) When the Biden Administration took office, one of the first actions was to stop the Keystone XL pipeline. That had a clear benefit to Warren Buffett and others investments.
6) “The Keystone pipeline. Cancelled by Biden on first day. Warren Buffet [i.e.: Berkshire Hathaway (BRK)] owns the railroad that is now transporting all that oil…Warren Buffetwould lose billions in transport fees if the pipeline is completed. See how politics works? It is not an environmental issue, it is a money issue…” That’s per the Foundation for Economic Education (FEE). The counterargument that some made is that FEE was mistaken in saying that Buffett made big donations to the Biden campaign. Money is fungible. There are numerous ways that Buffett could subtly or substantially support candidate-turned apparent 46th President Joseph “Joe” Biden. FEE’s point stands regardless of the amount of Buffett’s donation. While this has not been raised by MHARR, it fits their broader claim that the DOE energy rule process has been fundamentally tainted. Again, all linked comments should be considered as part of my submission for the DOE’s consideration.
7) While killing the Keystone XL, the Biden White House stood by while the Russian pipeline into the NATO powers of the European Union moved ahead. See the links from mainstream media.
https://www.politico.com › news › 2021/07/21 › democ…
Jul 21, 2021 — President Joe Biden is facing bipartisan backlash to his administration’s agreement with Germany that allows a controversial Russian …
Biden’s strategy on the Russia-to-Germany gas pipeline …
https://www.cnbc.com › 2021/05/21 › bidens-strategy-…
May 21, 2021 — The Biden administration is facing backlash for a decision to waive sanctions on a Russian company overseeing the construction of the …
Nord Stream 2: Biden waives US sanctions on Russian pipeline
https://www.bbc.com › world-us-canada-57180674
May 20, 2021 — The Biden administration has waived sanctions on a company building a controversial gas pipeline between Russia and Germany.
8) This cancelling of Keystone while green-lighting the Russian Nord Stream 2 pipeline is a glaring contradiction. But there are other contradictions that are frankly too many to mention.
9) Let’s point to just a few contradictions to illustrate how those who question ‘man made climate change’ underscore that the position of its supporters are absurd at best.
10) The Obama’s bought an ocean-side mansion in tony Martha’s Vineyard, where the elites meet, vacation, and live. If the oceans and seas are ‘rising,’ wasn’t this a pretty short-sighted move? Far more likely, says common sense, is that Obamas know that man-made climate change is not a real thing that humanity can change.
11) Additionally, per recent public polling, even those who believe that climate change is a serious concern, the public is not willing to pay much toward mitigation. These two links appeared number 1 and 2 under a Google search on this topic on 11.23.2021.
Jan 24, 2019 · More Americans believe in global warming — but they won’t pay much to fix it. Most Americans are unwilling to pay $10 a month to fight climate change, a survey found.
Americans Believe Climate Change Is Happening But Are Only Willing To Pay $1 In Carbon Tax, Poll Shows
Oct 27, 2021 · Americans Believe Climate Change Is Happening But Are Only Willing To Pay $1 In Carbon Tax, Poll Shows. The majority of Americans believe that human-caused climate change is occurring but are unwilling to pay more than $1 extra to mitigate its effects, a new poll shows.
- 12) If the public is unwilling to spend such a modest sum of money – and our Republic is supposed to be a country of, by and for the people – then under what argument can the DOE construe its authority to do far more costly efforts toward a problem that is disputed?
- 13) To the point of soft-corruption that some say is hiding in plain sight is this donation from one of the world’s richest men.
- 14) To underscore the above, one of the world’s richest men, Jeff Bezos, announced a donation to the Obama Foundation of $100 million dollars.
- 15) The argument for climate change is shown in part below, but in doing so, they cite a number of groups that are opposed to the notion of manmade climate change. While the list below is deemed to be front group for fossil fuel interests, that is akin to Warren Buffett or others making donations to the Sierra Club. There is no doubt that when someone ‘follows the money trail,’ there is money that is tainting both sides of the debate.
An overwhelming majority of scientists agree – global warming is happening and human activity is the primary cause. Yet several prominent global warming skeptic organizations are actively working to sow doubt about the facts of global warming.
Jul 16, 2008 · Published Jul 16, 2008 Updated Aug 16, 2013. An overwhelming majority of scientists agree — global warming is happening and human activity is the primary cause. Yet several prominent global warming skeptic organizations are actively working to sow doubt about the facts of global warming.
- 16) That said, per their website: “Climate Intelligence (CLINTEL) is an independent foundation that operates in the fields of climate change and climate policy. CLINTEL was founded in 2019 by emeritus professor of geophysics Guus Berkhout and science journalist Marcel Crok.”
Their statement is summed up like this: World Climate Declaration – Clintel “There is no climate emergency.”
- 17) Until there is a true consensus and citizens are willing to pay more than $1 to $10 monthly for climate mitigation efforts, any possible rationale advanced by the DOE to advance the manufactured housing energy rule is undermined by the kinds of concerns raised herein.
- 18) Not to be overlooked is the revolving door and Iron Triangle type influence on DOE.
[PDF] The New Revolving Door
Jan 20, 2020 · the environmental area—a new green revolving door—but we suggest that this new revolving door also may be emerging in labor, health and safety, and other regulatory areas. † David Daniels Allen Distinguished Chair of Law; Director, Climate Change Research Network; and Co-Director, Energy, Environment and
The iron triangle is a hypothetical arrangement among three elements (the corners of the triangle): an interest group, a congressional committee member or chair, and an agency within the bureaucracy. 57 Each element has a symbiotic relationship with the other two, and it is difficult for those outside the triangle to break into it.
Contact. American Enterprise Institute 1789 Massachusetts Avenue, NW Washington, DC 20036 Main telephone: 202.862.5800 Main fax: 202.862.7177
- 19) Last for now, but certainly not least, is the fact that the U.S. is utterly unable to effect change solo or in conjunction with other nations, so long as the two largest polluters – said to be Communist China and India, continue to expand their use of fossil fuels.
The economic challenges facing Jerome Powell and Joe Biden Opinion | Finance Specifically, the central challenge to Powell in his second term will be walking the fine line between controlling inflation and rising prices while also being careful not to raise interest rates in a way that curbs economic growth, causes stagflation, or leads to another recession.
Sep 09, 2020 · China, the United States and India are being hit harder than ever by climate impacts. There is growing public support for climate action, but there needs to be resolute country leadership.
- Estimated Reading Time: 9 mins
EXCLUSIVE – A Republican senator is claiming Facebook responded to her inquiry about the company’s harmful effects on children by suggesting it hasn’t done anything wrong, refusing to give access to relevant internal research, and egregiously misleading Congress and its users.
Jun 05, 2019 · There are many nations, the largest of which — China and India — are still rapidly developing their economies. U.S. emissions have been on the decline for more than a decade, in fact …
- 20) Summing Up Category #1 issues. Those who may sincerely support doing something run up against the sobering indications stated and linked above. There are factual and evidence-based reasons to doubt that any level of climate change is indeed caused to a large degree by human influences. History, geology, and archeology all reveal that climate on planet Earth has always been changing.
- 21) Citizens who ‘believe’ in climate change don’t want to pay much for it. There is a growing push-back against Biden Administration policies that are driving up prices and inflation. There are dark money forces on both sides of the debate, and there is no consensus despite claims to the contrary.
- 22) For these and an array of other reasons, the DOE energy rule for manufactured housing based on any Category #1 related thinking are fundamentally flawed.
- 23) Category #2 opposition to this proposed energy rule on manufactured housing should thus be given credence for these reasons.
- 24) At a minimum, the DOE should attempt a serious effort to have a healthy, transparent, and public debate over the climate issue. The fact that deep pockets are pressing the issue doesn’t mean it is genuine.
IV) Obvious and subtle Corruption, Iron Triangles, Conflicts of Interest, Purported Illegalities.
- A) We can look at statements and descriptions such as “the moat,” “sabotaging monopolies,” the revolving door and other similar notions for evidence that the process at DOE is tainted.
- B) There are years of evidence that MHI and their dominating brands are posturing support for manufactured housing while they routinely are ineffective at doing what they claim.
- C) Who says B? Ironically, one of their past chairman and one of their past award winners.
D) MHI notes that they had 48 state association affiliates. At one time, they claimed some 50 such groups. What happened? Let’s look.
- E) There is growing evidence that some key members of MHI are engaged in corrupt and/or illegal behavior.
F) One might think that MHI would on occasion win a battle on behalf of the manufactured housing industry. But in the Berkshire era, there seems to be a lot of paltering and posturing going on that results in lots of MHI generated headlines that yield few-to-any serious results that actually trace back to MHI.
G) MHI spent years and millions of dollars in lobbying for “Preserving Access to Manufactured Housing.” It never passed. But the truth hiding in plain sight was that Warren Buffett said he opposed the changes to the rule and that he supported the Obama-Biden Administration’s reelection.
- H) There is ample evidence that the controversies that routinely keep manufactured housing with a public black eye routinely traces back to MHI member brands. This is despite their so-called Code of Ethical Conduct.
- I) There is clear evidence that MHI has covered up behavior from federal officials that doesn’t fit their narrative.
- J) This pattern of MHI behavior has existed regardless if a Democrat or Republican is in the White House.
- K) A MHEC member explained why the state associations routinely go along with MHI.
- L) Former MHI VP turned MHARR founding president put it like this.
v) Summing Up and Conclusion
- A) Former MHI Chair Nathan Smith said it. MHI has a history of talk without delivery. Marty Lavin, J.D., has said similarly for years.
- B) I opened this comments letter with a quote similar to Lavin’s above. I make these comments as the co-founder and publisher of the most-read trade media serving manufactured housing professionals. MHProNews is documented to dominate, and we have a public-facing sister site – MHLivingNews – each of which gets millions of visits a year, per third party data. MHI and others praised MHProNews for years, right up to the point that they apparently recognized that their pattern of behavior was becoming apparent to us, and we began to report accordingly.
- C) Let’s recap the prologue to this letter and draw to a conclusion in that fashion.
- “The system is rigged.” – Senator Bernie Sanders (VT-DS), Donald J. Trump (as candidate and as the 45th President of the United States, R), Senator Elizabeth Warren (MA-D), along with a host of other candidates, officials, and pundits.
- “Propaganda works” on “most Americans.” – Guy Benson, author.
- “If you tell a lie big enough and keep repeating it, people will eventually come to believe it. The lie can be maintained only for such time as the State can shield the people from the political, economic and/or military consequences of the lie. It thus becomes vitally important for the State to use all of its powers to repress dissent, for the truth is the mortal enemy of the lie, and thus by extension, the truth is the greatest enemy of the State.” – Joseph Goebbels, Jewish Virtual Library.
- “The best way to control the opposition is to lead it ourselves.” —Vladimir Lenin.
- “Paltering is the active use of truthful statements to convey a misleading impression. Across 2 pilot studies and 6 experiments, we identify paltering as a distinct form of deception.” Harvard (2017). “Paltering is the active use of selective truthful statements to mislead. The term as applied in psychology and mediation studies was developed by researchers at the John F. Kennedy School of Government in the late 2000s. The first known use of palter to describe acting insincerely or deceitfully was in the 1580s.” – Wikipedia.
- “Facts are stubborn things.” More specifically: “Facts are stubborn things; and whatever may be our wishes, our inclinations, or the dictates of our passion, they cannot alter the state of facts and evidence.” ― John Adams, GoodReads.
- ‘Tell them what you will say. Say it with convincing evidence. Tell them what you told them.’
- D) Once the facts, conflicts of interests, competing claims, head fakes, apparent corruption and purported illegalities are unpacked and examined, it becomes clear that the DOE energy rule is just one more example of what this writer said to the FHFA Listening Session earlier this year. Please keep in mind that all of these linked items are part of my comments, as are the referenced MHARR comments letters.
- E) With all due respect to Harvard and Wikipedia, deception and misdirection, paltering, and such methods go back to Biblical times. The motivations are routinely about money and power. Who says? Warren Buffett and his longtime partner, Charlie Munger, J.D.
G) If MHI actually cared about minorities and those who are being denied access to affordable housing, they would be acting in cases like the one linked below.
H) If MHI authentically cared about stopping this energy rule, or a range of other issues that limit manufactured housing, they would use their financial and legal resources as the nonprofits below have done.
J) For these and other reasons, this multi-decade professional in manufactured housing professional who believes in the rights of all, not just the elites, opposes the DOE energy rule as being hopelessly corrupted.
L. A. “Tony” Kovach
LifeStyle Factory Homes, LLC
Connect on LinkedIn:
L. A. “Tony” Kovach is one of the most endorsed professionals in manufactured housing. He is the winner of numerous awards in history, including the Lottinville Award from the University of Oklahoma.
Whether you think you can or whether you think you can’t, you’re right. – Henry Ford ##
A copy of the PDF as submitted is linked here. The Regulations.gov website confirmed receipt.
Stay tuned for more of what is ‘behind the curtains’ as well as what is obvious and in your face reporting that are not found anywhere else in MHVille. It is all here, which may explain why this is the runaway largest and most-read source for authentic manufactured home “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, further below. 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.
Connect on LinkedIn: http://www.linkedin.com/in/latonykovach
The text/image boxes below are linked to other reports, which can be accessed by clicking on them.
Wrath of Khan? “Critical Time” “Support…Manufactured Housing Industry” Says Manufactured Housing Institute – Claims “Protecting Your Business and Expanding Opportunities” – Facts, Fiction, FRAUD-Analysis