As an outgrowth of MHARR’s strenuous and continuing opposition to the imposition of extremely costly new manufactured housing energy standards by the U.S. Department of Energy (DOE), a DOE contractor, Navigant Consulting — based on calls to our office from MHARR manufacturers — is attempting to arrange meetings and interviews with producers of manufactured housing and especially “small manufacturers,” supposedly to gauge “concerns” and assess the potential “impacts” of such standards.

This same contractor (among others) was directly involved in providing analytical support for DOE during the DOE manufactured housing “Working Group” process in 2014, and is fully aware – as is DOE – of MHARR’s opposition to the unnecessary and excessively costly Working Group recommendations that will reportedly form the basis for a DOE proposed rule, which may be issued very soon.

It is clear that because of MHARR’s effective opposition – at the Working Group level and since that time, having presented cost impact analytical data for smaller manufacturers to DOE at an in-person meeting with senior officials on March 26, 2015 – and also because of the support that these costly DOE proposals enjoy from larger industry manufacturers, DOE is pursuing a “divide and conquer” approach designed to corner individual manufacturers in separate meetings and with separate “questionnaires” seeking any type of information or comment(s) that could then be used to support the costly DOE proposed standards.

Therefore, if contacted in this manner, we suggest – given the information that MHARR possesses regarding the small business cost impacts of this rule and the significant institutional history of this proceeding – that you refer any such requests or inquiries to MHARR for follow-up on a collective basis.

Please let us know if you have any questions or additional information, and we will continue to keep you updated as developments warrant.