U.S. Department of Energy Proposed Rulemaking Could Impact Manufactured Housing


The Department of Energy was established during the administration of President Jimmy Carter.

The creation of the DOE was a throwback to the drama of lines at U.S. gas stations arguably sparked by policies from the Organization of the Petroleum Exporting Countries or OPEC.


Decades of American involvement in Middle Eastern affairs was just part of the ebb and flow of oil, energy, terror, or geopolitical issues.


Fast-forward to the 2019.  A generation has grown up that has no experience much less memory of those episodes from the 1970s.  The U.S. says it is now the top oil and gas producer in the world. Texas, per reports, is now producing more oil and gas than at any other time in its history.

And from the great state of Texas comes former Governor Rick Perry, who is now the Secretary of the Department of Energy.

With that brief backdrop, is this press release to the Daily Business News on MHProNews from the Manufactured Housing Association for Regulatory Reform or MHARR.



FEBRUARY 13, 2019


TO:                  MHARR MANUFACTURERS

                        MHARR STATE AFFILIATES

                        MHARR TECHNICAL REVIEW GROUP (TRG)


FROM:             MHARR





The U.S. Department of Energy (DOE) has published a new proposed rule in the February 13, 2019 Federal Register (copy attached) that would significantly modify its procedures for developing new or revised energy conservation standards and related test procedures for consumer products, “appliances,” and certain commercial and industrial equipment.

While the proposed rule, as published, does not specifically reference standards development and/or test procedures under section 413 of the Energy Independence and Security Act of 2007 (42 U.S.C. 17071) directly pertaining to manufactured homes, the proposed rule does, by its terms, apply to DOE’s Appliance Standards Program — the same program under which the original proposed DOE manufactured housing energy standards rule (published June 17, 2016) was developed and subsequently modified by DOE pursuant to a Notice of Data Availability (NODA) published in the Federal Register on August 3, 2018. Industry members will recall that the manufactured housing energy rule had not substantially progressed at DOE until a segment of the industry, together with energy special interests (and DOE) in 2014, sought and engineered an illegitimate, truncated, dysfunctional “negotiated rulemaking” under DOE’s “appliance” rulemaking process, as a fig-leaf designed to achieve a pre-ordained result.

Given that the proposed (and still pending) DOE manufactured housing standards were developed under DOE Appliance Standards Program procedures that are addressed by the changes proposed in the February 13, 2019 DOE Notice, MHARR will file comments with DOE seeking to have the procedural modifications noted in the proposed rule applied to the manufactured housing proceeding, which would constitute yet another basis (among many others previously detailed by MHARR) for the withdrawal of any and all previously-proposed versions of the DOE manufactured housing standards – developed under or derived from — the inherently tainted DOE “negotiated rulemaking” process, and the ultimate development of a new rule based on a legitimate and lawful standards-development process consistent with the regulatory policies of the Trump Administration.

Among other things, the February 13, 2019 proposed rule would: (1) expand various procedural protections to test procedure rulemakings for regulated products; (2) define “a significant energy savings threshold that must be met before DOE will update an energy conservation standard;” and (3) “clarify DOE’s commitment to publish a test procedure six months before a related standards [Notice of Proposed Rulemaking].”  This is particularly significant in relation to DOE’s proposed manufactured housing energy standards, insofar as proposed test procedures were not published by DOE until after publication of the June 17, 2016 proposed rule, as was pointed out by MHARR at the time.

Written comments on the proposed rule are due by April 15, 2019.  MHARR will submit comprehensive comments (and participate in related meetings) in advance of the April 15, 2019 deadline and will make its comments available for reference by industry members.

As always, MHARR shall keep you apprised of any new developments in this matter.


cc:  Other Interested HUD Code Industry Members


— end of MHARR release —


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