by L. A. “Tony” Kovach
When MHI sent us a news release on not yet published DOE standards, it immediately raised some questions for me. So we contacted M. Mark Weiss, the Manufactured Housing Association for Regulatory Reform’s president and CEO and asked him the following questions.
Legend below: MHProNews questions are the Q, Mark Weiss replies are the A.
Q1. We’ve received a news release from MHI about a U.S. Department of Energy (DOE) proposed energy rule for manufactured housing being published. We did not receive anything from MHARR, however. Is there a reason?
A. Yes, the reason is that as of the time of your call to us, the DOE proposed rule has not yet been officially published in the Federal Register.
Q2. So, are you saying that DOE and MHI have put this out before official publication of the proposed rule in the Federal Register and, if so, why?
A. Yes, it appears that DOE — knowing that there is significant opposition to this within the industry – has given a head-start to MHI to provide them an advance opportunity to put a positive “spin” on this horrendous proposed rule and soften industry resistance. Of course, DOE, knowing of MHARR’s vehement and consistent opposition to the proposed rule, obviously would not provide the same advance notice to us.
Q3. Will MHARR put anything out about the proposed DOE rule when it is officially published?
A. Absolutely. As you know, MHARR has consistently opposed not only the substance of the DOE proposal arising out of the 2014 DOE “Working Group” process, but also the scandalous procedures by which DOE has advanced the proposed rule to this stage, with help from MHI. This rule would devastate smaller businesses in our industry, while taking a large chunk of potential manufactured home buyers out of the market because of unnecessary cost increases to our industry’s homes. At best, going along and supporting this process reflects bad judgment on the part of MHI. At worst, it amounts to seeking government assistance in hurting the industry’s small businesses.
Q4. Isn’t this rule taking away a consumer’s right to choose the type and level of energy efficiency that works best for them over the time they expect to own their home?
A. Exactly. This is a one-size-fits-all big government mandate that amounts to a highly regressive tax on our industry’s homebuyers. MHARR and other opponents of the rule have shown that today’s manufactured homes are already energy-efficient and that enhanced energy packages are already available on an optional basis for those home buyers who want them. Some home buyers choose to spend their dollars on those optional energy packages, while others choose upgraded kitchens, upgraded bathrooms, upgraded flooring, or other amenities, but that is their choice.
Q5. Doesn’t an NAHB (National Association of Home Builders) study suggest that this rule will cost the industry significant numbers of potential home buyers?
A.You’re right again. The NAHB study, which was the only direct market impact information submitted during the DOE “Working Group” process, shows that increasing the price of new single-section manufactured homes by $1,000 would “disqualify 347,901 households from being able to afford these homes.” Similarly, if the price of new double-section manufactured home “rises by $1,000, 315,385 households will be priced out of the market.” Cost information developed by the DOE Working Group shows price increases from $2,000 to $4,000.00 under its proposal, while information developed by MHARR shows increases of $6,000 and likely more, once regulatory compliance costs are factored in. This is why DOE, MHI and other supporters of this rule have not heard the end of this. MHARR will continue to fight the implementation of this horrendous rule – and let me stop at that, without going into further detail at this time.
Q6. Will our MHProNews readers and others in the industry know more about MHARR’s views on this proposed rule soon?
A. Absolutely. MHARR, though, works within the law. Once this proposed rule is officially published in the Federal Register, MHARR will issue an announcement, followed by comments to DOE and possible further actions if DOE proceeds with a final rule. So please, stay tuned. (end of interview Q&A)
The graphics below link to information that should give MHPros pause as to why this proposed DOE energy rule should NOT be implemented. Note the sources are from outside of the MH industry.
Editor’s Note: MHProNews also asked DOE and MHI both to comment at that same time, both declined to avail themselves of the opportunity. Hmmm…
The extensive excerpt of the MHI Housing Alert on this topic is linked here, and includes two links to downloads that were in their original release. ## #