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The Manufactured Housing Association for Regulatory Reform (MHARR) provided a copy of their letter to DOE Secretary Chris Wright which is published on their site at this link here. Part II of this report with analysis will include the video that is the source for the base of the featured image for this article. Numbers of other details related to these topics are included or linked.
Part I – The letter below, as noted above, was provided by MHARR. Notice: The press release logo was created by MHLivingNews/MHProNews for use with MHARR media releases, it is not an official MHARR image.
February 26, 2025
VIA FEDERAL EXPRESS
Hon. Chris Wright
Secretary
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585
Re: Manufactured Housing Energy Standards and Enforcement Regulations
Dear Secretary Wright:
I am writing on behalf of the members of the Manufactured Housing Association for Regulatory Reform (MHARR). MHARR is a Washington, D.C.-based national trade organization representing the views and interests of producers of manufactured housing subject to regulation by the U.S. Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act (42 U.S.C. 5401, et seq.) as amended by the Manufactured Housing Improvement Act of 2000 (2000 Reform Law), and by the U.S. Department of Energy (DOE) pursuant to section 17071 of the Energy independence and Security Act of 2007 (42 U.S.C. 17071) (EISA). MHARR’s members are primarily smaller and medium-sized independent producers of manufactured housing located in all regions of the United States.
On January 23, 2025, MHARR wrote to both you and HUD Secretary Scott Turner regarding pending Biden-Era “energy conservation” regulations for manufactured homes (copy attached as Attachment 1 hereto). In that communication, we noted that both the “standards” portion of the DOE energy regulation — published as a final rule on May 31, 2022, but not yet been implemented, and the “enforcement” portion of the regulation, published as a proposed rule on December 26, 2023 – could not proceed to implementation and were required to be delayed pursuant to President Trump’s January 20, 2025 Regulatory Freeze Executive Order (EO). We also asked, at that time, that the “Trump Administration disavow and withdraw” both of these regulatory actions based on multiple fatal defects that irretrievably tainted and contaminated the DOE administrative process leading to their promulgation.
Since the time of that communication, DOE, in a filing before the United States District Court for the Western District of Texas, in litigation concerning the manufactured housing energy standards, styled Manufactured Housing Institute v Department of Energy (Civil Action No. 23-cv-00174), has stated that “DOE intends to initiate rulemaking to propose a further delay to the Final Rule’s compliance date for Tier 2 [manufactured] homes.” (See, Attachment 2 hereto).
While MHARR, in that “rulemaking,” will not object to a further delay of the May 31, 2022 DOE manufactured housing energy standard, per se, it must be stressed, emphasized and understood by DOE, that the May 31, 2022 standard is itself fatally flawed, arbitrary and capricious in violation of applicable law, wholly in violation of both substantive federal manufactured housing law and Trump Administration policies concerning “climate” mandates, and should (and must) be rejected and withdrawn by DOE as a final action, and not merely “delayed.” As MHARR’s filings in the administrative record of both the standards rule and the enforcement proposed rule amply demonstrate, the entire DOE standards development process leading to both such actions was inherently, fundamentally and irretrievably tainted and infected by multiple instances of unlawful activity and conduct by DOE (and arguably others as well). As a result, there is no path or method available to DOE to somehow “rehabilitate” either the May 31, 2022 standards rule or the December 26, 2023 proposed enforcement rule, and both should (and must) be abandoned without any implementation.
Further, there is no extant judicial mandate requiring that the said standards be promulgated. While the United States District Court for the District of Columbia, in litigation styled Sierra Club v. Perry (Civil Action No. 17-2700) entered a consent decree on November 21, 2019 requiring, inter alia, that DOE “sign a Federal Register notice proposing standards for energy efficiency in manufactured housing pursuant to 42 U.S.C. 1707(a)(1)” by “not later than May 14, 2021,” that decree was vacated upon motion of DOE itself and the underlying case dismissed by a minute order entered on October 19, 2022.
Accordingly, and insofar as manufactured housing energy standards as posited by DOE would decimate both the manufactured housing industry and American consumers of affordable housing, particularly lower and moderate-income American families who rely on HUD Code manufactured housing as their only means of obtaining homeownership — needlessly adding thousands of dollars to the purchase price of a new home — DOE should reject any and all such “standards” and allow HUD to address any relevant issues through the statutory Manufactured Housing Consensus Committee (MHCC). At a time when affordable housing and homeownership is already in critically short supply, DOE should not make matters worse through baseless regulatory burdens.
Thank you in advance for your consideration, we look forward to meeting with you soon to address this crucial matter.
Sincerely,
Mark Weiss
President and CEO
cc: Hon. Donald J. Trump
Hon. Scott Turner
Hon. Russell Vought
HUD Code Manufacturers
Part II – Additional Information with More MHLivingNews Analysis and Commentary
1) There are good reasons to believe that MHARR’s message, shown above, could be favorably recieved by the President Donald J. Trump 2.0 Administration (a.k.a.: T2) and Energy Secretary Chris Wright. To illustrate, consider this video by Sec. Wright in a Q&A with the Alliance for Responsible Citizenship (ARC) 2025 a week ago.
2) For those who watch the roughly 12:51 second video above will notice some strong remarks that evoked applause from the ARC 2025 event attendees. While it predates that report, the articles linked below shed relevant light on Sec. Wright’s remarks.
3) According to left-leaning Wikipedia, this is part of Sec. Wright’s bio.
Wright was born in 1965 and grew up in Colorado. He earned a bachelor’s degree in mechanical engineering and a master’s degree in electrical engineering at the Massachusetts Institute of Technology (MIT). He was a graduate student in electrical engineering at the University of California, Berkeley and at MIT.
4) From the DOE website is this biographical background about Sec. Wright.
Chris Wright is the 17th Secretary for the U.S. Department of Energy. A self-described energy nerd turned entrepreneur, Chris is a dedicated humanitarian with a passion for bringing the benefits of energy to every community in the world. This passion has inspired a career in energy, working not only in oil and gas but nuclear, solar, and geothermal. As Secretary of Energy, Chris is focused on unleashing American energy dominance, accelerating innovation and advancing all energy sources that are affordable, reliable and secure for the American people.
Chris completed an undergraduate degree in Mechanical Engineering at MIT and graduate work in Electrical Engineering at UC Berkeley and MIT. He founded Pinnacle Technologies and served as CEO from 1992 to 2006. Pinnacle created the hydraulic fracture mapping industry, and its innovations helped launch commercial shale gas production in the late 1990s. Chris was Chairman of Stroud Energy, an early shale gas producer, before selling to Range Resources in 2006. Most recently, Chris served as Chairman and CEO of Liberty Energy, where his team helped to expand the shale revolution to include oil as well as natural gas. Chris has also participated in an effort to apply shale technology to unlock next-generation geothermal and helped to launch small modular reactors.
Chris was nominated by President Trump to serve as the 17th Secretary of Energy on November 16, 2024 and confirmed by the U.S. Senate on February 3rd, 2025. He grew up and in Colorado and currently lives in Washington, D.C. with his wife, Liz. He is a passionate father, grandfather, skier, cyclist, climber, and outdoor enthusiast.
5) Thanks in no small part to the efforts of MHARR, MHLivingNews, and MHProNews. The details are found in the deeper dive linked below.
Note that in the letter above, Mark Weiss, J.D., President and CEO of MHARR said this. The bold is added by MHLivingNews and will be the focus of the comments that follow the report linked below that pull quote.
As MHARR’s filings in the administrative record of both the standards rule and the enforcement proposed rule amply demonstrate, the entire DOE standards development process leading to both such actions was inherently, fundamentally and irretrievably tainted and infected by multiple instances of unlawful activity and conduct by DOE (and arguably others as well).
There are not details provided by MHARR as to who or what those “multiple instances of unlawful activity and conduct by DOE (and arguably others as well)” parties are. Does it imply, among others, the Manufactured Housing Institute? See the report linked above for greater insight into that relevant question.
6) MHLivingNews and/or our MHProNews sister site will be monitoring and reporting on the factors that are fostering, or slowing, the availability of more affordable manufactured homes for Americans. See the linked reports to learn more.
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That’s a wrap on this installment of “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 MHLivingNews.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
Recent and Related Reports:
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