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The lack of affordable housing was one of the top issues that guided voting decisions according to various pollsters. The lack of affordable housing near where it is needed in the U.S. costs the economy about $2 trillion dollars a year in economic drag. The 2024 election is largely in the rearview mirror. Donald J. Trump (R) has overcome the challenge of essentially incumbent Kamala Harris (D), winning both the popular vote and the electoral college. Some states and votes are yet to be settled, but several sources, including Real Clear Politics (RCP) Republican will hold the U.S. House, take control of the U.S. Senate, and of course won the presidency. The incoming president determines who will lead various federal agencies and other senior positions. The new Trump cabinet and senior advisors, chief of staff and other presidential team members are being organized. More details on the nuances before or since the election can be found on MHProNews or on our series on the Patch, which included articles on the political, economic, messaging, and media angles plus several affordable housing and manufactured home focused items among them. With those thoughts in mind, the Manufactured Housing Association for Regulatory Reform (MHARR) issued a media release, provided below, urgently asking the incoming Trump transition team to intervene in the controversial application of the Biden-Harris (D) regime’s Department of Energy (DOE) manufactured housing energy rule. Reports on that topic from MHARR are linked here and on MHProNews are linked here.
Part I of this article will provide the news release from the Manufactured Housing Association for Regulatory Reform (MHARR).
Part II of this report has the text of the letter from MHARR to President-elect Trump and the Trump Transition team members.
Part III provides additional information with more analysis.
Part I
NOVEMBER 12, 2024
TO: HUD CODE MANUFACTURD HOUSING INDUSTRY MEMBERS
FROM: MHARR
RE: MHARR CALLS FOR URGENT ACTION BY PRESIDENT TRUMP
TO WITHDRAW AND REPEAL DOE MH ENERGY REGULATIONS
Upon the election of Donald J. Trump as the 47th President of the United States, the Manufactured Housing Association for Regulatory Reform (MHARR) has taken immediate action, urging the President and his transition team to prioritize the repeal and withdrawal of pending U.S. Department of Energy (DOE) manufactured housing “energy” regulations that would needlessly undermine the inherent affordability of mainstream HUD Code manufactured homes.
In a November 7, 2024 communication to the President-Elect (copy attached), MHARR states: “… it is imperative that your new Administration take action at the earliest possible date to prevent the implementation of the pending DOE manufactured housing “energy” standards and withdraw or repeal those standards.”
MHARR’s communication stresses that a repeal of the pending 2022 manufactured housing energy standards and 2024 proposed enforcement procedures rule is not only essential for the continued affordability of mainstream manufactured housing, but would be fully consistent with President Trump’s withdrawal of an earlier iteration of the DOE manufactured housing “energy” standards upon assuming office for his first term in 2017. Such an action by the incoming administration would potentially moot the need for further litigation against the DOE rule in the pending federal court case.
Because of the fundamental importance of this issue to the entire industry – and consumers of HUD Code manufactured housing as well – MHARR strongly urges and encourages all industry members and all state associations in particular, to join in the effort to encourage President Trump to repeal and withdraw these destructive pending regulations before they can inflict real and irreparable damage on both the industry and consumers. Simply put, at a time when homeownership is increasingly out of reach for lower and moderate-income Americans, and younger Americans in particular, the availability of affordable homeownership via manufactured housing should not be mortally wounded by needless, unnecessary regulation driven by climate extremists and their allied special interests.
For its part, MHARR will continue to take strong action to oppose the DOE standards and remove and eliminate the threat that they pose to both the industry and American consumers of affordable housing.
—
Part II
November 7, 2024
VIA FEDERAL EXPRESS AND FIRST-CLASS MAIL
Hon. Donald J. Trump
President-Elect
1100 S. Ocean Boulevard
Palm Beach, Florida 33480
Re: Urgent Manufactured Housing Transition Issue
Dear President Trump:
On behalf of the Manufactured Housing Association for Regulatory Reform (MHARR) and its members, please accept our congratulations on your election as the 47th President of the United States.
MHARR is a Washington, D.C.-based national trade association representing the views and interests of producers of manufactured housing regulated by the U.S. Department of Housing and Urban Development (HUD). MHARR’s members – like the vast majority of the manufactured housing industry – are primarily smaller businesses.
We are writing to inform you of an urgent, time-sensitive regulatory issue affecting our industry, that we hope your incoming administration will address and resolve on an expedited basis.
Specifically, the Biden Administration, through the U.S. Department of Energy (DOE), is on the verge of implementing destructive “energy conservation” regulations for manufactured homes that will destroy the inherent affordability of the industry’s mainstream homes. At a time when the cost of homeownership is at record highs, when the supply of affordable homes (and particularly affordable “starter” homes) is millions of units below existing demand, and the number of first-time homebuyers stands at a record low due, in substantial part, to home price inflation, the implementation of these new “climate change” standards – which would needlessly add thousands of dollars to the retail cost of new manufactured homes – would price hundreds-of-thousands of lower and moderate-income manufactured homebuyers out of the market (and out of homeownership altogether) while delivering a death blow to many industry businesses and smaller businesses in particular.
It is important to stress that these impending standards – an earlier iteration of which was rejected and withdrawn by your first Administration in 2017 – would not only be economically disastrous, but are also totally unnecessary. As MHARR has consistently demonstrated in the DOE rulemaking proceedings that culminated in the rejected 2016/2017 proposed rule and the impending 2022 final rule, manufactured housing energy consumption costs for homeowners and renters, according to official U.S. Census Bureau data, are already (and long have been) lower than or equal to those for other more costly types of housing.
Consequently, the impending DOE standards do not respond to or address any proven consumer need or any legitimate alleged deficiency in today’s modern manufactured housing, but instead are a product of the phony “climate change” agenda and represent an effort by “climate change” extremists to insinuate their destructive demands within the multi-billion dollar housing market by first infecting the comprehensively federally-regulated manufactured housing sector as a regulatory “Trojan Horse.”
While the manufactured housing industry faces other headwinds that are preventing it from truly fulfilling its enormous potential to help solve the nation’s affordable housing crisis – including discriminatory zoning exclusion and a complete lack of federal support for the manufactured housing consumer finance market in violation of existing law – all issues that we will seek to address and rectify with your Administration in due course, it is imperative that your new Administration take action at the earliest possible date to prevent the implementation of the pending DOE manufactured housing “energy” standards and withdraw or repeal those standards. Materials providing additional relevant details regarding the DOE standards are attached for your reference.
On behalf of MHARR and its member manufacturers, we appreciate your attention to this matter and look forward to working with your incoming Administration to Make America Great Again.
Thank you and please accept our best wishes.
Sincerely,
Mark Weiss
President & CEO
cc: Ms. Linda McMahon
Mr. Howard Lutnick
Hon. Mike Johnson
Hon. Patrick McHenry
Hon. Tim Scott
Mr. Danny Ghorbani (MHARR Founding President and CEO)
MHARR Manufacturers
Part III – Additional Facts, Evidence, and Analysis (FEA) from MHLivingNews
In no particular order of importance are the following related facts, evidence, and commentary.
1) Along with rent and conventional housing, manufactured home costs shot up during the Biden-Harris years. Per the U.S. Census Bureau is the following data snapshots to illustrate evidence for that point. The average cost of all manufactured homes produced, using U.S. Census Bureau data, in the 32 months from Jan 2021 to Sept 2023 was 1.26, or a 26 percent increase for consumers (see table below). Using the National Association of Home Builders (NAHB) “priced out” data, that means millions that previously could have qualified for a manufactured home no longer could, due in large part to factors directly attributable to Biden-Harris policies.
| United States | Total Avg | Single | Double | |||
| Sep 2023 | $119,700 | $80,400 | $151,700 | |||
| Jan 2021 | $95,000 | $64,100 | $118,500 | |||
2) The Manufactured Housing Institute (MHI) on this data (11.13.2024) at about 11:25 AM ET has no apparent news articles on the topic of the pending DOE manufactured housing energy rule. Nor is there any other apparent mention of the 2024 election outcome, as there is from the MHARR website.
3) Additionally, MHI still has on this date their “celebrating” “50 years of partnership with HUD.” By contrast, MHARR has said that HUD is part of the problem at the federal level rather than part of the solution.
4) In an interview with our sister site, MHProNews, MHARR’s Danny Ghorbani pointed out that MHI played an apparent role in fostering the current DOE regulations. Nevertheless, after months of public pressure from MHARR, MHProNews, and MHLivingNews, MHI finally filed suit to stop the implementation of the DOE energy rule that MHARR is now asking the incoming Trump administration to stop altogether.
5) MHI’s split-personality behavior on the DOE energy rule included belated launching litigation only after being pressured, and then they claimed asserted that the energy rule would cause “irreparable harm”
6) What is inescapable is that the energy rule proposed is based upon a flawed premise. Conventional housing standards don’t work for homes that are built in a factory to performance standards. MHI has admitted as much. But that begs questions, such as, why didn’t they issue a letter to the Trump Transition team like MHARR has done? If MHI have done so, there is no known evidence for that move. To illustrate, consider the following Q&A with left-leaning Bing’s AI powered Copilot.
MHARR has issued a statement that they have contacted the Trump transition team to ask them to stop the problematic DOE energy rule: https://manufacturedhousingassociationregulatoryreform.org/mharr-calls-for-urgent-action-by-president-trump-to-withdraw-and-repeal-doe-manufactured-home-energy-regulations/ can you find any evidence that the Manufactured Housing Institute has done similarly?
The Manufactured Housing Institute (MHI) has expressed concerns about the DOE’s energy efficiency standards for manufactured housing. They have stated that the final rule is not cost-effective and will hurt the affordability of manufactured homes. However, I couldn’t find any specific evidence that MHI has contacted the Trump transition team or taken similar actions as MHARR.
If you need more detailed information, you might want to check MHI’s official website or contact them directly.
1 www.manufacturedhomepronews.com …”
See the linked reports or use the search tool on here on MHLivingNews, on MHProNews, or on MHARR to learn more. ###
Mobile Home and Manufactured Home Living News explores the good, bad, and ugly realities that keep the most proven form of affordable home ownership under-appreciated and misunderstood. MHLivingNews provides third-party research and other resource collections and reports not found on other sites. We also provide thought provoking analysis that are designed to open minds and hearts. This is the widely acknowledged best source for authentic news on mobile and manufactured home living, as well as the policies that impact this segment of housing that provides 22 million Americans with good, surprisingly appealing living.
On our MHProNews sister-site and here on MHLivingNews, we lay out the facts and insights that others can’t or won’t do. That’s what makes our sister site and this location the runaway leaders for authentic information about affordable housing in general, the politics behind the problems, and manufactured homes specifically.
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
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