MHI And Texas Manufactured Housing Association Take Legal Action To Delay Implementation of The DOE Energy Standards

The following is a letter to MHI members from Leo Poggione. MHI Chairman.

Dear MHI Members,

Yesterday, MHI and the Texas Manufactured Housing Association took legal action to delay implementation of the Department of Energy’s (DOE) “Energy Conservation Standards for Manufactured Housing,” which are scheduled to take effect on May 31.

For several years, MHI has been pursuing a multi-pronged strategy to stop implementation of the DOE standards until the standards are properly incorporated into the HUD Code. Progress has been made with HUD and lawmakers, and we are continuing to work with DOE and HUD to find a workable and affordable solution. However, with the looming deadline and continued lack of clarity from DOE, MHI decided legal action was the only option available.

DOE set an arbitrary and unrealistic 1-year deadline, and the proposed requirements are not ready for implementation on May 31. DOE failed to consult with HUD, and the standards do not align with the HUD Code, contain inaccurate cost estimates, do not take current manufactured home construction methods into consideration, and fail to address testing, inspection and certification.

In addition to legal action, MHI is dedicated to:

• Continuing to work with regulatory agencies to delay implementation of the DOE standard until there is alignment between DOE and HUD regulations.
• Ensuring HUD’s Manufactured Housing Consensus Committee’s (MHCC) proposed changes to incorporate the DOE standards into the HUD Code are finalized.
• Supporting legislation to guarantee HUD is the primary regulator for all construction standards for manufactured housing.

In an effort to ensure a consistent industry message, we ask you please from making comments to reporters on this matter and instead refer any media inquiries to Molly Boyle. Molly’s email is 

mollyboyle@fpmgi.com and her phone number is 202-777-3668.