WASHINGTON, D.C. – 22 Sep, 2016 – An arm of the U.S. Small Business Administration (SBA) and policy analysts at George Washington University have weighed in on a controversial proposal by the U.S. Department of Energy (DOE).
The new rule would require energy efficiency standards that exceed those already set by the U.S. Department of Housing and Urban Development for manufactured homes and energy standards for site-built homes in most states.
Written comments to DOE by both organizations echo the sustained and vigorous objections of the Manufactured Housing Association for Regulatory Reform (MHARR), which has led opposition to the proposed rule.
In comments filed on August 16, 2016, linked here, SBA’s Office of Advocacy notes that the DOE proposal “does not comply” with federal requirements that an agency “quantify or describe the economic impact that its proposed regulation might have on small [businesses].”
In a separate public comment letter submitted the same day, linked here, Sofie E. Miller, a senior policy analyst at George Washington University’s Regulatory Studies Center, noted that that DOE’s calculations “overestimate” the benefits of its proposed rule in several key respects – particularly for low-income purchasers.
MHARR has been highly critical of the proposal, highlighting serious (in fact, fatal) defects in the rule and the rulemaking process, which has been marred by leaks, discrepancies and non-transparency.
The industry organization has called the DOE’s cost-benefit analysis a “sham” driven by special interests.
George Washington University analysts — citing MHARR materials published in the industry trade journal, MHProNews – echoes serious concerns over anti-competitive effects resulting from the DOE proposal.
Pointing to an Executive Order issued by the President on April 15, 2016, the Center calls on DOE to “pay particular attention to the prospective effects of its proposed rule on competition within the MH market.”
According to the Center’s recommendations, “DOE should commit to retrospectively reviewing its standard to ensure there is no conflict or overlap with existing HUD regulations and to evaluate the rule’s effects on competition within the MH market and the availability of affordable housing.”
SBA’s Office of Advocacy, in its comments, also focused on the proposal’s adverse impacts on competition within the industry, noting that the rule “would have significantly disproportionate economic impacts on small manufactured home manufacturers if finalized.”
It called on DOE to “adopt a regulatory alternative to the proposed standard that will minimize the economic impact to small manufacturers.”
MHARR commends these highly respected, independent organizations for filing comments on the proposed MH energy rule.
“It does not appear that DOE grasps the unique challenges that small manufacturers encounter.”
— U.S. Small Business Administration, Office of Advocacy
“…mandatory, across-the-board increases in efficiency will price many low-income consumers out of the market for manufactured homes entirely.”
— The George Washington University Regulatory Studies Center
“The cost-benefit analysis for the rule is skewed to the point of being arbitrary at best and deceitful at worst.”
— Manufactured Housing Association for Regulatory Reform
The Association is committed to opposing the adoption of the DOE proposed rule in its current form, and will closely monitor future activity in this rulemaking for aggressive follow-up as warranted.
Read more about the proposed rule and its impact on consumers and the manufactured housing industry here at MHProNews.com
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).
To learn more about this issue, contact:
President & CEO
Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave. N.W., Suite 512
Washington, D.C. 20004
(Image credits: each logo is the property of their respective organization and are used here under fair use guidelines. Text credit, MHProNews.)
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