Issue link: http://read.dmtmag.com/i/755715
DECEMBER 2016 23 THE JOURNAL Some homes SHAKE RATTLE & ROLL to their destination, often causing floor problems that need adjustment. "Squeak-Ender" "Seam-Ender" "Sag-Ender" For more details and ordering information, go to squeakender.com or call 586-978-3377 -- ask for Ken Shore, the Dean of Floors Squeaks ... Separates ... Sags ... According to the Manufactured Housing As- sociation for Regulatory Reform (MHARR) an- other piece of the proposed DOE manufactured housing energy rule was published in the Federal Register on November 9, 2016. This pro- posed rule would establish "test procedures to support … proposed manufactured housing thermal envelope re- quirements, air leak- age requirements and fan efficacy require- ments" as already set forth by DOE in its June 17, 2016 energy conservation standards proposed rule. Com- ments on the proposed testing methods are due on or before December 9, 2016. Significantly, these testing requirements do not address and do not propose a compliance or enforcement system for the excessive, unneces- sary and fundamentally-tainted June 17, 2016 proposed "energy conservation" standards de- veloped by DOE pursuant to an illegitimate and fatally-flawed "negotiated rulemaking." As DOE notes in the preamble to the proposed testing methodologies: "DOE has not included or proposed any additional compliance or en- forcement provisions at this time. DOE antic- ipates that it will address issues related to certification, compliance and enforcement of the proposed standards in a separate rulemak- ing. DOE will address any associated costs re- sulting from the compliance or enforcement as part of that rulemaking." (Emphasis added). As a result, the fatal flaws in the statutorily- mandated cost – benefit analysis contained in DOE's June 17, 2016 rule, as emphasized by MHARR, the Manufactured Housing Consen- sus Committee (MHCC), the George Wash- ington University Regulatory Studies Center and other commenters in that docket, have not, will not and cannot be resolved or reme- died by DOE. Accordingly, MHARR continues to strongly oppose that proposed rule in all of its aspects as fundamentally and irretrievably tainted and il- legitimate, and will pursue available remedies as warranted – as should all other manufactured housing program stakeholders, including con- sumers. Consistent with its overall approach to this action, MHARR will submit comments on DOE's proposed testing regulations in advance of the December 9, 2016 deadline and will make those comments available to industry members for their own use and/or information. DOE Pressing To Complete MH Energy Rule "DOE has not included or proposed any additional compliance or enforcement provisions at this time. DOE anticipates that it will address issues related to certification, compliance and enforcement of the pro- posed standards in a separate rulemaking. DOE will address any associated costs resulting from the com- pliance or enforcement as part of that rulemaking."