The Journal

August 2014

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by driving erratically or too fast. And, we may take a little longer to walk across the intersec- tions, but give us the space, and we will get there, eventually. In fact, we have learned its better to plan ahead by leaving for our appoint- ments and meetings well ahead of time, so we don't have to speed, or worry about traffic tie- ups, or unexpected accidents on the way to make us late. Old Persons have moral courage and personal integrity. By their later years, they have saved wisely, and usually have good credit. When purchasing a home, they usually have substan- tial down payments, and lenders are more than willing to finance their purchases. When they live in a community, they keep up their homes with true "pride of ownership", and rarely leave their tricycles out in the roadway at night. They seldom brag about their personal accomplishment unless it's about their children, grandchildren or their animals, however admittedly sometimes they talk about more recent medical procedures. It's the Old Persons who know our great country is protected, not by many of the self-serving politi- cians, but by the young men and women in the military, proudly and unselfishly serving their country. Old Persons openly and proudly support them all for their service to our country. They are often the first to say "thank you for your service to our country". Our countrymen should recognize the value of caring for Old Persons with their old-fash- ioned work ethic, sense of responsibility, pride in their country, and decent social and human val- ues. And, with recent advances in medicine, it is apparent that more and more of us are living into old age. In the 40s and 50s I was taught to respect my elders, not to disregard or disrespect them. It's just getting harder to find them these days. And, now I are one! Old Persons are and will continue to be good friends of the manufactured housing industry. We need them/us now more than ever. Thank goodness for Old Persons. Edward Hicks, Lic. Mortgage Broker, Licensed RE Broker, since 1963 as a m/h retailer, home manu- facturer, community developer, and consultant. easteddie@aol.com, www.mobilehomepark.com, www.factorybuilthome.com, www.fha107m.com 813 300-6150 AUGUST 2014 19 THE JOURNAL T J Call us for more information! 6676 GunPark Drive, Suite F • Boulder, Colorado 80301 (303) 530-1566 • Toll Free 1-800-843-3336 See Website for more info: www.everlock.com SYSTEMS 3 New 1" Neopor ® EPS Foam Provided by BASF Provides R7 Insulation Factor 3 Reduce Foundation Energy Loss up to 22% - Save $ 3 Easy Installation – No Additional Framework Required 3 Newly Constructed Rail System available. Options include: Top & Bottom Rails and Hardware NOW AVAILABLE NEW INSULATED SKIRTING from EVERLOCK SYSTEMS NEW INSULATED SKIRTING from EVERLOCK SYSTEMS No. 11 on Get It Quick Page DOE Shifts to "Negotiated Rulemaking" for MH Energy Standards In just the latest twist in a now seven-year saga, the Department of Energy (DOE) has formally announced that it will develop manufac- tured housing energy efficiency standards mandated by the Energy In- dependence and Security Act of 2007 (EISA) via a "negotiated rulemaking" with a new federal advisory committee being assembled for that purpose. In a Federal Register "Notice of Intent" published on June 13, 2014, DOE requested nominations for members to serve on the new manu- factured housing standards advisory committee that will operate under the auspices of an obscure DOE "Appliance Standards and Rulemak- ing Advisory Committee" (ASRAC), which already has other "work- ing group" offshoots engaged in developing standards for other types of products. Nominations for voting participation in the manufactured housing committee, in accordance with the Notice of Intent, are due by June 27, 2014. The deadline for the committee to "negotiate[e] a proposed rule and submit[t] it to ASRAC is September 30, 2014." DOE's turn to a negotiated rulemaking is the latest oddity in a seven-year process which has already seen, among other things – (1) DOE develop a "draft" proposed manufactured home energy conserva- tion rule; (2) DOE selectively leak that draft proposed rule to certain interested parties; (3) the utilization of that leaked "draft" proposed rule by those interested parties as the basis for a still undisclosed energy proposal that may be brought to the MHCC; (4) the DOE "draft" pro- posed rule being withdrawn after its submission to the Office of Man- agement and Budget (and after objections and a request for an investigation by MHARR); and (5) now this shift, in midstream, from the "standard" DOE rulemaking process to a "negotiated" rulemaking. In direct communications with DOE officials, MHARR has made it clear that any advisory committee or "working group" for a manufac- tured housing energy standards rulemaking that does not include full and proper representation for smaller HUD Code industry businesses and consumers would be unacceptable and that any DOE rulemaking process – "negotiated" or otherwise -- must include consultation with, and the full involvement of, both HUD and the MHCC, at a mean- ingful stage in the proceedings and not as a cosmetic afterthought. MHARR will be meeting with DOE officials to sort out these issues and fully participate in this new DOE approach going forward, in order to protect the rights, interests and views of HUD Code industry small businesses and consumers of affordable housing. Toward that end, MHARR has already submitted a nomination for committee member- ship in order to ensure that smaller industry businesses have collective voting representation and real voice on that committee.

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