Issue link: https://read.dmtmag.com/i/406201
NOVEMBER 2014 15 THE JOURNAL No. 11 on Get It Quick Page 7 YEARS WARRANTY COVERAGE "The Perfect Addition For Your Home Sales" Most Competitive & Comprehensive Program in the Manufactured Home Industry Up to 7 Years Structure Coverage 7 Years Systems (Heating, A/C, Plumbing & Electrical) 7 Years Appliance Coverage Component Only Coverage Coverage Available for New & Pre-Owned Homes FHA/VA/HUD Coverage Offered Renewable Coverage Available Coverage Available For: Manufactured / Modular / Park Model Homes HomeCarePlus A Complete Package Designed for Today's Homes For More Information Contact: Diversified Profits, Inc. (800) 851-3738 Office 651-458-2905 Fax E-Mail: diversifiedprofits@comcast.net Welcoming Former American Modern Manufacturer's, Lenders, Communities & Dealers No. 10 on Get It Quick Page tive to DOE to re-start the entire rulemaking from scratch, as MHARR had previously re- quested in written comments and correspon- dence with DOE. Subsequently, in May 2014 -- and appar- ently aware of this rejection and directive by OMB -- many of the same parties which had received the "impermissibly" disclosed draft rule (including the same industry organization), re- quested a "negotiated" rulemaking process for the EISA manufactured housing standards under the auspices of DOE's Appliance Stan- dards and Rulemaking Advisory Committee (ASRAC). This request, not surprisingly, was quickly "accepted" by DOE, leading to forma- tion of the manufactured housing "Working Group" – comprised almost entirely of the same groups that had requested the face-saving "ne- gotiated" rulemaking in the first place -- that has been meeting since August 2014. Over the past three months, however, based on: (1) The minimal time allotted to the nego- tiated rulemaking Working Group by ASRAC/DOE (i.e., three months) to com- plete its standards recommendations (as con- trasted with the years that DOE has had this matter before it; (2) The arbitrary division of standards and enforcement by ASRAC -- with the charter of the current Working Group limited to standards only (thus ensuring that regulatory compliance costs are excluded from analyses of consumer purchase price impacts); and (3)The participation of multiple recipients of the OMB-rejected, "impermissibly" disclosed DOE "draft" rule in the Working Group, MHARR has concluded that the current process is little more than a regulatory fig leaf designed to provide DOE a veneer of legitimacy and the appearance of the "fresh-start," as de- manded by OMB, while ending-up at essen- tially the same place as the prior, illegitimate, OMB-rejected process. Put differently, what DOE could not accomplish in seven years – ul- timately being rejected by OMB – is now being railroaded via the current process. Most baffling, though, is why part of the in- dustry is actively assisting DOE in the imple- mentation of this fundamentally flawed statute – that more accurate and targeted estimates from smaller manufacturers show would increase the purchase price of base manufactured homes by more than $5,000.00 -- providing the veneer of legitimacy that DOE desperately needs, while effectively removing any burden from DOE to develop its own factual and accurate consumer cost figures, as would normally be its burden in a federal rulemaking. Indeed, such assistance has provided cover for DOE to resist calls by MHARR during the negotiated rulemaking process for the agency to commission actual homes from small, medium-sized and larger manufacturers, built to the 2015 IECC, to accurately determine and assess all the cost implica- tions of compliance with that code. And, while some of these industry members maintain that rules developed with industry co- operation and assistance will be "better" than would otherwise be the case, such cooperation does not change the fact that the 2007 EISA law is completely inappropriate for manufactured housing and should go back to Congress for cor- rection and modification, with proper input (this time) from the industry and consumers. Short of that, it could still be tied-up for years through legal challenges (and related discovery) addressing its various aspects. In MHARR's view, both EISA and the DOE process to implement its manufactured housing provisions are misdirected and unacceptable … and should be corrected one way or the other. Danny D. Ghorbani is President & CEO of the Manu- factured Housing Association for Regulatory Reform. MHARR is a Washington, DC-based national trade as- sociation representing the views and interests of inde- pendent producers of federally-regulated manufactured housing. Danny can be reached at 202-783-4087. 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