Issue link: https://read.dmtmag.com/i/720597
SEPTEMBER 2016 21 THE JOURNAL Conquer the #1 Cause of Business Failure - lack of cash ow. A new program by Je Prager and Scott Stroud Visit CashFlowEngineering.com Or call 606-416-2078 for details. Recently the Manufactured Housing Institute submitted a comment letter to the Department of Energy in response to its July 17 proposed rule on "Energy Conservation Standards for Manufac- tured Housing." MHI expressed concerns that the proposed rule would increase the purchase price of manufactured homes without providing any plans to mitigate this increased up-front cost. MHI also called on the DOE to es- tablish a clear c o m p l i a n c e r e g i m e n , where such standards would be integrated into the HUD Code, before any rule is finalized. MHI urged DOE not to finalize the proposed rule until mar- ket impacts are reanalyzed and compliance con- cerns are addressed. In its comment letter, MHI argued that the in- crease in the cost of a manufactured home as a re- sult of the standard will be a burden to many lower-income homebuyers, who already struggle to obtain the necessary housing credit to afford to purchase a home. According to MHI's letter: "even a small increase in home cost has a dispro- portionately large impact on manufactured home- buyers, with respect to their ability to qualify for a home loan, the proportion of income that will have to be used for mortgage payments, and their ability to purchase basic amenities. It is vitally im- portant, therefore, that any increase in home cost resulting from new energy standards be cost justi- fied and not burden affordability by increasing up- front costs." Additionally, in its letter MHI urged DOE to find ways to help consumers absorb any higher initial costs resulting from the rule. While the DOE contends that the proposed standards would result in increased monthly util- ity savings for consumers, MHI questioned the methodology used by DOE to assess costs result- ing from the rule. MHI's letter stated: "The cost impact analysis used by DOE seems to rely on op- timistic assumptions that have the effect of un- derestimating the impact the rule would have not only on pro- duction, but also on con- sumers. MHI questions the use of two key variables - the elasticity value and the cost markup factor - both of which appear to be well below industry norms in the proposed rule. Furthermore, the as- sumption of a 20 percent down payment amount for a manufactured home is completely out of the norm in the manufactured housing market, where down payments of that magnitude are extremely rare." MHI also argued that the proposal does not address implemen- tation of the new stan- dards, which could result in manufacturers facing complicated and overlapping require- ments, with two sepa- rate entities overseeing the standards. It its letter, MHI called on DOE to "work with HUD to ensure energy standards are inte- grated into a single regulation and develop a memorandum of understanding to ensure that en- ergy standards, while developed by DOE, are en- forced by HUD through the HUD Code before the rule is finalized. MHI also strongly recom- mended that HUD's Manufactured Housing Consensus Committee should "review the pro- posed rule to ensure alignment with the HUD Code and all compliance, enforcement, and overlapping regulations are resolved." Given the breadth of these concerns, MHI urged DOE to "consider publishing a revised draft rule for comment that more accurately addresses economic impacts and provides a compliance path through HUD enforcement." If you have any questions, please contact Tom Heinemann, MHI's Vice President of Federal Government Affairs, at (703) 229-6207 or theinemann@mfghome.org or Lois Starkey, Vice President of Regulatory Affairs at (703) 558-0654 or lstarkey@mfghome.org. 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 Save valuable energy costs with INSULATED SKIRTING! New, stronger Top Rail system is now available for Thermal EverRock (R7 Insulation Factor) & Gorilla Thermal Skirting (R9). Call for introductory discount offer. NOW AVAILABLE NEW INSULATED SKIRTING from EVERLOCK SYSTEMS NEW INSULATED SKIRTING from EVERLOCK SYSTEMS MHI Calls on the Department of Energy to Reduce Impact on Home Prices and Implementation Challenges Posed by its Energy Conservation Proposal "even a small increase in home cost has a disproportionately large impact on manufactured homebuyers..."