The Journal

October 2016

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OCTOBER 2016 28 THE JOURNAL No. 17 on Get It Quick Page EASY TO USE • NO MESS • PERMANENT • High-tech, super-aggressive adhesive • User-friendly product with easy-to-remove liner • Permanent and easy way to mend holes, cuts, and tears • Manufactured Home/RV repairs, vapor barriers, tarp repairs, etc. PREMIUM BOTTOMBOARD TAPES SIZES PART NO. 2" - 18" ROLLS 2" X 180' FM-200T 2" X 108' FM-2108T *4" X 180' *FM-400T 4" X 108' FM-4108T *6" X 180' *FM-600T 6" X 108' FM-6108T 8" X 180' FM-800T 18" X 180' FM-1800 28" ROLLS *28" X 25' *FM-2825 28" X 50' FM-2850 28" X 100' FM-2800 ALSO AVAILABLE! DO-IT-YOURSELF KITS FM-2845 ZIPPERED ACCESS 18" X 18" TRAP-FLAP FM-1818 4" X 72" ZIP-STRIP FM-0472 6" X 72" ZIP-STRIP FM-0672 CUSTOM SIZES AVAILABLE! *DENOTES MOST POPULAR SIZES Look for the logo on the core of every roll of tape! THANK YOU FOR STICKING WITH FLEX-MEND! Visit FLEXMEND.COM for your nearest distributor, or for distribution opportunities, please call: 1.800.462.1775 F F No. 16 on Get It Quick Page The U.S. Department of Energy (DOE), re- sponding to a May 10, 2016 Freedom of Informa- tion Act (FOIA) request filed by the Manufactured Housing Association for Regulatory Reform (MHARR), has produced documents showing that $1,606,348.00 was paid by DOE to The Levy Partnership, Inc. (TLP) between 2012 and 2015 for work on DOE "research" contracts. TLP describes itself as "the general support con- tractor for the Systems Building Research Alliance (SBRA)," the alleged "non-profit research or- ganization of the factory-built housing industry." According to documents filed by TLP with the U.S. General Services Administration (GSA), TLP is responsible for "coordinating all of [SBRA's] administrative and technical func- tions," and has "managed SBRA since its incep- tion." These payments to TLP, under multiple Task Orders issued by DOE through its National Re- newable Energy Laboratory (NREL) in Golden, Colorado beginning in January 2012 and continu- ing through October 2015, preceded and over- lapped with the time period that SBRA and its Executive Director (who was simultaneously Pres- ident of TLP) were appointed by DOE to serve on the DOE Manufactured Housing Working Group (MHWG) which – through a process of supposed "negotiated rulemaking" -- developed the basis for the disastrous proposed DOE manufactured hous- ing "energy conservation" rule, issued on June 17, 2016. As is extensively detailed in MHARR's com- prehensive August 8, 2016 comments opposing the proposed DOE rule, SBRA provided exten- sive technical input and analysis in connection with the truncated and fundamentally-tainted proceedings of the MHWG, as well as key cost in- formation inputs from unidentified, non-trans- parent sources. At no point in the MHWG process, though, did DOE disclose either the fact – or the extent – of its payments to TLP, TLP's symbiotic relationship with SBRA, and the po- tential conflict of interest involved in those rela- tionships. MHARR, ultimately, cast the only "no" vote against the MHWG "Term Sheet" that became the basis for DOE's June 17, 2016 pro- posed rule. SBRA, moreover, over the same period that TLP was receiving these DOE payments, acted to promote DOE manufactured housing energy reg- ulation, such as in a presentation at the April 2015 Manufactured Housing Institute (MHI) Na- tional Congress and Expo, entitled "Energy Stan- dards: From Laggard to Leader." Among other things, that presentation – with slides bearing the logo of the "Systems Building Research Alliance" – touted potential approaches to increased manu- factured housing energy regulation, utilizing tech- nologies developed with DOE funding, including so-called "Advanced Roof Prototyping" (NREL subcontract KNDJ-0-40347-05) and "Advanced Walls Prototyping" (NREL subcontract KNDJ-0- 40347-04). MHARR, as part of its aggressive opposition to the DOE proposed manufactured housing "energy" rule, will continue to press for additional informa- tion concerning relevant aspects of the sham DOE process leading to the June 17, 2016 proposed rule. The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.-based national trade association representing the views and interests of independent producers of feder- ally-regulated manufactured housing. FOIA Documents Confirm Millions in DOE Payments to SBRA Management Co.

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