Federal Government Shutdown and Manufactured Home Installers

I have received a few emails recently asking how the shutdown of the federal government (most notably HUD) impacts the roles and responsibilities of manufactured home installers and retailers operating in states where HUD oversees the installation program.

I think it is important to know that the daily activities required by the Manufactured Housing Installation Program (24 CFR 3285 & 3286) are carried out by SEBA who is under contract with HUD. So, we can assume that SEBA is still at work processing HUD 305, 306, 307 and 309 forms and performing other related activities.

Currently the biggest impact is the issuing of installer licenses. While SEBA continues to process the forms for installer license applications, the folks at HUD issue the actual license. So, don’t expect your license to be renewed or any new licensees issued until the shutdown impasse is resolved.  

Until the federal government reopens, installer licenses are not being issued.

Regarding the reporting that is required for new manufactured homes sold and installed, (forms 305, 306 & 309) my advice is that retailers and installers should continue to conduct business just as before. Keep submitting the forms within the required time frames and keep good records! The processing of these forms is conducted by SEBA, who is currently working as usual.

Eventually, all federal government contractors will want to be paid and there could be further impact should things drag on much longer. 

It is important to remember that regardless of the when the government reopens, the requirements are still in place. A lack of enforcement or oversite doesn’t change the law. So be certain to complete the needed forms in a timely manner and submit them as usual. 

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Manufactured Homes and Attached Structures-Part 3

In this post let’s talk about some of the other structures commonly attached to many manufactured homes, starting with garages:

Home being prepared for a garage attachment in a factory.

A few years ago, HUD started taking a hard look at garage attachments and they were very clear in stating their requirements. Simply put, HUD requires that if a manufactured home with an after-market garage attachment must be designed for such attachment and that the manufacturer should request a letter of “Alternative Construction” (click here for more on Alternative Construction). This Alternative Construction (AC) letter is required to establish a process to assure that these manufactured homes (with an attached garage) will meet all applicable codes and still provide safe, durable and high-quality housing as expected under the program. Here are a few of the code requirements that must be considered by the manufacturer when designing a home for garage attachment:

  • That neither of the required 2 egress doors enter into the garage.
  • That no windows are located in the garage attachment wall.
  • That there is a fire rated wall assembly (and door) separating the garage from the living space of the home.
  • That there is a separate GFCI protected circuit to serve the garage.
  • That the addition of the garage does not impact any exhaust fans (such as range hood) air intakes (such as furnace or fireplace), plumbing venting or roof venting.
  • That the manufactured home is designed for the added weight of the garage. 

    This garage attachment was the cause of several safety related code violations.

HUD does NOT address the need for a carbon monoxide detector which is generally required under state and local building codes when any home has a garage attached. Even though the HUD Code does not provide for CO detectors, I strongly recommend one be added to every home with a garage.

 

This addition led to several code violations.

If you are considering adding a Florida room, three-season room or similar addition to a manufactured home, with the exception of the fire rated wall assembly and door, every other point raised above regarding garages must be considered. Bottom line, have the manufacturer design the home for the three-season room before you proceed!

This added roof didn’t account for the penetration in the valley! The potential for a leak is great!

 

Solar panels add unintended weight to the home!

Lately I have been seeing a lot of manufactured homes with solar panels installed on the roof. I am a big fan of alternative energy solutions, but again, we need to ask ourselves if the home is designed for the added weight. My research shows that a typical solar panel adds about four lbs. per square foot onto the roof of the home. A typical manufactured home roof truss is designed for a dead load of eight (8) PSF. That eight pounds dead load is so the roof truss can support the weight of the ceiling board, insulation, roof decking, underlayment and roof shingles. While four extra pounds may not seem like much, it exceeds the allowable dead load of the roof by 50%.

Again, make sure the home is designed by the manufacturer for the additional weight of roof mounted solar panels.

On a positive note, I have been seeing some DAPIA approved designs from a few manufacturers that are a little more flexible then previous designs when it comes to certain added structures (primarily extended or attached dormers). Be sure you read the fine print on these designs, and keep good records of the construction. Remember, the devil is in the details!

This might be a topic for a future post!

Manufactured Homes & Attached Structures, Part 2

In our last post we talked about how added structures, such as carports, patio covers and the like, add unintended vertical loads to a manufactured home. Today, let’s talk about how added structures subject the manufactured home to increased horizontal (wind) loads, and the possible damage that can occur as a result.

Another example of a patio cover improperly attached to a manufactured home.

The biggest problem that I have seen is when an awning, carport or patio cover is attached directly to the fascia board of the manufactured home. Typically, the fascia board on a manufactured home is attached to the roof trusses without anticipation of a large attachment. Studies has shown that the manufactured home can easily withstand the required wind loads when the home is anchored according to the manufacturer’s installation instructions. But when a carport or patio cover is attached to the fascia board, it can subject the home to significantly higher loads than the home is designed for.

This warning is found in every typical manufactured home installation manual

A quick review of the installation instructions for a few different awnings, carports or patio covers (common in the manufactured housing industry), shows that they agree that the awning should not be attached to the fascia board. However, there remains a concern as they suggest their products can be attached to the actual roof rafter or wall stud of the home (no mention of type of home, manufactured home or otherwise). I found no mention of fastening the mounting rail to a roof truss as opposed to a roof rafter. Nonetheless,  I feel very safe in stating that the home manufacturer did not design the roof truss to support an awning, carport, porch canopy, or similar accessory.

Most critical is when the wind gets under these structures an they start to tear away from the home. As they break free, they create openings that allows the wind to get into the roof cavity, which can lead to catastrophic failure. Take a few minutes and watch these two videos. I think they make a pretty convincing case.

Click Here for American Modern Manufactured Home Wind Test

Click Here for The Today Show, Homes vs Hurricane Winds

There are a few more things to discuss in regards adding structures to manufactured homes, but lets save those topics for yet one final post on this topic.

Manufactured Homes & Attached Structures Part 1

It is pretty hard to drive through any manufactured home community and find a home that doesn’t have some type of attached patio cover, carport, deck, Florida room or door canopy. In fact, it is so common that it is almost expected by homeowners and routinely overlooked by installers, retailers, community owners and building code officials. I think we should talk about this common practice to be certain we are doing the right thing.

Typical patio cover improperly attached, adds over 1 ton of weight to the manufactured home.

 

A typical manufactured home installation manuals will say something like this:

Install site-built structures such as steps, landings, garages, awnings, carports, breezeways, porches, decks, railings, sheds and utility rooms to the manufacturer’s instructions and according to the following:

  • Construct site-built structures to be structurally independent unless provided for in the design of the home

 (there are additional bullet points in the home installation instructions that we will explore in future posts).

A properly supported door canopy!

 

So why must these common awnings, landings, steps and the like, have to be “structurally independent” of the manufactured home?

It all starts with the Manufactured Home Construction & Safety Standards (HUD Code) and the Model Installation Standards. The HUD Code is no different from other building codes as they all establish the minimum building code requirements.  Building codes cannot anticipate aftermarket construction or additions, and neither can the home producers. So, when we are thinking about attaching patio covers or carports to a manufactured home, we need to focus on the potential impact these added structures can have on the home and the foundation.

Unauthorized site-built additions to a home can impose unintended vertical and horizontal loads beyond what the building code minimum requires. Let‘s start with a look at the vertical load, and save the horizontal (wind) load for the next post.

Most manufactured homes are designed to handle a roof snow load of 20 to 40 pounds per square foot (psf) based on where the home is to be installed. In addition to this snow load, manufacturers must include the actual weight of the home itself (somewhere around 20-25 psf) and the assumed weight of the contents inside of the home (for furnishing, people, pets, etc.). The HUD Code requires that the manufacturers calculate this as an additional 40 psf. Ultimately, a typical manufactured home must be designed to support between 80 and 105 psf with limited deflection of the structure. The foundations are then designed to transfer all of this weight into the ground to assure a stable, plumb and level home.

This improperly supported deck can easily pull free from the home and collapse!

 

Now let’s assume you attach a 20’ x 12’ (240 sq. ft.) patio cover to fascia board of the home.  For a home located in the south roof load zone, that would add 4,800 lbs. (240 sq. ft x 20 psf of snow) of potential snow load beyond what was intended by the manufacturer of the home (not to mention the weight of the patio cover!). About half of that load would be transferred to the columns supporting the front of the patio cover, but the remaining weight (2,400 lbs.) is being transferred back to the fascia board, into the roof trusses and into the structure and foundation of the manufactured home itself.

You have just added over a ton of weight to the home that was not accounted for by the building code or the design of the home.

Carport pulled fascia from the roof trusses

 

I have seen first hand where this added weight has led to ceiling cracks, inoperative windows and doors, floors bowing, and piers cracking, breaking or sinking into the ground and other structural failures.

Broken ceiling panel, due to added structure.

 

There are some other issues to consider as well. The fascia board is not intended to resist the pull of an awning or patio cover. Fascia boards can easily pull free from the home and cause significant damage to the home. The same can be said for decks attached to the floor rim (or band) joist. You run the risk of deck collapse since the rim joist attachment to the floor joists in a manufactured home is not designed for attachment of a deck. The International Residential Code does not allow deck attachment to rim or band joists without a positive attachment such as a deck tension ties. Basically, a threaded rod and bracket that runs through the rim joist and screws to the floor joists.

Simpson Strong-tie deck bracket

See https://www.windsorlocksct.org/site/deck_lat_load.pdf for more details.

So that leaves the installer with two options:

  1. Install columns on both sides of an added structure so the home is not bearing any additional weight.
  2. Ask the home manufacturer to design the home to accept whatever loads will be added. In fact, a few manufacturers already have some designs, but typically they call for attachment to the side wall, not the fascia board.

Ok…we are just starting to explore this issue and there is much more to discuss!  Let’s talk about how added structures impact horizontal (wind) loads in our next post.

HUD Installer Continuing Education Now On-Line

A new on-line training opportunity for HUD licensed manufactured home installers is now available. I have partnered with Certified Training Institute to provide my current HUD approved continuing education training to HUD licensed installers that cannot attend the typical classroom style training.

 

 

Keep in mind, currently this is only for HUD licensed installers in need of continuing education. The training cost is $129.

Click Here to log in!

A HUD approved initial training (for persons seeking their first HUD manufactured home installer license) will be available in the Spring of 2019.  

Who Really Owns the Tires & Axles?

I recently was called on to inspect a manufactured home installation located along the eastern shore of Virginia. While reviewing the mountain of documents provided to the homeowner from the retailer, one document in particular caught my eye. A one-page, single sentence document that simply stated:

“The tires and axles are property of (the name and address of the retailer) and will be removed after delivery”

Really? Are the tires and axles the property of the dealer?  Or do the belong to the purchaser? Is it okay for the dealer to just take them?

 

For me, the answer is pretty clear, although you might need some convincing. Let me share my thoughts and you can draw your own conclusions.

First look at the Manufactured Home Construction & Safety Standards (HUD Code) and see what is says about the tires and axles. We all know that a manufactured home by definition must be “transportable” and “built on a permanent chassis” (24 CFR 3280.2)  CLICK HERE to access the HUD Code.

While you are checking out the HUD Code, look at Subpart J “Transportation”. The general requirements at 24 CFR 3280.903(a) clearly state that the home must be designed to withstand the stresses of transportation for “its intended life”.

So, the HUD code requires a transportable home, not just to the initial location, but to future locations as well. But wait, there is more!

Look at 24 CFR 3280.902(a) that defines the term chassis.

“Chassis” means the entire transportation system comprising the following subsystems: drawbar and coupling mechanism, frame, running gear assembly and lights.  This same section tells us that the running gear assembly is a subsystem consisting of springs, axles, bearings, wheels, hubs, tires and brakes and their related hardware.

By now, I hope you can agree that the tires and axles are required by the building code, the Manufactured Home Construction & Safety Standards. Can a retailer write a statement into the sales contract and take them?

Look at retailer responsibilities that are outlined in the Manufactured Housing Procedural & Enforcement Regulations (24 CFR 3282.252). It states that a distributor or retailer is prohibited selling, leasing or offering for sale or lease a new manufactured home if he knows that it does not conform to any sections of the HUD Code. That would include the code sections that I referenced above. CLICK HERE to see these Regulations.

Ok…but what about having the homeowner sign an agreement, allowing you to remove the tires and axles? Let me make one final point. If you take a look at the federal law which is the basis for this entire program, there is one short section called “Prohibition of Waiver of Rights”. It states; “The rights afforded manufactured home purchasers…may not be waived and any provision of a contract or agreement entered into…to the contrary shall be void”. CLICK HERE and scroll to page 5657

So, what does all of this mean? To me it is simple. The tires and axles of a manufactured home are required by the code, and the purchaser has right to a manufactured home that meets all applicable aspects of the code. Any contracts to the contrary are void under the federal law.

Now I am not a lawyer, and as is the case with all of my posts, I am only sharing my opinions. I hope you find this information helpful in order to make informed decisions, and take steps to avoid any potential liability.

Your comments are invited!

 

Using a Manufactured Home as a Sales Office

The longer I work in the manufactured housing industry, the more I run up against too many misunderstandings that place installers, retailers and homeowners in jeopardy. So, starting with this post, and over the next several weeks, we will attempt to look at some of these issues in hopes of providing some clarification.

So let’s start with this one:

Can we use a manufactured home as a sales office?

We all know that many retailers use a manufactured home, installed on their sales lot,  as their office. Often retailers use these homes to complete sales transactions and perform the day to day operations of their business. Maybe they made some modifications to appease the local building code official, such as replacing the front door with an out-swing door, sometimes adding a ramp, maybe hanging an exit sign, or modifying the bathrooms.  But does that really transform a manufactured home into a commercial structure?

Four years ago, HUD issued a memo on this topic and they were very clear from their prospective. The memo reminds us that a manufactured home by definition is designed to be used as a dwelling and to be used by a single family. And when you think about it, aren’t manufactured homes governed by the Department of HOUSING & Urban Development?

Click Here for the HUD Memo on proper use of Manufactured Housing

That seems pretty straight forward. But that is only one-half of the discussion.

Since a manufactured home is pre-empt from state and local building codes only when it is to be used for residential purposes, you could say that the Manufactured Home Construction and Safety Standards (HUD Code) only pre-empts or replaces the state or locally adopted Residential Code.  The HUD code does NOT pre-empt the building code for commercial buildings. And certainly, a sales center/office is classified as a commercial building.  

Chapter 3 of the International Building Code, titled “Use and Occupancy Classification” describes various building uses and assigns a specific classification. Some contend that a structure used as a sales center would fall under the “Business Group” as it meets the definition of a professional services office. Others could argue that a manufactured home sales center should be addressed in the “Mercantile Group” as it is used as a “Sales Room”. Ultimately, your building code official would make the final determination. But regardless of the classification, a structure designed for the entry of the public to conduct business, (such as a home sales center) is definitely not classified as a single-family dwelling under any building code. Click on the link below to view “Use & Occupancy Classifications”. 

International Building Code, Chapter 3

So, what does this mean? It means a building intended to be used for commercial purposes, must be designed as outlined by the Building Code, not the Residential Code. The differences are significant; exit door sizes with panic style hardware, accessible bathrooms with grab bars and wheel chair accessible sinks and fixtures within reach, fire sprinklers, electrical and plumbing designs, floor and roof load demands, to name a few (while many states do not require fire sprinklers for residential occupancy, most do for commercial use).

Likewise, please don’t suggest to a potential customer that they can use a manufactured home for anything other than a dwelling. That would be misleading, and could easily get you into hot water.

Now, this is not to say that a manufacturer could not design and construct a commercial building. In fact, the commercial modular building industry is well-established, and is fully capable of designing and constructing buildings that comply with all of the code requirements for this particular building classification. Those manufacturers operate in coordination with state and/or local code enforcement and third-party inspection and design agencies that are approved for constructing commercial modular buildings.  

Bottom line, a manufactured home may only be used as a dwelling, and not for commercial purposes.  

While I have a list of a few more sensitive topics to raise over the next several weeks, feel free to send me a message if there is a particular issue that you think we should explore.  markconte3@yahoo.com

As always, feel free to comment on this or any other posts!

Service Plan for Manufactured Housing

 Have you ever considered the value of maintaining a relationship with your customers after the installation or sale of the home? A relationship that would be profitable for you while providing an important service to the folks living in manufactured homes? Maybe it is time to consider a long-term service plan where you help your customers with their routine maintenance, and potentially identify and address small problems before they become big problems.

Service plans are very common in many other industries. Look at this advertisement I received from a local HVAC company.

This HVAC company offers a 10% discount on necessary repairs as an incentive to participate in their Service Plan

I know people that have long-term service plans with their electricians, plumbers, exterminators, and landscapers to name a few.  There is no reason that the manufactured housing industry can’t offer this same option to customers. While very few manufactured housing industry professionals have been offering service plans, the ones that do claim that it is a good source of income, and it also had a great impact on customer relations and the overall performance of the manufactured home!

I believe there are two important tools that retailers or professional installers must use in order to establish a smart, effective and profitable service plan or agreement with their customers:

1.       A legal contract outlining the overall plan, the limitations and the expectations.

2.       A written checklist to direct and document the inspection process that is the basis for the service plan.

I did a little research on this, and found that there are several service agreement templates available on the web. Just search for “service agreement templates”. Look these over to get an idea of how a service plan could be drafted. Or if you prefer, talk to a lawyer.

One of several templates found on the internet.

The scope of work for a service plan should be extracted from the Installation Checklist that you already are completing (I hope), and the homeowner’s manual that is provided with every home.  The contract should clearly state what elements of maintenance are covered under the service plan, which elements require an additional charge, and what may be totally beyond the capabilities of the agreement.

A leaking P-Trap resulted in a belly filled with water. A routine service plan could have found this problem when it was still just a drip!

Ultimately, you would give the home an “annual check-up” and document anything that might have a negative impact on the durability and overall performance of the home. For example, you would check for holes in the bottom board. Look over the piers, are there loose shims or cracked blocks? How about the anchoring system? Are there loose anchor straps or components?  Inspect the rain gutters and downspouts. Are splash blocks in place? Does the water drain away from the house? Are the roof penetrations sealed? Do the furnace filters need changed? Do the bath and kitchen exhaust fans work? Is the dryer vent clear? Are the P-Traps tight? Is the heat tape in place and properly installed? Test the smoke alarms and change the batteries. I think you get the idea.

Have a checklist to keep things well documented.

Keep in mind, a typical service plan is limited to addressing the basic maintenance requirements that every homeowner is expected to perform. The difference is that you would provide this service for your customers for a fee. As is always the case, should you were to run across any code related defects, you should report the issue to the manufacturer and document the reporting.  

I personally believe that the reputation of the manufactured housing industry is directly tied to the relationship (or lack of relationship) that we have with our customers after the sale/installation is completed. Maybe service plans can be a step towards improving our reputation, while helping the homes reach its’ full potential as not only affordable, but high quality, safe and durable housing.

Manufactured Housing-Different From The Rest

I recently was contacted by a real estate appraisal company from Michigan that was in a heated dispute with a property owner regarding their factory-built home. Was it a modular home or a manufactured home? The homeowner claimed is was a modular, while the appraiser disagreed.

A steel chassis does NOT always mean it is a manufactured home.

This appraisal company had over 30 years experience, yet had never received any training specifically on manufactured housing. Most training courses will include a few slides that basically say that if a home has steel chassis (or frame) attached to the floor joist, it must be a manufactured home. As you know, that is not always the case. 

Now, don’t think I am criticizing real estate appraisers. I have seen tax assessors make the same mistake. In fact, not just appraisers and assessors, but code officials, zoning officers, banks and home inspectors as well. This leads me to ask, why are so many housing professionals misinformed regarding manufactured housing? 

I visited several web sites to see what they say regarding the differences between manufactured and modular housing, and found most of the information on the web is more focused on marketing as opposed to structural features and building code differences. To make things worse, too many industry professionals do not have a clear understanding of the differences, and play fast and loose with the terms manufactured, mobile, modular, etc., causing further confusion.

Now, to muddy the water even more, we are dealing with “tiny houses” which are a completely different product! Why do they use the word “house”? Calling them “Tiny Campers” would be more accurate. But, as it stands they also add to the confusion. 

A tiny home is not a Manufactured Home!

So, what is so different about a manufactured home compared to other housing? And who should be responsible to assure that manufactured homes are not confused with other housing types? And does it even matter?

Simply put, modular homes are generally built to a state specific building code and are not intended to be moved after the initial installation.  They are considered real estate and must be placed on a permanent foundation on privately owned land. And like it or not, some producers design and construct modular homes that leave a chassis in place, even after it is placed upon the foundation. But the intent is that the modular home will never be moved after placement.

As you know,  manufactured homes are built to a national building code. However each state has their own set of requirements (or lack of requirements) regarding assesment, classification, zoning, lending, sales, etc. Many states consider manufactured homes to be vehicles, registered or titled through the state Department of Motor Vechicles (DMV). Therefore, like a “vehicle”, manufactured homes are considered “personal property”. Which means instead of a low interest rate mortgage, purchasers must either pay cash or take out a high interest rate “chattel” loan.  

This home on private land will likely never be relocated.

So why are manufactured homes considered vehicles? Because by definition, a manufactured home must be permanently transportable. It doesn’t matter if the home is placed on a full basement, masonry crawl space, piers or slabs. A manufactured home must retain the ability to be moved from one location to the next. It may not always be practical, but the on-going ability to lift the home from the foundation, re-attach tires and axles, hitch and lights for transport is required.

For a manufactured home installed in a leased land community (park), a chattel loan makes sense. But today, many manufactured homes are placed on private land with permanent foundations. For these situations, a chattel loan is not the best option.  The owner of the manufactured home would have to work with their state DMV to retire the registration or title and establish the home as “real” property, and therefore qualify for a mortgage.

I hope this helps you better understand the mortgage/chattel loan issue. Banks are reluctant to lend money to a structure that could potentially be towed from the building site.

So, can you blame an appraiser who looks in the crawl space and sees a steel chassis and assumes it is a manufactured home?  

I don’t presume to have all of the answers to this decades old problem, but I do think that understanding the requirement of transportability is important. I also believe that there are some simple steps that all of us can take to help educate those in the housing industry as well as the home buying public:

  • Use the correct terminology. If it is a Manufactured Home, call it a Manufactured Home!
  • Earn the confidence of other housing professionals. Start sharing how this program is regulated, and that there is oversight to protect the consumer and the public.
  • Consider sponsoring a training session in your area for code officials, assessors, appraisers, or other housing professionals.
  • Teach the consumer that at some point the home’s label and data plate will be important and should be preserved.
  • Invite housing officials to your trade show, retail center, or to visit an installation site.
  • Become your area’s manufactured housing expert. 

The Manufactured Housing Program is likely the best kept secret in the housing industry. To encourage the industry to grow, we need to get the rest of the housing industry to better understand what makes our product different.

Comments on the Manufactured Housing Consensus Committee Meeting, Sept 11-13, 2018

I heard from a few folks that attended the Manufactured Housing Consensus Committee (MHCC) meeting held last week in Washington, DC. Since they shared their observations with me, I thought it would provide you with a short summary of the meeting.

Let’s start with what did NOT happen:

HUD did not introduce a new Administrator to oversee the program. As you may recall, the previous administrator and one other high-level manager were removed in December, 2017 (see my post from December 27, 2017 on this topic). But no replacements were announced.

HUD did not include any installers in the discussions. I had hoped that HUD would have invited an installer or two to attend the meeting to try and keep things balanced. But once again, installers were not represented.

Local Code Officials were not invited. I hoped that HUD would invite a few local code officials to participate in this meeting. However, none were invited.

Ok…so let’s talk about what DID occur at this meeting:

The MHCC talked about the HUD Interpretive Bulletin on frost free foundations. Basically, the MHCC wants HUD to withdraw their earlier issued bulletin and allow the states and local governments to have final say in how to protect the manufactured home foundation from frost heave. I personally believe that protecting a foundation from frost heave should be a local or state issue. However, HUD should provide some guidance to help local code enforcers have a better understanding of manufactured home foundations.

The MHCC talked a lot about carports, porches, garages, patio covers and the like. It seems that the discussions suggested that the installer or retailer will need to get much more involved in the design of these after-market structures and as a result, take on additional responsibility. The MHCC wants to add information to the data plate about this. It appears to some folks that this approach is just kicking the can down the road….to the installers and retailers.

The MHCC talked about installation inspectors getting involved in On-Site Completion (SC) inspections. Too bad there were no installation inspectors at the meeting.

They also talked about things like removal of the steel chassis, multi-family manufactured homes and the energy standard (which hasn’t been updated since 1994).  But, not much promise of changes anytime soon.

Looking on the bright side, this was the first face to face meeting of the Manufactured Housing Consensus Committee in a long time (October 2016). So, I guess it is good they met.

Maybe the next time, they will invite some installers!

Keep this in mind!

If any of you attended this meeting and/or would like to add your comments, feel free!