Let’s talk about: Alternative Construction

Last week during a discussion in an installation training class, it became obvious that too many installers and retailers aren’t being informed about Alternative Construction (AC) and On-Site Completion (SC) and what this means for the manufactured homes that they install and/or sell.

So, lets take a look and see if we can shed some light on these issues, starting with Alternative Construction.

When a manufacturer intends to produce a manufactured home with a construction aspect that does not meet the Manufactured Home Construction & Safety Standards (MHCSS), but will perform at least equal to the MHCSS, they can request HUD allow such construction.

Let me give an example:

Say you want the manufacturer to construct a home for your customer that has tankless water heaters instead of the typical storage type water heater.  Since the MHCSS doesn’t provide for a tankless water heater, the manufacturer needs a special approval from HUD to omit the storage type water heater and replace it with the tankless type. That approval is called a Letter of Alternative Construction (or an AC letter).

Here is another example: your customer needs a shower that is designed for wheelchair access. The MHCSS requires a minimum 2” dam (or threshold) to keep the water from running onto the floor, making it impossible to access the shower with a wheelchair. The manufacturer can request an Alternative Construction authorization from HUD to provide a shower without a 2” dam, designed to facilitate wheelchairs.

Accessible Shower

 In both of these cases, the home will not meet a specific requirement of the Manufactured Home Construction and Safety Standards, however they both will perform equal or better than the actual code requirement.

DAPIA approved floor plan for a home with garage attachment.

 Currently, one of the biggest requests for AC letters is when a manufactured home is designed for the attachment of a site-built garage. There are many issues of code compliance that must be examined when designing a home for garage attachment.  Issues such as the path of egress (exit) from the bedrooms, impact on lighting and ventilation in the area where the garage is attached, additional loads on the structure of the home, and electrical considerations, to name a few. But the omission of the exterior covering (siding) for the application of gypsum to provide the needed fire separation is where you will find the need for the AC letter.  On a side note…the MHCSS still does not address carbon monoxide alarms! If you are selling/installing a home with a garage attachment, talk to the manufacturer about a combination smoke/CO alarm or an added electrical outlet where you can provide this important safety consideration.

Through the years, the most common use for an AC letter has been a home with a hinged roof, usually a 5/12 roof pitch or greater (this never made sense to me, but that is how they handled hinged roofs). Today most manufactured homes with a hinged roof are being constructed under the new On-Site Completion Process, which we will discuss in a our next post.

 Here are a few “take aways” for retailers and installers when it comes to Alternative Construction.

  •  A manufactured home covered by an AC letter is determined to perform equal to or greater than the MHCSS requirements.

Typical notice to consumer of Alternative Construction.

  • Every manufactured home under an AC letter requires a notice to the perspective purchaser. This notice, as well as an appropriate checklist, and other information related to the AC process is provided by the manufacturer.
  • You can identify a manufactured home constructed under a letter of Alternative Construction by the letters “AC” which will be included in the serial number.
  • Often the home will require a special inspection.   
  • Both the retailer and installer should maintain records of compliance with the AC requirements, and a copy of any needed inspection of the completed home.

 Ok…I hope this helps. If you have anything to add, submit a comment.

In our next post we will talk about On-Site Completion.

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Our Comments to HUD!

On my February 6, 2018 post I shared information from HUD that they want to hear from the manufactured housing industry regarding the impact of their regulations. As of February 21, there are almost 300 people that have taken the time to share their opinion. I was encouraged to see how many installers weighed in!

Comments are being accepted until February 26, 2018, so there is still time! Click Here to access the previous post with directions on submitting comments.

For your information, below is a copy of my comments to HUD that were submitted this morning:

Docket Number: FR–6075–N–01 – Regulatory Review of Manufactured Housing Regulations

Thank you for the opportunity to comment on current and upcoming manufactured housing regulations. It is extremely important that HUD conduct on-going reviews and analysis on the impact of all regulations. Having made my career in the manufactured housing industry, I provide the following comments:

·         Since the adoption of the Manufactured Housing Improvement Act, manufactured home installers have been the most significantly impacted segment of the manufactured housing industry. However, manufactured home installers have never been represented on the Manufactured Housing Consensus Committee. The vast majority of home installers do not belong to trade groups, and as a result have been excluded from the rule-making process.  I encourage you to seek input from all affected parties, and particularly manufactured home installers as you review installation related regulations.

·         I know that many have commented on broadening HUD’s enforcement of preemption as it relates to manufactured housing. Please keep in mind that to successfully preempt manufactured housing from state and local building codes, the Manufactured Housing Constructions and Safety Standards must be kept current. I encourage you to provide your Office of Manufactured Housing Programs with sufficient staff and resources to effectively and efficiently operate the program and work towards continual updating the construction standards, just as every other construction code is kept current.

·         In regards to HUD providing guidance on frost protected foundations for manufactured housing installation, I agree with most commenters that this issue is better left to state or local building code enforcement. However, regardless of the which governmental agency has authority over the issue of frost protection for manufactured home foundations, I believe that HUD has a role in working with local code enforcers so that they can properly and effectively understand their role in manufactured housing. A HUD sponsored outreach program that provides training to municipal building code officials regarding proper handling of manufactured housing would be a very effective tool in broadening preemption.  Additionally, in a situation similar to installers, local code enforcement has not been properly represented on the Manufactured Housing Consensus Committee.

 I appreciate the opportunity to provide comments regarding overly burdensome regulations and requirements. As you and your staff wade through this and the other comments, I encourage you to keep in mind that there are four equal tenants to the manufactured housing program. Manufactured homes must be safe, high quality, durable and affordable. All four tenants must be preserved to support this program as it moves toward the future.

 

Mark Conte

 

Alternative Foundations

This concrete slab on grade is one example of an alternate foundation.

I know that through the years a lot of community owners have hired professional engineers to design foundations for homes installed in their parks. Many times, these foundations are elaborate, well designed, and constructed beyond the minimum requirements of the installation standards.

 In some places, these foundation designs were also reviewed and approved by the state, county or local code official.  With approval from engineers and building code enforcers, what could be the problem???

 Well grab your “Model Manufactured Home Installation Standard” and open to section 3285.2(c)(1). It says that BEFORE an installer provides support or anchorage that are different then the installation instructions, or if the installer encounters site conditions that prevent the use of the installation instructions, the installer MUST:

  •  Try to get DAPIA approved designs or instructions from the manufacturer; or
  •  If the designs are not available, have designs prepared and stamped by a professional engineer (or architect), and submit these designs to the manufacturer for their approval, and approval by the DAPIA!

After a few modifications, this foundation was manufacturer and DAPIA approved!

 Basically, any foundation system that is not addressed in the manufacturer’s installation instructions would be considered an “Alternative Foundation System”. It would need to be approved by the manufacturer and their DAPIA before you can use it to support/stabilize a new manufactured home. Ultimately, the manufacturer needs to agree that any alternate foundation will properly support and stabilize their homes.   

 So, if you are placing new manufactured homes on anything other than a typical concrete block pier with individual footings that extend below the frost line, and a ground anchor tie down system, you have a little paper work to do.

 First off, do you follow an actual design plan for the foundation you are constructing? I know far too many installers follow  the “way we have always done it” plan. If it is a concrete slab or a purchased system from a supplier, or something entirely different, make sure there is a design to be followed and make sure you follow that design.

 Next, check through the manufacturer’s installation manual for the home. Some installation manuals provide the installer supplements that address a wide verity of alternative foundations. For example, certain manufacturers provide DAPIA approved designs on placing their homes on steel crossbeams in masonry crawl spaces and basements, and others have DAPIA approved designs for concrete slabs. Most have DAPIA approvals for alternative anchoring systems. Grab the most current manual from the manufacturer and see if your foundation is addressed. If it is, make sure you read all of the little notes and disclaimers so that you are in full compliance.

 If you can’t find any designs for the alternative foundation you utilize, call the factory’s Quality Assurance Manager and ask him to help. It is possible that the manufacturer already has designs that can help you.  Don’t ask the sales department, service department or supplier about design or code related issues. The Quality Assurance Department is your best bet.

 A word of caution, I have seen foundation products from supply houses that appear to be approved by a DAPIA, but the specific manufacturers approval is needed as well.

 So, before you get too deep into your busy season, take some time and make sure you:

1.       Have a manufacturer and DAPIA approved design that clearly addresses the foundations you construct for new manufactured home installations.

2.       Make sure you read all of the fine print, notes, instructions, and limitations of the designs you are using.

3.       Make sure you follow the designs!

4.       Make sure you have copies of these designs for your records.

5.       Take a few pictures through the process.

Bottom line, make sure you have a design from the manufacturer that has a stamp showing it is DAPIA approved for every foundation type you construct!

HUD wants to hear from YOU!

Last week the U.S. Department of Housing & Urban Development announced that they are reviewing existing and planned manufactured housing regulations. This is to better look at the cost of compliance to try and reduce the regulatory burden on anyone impacted by their regulations.

HUD is looking for comments from installers and retailers (and others)  to assist in identifying regulations that may be outmoded, ineffective, or excessively burdensome and should be modified, streamlined, replaced, or repealed.

Comments are due by February 26, 2018 and can be mailed or submitted electronically. All comments must include the following docket number and title:

Docket No. FR-6075-N-01      Regulatory Review of Manufactured Housing Rules                                                 

It is pretty easy to send comments electronically. Just go to www.regulations.gov

In the big blue search box, type in 6075-N-01. From there you can read the notice published by HUD, and when you click on “comment now” you can type in your concerns.

Should you want to mail written comments to HUD, send them to:

Regulations Division, Office of General Counsel     

Department of Housing & Urban Development    

451 7TH Street SW, Room 10276

Washington, DC 20410-0550

 

Don’t forget to include the docket number and title in your letter.

I strongly suggest that you reference each of your comments to a specific requirement under the federal regulations. For example, if you feel the requirement for the Surety Bond/Insurance (in HUD administered states) is too burdensome, make sure you reference 3286.205(d). If you think the requirements for pier construction are confusing and need simplified, reference 3285.304.

I know many installers object to the requirements for testing water supply lines 3285.603(e), drain lines 3285.604(d), and fuel supply piping 3285.605, especially since the manufacturer performed this testing at the factory. Just include the reference in your comment. You can access the HUD regulations for installation at their website or just CLICK HERE

HUD is also interested in your thoughts on placing homes on foundations in freezing climates. I know that many of you have some strong feelings on this issue.

But regardless of the specific issue, now is your chance to be heard. Keep in mind the deadline is February 26, 2018.