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

 

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