Pennsylvania Suspending Installation Program

As predicted, the Pennsylvania Department of Community & Economic Development (DCED) is suspending their manufactured housing installation program. As a result, there are several important considerations for both installers and retailers.

While everything is subject to change, currently the effective date for this suspension is set for October 1, 2020. However, the transition will begin almost immediately.

As of October 1, 2019, Pennsylvania will no longer issue installer “certifications”. However, installers can continue to operate under their current PA Installer Certification until it expires. Upon expiration, installers will need to acquire a HUD Manufactured Home Installer License. With that said, installers need to know that the HUD Manufactured Home Installer License is valid for three (3) years and there is no cost for the actual license.

Sample HUD Installer License

 

Over this transition period (Oct. 1, 2019 to Oct. 1, 2020) the Pennsylvania Certificate of Compliance will continue to be utilized and can be signed by either a PA Certified Installer or a HUD Licensed Installer. Starting October 1, 2020, installers will need to complete and submit the HUD 309 form for new manufactured homes that they install.

The Pennsylvania Certificate of Compliance form will be modified and will continue to be utilized for relocated manufactured homes.

Retailers selling new manufactured homes for placement in Pennsylvania will need to begin completing the HUD 305 and 306 forms as of October 1, 2020.

In order for installers to qualify for a HUD issued license, they must complete a 12-hour HUD approved training course. There are a few options available: two on-line HUD approved trainings (Certified Training Institute Click Here and MHEI), and there are 3 approved classroom trainers.

I have already begun scheduling HUD approved training classes in Cumberland, Clarion, Centre and Lehigh Counties. The first course is set for November 7 & 8, 2019 in Camp Hill (Harrisburg area). Click Here HUD Installer Training Registration-Nov 2019, PA. The dates and exact locations of the other trainings will be announced in the very near future. Additional classes will be added as needed.

I encourage all Pennsylvania installers and retailers to visit the HUD Installation Program website (click here) for additional information, and for forms needed for the HUD Installation Program.

Feel free to email me with questions.

This is an unofficial explanation of the situation based on information at hand. Please refer to the Pennsylvania Bulletin (Sept 7, 2019) for the official announcement. 

Also, if you are currently registered for a Pennsylvania Installer Training Course, I will be contacting you soon to discuss the available options. 

Is Everyone Playing By the Rules?

Not a week goes by when I don’t hear from an installer or retailer that is upset because they are losing jobs, and as a result money to competitors that aren’t playing by the rules. Maybe unlicensed installers are working in the area. Maybe the footings they are digging are too small or too shallow. Maybe they are cutting corners on the anchoring of the homes they install. Maybe they are not performing the required testing. Maybe they aren’t doing all of the required paperwork. Maybe they aren’t having their installations inspected, or maybe they are forging the signatures on the installation forms.

How can you compete and still do a quality job?

Let me tell you, it is tough, very tough! Just as sure as there will always be speeders on the highway, there will always be a few dirty dogs in the manufactured housing industry. The end result is the reputation of the entire industry suffers, and opportunities and profits are lost!

Now, I will admit that I don’t have a perfect plan to stop cheaters from stealing your business, but I do have a few thoughts that I would like to share with you.

I contend it all starts with educating the consumer. One of the best ways to educate potential customers is by handing every person that walks into your sales lot a well-designed, easy to read, consumer disclosure brochure. You all should know that this consumer brochure is a national requirement, but far too many retailers/installers underestimate how powerful a tool these brochures can be. You can make these brochures serve a dual purpose: a regulatory requirement as well as an educational/marketing tool!

The brochure that I have made available is a good place to start, (see the blog post from November 13, 2017 or click: Consumer brochure). You will need to customize it for your own use. This installation brochure is step one to getting the customer to understand that you are a professional installer and/or retailer and that you are worth the extra cost.

Next, if you are lucky enough to have a working relationship with a building code official (yes, lucky enough), then educate them! A well-educated code official can stop the corner cutters right at the building permit application process! For years I have encouraged good installers and retailers to start showing code officials what documents should be expected for the permit application process. For decades, the manufactured housing industry has been reluctant to engage code officials and as a result, little has changed. We actually have a good product and a good program that protects the interests of everyone. It is time to start showing it to the code enforcement community. If the code official starts expecting every other manufactured home installer to come up to your quality of work, that will mean trouble for the competition. Remember, a rising tide lifts all boats!

What about enforcement? I know nobody likes being inspected or monitored, but just like going to the dentist for your regular visit, enforcement is a necessary evil. Start demanding that the folks that placed these costly requirements on your business take steps to assure that everyone complies. That can happen several different ways, but it needs to happen and it doesn’t have to be just inspections. It can begin with regular, on-going communication. Maybe regional meetings between regulators and installers. Quarterly newsletters on enforcement actions with maybe some input from home and product manufacturers on recent changes. How about a few installers working together to form peer review groups? Sounds crazy, but why not? Doing nothing, changes nothing.

A lot of requirements have been placed squarely on the shoulders of the installers and retailers, without much input or feedback. I can tell you there will only be more to come, and as professional manufactured home installers we need to get involved and have our concerns heard and start thinking outside of the box.

There is a Manufactured Home Consensus Committee (MHCC) meeting scheduled for October in Washington DC. I don’t know if any installers are invited, but I sure hope so. If you are interested in attending and speaking at this meeting, or just learning more and possibly become a member of the MHCC, CLICK HERE .

As I have said before, you’re either at the table or you are on the menu!

New Jersey Ends Manufactured Housing Program & Why This Should Concern You!

In case you haven’t heard, as of today (August 5, 2019), the state of New Jersey is ending its partnership with HUD as a “State Administrative Agency” or SAA. One of the results of this action, NJ code officials no longer have authority to issue permits and perform inspections of manufactured housing installations. A summary of the new rule states that “the Federal government will be responsible for oversight of the installation of manufactured homes in the State of New Jersey”.

When I read over the NJ rule, they seemed to tie the entire issue to HUD not accepting their existing installation program. I truthfully don’t understand how failure to meet the installation requirements led to this, but regardless, the rule is now in effect.

Read the Rule Here.

You may be thinking, unless you are doing business in the Garden State, that this change in New Jersey doesn’t have anything to do with you. Maybe you are right…but maybe this is a sign of things to come. New Jersey isn’t the first state to drop out recently, and I doubt it will be the last. I can’t help but believe that the manufactured housing industry needs more state (and as a result) local government involvement, not less. So, lets talk a little bit about this current relationship between the states, HUD and the Manufactured Housing industry and see if we can identify some problem areas.

As is the case with most relationships, a lot of problems start with money. I vividly recall that 25 years ago, when I first met the NJ Program Manager (Paul S., long since retired), he had two major concerns. The first was the “Alternative Construction” process and how it was never properly implemented, and the second was lack of adequate funding to run the program. Since NJ is not a production state (there are no factories), the funding that NJ received from HUD was not sufficient to pay his wages. In fact, Paul had to split duties between running the NJ Manufactured Housing Program and overseeing the safety of amusement park rides. Even states with a number of production plants have a hard time supporting their SAA staff with their share of the label fees that HUD collects from the plants. So maybe HUD needs to provide more financial support to their state partners. To be fair, I know that there has been some effort recently to increase state funding, so keep your fingers crossed that it comes about sooner than later.

Next issue to examine is the perceived value. Do the state legislators and the government policy offices see a value in maintaining a Manufactured Housing Office? You know, the Federal Manufactured Home Procedural & Enforcement Regulation is clear that if a state decides not to perform the functions of a SAA, that HUD MUST do it (24 CFR 3282.502)! State governments are always looking for ways to reduce the number of employees. So why not get out of the Manufactured Housing Industry and let HUD handle things? Generally, the job of the SAA is not sexy, doesn’t get a lot of press coverage and does very little to help get any votes for elected officials. So, unless someone can convince the folks at the top state level that SAA’s have an important function, they are at risk of becoming extinct.

What about the limitations of the Manufactured Housing Program? Specifically, that this entire program excludes relocated homes! If you sit down and talk to most building code officials and similar government regulators and tell them that HUD has this wonderful oversight program, but the program ends with the completion of the sale to the first purchaser, they would be shocked! There are a few states that have specific requirements for relocated manufactured homes, but most do not.

What about the states and local governments that just don’t understand the Manufactured Housing Standards? If you read over the NJ rule, it is obvious that they are assuming that certain things will be covered under the HUD Installation Program, but that in reality several issues will not addressed. Issues such as the connection to utilities, set back requirements, soil issues, add-ons, and not to mention the obvious issues like carbon monoxide alarms.

I think it is time that the folks at HUD and the Manufactured Housing Consensus Committee start thinking outside the box. Maybe establishing guidance for handling relocated manufactured homes! And while we are stepping outside of the box, how about some guidance for local code enforcers and zoning officers? I know things like this are not required under the current regulations, but they aren’t prohibited either. I guess it boils down to who the program is intended to benefit? Is it the residents of new and relocated manufactured homes or is it the manufactured home industry.

If this program is intended to solely benefit the industry, then I can’t blame New Jersey for ending their program. But if the program intends to protect the residents of all manufactured homes, both new and relocated, maybe we should be looking at new ways to improve the state/federal relationship.