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.

Advertisements

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!

Let’s Talk About Marriage Line Fastening

A while back we talked about all of the different issues that a professional manufactured home installer needs to know regarding the marriage walls. I thought we should revisit that issue and focus only on the fastening together of the two halves to make the home a single,  solid, integrated structure. Since this is a big topic, I think I will split things up and only discuss the fastening of the floors and walls. Let’s save the roof for a future date.

Your goal should be to make the joint between the home sections as tight as possible. There should be no gaps, and the fasteners must be installed per the manufacturers installation instructions. These fasteners should not split the lumber and must have adequate penetration to secure the home.

Remember that assembly of the home is critical to the home’s ability to survive high winds. A two (or three) section manufactured home must be able to transfer wind loads across the marriage line to the specific walls designed to accept these loads (shear walls), and ultimately into the ground through the anchoring system. Spaces, gaps, voids, etc., between the two sections, can prevent the home from safely handling these loads.

This gap must be shimmed!

It goes without saying that you need to remove all shipping materials (plastic, straps, nails, staples) while you can still access them. Next, look over the marriage line gasket for damaged areas and add new gasketing material where needed. Ask the manufacturer to supply a decent length of extra gasket material to do this.

Look closely where the staple keeps the sections apart.

If you have attended any of my training classes, you know that I think the marriage line gasket is the weakest point in the entire design of a manufactured home. Take a few minutes to make sure the gasket can do its intended job. Consider offering better options, if possible. We can talk about this idea in a future post.

Never work under a suspended load! Support the home with cribbing every time!

Be sure to protect yourself and others at the job site. Use cribbing or other support devices in the event that a home section should fall. Never allow a situation where a worker could be crushed or worse.

For new manufactured homes, the manufacturer will be providing all the fasteners necessary to secure the home sections. If you are not receiving these fasteners, you need to have a serious talk with someone at the factory.

Bring the home sections together as tight as possible. Any gaps between the sections must be shimmed! The manufacturers all say that if the gap is wider then 1”, you need to reposition the home to reduce/eliminate the gap.  Any shims used at the marriage line are generally ¾” thick lumber, wide enough to accept the fastener without splitting. I favor a ¾” x 2 ½” pine firring strip. Be careful not to pull the rim joist away from the floor joists. The same is true at the roof ridge. Don’t pull the top rail or ridge beams away from the roof truss. Ultimately, the fasteners you install should just hold the home tightly together, not be pulling the sections tighter. 

In general, most manufacturers (for homes in wind zone 1) require lagging the floor sections together using a lag screw and washer at each floor joist bay, and staggered from side to side. The lags may be installed at an angle (toe screwed), but not so much of an angle to reduce how far the lag goes into the other joist. You can also drive them straight into the floor joist, but that leaves a bigger hole in the bottom board to repair. At least 1 ½” penetration into the receiving joist is required.

These lags should be staggered and the bottom board patched!

Seal the bottom board with bottom board tape after the lagging is completed. Some manufacturers require additional fasteners at the ends of the home and at any through-the-rim heat duct connection. Be sure to check the manual, specific for the home you are installing.

This manual requires additional fasteners at the floor of the home.

 

Fastening of the walls is getting a bit more complicated with several manufacturers providing different options. Most installations I see still use wood screws (#10 x 4 ½”) 24” apart from the bottom plate to the top plate of the wall. Be careful using lag screws as they can split the wall studs.

Likewise, you need to fasten the marriage line along any openings or door ways with the same fasteners and spacing. I have been seeing some manufacturers sending brackets or plates for fastening the marriage line. Be sure to use the right number of nails per bracket and that you use appropriate length common nails. Not finishing nails, aluminum nails, roofing nails, etc.

Brackets at marriage line opening

Hopefully, this will encourage you to reexamine how you assemble multi-section manufactured homes. Make sure everyone on your crew understands how important this is! We will talk about roof fastening at a future date.

As always, refer to the specific manufacturers installation instructions for every home you install!

Affordability-Installation and the Manufactured Housing Consensus Committee

From my first day working in the Manufactured Housing Industry, I was told how manufactured housing is “affordable” housing, and that preserving affordability was a top priority. Through the years, I saw how adopting new code requirements were often derailed solely based upon their potential impact on the cost of the home. Arc-Fault protection, carbon monoxide alarms, and an energy/insulation standard that is 24 years old are only a few code provisions that are not adopted or updated largely because of their impact on the price tag of the home. 

When it comes to the cost of installation, I think affordability has been forgotten.

Over the past ten years, we watched the roll-out of the installation standard and the installation program which seemed to have an impact on affordability. Let’s take a look at some new requirements that effect affordability:

Bonding/Insurance:  I spoke with a couple installers, and it seems that the average rate is about $300 per year to comply with this HUD installation program requirement. For the independent, self employeed installer, this is quite an added expense. While I am not saying that being bonded and insured is a bad idea, I wonder how many installers have had an action taken against their bond or had a claim made against their insurance. I am sure there have been a few, but are there sufficient claims to justify this added cost? 

Paperwork:   Regardless of which state you are in, you now have an additional paperwork burden. It could be monthly HUD reporting, state labels, decals or certificates. Retailers now have installation disclosures, dispute resolution disclosures, HUD reporting, on top of the existing reporting requirements. time-is-money-create-a-clear-job-description

Recordkeeping:  The dispute resolution program requires all installers to maintain records of every new manufactured home they install for a minimum of three years. Documents such as contracts, checklists, installation manuals, service requests, parts requests, etc., all must be collected and retained.

New Installation Requirements:   There are so many items added to the installation process that directly impact affordability of the home, that I am hesitant to list them.  But consider the added costs of water supply line pressure testing, and anti-scald temperature testing (tub and showers), DWV testing, electrical continuity and operation tests, polarity check, and gas line tests. The costs of acquiring the needed testing equipment and the additional time to conduct these tests have a considerable effect on the price of installation and as a result, the home.

You may be asking yourself “how did installation costs get so out of hand”? In my opinion, it is due to the lack of installer representation on the Manufactured Home Consensus Committee (MHCC) which has the job of advising HUD on these matters. I know that HUD and the MHCC have worked closely with the trade associations in developing the installation standard, but very few installers are members of these associations and few if any were at the table during these discussions.

 

With this in mind, I wanted to inform you all that the next Manufactured Home Consensus Committee meeting is being held on September 11-13, 2018 in Washington D.C. The meetings are open to the public, but I don’t think too many installers will be in attendance. You could email a proposal or comment to the Consensus Committee Click HERE.

Maybe just let them know how all of the changes have impacted the affordability of manufactured housing.

For more information on the Manufactured Home Consensus Committee, Click Here

 

Update on HUD Reporting Forms & Your Comments

Note: This information pertains to HUD licensed manufactured home installers and manufactured home retailers that are located in, or sell homes into states where HUD administers the Manufactured Housing Installation Program.  

If you recall, on May 2, 2018, I posted about the expiration date of the HUD forms that retailers and installers use to comply with the HUD installation program requirements.

HUD Form clip

While it is important that you continue to use these forms and submit the information as in the past, I have recently been made aware that the Office of Management & Budget (OMB) is now reviewing these forms and is seeking input from you.

The OMB is seeking comments on whether the information that you provide HUD on these reporting forms is necessary, and if the reporting forms can be improved for HUD to properly operate the program.

I am attaching the comments that I already provided for your review if interested. Comments on MH Installation Program Reporting Requirements

Also, I am attaching the Federal Register notice with the particulars needed to submit your thoughts. Click here to see the Federal Register Notice

The deadline for comments is August 13, 2018.

Finally, if submitting via email, the email address provided in the notice appears to be in error. Try sending it to:

OIRA_Submission@omb.eop.gov