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!

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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