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Manufactured Housing Consensus Committee 2012 Meeting Report

November 9th, 2012 No comments

The MHCC Holds First Meeting in 2012

Lois Starkey, Vice President, Regulatory AffairsThe Manufactured Housing Consensus Committee (MHCC) held its first and only meeting of 2012 on October 22nd – 25th to consider a number of recommendations for changes to the Manufactured Housing Construction and Safety Standards Program. HUD intended to have two meetings in 2012 but problems with the approval of a new contract for the Administering Organization, the National Fire Protection Association, resulted in a hastily arranged fall meeting in Arlington, VA. All but three of the 21 members were in attendance. Representatives from HUD included the Deputy Administrator of the HUD Manufactured Housing Program, the HUD engineering staff, and a representative from HUD’s office of General Council.

MHI was surprised and disappointed that higher ranking officials who oversee the program from the Department’s Office of Regulatory Affairs were not in attendance at any time during the meeting.

The Committee worked over two days to conclude work on all outstanding items before the Committee and to consider several new issues. This is despite the frustration voiced by MHCC members and MHI over HUD’s failure to implement dozens of recommendations of the MHCC over the last four years or more.

Highlights of the Committee Recommendations

Southern Yellow Pine Design Standards – By a 15-2 vote, the MHCC recommended that HUD delay implementation of the National Design Specification (NDS) for Wood for 2×2 and 2×4 southern pine lumber, effective January 1, 2013, until such time that it presents the MHCC with a proposal for changes to the existing standards as required by law, or until such time that HUD issues an emergency rule under Section 604(b)(5) of the Manufactured Housing Improvements Act of 2000. This is consistent with MHI’s petition to HUD earlier this year, and with MHI’s testimony before the committee.

Hinged Roof Assemblies – The MHCC voted 15-2 to recommend that HUD withdraw requirements for Alternative Construction Letters for certain types of hinged roofs designed for Wind Zone I until HUD clarifies current regulations regarding the on-site installation of hinged roof assemblies known as “double hinged” and “ridge box or peak cap” assemblies. The industry argued that such hinged roof assemblies do not need AC letters because they are constructed in the factory and are part of the “close–up” requirements under the installation standards, 3285,801(f). Members argued that methods for completing the installation of such homes are much less complicated than many multi-section home “close-ups.” These types of assemblies are common practice in the industry, and installers are trained and certified to complete these types of installations.

Wind Design Standards – The MHCC voted 17-0 to recommend that the reference standards of the American Society of Engineers (ASCE 7) wind design standards be updated to the 2005 version from the 1995 version, and the existing wind speed design requirements in the HUD Code be adjusted accordingly. However, the committee did not recommend any code changes regarding design requirements for wind pressure. It voted to maintain the current three wind zones as opposed to four. The new wind safety recommendations are the result of many hours of work by an industry led task force that included HUD and members of the ASCE-7 committee, who concluded that any new requirements beyond what the MHCC recommended would not be cost beneficial.

Indoor Air Quality – The MHCC concluded action on pending recommendations debated over the last four years, to improve ventilation and indoor quality in manufactured homes. In a unanimous vote, the MHCC recommended that the HUD Code provide for the voluntary use of ASHRAE 62.2, Ventilation and Acceptable Indoor Air Quality in Low-Rise Residential Buildings. In a change supported by MHI, the Committee voted to amend existing regulations to provide more flexibility in the types and size of ventilation systems that may be utilized to ensure adequate ventilation. (In a related issue, see information below on the GAO report).

Other MHCC Actions

In other actions, the Committee added new testing and certification requirements for certain types of vinyl siding; provided a new reference standard for Medium Density Fiberboard (MDF); updated and clarified language regarding construction methods; tabled a proposal regarding alternative foundation designs; rejected a site drainage proposal; rejected updated testing and certification requirements for windows and sliding doors; and referred new issues to MHCC subcommittees regarding water heaters.

Highlights of HUD (Designated Federal Officer) Report and Comments to MHCC

Status of MHCC recommendations pending at HUD

• Final Rules for the proposed 2nd set of updates to the standards, changes to roof truss testing, and changes to 3282, Subpart I, are in Departmental Clearance.

• A final rule for On-Site Completion of Construction is still being developed by HUD staff.

• HUD is still working to develop a proposed rule on a proposal developed by MHI regarding ground anchor testing. HUD is also working on changes to the regulations regarding Primary Inspection Agencies.

MHCC recommendations need a cost benefit analysis

HUD's Designated Federal Officer (DFO), Henry Czauski, reported that the MHCC/DFO must present to the committee its recommendations with an economic cost/benefit analysis. The recommendations must be in a format consistent with the Administrative Procedures Act (APA) regarding proposed rules and should include a preamble.

Manufacturers need to adhere to regulations regarding Alternative Construction

During discussion of hinged roof designs and Alternative Construction (AC) letters Mr. Czauski noted that there have been numerous instances where manufacturers are not following the regulations under 3282.14 regarding Alternative Construction. If the industry members demand a timely response it is imperative that complete information is provided and regulations regarding inspections, labeling and reporting be followed.

DOE has not communicated on energy efficiency proposals

In response to a question by a committee member, HUD reported that it has had no recent conversations with the Department of Energy regarding energy efficiency standards, although the law requires it, and a recent Congressional directive, sought by MHI, directs DOE to also consult with the MHCC.

Highlights of MHI’s Public Remarks to MHCC

MHI staff provided the following public testimony during each of the three public comment periods:

• Recommended that the MHCC consider HUD’s inappropriate action regarding enforcement of the new design standards for southern pine lumber.

• Urged the committee to review and comment, if necessary, on the recent and pending changes to the NDS standard for southern pine lumber.

• Recommended that the MHCC review HUD’s guidelines for quality assurance under the procedural and enforcement regulations and codify the guidelines.

• Expressed concern about lack of transparency and timely action by HUD and the MHCC on MHCC recommendations.

• Thanked HUD for recent actions regarding preemption and the City of Richland, Mississippi.

• Announced that MHI is working on an industry-based energy efficiency standard and hopes to bring it before the MHCC early in 2013.

GAO Report Published on Indoor Air Quality to Coincide with MHCC Meeting

Coincidently, related to MHCC’s recommendation on indoor air quality, the Government Accountability Office (GAO) issued a report entitled “Manufactured Housing Standards – Testing and Performance Evaluation Could Better Ensure Safe Indoor Air Quality” (available at www.gao.gov/products/GAO-13-52.) The report was requested by several members of Congress last year to examine indoor air quality standards for manufactured housing.

The report's key findings conclude that some provisions of the HUD Code provide a lower margin of safety against a carbon monoxide exposure incident than those for site-built homes. The report concluded that the primary reason for the differences in ventilation standards for manufactured homes and site-built homes is that the HUD Code has not been updated and has not kept pace with standards tied to ventilation and air quality for site-built homes. This is despite recommendations by the MHCC in 2009 and 2010 to update various ventilation standards and carbon monoxide requirements. The GAO report is consistent with MHI’s position that the HUD Code, to remain viable, must be updated.  

Lois Starkey, Vice President, Regulatory AffairsLois Starkey, Vice President, Regulatory Affairs, Manufactured Housing Institute (MHI)

Update on “FEMA In-Community Housing Relief”

June 10th, 2011 No comments

Editor’s Note: Spencer Roane is keeping us updated on the task force behind using manufactured homes as a part of post-tornado solutions to housing.

Tony and Catherine,

Here’s a note which we sent to FEMA, GEMA (Georgia counterpart), and various others with whom we hope to work on the idea of using vacant land lease community sites for disaster relief. It may also serve as an update for your readers.

From the time of David Roden’s first report here on May 7 – Manufactured Homes Could Be Part of Post-Tornado Solution in Georgia – our task force has continued to pursue the use of manufactured housing as an option in disaster situations. We are currently working to schedule a meeting of the Georgia Disaster Housing Task Force to explore issues of common interest. In the meantime, allow me to identify the players in this effort at this juncture:

The Georgia Manufactured Housing Association (GMHA) represents the interests of all segments of manufactured housing in Georgia, including manufacturers, transporters, retailers, communities, lenders and suppliers. Jay Hamilton is our executive director. He is new to the position, but has extensive experience in the industry. His office phone is 770-955-4522. David Roden is a community owner (CO) and active member of GMHA. Steve Case and Spencer Roane are also community owners who serve as community representatives on the GMHA board.

Our national organization is Manufactured Housing Institute (MHI) in Washington, DC. Thayer Long is president. MHI formed a task force to work with FEMA on the design of MHs for disaster relief and to advance the concept of placing disaster relief homes in land lease communities (LLCs, aka mobile home parks). Lois Starkey is the primary contact at MHI for this program. Spencer serves as one of several community owners on the MHI task force. Several members of that task force attended the “Industry Day” Seminar with FEMA personnel in Washington DC on June 7. We will learn more about that meeting next week.

David volunteered in the cleanup effort after the April tornadoes struck Georgia and Alabama and subsequently proposed that MHs be located on vacant lots in LLCs for use by disaster victims. Since then he and Spencer have been exploring that concept with MHI, GMHA, FEMA, GEMA, and community owners across the country. Several relatively recent developments in our industry have come together to make this more feasible than ever:

• Most LLCs have 5-15% vacancy rates, mainly as a result of the economic slowdown and the same finance meltdown that affected conventional housing. “Best guess” at this point is that there are about 200,000 vacant LLC lots across the country.
• As COs have sought to fill vacant lots with new MHs, many manufacturers have begun building “Community Series” homes (CSHs). George Allen and Don Westphal have worked closely with Business Development Managers (BDMs) with most manufacturers to develop this concept. These are generally lower priced, single-section, usually 16’ wide by 70-80’ long, 3 Br 2 Ba, vinyl sided, shingle roof, with attractive exterior and interior features. INSERT PHOTOS OF TWO CSH HOMES. The cost of these attractive, functional homes is about $25,000, delivered to the LLC. Setup, utility connections, A/C, skirting, and decks add about $10,000 more to the cost.

 

Community Series Home 1

 

Community Series Home 2

 

• To provide quick and efficient support to disaster victims, a database of available home sites which are in close proximity to a disaster is a necessity. Several alternatives exist in Georgia and elsewhere:
• The Community Attributes System (CAS) was developed as a joint effort between MHI and Datacomp, which also owns the Internet marketing site “MH Village.” Dan Rinzema is president of Datacomp. Although the database contains approximately 40,000 land lease communities (LLCs) across the country, much of the information is outdated. The website is www.mhicas.org.
• We just learned of another database which serves Georgia and 29 other states. The Georgia service is Georgia Housing Search.Org.  We understand that it currently contains about 170,000 rental listings, including manufactured homes, LLC lots, site-built houses, and apartments, and experiences 8,000 – 9,000 searches per day for available rentals. The parent non-profit organization is www.socialserve.com. The services are apparently funded by state or federal agencies and are free to landlords and prospective tenants. We’re still collecting information on both.
• Some real estate brokers and agents who specialize in LLCs have surveyed many LLCs in states in which they broker properties. Max Baker, a GMHA member and agent with Marcus & Millichap, recently compiled a database of about 900 LLCs in Georgia ranging in size from a few lots to about 500. We know there are others elsewhere with similar LLC data who are willing to participate in this disaster housing relief effort.

Since CSH homes are compatible with other homes in LLCs, COs would be glad to have them moved into their LLCs for disaster relief, provided the CO screens the new resident as he/she would any other resident. Also, since COs want homes to remain in the LLC, they would be willing to purchase the MH after FEMA/GEMA use. This would seem to be an efficient, cost-effective “exit strategy” for FEMA since the homes would not have to be moved to a storage facility, rehabbed, and stored for the next emergency.

We welcome the opportunity to work with GEMA, FEMA and others to implement this program. We are planning a meeting of about 100 COs in the Atlanta area in mid-October and would be glad to have someone from GEMA and/or FEMA discuss this program at that meeting. We also encourage FEMA to contact George Allen who holds an annual meeting (Roundtable) of COs across the country in mid-September. This year’s meeting will be in San Antonio, Texas. It would be an excellent means of publicizing this program on a national basis. # #

David Roden, davidroden@yahoo.com, 423-760-4819
Spencer Roane, spencer@roane.com, cell ph. 678-428-0212