By MHI
HUD's Manufactured Housing Consensus Committee (MHCC) met this week in Arlington, Virginia and completed work on a full agenda of pending items. The MHCC considered a number of recommendations, many of which were proposed by MHI and its member representatives on the panel. The committee, in mostly unanimous votes, adopted the following:
- A change to exempt from HUD regulations, recreational vehicles and park models built and certified in accordance with NFPA 1192-2015 or ANSI A119.5-09 consensus standards.
- A recommendation for HUD to rescind its October 2014 memorandum regarding recreational vehicles, and delay further enforcement until new regulations are adopted.
- A recommendation for HUD to conduct proper rulemaking regarding attached garages. The position also includes a recommendation that until such rulemaking is undertaken, HUD should stop requiring expensive, time consuming and unnecessary Alternative Construction approvals for such designs, and halt any enforcement under Subpart I of the Procedural and Enforcement Regulations.
- A recommendation for HUD to convene a MHCC task force or subcommittee to develop standards for certain types of HUD-Code homes used as multifamily housing.
- A recommendation for HUD to reverse its current requirement for costly Alternative Construction approvals for certain types of roof assembly designs.
The MHCC also approved numerous updates to the standards (anticipated to be cost neutral) to provide more flexibility in the design and construction process, consistent with current building methods and practices. And, in response to a 2012 GAO report on manufactured housing, the MHCC approved a recommendation to improve indoor air quality in manufactured homes.
With regards to the back-log of recommendations, HUD's General Counsel estimated it currently takes up to two years for rulemaking to occur. Manufactured Housing Program Administrator Pamela Danner, pledged to try to speed up the process for MHCC recommendations.
The group was updated on HUD's efforts to develop an installation regimen for the states currently without programs (estimated at 12-14 states). MHI staff, George Porter and Mike Zieman of RADCO (MHI and MHEI members) are working with HUD's third-party contractor on this effort. HUD expects to launch a pilot program in two states by March and anticipates full implementation sometime in 2017.
Representatives from the U.S. Department of Energy (DOE) provided the committee with a summary of the recommendations developed by its Appliance Standards Rulemaking Advisory Committee Working Group on Manufactured Housing (ASRAC). Pending final approval from the Secretary of DOE, the previously released "Term Sheet" will be incorporated into a proposed rule, expected to be published early next year. As requested by MHI, it is likely the MHCC will have an opportunity to review and make recommendations prior to publication of the proposed rule.
Finally, in order to be included in the 2014-2016 Code Cycle, HUD officials noted the MHCC will be accepting proposed code changes until December 31, 2014. The MHCC's next face-to-face meeting should take place early summer of 2015. In the meantime, subcommittees and task forces will hold conference calls to work on pending proposals.
For more information, contact MHI Vice President of Regulatory Affairs Lois Starkey at (703) 558-0654 or lstarkey@mfghome.org.
