The joint report recently published by the U.S. Centers for Disease Control (CDC) and the U.S. Department of Housing and Urban Development (HUD) on “Safety and Health in Manufactured Structures” says a great deal about HUD and the manufactured housing industry – though not what its authors likely intended.
MHARR has warned for years that, as an industry comprehensively regulated by the federal government, the problems of the manufactured housing industry flow directly from Washington, D.C. and the failure of much of the industry to deal effectively with the federal regulatory establishment.
The CDC-HUD report provides the proof. It illustrates, in one package, the continuing bias of HUD regulators against manufactured homes as “trailers,” which lies at the root of their failure – with a wink and a nod from part of the industry – to fully and properly implement key reforms of the Manufactured Housing Improvement Act of 2000. Together, these ensure continuing discrimination against manufactured homes as “trailers,” which has fueled the drastic industry decline of the past decade. The CDC-HUD report is not a report on “housing.” Site-built housing Is not included. Modular housing is not included. What is included? “Travel trailers,” “camping trailers,” “park trailers,” “trailers” used as “classrooms, day care centers and workplaces” and, oh yes, “manufactured homes” that, according to the report, are “sometimes used as school classrooms, offices and purposes unrelated to housing.” So, a report about “trailers,” just lumps manufactured housing together with these unregulated “structures” that are not designed to be used as a permanent dwelling by anybody. The report, with photographs of mice and mold on the cover, then goes on to trash manufactured homes, repeating the same timeworn arguments and outdated “studies” of the usual suspects – special interests, like sprinkler proponents.
For example, the “fire safety” section relies partly on 20 year-old studies and partly on studies conducted by or on behalf of a leading sprinkler advocate – all casting manufactured housing in the worst possible light. At the same time, the report dismisses the impact of the HUD Code fire safety standards, stating only that “there is some evidence that fire safety in manufactured homes has improved since HUD’s standards took effect….”
Some evidence? The U.S. Fire Administration (USFA), in its 2004 report, “Fire in the United States,” concluded that “the HUD [fire safety] standard clearly made an impact,” noting “large downward trends in fires (48 percent), deaths (57 percent), injuries (51 percent), and property loss (50 percent), even as the mobile housing stock has increased…” (Emphasis added). Is this information in the report? Of course not. Is HUD aware of it? Absolutely, because MHARR highlighted it at the October 2010 Manufactured Housing Consensus Committee (MHCC) meeting, when HUD and the Manufactured Housing Institute (MHI) floated “where required” sprinkler proposals.
What about other “evidence?” An earlier USFA report showed similar results, stating: “despite an increase in mobile home stock, deaths have dropped 5 percent, dollar loss 35 percent and fires 25 percent over the period 1983-1990… These are all uuite similar to other single-family dwelling changes during that period, except for dollar loss, which had a much sharper decrease for manufactured homes.” (Emphasis added). And, all of this is consistent with a study by Foremost Insurance Company – which has to deal with fire claims – that “the chance of a fire occurring in a site-built home is twice that of a manufactured home” and that “manufactured housing… measures up favorably with site-built homes from a fire safety standpoint.” None of this positive information, however, was included in their report by CDC or HUD.
It would be easy enough to blame the biased focus and content of this report on CDC and dismiss it as a product of that agency’s inexperience and unfamiliarity with housing in general and manufactured housing in particular. It would be just as easy, and true, to blame CDC for developing this report under false pretenses – telling participants in an October 2008 meeting, including MHARR, that a “public comment draft” of the report would be provided to stakeholders for review – and then failing to do so. But that would miss the most important aspect of this report for purposes of the industry, its recovery, its relationship with federal regulators and the representation of its interests.
Congress told HUD, in the 2000 law, to “facilitate” the “availability of affordable manufactured homes” and “the acceptance of the quality, durability, safety and affordability of manufactured housing.” Yet, this biased “report” was not only co-published by HUD, it was reviewed prior to publication by HUD program regulators. In fact, the report specifically names and credits, among others, HUD program personnel who, as “subject matter experts and reviewers… helped guide the authors in developing and producing this document.”
Why would HUD, a housing agency with responsibility over the most affordable form of home ownership available to lower and moderate-income families tolerate, let alone put out a report like this? Why would HUD, with the industry in a sustained and deep decline, publish a biased, one-sided “report” that can only feed discrimination against the industry and its homebuyers? And, why would federal program personnel allow a report that lumps federally-regulated manufactured housing together with unregulated “trailers” and contains so many obvious errors and misleading assertions?” Given all this, is it any wonder why it remains so difficult to get public or private financing for a manufactured home?
The CDC-HUD report is a smoking gun, proof of what MHARR has highlighted for the past 11 years as HUD has systematically ignored or undermined the 2000 law – HUD regulators still view manufactured homes as “trailers” and this will not change unless and until they realize that the entire industry is serious about this matter. In the meantime, this prejudice against manufactured housing has had (and will continue to have) ripple effects far beyond the federal program, fueling discrimination against the industry and Its homebuyers in financing, placement, zoning and other matters that have led to the disastrous decline of the past decade. The CDC-HUD report should be a wake-up call for everyone that the industry’s problems are focused in the nation’s capital and that its weakness, timidity and ineffectiveness have allowed an outdated, antiquated and biased view of manufactured housing to continue undermining the industry’s legitimate, hard-earned place in the housing market, as well as its revitalization to a market share that should routinely run in the hundreds of thousands of homes annually.
In MHARR’s view, the CDC-HUD report is a slander against a bedrock American industry, filled with good, hard-working people, doing their best under difficult circumstances to provide decent and affordable housing for the nation’s lower and moderate-income families.
MHARR is a Washington D.C.-based national trade association representing the views and interests ofproducers of federally-regulated manufactured housing.
