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HUD Rescinds 2017 “Guidance” on Carport-Ready Manufactured Homes, Other Changes Ahead?

 

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In a news release to the Daily Business News on MHProNews, the Washington, D.C. based Manufactured Housing Association for Regulatory Reform (MHARR) said the following.

MAY 21, 2019

 

 

TO:                 MHARR MANUFACTURERS
                        MHARR STATE AFFILIATES
                        MHARR TECHNICAL REVIEW GROUP (TRG)

 FROM: MHARR

RE:                  HUD RESCINDS 2017 “GUIDANCE” ON CARPORT-READY HOMES

In one of its first substantive regulatory reform actions under Trump Administration Executive Orders (EO) 13771 and 13777, the U.S. Department of Housing and Urban Development (HUD) announced on May 20, 2019 (see, copy attached), that it is rescinding sub-regulatory “guidance” issued in 2017, requiring Alternate Construction (AC) approval for “carport-ready” manufactured homes.

MHARR first raised the issue of HUD’s unilateral designation of certain manufactured home features as “add-ons” pursuant to 24 C.F.R. 3282.7(b) – and thus requiring AC approval – in 2014 meetings and communications with former HUD program administrator, Pamela Danner.  The Association continued to press the issue of de facto rulemaking via sub-regulatory “guidance” memoranda (i.e., agency dictates issued without notice and comment rulemaking proceedings or Manufactured Housing Consensus Committee review as required by federal law) – concerning this and numerous other matters, in its EO 13771/13777 comments to HUD filed on June 7, 2017, further EO 13771/13777 comments submitted to HUD on February 20, 2018, and in an April 25, 2018 communication to Acting HUD General Deputy Assistant Secretary, Dana Wade.

HUD’s action in this matter is specifically based on recommendations of the Manufactured Housing Consensus Committee (MHCC), approved at its September 2018 in-person meeting.  As reported by MHARR at the time, “the Committee voted to recommend the withdrawal of HUD Field Guidance memoranda requiring Alternate Construction (AC) approval for carports, by effectively classifying carport-ready designs as involving an ‘add-on.’ The Committee also adopted a resolution supporting amendments to various sections of the Procedural and Enforcement Regulations to permit specific ‘add-on’ structures, including garages. Again, each of these changes have been specifically addressed and advocated by MHARR in both written comments and direct interactions with HUD officials.”

Consistent with these MHCC recommendations – and, again, as noted by HUD in its May 20, 2019 Notice – a separate June 12, 2014 HUD memorandum concerning “attached garages” is not being formally rescinded pursuant to this Notice, but will, apparently, be addressed by forthcoming proposed-amended regulations.  Nevertheless, MHARR continues to maintain and assert in direct meetings with HUD officials and related communications that all such sub-regulatory “guidance” memoranda are unenforceable and must be withdrawn.

Moreover – and in addition to the foregoing – the fact that it has taken more than two years for the HUD program, under its current leadership, to implement the very first substantive regulatory reform action since the Trump Administration took office, underscores a growing concern among manufactured housing program stakeholders, as first reported by MHARR following the recent April 30 – May 2, 2019 MHCC meeting, that some within the HUD program may be “slow-walking” long-overdue regulatory and program reforms in order to “wait-out” the current Administration and the tenure of Secretary Carson, who, according to media reports, may be leaving HUD at the conclusion of the President’s current term.

Regardless, MHARR will continue to aggressively pursue this matter with HUD, Congress and other appropriate authorities.

##

The release included an attachment from HUD Office of Manufactured Housing Program (OMHP) acting administrator, Teresa B. Payne.  That official HUD letter is linked here.

MHProNews notes that this follows in the wake of the recent address by HUD Secretary Ben Carson, who pledged to continue to work with the manufactured housing industry in practical ways to make more affordable housing available.

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https://www.manufacturedhomelivingnews.com/hud-secretary-ben-carson-speech-on-manufactured-homes-manufactured-housingactive-ingredientmedicationfor-a-stronger-america/

The full text of Carson’s speech is linked above, along with related videos and more.

Assistant Secretary Brian Montgomery Removal of Obsolete and Superseded Guidance Documents Letter | Manufactured Housing Association Regulatory Reform

Re: Notice of Removal of Obsolete and Superseded Guidance Documents – Docket No. FR-6156-N-01 Dear Secretary Montgomery: As you know, the Manufactured Housing Association for Regulatory Reform (MHARR) is a Washington, D.C.-based national trade association representing the views and interests of smaller and medium-sized independent producers of manufactured Housing regulated by the U.S.

Note too this recent MHARR effort, linked above.  In the wake of that, came this decision. Clearly, there advocacy is having some impact, it is more than just photo ops.

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Submitted by Soheyla Kovach to the Daily Business News for MHProNews.com.

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