The Manufactured Housing Consensus Committee (MHCC) was created by the Manufactured Housing Improvement Act of 2000 and has several important functions. To set the stage for today’s report, understanding the rationale for the MHCC is useful.
“The Manufactured Housing Consensus Committee (MHCC) is a statutory Federal Advisory Committee body charged with providing recommendations to the Secretary on the revision and interpretation of HUD’s manufactured home construction and safety standards and related procedural and enforcement regulations. The MHCC is charged with developing proposed model installation standards for the manufactured housing industry. By regulation, HUD has included the MHCC in the process of revising the Manufactured Home Model Installation Standards, Installation Program Regulations, and Dispute Resolution Program regulations,” says HUD’s ‘official’ definition of the MHCC.
“The MHCC [Manufactured Housing Consensus Committee] is designed to ensure two fundamental objectives of the Manufactured Housing Improvement Act of 2000,” said attorney Mark Weiss, President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) to MHProNews. “First, substantively, to ensure that federal manufactured housing standards and regulations, as well as interpretations of the foregoing and any other changes to HUD policies and practices with respect to enforcement and monitoring represent and reflect a consensus view of all program stakeholders. Second, procedurally, it is designed to ensure that all such HUD enactments are developed in the “sunshine” — i.e., in an open, public forum followed by notice and comment rulemaking that in total provide due process for all program stakeholders.”
Against that backdrop, the following news item was provided by MHARR to MHProNews.
MHCC SUBCOMMITTEES MEET FOR FIRST TIME SINCE JANUARY 2020
Gathering for the first time since January 2020, two subcommittees of the Manufactured Housing Consensus Committee (MHCC) conducted conference call meetings on November 12, 2020 and November 19, 2020 to consider proposals submitted as part of the most recent code update cycle. Thus, while HUD has taken no public action whatsoever to move forward with rulemaking on dozens of regulatory reform proposals submitted pursuant to Executive Orders 13771 and 13777 — and recommended by the MHCC after a series of marathon meetings during 2019 — the Department is shifting the focus of the MHCC from de-regulatory proposals to a consideration of new proposed standards and regulations. This would appear to be the final step in HUD regulators’ strategy to “run out the clock” on any possibility of genuine manufactured housing program reform under those orders and the regulatory reform policies of President Trump, followed by a quick return to expected regulatory excesses under a new administration.
The MHCC’s Structure and Design Subcommittee, meeting on November 12, 2020, thus considered nine separate proposals, calling for: (1) new snow load requirements; (2) additional chassis protection against “deformation;” (3) carbon monoxide alarms; (4) new serial number posting locations; (5) adhesive seals for bottom board patches; (6) new wind zone, thermal zone and roof load zone posting locations; (7) deletion of a lock requirement for bathroom and toilet compartment doors; (8) combination smoke and carbon monoxide alarms; and (9) pre-tensioning for installation ground anchors. Consistent with MHARR’s written comments and observations submitted in advance of the meeting, the Subcommittee voted to disapprove these proposals with the exception of a change in serial number posting locations and a proposal to modify and retain language which would require “doors that access the toilet compartment” to be equipped with a privacy lock.” (24 C.F.R. 3280.107).
Subsequently, the MHCC’s Regulatory Enforcement Subcommittee, meeting on November 19, 2020, voted on three separate proposals to: (1) update the Part 3282 reference standard concerning recreational vehicles (RV) exempt from regulation as manufactured homes; (2) repeal certain duplicative installation inspection requirements; and (3) update the Part 3285 reference standard for separation between homes from the 2003 edition of the National Fire Protection Association (NFPA) 501A standard, to the 2017 edition of that standard. Of these proposals, the Subcommittee voted to recommend the proposed update to the recreational vehicle reference standard that is a component of the regulatory exemption of RVs from regulation under the HUD Code, while voting to reject the remaining two proposals.
These recommendations, as well as those resulting from a just-scheduled meeting of the MHCC Technical Systems Subcommittee meeting on December 8, 2020, will now be forwarded to the full MHCC for further action at a meeting expected during 2021.
MHARR is a Washington, D.C.-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.
The Manufactured Housing Institute (MHI), as of the time this report is being drafted, has not yet published their MHCC meeting notes. Their prior email to MHI members included a link to their MHCC comments letter, which did not go to the correct MHCC referenced document.
MHARR’s analysis and report above echoes in part a statement they made weeks- and months – ago that HUD is trying to ‘run out the clock’ on the Trump Administration and that MHI is arguably part of that foot-dragging, delay-tactics effort.
MHProNews will continue to monitor regulatory developments like this and others, reporting as warranted.
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By L.A. “Tony” Kovach – for MHProNews.com.
Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing.
For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.
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