MHARR, MHI Statements on HUD’s Frost Free IB Rule

Featured image credit, MHARR, MHProNews.

The Manufactured Housing Association for Regulatory Reform is calling for the withdrawal of a proposed “Interpretive Bulletin” (IB) regarding “frost free” manufactured home foundations.

The IB violates multiple provisions of the National Manufactured Housing Construction and Safety Standards Act of 1974. It also violates HUD’s own regulations and regulatory reform policies of President Trump, the MHARR said.

The HUD proposed ‘frost-free’ IB, at best, is a purported solution in search of a problem that simply does not exist,” Mark Weiss, MHARR President and CEO, stated in a press release to MHProNews.

“At worst, it represents indefensible regulatory overkill that will needlessly harm Americans and American small businesses, while it simultaneously seeks to illegitimately divest the role and authority of state governments with respect to the installation of manufactured homes.” Weiss said.

In either case, it should be resoundingly rejected by the Trump Administration and Secretary Carson.” Weiss stated.

MarkWeissManufacturedHousingAssociationForRegulatoryReformMHARRPresidentCEOMHProNewsMHARR pointed to the American Action Forum (AAF) report finding “that federal rulemaking and the imposition of new federal regulatory burdens on American businesses and consumers has fallen to record-low levels during the first six months of the administration of President Donald J. Trump.


As regular Daily Business News readers know, the Manufactured Housing Association for Regulatory Reform is a Washington, D.C.-based national trade association. They represent the views and interests of independent producers of federally-regulated manufactured housing.

While they do not claim to be an umbrella organization, they have in recent years become more involved in finance, community and retail related issues, because – as they put it – of the failure of the industry’s “post-production” sector to properly address such matters.

Lesli Gooch. Credit: MHI.

On the surface, MHARR and MHI’s position (click here) on this issue look similar. But unlike Lesli Gooch, Senior VP at MHI, Weiss goes to the heart of the matter. Without changing HUD program director Pam Danner, Weiss says, no changes will take place in the manufactured home program. See a prior report, with Gooch’s comments and Weiss’ sparks flying, linked here.

Image credits, MHProNews/Pixabay.

Sources tell MHProNews that MHI has communicated to some state executives that the door is closed on the removal of Danner topic.

Not so for MHARR.

Weiss’ statement said, “the HUD manufactured housing program, under its current Administrator, continues to churn out reams of new unnecessary and unnecessarily-costly de facto regulatory mandates, including its proposed “frost-free” IB, designated “I-1-17.”

As MHARR’s comments demonstrate, the proposed IB is not, in fact, an “interpretation” of HUD’s existing standards at all, but rather, a disingenuous manipulation of the IB process to substantively alter the existing regulations – and impose costly new requirements on consumers and thousands of smaller industry businesses.

The MHARR goes on to point out that there is “no evidence whatsoever of systemic problems with “frost-free” manufactured housing foundations designed for – and used – in “freezing climates” under the existing HUD installation standards for homes.

Instead, they suggest that “the proposed IB is part of a broader pattern of action by the current administrator – an Obama Administration holdover parachuted into the HUD program nearly four years ago — which has substantially intensified the scope, extent, compliance burdens and costs of needless federal regulation on consumers and the industry, to the ultimate benefit of program contractors and industry competitors.”

Based on these violations of applicable law, HUD regulations and Trump Administration policy, MHARR’s comments call on HUD to withdraw the proposed IB.”

The entire MHARR release is linked here.  The MHARR comments letter on the frost free IB proposal, is linked here. ## (News, anlysis.)

(Image credits are as shown above, and when provided by third parties, are shared under fair use guidelines.)

JuliaGranowiczManufacturedHomeLivingNewsMHProNews-comSubmitted by Julia Granowicz to Daily Business News for MHProNews.







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