On March 1, in response to MHI’s urging, HUD’s Associate Deputy Assistant Secretary for Regulatory Affairs and Manufactured Housing, Bill Matchneer, sent a memo to the Primary Inspection Agencies (PIA’s) clarifying the Department’s position on Combustion Air Inlets for Fireplaces and Fireplace Stoves. Click here to view the letter.
Late last year, the Pennsylvania Department of Economic and Community Affairs erroneously ruled that the Manufactured Home Construction and Safety Standards (MHCSS) required manufacturers to install fireplace air combustion inlet ducts through the skirting of the homes to the outside.
HUD’s Field Guidance affirms MHI’s position that the Manufactured Home Construction and Safety Standards (MHCSS) §3280.703 and 3280.709(g) are consistent with other model building code requirements and with fireplace manufacturer instructions which permit air inlet ducts to terminate in the crawl space under certain conditions. HUD’s memo is in concurrence with MHI’s assertion that, while the Manufactured Home Installation Standards (MHIS) §3285.505(f) require that air combustion inlets must pass through to the outside of a skirted home, it is the installers responsibility and manufacturers are not required to provide necessary materials. HUD’s memo advises, however, that manufacturers ship the necessary materials. HUD will not take any enforcement actions against manufacturers that have not shipped the combustion air inlet duct with their homes.
In a February 24 letter to HUD, MHI reiterated its concerns and proposed a change in 3285.505(f) to make it compatible with the MHCSS, other model codes, and with fireplace manufacturer instructions. HUD’s memo says it will propose changes to clarify installer and manufacturer responsibilities for provision and field installation of combustion air inlets at the next meeting of the Manufactured Housing Consensus Committee in Tulsa, Oklahoma.
Representative James Clyburn (D-SC) to Introduce Legislation to Encourage Lending to Homeowners to make Energy Efficient Upgrades to Homes
Representative James Clyburn (D-SC), a Democrat leader of the U.S. House of Representatives, plans to introduce legislation in the near future that would encourage lending to rural homeowners to make energy efficient upgrades to their homes. The draft bill language would have not allowed such funds to go to owners of manufactured homes considered to be personal property (home only). In response to comments offered by MHI, Representative Clyburn has agreed to amend the bill’s language so that owners of all manufactured homes, including those considered personal property, would be eligible to apply for such energy-related loans.
