Attached, for your information, review and use, are MHARR’s comments in response to the proposed rule on “Test Procedures for Roof Trusses” published by HUD on June 16, 2010. MHARR has prepared and filed these comments at an early stage in the rulemaking process so that they can be used as a model, basis, or support, as needed, for industry members who wish to submit their own comments. Comments in response to the proposed rule must be filed no later than August 16, 2010. Specific instructions for filing comments either electronically or via mail delivery are contained in the Federal Register notice at 75 Federal Register No. 115, June 16, 2010, page 34065, which can be accessed through the internet.
MHARR’s comments, based on extensive input from industry manufacturers, urge HUD to refrain from issuing the proposed rule at this time and to return this issue to the Manufactured Housing Consensus Committee (MHCC), for further analysis and consideration of both the necessity (if any) and cost-impact of changes to the roof truss testing process. As the comments indicate, the new testing procedures will affect a substantial number of the roof trusses used by the industry and will significantly impact both the cost of truss testing and the cost of trusses themselves. This will lead to home price increases that will unavoidably be passed to consumers. In addition, the transition to new testing procedures could result in a shortage of qualifying trusses for an extended period of a year or more. Yet no evidence has been presented that the existing, less costly, testing procedures are inadequate or have resulted in significant problems affecting roofs on manufactured homes.
These comments are consistent with the message that MHARR has been and continues to convey in other communications – regarding a range of issues and particularly regulatory compliance costs — with HUD, the Department of Energy (DOE) and other federal agencies, that now is not the time to impose costly new mandates, without corresponding benefits, on either the industry or its consumers. With industry production in 2009 at its lowest point in four decades and with consumers facing unprecedented difficulty in obtaining and/or qualifying for purchase financing, HUD — and all other relevant agencies — should not be imposing unnecessary and unnecessarily costly new requirements that will only result in the exclusion of more lower and moderate-income consumers from the manufactured housing market and further downward pressure on production and sales of HUD Code homes. Thus, insofar as this proposal originated with the MHCC, it should be returned to the MHCC for further study in accordance with the consensus process.
MHARR, as always, extends its thanks to the manufacturers and industry technical personnel who provided important information and input used in the development of these comments.
We will continue to keep you updated on this proposed rule as developments warrant.
Attachment – MHARR’s comments in response to the proposed rule on “Test Procedures for Roof Trusses”
Mark Weiss
Senior Vice President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
phone: 703/509-9489 (direct)
Phone: 202/783-4087
Fax: 202/783-4075
Email: mmarkweiss@aol.com
