The Federal Emergency Management Agenacy (FEMA), following several delays, conducted two “Industry Day” meetings on March 15, 2013 to obtain industry input — and provide relevant information to interested parties — regarding expected future solicitations for emergency Temporary Housing Units (THUs).  The meetings were divided into a morning session primarily focused on design, supply and contract issues relating to the THUs themselves, and an afternoon session devoted to logistical matters including transportation, storage and other similar concerns.

The meetings, which were fundamentally question and answer sessions, were conducted by the FEMA Deputy Branch Chief for the THU program and were attended by the FEMA contracting officer who has been responsible for past procurements of HUD Code THUs. 

During the course of the FEMA-industry dialogue — and based, in part, on inquiries posed by MHARR — certain new information was made available or confirmed by FEMA.  In addition, the agency invited further comment from interested parties on a number of contract-related issues, as follows:

· It was made clear that future FEMA procurements of THUs will be for HUD Code units only, instead of recreational vehicles, “park models” or other structures that do not meet a preemptive federal code allowing placement anywhere in the country. 

· FEMA representatives stated that there would be no separate FEMA testing or requirements regarding indoor air quality and that compliance with the HUD Code standards regarding formaldehyde would satisfy expected contract terms.

· FEMA indicated that it is currently planning to require 100% PIA inspections during production of THU units.

· FEMA invited comment from producers regarding minimum weekly production levels and “ramp-up” times that would facilitate bidding and participation by smaller producers. 

· FEMA indicated that future procurements will not specify one particular HVAC type or supplier, but will allow manufacturers to satisfy performance-oriented requirements in order to address problems raised by more restrictive requirements contained in previous solicitations.   

· FEMA indicated that it would also be willing to consider alternatives to drywall construction with taped joints that is more costly and subject to transportation damage.

· FEMA addressed the possible elimination of the previous distinction between homes for “North” and “South” zones – for design, procurement and deployment simplification –and instead requiring that units be constructed for use anywhere in the country.

· FEMA highlighted its interest in the development of designs for smaller HUD-compliant manufactured homes in the 8-foot width range that could be situated, among other places, on existing driveways and small lots in disaster areas.

· FEMA addressed cleaning, storage and re-use of deployed units, specifically focusing on issues raised by long periods of storage. 

Although, FEMA, as is typical, would make no verbal commitments at the meeting, it’s most recent “Request for Information” concerning THU units stated that FEMA does anticipate “issuing a solicitation for manufactured homes in the near future.”  FEMA representatives stressed, moreover, that the solicitation will first be published as a “draft solicitation,” which will provide a further opportunity for comments and additional input from interested parties.

Manufacturers with an interest in future THU solicitations can contact FEMA directly to ensure that they receive relevant information.  In the interim, MHARR will continue to carefully monitor developments concerning FEMA’s use of HUD Code manufactured homes, focusing particularly on two issues: (1) advancing solicitation terms and parameters that will allow – to the maximum degree possible – full and fair competition, including participation by smaller manufacturers that wish to do so; and (2) ensuring that FEMA contract requirements, even though fully financed by the federal government, do not become a “laboratory” for the future development of new federal standards, regulations and requirements that would undermine the private market affordability of manufactured housing.  This is a concern that requires constant vigilance because, as a comprehensively regulated industry, manufactured housing is a tempting target for special interests which seek to impose new mandates on an entire segment of the housing industry in one fell swoop.  

The subject of FEMA THUs will be discussed in greater detail at the upcoming MHARR Board of Directors meeting in Tunica, Mississippi.