Attached for your review and information are comments filed by MHARR in response to a proposed rule published by HUD in the Federal Register on July 26, 2013, to establish new ground anchor testing criteria and standards as part of the federal Model Manufactured Housing Installation Standards (24 C.F.R. 3285).

As MHARR has reported all along, this matter was the subject of extensive review and debate – including MHARR input – within the Manufactured Housing Consensus Committee (MHCC). Thus, to the extent that the proposed standards, as stated by HUD in its Federal Register preamble, are consistent with recommendations adopted unanimously by the Manufactured Housing Consensus Committee (MHCC) at its March 2011 meeting — except for “formatting and other editorial changes” – MHARR, as indicated in its comments, does not oppose the proposed rule. The comments, however, emphasize that in any final rule, HUD must address and minimize any potential cost issues that have not previously been considered by the MHCC, and should allow the continued use – after implementation of the new standards – of existing anchors produced and certified prior to the effective date of the new standards, until such existing inventories are exhausted.

The comments also emphasize that MHARR continues to object to the re-codification of the federal installation standards outside of the Part 3280 Federal Manufactured Housing Construction and Safety Standards (24 C.F.R. 3280) – contrary to the recommendations of the National Commission on Manufactured Housing, which served as the foundation for the Manufactured Housing Improvement Act of 2000 — based on a strained HUD interpretation of the “structure” of that law. MHARR has – and will – continue to object to this action because, among other things, it allows the industry and consumers to be subjected to inconsistent and discriminatory state and local regulation, as was fully explained and detailed in MHARR’s original comments on the HUD-proposed installation standards rule filed on June 24, 2005 and the HUD proposed installation program rule, filed on August 1, 2006.

This re-codification issue will be one of several Title VI matters that MHARR will address with a new non-career program administrator once that official has been appointed by the HUD Secretary.

MHARR Comments on HUD Anchor Proposal pdf download here