FFF: Embrace it or Dig Deep Into $ Pocket!

COBA7® via community-investor.com Blog # 326 Copyright @ 7 December 2014

Perspective. ‘Land-lease-lifestyle communities, a.k.a. manufactured home communities and ‘mobile home parks’, comprise the real estate component of manufactured housing.’

This blog posting ‘is the primary national advocacy voice, official ombudsman, research reporter, & online communication media for all LLLCommunities in North America!

To input this blog &/or affiliate with Community Owners (7 Part) Business Alliance®, a.k.a. COBA7®, use Official MHIndustry HOTLINE: (8777) MFD-HSNG or 633-4764.

Introduction to this week’s COBA7® blog posting at community-investor.com website:


‘Frost Free Foundation’, a.k.a. ‘FFF’; the ‘Silver Bullet’ for Home Installations in LLLCommunities?’ YES! This is the ‘sleeping giant’ of the past decade, now awakening!


‘Good-bye Danny Ghorbani! Or, ‘See You Later as Arbitrator?’ Manufactured housing industry losing it’s ‘watchdog’ of the past three decades! Who steps into his shoes???


If you’re not yet an ‘MHInsider’, takes steps now to become one during the Year 2015!



‘Frost Free Foundation’, a.k.a. ‘FFF’ the ‘Silver Bullet’ for Home Installations in Communities?


If You Remember George Porter, SBRA, & Model MH Installation Standards: Final Rule 24 CFR 3285!

During the decade between dawning of the 21st Century and year 2010, as the manufactured housing industry was staggering from having lost easy access to chattel capital and plummeting home shipment volume, it faced the eventual reality of increased regulatory oversight from HUD, where the Model MH Installation Standard was concerned. Well, it appears that feared time has arrived (2015), and land-lease-lifestyle communities (a.k.a. manufactured home communities) nationwide are ill prepared for it.

The Challenge? When the Model Manufactured Home Installation Standards: Final Rule, 24 CFR 3285 was implemented by the U.S. Department of Housing & Urban Development, October 2007, it was pretty much assured that unless one’s existing concrete foundations (i.e. piers & concrete ribbons) extended below the frost line, they’d have to be replaced, upon home turnover, at a minimum cost of around $5,000.00 per foundation – even if the preexisting foundation system(s) had never failed!

The Opportunity? Paraphrasing a 1960s hit song about coal miner, ‘Big John’:

‘Along came George Porter & the Systems Building Research Alliance (or SBRA)!’

The adventure began with George experiencing an epiphany-like personal insight, where manufactured housing installations were concerned. While he’d been a practicing installation specialist ‘for decades’, it all came together for him one day, with this simple, eureka-like realization…

“…frost heave can only occur in the presence of three interrelated factors: 1) subfreezing temperatures, 2) frost susceptible soil and 3) sufficient moisture in the soil (about 80% saturation or greater). Elimination of any of these factors will prevent frost heave from occurring.”

The above quote is from the summary of ‘A Frost Free Foundation® (FFF); an Alternative Shallow Frost Protected Foundation Design for Manufactured Homes, by Paul W. Hayman, MS, PE or Hayman Engineering, Inc., prepared by Systems Building Research Alliance, July 2010

But how did the manufactured housing industry research and codify George’s epiphany into that summary statement? Via interrelated cooperation between Porter and SBRA’s Technical Advisory Committee, with Hayman Engineering; plus financial support from ten suppliers/businesses and the encouragement of 36 manufactured housing association executives!

The SBRA (formerly the Manufactured Housing Research Alliance), FYI “…is a non-profit organization with the mission of developing new technologies to enhance the value, quality, and performance of the nation’s factory-built structures.” As such, it served as the linchpin for this project. It provided the venue for establishment of scientific proof, and solicitation of engineering support, for the ‘frost free foundation’ or ‘FFF’ concept, and its’ applicability to HUD-Code manufactured homes!”

So, what’s ‘FFF’ all about? Instructing raw land developers and owners/operators of land-lease-lifestyle communities (a.k.a. manufactured home communities) how to properly implement and maintain frost free foundations in lieu of expensive monolithic concrete foundations. Read that sentence again. It’s the gist of what’s to follow here!

Permission has been sought to reproduce the 11 page ‘FFF’ report, cited in this blog posting, as a booklet to be made available to anyone in the HUD-Code manufactured housing industry and LLLCommunity asset class who requests it. Cost? To be determined, but minimal, with any profits generated going to the RV/MH Heritage Foundation’s Hall of Fame facility in Elkhart, IN, or possibly the SBRA. More information on that when available, along with ordering instructions.

In the meantime, for more information, simply phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764 to reach the Community Owners (7 part) Business Alliance® or COBA7®.

But Whoa! There’s More to The FFF Story! Some of it Good, Some of it Hardly so….

First the Good.

Want to make the Frost Free Foundation, or ‘FFF’, appropriate to your particular LLLCommunity(ies) application? Heed this sage advice from one Midwest manufactured housing state association to their members:

• Obtain a copy of ‘A Frost Free Foundation® (FFF): An Alternative Shallow Frost Protected Foundation Design for Manufactured Homes, prepared by Paul W. Hayman, MS, PE, Hayman Engineering, Inc. (This should be part of every Installation Manual, but isn’t. And why we’re attempting to reprint the document)

• Require a soil test by a licensed soil tester

• Require the ‘FFF’ design be used only with certain soil types, unless native soil is replaced

• Require the frost line be above the water table

• Require drain tile and or roof gutter installation to facilitate movement of water away from the ‘FFF’

• Have an ‘FFF’ plan (See first bullet point) sealed by a registered engineer; and if applicable (given a statewide building code), pay the state – where ‘FFF’ is to be utilized, to have design ‘state approved’. Doing so, in the latter instance, forces local building inspectors to accept the design – since, at this point, ‘FFF’ is not mentioned in most Installation Manuals. Furthermore, and this is an important point, if a local inspector attempts to decline accepting an ‘FFF’ design because it’s not in new home Installation Manual, remember: the HUD-Code is what it says, and if home manufacturer overlooks a viable alternative (i.e. ‘FFF’ plan sealed by a registered engineer), that’s an issue under warranty law for the licensed installer and home manufacturer to work out. It isn’t a code issue.


Now, for the Not so Good

To date, as a land-lease-lifestyle community owner/operator, I’ve reviewed official Home Installation Manuals prepared and distributed by several HUD-Code home manufacturers, to see if the aforementioned Frost Free Foundation system is included therein (It isn’t), or even mentioned, e.g. Is ‘FFF’ in the index to the manual? (It isn’t). Thus, the emergence of this disturbing reality:

While it’s easy to be impressed with the detailed and complicated descriptions, in these Installation Manuals, as to effecting the proper installation of a HUD-Code home. From the home manufacturers’ perspective, this is their ‘bread & butter’, their means of ensuring – as far as it goes – the safe, secure, and stable installation of their product. But the question that comes to mind is, ‘Why the absence of (any) mention of ‘FFF’ in Installation Manuals?’

Frankly, most – to – all HUD-Code home manufacturers (i.e. certainly MHI direct, dues-paying members) are well aware of the ‘FFF’ researched and codified, engineering wise, by the Systems Building Research Alliance in 2010, given SBRA’s close working relationship with MHI.

Perhaps it is a matter of perspective, as suggested in a previous paragraph. The home manufacturer’s primary installation concern is to explain how to do it ‘right and well’, per the design and performance requirements of their HUD-Code housing product. And expensive installation costs be damned, as those high dollar costs are not the manufacturer’s responsibility. Remember however, these are the folk about whom the image-compromising apercu, ‘D&R Deliveries’ (i.e. ‘Drop & Run!) was coined in the early days of the industry. So maybe not much has changed, yet…..

However, the matter is much different from the LLLCommunity owner/operator perspective. Here, expensive installation costs do matter, they matter a lot! For example, given a properly drained rental homesite featuring concrete ribbon foundations in place, under the same fully and well-skirted home, for 30 years, with no failures whatsoever. When that home is removed from said foundation system, federal installation standards require those 30 year old ribbons be replaced with a monolithic slab (not concrete ribbons) or conventional below the frost line piers, to the tune of approximately $5,000.00. per rental homesite! On the other hand, given a properly drained rental homesite, with appropriately porous soil, and perimeter skirting around the home – all requirements of the engineered and registered Frost Free Foundation, then any home can be installed on the rental homesite using specially-designed pads or piers, even the original concrete ribbons, at little to no extra cost to the property and or home owner.

And there’s yet a further $ matter here. Who pays for the cost of the new foundation system? Well, in some locales it’s a matter of state law. How so? In states that have adopted AARP’s landlord tenant law model language, whereby the LLLCommunity owner/operator cannot make the tenant (homeowner/site lessee) pay for ‘permanent improvements’, two key questions come into play, being: 1) Is the new foundation a permanent improvement? 2) Does it serve the community or the home? Answer might be a matter of choice. If homeowner/site lessee has a choice between the two cost extremes described, he/she pays for said choice. If the property, however, ‘requires’ one or another of the options, it pays for the improvement. All the more reason to take the steps outlined earlier, to ensure one is enabled to use the ‘FFF’ alternative on-site in one’s LLLCommunity(ies).

Bottom line? Follow the money! Again, matters of perspective….

The home manufacturer fabricates and delivers a new home – with an official Installation Manual, to the rental homesite, often within a LLLCommunity, and ‘end of story’ unless there’re service issues later. On the other hand, pity the LLLCommunity owner/operator who has 100 well-functioning rental homesites, using concrete ribbons or shallow piers, for the past 30 years; and now faces the prospect of being forced, maybe beginning during year 2015, of having to retrofit every one of them, to the tune of $500,000.00. (That’s $5,000/site X 100 sites)!

For the HUD-Code home manufacturer, ‘FFF’ offers little to no value – added to their (housing) product, when the official Installation Manual is supplied with the home upon delivery. However, for the LLLCommunity owner/operator, ‘FFF’ is worth at least $5,000 per site savings, on rental homesites not presently in compliance with the nearly decade old federal home installation standards, soon to be enforced during 2015.

All this, in my opinion, is a major disconnect between two major segments of the HUD-Code manufactured housing industry. Anyone care to bet how the two national advocacy bodies, both of which are home manufacturer-dominated, will arbitrate this important and potentially costly issue – if they even allow it to see the light of day, except for social media communiqués like this blog posting? Specifically, this is a timely and serious challenge for MHI’s national communities council division to soon publicly discuss and resolve with the institute’s manufactured housing division.

In the meantime, what can you, as a LLLCommunity owner/operator do? Encourage your source of new HUD-Code homes to put ‘Frost Free Foundation’ into their Installation Manual as an approved alternative. And, if you’re a direct, dues-paying member of either or both national manufactured housing advocacy bodies, contact them ASAP, requesting they intercede, in your behalf, with their HUD-Cod manufacturer members to do the same, and put ‘FFF’ into their Installation Manual as an approved alternative.

And watch here for instructions on how to obtain your copy of ‘A Frost Free foundation® (FFF): an Alternative Shallow Frost Protected Foundation Design for Manufactured Homes’, by Paul W. Hayman, MS, PE., of Hayman Engineering, Inc. Prepared for the Systems Building Research Alliance, New York, NY., 1 July 2010.


Good-bye Danny Ghorbani!
‘See You Later as Arbitrator’?

As One Era Ends, is Another About to Begin?

Frankly, I can’t imagine the manufactured housing industry without Danny Ghorbani ‘front and center’ every day in every way, as he has been for the past 28+ years – but now (soon) waiting ‘in the wings’ ready to advise and arbitrate when asked!

But first, a brief look back at his career, one spanning more than four decades; 46 years to be precise. Not many in the business today (are old enough) to say they ‘cut their manufactured housing teeth’ reading and hearing Danny Ghorbani ‘holding forth’, as an engineer on MHI’s staff, then as founder – and now long time executive VP, of the Manufactured Housing Association for Regulatory Reform, or MHARR. I can, so take the liberty of sharing what follows here…

As an industry, we are about to lose our watchdog! Of all the labels that could be, and some have been, applied to Danny ‘over the years’, e.g. maven, guru, lobbyist par excellence – and more; ‘Watchdog’ covers the territory best! Why? Because Washington, DC., and its’ surrounds, oft referred to as ‘Inside the Beltway’ works and functions pretty much to and for itself – just think of the politicking we read, see, and hear about all the time. Well, Danny G., for nearly four decades has been our ‘first source of credible information’ about what was soon going to happen to us as an industry, where regulators, bureaucrats and politicians were concerned.

While many ‘inside the beltway’ prefer the attitude and MO of ‘Going along to get along’ (a.k.a. consensus building) when dealing with politicians and regulators, Danny G, frequently went ‘pretty much alone’ as he confronted Congressmen, Senators, and bureaucrats – of both the appointed and career types, ‘head on’ over issues, proposed legislation, laws, regulations, and more, that would impact or already impacted manufactured housing. Of late, he’s even found time to learn more about the ‘post production’ segments of the MHIndustry, particularly chattel finance and land-lease-lifestyle communities, in his search and effort to restore easily accessible chattel capital to our business environs, and garner cooperation from resident-focused national bodies.

I sincerely hope his peers at the Manufactured Housing Association for Regulatory Reform host a retirement party in the near future, and invite the entire manufactured housing industry to fete this deserving leader and spokesperson one more time! If and when I hear about such a gathering, I’ll let you know about it here, and in the Allen Letter professional journal. Hmm. Wonder who’s going to fill Danny’s monthly ‘white paper space’ in The Journal? Bet you hadn’t thought about that…One more way he’s nigh irreplaceable in the manufactured housing industry. And make sure YOU say ‘Good – bye!’ to him in your own way!

What’s this about a NEW ERA beginning? Well, we already know a NEW ERA began for land-lease-lifestyle community owners/operators began 1 January 2014, with the launch of the Community Owners (7 Part) Business Alliance® or COBA7®. Read more about that in Part III of this blog posting (to follow) and the 26th annual ALLEN REPORT, a.k.a. ‘Who’s Who Among LLLCommunity Portfolio Owners/operators Throughout North America!’, soon to be distributed (January 2015) to COBA7 affiliates, a.k.a. ‘MHInsiders’ and owners/operators who completed AR questionnaires in their entirety. For more info on any of this, phone the Official MHIndustry HOTLINE: (877) MFD-HSNG or 633-4764.

So, is there yet another NEW ERA on the heels of COBA7®? Some think so. The nature of this NEW ERA? Take your pick of worthy foci: major changes needed to MH business model, to attract financing and homebuyers; restructure national advocacy presence, to better fulfill needs of post-production segments of the industry/asset class; debate and decide whether we’re better off, going forward, as ‘consumer product’ or ‘affordable housing’, but not both; and more….


Not Yet a ‘MHInsider?’ Well, here’s how to make that happen before 2015!

If you’re reading this blog posting and haven’t yet formally affiliated with the Community Owners (7 Part) Business Alliance, commit to do so as we segue into year 2015. Why? More good reasons that I have space to tell you here, but for starters:

• More than 200 of your MHIndustry & LLLCommunity peers, including HUD-Code home manufacturers, LLLCommunity owners/operators, lenders, and vendors have already done so. Goal is to have 400 affiliates by year end 2015!

• And you’re not just affiliating with the newest and most vibrant national business alliance, but once you start reading the monthly Allen Letter professional journal, and if so opted, the Allen CONFIDENTIAL!, you in effect become a special class of businessman and woman, a true ‘MHInsider’! How so? You’re now privy to information, news, and statistics not available from any other source anywhere!

• All of a sudden, regional and national MH venues become more valuable to you, as you meet privately, and learn with COBA7® ‘MHInsiders’. For example; on 20 January 2015, in Louisville, KY., I’ll be teaching the one day Manufactured Housing Manager®, or MHM® professional property manager training and certification class. If you’re not yet ‘certified’, this is your unique and timely opportunity. And other special opportunities are being planned for this year.

• Frankly, there is/are no other sources for the directories and hard copy tools provided monthly by COBA7. For example: the ALLEN REPORT, State of the MHIndustry & LLLCommunities, National Registry of Lenders, ‘Who Ya Gonna Call in 2015 – directory of consultants, Official MH Lexicon, PM Training & Certification Directory, Industry Briefing Sheet (Best there is!), directory of national advocacy entities, only list of HUD-Code manufacturers in the U.S., annual Paradigm Shifts historical timeline, & directory of real estate brokerages.

• And the list goes on, to include: annual Networking Roundtable, periodic FOCUS Group gatherings, deal-making opportunities, even ombudsman (press) services!

Phone the aforementioned Official MHIndustry HOTLINE to affiliate, or request a COBA7® brochure listing all the above opportunities, services, products, and more.

Stop and think about it; this; there’s gotta be a very good reason why COBA7® happens to have the Official MHIndustry HOTLINE all to itself! It’s because, during the past 3 ½ decades, everyone in the MHBusiness has learned where to go for answers. Now it’s time for you to affiliate with COBA7® and become a key part of that special network of ‘MHInsiders’!


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