The Federal Register & You; Maybe….!
Blog # 452; Copyright @ 25 June 2017; at community-investor.com/blog
Perspective: ‘Land lease communities’, previously manufactured home communities, & ‘mobile home parks’, comprise the real estate component of manufactured housing.
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INTRODUCTION: The Federal Register, for many of us, does not make for engaging reading. However, it oft contains important information about our industry (i.e. manufactured housing), and other matters. Then there’s Part II. Sure hope you plan to participate on one or the other of the two upcoming land lease community-specific options: Think Tank and or interpersonal networking & superb educational opportunity.
The Federal Register & You; Maybe…!
‘HUD’s Interpretative Bulletin for Model Manufactured Home Installation Standards Foundation Requirements in Freezing Temperature Areas Under 24 CFR 3285.312(b)’
Docket No. FR-6023-N-01
Pay attention to the above Docket No. You’ll need it, for reference purposes, if/when you ‘comment’ on HUD’s Interpretative Bulletin for Model Manufactured Home Installation Standards Foundation Requirements in Freezing Temperature Areas’.
Well, here’re my initial observations regarding some content of this bulletin, along with a special, even sage one, from a highly-respected ‘manufactured housing installation specialist’
• Land lease community specific? In my opinion, ‘Yes & No’. Here goes: “The purpose of this proposed Interpretative Bulletin (‘IB’) is to provide guidance for designing and installing manufactured home foundations in areas subject to freezing temperatures with seasonal ground freezing, in accordance with the Model Manufactured Home Installation Standards, wherever soil conditions are susceptible to frost heave” & “”when footings do not extend below the frost depth at the site.” Observation: This clearly affects raw land developed as building sites conveyed fee simple, and (maybe) rental homesites in land lease communities being readied for new HUD-Code manufactured homes. But no requirement to retrofit existing foundation systems under existing homes in either instance. For that matter, there is no specific mention of land lease communities (a.k.a. manufactured home communities) – that I saw – in this IB.
• What types of foundations systems? “Monolithic slab systems, ‘frost protected shallow foundations’ (‘FPSF’), and alternative foundation systems”, e.g. frost free foundations (‘FFF’). Observation: While some have disparaged FFF, in the recent past, this IB provides additional guidance for “installing manufactured home foundations, when non-frost susceptible soil conditions are available at the site to protect foundations against the effects of frost heave.” That reads to me like FFF remains ‘good to go’, when appropriate site drainage and foundation skirting measures are in place. Effectively making the area under such a protected home: of non-frost susceptible soil condition.
• But wait; the IB cites an SEBA Professional Services ‘assessment of design & installation practices’ report for manufactured homes in climates with seasonally frozen ground. (Some have criticized SEBA’s lone ranger, i.e. single engineer, preparation of this report). In any event, the “…report found some key factors needed for long-term and consistent success require special considerations that are often neglected, particularly for FFF designs and installations….” Said considerations are described later in the IB. Observation. Perhaps the manufactured housing industry (i.e. its’ housing manufacturers) should bear responsibility for some of the neglected considerations. How so? Installation Manuals required to accompany all new HUD-Code homes, in many cases (that I’ve seen), are often deficient in definition and description of FFF installation design and construction.
• The target audience for this IB? The Manufactured Housing Consensus Committee (‘MHCC’) recommended this IB target these audiences: installers, local jurisdiction, regulators, and manufacturers. HUD agreed. Observation: Should land lease community (a.k.a. manufactured home community) owners/operators take faint comfort in not being specifically named in this report? For that matter, the unique, income-producing property type is nowhere, in the IB, mentioned by any name, description, or any other means. Makes one wonder, a bit, about the role private (real) property rights might be playing here….Later, in this IB, there’s this statement: “Retailers should verify that the installations are performed only by licensed installers.” Observation: Hmm. ‘retailers’ , like land lease community’ owners/operators, are not identified as a target audience. So, are these two omissions accidental or purposeful omissions – hence potential loopholes, for two segments of the manufactured housing industry, relative to enforcement of requirements set forth in this IB?
• Are you an FFF aficionado? Then you should be interested in the ‘flaws or non-conformances’ identified in the aforementioned SEBA report: “a lack of clarity of technical requirements in manufacturer installation instructions, details, & notes” & “Missing or vague criteria for identification and measurement of soil frost susceptibility” & “Missing or vague guidance for determining soil moisture, sub-surface drainage conditions; and water table depth…” & “Missing guidance to direct appropriate site specific adjustments of important installation details….” Observation: If you’re going to use the far more economical FFF, ‘Get it Right’!
• Lest you think I strain at making the case for this IB being ‘not applicable’ to retailers and land lease community folk, read this from the Summary of said document: “…all responsible parties in the process should follow the guidance in this Interpretative Bulletin. These concerns and issues involve designers, DAPIAs, (presumably ‘housing’) manufacturers, installers, and regulatory authorities.” Observation: Nary a retailer or land lease community mention to be found.
• Now for that promised sage observation from a highly-respected manufactured housing installation specialist’: “I do not believe…HUD and …..(its’ employees) understand ‘ice 101′. And how “You need water”, to have ice under a manufactured home! Here’s an apt analogy: When pouring a monolithic slab, one is not required to effect the investigations described in this IB. Well, a manufactured home either on a rental homesite or a building site conveyed fee simple, is a slab in its’ own right, as it ‘covers the soil’ & = ‘No Ice!’
• Well, if you too would like to prepare a comment letter, relative to this IB, suggest you obtain a copy via (202) 708-6409. Then, read it for yourself, before penning your correspondence. You have until 21 August 2016 deadline to get your communiqué to HUD via: Regulations Division, Office of General Counsel, Dept. of Housing & Urban Development, 451 Seventh Street SW, Washington, DC. 3\20410-0500. Important REMINDER: Comment letter must reference this docket number & title: Docket No. FR-6023-N-01 & ‘Interpretative Bulleting for Model Manufactured Home Installation Standards Foundation Requirements in Freezing Temperature Areas Under 24 CFR 3285.312(b)
In little more than a month’s time, 7 August, to be exact, nearly 700 RV & MH pioneers and leaders are expected to gather at the RV/MH Heritage Foundation’s Museum, & Library to induct ten of our colleagues into the prestigious RV/ MH Hall of Fame! Will you be present? I sure will. Here’s the number to call to purchase tickets (574) 293-2344.
And earlier the same day, same location (21565 Executive Parkway, Elkhart, IN.), 7 August, from 9-11 AM, a dozen or two land lease community owners/operators will gather for an MHAlive! Think Tank session. Manufactured housing industry ‘concerned parties’ are welcome as well! There’s no fee to attend, but you must pre-register by phoning (317) 346-7156 or send an email to firstname.lastname@example.org. Why? Because we’ll soon mail a comprehensive list of manufactured housing-related issues that have been collected from businessmen and women, during an Input Session in Chicago, last month.
In little more than two month’s time, 6-8 September to be exact, 200+/- land lease community owners/operators will convene at The Alexander Hotel in Indianapolis, IN., for the 26th annual Networking Roundtable. Event brochures are available for the asking (see previous paragraph for contacts). For several reasons, this promises to be one special MHIndustry & LLCommunity event! An MHM class will be conducted on the 6th, as well as a completely redesigned Investors Symposium, from 4-6PM. And during the next two days? Chock full education sessions and nine unparalleled interpersonal networking F&B (food & beverage) events! And if all goes to plan, everyone present will receive the gift of a new book: SWAN SONG, subtitled: ‘George Allen’s History of the Land Lease Community Realty Asset Class, from 1970 to 2017, & Manufactured Housing Shipment History from 1955 thru 2016’. How can you not want to be present for this special celebration of National Land Lease Community Week?! For an agenda, see the Networking Brochure attached to this blog posting.
George Allen, CPM & MHM
Box # 47024, Indianapolis, IN. 46247