Updates to the HUD Code
MHI joined HUD Secretary Ben Carson as he announced updates to the HUD Code and released the final rule on formaldehyde emissions for manufactured homes. The announcements were made following his tour of Clayton’s Southern Homes manufactured home facility in Russellville, Alabama with state Governor Kay Ivey. MHI has been calling for these important updates and the announcement demonstrates that MHI’s advocacy efforts are resulting in impactful and tangible actions by HUD to improve the regulation of manufactured housing.
The changes to the HUD Code proposed include removing the requirement for manufacturers to follow the Alternative Construction (AC) approval process for add-on features, such as garages and carports. The proposed changes also address carbon monoxide detection, stairways, fire safety considerations for attached garages, draft stops and venting systems. The proposals will now go through a public review process before they are finalized. MHI will review the proposed changes and provide specific comments to HUD.
MHI has long called on HUD to make these updates to the HUD Code, serving as an effective and constructive voice at the Manufactured Housing Consensus Committee where these proposals were ultimately approved and forwarded to the Secretary. With respect to the AC process for add-ons, MHI’s strong advocacy efforts resulted in Congress directing HUD to review these requirements and “develop a solution that ensures the safety of consumers and minimizes costs and burdensome requirements on manufacturers and consumers.” Last May, HUD followed up on this directive by announcing that it would no longer require carport-ready home designs to go through the AC approval process.
While Secretary Carson’s announcement represents critical progress in clearing out the backlog of dozens of items that have been approved by the MHCC, but not incorporated into the HUD Code, MHI continues to urge HUD to implement a streamlined process for HUD Code updates so that changes can be made more regularly. MHI’s recommendation for expediting the code-making process was not only included in HUD’s Housing Finance Reform Proposal to President Trump but reiterated by FHA Commissioner Brian Montgomery in testimony at a recent House Financial Services Committee hearing. Montgomery stated that HUD is working to improve its internal processes to ensure regular, timely updates to HUD Code standards to keep pace with industry advancements in technology and construction.
In addition to the HUD Code changes announced, Secretary Carson also announced the finalization of HUD’s formaldehyde rule. This is an important development to align the HUD Code with Environmental Protection Agency regulations and eliminate the requirement that a formaldehyde emissions health notice be posted in each manufactured home. MHI has long advocated for the removal of this notice requirement, which is not required for site-built homes.
Secretary Carson also discussed HUD’s efforts to ensure manufactured housing is part of Opportunity Zone investment initiatives. Opportunity Zones are a new federal tool from the Tax Cuts and Jobs Act of 2017 intended to spur investment in certain financially disadvantaged communities and other lower income areas designated by the states. HUD has been working to identify actions it can take to encourage beneficial investment, both public and private, in Opportunity Zones. MHI has provided several recommendations to HUD for the successful utilization of manufactured housing in Opportunity Zones. In addition to addressing zoning and financing issues, MHI also urged HUD to promote new manufactured home plants in Opportunity Zones and also suggested that HUD collaborate with other federal agencies, such as the USDA, to promote manufactured housing in their rural housing programs. At MHI’s Open House on the National Mall in June 2019, Scott Turner, Executive Director of the White House Opportunity and Revitalization Council (the Council), expressed the Council’s eagerness to work with MHI and its members to ensure manufactured housing is a part of Opportunity Zone investments.
MHI commends Secretary Carson for his leadership in updating the HUD Code, aligning HUD formaldehyde regulations with EPA guidelines and working to alleviate regulatory barriers to manufactured housing at all levels of government. Keeping the manufactured housing construction code up to date is critical for ensuring the industry can efficiently produce homes with innovative features and amenities consumers want. We appreciate Secretary Carson’s support and for recognizing the quality, value and affordability that manufactured homes offer.
MHI will continue to serve as the industry’s advocate, and work with HUD, the Administration, policy makers and others to support manufactured housing. If you have any questions, please email MHI at firstname.lastname@example.org.