Although it seems odd to be discussing frost during this summer’s heat wave, I wanted to first off thank all the community owners who recently submitted comments to HUD on the proposed model installation standard, which would require all footings to be below the frost line unless a monolithic slab is used. This single provision of the standard, which was not recommended by the Manufactured Housing Consensus Committee, was inserted by HUD just prior to the proposed standard being published. The MHI National Communities Council has raised vigorous objections to this provision, which were included in the official MHI comments to HUD on the proposal.

Why is this provision so alarming? For one thing, it could add from $3,000 to $6,000 per community installation. Community owners are already struggling to remain competitive in the marketplace. We don’t need HUD pricing us right out of the market. In addition, while the standard would take effect in the states that have not enacted their own installation standard (the “default” states), it will also pose a challenge for those that do and seek approval from HUD. State standards must meet or exceed the HUD model, so approval of existing state standards could be in jeopardy.

In its comments to HUD, MHI has strongly recommended additional installation options, such as insulated skirting, which would protect against frost heave but yet not dramatically impact the cost of installations. In order to maintain the affordability of our homes, HUD must make changes from its proposal and the NCC will continue to press for modification of the proposed standards using every avenue possible. We appreciate the support community owners across the country have given to this effort.

On another note, I’m pleased to report that implementation of the MHI Community Attributes System (CAS) is going smoothly. The CAS collects a uniform set of over 75 objective attributes about a community without making bottom-line judgments and is designed to improve and increase lending in manufactured home communities and rid the industry of the subject rating systems currently being employed.

I have entered information on my own communities and can report that the system is user-friendly and there is no cost to the community owner. As the system is opened up to lenders and appraisers to access reports, I would like to strongly encourage you to take the time now to enter the information on your community at www.mhicas.org. Once you’ve entered the initial information, it will just be a matter of updating in the future. I also encourage you to give feedback on the system as you use it, so we can strive to improve it as it grows and evolves. The CAS will only be successful if everyone participates. We don’t want to go back to the old way of doing things, so your support is key.

As always, feel free to contact me with your thoughts and concerns at nsmith@sskcommunities.com

Nathan Smith, PHC
Partner, SSK Communities
Chairman, MHI National Communities Council