Manufactured Housing Institute Issues Public Comment on FEMA Notice

WASHINGTON, Jan. 29 -- Lesli Gooch, CEO of the Manufactured Housing Institute, Arlington, Virginia, has issued a public comment on the Federal Emergency Management Agency notice entitled "Request for Information on the National Flood Insurance Program's Floodplain Management Standards for Land Management and Use, and an Assessment of the Program's Impact on Threatened and Endangered Species and Their Habitats". The comment was written and posted on Jan. 26, 2022:

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The Manufactured Housing Institute (MHI) is pleased to submit comments in response to the Federal Emergency Management Agency's (FEMA) request for information about the National Flood Insurance Program's (NFIP) Floodplain Management Standards.

MHI is the only national trade association representing all segments of the factory-built housing industry. MHI members include manufactured home builders, lenders, home retailers, community owners and managers, suppliers and others serving or affiliated with the industry, as well as 48 affiliated state organizations. In 2020, our industry produced nearly 95,000 new homes, accounting for approximately nine percent of new single-family home starts. These homes are produced by 33 U.S. corporations in 138 plants located across the country. MHI members are responsible for close to 85 percent of manufactured homes produced each year.

Manufactured housing is the largest form of unsubsidized affordable housing in the U.S. and the only type of housing built to a federal construction and safety standard (i.e., the HUD Code) regulated by the Department of Housing and Urban Development (HUD). The HUD Code's single regulatory framework for home design and construction includes standards for health, safety, energy efficiency, and durability. It is also the only type of housing that Congress recognizes as having a vital role in meeting America's housing needs as a significant source for affordable homeownership accessible to all Americans. Today, 22 million people live in manufactured housing and the industry employs tens of thousands of Americans nationwide.

Currently, the NFIP standards treat manufactured homes differently than site-built homes. The required flood elevation of site-built homes is currently allowed to be measured from the bottom of the lowest floor, while for manufactured homes, it is measured from the bottom of the I-beam. The space between the I-beam and the lowest floor is generally used for insulation and some ductwork and would be inexpensive to replace versus the cost of the extra elevation of the home (See Appendix A). Making this standard consistent for site-built and manufactured homes would help these properties meet the Base Flood Elevation (BFE) requirements. Communities should not discriminate between type of constriction. Freeboard credit should be awarded for policies that affect all residential dwellings. No distinction should be made between a manufactured home located in manufactured home community or a manufactured home or conventional site-built home located on private property.

The Administration recently published an initiative to increase the supply of affordable housing by boosting the supply of manufactured housing."/1

In their Fact Sheet, the White House stated that "While the federal government has a critical role to play in boosting the supply of affordable homes, state and local governments often play the primary role in setting policies that encourage - or in some cases, discourage - boosting housing supply. One of the most persistent factors depressing the supply of housing, especially entry-level and rental units, is exclusionary zoning laws and practices, like minimum lot size requirements, minimum square footage requirements, unnecessary parking requirements, prohibitions on or differing treatment for multi-family homes, accessory dwelling units, and manufactured housing." FEMA should not enact rules and regulations that limit access to manufactured homes or eliminate the ability to place these affordable homes in those few areas that are currently zoned for manufactured housing.

Manufactured homes offer affordable housing options that are resilient and efficient and can help address the shortage of affordable housing in the country, while mitigating and managing climate and natural disaster risk on our nation's affordable housing system. The NFIP guidelines should not hold manufactured homes to a higher standard (and elevation) than site-built homes. The Administration has placed a significant focus on climate change and resilience. Today's manufactured homes provide both resiliency and affordability. Limiting the ability to replace mobile homes with new, safe, durable manufactured homes only places families in danger. Manufactured homes can also contribute significantly to solving our nation's affordable housing crisis. MHI urges FEMA to make the elevation floor the same for site-built and manufactured homes; by doing so it would help these properties meet the BFE requirements.

View attachment at https://downloads.regulations.gov/FEMA-2021-0024-0232/attachment_1.pdf

Sincerely,

Lesli Gooch, Ph.D.

Chief Executive Officer

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Footnote:

1/ FACT SHEET: Biden-Harris Administration Announces Immediate Steps to Increase Affordable Housing Supply, https://www.whitehouse.gov/briefing-room/statements-releases/2021/09/01/fact-sheet-biden-harris-administrationannounces-immediate-steps-to-increase-affordable-housing-supply/, September 1, 2021

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The notice can be viewed at https://www.regulations.gov/document/FEMA-2021-0024-0001

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