Problems Found with Accessibility Modifications to Smith County Manufactured Home

KLTV reports that a Habitat for Humanity of Smith County is facing criticism over home accessibility modification work done through its “Rehabitat” program.  ReHabitat helps low-income seniors and low-income individuals with disabilities with emergency home repairs and modifications.

According to the KLTV, a man in Smith County asked Habitat to make his manufactured home scooter-accessible, but the quality of the construction prompted him to complain to the Texas Department of Housing and Community Affairs.

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Increasing Minimum Entry Door Width in Manufactured Housing

TxLIHIS recently submitted Comments to the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee to HUD on the regulation of manufactured housing, regarding its review of the minimum exterior door and interior hallway widths allowed in the building code for such homes.  These comments follow:

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April 8, 2011

Mark J. Mazz, AIA

General Subcommittee Chair, MHCC

Via Email.

RE: Comments on MHCC Log items #2, #3, #11, related to increasing the minimum width of exterior doors and interior hallways of HUD-code homes.

Dear Mr. Mazz:

The Texas Low Income Housing Information Service has compiled the following analysis and commentary related to the minimum width of entry doors and interior hallways of manufactured homes built to the HUD code.  We submit this information for consideration by the Manufactured Housing Consensus Committee (MHCC) during its evaluation of log items #2, #3, and #14.

1) Currently, the HUD-code allows for exterior door and interior hallways (“passageways”) to be as narrow as 28-inches, significantly narrower than the minimum width requirements of the International Residential Code, a building code commonly adopted by localities to regulate site-built housing.  A 28-inch passageway prevents entry and use by people with disabilities who rely upon the use of mobility aids such as wheelchairs.

2) Data from the American Housing Survey indicates 13% of MH units contain at least one person that has a “serious difficulty walking or climbing stairs.”  This rate of walking disability is higher than the rate of 9% in the nation’s house stock as a whole.  Residents who “age in place” in their homes have an higher chance of having, or living with someone with, a walking disability: 21% of MH households who have lived in their unit for 10 years or more include someone with a walking disability.[1]

3) The HUD-code and initial design approval only addresses the initial, in factory, construction, complicating post-construction modifications widen doorways or interior hallways.  While these modification must technically be made to local codes, the impact of these modifications to the health and safety standards (such as wind resistance) addressed by the HUD code are unlikely to be evaluated at the time of modification.  Many companies specializing in accessibility remodeling avoid working on manufactured homes due to their non-conventional construction.[2]

4) Post-construction modifications to widen doors are significantly more expensive than incorporating wider passageways in the initial design and construction.  While the production cost of increasing door width is negligible,[3] invoice data from the Amy Young Barrier Removal Program, a Texas home-modification program addressing the accessibility needs of low-income Texans, documents a cost of over slightly over $1000 per door to widen exterior doors on a manufactured home.[4]

5) Giving consumers “the choice” of inaccessible doors and hallways effectively increases the end-cost to consumers of more accessible design in the retail process.  This is due to “versioning,” a marketing technique that uses any consumer choice opportunity to extract additional value from consumers.[5] Under versioning, retailers may offer a less-accessible door solely to justify increasing the markup on more-accessible options.  This appears to occur in manufactured home sales today: While the difference in production cost to increase the entry door width is negligible,[6] a retailer gave us a $300-500 quote for this “upgrade.”[7]

6) Design limitations on the ability of residents to age in place increases lifetime healthcare costs to the purchaser and, thorough Medicaid, state and federal governments.  Community Based Care provides home-based services and supports for older people and those who have disabilities, and costs, on average, $51.30 per day in Texas.  For those who cannot age in place in their homes, perhaps due to inaccessible design, Nursing Home care costs, on average, $127.14 per day in Texas.  This is an increase of $75.84 per day.[8]

7) Maintaining 28-inch doors and hallways in the HUD-code encourages the manufacture of homes designed to exclude use by a significant portion of the US population.  Building codes address the fact that a building is a durable good that must anticipate use over the life of the building.  Not only does narrow entry and interior passage negatively impact the changing needs of the first purchaser of the home[9] and exclude potential visitors to the home, such design inherently limits the housing choice of disabled Americans who wish to buy a used manufactured home.  HUD has a responsibility, under Executive Order 12892, to administer its programs and activities (including its “exercise of regulatory responsibility”) to affirmatively further fair housing.  28-inch entry doors and interior hallways are an impediment to housing choice for people with disabilities, and HUD has a responsibility to take action to address this impediment.

Based on the facts and analysis above, the Texas Low Income Housing Information Service strongly encourages HUD and the MHCC to adopt proposals to increase the minimum width of the passageways of Manufactured Homes built under the HUD code.

Sincerely,

Kevin Jewell


[1] 2009 American Housing Survey, Disability Supplemental.

[2] Interview with Larry Williams of OnCall Remodeling by Elizabeth Nowrouz.

[3] Author’s communication with Richard C. Duncan, MRP, Executive Director, RL Mace Universal Design Institute.

[4] In response to our request under the Texas Public Information Act, The Texas Department of Community Affairs released a document detailing the cost of modifying a manufactured home under the Amy Young Barrier Removal Program for an elderly person with a disability in 2010. The modifications removed the front door, widened the doorway to accommodate for accessible door, installed a new door and adjusted a view-hole at a custom height for the owner. The crew also widened the back doorway, installed a new door and a custom view-hole.  The total cost for this modification was $2200.  Gordon Anderson, the public information officer at TDHCA, stated this invoice is a good representation of the standard cost of such a modification.

[5] Marketing studies find sellers can charge a consumer more for something they “choose,” even when it doesn’t cost more to produce.  See, for example, the discussion of software pricing in: Shaprio and Varian, “Information Rules” chp. 2-3, Harvard Business Press. 1999.

[6] Author’s communication with Richard C. Duncan, MRP, Executive Director, RL Mace Universal Design Institute.

[7] Communication with Palm Harbor Retailer by Elizabeth Nowrouz.

[8] Texas Department of Aging and Disability Services (DADS), “Reference Guide 2011,” pg. 33, 68. Internet Source: http://cfoweb.dads.state.tx.us/ReferenceGuide/guides/FY11ReferenceGuide.pdf

[9] An AARP survey indicates almost 90 percent of adults 50+ would prefer to stay in their homes as long as possible. Internet Source: http://assets.aarp.org/rgcenter/ppi/liv-com/fs167-expanding-implementation.pdf

Manufactured homes, mobile homes, and trailers, oh my!

While many readers were tracking the exciting housing bills popping in the mad-end-of-bill-filing rush in the Texas Legislature last week, I was in DC attending the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee to HUD on the regulation of manufactured housing.

I’ll keep most of the exciting details of parliamentary intrigue and interpersonal conflict to myself, but I want to highlight three items on the MHCC agenda that should be of interest to anyone who lives in a manufactured home, lives near someone in a manufactured home, or cares about the folks who will be buying a manufactured home in the future:

The first, and probably least glamorous, was a recommendation to HUD to adopt a specific set of national procedures to test ground anchors.  Ground anchors are what hold manufactured homes to the ground, and in high wind events like hurricanes and tornadoes, the failure of a ground anchor can lead to extensive death and property damage.  Over half of the 10,000 manufactured homes destroyed in Hurricane Andrew had tie down or anchor failure.  Apparently, HUD has been attempting to develop these testing procedures for the last 20 years.

The second was a continuation of a discussion related to the interaction of local fire sprinkler requirements and the manufactured home code.   No action was taken, but a subcommittee chair will be aggregating fire safety data related to manufactured home for further debate.  Recently Ocean City Maryland explicitly extended their single-family fire sprinkler requirements to manufactured homes, and under my read, the industry is reacting by looking for ways to exempt manufactured homes from such requirements.

The third major issue relates to the accessibility of manufactured homes.  The building code for manufactured homes allows for the front door and interior hallways to be only 28 inches wide, significantly narrower than the width requirements in the International Residential Code governing most conventionally built housing.  Such design prevents entry and use by many mobility-impaired persons.

Over the next 60 days, a MHCC will be gathering information related to both the costs to manufacturers of such a code change and the costs to residents and visitors of not changing the design.  Contact me if you have information you believe should be considered by the committee on this issue.

Improving Manufactured Homes, One Tabled Proposal at a Time.

I spent much of last week in DC at the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee to HUD regarding the regulation of manufactured housing.*

The MHCC was created through a bill passed in 2000.  (“The Manufactured Housing Improvement Act.”)  One task the committee performs is to consider public suggestions for changes to HUD’s regulation of manufactured housing.

For context, things do not move quickly in this august body, which operates under Roberts Rules of Order.  In the October 2010 meeting the committee tabled (not for the first time) the first public suggestion it ever received for consideration (probably back in 2002 or so), regarding a testing protocol for Manufactured Home anchoring systems.

In my opinion, the committee is better at holding things up than getting things done.  The committee is comprised substantially of industry representatives, and my perception is that their goal is to use the committee to delay or kill new regulations for the manufactured home industry.

Two highlights from the last meeting:

Preemption of Local Fire Sprinkler Requirements:

Under current law and HUD rules, if a locality requires fire sprinklers in single family dwellings, they are required in manufactured homes.  As more localities adopt the 2010 International Residential Code (which requires fire sprinklers in single family dwellings), such requirements are becoming more common.

My perception is that many manufactured home manufacturers would like to be exempted from such safety requirements.  (I guess this follows the previously noted industry logic that manufactured homes aren’t dwellings.)  This topic precipitated a discussion of fires in manufactured homes, in which an industry lobbyist quoted, apparently as proof of manufactured home safety, a 2004 USFA report stating that deaths in manufactured homes have fallen dramatically (57%!) since 1976, (the date at which manufactured homes were first subjected to a federal building code).

Unfortunately, the lobbyist forgot to mention (inadvertently, I’m sure) data from that same report which indicated that the per-fire death rate in manufactured homes remains twice that of conventional housing.  He also skipped over data elsewhere (but from the same source) indicating manufactured homes have a fire death rate per 100,000 housing units 32-50 percent higher than the rate for other dwellings.**

The fire sprinkler issue was sent to a subcommittee for further review.

Wheelchair and Walker Accessibility:

Have you bought a washer/dryer recently?  Ever noticed some of them have a sticker saying something along the lines “suitable for use in a manufactured home”?

Why do they need this sticker?  Well, the building code for manufactured homes only requires a 28-inch entry door, and many regular-sized appliances won’t fit.

Besides being a pain for finding usable appliances, this twenty-eight inch door standard is a barrier to the accessibility of manufactured homes for people with disabilities.  For those keeping track, twenty-eight inches is four inches smaller than the thirty-two inch door clearance called for under the Uniform Federal Accessibility Standards, and eight inches smaller than a standard front door.

A proposal to increase the minimum size of manufactured home entry doors has been pending before the committee for several years.  In this meeting, the committee took the bold action of sending the proposal back to an informal task-force for further consideration.  On the upside, the task force will also be considering requiring an increase in the minimum width of access to one bathroom and one bedroom in each manufactured home unit.

That’s about it for the meeting highlights.  If this blog post interested you, I’ve got good news for you: there are two empty consumer seats on the MHCC.  If you apply now, you might be able join me for the spring 2011 meeting.

*You probably call them mobile homes or trailers.  (But not RVs—those considered cars.)

** To be fair, other sources indicate that while more people die per-fire in manufactured homes, there are fewer fires, so the death rate per-home is comparable between manufactured and conventionally constructed homes.

Home builders object and Austin backs away from housing visitability requirements

Housing protestJune 18 was not an auspicious day in Austin housing rights history.

Shortly before voting to adopt the anemic affordable housing PUD ordnance I describe at length in the previous posting, the Austin City Council gutted an already weakened proposal offered by retiring Mayor Pro Tem Betty Dunkerly to require that new houses in Austin be constructed in a manner to be “visitable” by people with disabilities.

The goals of the “visitability” movement is simple: to ensure that a person with a disability can visit a home, use a restroom in a newly built home and ensure new homes are designed to able to be modified in the future at a reasonable cost to accommodate a permanent elderly or disabled resident.

A person using a walker or wheelchair should be able to:

  • enter a home
  • fit through the interior doors, and
  • be able to use a toilet.

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