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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Update:2011 Tornado Season

Three weeks ago we had an extensive discussion of the relationship between tornado fatalities and manufactured housing (see Many of These Are Preventable Deaths, 4/28).  At that point in time, the National Weather Service had not yet examined the string of tornadoes that blew through the South on that day.

The data is still coming in, but as of today, the National Weather Service has analyzed 112 of the 309 deaths attributed to the April 27-28 storms.  Sixty-three, or 56%, of the tornado fatalities examined occurred in manufactured or mobile housing.

More Blogosphere/Press discussion on this topic:

5/16 discussion update:

Many of These Are Preventable Deaths

“Spalding County reports two fatalities. Officials say the severe storms tore a mobile home from its foundation and tossed it nearly 500 feet. The two victims — a male and a female — were found near the mobile home.” – MyFox Atlanta

“One of the hardest hit by overnight storms is Halifax County, where one person died and seven others have been confirmed injured. […] Her niece, 52-year-old Shirleen Howard, didn’t survive. Her mobile home flew about 50 yards, landing in the middle of the road.” – WSET-TV Virgina

“Concrete steps lead to remains of a tornado demolished mobile home in Preston, Miss., Wednesday, April 27, 2011. The home and one next to it were blown about 100 feet away into a cow pasture. Three related women died at the site.” -AP

A year ago we noted here at Texas Housers that of 479 tornado-related deaths from 2002 to 2009, 249, or 52% of the deaths, occurred in mobile homes.  As of yesterday, 33 of the 51 tornado deaths this year occurred in mobile homes.  (NOAA-confirmed information on the impact this morning’s storms won’t be available for several days.)  A recent book, “Economic and Societal Impacts of Tornadoes,” calculates that people are 10 times more likely to die in a mobile home than in a regular house during a tornado.

Why does this happen to mobile/manufactured homes?  Three factors- Anchoring, Construction, and Density.  Each of these factors suggests action our society could (and should!) take to prevent these deaths in the future.

Anchoring – a mobile (or manufactured) home is built in a factory and then installed on the home site.  While manufactured homes can be placed on a permanent, poured concrete foundation, they are often attached to the ground with metal straps.  A recent report by the Texas Sunset Commission found that 15% of Manufactured home installations inspected in Texas had some type of ‘deviation’ from the state’s installation standards.  Despite the fact that 15% (1 out of every 7!) installations had a problem, the state was successfully inspecting only about 40% of installations, and has a statutory requirement to inspect only a 25%.

Action Society Could Take: The weak link of high-wind home safety is a poorly tied-down home, and inspecting all homes is necessary to insure the integrity of home anchors.

Construction.  After Hurricane Andrew destroyed 97% of the manufactured homes in its path, the wind construction standards for manufactured homes were increased.  Nevertheless, the improvements focused primarily on manufactured homes installed in hurricane-prone coastal areas.  Manufactured homes installed inland, where many tornado deaths occur, are built to inferior standards.  On top of that, despite significant changes in conventional construction standards, (The latest wind load design standards for conventional construction, ASCE 7, was adopted in 2010.) wind standards for manufactured homes have not been updated in almost two decades and are based on ASCE standards from the late 80s.  This has no prospect of changing any time soon: A HUD taskforce developing a proposal to update the wind standards for new manufactured homes has decided not to address inland standards, despite their obsolescence.

Action Society Could Take:  Adopt wind-load standards for manufactured homes (both those installed inland and on the coast) equivalent to conventional homes, and regularly update the standards to reflect the latest science on wind-load and construction.

Density: An improperly installed home that fails in a high-wind event such as tornado endangers the homes around it, especially in high-density manufactured home parks.  The National Hurricane Center reports: “debris from the damaged or destroyed homes will become missiles that have the potential to substantially damage other units…”  In short, the density of mobile homes parks contributes to the danger of tornadoes.

Action Society Could Take:  Homeowners have little leverage to ensure that their neighbors’ homes are properly installed and won’t become “missiles” in the next storm.  But park owners do.  Requiring park owners to perform regular assessments of the wind-stability of the anchors of homes in their park would reduce the danger to the community of a poorly installed home.  Requiring community tornado shelters and audible tornado-watch warnings in large, high-density parks would also reduce this risk.

Poorly constructed housing and residential environments are magnifiers of ‘natural disasters’.  As the death toll rises from these storms, remember while these storms are ‘natural’, the deaths aren’t.

We’ve just listed three things society can do to prevent them.

Will we?

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.

Recap of Sunset Commission Recommendations for TDHCA

Last week the Texas sunset commission adopted its final recommendations regarding the Texas Department of Housing and Community Affairs (TDHCA).  Burying its lead, the final recommendation adopted was to continue the department for another 12 years, recognizing the improvements since the last full sunset review in 2000.

A detailed recap of the full recommendations is after the jump:

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