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Friday,

October 19, 2007

Part II

Department of
Housing and Urban
Development
24 CFR Parts 3280 and 3285
Model Manufactured Home Installation
Standards; Final Rule
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DEPARTMENT OF HOUSING AND SUPPLEMENTARY INFORMATION: proposed definition of anchoring system


URBAN DEVELOPMENT should include forces on the foundation
I. Background
and anchorage systems, which may
24 CFR Parts 3280 and 3285 On April 26, 2005, HUD published in actually control the design in some
the Federal Register at 70 FR 21498 a instances.
[Docket No. FR–4928–F–02]
proposed rule that would establish HUD Response: The definition of
RIN 2502–AI25 Model Manufactured Home Installation anchoring system includes a reference
Standards (Model Installation to the forces that are required to be
Model Manufactured Home Installation Standards) for new manufactured resisted by foundation and anchorage
Standards homes, as required by the National systems.
AGENCY: Office of the Assistant Manufacture Housing Construction and
Safety Standards Act of 1974 (42 U.S.C. II.B. Analysis of Public Comments—
Secretary for Housing—Federal Housing Part 3285
Commissioner, HUD. 5401–5426) (the Act). The Act gave the
MHCC responsibility to develop and Subpart A—General
ACTION: Final rule.
submit to the Secretary proposed Model
Installation Standards. The MHCC’s Comment: § 3285.1(a) Scope. The
SUMMARY: This final rule establishes Model Installation Standards should be
new Model Manufactured Home proposal was provided to HUD in
September 2004. The Department agreed preemptive of state and local
Installation Standards (Model requirements.
Installation Standards) for the with most of the proposal, and
thoroughly involved the MHCC in the HUD Response: HUD has concluded
installation of new manufactured homes that a plain reading of Sections 604(d)
and includes standards for the process by which the proposed rule for
the Model Installation Standards was and 605 of the Act indicates that
completion of certain aspects necessary Congress did not intend for these Model
to join all sections of multi-section developed prior to its publication in the
Federal Register. Installation Standards to be preemptive
homes. The National Manufactured of more stringent state or local
Housing Construction and Safety There were a total of 101 commenters
on the April 26, 2005, proposed rule. government requirements, only that
Standards Act of 1974 requires HUD to they establish minimum national
develop and establish Model Seventy-seven of the commenters were
from the industry, including requirements for the installation of
Installation Standards after receiving manufactured homes. This conclusion is
proposed installation standards from the manufacturers, component suppliers,
retailers, installers, realtors, trade strengthened by the statement from
Manufactured Housing Consensus then-Chairman Jim Leach during his
Committee (MHCC). HUD received and associations, and community operators.
Nineteen commenters came from the section-by-section comments on the
reviewed the MHCC’s recommended floor of the House, that ‘‘the bill would
proposed model installation standards government, including HUD-approved
Primary Inspection Agencies and State reinforce the proposition that
and published a proposed rule for installation standards and regulations
public comment. Based on HUD’s Administrative Agencies. Finally, four
commenters were individual consumers remain under the exclusive authority of
review of the comments that were each state.’’ (Dec. 5, 2000, 146 Cong.
submitted, including those from the and consumer groups and one was a
private code organization. Rec. H11987). In earlier floor remarks,
MHCC, a number of revisions to the then-Ranking Member John LaFalce
Among the recommendations most
proposed rule have been made in this said, ‘‘States that wish to have their own
often made by the commenters were: (1)
final rule. This final rule also installation standards may continue to
To codify the Model Installation
incorporates certain amendments to do so, as long as they provide
Standards in existing part 3280 rather
definitions contained in the protections comparable to the model
than new part 3285, in the belief that
Manufactured Home Construction and standards.’’ (Oct. 24, 2000, 146 Cong.
the installation standards would thereby
Safety Standards (MHCSS) that are Rec. H10685). HUD therefore believes
become ‘‘preemptive’’ of state and local
affected by definitions provided in the that Congress has permitted any state
installation standards; (2) to make the
Model Installation Standards. that chooses to operate its own
installation standards applicable to
DATES: Effective Date: The effective date secondary or other subsequent installation program to enforce
for this final rule will be October 20, installations of manufactured homes; (3) installation standards more stringent
2008. The date of approval by the to include provisions assuring that HUD than these Model Installation Standards,
Director of the Federal Register for will consult with the MHCC on future provided that those standards otherwise
incorporation by reference of certain changes to the installation standards; (4) offer protection that equals or exceeds
publications listed in this rule is that manufacturers’ installation the minimum protection established by
October 20, 2008. instructions be considered as evidence these Model Installation Standards.
FOR FURTHER INFORMATION CONTACT: of compliance with the Model Comment: § 3285.1(a) Scope. The
William W. Matchneer III, Associate Installation Standards; (5) that the Model Installation Standards should be
Deputy Assistant Secretary for installation standards apply to the codified under 24 CFR part 3280,
Regulatory Affairs and Manufactured joining together and close-up of multi- Manufactured Home Construction and
Housing, Office of Manufactured section homes and to certain other Safety Standards.
Housing Programs, Department of aspects of on-site completion that HUD HUD Response: Contrary to the views
Housing and Urban Development, 451 had originally treated as part of the expressed by some commenters,
Seventh Street, SW., Room 9164, construction process. HUD has given preemption authority can only come
Washington, DC 20410; telephone these subjects particular attention in from Congress, and no decision that
number (202) 708–6401 (this is not a preparing the final rule. HUD could make regarding the
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toll-free number). Hearing-or speech- codification of these Model Installation


impaired individuals may access this II.A. Analysis of Public Comments— Standards could increase or diminish
number through TTY by calling the toll- Part 3280 that authority. However, as indicated
free Federal Information Relay Service Comment: § 3280.302 Definitions. above, HUD believes there is good
at (800) 877–8339. Two commenters wrote that the reason to conclude that Congress did

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not intend to extend preemption In early drafts of these Model Comment: § 3285.1(a) Scope. The
authority to these Model Installation Installation Standards, HUD treated all Model Installation Standards should be
Standards. activities associated with close-up as applicable to subsequent installations
In any event, HUD has chosen, as a part of construction of the home and, as beyond the initial siting and placement
matter of administrative necessity, to such, subject to the MHCSS and the of the manufactured home.
codify these Model Installation manufacturer’s certification label. HUD Response: It is HUD’s position
Standards, as in new part 3285 of 24 However, HUD recognizes that that Congress intended the installation
CFR, in order to maintain the clear installers, not manufacturers, typically standards to be applicable only to the
distinctions the Act makes between perform close-up work. Therefore, HUD initial installation of new manufactured
installation and construction. The has concluded that the Model homes, as indicated by references in
regulatory structure that Congress has Installation Standards provide the best Section 623(g) of the Act to the date of
given HUD for enforcement of these opportunity to address close-up installation and by the definition of
Model Installation Standards is entirely activities and concerns. ‘‘purchaser’’ as the first purchaser in
different from the enforcement authority Further, under the final rule, home Section 603 of the Act. A very small
it previously gave HUD for the federal purchasers generally will look to percentage of manufactured homes are
MHCSS. As HUD reads the Act, section installers or retailers who often employ ever relocated after the initial siting and
613 (42 U.S.C. 5412) and section 615 (42 or contract with installers to perform placement of the homes. The
U.S.C. 5414), the principal sections home installations, to remedy close-up Manufactured Home Procedural and
requiring notification and correction of problems that are not the result of Enforcement Regulations encourage
defects, do not apply to these Model inadequate or incorrect manufacturer states to establish procedures for the
Installation Standards. As HUD reads instructions or of production errors that inspection of used manufactured homes
the Act, the primary enforcement have resulted in the sections of the and for monitoring of the installation of
authority for these Model Installation home not fitting together properly. manufactured homes within each state
Standards is instead limited to section Comment: § 3285.1(a) Scope. (§ 3282.303), thus indicating the
605 (42 U.S.C. 5404) itself, which not Compliance with the Manufacturer’s regulations’ intent to place the
only provides more limited authority for Installation Instructions should be supervision of re-installments in the
these Model Installation Standards, but accepted as compliance with the Model hands of the states.
The final rule does not prevent state
also adds entirely new requirements Installation Standards. Several
and local governments from enforcing
regarding the licensing and training of commenters also recommended the
standards for installations after the
installers. section be rewritten as follows: ‘‘The
initial installation or from imposing
Given these fundamental differences manufacturer’s installation instructions higher installation standards than are
between the installation and shall apply under any of the following required by HUD’s ‘‘minimum’’ Model
construction and safety programs, conditions where they do not take the Installation Standards for the initial or
publication of these Model Installation home out of compliance with the any subsequent installation of a
Standards in new part 3285 of 24 CFR Federal Manufactured Housing manufactured home. State standards for
will best allow HUD to maintain the Construction and Safety Standards: (1) initial installation must meet or exceed
regulatory separation necessary to To items not covered by this standard; HUD’s minimum installation standards,
administer two such different programs. (2) Where the manufacturer’s approved while state standards for secondary
Comment: § 3285.1(a) Scope. Work installation instructions provide a installations do not have to adhere to
associated with the joining together and specific method of performing a specific the minimum HUD standards. HUD
close-up of sections of multi-section operation or assembly; (3) Where the continues to believe that any subsequent
homes and certain aspects of on-site manufacturer’s approved instructions installation of a manufactured home
completion should be considered as exceed this standard.’’ best resides with state authority.
installation of the home and not as HUD Response: § 3285.1(a) of the final Notwithstanding all of the above, HUD
construction. rule recognizes that the Model will continue to study this issue in
HUD Response: Under the final rule, Installation standards serve as the basis developing the final rule for its
work necessary to join sections of a for the manufacturer’s installation installation program regulations.
multi-section home, such as work instructions and accepts those Comment: § 3285.1(c) Consultation
identified in Subparts G, H, and I of the instructions for compliance, as long as With the Manufactured Housing
installation standards, and work they meet or exceed the minimum Consensus Committee. The
associated with connecting exterior requirements of the Model Installation Manufactured Housing Consensus
lights, ceiling-hung light fixtures, or Standards and do not take the home out Committee (MHCC) should have a
fans, as identified in Subpart I, are of compliance with the MHCSS. continuing involvement in revising the
treated as installation, and therefore is However, the methods for performing installation standards.
subject to these Model Installation operations that are included in a HUD Response: HUD agrees with
Standards and any future requirements manufacturer’s installation instructions comments received from the MHCC and
of the installation program regulations. will be enforced by the Department, in others that the Committee should have
Accordingly, close-up work completed their entirety. a continuing role in reviewing and
on-site would require inspection under Furthermore, the final rule requires recommending future changes to the
the Manufactured Home Installation that manufactured home manufacturers Model Installation Standards. HUD
Program Proposed Rule published in the include installation instructions with recognizes the valuable guidance and
Federal Register on June 14, 2006. each new home. The instructions must assistance provided by the MHCC
However, features such as penetrated be approved by a Design Approval throughout the rulemaking process with
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hinged roofs, high-pitched hinged roofs, Primary Inspection Agency (DAPIA) and the development of these installation
and eave construction will remain must provide protection to the residents standards. Accordingly, a new section,
subject to the MHCSS and the of manufactured homes that equals or § 3285.1(c), ‘‘Consultation with the
Procedural and Enforcement exceeds the protections provided by the Manufactured Housing Consensus
Regulations in 24 CFR part 3282. Model Installation Standards. Committee,’’ has been included in the

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final rule. That section provides that capacities, minimum support and Comment: The only way to get
HUD will afford the MHCC with a 120- anchorage locations, other structural efficient and consistent installation
day opportunity to offer input and design requirements, plan-specific compliance with both the Model
comment prior to proposing any information for completion of utility Installation Standards and the
changes to the installation standards. systems, etc.)? manufacturer’s support requirements is
The new provisions also direct the Comment: This should be left up to to require manufacturers to take
MHCC to send its own suggested each manufacturer to decide. responsibility for the vertical support of
changes to the Department at least every Comment: There is no need to require their own designs and to provide
2 years. The final rule also provides that model-specific home plan criteria for foundation plans with all pier locations
HUD will accept, modify, or reject each every conceivable single or multi- and minimum pad sizes specified and
recommendation and explain to the section home design as there must be drawn to scale, in a graphical format
MHCC the reasons behind any some reliance on the manufacturer’s serviceable for both the permit process
modifications or rejections of those installation manual for model-specific and the foundation layout at the jobsite.
recommendations before publication of home designs as the model standard is Comment: All engineered foundations
any new revised standard. the minimum necessary requirements. should be designed per SEI/ASCE 7,
Comment: 3285.1(d) Administration. Comment: There is no need to require Loads for Buildings and Other
One commenter wrote that certain model-specific plan criteria for every Structures. This will allow engineers
permanent site-built foundations with conceivable floor plan and design under and architects to develop foundation
manufacturer certification are not the Model Installation Standards. If designs that are capable of resisting all
subject to the proposed rule. This there needs to be specialized criteria, natural hazards at the site.
recognizes that site-built foundations the manufacturer can provide it in the Comment: Experience has shown that
under state and local codes are suitable installation manual that comes with the out-of-state registered professional
and that all localities have such codes. engineers and architects unfamiliar with
new home. The DAPIA will determine
It also implies that state and local codes the conditions of the locality design
whether the specialized manufacturer’s
for non-permanent foundations are foundation systems that fail, and that
manual has met or exceeds the Model
lacking and that HUD needs to the engineer or architect should be
Installation Standards. With regard to
intervene. This does not make sense, registered in the state where the home
§ 3285.403, the best alternative might be
unless there is a significant difference is to be installed.
to permit the mating line anchorage/ HUD Response: Section 3285.2(c) of
between permanent and non-permanent connection to be determined by the
foundation requirements and their the final rule has been revised
manufacturer’s installation manual. specifically to allow for variations to be
administration and enforcement.
HUD Response: This provision stems HUD Response: HUD has decided that made to installation instructions for site
from Section 604(f) of the Act and 24 model-specific foundation plans are not conditions that are not covered,
CFR part 3282.12 of the Manufactured required, but that special foundation provided that installers first attempt to
Home Procedural and Enforcement and anchorage plans are required to obtain those variations for site-specific
Regulations, which require HUD to address site-specific conditions or when conditions from the manufacturer and,
exclude from coverage any structure the support and anchorage methods in if not available from the manufacturer,
which, among other things, is designed the manufacturer’s installation the installer is to use designs prepared
to be erected and installed upon a site- instructions are not suitable and vary by a professional engineer or registered
built permanent foundation. from those included with the architect. The installer must have the
Comment: §§ 3285.2, 3285.301(b), manufacturer’s installation instructions. professional engineer’s or registered
3285.401 HUD Question: Should the Comment: § 3285.2 Manufactured architect’s design approved by the
Model Installation Standards offer more Installation Instructions/HUD Question. manufacturer and its DAPIA prior to
performance-based equivalents instead Should the manufacturer’s installation installation. DAPIA approval is
of prescriptive requirements to facilitate instructions provide that a professional necessary to enable HUD to enforce
the use of alternative installation engineer or registered architect must be such modifications to the
methods? consulted when general site conditions manufacturer’s installation instructions.
HUD Response: Based on the are not covered by the installation HUD has determined that the Model
recommendations of the MHCC and the instructions? Installation Standards do not need to
public comments, the final model Comment: When instructions do not require that professional engineers or
installation standards are a combination address specific site conditions and registered architects be licensed in the
of prescriptive and performance hazards, the foundations and anchorage state where the home is to be installed,
standards. While the minimum should be designed by a professional since they are responsible for only
standards do offer prescriptive methods engineer or registered architect. performing work or preparing designs in
for compliance, they also provide for Comment: There is no reason for the areas of construction in which they are
alternatives in design that will allow for Model Installation Standards to require competent and knowledgeable.
innovation. Accordingly, manufacturers’ that a professional engineer or architect However, a state that operates its own
instructions may be based on either the be consulted for site preparation, if the installation program may require that
minimum requirements in these model manufacturer’s manual does not cover the engineer or architect be specifically
installation standards or may use this installation consideration. Such a licensed by that state.
performance-based design in requirement could substantially raise Comment: HUD requested comments
demonstrating compliance with these the cost of site preparation for the on the efforts associated with checking
standards. retailer/installer. installation instructions. One
Comment: § 3285.2 Manufactured Comment: It is not reasonable to commenter wrote that since installation
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Installation Instructions/HUD Question. expect the manufacturer to effectively instructions vary by manufacturer and
Should model-specific plans for give installation instructions and model, the estimates of number of
installation be required and, if so, what assume liability when they have no site- respondents and responses per
minimum information should be specific knowledge. ‘‘A registered respondent were very low, while the
required on the plans (i.e., pier engineer is the right call.’’ number of hours spent on review was

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high, unless the time includes back-and- proposed rule and should be defined as Comment: § 3285.5 Definitions.
forth communication. If HUD does not the greater of either: (1) The base flood ‘‘Local Authority Having Jurisdiction
intend to take action to ensure or (2) the flood so designated by the (LAHJ).’’ The definition of LAHJ should
conformity with the Model Installation Local Authority Having Jurisdiction be rewritten to refer to local
Standards (MIS), there is no need to (LAHJ) as its regulatory flood, with a responsibilities in such a way that if
collect this data. one percent chance or less of being they are within the coverage of the
HUD Response: This issue will be equaled or exceeded in any given year. Model Installation Standards (MIS) they
addressed under the installation Comment: The term ‘‘design flood are applicable, but if outside the MIS
program regulations and any elevation’’ (DFE) should be added to the they are not applicable.
adjustments to the burden estimates will definitions as follows: ‘‘Design Flood Comment: Having states included
be made as part of those regulations. Elevation. The elevation of the design within the definition of an LAHJ seems
Comment: Section 3285.4 flood, including wave height, relative to to conflict with other provisions of the
Incorporation by Reference. There is a the datum specified on a LAHJ’s hazard rule and means that a state or local
more recent edition of the American map.’’ government entity that does not have
Society of Heating, Refrigerating and Comment: § 3285.5 Definitions. such requirements, even though they
Air-Conditioning Engineers ‘‘Lowest-Floor.’’ The definition of may be identical to the MIS, would not
Fundamentals Handbook and the Lowest Floor should be revised, as be considered an LAHJ. One commenter
Underwriters’ Laboratories (UL) 181 follows: ‘‘Lowest floor. The floor of the wrote that no level of government below
standard has been separated into UL lowest enclosed area of a manufactured the state level should be included in the
181, 181A, and 181B. home. For flood-resistant design definition of an LAHJ, because it
Comment: Add the American Wood purposes of these MIS, the term ‘‘lowest implies that lower levels of
Preservers Association (AWPA) to the floor’’ shall mean the bottom of the government’s programs are sanctioned,
list of Referenced Publications. AWPA longitudinal chassis frame beam in A which could result in the imposition of
Publications, American Wood- zones, and the bottom of the lowest additional fees, thereby causing
Preservers’ Association, P.O. Box 388, horizontal structural member increased costs for consumers.
Selma, AL 36702. AWPA U1–04, Use supporting the home in V zones. An HUD Response: The definition is
Category System: User Specification for unfinished or flood resistant enclosure, essentially unchanged in the final rule
Treated Wood, 2004, and AWPA M4– used solely for vehicle parking, home because any entity or subdivision of
02, Standard for the Care of access, or limited storage, must not be state government is not restricted from
Preservative-Treated Wood Products, considered the lowest floor, provided establishing more stringent
2002. The references to treated wood the enclosed area is not constructed so requirements than those in the MIS for
standards need to be updated because: as to render the home in violation of the states in which HUD will operate the
(1) AWPA C2 and C9 are no longer flood related provisions of this installation program. The proposed rule
updated by AWPA and will not include standard.’’ for the installation program regulations
new preservative treatments that are HUD Response: Section 3285.102 of in 24 CFR part 3286 includes detailed
appropriate for this application; (2) the final rule clarifies that the above provisions for state-run installation
Standard U1 is currently referenced in terms are used as defined in 44 CFR part programs and how those requirements
the 2004 amendments to the 2003 59.1 of the National Flood Insurance will impact on local governmental
International Building Code (IBC) and Program and, as such, are not required entities within their state. However, the
International Residential Code (IRC) in to be again defined in these installation definition has been modified in the final
place of standards C2 and C9 and will standards. rule to clarify that an LAHJ must have
be referenced in the 2006 editions; and Comment: § 3285.5 Definitions. both responsibilities and requirements
(3) the 0.60 lbs. per cubic foot is not the ‘‘Labeled’’ and ‘‘Listed or certified.’’ The that must be complied with during the
required retention level for all of the term ‘‘labeled’’ is very similar to the installation of a manufactured home.
appropriate preservatives. Copper azole term ‘‘listed or certified,’’ except that Comment: § 3285.5 Definitions.
(CA–B) has a required retention of 0.31 ‘‘listed or certified’’ requires that an ‘‘State.’’ The ‘‘Canal Zone’’ should be
lbs. per cubic foot for this application approved product be on a published list. deleted from the definition of ‘‘State,’’
that is equivalent to Chromated Copper All of these terms could be read to because the Panama Canal Zone has not
Arsenate used at 0.60 lbs. per cubic foot. require the contracting of an agency on been under United States control or
HUD Response: The editions of these a continuing basis to maintain product jurisdiction for nearly 30 years. emsp;
standards that are adopted in this final approval status rather than using a HUD Response: HUD has removed
rule are consistent with those recently nationally recognized third-party testing ‘‘the Canal Zone’’ from the definition of
updated by HUD in recent amendments agency for a one-time approval. ‘‘State,’’ but recognizes that the statute
to the Manufactured Home Construction HUD Response: Both terms remain in has not been amended or updated to
and Safety Standards. HUD will the final rule because certain reflect this change.
consider issuing conforming components may not be required to be Comment: § 3285.5 Definitions.
amendments to more recent editions of labeled but must still be listed under the ‘‘Foundation.’’ The term ‘‘foundation’’
these standards in future rulemaking. purview of a nationally recognized should be a defined term in the MIS.
HUD also agrees there is a need to testing laboratory. HUD Response: A definition for a
update and revise the reference Comment: § 3285.5 Definitions. ‘‘foundation system’’ has been included
requirements for treated wood materials, ‘‘Crossovers.’’ The definition of in the final rule in both the
and the final rule incorporates the more crossovers should be amended to Manufactured Home Construction and
recent AWPA U1–04 and AWPA M4–02 include ducting for both heating and Safety Standards and the MIS.
standards into certain sections of the cooling ducting, and not just ducting for
Subpart B—Pre-Installation
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installation standards (§§ 3285.4, heating.


3285.303, 3285.312, and 3285.504). HUD Response: As recommended by Considerations
Comment: § 3285.5 Definitions. the commenters, the final rule includes Comment: Seismic Safety/HUD
‘‘Design Flood.’’ The term ‘‘design both heating and cooling ducts in the Question: Should the MIS attempt to set
flood’’ is used several times in the definition of ‘‘crossovers.’’ forth minimum installation

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requirements or pre-installation Comment: § 3285.101 Installation of Comment: Paragraph (d)(2) should be


considerations to address seismic Manufactured Homes in Flood Hazard renumbered as (d)(3) and a new section
safety? If so, how should HUD establish Areas. The requirements for installation (d)(2) should be added, as follows:
seismic zones and what minimum of manufactured homes in flood hazard ‘‘Performance requirements.
requirements would be included in the areas should be included in Subpart D Manufactured home installations shall:
Model Installation Standards? Foundations, § 3285.302, rather than in (a) Have the lowest floor elevated to or
Comment: If seismic zones are to be § 3285.101(d). While § 3285.101 requires above the design installation; (b) elevate
considered in the future as a the installer to determine if flood the home using support and anchorage
manufactured home design parameter, it hazards affect the site, it is more systems designed and constructed to
is best that they first be introduced into appropriate that more explicit design resist design flood loads in combination
part 3280 and then mentioned in set-up considerations be articulated in the with other storage loads; (c) construct
manuals. section on foundations. the support and anchorage system with
Comment: Part 3285 contains no Comment: States and communities in flood damage resistant materials; (d) in
criteria to protect homes from areas that are vulnerable to flood A zones, use flood openings in
earthquakes, and this omission makes damage should adopt regulations that permanent foundation walls and in
the standard incomplete. Other national exceed the minimum National Flood other solid walls (excluding skirting)
consensus standards have seismic Insurance Program (NFIP) requirements. forming an enclosure below the DFE, to
criteria, such as the IBC, the IRC, the Comment: The approach indicated in allow the automatic equalization of
National Fire Protection Association the proposed Model Installation flood levels; and (e) in V zones, elevate
(NFPA) 5000 Building Construction and Standards was considered and rejected the home on piles, columns, piers, or
Safety Code, and the NFPA 225. by NFPA 225. Basic performance stands that minimize obstructions below
Manufactured homes fall off this type of requirements related to floods can and the DFE, and use breakaway
support at very moderate ground must be included in the Model construction for any other non-
shaking levels, since such homes are Installation Standards, and doing so will structural walls or elements.’’
typically installed using piers not Comment: Fill is often used as a
not conflict with, replace, or preempt
designated for seismic resistance, which method to elevate sites so that the
NFIP and LAHJ flood requirements.
are not adequately attached and lowest floors of manufactured homes are
Comment: Method and Practices.
connected to the foundation and chassis elevated to or above the design flood
Manufactured homes located wholly or
of the home. This lack of seismic elevation. While compaction of fill used
partly within special flood hazard areas
resistant provisions will result in to elevate a manufactured home site is
significantly less protection than in must be installed using methods and
an important consideration, there are
other types of residential construction, practices that minimize flood damage
other particular considerations that are
and is technically inadequate in areas of during the base flood, including
important so that flood conditions do
high seismic activity. Congress elevation and stability of the foundation
not adversely affect the fill. In
authorized the Earthquake Hazard for anticipated conditions and loads in
particular, it is recommended that the
Reductions Program to develop seismic accordance with the LAHJ; 44 CFR
fill be sloped and protected with
safety provisions suitable for use 60.3(a) through (e), as applicable; and vegetation to minimize erosion that may
throughout the United States. The lack other provisions of 44 CFR referenced undermine the home. This can be
of seismic provisions is contrary to by those paragraphs. accomplished by adding
national policy. The approach for Comment: Section 3285.101(c) should § 3285.101(d)(2) to read as follows:
seismic detailing and design in NFPA be revised to read as follows: ‘‘(c) Pre- ‘‘Installation on fill. Fill placed in flood
225 should be accepted and used in part installation considerations. Prior to the hazard areas in order to elevate
3285. initial installation of a new manufactured home sites shall be
Comment: HUD should not include manufactured home, the installer is placed, compacted, and sloped to
any seismic requirements in the Model responsible to determine whether the minimize shifting, slumping, and
Installation Standards. When required, manufactured home site lies wholly or erosion during the rise and fall of
designs are handled by the retailer, the partly within a special flood hazard area floodwater.’’
installer, the owner, or the as shown on the LAHJ’s Flood Insurance Comment: A new paragraph,
manufacturer, in accordance with the Rate Map, Flood Boundary and § 3285.101(e), should be added to read
requirements of the local building Floodway Map, or Flood Hazard as follows: ‘‘Alternate Flood-Resistant
authority. This is working now and Boundary Map. If so located, the map Installation Provisions. The flood-
need not be covered in the installation and supporting studies and resistant installation provisions
standards. requirements adopted by the LAHJ or contained in NFPA 225 shall be deemed
HUD Response: The final rule does state should be used to determine the to equal or exceed the flood
not contain specific requirements for the flood hazard zone and design flood requirements of the Model Installation
design of foundation and anchorage elevation at the site. If the LAHJ has not Standards.’’
systems in seismically active areas. This adopted a Flood Hazard Map, the Comment: The only way to prevent
will allow states and local building code installer shall consult the LAHJ to flood damage is by elevating the home
authorities in seismically active areas to determine flood-resistant installation above the flood level on strong and
establish or continue to enforce requirements.’’ durable stabilizing devices. Performance
foundation and anchoring requirements Comment: § 3285.101(d) Installation requirements to prevent flood damage
for seismic design load considerations. of Manufactured Homes in Flood must be included if the Model
However, HUD intends to continue to Hazard Areas. LAHJs should be given Installation Standards are to be
study this issue and may recommend the option to enforce requirements for effective.
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requirements for seismic design in flood hazards at whatever level they HUD Response: The final rule
future rulemakings in the Manufactured deem necessary. The section should continues to reference the provisions of
Home Construction and Safety provide two options for flood hazard 44 CFR 60.3(a) through (e) and Federal
Standards and the Model Installation criteria: (1) Per the LAHJ or (2) per the Emergency Management Agency
Standards. NFIP regulations. (FEMA) 85, Manufactured Home

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Installation in Flood Hazard Areas, as included as an acceptable method to do not provide additional support in the
appropriate guidance for installation of determine soil-bearing capacity. While roof system in order to support gutters
manufactured homes in areas subject to penetrometers are not as precise a and downspouts. Installation could
flooding. A state or local community method for determining soil-bearing cause damage and take the home out of
may adopt more stringent performance capacity at an individual location, they compliance with the MHCSS. However,
requirements than those specified under have proven to be workable devices if gutters and downspouts are provided,
the Model Installation Standards for where multiple readings are taken at an the runoff must be directed away from
flood hazard areas. installation site. the manufactured home.
Comment: § 3285.102 Design Zone Comment: The proposed rule should Comment: Even though the Model
Maps. The design and construction of offer a default approach to determine Installation Standards require any
the foundation and anchoring systems the soil bearing capacity such as runoff from gutters and downspouts to
addressed in part 3285 should be permitted by other model codes. This be diverted away from the home, not all
compatible with the design and default approach used in some state and HUD Code homes are required to have
construction of the home, but should model building codes, such as the 2003 gutters and downspouts. If gutters and
not be restricted or limited by the International Residential Code, downspouts are provided, then
outdated and obsolete design zone maps generally recognizes a minimum soil installers should be required to ensure
contained in part 3280. bearing capacity of 1500 pounds per that adequate drainage is provided.
Comment: This section should require square foot (psf). HUD Response: The final rule has
that a manufactured home cannot be HUD Response: The final rule now been revised to require manufacturers to
installed in a higher wind zone, snow allows the use of the pocket specify in their installation instructions
load, or thermal zone than the home’s penetrometer as one of the acceptable whether the manufactured home is
original design for its initial installation. methods for determining soil suitable for the installation of gutters
Comment: The referenced design classification and bearing capacity and and downspouts and if so provided, the
maps identified in part 3280 should be permits the use of a 1500 psf soil instructions are also to indicate that all
included in this section. bearing capacity, unless site-specific roof water is to be directed away from
HUD Response: Section 3285.103(a) of information requires the use of lower the home.
the final rule requires that prior to the values based on soil classification and
§ 3280.204 Ground Moisture
initial installation of a new type.
Comment: § 3285.203(a) Drainage. Control/HUD Question: HUD is
manufactured home, the installer verify concerned that excessive voids and
that the design and construction of the The section should be revised to read as
follows: ‘‘Drainage must be provided to numerous tears in the vapor retarder can
home, as indicated on the design zone defeat the purpose of the requirement.
maps provided with the home required direct surface water away from the
home.’’ This was suggested because the Therefore, should limitations be placed
by the Manufactured Home on the number and size of voids and
Construction and Safety Standards and commenter believed it unnecessary to
include a ‘‘laundry list’’ of possible tears? If so, what specific limitations
regulations, are suitable for the site would be recommended?
location where the home is to be problems, if proper drainage was not
provided, that was identified in the Comment: Some commenters
installed.
proposed rule. advocated that the Model Installation
Subpart C—Site Preparation Comment: As written, subsection (b) Standards should state that all tears and
§ 3285.201 Soil Conditions/HUD would be impossible to enforce within voids in the ground vapor retarder be
Question. HUD sought comment on rental communities given their layout repaired. Others raised questions as to
whether the standards should require and design. The requirement should be what would constitute a minor tear or
that a minimum of six inches of soil, revised to provide an exemption for void, as indicated in the proposed rule;
including the organic material, be homes sited within manufactured home how many tears or voids would be
removed under load bearing footings to rental communities, or by changing the acceptable without repair; and how the
ensure that footings are placed on drainage requirement ‘‘from under’’ to regulation would be consistently
undisturbed soil for at-grade footings. ‘‘away from’’ the home. Further, in enforced by states. The commenters also
Comment: This would seem like a subsection (c) the first 10-foot provision suggested this was one situation where
good practice in general to avoid would be impossible to enforce in rental a prescriptive provision is warranted in
detrimental effects to foundation communities, since lots only provide for the standards.
support and anchoring systems; 5-foot sideyards and that the Comment: As it would be difficult to
however, to specify a minimum depth of requirement should be revised to repair tears or defects in the ground
six inches of soil be removed may in require drainage away from the vapor retarder around piers, the
some cases be too little or in other foundation of the home for the first 5 requirement should be revised to not
situations too excessive. To address this feet. require minor tears and voids at pier
concern, the commenters recommend HUD Response: The final rule has locations or other support to be
that the section be revised to indicate been revised to clarify that surface water repaired.
that topsoil is to be removed or that at- must be directed away from the home to Comment: The ground vapor retarder
grade footings should be installed on prevent water build-up under the home. should be overlapped at least 12 inches
undisturbed soil. Where property lines do not allow the at all joints to prevent weeds and grass
HUD Response: HUD finds the drainage to be diverted for the first 10 from growing through deck slats, and to
comment to be reasonable, and the final feet from the foundation, other methods minimize the likelihood of moisture
rule does not specify a required depth are allowed to remove the surface water. penetration.
of soil removal, thereby leaving the However, statements on the adverse Comment: The reference to a six
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determination of firm, undisturbed soil affects of not removing the water have millimeter polyethylene is a
as a site-specific matter. been removed from this section, as typographical error in § 3285.204(b). A
Comment: § 3285.202 Soil suggested by commenters. six millimeter polyethylene ground
Classifications and Bearing Capacity. Comment: § 3285.203(f) Gutters and vapor retarder would be .039″ thick, as
The pocket penetrometer should be Downspouts. Most home manufacturers opposed to the six mil polyethylene that

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was intended, which would be .006″ homes, (3) it is not specified where the foundation systems, including perimeter
thick. professional has to be registered, and (4) or permanent foundations, should not
Comment: Ground vapor retarders it will increase costs because services of be required if a manufacturer has
should be required only in enclosed engineers and architects will be complied with either engineered plans
areas and paragraph (a) should be required for each installation rather than or state-established standards for
revised to read as follows: ‘‘(a) If space having the manufacturer provide the permanent foundations.
under the home is to be enclosed with information universally. The commenter HUD Response: DAPIA-approved
skirting or other material, a vapor proposes to change the language to installation instructions are required to
retarder is required in the following read, * * * Must be prepared by the be provided by manufacturers under
situations: (1) In humid regions (this manufacturer or by a registered section 605(b) of the Act. The final rule
region is considered to follow the very professional engineer or a registered indicates that foundation systems that
heavy termite infestation probability architect in accordance with the are not of pier and anchor type
map, reference in the HUD Sept., 1996 manufacturer’s home design and the configurations may also be used, when
PFGMH); (2) in situations where the Manufactured Home Construction and substantiated by engineering design as
crawlspace soil elevation is below the Safety Standards (3280).’’ [Same being capable of resisting the design
natural surrounding surface elevation comment for §§ 3285.301(d), loads in the Manufactured Home
(i.e., pit set applications); (3) in 3285.306(c), 3285.310(c), 3285.312(c)(1) Construction and Safety Standards. If
installations where concrete decks, and (2), 3285.314(b), 3285.401(b) and alternative foundation designs are not
retaining walls or other solid barriers (b)(2), 3285.402(c)] provided in the installation instructions
prevent venting on more than one side Comment: § 3285.301(c) General. and are desired or needed for site-
(refer to § 3285.505).’’ Most registered professional engineers specific conditions, installers are
HUD Response: Section 3285.204 of or registered architects are not aware of required to first contact manufacturers
the final rule does not permit any voids the federal standards or how to obtain variations to the instructions
or tears in the ground vapor retarder, manufactured homes are designed and or, if not available from the
requires all joints to be overlapped at constructed. They are also unaware of manufacturer, to use a design prepared
least 12 inches, and allows the vapor critical areas of support. If the designs by a professional engineer or architect
retarder to be installed around or over fail, the federal program has no (§ 3285.2(c)). The installer must have
footings and other obstructions, as authority over these outside the professional engineer’s or registered
suggested by the commenters. The final professionals. architect’s design approved by the
rule also corrects the typographical error HUD Response: The requirements for manufacturer and its DAPIA prior to
in the proposed rule in paragraph (b) by the use of professional engineers or installation. DAPIA approval is
requiring the thickness of the vapor architects to certify various aspects of necessary to enable HUD to enforce
retarder to be a minimum of six mil the manufacturer’s installation such modifications to the
polyethylene sheeting. The final rule instructions for foundation and manufacturer’s installation instructions.
also clarifies that all enclosed and anchoring support, including alternative Comment: § 3285.301(a) General.
skirted areas are to be provided with a foundation systems, are retained in the The design of the foundation system
ground vapor retarder, except in arid final rule and are no different than what should not be limited to the design
regions and areas for open porches, is currently required for certification of loads required by the Manufactured
decks, and recessed entries. this information under the Home Construction and Safety
Manufactured Home Construction and Standards, as indicated on the home’s
Subpart D—Foundations Safety Standards. In addition, one of the data plate. Presently, manufactured
Comment: § 3285.301(b) Alternative responsibilities of a professional homes are not designed for flood loads,
Foundation Systems. The requirement engineer or registered architect is to but foundation and anchorage systems
that foundations that are not of the pier understand all aspects of any design, sited in flood hazard areas should be
and footing type are to be designed by including critical areas of support, capable of resisting flood loads.
a professional engineer increases costs before certifying that it complies with Similarly, manufactured homes are not
to the consumer. the appropriate standards or presently designed for seismic forces,
Comment: It is unnecessary for a requirements. The installer must have but foundation and anchorage systems
professional engineer or architect to be the professional engineer’s or registered installed in areas subject to earthquake
consulted for site preparation, if the architect’s design approved by the forces should be capable of resisting
manufacturer’s manual does not cover manufacturer and its DAPIA prior to seismic loads. To remedy the above
the specific conditions for the site, installation. DAPIA approval is concerns, the section should be revised
because every manual has been necessary to enable HUD to enforce to read as follows: ‘‘(a) Foundations for
reviewed by the industry’s national such modifications to the manufactured home installations must
association and it always contains some manufacturer’s installation instructions. be designed and constructed in
information with regard to site Comment: Installation Instructions for accordance with this subpart and must
preparation. If not, the LAHJ can be Perimeter and Permanent Foundations/ be based on site conditions, home
looked to for any other conforming HUD Question: Should manufacturers design features, and the greater of (1) the
requirements. who design their manufactured homes loads the home was designed to
Comment: § 3285.301(b) et al. The to be installed on perimeter or withstand as shown on the home’s data
proposed rule’s requirements for permanent foundations, in addition to plate, and (2) design loads specified
‘‘acceptable engineering practice’’ are pier, footing, and anchor foundations, elsewhere in these Standards or by the
too broad to ensure uniformity. As be required to also provide DAPIA- LAHJ or state.’’
written, the commenter finds four approved installation instructions for HUD Response: Under the final rule,
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problems with the proposed language: perimeter and/or permanent states and localities are not prevented
(1) It suggests that all aspects of design foundations and the pier, footing, and from establishing and enforcing seismic
require registered professionals, (2) the anchor systems? requirements or higher design
standard is not specific to the design Comment: Additional DAPIA- requirements for foundations and
and construction of manufactured approved instructions for other anchorage to resist flood loads.

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Comment: Test Protocol for Category 4B ground contact should be simplified by retaining only
Alternative Foundation Systems/HUD applications, or adjustable metal or the ‘‘Pier and Footing Load’’ column
Question: What specific requirements concrete piers.’’ and by deleting all references to the
should be included in the national test HUD Response: Section 3285.301(b) 16″x16″ concrete footing /pyramid
protocol for alternative foundation of the final rule has been revised in layout method in the Tables and by
systems protocol referred to in the accordance with the above comment to deleting Figure C to § 3285.312 in its
proposed Model Installation Standards? reference a more current standard entirety.
Comment: It would be best to delay permitting the use of water-borne Comment: The footnotes in the tables
providing any specific considerations or preservatives for pressure treatment of should indicate that flood or seismic
testing requirements in the final rule, wood members. loads were not considered in developing
because the MHCC has been tasked to Comment: § 3285.303 Piers/HUD the tables and that the tables should not
develop a recommended test protocol Question: Should the Model Installation be used in determining foundation
for proprietary foundation systems. Standards include other design requirements in flood hazard areas or
Further, any proprietary system can be characteristics or standards for seismic hazard areas.
evaluated by a manufacturer and manufactured piers such as protection HUD Response: The Tables in the
included, at its option, in the from the elements, material final rule have been revised to delete the
installation manual, subject to DAPIA specifications, a testing protocol, or references to footing layouts, and Figure
approval. listing and labeling requirements? C to § 3285.312 has also been deleted in
Comment: Currently a de facto, Comment: Piers and other support or the final rule. A footnote has also been
nationally recognized protocol exists, anchorage devices should be designed added to each of the Tables in the final
which has been extensively used to and constructed to resist weathering, rule indicating the Tables do not
evaluate most of the alternative corrosion, and deterioration with consider flood hazard or seismic design
foundation systems on the market. minimal maintenance and upkeep on load requirements.
HUD Response: Section 3285.301(d) the part of the owner. This is especially Comment: § 3285.304 Pier
of the final rule includes provisions for important in coastal areas where salt Configuration. There are a number of
a nationally recognized testing protocol spray corrosion is present, and in flood
for proprietary foundation systems or inconsistencies between the text in this
hazard areas where the supports and section and Figures A and B to
alternatively requires proprietary anchorage are subject to inundation.
foundation system designs to be § 3285.306 with regard to cap thickness,
Comment: Manufactured piers are
prepared or tested by a registered size, and material callouts and
designed to withstand certain loads and,
professional engineer or registered specifications; shim size, use, thickness,
as long as the home manufacturer
architect. Efforts are underway by the and orientation; and gaps between the
provides the loading requirements at
MHCC to develop recommendations for main chassis beam and foundation
each intended pier location, a
a national testing protocol, which will support system specifics.
manufactured pier that is capable of
be considered by the Department of HUD Response: Figures A and B and
resisting those loads should be
Housing and Urban Development upon the text of this section have been revised
acceptable for use.
its completion. Presently, states that are Comment: The proposed rule in the final rule to address comments
operating an installation program have specifies that manufactured home piers, regarding inconsistencies between them
differing requirements for the testing of other than concrete masonry units or in cap requirements (i.e., 1⁄2″-steel plate
proprietary foundation systems, and steel jack stands, be listed and labeled thickness has been used in both the text
there is no universally accepted de facto for the required vertical loads and and Figures in the final rule), by
method for testing, as suggested by one appropriate lateral loads. This appears requiring wood shims to be hardwood
of the commenters. to be a performance-based requirement. and by clarifying alternatives for filling
Comment: § 3285.302 Installation of There does not seem to be any reason gaps.
Manufactured Homes in Flood Hazard to provide a laundry list of design Comment: § 3285.305 Clearance
Areas. Manufacturers should be conditions. HUD should maintain the Under Homes/HUD Question: Should
required to either include flood-resistant status quo until some nationally the Model Installation Standards
considerations in their foundation recognized material/testing protocol can include minimum clearances in areas
specifications (and state the conditions be developed. such as those required for access or
under which the specifications are HUD Response: The proposed rule inspection?
applicable in terms of specific ranges of did not exclude metal stands or piers Comment: A minimum clearance
velocities, depths, and wave action), or from the requirement to be listed and under a home is required to install and
state that their foundation specifications labeled, as suggested by the commenter. inspect utility connections, bottom
do not address flood loads and shall not This is further clarified in § 3285.308 of board repairs, etc. All of the area
be used in flood hazard areas. the final rule, which requires that any underneath a home should be accessible
HUD Response: Section 3285.302 of metal pier or other type of manufactured for that, and even if there are no utility
the final rule requires that the pier be listed, meet the pier load connections in an area, bottom board
installation instructions identify requirements of the Model Installation repairs may still need to be made on-
whether the foundation specifications Standards in § 3285.303, and be site.
have been designed or not designed for protected against weather deterioration Comment: A 12-inch minimum
flood-resistant considerations. and corrosion. clearance should be maintained beneath
Comment: § 3285.303(b)(1) Comment: § 3285.303(d) Pier Loads. the lowest member of the main frame
Acceptable Piers-Material The word ‘‘poured’’ should be deleted, and the ground under 100 percent of the
Specifications. The section should be as it suggests that the footers for piers home.
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revised to read as follows: ‘‘Piers are loads need to be poured. HUD Response: The final rule
permitted to be concrete blocks, HUD Response: The term ‘‘poured’’ requires a minimum clearance of 12
pressure-treated wood treated with a has been deleted in the final rule. inches under the home to the ground,
water-borne preservative in accordance Comment: § 3285.303 Tables 1, 2, including areas between the lowest
with AWPA Standard U1 for Use and 3. The Tables are confusing and point of the frame and the grade.

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Comment: § 3285.306(b) Frame Piers specifically addressed by these Model the commenters to indicate that pier
36 Inches to 80 Inches and Corner Piers. Installation Standards. supports are required for any opening of
The MHCC and other commenters stated Comment: § 3285.310 Figures/Tables 48’’ or greater. The footnotes to the
that mortar should not be required, for Marriage Line Pier Supports figures have also been revised by
unless specified in the manufacturer’s (Generally). The manufacturer’s reducing the maximum load permitted
installation instructions. Further, if installation manual would be easier to on a single stack concrete block pier
mortar is required for all frame or corner reference for these requirements rather from 10,000 lbs. to 8,000 lbs., as
piers between 36 inches and 67 inches than the specifications, Tables, and determined by HUD’s analysis.
in height, it would add unnecessary Figures in the proposed rule. Comment: § 3285.310(b). Paragraph
costs to the installation of the home. HUD Response: As recommended by (b) should be revised to read, ‘‘(b) Mate-
Comment: When concrete block piers the MHCC and others, the Tables, line and column pier supports must be
are required to use mortar, the type of Figures, and specifications are needed in accordance with this subpart and
mortar should be indicated in the to establish the minimum requirements consistent with Figures A through C to
standards. and guidance needed for preparing this section or located and sized to
Comment: Section 3285.306(a)(5) manufacturer’s installation instructions. withstand the loads provided by the
should be changed to read as follows: Comment: § 3285.310 Typical Mate- home manufacturer for the specific
‘‘Mortar is not required if a solid 4″ cap Line Column Pier and Mating Wall home.’’
block is placed on top of the hollow Support. Footnote 1 of Figure A to HUD Response: Paragraph (b) has
masonry blocks and the pier is not being § 3285.310 requires all footings to been revised in the final rule to indicate
considered as an anchoring point, extend below the frost line depth. This that the mate-line column and pier
unless otherwise specified in the requirement is inconsistent with supports are required to be in
installation instruction or required by a § 3285.312(c), which allows footings to accordance with the provisions of
registered engineer or registered be located at grade, when insulated Subpart D, unless the pier support and
architect.’’ foundation systems are used in areas footing configuration is designed by a
HUD Response: Paragraphs (a), (b), subject to freezing. Instead, Footnote 1 registered professional engineer or
and (c) of § 3285.306 of the final rule should be revised to reference architect.
have been revised to indicate that the § 3285.312(c) for footing requirements in Comment: § 3285.311 Required
use of mortar is only required when frost-heave susceptible soils. This same Perimeter Supports. Piers are not the
specified in the manufacturers comment also applies to Figure B. only means of perimeter support; other
installation instructions or required in Comment: Figure A to § 3285.310 means such as additional outriggers or
designs prepared by a professional Typical Mate-Line Column Pier and floor joists should also be permitted.
engineer or registered architect. Mating Wall Support When Frame-Only Comment: The reference to wood
Comment: § 3285.306(b)(2). The Blocking is Required and Figure B to stoves should be changed to fireplace
Model Installation Standards should § 3285.310 Typical Mate-Line Column stoves, since wood stoves have not been
address offsets in piers over 36″ in Pier and Mating Wall Support When used in manufactured homes for many
height and the maximum tilt of piers Perimeter Blocking is Required. For years.
from vertical for piers of any height. locations more than two feet from the Comment: References in § 3285.311(b)
HUD Response: Horizontal offsets for perimeter of the home, the frost line to Tables 1 and 3 should be deleted,
piers over 36″ and up to 67″ in height depth should be one half of that because only Table 2 addressed the use
are limited to 1″ in § 3285.306(b)(1) of required for perimeter footings, because of perimeter piers.
the final rule. temperatures under the home are not Comment: In recognition of
Comment: Figure B to § 3285.306 low enough to cause severe soil frost mountainous areas where snow loads
Typical Footing and Pier Installation, line conditions. are greater than 40 psf, a new paragraph
Double Concrete Block. The maximum Comment: The pier capacity indicated (c) should be added to read, as follows:
pier height of 80 inches should be in Footnote 3 for single dry stack ‘‘Perimeter support in accordance with
reduced to 67 inches, because the tie- concrete block piers should be reduced manufacturer’s installation instructions
down charts provided in this standard from 10,000 lbs. to 8,000 lbs., while may be required for roof loads in excess
are limited to 67’’ and pier designs another commenter recommended the of 40 psf.’’
greater than 67’’ in height will require capacity be reduced even further to HUD Response: Section
independent engineering designs. 5,725 lbs. 3285.311(a)(2) of the final rule provides
HUD Response: The requirements for Comment: Footnote 6 for Figure A for other means of perimeter support,
frame and corner pier height in Figure and Footnote 4 for Figure B should be such as by additional outriggers or floor
B and the text of the final rule have been revised to indicate that pier or other joists, and requires the sizing of pier and
reduced from 80 inches to 67 inches to supports are required for any opening footing supports to consider the
be consistent with other tables and 48″ or greater at either the mate-line or additional loads from these alternative
figures in the Model Installation the side wall. supports. The final rule has also been
Standards. HUD Response: Footnote 1 of the revised to change the term ‘‘wood
Comment: § 3285.309 Elevated Figures A and B to § 3285.310 in the stoves’’ to ‘‘fireplace stoves’’ to be
Homes. Since information is provided final rule have been revised to indicate consistent with the Manufactured Home
for designing tie-downs and piers up to that the bottom of the footings must Construction and Safety Standards. For
67’’ high, the ‘‘one-fourth of the area of extend below the frost line depth, roof live loads in excess of 40 psf or
a home’’ requirement should be deleted. unless designed for placement above the greater, a professional engineer or
HUD Response: The provisions for frost line. In addition, alternatives to architect must determine the maximum
elevated homes have been deleted in the locating footings below the frost line, sidewall opening that is permitted. In
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final rule, as recommended by the such as by using an insulated addition, the references to Tables 1 and
commenters. A professional engineer or foundation system, are provided in 3 have been deleted in the final rule, as
registered architect would be required to § 3285.312(b) of the final rule. Other recommended by the commenters.
prepare designs that exceed 67″ in footnotes to the figures in § 3285.310 Comment: § 3285.312(b)(1)(i)
height or for other conditions not have been revised, as recommended by Footings; Acceptable Types of Footings

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Concrete/HUD Question: Should the plywood with a minimum thickness of HUD Response: A new paragraph,
Model Installation Standards provide three-quarters of inch and a maximum (a)(4), has been added to this section in
minimum steel reinforcement size of 16″x16″, or, for larger sizes two the final rule to allow the use of other
specifications for cast-in-place footings? pieces of nominal three-quarter inch materials for footing pads, provided
Comment: There should be minimum thick plywood. Plywood shall be they are listed for such use and meet all
requirements for steel reinforcement of American Plywood Association-rated other applicable requirements for
footings to prevent footing damage or sheathing, Exposure 1 or Exterior in footings in this subpart.
failure. accordance with PS1. (ii) Pressure- Comment: § 3285.312(c) Placement
Comment: Footing design, including treated lumber and plywood shall be in Freezing Climates. DAPIA-approved
the amount and size of steel treated with a water-borne preservative installation manuals should indicate
reinforcement, should be left up to the in accordance with American Wood that all footings must extend below the
registered professional engineer or Presservers’ Association standard U1 for frost line or be protected from the effects
architect preparing the design. Use Category 4B ground contact of frost heave.
Comment: Steel reinforcement applications. (iii) Cut ends of pressure- Comment: Why are frost depths not
specifications for cast-in-place concrete treated lumber shall be field treated in established in the Model Installation
footings are not necessary for inclusion accordance with AWPA M4–02.’’ Standards as they are in other model
in Model Installation Standards, since HUD Response: Section building codes, and instead determined
these are specified by the manufacturer 3285.312(a)(2) of the final rule for by the LAHJ?
and would exceed the minimum pressure-treated wood footings has been Comment: The requirements for
standard requirements. revised, in accordance with the above monolithic slab systems and insulated
HUD Response: Section foundations in paragraphs (2) and (3)
recommendations.
3285.312(a)(1)(ii) in the final rule has should be revised to permit the design
Comment: § 3285.312(b)(3)
been revised to indicate that site- to be prepared by a registered
Acrylonitrile Butadiene Styrene (ABS)
specific soil conditions may require the professional engineer or registered
Footing Pads/HUD Question: Should
use of reinforcing steel for design of architect using acceptable engineering
ABS footing pads be listed and what
cast-in-place footings. practice to prevent the effects of frost
Comment: § 3285.312(b)(1)(i) type of criteria should be contained in
heave or in accordance with SEI/ASCE
Acceptable Types of Footings. Concrete. the Model Installation Standards to
32–01, rather than requiring compliance
The requirement for four-inch nominal ensure the products are durable and can
to both of the above provisions. The
precast concrete pads to have a 28-day be adequately and uniformly evaluated
commenters indicated that for
compressive strength of at least 4,000 for review and approval?
monolithic slabs and insulated
psi is inconsistent with the industry Comment: ABS footing pads should foundations there should be two ways to
practice of using 1,200 psi. Further, be certified for use by soil classification. obtain approval, to avoid increasing the
there is no explanation or engineering ABS or other plastic type footing pads cost of installation.
rationale provided as to why 1,200 psi tend to deflect more in sandy soil Comment: The reference to the SEI/
cannot be used, and 4,000 psi precast conditions. ASCE 32–01 design criteria should not
footing pads are not currently available. Comment: ABS footing pads are be included because it is too stringent
The standard should be set at 1,200 psi currently being approved and used and and would not allow perfectly
and the same revision should be made should be permitted under the Model acceptable installation alternatives to be
to Figure C to § 3285.312. Installation Standards. States should used. Further, any installation system
Comment: The word ‘‘must’’ should continue to be responsible for outlined by the manufacturer that meets
be stricken from § 3285.312(b)(1) to determining the appropriate criteria and or exceeds the requirements contained
allow concrete footings to be either approval procedures for use of ABS in the Model Installation Standards, is
precast or poured-in-place, or both. footing pads until a nationally approved by a registered engineer, and
HUD Response: The final rule has recognized material/testing standard is provides for protection from the effects
been revised to reduce the 28-day developed. of frost heave should be allowed.
minimum compressive strength for Comment: The proposed rule does not Comment: If only SEI/ACSE 32–01 is
precast concrete footings from 4,000 psi mention that any limitations for use of referenced, it may effectively eliminate
to 1,200 psi, in accordance with the ABS pads in areas subject to freezing or any type of insulated skirting system
recommendations of the commenters. frost. from being used to permit pier footings
While the rule permits either precast or Comment: ABS footing pads must be to be above the frost line.
poured-in-place concrete footings, approved for the permitted load and soil Comment: Four field test reports
because of different settlement rates for bearing capacity since there are no appeared to indicate that alternative
the different types of footings, the use of requirements for listing or labeling. strategies could be used to protect
both at a particular site is limited to a HUD Response: Section manufactured home foundation systems
design approved by a registered 3285.312(a)(3) of the final rule permits in freezing climates without requiring
professional architect or engineer. the use of ABS footing pads, but the foundations to be embedded below
Comment: § 3285.312(b)(2) Footings; requires they be listed and labeled as to the frost line or conform to SEI/ASCE
Pressure-Treated Permanent Wood. This their load capacity and adds the 32–01. The above-referenced tests have
subsection should be reorganized into: requirement that they also be certified shown that insulated skirting materials
(i) Physical requirements, (ii) treatment for use in the soil classification at the can keep the ground under the home
requirements, and (iii) field treatment of site. above freezing temperatures.
cut ends. The subsection, as designed Comment: § 3285.312 Footings. Any Comment: Requiring monolithic slabs
and combined by the commenter, would type of interior supports and pads that to be approved by a registered
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read: ‘‘(2) Pressure-treated Wood. (i) are deemed appropriate by the professional engineer or a registered
Pressure-treated wood footings shall manufacturer should also be acceptable architect will have the consequence of
consist of a minimum of two layers of for use on interior supports of adding thousands of dollars in costs to
nominal 2″ thick pressure-treated wood, permanent foundations, where any the purchase price of homes placed in
or a single layer of pressure-treated material longevity issues are satisfied. manufactured home communities, not

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to mention the additional costs resulting Construction of Frost-Protected Shallow modular, panelized, or stick-built home
from either the relocation of, or damage Foundations. By permitting the use of under an LAHJ.
and disruption to, the underground these alternative methods and not Comment: Without a clear definition
utility infrastructure such as water and requiring foundations to be placed for a permanent foundation, how will it
sewer lines, electric supply lines, and below the frost line, HUD believes that be determined whether the proposed
cable and telephone lines. problematic situations with utilities and permanent foundation is adequate?
Comment: Manufactured home land- in existing land-lease communities, as Comment: ‘‘Designs for permanent
lease communities do not have any described by the commenters, are foundations (such as basements, crawl
flexibility in being able to shift a home reduced. spaces, or load-bearing perimeter
even a few inches on a lot to avoid the Comment: Figure A to § 3285.312 foundations) may be permitted to be
intersection of the frost-free foundation Typical Blocking Diagram for Single obtained from the home manufacturer,
system with the existing infrastructure. Section Homes. Footnote 4 of this figure or designed by a registered professional
Further, frost-free foundation systems should be revised by changing the engineer or architect, and constructed in
would require state-mandated lease reference from ‘‘atrium doors’’ to accordance with local building code
agreements to be modified to reflect ‘‘sliding glass doors,’’ to maintain requirements.’’ This is the proper
who the responsible party will be if a consistency with other requirements in performance-based language for any
home’s concrete slab needs to be the Model Installation Standards. section on permanent foundations.
removed for emergency repairs or for HUD Response: Footnote 4 has been Comment: HUD has materially
maintenance work to the park’s revised in the final rule to refer to patio deviated from the intent of the MHCC
infrastructure beneath the home. In doors and sliding glass doors instead of language by allowing states and
addition, digging frost-free foundations atrium doors. localities to mandate that permanent
could cause damage to existing utility Comment: Figure C to § 3285.312
foundations be used.
services. Further, land-lease Footing Configuration Layout Designs.
Comment: HUD should permit states
communities have allowed Figure C should be deleted from the
or local governments to impose
manufactured homes to be supported final rule, since it is based on 16″ x 16″
requirements for homes on permanent
upon concrete block piers resting on footing pads; stacked footer layouts that
foundations in accordance with local
either concrete ‘‘ribbons’’ or on concrete could lead to poor foundation
governing codes, as long as the design
pads under the home. These systems performance and that are inconsistent
exceeds the model standard, and HUD
have proven successful and provide an with the size and thickness of footing
should not limit mortgage lenders from
affordable alternative to supports pads (i.e., 2′ x 2′ pre-cast concrete pads)
establishing financing eligibility
embedded within the soil, if proper typically used in installing
requirements or underwriting standards
skirting and flexible utility connections manufactured homes. In addition, the
that provide greater protection than the
were properly installed. The provisions use of footing layout configurations is
model standard.
of the proposed HUD standards overly conservative, not cost-effective,
requiring supports to be installed to or and should not be used as a minimum Comment: Section 3285.314(a) should
below frost depth should be limited to standard. be deleted and replaced with, ‘‘The
apply only to those homes permanently HUD Response: HUD agrees with the placement of a manufactured home on
installed as real estate. commenters, and Figure C has been a permanent foundation must be in
Comment: If it is determined that deleted from the final rule. accordance with state [or LAHJ]
interior footings at crawl space finished Comment: § 3285.314 Permanent requirements, installed in accordance
grade, or at least at a reduced depth, are Foundations/HUD Question: Should the with the listing by a nationally
appropriate in frost climates on Model Installation Standards include a recognized testing agency based on a
perimeter-insulated foundation designs, definition and expanded requirements nationally recognized testing protocol,
then this determination should also for permanent foundations? If so, what or installed in accordance with the
extend to permanent foundations. specifics should be considered and manufacturer’s approved permanent
Placing all interior footings at frost included in the Model Installation foundation installation instructions and
depth below grade is unnecessary and Standards? in all cases, based on the home’s design
will make manufactured homes less Comment: The model (minimum) and load requirements of the
affordable, as the cost is estimated to be standard should not require Manufactured Home Construction and
between $3,000 and $5,000. manufacturers to provide DAPIA- Safety Standards.’’
HUD Response: The need to protect approved designs for permanent HUD Response: As suggested by a
foundation and anchorage systems foundations. This would be an added majority of the commenters, the
against the effects of frost heave is now extra cost to these producers for requirements for permanent foundations
specifically referred to in §§ 3285.312(b) complying with a requirement that their have been deleted in the final rule.
and 3285.404 of the installation buyers may not even wish to consider. HUD’s decision was based on a number
standard. HUD believes that, due to Comment: The model standard should of factors, including: (1) Under the Act,
local variability in frost depth locations, make no mention of anything states and local governments are not
local municipalities are the best sources concerning how mortgage lenders or restricted from establishing specific
for this information, and HUD will others can establish financing eligibility requirements for permanent
allow frost depth to be determined by requirements for permanent foundations, provided they comply with
the LAHJ in the final rule. Other cost- foundations. This is for the financial the minimum requirements of the
effective alternatives are permitted in institutions to decide, and this standard Model Installation Standards; (2)
the final rule, such as monolithic slabs needs to stay focused on providing a Mortgage lenders are not governed by
and insulated foundation systems, model installation standard. Financing the Model Standards; (3) HUD believes
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provided they are designed in options are outside the scope of the rule, that these requirements may be better
accordance with either accepted and such references should be deleted. addressed as part of the national test
engineering practice to address the Comment: A permanent foundation protocol for alternative foundations
effects of frost heave or in accordance under a HUD-Code home should be referred to in § 3285.301(d) that HUD is
with the SEI/ASCE 32–01, Design and subject to the same requirements as any developing together with the MHCC.

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Comment: § 3285.315 Special Snow Comment: § 3285.401(c). The current Comment: Proposed changes to
Load Conditions. The MHCC language wording sounds as if a home MUST be ground anchor testing methods are not
regarding ramadas is preferable to that installed to the design loads. The necessary because the testing protocols
used in the proposed rule, because HUD language should be changed to read as currently in place have worked well for
unnecessarily limits the use of ramadas follows: ‘‘(c) All anchoring and many years. Failures are not a result of
to areas where the snow load exceeds 40 foundation systems must be capable of test requirements; they are a result of
psf. Commenter asks why couldn’t a meeting the loads required by part 3280, not following installation instructions.
ramada be used on a home with a 20- Subpart D of the Manufactured Home Changing the testing requirements
psf roof where the snow load is 30 psf? Construction and Safety Standards would result in higher costs to
Also, the MHCC language of ‘‘self (MHCSS), for the area in which the homeowners.
supporting’’ is much clearer as to the home is located. The home’s design Comment: The rule does not address
intent than is the HUD language. must be based on the loads shown on the capacity of ground anchors in wet or
HUD Response: The final rule is the data plate, or higher.’’ Another saturated soil. The lack of specific test
revised to clarify that ramadas are to be commenter indicated that this provision standards and protocols in the rule will
self-supporting. HUD’s installation would be unnecessarily burdensome result in the actual performance of
program regulations will address and costly for foundation and anchoring different anchors under the same
requirements for placement of homes in requirements, if a home is to be sited in conditions to vary greatly. This will
accordance with the design a roof load zone or wind zone that had impact the ground anchor spacing
requirements for roof loads and other less restrictive design load requirements provided in the rule.
geographic variations as indicated on than the home had been designed to Comment: Minimum spacing of
the home’s data plate. resist. anchors is not a requirement in the
HUD Response: An exception has current anchor test protocol being
Subpart E—Anchorage Against the developed by the MHCC Installation
Wind been added to this section in the final
rule to indicate that when manufactured Subcommittee and should be
Comment: § 3285.401(c). This section considered.
homes are installed in less restrictive
lacks sufficient detail as to the HUD Response: HUD disagrees with
roof load zone and wind zone areas,
information that needs to be included in the comment that a national testing
they may have foundation or anchorage
the manufacturer’s installation protocol is not needed, because anchor
instructions for anchor assembly type systems that are capable of meeting the
performance is dependent on a number
installations. Areas that need to be lower design load provisions of the part
of factors, including soil strength, angle
addressed include: strap attachment, 3280 standards. However, this is
of pull, and size of the stabilizer plate,
strap angle, stabilizing plates, protection conditioned upon the availability of
which are not consistently being
at the sharp corners, longitudinal either a design for the lower
evaluated due to the unavailability of a
anchoring methods, and alternative requirements in the manufacturer’s
national testing requirement.
anchoring methods. installation instructions or having a
Recommendations for a nationally
HUD Response: A new paragraph (d) foundation and anchorage system
recognized testing protocol for anchors
has been added in the final rule to designed for the lower requirements by
referred to in § 3285.402(a) of the final
clarify that all of the information is a professional engineer or registered
rule are currently being developed by
required to be provided for anchor architect.
the MHCC, and when completed, are
assembly type installations. Comment: § 3285.401(d) Anchoring expected to address testing and
Comment: § 3285.401(a–c) Instructions. A new paragraph should certification of anchors in saturated
Anchoring Instructions. The Maximum be added to 3285.401: ‘‘Compliance soils.
Diagonal Tie-down Strap Spacing with the wind requirements of NFPA As part of HUD’s current research
Tables for determining anchorage 225 shall be deemed to comply with program to evaluate the MHCC draft
requirements to resist wind loads in 3285.401(a) through 3285.401(c). testing proposal and make
§ 3285.401 are intended for use under HUD Response: This comment was recommendations for a national test
specific circumstances. Since flood or not accepted, as the requirements in the method for anchoring systems, anchor
seismic loads are not considered in the final rule for anchoring are different in resistance, and behavior when anchors
tables, a new footnote should be added certain respects than those contained in are located in close proximity to each
at the end of each table to read as NFPA 225. other will also be considered.
follows: ‘‘The maximum heights and Comment: § 3285.402(a) Ground During the interim, anchors are
strap spacing specified in the table Anchor Installations. The definition for required to be capable of resisting an
assume no flood or seismic loads acting ‘‘ground anchor’’ should be changed to ultimate load of at least 4,725 pounds
on the foundation or home. These tables ‘‘ground anchor assembly,’’ as all and a working load of at least 3,150
shall not be used in flood hazard areas portions of the anchor, anchor head, pounds in any soil type or classification,
or seismic hazard areas. In these areas, bolts and nuts, stabilizer plates, etc., including saturated soils, unless
the foundation and the anchorage should be protected from corrosion. reduced ground anchor or strap
design shall be specified by a registered HUD Response: A new definition for capacities are used, as permitted in the
engineer or professional architect.’’ anchor assembly is included in the final rule.
HUD Response: The tables have been revisions to parts 3280 and 3285. Comment: 3285.402(b)(1) Ground
relocated to § 3285.402 in the final rule. However, the final rule also contains a Anchors. Ground anchors must be
A footnote has been added to each table separate definition for ground anchors. required to be installed to their full
indicating that flood or seismic loads Comment: § 3285.402(a). The depth because when ground anchors are
have not been considered and that the requirements for a nationally recognized tested they are installed to their full
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tables are not intended for use in flood ground anchor test protocol should not depth.
or seismic hazard areas. In those areas, be finalized until the MHCC HUD Response: Section 3285.402(b)
the anchorage system must be designed recommendations for the test protocol of the final rule has been revised to
by a registered professional engineer or are finalized and presented to HUD for require that ground anchors be installed
architect. its consideration. to their full depth. Ground anchors that

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are not installed to their full depth have Comment: Section 3285.402(b)(2) is Comment: The provision in Note 9 in
significantly reduced resistance to overly prescriptive and restrictive and Table 1 and Note 10 in Tables 2 and 3
lateral, longitudinal, and uplift forces. should be modified to permit pan- should be revised to require that ground
Comment: § 3285.402 Ground bracing or other types of bracing anchors be installed in accordance with
Anchor Installations. This section of the systems to be used for longitudinal the ground anchor manufacturer’s
proposed rule would require anchoring. The standard should be instructions and not the home
galvanizing of ground anchors, anchor modified to permit pan-bracing systems manufacturer’s instructions.
equipment, and stabilizing plates to be to be used, unless there is data Comment: The ‘‘second beam
zinc-coated in all instances. This is indicating such systems are insufficient method’’ provided in Tables 2 and 3 is
inconsistent with § 3280.306(g) of the for this purpose. not a viable option because of potential
Manufactured Home Construction and HUD Response: Longitudinal damage to HVAC ducts, plumbing, etc.,
Safety Standards that permit anchoring anchoring is required to be provided to in the floor. If the ‘‘second beam
equipment to have a resistance to resist the design wind forces in all wind method’’ is retained, a cautionary note
weather deterioration at least equivalent zones in the final rule based on the should be added to the tables to warn
to that provided by a coating of zinc on recommendations of the MHCC, NFPA of potential damage.
steel of not less than 0.30 oz./ft2. It also 225, and engineering analysis. As Comment: The anchor test protocol
would preclude other acceptable forms suggested by the commenters, a new currently being developed by the MHCC
of acceptable corrosion protection from Figure C to § 3285.402 has been added Installation Subcommittee is
being used, such as stainless steel, in the final rule to provide an example recommending a 30-degree minimum
epoxy coatings, and even mill method for providing the longitudinal angle for testing anchors in the diagonal
galvanizing, which are acceptable anchoring required by the final rule. direction. As such, 18-foot-wide units at
methods of corrosion protection in the Section 3285.402(c)(3) has also been 25″ or less in height from the ground to
site-building industry. Has HUD revised in the final rule to permit the the attachment point on the frame
considered the economic impact of use of alternative systems, such as pan- represent the only situation where the
requiring all anchoring equipment to be bracing type systems, provided they are 30-degree minimum angle from
zinc coated? capable of resisting the wind forces in horizontal cannot be maintained. Rather
Comment: Not all ground anchor the longitudinal direction. than unnecessarily limiting anchor
assemblies will require the use of steel Comment: § 3285.402 Figure B performance, HUD should require the
stabilizer plates. If a ground anchor Anchor Strap and Pier Relationship. minimum height for 18-foot sections to
assembly is tested to be listed or Note 2 (the diagonal ties footnote) be 33 inches or higher.
certified according to the Ground should be removed, as there are other Comment: A footnote should be
Anchor Test Protocol currently under methods of preventing rotation of the I added to Tables 2 and 3 to indicate that
consideration by the MHCC beam, including cross member the tables are based on a maximum force
Subcommittee on Installation, that placement. The sentence should be of 1,640 lbs. being resisted by vertical
design should be able to be listed as a reworded to state: ‘‘When strap is tie straps. This is the maximum tension
certified anchor assembly under that attached to bottom of I beam, the I beam in the vertical strap as a result of tie-
section. must be designed to prevent rotation.’’ down calculations used to develop the
HUD Response: HUD agrees with the HUD Response: Section tables. This note is important to
commenters and § 3285.402(c)(2) of the 3285.401(d)(3) and Note 2 to Figure B properly size sidewall strap attachment
final rule has been revised to indicate on Anchor Strap and Pier Relationship components and brackets.
that if metal stabilizer plates are used, have been revised in the final rule to HUD Response: The tables for
they must be provided with protection indicate that when diagonal ties are not diagonal strap spacing are based on
against weather deterioration and attached to the top flange of the main recommendations from the MHCC and
corrosion at least equivalent to that chassis beam, that the frame must be represent the most commonly used
provided by a coating of zinc on steel designed to prevent rotation of the main chassis beam spacing of 82.5
of not less than 0.30 oz./ft2 of surface beam. inches and 99.5 inches and sidewall
coated. This paragraph of the final rule Comment: Tables 1–3 to § 3285.402. height of 90 inches. Other main beam
also indicates that ABS stabilizer plates The information listed in the tables does spacing configurations or sidewall
may be used when listed and certified not include tie-down strap spacing heights must be designed by a
for such use. requirements for 36-foot-wide units. The professional engineer or registered
Comment: § 3285.402 Ground tables should be expanded to also architect. The tables for diagonal strap
Anchor Installations. Longitudinal include 75.5″ I-Beam spacing, because spacing were developed based on a 4″
Anchoring. Longitudinal anchoring homes are currently being constructed maximum inset. Other insets for ground
should not be required in wind zone 1 to that specification. Also, the tables anchors are permitted, provided they
locations. should be expanded to include other are included in the installation
Comment: A figure illustrating the sidewall heights, such as 84″, 96″, and instructions or designed by a
installation of longitudinal anchors and 108″, which are industry standards. professional engineer or registered
tie-down straps should be provided Comment: Note 2 of the tables architect.
showing the correct and incorrect specifies maximum 4″ inset of the Note 6 in Table 1 and Note 7 in Tables
methods of attachment of the tie-down anchor head, but an inset of 6″ is more 2 and 3 on minimum height between the
straps to the chassis beams, as indicated typical to allow for skirting and ground and floor joist has been revised
in note 2. Also, further illustrations perimeter wall or piers. in the final rule, in accordance with the
should be included to show the correct Comment: In Note 6 for Table 1 and above comments. Spacing requirements
and/or incorrect methods of ground Note 7 for Tables 2 and 3, the second for 18-foot section widths were removed
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anchor installations, such as stabilizer sentence should be revised to read as from the Tables 1 through 3 for
plates, strap attachment (swivel strap, follows: ‘‘Table based upon the consistency with other tables in other
frame tie w/hook, frame tie w/buckle), minimum height between the ground chapters of these installation standards.
proper strap tensioning, and concrete and the bottom of the floor joist being Tables 1 through 3 have also been
slab anchors. 18 inches.’’ revised in the final rule by providing

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additional conditions for the minimum engineering practice must design appliance manufacturer’s instructions
and maximum angles for their anchorage for the special wind may not address all requirements that
applicability and use in determining the conditions. Compliance with the severe would be included in local or state
maximum spacing of diagonal tie-down wind requirements of NFPA 225 shall codes enforced by the LAHJ.
straps in Wind Zones I, II, and III. These be deemed to comply with 3285.405.’’ Comment: The word ‘‘must’’ could be
limitations were recommended by the HUD Response: The final rule does confusing when referring to optional
MHCC Installation Subcommittee based not include a provision that recognizes appliances. These appliances are
on the unfavorable results of anchor the wind and anchoring provisions of optional, but the language could be read
tests in weak soils, where the angle of NFPA 225 as deemed to comply with to require them to be mandatory.
pull on the anchor was 30 degrees or these standards, as those requirements Accordingly, the section should be
less. As a result, a number of the far are not consistent with these standards. clarified to read as follows: ‘‘Comfort
beam spacing provisions are no longer For purposes of installation, a state or cooling systems installed by someone
applicable for use with the tables, LAHJ can establish more stringent wind other than the home manufacturer, must
although such provisions may be used design provisions for anchoring than are be done according to the appliance
in accordance with a site-specific design required by these minimum standards. manufacturer installation instructions.’’
approved by an architect or engineer. Comment: § 3285.406 Flood Hazard Comment: Minimum standards found
In the final rule, HUD did not include Areas. The section should be reworded in the International Residential Code
information on vertical tie strap to read as follows: ‘‘In flood hazard (IRC) and International Fuel Gas Code
capacity for connections, as this needs areas, the piers, anchoring, and support should be referenced for various
to be considered in the manufacturer’s systems must be capable of resisting all appliances and ventilation requirements
designs and installation instructions combined loads associated with design in this chapter.
and is, therefore, not specified in the flood and wind events.’’ This is Comment: While ventilation
tables. particularly important in geographic requirements should be consistent with
Comment: § 3285.404 Severe areas susceptible to hurricanes where model building codes, referencing the
Climatic Conditions. Under § 3285.404, the homes will be subjected to high model codes in these standards would
it should be acceptable for ground winds and saturated soil create yet another document that will
anchors to be installed above the frost simultaneously. The scouring effects of need to be updated and revised.
line, when the footings for the both wind and water forces also need to HUD Response: These installation
foundation system are frost-protected be addressed regarding the anchoring standards are minimum requirements
against the effects of frost heave. There and support system components. that a state or local jurisdiction must
should be a reference to § 3285.312(c), HUD Response: A reference to meet or exceed for any provision of
in which the approved alternate anchoring requirements in flood hazard these standards, including optional
anchoring system may be included as areas has been included in § 3285.302 of features covered by this subpart.
part of a listed or labeled foundation the final rule. Accordingly, HUD is not preempting
support system (floating slab or state or local authority in these areas as
insulated foundation). Subpart F—Optional Features suggested by the commenters, as states
HUD Response: Section 3285.404 of Comment: § 3285.502 Expanding and municipalities may adopt
the final rule has been revised to permit Rooms. The first sentence of this section additional requirements for the
ground anchors to be installed above the should be revised to read as follows: installation of optional appliances.
frost line, provided the foundation ‘‘The support and anchoring systems for References to the International
system is frost protected to prevent the expanding rooms must be installed in Residential Code (IRC) or International
effects of frost heave, in accordance accordance with designs provided by Fuel Gas Code (IFGC) were not
with acceptable engineering practice the home manufacturer or prepared by presented to the MHCC or suggested to
and §§ 3280.306 and 3285.312. a registered professional engineer or the Department during the development
Comment: § 3285.405 Severe Wind registered architect in accordance with and issuance of the proposed rule.
Zones. As more stringent anchorage acceptable engineering practice.’’ As Accordingly, they cannot be considered
design requirements may be specified proposed, the paragraph suggests that for introduction at this time into the
elsewhere in these standards, by the only a registered professional engineer final rule. However, the commenter may
LAHJ or the state, wind-resistant or architect can design the installation. want to re-introduce them again when
anchorage provisions contained in HUD Response: The final rule has subsequent revisions to the installation
NFPA 225 should be deemed been revised to also allow designs for standards are being considered by HUD.
acceptable, and should be referenced for support and anchoring of expanding The final rule also indicates that
use by installers, designers, and LAHJs, rooms to be provided by the home when not provided and installed by the
if they so choose. The section should be manufacturer as an alternative to manufacturer, any comfort cooling
revised to read as follows: ‘‘When any designs having to be prepared by a system that is installed must be
part of a home is installed within 1,500 professional engineer or registered installed according to the appliance
feet of a coastline in Wind Zones II or architect. manufacturer’s instructions.
III, the manufactured home must be Comment: § 3285.503 Optional Comment: § 3285.503(a)(1)(i) Energy
designed for the greater of the increase Appliances. These items [all optional Efficiency. The references within this
requirements as specified (1) on the features] are clearly under the scope of section should be clarified as to what
home’s data plate (refer to § 3280.5(f) of state and local codes. It would seem that constitutes proper operation and energy
this chapter), (2) elsewhere in these HUD would be preempting such efficiency and closely match, with
standards, or (3) by the LAHJ or state, authority by state and local government regard to heat gain for sizing, site-
and in accordance with acceptable to address such items. installed air conditioning systems. Also,
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engineering practice. Where site or other Comment: Section 3285.503(a) should the requirements for determining heat
conditions prohibit the use of the also include a reference to the LAHJ and gain do not appear to include a
manufacturer’s instructions, a registered local or state code requirements, in calculation for latent heat gain.
professional engineer or registered addition to requirements in the Comment: ASHRAE and other energy
architect in accordance with acceptable manufacturer’s instructions. The standards require the calculation of the

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design cooling load, provide the appliance air inlets and exhausts in with other model codes and have not
standards by which such load is flood hazard areas are to be located at been changed in the final rule, with the
calculated, and then require the or above the lowest floor elevation of exception of the minimum access
equipment chosen to be the next size the home. opening dimensions and requirements
available that meets that load to be Comment: § 3285.503(d) Figure for operable or adjustable type openings
chosen. Dryer Exhaust System. The illustration to be provided in areas subject to
HUD Response: Section shows a reverse slope that does not freezing. The access opening has been
3285.503(a)(1)(i) of the final rule has agree with Note 2. increased in § 3285.505(e) of the final
been revised to eliminate the references HUD Response: The illustration has rule from 18 inches in any direction to
to: (1) ‘‘For proper operation and energy been corrected to eliminate the reverse 18″ by 24″ in height. In addition, the
efficiency’’ and (2) sizing site-installed slope. term ‘‘metal’’ has been deleted in
air conditioning systems to ‘‘closely Comment: § 3285.504 Skirting. To paragraph (d) and replaced with
match’’ the home’s heat gain ensure performance, uniformity, and ‘‘corrosion and weather resistant’’
requirement. The final rule now repeatability, some standard should be covering. The final rule also requires
provides that the air conditioning referenced to determine that the openings for ventilation to be placed as
system must meet the heat gain materials used for skirting are weather- high as practicable above the ground.
requirement. In addition, the reference resistant.
to the term ‘‘sensible’’ has been deleted Comment: All wood skirting within 6″ Subpart G—Ductwork and Plumbing
in the final rule so that air conditioning of the ground should be pressure-treated and Fuel Supply Systems
systems are now required to be sized to in accordance with the AWPA standard Comment: § 3285.601 Field
meet the home’s overall heat gain. U1 for Use Category 4A ground contact Assembly. HUD should clarify if the
Comment: § 3285.503(a)(1)(iii) A- applications or be naturally resistant to section refers to manufacturer-supplied
coil Units. Simply stating that the air decay and termite infestations. This shipped loose duct systems, because, as
conditioning unit is to be compatible for would allow a lower requirement for presently written, any loose duct would
use with the furnace may not be enough skirting materials than for footing pads, be covered by the rule.
to ensure safety and performance. What since it is a non-structural application. HUD Response: The final rule now
about the furnace’s manufacturer’s HUD Response: Performance criteria refers to ‘‘manufacturer-supplied
instructions and warranties? for protection against weather shipped loose ducts,’’ to clarify the
HUD Response: The final rule has deterioration for skirting materials have intent of this section.
been revised to require that A-coil air been included in the final rule and Comment: § 3285.603(c) Mandatory
conditioning units must be compatible pressure-treatment requirements for Shutoff Valve. This section should be
and listed for use with the furnace and wood skirting have been revised, as modified to require the mandatory
also comply with the appliance suggested by the commenter. shutoff valve to be accessible and
manufacturer’s instructions, as Comment: § 3285.505(a) Crawlspace clearly identifiable.
recommended by the commenters. Ventilation. Consider model building HUD Response: Section 3285.603(c) of
Comment: § 3285.503(a)(2) Heat code requirements for ventilation the final rule has been revised to require
Pumps. The section as proposed does requirements, as the proposed the master shutoff valve to be both
not provide any sizing criteria for heat requirement for ventilation of one accessible and identifiable, as suggested
pumps and should refer to minimum square foot for every 1,500 square feet by the commenter.
standards that would apply to such is insufficient. There should also be not Comment: § 3285.603(d) Freezing
equipment. less than four vents in order to control Protection. The term ‘‘heating cable’’
HUD Response: Heat pumps must be humidity and for management of mold/ should be replaced with the more
sized to meet the requirements of the mildew and temperature handling. commonly used term, heat-tape.
Manufactured Home Construction and Comment: § 3285.505(b). The section Comment: What is ‘‘normal
Safety Standards, 24 CFR part 3280. should be revised to read as follows: occupancy,’’ as referred to in
Comment: § 3285.503(c) Appliance ‘‘Ventilation openings must be placed as § 3285.603(d), and what would then
Venting. This section should be revised high as practicable above the ground.’’ constitute ‘‘abnormal occupancy’’?
to be consistent with the wording in 24 Comment: § 3285.505(d) Crawlspace HUD Response: Sections
CFR 3280.707(b), as follows: ‘‘Heat Ventilation. The word ‘‘metal’’ should 3285.603(d)(1) and (2) have been revised
producing appliances, except ranges be eliminated from § 3285.505(d) to to delete reference to the term ‘‘under
and ovens, must exhaust to the exterior allow other materials to be used for normal occupancy,’’ as suggested by the
of the home.’’ ventilation openings that may perform commenters. However, heating cable is
HUD Response: Section equal to or better than metal. the correct term to be used to describe
3285.503(c)(1) and (2) of the final rule Comment: Ventilation openings this material and, accordingly, no
have been revised to be consistent with should be covered with a perforated change is being made to this section in
the requirements of the Manufactured rodent resistant covering resistant to the final rule. A conforming change to
Home Construction and Safety decay. the term ‘‘heating cable’’ will also be
Standards, as recommended by the Comment: Requirements for operable made in future revisions now
commenter. louvers should be addressed in cold contemplated for the MHCSS.
Comment: § 3285.503(d) Flood climates. Comment: § 3285.605 Fuel Supply
Hazard Areas/HUD Question. Where Comment: § 3285.505(e). A minimum System. The first sentence of
should the outside appliance air inlets access opening of not less than 24″ by § 3285.605(a) should be revised as
and exhausts be located with respect to 30″ or five square feet should be follows in order to be consistent with
the base flood elevation in flood hazard required. An opening less than 18″ in the requirements specified in 24 CFR
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areas? any dimension is typically not large 3280.705(a): ‘‘The gas piping system in
HUD Response: The requirements enough for service personnel to access the home is designed for a pressure that
have been relocated to underneath the home. is at least 7 inches of water column
§ 3285.102(d)(2)(ii) in the final rule and HUD Response: The ventilation * * * and not more than 14 inches of
revised to indicate that exterior requirements are generally consistent water column * * *’’.

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HUD Response: The requirements for that the crossover duct must be listed materials that are not designed to be
testing of gas piping systems in the final for exterior use. exposed to the weather are to be covered
rule have been revised to be consistent with plastic sheeting.
Subpart H—Electrical Systems and Comment: § 3285.801(d) Joints and
with the testing requirements in the
Equipment Seams. Any holes made in the roof must
Manufactured Home Construction and
Safety Standards. Comment: § 3285.702(d) be sealed, utilizing approved methods
Comment: § 3285.606 Ductwork Miscellaneous Lights and Fixtures. and materials.
Connections. Mastics approved to UL Ceiling fans must be attached to a Comment: The type of acceptable
181 should be used in all cases to seal properly installed junction box that is sealant should be specified in the Model
connections to prevent air leakage. listed for ceiling fan application. Installation Standards for sealing the
However, mastics should not be used as HUD Response: Section holes.
the only means of connection. Tapes, 3285.702(e)(1) of the final rule has been HUD Response: Section 3285.801(d)
regardless of whether they are approved revised to refer to Article 314.27(b) of has been revised in the final rule by
or not, should not be allowed, except to the National Electrical Code, NFPA No. clarifying that the roofing must be made
aid in the installation of the ductwork 70–2005, for connection requirements of weatherproof and any holes sealed with
for temporary securement. the ceiling fan to the electrical junction a sealant that is suitable for use with the
Comment: UL standards 181A and box and to require the junction box to type of roofing in which any hole is
181B should be referenced for the be listed and marked as suitable for made.
sealing of duct systems. ceiling fan application. Comment: § 3285.801(e) Mate-line
Comment: The term metal plumber’s Comment: § 3285.702(e) Testing. Gasket. Gaskets should also be capable
tape should be removed from Paragraph (e)(1) should be deleted in its of resisting the entry of water vapor in
§ 3285.606(a). entirety and (e)(2) should be changed to addition to air, water, insects, etc.
HUD Response: The final rule has (e)(1) and revised to read as follows: Comment: Permit installers or
been revised to clarify the requirements ‘‘After completion of all site homeowners to provide the mate-line
for sealing of ductwork connections so connections of cross-overs, exterior gasket, provided the materials comply
that the appropriate type of tapes and lights, ceiling fans, etc., each with the manufacturer’s installation
mastics are specified, depending on the manufactured home must be subjected instructions.
type of air duct being used. In addition, to the following tests, consistent with HUD Response: The final rule has
the final rule also clarifies that sheet § 3280.810 of the MHCSS * * *’’. been revised by requiring the mate-line
metal ducts must be mechanically Comment: The section should be gasket to also be capable of providing
fastened, as suggested by the revised to refer to the electrical testing resistance against water vapor entry.
commenters. The reference to ‘‘metal requirements in § 3285.810(b) of the However, HUD does not agree with
plumber’s tape’’ has also been deleted. MHCSS in order to clarify that dielectric suggestions made by commenters that
Comment: § 3285.606(e). The section tests are not required to be performed the mate-line gasket be allowed to be
should be revised to read as follows: after setup. In addition, all of provided by parties other than the home
‘‘The duct must be suspended or § 3285.702(e)(2) should be deleted as it manufacturer. This is because HUD
supported above the ground at both duplicates and contradicts what is deems the gasket material to be an
maximum 4 feet-0 inches on center already required by § 3285.810(b). integral part of the construction of the
(unless otherwise noted) and arranged HUD Response: The final rule has home to provide the resistance to the
under the floor to prevent compression been revised in a manner that is weather required by the MHCSS.
or kinking in any location, as shown in consistent with the recommendations of Comment: § 3285.801(f) Hinged
Figures A and B of this section.’’ the commenters. Roofs and Eaves/HUD Question. Should
Comment: When straps are used to the requirements for hinged roofs and
Subpart I—Exterior and Interior Close
support a flexible duct, the straps must eaves be considered installation and
Up
be at least 1⁄2″ wider than the metal subject to the Model Installation
spiral spacing of the duct, and installed Comment: Figure A to § 3285.801 Standards and not construction, as
such that the straps cannot slip between Installation of Field-Applied Horizontal proposed by HUD?
any two spirals. Lap Siding. The notes and figure need Comment: A hinged roof should be
HUD Response: Section 3285.606(e) to be less specific and revised to read as treated as construction of the home’s
has been revised in the final rule, in follows: Note 1 should be revised by roof assembly and subject to the
accordance with the recommendations changing the reference from ‘‘double requirements of the HUD Code.
of the commenters. section’’ to ‘‘multi-section.’’ Note 2 Comment: The Model Installation
Comment: Figure A to § 3285.606 should be revised to clarify that all Standards should be extended to cover
Crossover Duct Installation With Two doors and windows need not be covered any hinged roof, regardless of wind
Connecting Ducts, Figure B to with plastic sheeting, and the word zone, roof pitch, or flue penetration.
§ 3285.606 Crossover Duct Installation ‘‘fasteners’’ deleted, because installers, This is a normal construction process
With One Connecting Duct. Note 2 rather than manufacturers, generally that is occurring more routinely with
should be revised to read as follows: provide fasteners so that they are HUD Code installations and would save
‘‘Note 2. Crossover duct should be listed compatible with their installation considerable money with regard to
for exterior use.’’ equipment. The note in Figure A should Production Inspection Primary
Comment: The concrete block support be revised to read as follows: ‘‘Windows Inspection Agency (IPIA) inspection
shown in both figures should be installed with j-rail or brick mold under the on-site completion rule and
removed as an acceptable support for around it,’’ because many windows are time under the alternative construction
the crossover duct. equipped with brick mold and it serves (AC) letter process.
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HUD Response: HUD agrees with the the same purpose as the j-rail. HUD Response: It continues to be
commenters, and Figures A and B have HUD Response: As suggested by the HUD’s position that the on-site
been revised by deleting the concrete commenters, editorial revisions have completion of hinged roofs with eaves is
block support from each figure and by been made to the section and Note 2 has generally part of the construction
adding a note to each figure to indicate been clarified to indicate that only process, and that hinged roofs with

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eaves must comply with all multi-section homes. However, prior to described in the installation
requirements of the Manufactured Home completion of the close-up, gaps of up instructions.
Construction and Safety Standards (24 to one inch are allowed between
Subpart J—Recommendations for
CFR part 3280) and the Manufactured structural elements if they are closed
Manufacturer Installation Instructions
Home Procedural and Enforcement upon completion of the set-up; the
Regulations (24 CFR part 3282), even home sections are in contact with each Comment: § 3285.901
though this work is often completed other, and the mating gasket is Recommendations for Manufacturer
during the set-up of the home. providing a proper seal. Also, all gaps Installation Instructions. The reference
Accordingly, certain hinged roofs and are to be shimmed with dimensional to the ‘‘following cautions’’ in paragraph
other construction completed on-site lumber and fastener lengths are to be (c) should also include the cautions or
will continue to be subject to the increased to provide adequate recommendations in paragraphs (a) and
provisions for Alternative Construction penetration into the receiving member (b), as they are as important as the
in § 3282.14 of the Manufactured Home of the elements being joined. remaining sections of Subpart J.
Procedural and Enforcement Comment: § 3285.803(b) Interior Comment: The provisions of Subpart
Regulations, and may be also subject to Close-up. This section should be revised J do not relate to the content of
the provisions of the future rulemaking or deleted. Polyvinyl acetate (PVA) manufacturer instructions. It is
for on-site construction. However, adhesives should not be required for on- recommended that this subpart be
manufactured homes with hinged roofs site fastening of shipped loose panels. reconsidered as follows: § 3285.901(a)
and eaves are not subject to these Standard drywall fastening does not and (b), § 3285.902, and § 3285.903
special requirements if the homes: (1) require adhesive and thus there is no could be relocated to subpart B;
Are designed to be located in Wind reason for this excessive prescriptive § 3285.904 could be moved to
Zone I; (2) have a pitch of the hinged requirement. When the home has been § 3285.203; and § 3285.905 could be
roof that is less than 7⁄12; (3) have fuel designed utilizing a structural adhesive consolidated at § 3285.602.
burning appliance flue penetrations that for wall panels, the requirement should HUD Response: This subpart of the
are not above the hinge; and (4) have be specified in the installation final rule has been re-titled ‘‘Optional
been completed and inspected as part of instructions of the particular home Information for Manufacturer
the installation process under future manufacturer. Installation Instructions’’ and
rulemaking being developed for the HUD Response: Editorial revisions reorganized to include
installation program regulations. have been made to this paragraph in the recommendations that may be provided
Nevertheless, even for the above- final rule, and the final rule has been as part of the installation instructions.
described conditions, manufacturers are revised to permit alternative fastening The cautions have been removed in the
still responsible for providing methods to PVA adhesives for installing final rule and replaced with
instructions on how to complete each shipped-loose panels, if specified in the recommendations for inclusion by
hinged roof and/or eave construction, in manufacturer’s installation instructions. manufacturers in their installation
accordance with the requirements of the Comment: Figure A to § 3285.803 instructions.
Manufactured Home Construction and Installation of Field-Applied Panel. Comment: § 3285.903 Permits,
Safety Standards. What is the intent of restricting the Alterations, and On-site Structures.
Comment: § 3285.802 Structural panel width to no less than 16″ or no Planning and permitting processes, as
Interconnection of Multi-Section larger than 32″? Further, if typical well as utility connection requirements,
Homes. As proposed, the section is panels are 48″ inches in width, how can are outside HUD’s authority, but in the
unclear and needs to be clarified as to a ‘‘full size’’ panel be over 16″ but less proposed rule, HUD does provide
whether any gap is permitted along the than 32″ in width? standards for some of these items.
mate-line between sections of multi- Comment: The panel size depicted in HUD Response: The final rule makes
section homes. the figure and note should be changed recommendations, rather than
Comment: The section needs to be to read as follows: ‘‘One full-sized panel mandatory directives, for inclusion of
clarified as to whether any gap between 48 inches or less in width.’’ certain information in the installation
structural elements must be shimmed or HUD Response: As suggested by the instructions related to moving homes to
only those gaps that exceed 11⁄2 inches. commenters, the note in the figure has locations; permits, alterations, and on-
Comment: Fastener lengths would been revised in the final rule to indicate: site structures; utility system
need to be increased to provide ‘‘One full-sized panel 48 inches or less connections; and telephone and cable
adequate protection and staples or nails in width.’’ TV wiring. It contains no requirements
need to be at least 11⁄2 inches in length Comment: § 3285.804 Bottom Board that these items be actually included in
at a minimum. Repair. Prior to closure of the the instructions. The requirements for
Comment: A 11⁄2″ gap is too much underbelly cavity of the home, any areas ‘‘positioning the home’’ have been
because these homes are built in a being repaired must be inspected and deleted in the final rule.
factory environment where conditions any missing insulation replaced before Comment: § 3285.902(d). Fire
are controlled so that there should be completing the repair of the bottom separation distances should consider
tighter tolerance. The requirement board material. the requirements of the LAHJ, as well as
should be reduced to no more than 3⁄4″ Comment: Any splits or tears must be distances required in NFPA 501A.
gap between structural elements. resealed in accordance with the HUD Response: The provisions for
Comment: When home sections are in manufacturer’s installation instructions. fire separation in the final rule have
contact and the mating gasket is sealed, HUD Response: Section 3285.804(a) of been relocated to subpart B, § 3285.101,
then all gaps should be filled. the final rule has been revised to require and require installation instructions to
HUD Response: Section 3285.802(c) of any missing insulation to be replaced indicate that fire separation distances
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the final rule has been revised to clarify prior to closure and repair of any must be in accordance with Chapter 6
that upon completion of the close-up, damage to the bottom board. Section of NFPA 501A, 2003, or the
no gaps are permitted between 3285.804(b) has been revised to require requirements of the LAHJ.
structural elements being any split or tear in the bottom board to Comment: § 3285.902(a) Moving
interconnected at the marriage line of be resealed, in accordance with methods Manufactured Home to Location. One

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commenter wrote that the following systems installed at the site are not needs to take responsibility, which they
sentence should be added to the within the scope of HUD’s authority, believe should be the manufacturer.
introductory paragraph: ‘‘Inform and what makes fuel oil different from HUD Response: A definition for
contact the LAHJ before moving propane, site installed air conditioning ‘‘installer’’ is in the proposed rule for
manufactured home to the site or systems, etc? This will make it harder to the installation program regulations in
location.’’ determine who is responsible for part 3286.
HUD Response: The final rule has installation and liability, should Comment: Exclusivity of Model
been revised to indicate that the LAHJ something go wrong. Installation Standards. It is important
should be informed before moving the HUD Response: While HUD agrees for the standards or their state-adopted
manufactured home to the site. that these provisions for site-installed counterparts to be the only federal
Comment: § 3285.903(c)(3). The oil fuel tanks and systems are outside of installation standard recognized by
section should be revised to read as the scope of HUD’s authority, for fire HUD. Currently, HUD’s FHA Title II
follows: ‘‘Unless approved by the home safety and other considerations the final program references the Permanent
manufacturer’s installation instructions, rule does recommend that installation Installation Guide for Manufactured
all buildings, structures, and accessory instructions include information related Housing.
structures must be designed to support to installation and testing of oil supply HUD Response: HUD is considering
all their own live and dead loads.’’ tank and piping, in accordance with whether to amend references in its
Recent tornado and hurricane activities NFPA 31, 2001, Standard for the current Title II program to specifically
have caused many manufacturers to Installation of Oil Burning Equipment, refer to these Model Installation
realize the importance of proper Standards.
and oil furnace manufacturer
connections of site-installed structures Comment: Impact on Federal
instructions for pipe sizing and
to their homes and offer designs that Agencies. One commenter wrote that
installation procedures. HUD has not considered the impact of
incorporate the additional roof and Comment: § 3285.907 Telephone
wind loads imposed by those site the proposed rule on other federal
and Cable TV. A reference to the agencies that are engaged in purchasing
additions. applicable sections of the National
HUD Response: Section 3285.903(c) of and installing manufactured homes for
Electrical Code, NFPA 70—2005 federal purposes. Since the proposed
the final rule has been revised to require
Edition, should be incorporated in the rule does not address the regulations
any accessory building or structure to be
manufacturer’s installation instructions establishing an installation program, it
capable of supporting its own live and
for telephone and TV cable wiring and is impossible to determine if this rule,
dead loads, unless the structure is
connections. as part of a larger program, imposes any
designed to be attached to the
HUD Response: A reference to the mandates on state or local government.
manufactured home by a professional
National Electrical Code has been added HUD Response: These issues will be
engineer or registered architect or is
in the final rule to the recommendations considered as part of HUD’s federalism
otherwise specifically included in the
for installing telephone and cable TV analysis on this final rule.
manufacturer’s installation instructions.
Comment: § 3285.905 Utility System wiring. Comment: Bay Windows. The
Connections. If LAHJ requirements Miscellaneous Comments Department deleted the MHCC draft
govern utilities and LAHJ standards recommendation for inclusion of bay
vary, how can there be any meaningful Comment: Enforcement and Program window installation under the proposed
installation instruction with regard to Operation Matters. HUD received a large Model Installation Standards.
utilities? The instruction, at best, should number of comments and questions Commenters wrote that under
refer installers and residents to consult related to the operation and § 3285.801(f), a manufacturer would
with any serving utilities; and, as such, enforcement of its installation program. need to furnish installation instructions
no regulation is necessary. HUD Response: Comments and for a hinged roof so that the installer
HUD Response: The final rule has questions related to program operation would know the necessary elements of
been revised by recommending the and enforcement are not being field installation. Bay windows are
installation instructions suggest addressed in this rulemaking. Instead, similar, as they would be a ‘‘ship-loose’’
different procedures for the installer to they will be duly considered by HUD, item. In the opinion of these
follow prior to making any utility as appropriate, in response to the commenters, as long as the home is
system connection, depending on the proposed rule for the Manufactured designed properly for the product
availability of utility services, an LAHJ, Home Installation Program, 24 CFR part attachment, the manufacturer provides
or both, as well as procedures to follow 3286, that was published in the Federal DAPIA-approved installation
in rural areas where utility services are Register on June 14, 2006. instructions, and the installer can follow
not available and there is no LAHJ. Comment: § 3285.5 Definitions— those instructions, bay windows should
Comment: § 3285.905 Drainage ‘‘Installers.’’ One of the most glaring be covered under the Model Installation
Systems. The proposed language for omissions from the proposed Standards and not the Manufactured
making drainage-to-sewer system installation standards was a definition Home Construction and Safety
connections is too restrictive, as an or identification of manufactured home Standards.
installer may opt to ‘‘hard-pipe’’ the installers since, as drafted, so many HUD Response: HUD does not agree
connection without the use of an construction responsibilities are with these commenters, and will
elastomeric coupling device. redistributed to installers. While the continue to treat the site completion of
HUD Response: The final rule has proposed rule speaks as if there is one bay windows as construction that is
been revised by recommending the use installer per project, in reality there are subject to the Manufactured Home
of other methods acceptable to the LAHJ many installers involved. By failing to Construction and Safety Standards. A
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as an alternative to elastomeric define installers, responsibilities are detailed discussion of the comments
couplings for connecting the main drain being further fractured and protections and HUD’s position on hinged roofs and
line to the site sewer hookup. are weakened. The commenters eaves can be found above under the
Comment: § 3285.906 Heating Oil advocate that to ensure quality, analysis of public comments for
Systems. Since fuel oil supply tanks and durability, and safety, a single entity § 3285.801.

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Comment: Every other national design subject to the MHCSS and Procedural such modifications to the
standard and code for residential and Enforcement Regulations. manufacturer’s installation instructions.
construction, including NFPA 225 and The applicability provisions in A new paragraph (e) is being added to
NFPA 501, references more recent § 3285.1(b) were modified to indicate § 3285.2 in the final rule to require the
editions of ASCE 7 Standard for that the installation standards are not to manufacturer to include, as part of its
Minimum Design Loads for Buildings be construed as relieving manufacturers, instructions, at least one method for
and Other Structures. The Model retailers, or other parties of temporarily storing each section of a
Installation Standards must also do this responsibility for compliance with other manufactured home at the
to achieve equivalent protection to applicable ordinances, codes, manufacturer’s facility, retailer’s lot, or
manufactured homes and manufactured regulations, and laws. In addition, the the home site.
home residents. section was revised to indicate that Section 3285.4 is being revised to
HUD Response: The ASCE 7–88 manufactured homes are also subject to provide an updated list of the standards
standard is currently referenced in the the requirements of the Manufactured being incorporated by reference in the
HUD Manufactured Home Construction Home Installation and Dispute final rule. (See discussion in ‘‘V.
and Safety Standards and is used as the Resolution Programs, upon effect. A Revisions to Standards Incorporated by
basis for establishing the design load new provision, § 3285.1(c), has been Reference’’ in this preamble.) Reference
requirements for the construction included in the final rule that requires standards have the same force and effect
standards that are referenced in these HUD to seek input from the MHCC as the other Model Installation
installation standards. Accordingly, it is when considering future revisions to the Standards, except that whenever
not necessary to again reference the installation standards. (See discussion reference standards and the Model
ASCE 7 standards in these installation in II, Analysis of Public Comments). Installation Standards are inconsistent,
standards. Paragraph (a) of § 3285.2, the requirements of the Model
Manufacturer Installation Instructions, Installation Standards prevail to the
III. Section-by-Section Revisions— is being revised to clarify that the extent of the inconsistency.
Changes to Proposed Rule installation instructions must include Certain definitions have been added
In response to the public comments all topics covered in the installation or modified in § 3285.5 of the final rule
and subsequent reevaluation by HUD, standards. This paragraph is also being for terms used in the Model Installation
the following is a summary by subpart revised to require the installer to certify Standards.
of the section-by-section revisions being that it completed the installation in A new section, § 3285.6, ‘‘Final
made to the proposed rule for the Model compliance with the manufacturer’s leveling of the manufactured home,’’ is
Installation Standards, 24 CFR part instructions or an alternate design (see being added to require that a home be
3285, published in the Federal Register paragraph (c)), prepared by the adequately leveled prior to completion
on April 26, 2005. An overall editorial manufacturer or certified by a of the installation. A manufactured
change made throughout the rule was to professional engineer or architect, that home is considered to be adequately
move all tables and figures within a provides a level of protection equivalent leveled if there is no more than a 1⁄4-
section to the end of the section. This to or greater than what is required by inch difference between adjacent pier
change will promote ease of reference the installation standards. supports, and if the exterior windows
and will simplify the process of A new paragraph § 3285.2(b) is added and doors do not bind and can be
amending the rule, as may be necessary, to specify those circumstances when a operated properly.
in the future. professional engineer or registered
architect must prepare and certify that Subpart B—Pre-Installation
Subpart A—General Considerations
the manufacturer’s installation
Section 3285.1(a) in the final rule instructions meet or exceed the Model The fire separation provisions have
makes clear that the manufacturers’ Installation Standards for foundation been relocated from the recommended
installation instructions required by support and anchoring. provisions in subpart J of the proposed
§ 3285.2, including any specific The recommended provisions for rule and incorporated as part of the
operation or assembly therein, are ‘‘variations to manufacturer installation minimum requirements in subpart B,
deemed to comply with the Model instructions’’ in subpart J of the § 3285.101, as part of the pre-
Installation Standards, provided they proposed rule are being relocated to installation considerations. The final
meet or exceed the minimum paragraph (c) of § 3285.2 in the final rule requires that fire separation
requirements in the installation rule. This will require installers who distances be in accordance with NFPA
standards and do not take the home out intend to provide support and 501A or the requirements of the LAHJ,
of compliance with the MHCSS. anchorage that is either different from which could be more or less restrictive
Further, clarifications are also being the methods specified in the than NFPA 501A. This will require
added to § 3285.1(a) with regard to the manufacturer’s instructions, or that compliance with the fire separation
applicability of the installation encounter site or other conditions that distances in NFPA 501A, 2003 edition,
standards to the work necessary to join prevent the use of the instructions, to whenever there are no requirements
sections of a multi-section home first attempt to obtain site-specific established by the LAHJ. Conversely,
together. Specifically, work associated instructions from the manufacturer or, if when the LAHJ has established fire
with the connection of exterior lights, not available from the manufacturer, to separation distance requirements, the
ceiling-hung light fixtures, or fans, as obtain a design that has been prepared separation distances need not conform
identified in subpart I, is considered by a professional engineer or architect to the NFPA 501A provisions.
installation. This section is also being that is consistent with the design and Additional requirements were added
modified to clarify that work associated the MHCSS. The installer must have the for installation of manufactured homes
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with hinged roofs and eaves in professional engineer’s or registered in flood hazard areas in paragraph (d) of
§ 3285.801 and other work done on-site architect’s design approved by the § 3285.102 to include provisions for the
and not specifically identified in this manufacturer and its DAPIA prior to installation of exterior appliances.
part as close-up is not covered by the installation. DAPIA approval is Section 3285.103 is being revised to
installation standards and, as such, is necessary to enable HUD to enforce clarify that, prior to the initial

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installation of a new manufactured specifications have been designed to joists. However, when alternative
home, the installer is to verify that the resist flood loads. supports are used, the designs must
design and construction of the Tables 1, 2, and 3 to § 3285.303 for consider the additional loads in sizing
manufactured home, as indicated on the pier loads have been modified in the the pier and footing supports under the
design zone maps provided with the final rule by removing all references to main chassis beam. In addition, for roof
home, are suitable for the site location allowable soil bearing pressure and live loads of 40 psf or greater, paragraph
where the home is to be installed. In footing configurations that were (b) of this section requires that a
addition, to assist the installer in previously associated with the tables professional engineer or architect
verifying the appropriate zone location and by deleting Figure C to § 3285.312— determine the maximum sidewall
for the specific site, this section is being Footing Configuration Layout Designs support opening permitted with
revised by referring to the county and that was referenced in each of the tables. perimeter pier or other supports.
local government references that further Paragraphs (b) and (c) in § 3285.304 of Footnotes are also modified in the
define the wind zone, roof load zone, the final rule are being modified to be final rule to Figures A and B to
and thermal zone in part 3280. consistent with the provisions and notes § 3285.312, ‘‘Typical Blocking Diagrams
shown in Figures A and B to for Single Section Homes and Multiple
Subpart C—Site Preparation § 3285.306(b). Section Homes,’’ to require piers on
Section 3285.201 is being revised in Section 3285.305 has been modified both sides of exterior sidewall doors,
the final rule to indicate that, after in the final rule by requiring a minimum patio doors, sliding glass door openings,
removal of organic material, the home of 12″ of clearance between the main under jamb studs at multiple window
site must be graded or otherwise chassis frame member and the grade and openings, and other openings of 48″ or
prepared to ensure adequate drainage. all other areas of the home. greater in width.
A pocket penetrometer is now The maximum height for frame and The requirements for footings in
included in the final rule as one of the corner piers in § 3285.306(b) and (c) of paragraph (a) and (b) of § 3285.312 of
acceptable methods for determining the final rule has been reduced from 80″ the proposed rule are incorporated into
bearing capacity and soil classification to 67″ to be consistent with the paragraph (a) of this section in the final
in § 3285.202(d). Furthermore, a new maximum heights shown in the tables rule by reducing the minimum
paragraph (e) has also been included in for maximum diagonal tie-down strap compressive strength for 4″ pre-cast
this section that permits the use of an spacing in Tables 1, 2, and 3 to concrete pads from 4,000 psi to 1,200
allowable default soil bearing pressure § 3285.402. Furthermore, mortar is no psi; by noting that for 6″ or greater
of 1,500 psf, unless site-specific longer required for this range of pier poured-in-place concrete pads, slabs, or
information requires the use of lower heights, unless specified in the ribbons, reinforcing steel may be
soil bearing values. manufacturer’s instructions and the required for site-specific conditions; by
The site drainage provisions in maximum horizontal offset from the top revising the requirements for pressure-
paragraph (b) of § 3285.203 of the final to the bottom of the pier is one inch. treated footings and by changing the
rule have been revised by adding other The provisions for elevated homes in specification for their pressure
alternatives than site grading to remove the proposed rule are no longer needed treatment to a water-borne adhesive, in
any water that may collect under the and have been deleted and replaced accordance with AWPA Standard U1–
home. with new paragraph (c) in § 3285.306, 04; by requiring ABS footing pads to be
The provisions for gutters and ‘‘All piers over 67 inches high,’’ in the certified for use in the soil classification
downspouts in paragraph (f) of final rule. Mortar is not required for at the site; and by adding new
§ 3285.203 have been modified in the concrete block piers of this height, provisions to allow other types of
final rule to indicate that manufacturers unless specified by the design. footing materials, provided they are
specify in their instructions whether the A new paragraph (b) has been added listed for such use and meet all other
home is suitable for the installation of to § 3285.308 in the final rule that applicable provisions of the installation
gutters and downspouts. requires metal or other manufactured standards.
The provisions for ground moisture piers to be weather-protected against The provisions for placement of
control have been revised in paragraph deterioration and corrosion with footings in freezing climates is being
(c) of § 3285.204 of the final rule by protection that is at least equivalent to relocated from paragraph (c) in the
allowing the required vapor retarder to a coating of zinc on steel of at least 0.30 proposed rule to paragraph (b) in
be installed around or over footings oz./ft2. § 3285.312 of the final rule and is being
placed at grade and around anchors and Footnotes were added to Figures A revised to require that footings be
by requiring any void or tear in the and B to § 3285.310 to require piers to designed to resist the effects of frost
vapor retarder to be repaired. be placed on each side of any mating heave by one of the methods specified
wall opening when the opening is 48″ in this section. The final rule requires
Subpart D—Foundations or greater in width and to indicate that that conventional footings be placed
Section 3285.301(b) of the final rule for roof loads of more than 40 pfs, a below the frost line, unless an insulated
has been revised to also recognize metal professional engineer must determine footing or monolithic slab is used. In
piers as one of the possible variables to the maximum mating wall opening addition, alternatives allowing insulated
the pier and footing specifications and permitted without piers or other footings or monolithic slabs to be placed
configurations in this subpart. supports. Footnote 3 was also revised in above and not below the frost line depth
Section 3285.302 of the final rule has both figures to indicate that the must be designed by a professional
been revised to require all manufactured maximum single stack concrete block engineer or architect, in accordance
homes in flood hazard areas to be pier loads cannot exceed 8,000 lbs. with either acceptable engineering
installed on foundation supports that The requirements for perimeter pier practice or SEI/ASCE 32–01, and not
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are designed and anchored to prevent supports are modified by adding a new both, as previously indicated in the
floatation, collapse, or lateral movement paragraph (a)(ii) in § 3285.311 of the proposed rule. Furthermore, these
of the structure. In addition, final rule permitting the use of alternatives are permitted only if all
manufacturers’ instructions must alternative supports in lieu of perimeter relevant site conditions such as soil
indicate whether or not the foundation piers such as outriggers or extra floor characteristics, site preparation,

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ventilation, anchorage requirements, determined by a professional engineer paragraph (a)(1)(iii)(A) is revised by


and insulative properties of the under- or registered architect. requiring A-coil air conditioning type
floor enclosure are considered. Paragraph (b) of § 3285.402 has been units to be installed in accordance with
Figure C to § 3285.312 in the renumbered as paragraph (c) in the final the appliance manufacturer’s
proposed rule has been deleted in the rule, and paragraph (c)(1) is revised by instructions and be compatible and
final rule, as the footing configuration indicating that the spacing for ground listed for use with the furnace installed
and layouts shown in the figure were anchors and straps be no greater than in the home; a new paragraph (a)(3)(ii)
determined to be non-typical of current the spacing in the Tables 1 through 3 of is added for evaporative coolers that are
practices used in installing this section, unless designed by a not roof-mounted to be installed in
manufactured homes. professional engineer or registered accordance with the more restrictive
The table for the size and capacity of architect. A professional engineer or provisions of the listing or the appliance
unreinforced cast-in-place footings in registered architect must also prepare manufacturer’s instructions; and a new
§ 3285.312(d) is revised by limiting the the design for any conditions where the paragraph (c) is added for completion of
maximum capacity of certain footing tables are not applicable, such as for appliance venting systems for
sizes to 8,000 lbs. and 16,000 lbs., based higher sidewall conditions, or diagonal compatibility with the requirements of
on the maximum pier capacity of single strap angle-to-ground conditions that the MHCSS. In addition, the provisions
or multiple stack concrete block piers. A are below 30 degrees or exceed 60 for outside appliances and air inlets in
footnote has been added to the table degrees, etc. Tables 1 through 3 are also flood hazard areas have been relocated
indicating that higher design load revised by limiting the spacing to to § 3285.102(d)(2).
capacities may be permitted if a applicable conditions for the diagonal The weather protection and pressure
professional engineer or architect strap to between 30 degrees and 60 treatment requirements for metal and
prepares the design. degrees to the ground. wood skirting are further clarified in
Paragraph (c)(3) is renumbered as § 3285.504(a) and (c) of the final rule.
The provisions for permanent
paragraph (c)(2) and the provisions of
foundations in § 3285.314 of the The provisions for ventilation
(ii) in the proposed rule are separated
proposed rule have been deleted in the openings are revised in § 3285.505(d) of
into (ii) and new (iii) of this paragraph
final rule. The requirements for the final rule by requiring them to be
in the final rule. In addition, (iii) is also
permanent foundations can be corrosion- and weather-resistant and to
revised to require the correct size and
adequately considered and addressed be designed to resist the entry of
type of stabilizer plate to be installed, if
under the provisions of the final rule for rodents. In addition, in areas subject to
required by the listing, and by allowing
alternative foundation systems, freezing, the openings must be of the
the use of ABS stabilizer plates when
including the requirement that such adjustable type permitting them to be
they are listed and certified for such
designs be prepared by a professional open or closed, depending on the
use.
engineer or architect. climatic conditions.
Paragraph (c)(2) on longitudinal
Section 3285.315(b) for ramadas in anchoring is renumbered as paragraph Section 3285.505(f) of the final rule is
the final rule is revised by requiring (c)(3) and is revised in the final rule by being revised to require any surface
them to be self-supporting, except for providing a new Figure C as an example water runoff from the furnace, air
any weatherproofing connection that is of one acceptable method that may be conditioning, or water heater drain to be
made to the home. used for longitudinal anchoring and for directed away from the home or
attaching the longitudinal strap to the collected by other methods identified in
Subpart E—Anchorage Against Wind § 3285.503.
ground anchor and main chassis beam
A new paragraph (d) has been added of the home. Subpart G—Ductwork and Plumbing
to § 3285.401 in the final rule that Section 3285.404 of the final rule is and Fuel Supply Systems
provides the minimum information and revised to indicate that ground anchors
details that must be included in the must be installed below the frost line, Section 3285.606(c)(1) of the final rule
manufacturers installation instructions unless the foundation system is frost- is modified to require that the
for anchor type installations necessary protected to resist the effects of frost mandatory shutoff valve installed be
to secure manufactured homes against heave, in accordance with acceptable identified, accessible, and installed
the wind. engineering practice, § 3280.306 of the between the water supply and inlet.
A new paragraph (a) has been added MHCSS, and § 3285.312 of these The test pressure requirements for gas
in reorganizing § 3285.402 in the final installation standards. piping systems in § 3285.605(a) of the
rule to require each ground anchor to be The requirements for anchoring final rule are revised to be consistent
provided with installation instructions, manufactured homes in flood hazard with the testing provisions for fuel
in accordance with its listing or areas in § 3285.406 of the proposed rule piping systems in the MHCSS.
certification, and to be certified for use have been revised by relocating the Paragraph (a) of § 3285.606 of the final
in a classified soil, based on a nationally requirements to § 3285.102 in the final rule for ductwork connections is revised
recognized testing protocol. Paragraph rule and by adding reference to the to require all crossover connections to
(a) of § 3285.402 in the proposed rule relocated section in § 3285.406 of the the main duct system to be sealed to
has been renumbered as paragraph (b) final rule. prevent air leakage. Paragraph (e) is also
and has been modified in the final rule revised to require the crossover duct to
to require that anchors be installed to Subpart F—Optional Features be supported by straps spaced at a
their full depth and that anchors and The requirements for optional maximum distance of 4 feet or as
tie-down straps be protected against appliances in § 3285.503 of the final otherwise permitted by the installation
corrosion at least equivalent to that rule are being revised as follows: instructions. In addition, for flexible
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provided by a coating of zinc on steel Paragraph (a)(1)(i) requires site-installed type ducts, the straps must be at least
of 0.30 oz./ft2 of surface coated. This air conditioning equipment to be sized 1⁄2″ wider than the metal spirals

section now also requires that both the to ‘‘meet’’ the home’s heat gain rather encasing the duct and be installed so
working and ultimate load of the ground than ‘‘closely match’’ the heat gain, as that the duct cannot slip between any
anchors and anchoring equipment be indicated in the proposed rule; two spirals.

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Subpart H—Electrical Systems and mating gasket is providing a proper seal, or designed by a professional engineer
Equipment and (4) all such gaps are shimmed and or registered architect.
Paragraph (d) of § 3285.702 is revised connected to the structural element(s) The provisions for utility service
in the final rule to require that a ceiling with properly sized fasteners. connections are renumbered as
Section 3285.804 of the final rule is § 3285.904 in the final rule, and
paddle fan be connected to a junction
revised by requiring missing insulation recommendations for procedures to be
box that is listed and marked for ceiling
to be replaced prior to making any used prior to making utility service
fan application, in accordance with the
bottom board repairs, any splits or tears connections are revised in the final rule,
requirements of the NEC, 2005 edition.
to be resealed with tape or patches in as follows: (1) Where both utility
The testing requirements in paragraph
accordance with the installation services and the LAHJ are available,
(e) of § 3285.702 are also being modified
instructions, and by requiring all edges both should be consulted prior to
in the final rule to clarify that the
of repaired areas to be taped or making any connections of the
electrical system must be inspected and otherwise sealed.
tested at the site after completion of all manufactured home to the utilities; (2)
electrical wiring and connections, Subpart J—Optional Information for where no LAHJ exists and utility
lighting, and installation of any ceiling Installation Instructions services are available, the utility should
fans. be consulted before connecting the
This subpart of the final rule has been manufactured home to any utility
Subpart I—Exterior and Interior Close- re-titled and reorganized to include service; and (3) in rural areas where no
up recommendations that may be provided LAHJ or utility services are available, a
as part of the installation instructions. professional should be consulted prior
Section 3285.801(d) is revised in the The final rule also clarifies in a new
final rule to require any holes that are to making any system connections.
section, § 3285.907, that any other
made in the roofing to be made The provisions for heating oil systems
information manufacturers may want to
weatherproof and sealed with an are renumbered as § 3285.905 in the
provide in their instructions that is not
exterior sealant that is suitable for use final rule and the recommendations for
specifically addressed in this subpart
with the roofing material. the installation instructions are revised
must be consistent with the Model
The requirements for hinged roofs and in the final rule to indicate that homes
Installation Standards and not take the
eaves in § 3285.801(f) of the final rule with these systems and storage tanks be
home out of conformance with the
are revised to require compliance with tested to in accordance with NFPA 31,
MHCSS.
all requirements of the MHCSS (24 CFR The general provisions in § 3285.901 Standard for Installation of Oil Burning
3280) and the Manufactured Home are revised by also including ‘‘access’’ to Equipment, 2001 edition, or, if
Procedural and Enforcement the site as another area that is outside applicable, to the more stringent
Regulations (24 CFR 3282). While this of HUD’s authority and that may be requirements of the LAHJ.
work is often completed during the set- governed by the LAHJ. The provisions for telephone and
up of the home, it is not considered to Provisions addressing variations to cable TV in the proposed rule are
be installation, but work associated with manufacturers installation instructions renumbered as § 3285.906 in the final
the construction of the home and in the proposed rule have been rule and it is recommended that the
therefore subject to HUD’s MHCSS. As relocated to § 3285.2(b) in the final rule. installation instructions explain that
such, certain hinged roofs continue to Section 3285.902 of the final rule is these services should be installed in
be subject, as appropriate, to the revised by recommending that the accordance with the requirements of the
provisions of Alternative Construction installation instructions include LAHJ or the NEC, NFPA No. 70–2005.
in § 3282.14 and the provisions of the recommendations that the home should IV. Revisions to Standards
future rulemaking for on-site not be moved to the site until: (1) The Incorporated by Reference (Reference
construction, upon effect. Currently, LAHJ is informed, (2) the site is Standards)
manufactured homes with hinged roofs prepared in accordance with Subpart C
are not subject to these special of the Model Installation Standards, and The following is a list of the standards
requirements, if the homes are: (1) (3) utilities are available as required by incorporated by reference that is being
Designed to be located in Wind Zone I, the LAHJ. In addition, recommended revised from those in the proposed rule
(2) the pitch of the hinged roof is less provisions for: (1) Positioning the home by this final rule.
than 7/12, and (3) fuel burning in the proposed rule have been Added:
appliance flue penetrations are not relocated to § 3285.6 of the final rule, (2) AWPA—American Wood-Preservers’
above the hinge. However, even for the fire separation distances in the proposed Association, P.O. Box 388, Selma,
above-described conditions, rule have been relocated to § 3285.101 Alabama 36702.
manufacturers are still responsible for in the final rule, and (3) requirements AWPA M4–02, Standard for the Care of
providing instructions on how to for drainage structures have been Preservative-Treated Wood Products,
complete each hinged roof or eave relocated under paragraph (b) of this 2002.
construction in accordance with the section in the final rule. AWPA U1–04, Use Category System;
requirements of the MHCSS. Encroachment and setback distances User Specification for Treated Wood,
Section 3285.802(c) of the final rule is in the proposed rule have been 2004.
revised by clarifying that no gaps are relocated under § 3285.903, ‘‘Permits, APA—The Engineered Wood
permitted between structural elements alterations, and on-site structures,’’ in Association, 7011 South 19th Street,
along the mate-line of multi-section the final rule. In addition, paragraph (c) Tacoma, Washington 98411,
homes upon completion of the exterior of this section in the final rule is telephone number (253) 565–6600, fax
close-up. However, the final rule does modified to indicate that each accessory number (253) 565–7265.
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permit minor gaps, up to one inch, prior building and structure is to be designed PS1–95, Construction and Industrial
to completion of the exterior close-up to support its own live and dead loads, Plywood (with typical APA
provided: (1) All such gaps are closed unless the structure is attached to the trademarks), 1995 edition.
before completion, (2) the home sections manufactured home and otherwise NFPA Publications—National Fire
are in contact with each other, (3) the included in the installation instructions Protection Association, 1

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Batterymarch Park, Quincy, displays a currently valid control language of the Act and as set forth in
Massachusetts 02169–7471. number. § 3285.1 of this rule, these Model
NFPA No. 70, National Electrical Code, Installation Standards are not
Unfunded Mandates Reform Act
2005. preemptive, but rather establish
U.L.—Underwriters Laboratories, 333 Title II of the Unfunded Mandates minimum levels of protection to
Pfingsten Road, Northbrook, Illinois Reform Act of 1995 (2 U.S.C. 1531– residents of manufactured homes.
60062. 1538) (UMRA) establishes requirements The Model Installation Standards,
UL 181A, Standard for Safety Closure for federal agencies to assess the effects without the implementing regulations to
Systems for Use with Rigid Air Ducts of their regulatory actions on state, be developed for the federal installation
and Air Connectors, 1994, with 1998 local, and tribal governments, and on program, establish requirements for
revisions. the private sector. This rule does not installation instructions, but do not
UL 181B, Standard for Safety Closure impose any federal mandate on any have an impact on state-based
Systems for Use with Flexible Air state, local, or tribal government, or on installation programs and standards.
Ducts and Air Connectors, 1995, with the private sector, within the meaning of These minimum requirements do not
1998 revisions. UMRA. affect governmental relationships or
Removed: Environmental Review distribution of power. This rule does not
AWPA—American Wood-Preservers’ establish any responsibilities for states
A Finding of No Significant Impact and localities, but rather establishes
Association, P.O. Box 388, Selma, (FONSI) with respect to the
Alabama 36702. minimum requirements to be used by
environment was made at the proposed home manufacturers in the design of
AWPA C2, Standard for the Preservative rule stage, in accordance with HUD
Treatment of Lumber, Timber, Bridge manufactured home installation
regulations at 24 CFR part 50, which instructions. Therefore, HUD has
Ties and Mine Ties, by Pressure implement section 102(2)(C) of the
Processes, 2001. determined that the Model Installation
National Environmental Policy Act of Standards, if adopted, have no
AWPA C9, Plywood—Preservative
1969 (42 U.S.C. 4332(2)(C)) and remains federalism implications that warrant the
Treatment by Pressure Processes,
applicable to this final rule. The FONSI preparation of a Federalism Assessment,
2000.
is available for public inspection during in accordance with Executive Order
V. Findings and Certifications regular business hours in the Office of 13132.
the Rules Docket Clerk, Office of
Regulatory Planning and Review Regulatory Flexibility Act
General Counsel, Department of
The Office of Management and Budget Housing and Urban Development, 451 The Regulatory Flexibility Act (5
(OMB) reviewed this rule under Seventh Street, SW., Room 10276, U.S.C. 601 et seq.) requires that a
Executive Order 12866 (entitled Washington, DC 20410. Due to security regulation that has a significant
‘‘Regulatory Planning and Review’’). measures at the HUD Headquarters economic impact on a substantial
OMB determined that this rule is a building, please schedule an number of small entities, small
‘‘significant regulatory action,’’ as appointment to review the docket file by businesses, or small organizations
defined in section 3(f) of the order calling the Regulations Division at (202) include an initial regulatory flexibility
(although not an economically 708–3055 (this is not a toll-free analysis describing the regulation’s
significant regulatory action, as number). Hearing- or speech-impaired impact on small entities. Such an
provided under section 3(f)(1) of the individuals may access this number analysis need not be undertaken if the
order). The docket file is available for through TTY by calling the toll-free agency has certified that the regulation
public inspection between 8 a.m. and 5 Federal Information Relay Service at will not have a significant economic
p.m. weekdays in the Office of the Rules (800) 877–8339. impact on a substantial number of small
Docket Clerk, Office of General Counsel, entities.
Department of Housing and Urban Executive Order 13132, Federalism HUD has conducted a material and
Development, 451 Seventh Street, SW., Executive Order 13132 (entitled labor cost impact analysis for this rule.
Room 10276, Washington, DC. Due to ‘‘Federalism’’) prohibits, to the extent The completed cost analysis determines
security measures at the HUD practicable and permitted by law, an the cost difference between a typical
Headquarters building, please schedule agency from promulgating a regulation installation conforming to the Model
an appointment to review the docket file that has Federalism implications and Installation Standards from an
by calling the Regulations Division at either imposes substantial direct installation completed in accordance
(202) 708–3055 (this is not a toll-free compliance costs on state and local with current manufacturer installation
number). Hearing- or speech-impaired governments and is not required by instructions. A typical installation is
individuals may access this number statute, or preempts state law, unless the defined by the traditional installation
through TTY by calling the toll-free relevant requirements of section 6 of the method consisting of concrete footings,
Federal Information Relay Service at 1– Executive Order are met. This rule does masonry piers, and ground anchors. The
(800) 877–8339. not have Federalism implications and cost difference was found to vary
does not impose substantial direct slightly depending upon whether the
Paperwork Reduction Act compliance costs on state and local home is a single-section or multi-section
The information collection governments or preempt state law home. HUD has determined the
requirements contained in this rule are within the meaning of the Executive following recommended Installation
currently approved by OMB under Order. Standards would potentially affect the
section 3504(h) of the Paperwork HUD is required by statute to cost of the installation of manufactured
Reduction Act of 1980 (44 U.S.C. 3501– establish Model Manufactured Home homes over and above the installation
sroberts on PROD1PC70 with RULES

3520) and assigned OMB Control Installation Standards through the costs currently incurred using the
Number 2502–0253. An agency may not National Manufactured Housing manufacturer’s installation instructions:
conduct or sponsor, and a person is not Construction and Safety Standards Act 1. Manufacturer review and revision of its
required to respond to a collection of of 1974 (42 U.S.C. 5401–5426). manufactured home installation manual
information, unless the collection However, in accordance with the (§ 3285.2).

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2. Proper drainage slope away from the these are primarily mobile home set-up not provide an exemption for small
home (§ 3285.203). and tie-down establishments. The rule entities. This rule does not establish any
3. Vapor barrier lap at joints (§ 3285.204). thus would affect a substantial number responsibilities for installers; rather, it
4. Ensure proper configuration for concrete of small entities. However, the home establishes model requirements used by
piers (§ 3285.304).
5. Ensure proper orientation and location
manufacturers would only be subject to manufacturers in the design of
of pier supports (§ 3285.306). an associated labor cost necessary to manufactured home installation
6. Certification and testing of ground revise its instructions, and the home instructions.
anchors (§ 3285.402). installer would be subject to increased
labor and material costs that would be Catalogue of Federal Domestic
7. Water line shut-off valve (§ 3285.603).
8. Crossover duct collar hardware and passed through to the end user Assistance
fasteners (§ 3285.606). (manufactured home purchaser). The Catalogue of Federal Domestic
The cost impact for a single-section Moreover, because the great majority of Assistance number is 14.171.
home is determined to be about $133 manufacturers and all installers are
List of Subjects
per home and the cost impact for a considered small entities, there would
multi-section home is determined to be not be any disproportional impact on 24 CFR Part 3280
about $151 per home. Current small entities. Therefore, although this Construction, Housing standards,
manufactured home production is about rule would affect a substantial number Incorporation by reference,
135,000 homes, consisting of about of small entities, it would not have a Manufactured homes, Safety.
40,500 single-section homes and 94,500 significant economic impact on them.
Further, the benefits to the consumer 24 CFR Part 3285
multi-section homes. The combined
average cost impact is determined to be and public from the increase in cost Housing standards, Incorporation by
approximately $145.60 per home may be summarized as follows: reference, Installation, Manufactured
• Under the new standards, homes.
multiplied by a total of 135,000 homes
substantial damage due to moisture
produced in a year; this totals about ■ Accordingly, HUD amends 24 CFR
infiltration will be mitigated, thereby
$19.6 million annually. part 3280 and adds 24 CFR part 3285 to
avoiding repair and remedy that could
Based on a current installation cost of read as follows:
cost the homeowner hundreds to
about $5,000 for a single-wide home, the
thousands of dollars, depending upon PART 3280—MANUFACTURED HOME
$133 increase represents an increase of
the severity of the damage. CONSTRUCTION AND SAFETY
about 2.7 percent from the current cost • The new standard will require
of installing a single section home. STANDARDS
proper configuration, location, and
Similarly, the current cost of installing construction of piers to increase ■ 1. The authority citation for 24 CFR
a multi-section home is about $8,000. occupant and public safety. part 3280 continues to read as follows:
Therefore, the cost impact of $151 per • The new provisions for certification
multi-section home represents an Authority: 42 U.S.C. 3535(d), 5403, and
and testing of ground anchors has the 5424.
increase of about 1.9 percent from the potential to prevent occupant injury or
current cost. These estimated costs and death resulting from ground anchor ■ 2. In § 3280.302, add the definitions of
cost impacts do not represent a installations that utilize insufficient or anchor assembly, foundation system,
significant economic effect on either an under-performing ground anchors. and support system in alphabetical
industry-wide or per-home basis. These • The new requirement for a water order and revise the definitions of
estimates are further limited in the final line shut-off valve provides both safety anchoring equipment, anchoring
rule by recognition of the and convenience for the occupant. The system, diagonal tie, ground anchor, and
manufacturer’s installation instructions, absence of a water line shut-off valve stabilizing devices to read as follows:
including specific methods for can potentially cause hundreds to
performing an operation or assembly, as § 3280.302 Definitions.
thousands of dollars in water damage.
being deemed to comply with the Model • The new standard will require * * * * *
Installation Standards and, as a result, galvanized screws and galvanized Anchor assembly means any device or
may avoid the need to possibly change collars to secure site-installed ducting to other means designed to transfer home
certain practices in existing instructions factory provided connectors, thereby anchoring loads to the ground.
in order to comply with the installation providing for a durable and weather- Anchoring equipment means ties,
standards. protected connection that can withstand straps, cables, turnbuckles, chains, and
This small increase in total cost the elements without premature failure other approved components, including
associated with this rule would not and replacement. Replacement of the tensioning devices that are used to
impose a significant burden for a small connectors and fastenings per home can secure a manufactured home to anchor
business. The rule would regulate total about $30 per home, including $10 assemblies.
establishments primarily engaged in in materials cost and $20 in labor costs. Anchoring system means a
making manufactured homes (NAICS • The requirement for manufacturer combination of anchoring equipment
32991) and the mobile home set-up and review and revision of installation and anchor assemblies that will, when
tie-down establishments (installers) instructions and subsequent third-party properly designed and installed, resist
included within the definition of all approval of the installation instructions the uplift, overturning, and lateral forces
other special trade contractors (NAICS will provide a positive impact on on the manufactured home and on its
23599). Of the 222 firms included under occupant and general public safety. support and foundation system.
the NAICS 32991 definition, 198 are The Secretary, in accordance with the Diagonal tie means a tie intended to
small manufacturers that fall below the Regulatory Flexibility Act (5 U.S.C. resist horizontal or shear forces, but
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small business threshold of 500 605(b)), has reviewed and approved this which may resist vertical, uplift, and
employees. Of the 31,320 firms included rule and in so doing certifies that the overturning forces.
under NAICS 23599 definition, only 53 rule would not have a significant * * * * *
firms exceed the small business economic impact on a substantial Foundation system means a system of
threshold of 500 employees and none of number of small entities. The rule does support that is capable of transferring all

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design loads to the ground, including 3285.104 Moving manufactured home to 3285.904 Utility systems connection.
elements of the support system as location. 3285.905 Heating oil systems.
defined in this section, or a site-built 3285.105 Permits, other alterations, and on- 3285.906 Telephone and cable TV.
site structures. 3285.907 Manufacturer additions to
permanent foundation that meets the
installation instructions.
requirements of 24 CFR 3282.12. Subpart C—Site Preparation
Ground anchor means a specific 3285.201 Soil conditions. Authority: 42 U.S.C. 3535(d), 5403, 5404,
anchoring assembly device designed to 3285.202 Soil classifications and bearing and 5424.
transfer home anchoring loads to the capacity.
ground. 3285.203 Site drainage. Subpart A—General
* * * * * 3285.204 Ground moisture control. § 3285.1 Administration.
Stabilizing devices means all Subpart D—Foundations (a) Scope. These Model Installation
components of the anchoring and 3285.301 General. Standards provide minimum
support systems, such as piers, footings, 3285.302 Flood hazard areas. requirements for the initial installation
ties, anchoring equipment, anchoring 3285.303 Piers. of new manufactured homes, in
assemblies, or any other equipment, 3285.304 Pier configuration. accordance with section 605 of the Act
materials, and methods of construction 3285.305 Clearance under homes.
(42 U.S.C. 5404). The Model Installation
that support and secure the 3285.306 Design procedures for concrete
block piers. Standards are one component of the
manufactured home to the ground. Manufactured Home Installation
3285.307 Perimeter support piers.
* * * * * 3285.308 Manufactured piers. Program in Part 3286 of this chapter,
Support system means any pilings, 3285.309 [Reserved] upon effect, and serve as the basis for
columns, footings, piers, foundation 3285.310 Pier location and spacing. developing the manufacturers’
walls, shims, and any combination 3285.311 Required perimeter supports. installation instructions required by
thereof that, when properly installed, 3285.312 Footings. § 3285.2 of this subpart. The
support the manufactured home. 3285.313 Combination systems. manufacturer’s installation instructions,
3285.314 [Reserved]
■ 3. In § 3280.306, revise paragraphs including specific methods for
3285.315 Special snow load conditions.
(b)(2)(iii) and (iv) to read as follows: performing a specific operation or
Subpart E—Anchorage Against Wind assembly, will be deemed to comply
§ 3280.306 Windstorm protection. 3285.401 Anchoring instructions. with these Model Installation Standards,
* * * * * 3285.402 Ground anchor installations. provided they meet or exceed the
(b) * * * 3285.403 Sidewall, over-the-roof, mate-line, minimum requirements of these Model
(2) * * * and shear wall straps. Installation Standards and do not take
(iii) That ground anchors are to be 3285.404 Severe climatic conditions.
the home out of compliance with the
embedded below the frost line, unless 3285.405 Severe wind zones.
3285.406 Flood hazard areas. Manufactured Home Construction and
the foundation system is frost-protected
Safety Standards (24 CFR part 3280).
in accordance with §§ 3285.312(b) and Subpart F—Optional Features Work necessary to join all sections of a
3285.404 of the Model Manufactured 3285.501 Home installation manual multi-section home specifically
Home Installation Standards in this supplements. identified in Subparts G, H, and I of this
chapter. 3285.502 Expanding rooms.
(iv) That ground anchors must be part, or work associated with connecting
3285.503 Optional appliances. exterior lights, chain-hung light fixtures,
installed to their full depth, and 3285.504 Skirting.
stabilizer plates must be installed in 3285.505 Crawlspace ventilation.
or ceiling-suspended fans, as
accordance with the ground anchor specifically identified in Subpart I, is
Subpart G—Ductwork and Plumbing and not considered assembly or construction
listing or certification to provide Fuel Supply Systems
required resistance to overturning and of the home, although the design of
sliding.
3285.601 Field assembly. those elements of a manufactured home
3285.602 Utility connections. must comply with the Manufactured
* * * * * 3285.603 Water supply. Home Construction and Safety
■ 4. In Chapter XX, add part 3285 to 3285.604 Drainage system. Standards (MHCSS). However, work
read as follows: 3285.605 Fuel supply system.
3285.606 Ductwork connections.
associated with the completion of
hinged roofs and eaves in § 3285.801
PART 3285—MODEL MANUFACTURED Subpart H—Electrical Systems and and other work done on-site and not
HOME INSTALLATION STANDARDS Equipment specifically identified in this part as
Subpart A—General 3285.701 Electrical crossovers. close-up is considered construction and
3285.702 Miscellaneous lights and fixtures. assembly and is subject to the
Sec. 3285.703 Smoke alarms. requirements of the Manufactured Home
3285.1 Administration. 3285.704 Telephone and cable TV. Construction and Safety Standards (24
3285.2 Manufacturer installation CFR part 3280) and the Manufactured
Subpart I—Exterior and Interior Close-Up
instructions.
3285.3 Alterations during initial 3285.801 Exterior close-up. Home Procedural and Enforcement
installation. 3285.802 Structural interconnection of Regulations (24 CFR part 3282).
3285.4 Incorporation by reference (IBR). multi-section homes. (1) States that choose to operate an
3285.5 Definitions. 3285.803 Interior close-up. installation program for manufactured
3285.6 Final leveling of manufactured 3285.804 Bottom board repair. homes in lieu of the federal program
home. must implement installation standards
Subpart J—Optional Information for
Subpart B—Pre-Installation Considerations Manufacturer’s Installation Instructions that provide protection to its residents
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3285.101 Fire separation. 3285.901 General. that equals or exceeds the protection
3285.102 Installation of manufactured 3285.902 Moving manufactured home to provided by these Model Installation
homes in flood hazard areas. location. Standards.
3285.103 Site suitability with design zone 3285.903 Permits, alterations, and on-site (2) In states that do not choose to
maps. structures. operate their own installation program

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for manufactured homes, these Model approved by the Secretary or DAPIA. subject to flood damage or high seismic
Installation Standards serve as the The approved installation instructions risk) that prevent the use of the
minimum standards for manufactured must include all topics covered in the instructions, the installer must:
home installations. Model Installation Standards for the (i) First attempt to obtain DAPIA-
(b) Applicability. The standards set installation of manufactured homes. approved designs and instructions
forth herein have been established to These installation instructions and any prepared by the manufacturer; or
accomplish certain basic objectives and variations thereto that are prepared to (ii) If designs and instructions are not
are not to be construed as relieving comply with paragraph (c) of this available from the manufacturer, obtain
manufacturers, retailers, installers, or section must provide protection to an alternate design prepared and
other parties of responsibility for residents of the manufactured homes certified by a registered professional
compliance with other applicable that equals or exceeds the protection engineer or registered architect for the
ordinances, codes, regulations, and provided by these Model Installation support and anchorage of the
laws. The manufactured homes covered Standards and must not take the manufactured home that is consistent
by this standard must comply with manufactured home out of compliance with the manufactured home design,
requirements of the U.S. Department of with the MHCSS. These instructions conforms to the requirements of the
Housing and Urban Development’s must insure that each home will be MHCSS, and has been approved by the
(HUD) MHCSS Program, as set forth in supported and anchored in a manner manufacturer and the DAPIA.
24 CFR part 3280, Manufactured Home that is capable of meeting or exceeding (2) The manufacturer’s installation
Construction and Safety Standards, and the design loads required by the instructions must include an
24 CFR part 3282, Manufactured Home MHCSS. explanation of the requirement in
Procedural and Enforcement (b) Professional engineer or registered paragraph (c)(1) of this section.
Regulations, as well as with, upon architect certification. A professional (d) Installer certification. In making
effect, the Manufactured Home engineer or registered architect must the certification of the installation
Installation Program, 24 CFR part 3286, prepare and certify that the required under part 3286 of this chapter,
and the Dispute Resolution Program, 24 manufacturer’s installation instructions upon effect, an installer must certify
CFR part 3288. The requirements of this meet or exceed the Model Installation that it completed the installation in
part do not apply to homes installed on Standards for foundation support and compliance with either the
site-built permanent foundations when anchoring whenever: manufacturer’s instructions or with an
the manufacturer certifies the home in (1) The manufacturer’s installation alternate installation design and
accordance with § 3282.12 of this instructions do not conform in their instructions that have been prepared by
chapter. entirety to the minimum requirements the manufacturer or prepared in
(c) Consultation with the or tables or their conditions for compliance with paragraph (c) of this
Manufactured Housing Consensus foundation support and anchoring of section.
Committee. The Secretary will seek this Standard; or (e) Temporary storage. The
input from the Manufactured Housing (2) An alternative foundation system installation instructions must provide at
Consensus Committee (MHCC) when or anchoring system is employed, least one method for temporarily
revising the installation standards in including designs for basements and supporting each transportable section of
this part 3285. Before publication of a perimeter support foundation systems, a manufactured home, to prevent
proposed rule to revise the installation whether or not it is included in the structural and other damage to the
standards, the Secretary will provide the installation instructions; or structure, when those section(s) are
MHCC with a 120-day opportunity to (3) Materials such as metal piers or temporarily sited at the manufacturer’s
comment on such revision. The MHCC alternatives to concrete footing materials facility, retailer’s lot, or the home site.
may send to the Secretary any of the are required by the installation
§ 3285.3 Alterations during initial
MHCC’s own recommendations to adopt instructions; or installation.
new installation standards or to modify (4) Foundation support and anchoring
systems are designed for use in areas Additions, modifications, or
or repeal any of the installation replacement or removal of any
standards in this part. Along with each subject to freezing or for use in areas
subject to flood damage or high seismic equipment that affects the installation of
recommendation, the MHCC must set the home made by the manufacturer,
forth pertinent data and arguments in risk; or
(5) Foundations support and retailer, or installer prior to completion
support of the action sought. The of the installation by an installer must
Secretary will either: anchoring systems are designed to be
used in special snow load conditions or equal or exceed the protections and
(1) Accept or modify the
in severe wind design areas; or requirements of these Model Installation
recommendation and publish it for
(6) Site conditions do not allow the Standards, the MHCSS (24 CFR part
public comment in accordance with
use of the manufacturer’s installation 3280) and the Manufactured Home
section 553 of the Administrative
instructions; or Procedural and Enforcement
Procedure Act (5 U.S.C. 553), along with
(7) There are any other circumstances Regulations (24 CFR part 3282). An
an explanation of the reasons for any
in which the manufacturer’s installation alteration, as defined in § 3282.7 of this
such modification; or
(2) Reject the recommendation instructions would not permit the home chapter, must not affect the ability of the
entirely, and provide to the MHCC a to be installed in conformance with the basic manufactured home to comply
written explanation of the reasons for Installation Standards or the MHCSS. with the MHCSS, and the alteration
the rejection. (c) Variations to installation must not impose additional loads to the
instructions. manufactured home or its foundation,
§ 3285.2 Manufacturer installation (1) Before an installer provides unless the alteration is included in the
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instructions. support or anchorage that are different manufacturer’s DAPIA-approved


(a) Instructions required. A than those methods specified in the designs and installation instructions, or
manufacturer must provide with each manufacturer’s installation instructions, is designed by a registered professional
new manufactured home, installation or when the installer encounters site or engineer or architect consistent with the
designs and instructions that have been other conditions (such as areas that are manufacturer’s design and that

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conforms to the requirements of the (3) ASTM D 2487–00, Standard Underwriters Laboratories (UL), 333
MHCSS. Practice for Classification of Soils for Pfingsten Road, Northbrook, Illinois
Engineering Purposes (Unified Soil 60062.
§ 3285.4 Incorporation by reference (IBR). Classification System), 2000, IBR (1) UL 181A, Closure Systems for Use
(a) The materials listed in this section approved for the table at § 3285.202(c). With Rigid Air Ducts and Air
are incorporated by reference in the (4) ASTM D 2488–00, Standard Connectors, 1994, with 1998 revisions,
corresponding sections noted. These Practice for Description and IBR approved for § 3285.606(a).
incorporations by reference were Identification of Soils (Visual-Manual (2) UL 181B, Closure Systems for Use
approved by the Director of the Federal Procedure), 2000, IBR approved for the With Flexible Air Ducts and Air
Register, in accordance with 5 U.S.C. table at § 3285.202(c). Connectors, 1995, with 1998 revisions,
552(a) and 1 CFR part 51. The materials (5) ASTM D 3953–97, Standard IBR approved for § 3285.606(a).
are available for purchase at the Specification for Strapping, Flat Steel
corresponding addresses noted below, and Seals, 1997, IBR approved for § 3285.5 Definitions.
and all are available for inspection at § 3285.402(b)(2) and Note 10 to Table 1 The definitions contained in this
the Office of Manufactured Housing to § 3285.402. section apply to the terms used in these
Programs, U.S. Department of Housing (f) The materials listed below are Model Installation Standards. Where
and Urban Development, 451 Seventh available for purchase from American terms are not included, common usage
Street, SW., Room 9164, Washington, Wood-Preservers’ Association (AWPA), of the terms applies. The definitions are
DC 20410; or the National Archives and P.O. Box 388, Selma, Alabama 36702. as follows:
Records Administration (NARA). For (1) AWPA M4–02, Standard for the Act. The National Manufactured
information on the availability of this Care of Preservative-Treated Wood Housing Construction and Safety
material at NARA, call (202) 741–6030, Products, 2002, IBR approved for Standards Act of 1974, 42 U.S.C. 5401–
or go to: http://www.archives.gov/ § 3285.312(a)(2)(iii). 5426.
federal-register/cfr/ibr-locations.html. (2) AWPA U1–04, Use Category Anchor assembly. Any device or other
(b) The materials listed below are System; User Specification for Treated means designed to transfer home
available for purchase from the Air Wood, 2004, IBR approved for anchoring loads to the ground.
Conditioning Contractors of America §§ 3285.303(b)(1), 3285.312(a)(2)(ii), and Anchoring equipment. Ties, straps,
(ACCA), 2800 Shirlington Road, Suite 3285.504(c). cables, turnbuckles, chains, and other
300, Arlington, Virginia 22206. (g) The materials listed below are approved components, including
(1) ACCA Manual J, Residential Load available for purchase from the Federal tensioning devices that are used to
Calculation, 8th Edition, IBR approved Emergency Management Administration secure a manufactured home to anchor
for § 3285.503(a)(1)(i)(A). (FEMA), 500 C Street, SW., Washington, assemblies.
(2) [Reserved] DC 20472. Anchoring system. A combination of
(c) The materials listed below are (1) FEMA 85/September 1985, anchoring equipment and anchor
available for purchase from APA—The Manufactured Home Installation in assemblies that will, when properly
Engineered Wood Association, 7011 Flood Hazard Areas, 1985, IBR designed and installed, resist the uplift,
South 19th Street, Tacoma, Washington approved for § 3285.102(d)(3). overturning, and lateral forces on the
98411, telephone number (253) 565– (2) [Reserved] manufactured home and on its support
6600, fax number (253) 565–7265. (h) The materials listed below are and foundation system.
(1) PS1–95, Construction and available for purchase from the National Approved. When used in connection
Industrial Plywood (with typical APA Fire Protection Association (NFPA), 1 with any material, appliance or
trademarks), 1995 edition, IBR approved Batterymarch Park, Quincy, construction, means complying with the
for § 3285.312(a)(2)(i). Massachusetts 02169–7471. requirements of the Department of
(2) [Reserved] (1) NFPA 31, Standard for the Housing and Urban Development.
(d) The materials listed below are Installation of Oil Burning Equipment, Arid region. An area subject to 15
available for purchase from American 2001 edition, IBR approved for inches or less of annual rainfall.
Society of Heating, Refrigerating and Air §§ 3285.905(a) and 3285.905(d)(3). Base flood. The flood having a one
Conditioning Engineers (ASHRAE), (2) NFPA 70, National Electrical Code, percent chance of being equaled or
1791 Tullie Circle, NE., Atlanta, Georgia 2005 edition, IBR approved for exceeded in any given year.
30329–2305. §§ 3285.702(e)(1) and 3285.906. Base flood elevation (BFE). The
(1) ASHRAE Handbook of (3) NFPA 501A, Standard for Fire elevation of the base flood, including
Fundamentals, 1997 Inch-Pound Safety Criteria for Manufactured Home wave height, relative to the datum
Edition, IBR approved for Installations, Sites, and Communities, specified on a LAHJ’s flood hazard map.
§ 3285.503(a)(1)(i)(A). 2003 edition, IBR approved for Comfort cooling certificate. A
(2) [Reserved] § 3285.101. certificate permanently affixed to an
(e) The materials listed below are (i) The materials listed below are interior surface of the home specifying
available for purchase from American available for purchase from the the factory design and preparations for
Society for Testing and Materials Structural Engineering Institute/ air conditioning the manufactured
(ASTM), 100 Barr Harbor Drive, West American Society of Civil Engineers home.
Conshohocken, Pennsylvania 19428– (SEI/ASCE), 1801 Alexander Bell Drive, Crossovers. Utility interconnections in
2959. Reston, Virginia 20191. multi-section homes that are located
(1) ASTM C 90–02a, Standard (1) SEI/ASCE 32–01, Design and where the sections are joined. Crossover
Specification for Loadbearing Concrete Construction of Frost-Protected Shallow connections include heating and cooling
Masonry Units, 2002, IBR approved for Foundations, 2001, IBR approved for ducts, electrical circuits, water pipes,
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§ 3285.312(a)(1)(i). §§ 3285.312(b)(2)(ii) and drain plumbing, and gas lines.


(2) ASTM D 1586–99, Standard Test 3285.312(b)(3)(ii). Design Approval Primary Inspection
Method for Penetration Test and Split- (2) [Reserved] Agency (DAPIA). A state or private
Barrel Sampling of Soils, 1999, IBR (j) The materials listed below are organization that has been accepted by
approved for the table at § 3285.202(c). available for purchase from the Secretary in accordance with the

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requirements of Part 3282, Subpart H of whose listing states either that the Manufactured home gas supply
this chapter, which evaluates and equipment or material meets nationally connector. A listed connector designed
approves or disapproves manufactured recognized standards or has been tested for connecting the manufactured home
home designs and quality control and found suitable for use in a specified to the gas supply source.
procedures. manner. Manufactured home site. A
Diagonal tie. A tie intended to resist Local authority having jurisdiction designated parcel of land designed for
horizontal or shear forces, but which (LAHJ). The state, city, county, city and the installation of one manufactured
may resist vertical, uplift, and county, municipality, utility, or home for the exclusive use of the
overturning forces. organization that has local occupants of the home.
Flood hazard area. The greater of responsibilities and requirements that Manufactured Housing Consensus
either: The special flood hazard area must be complied with during the Committee or MHCC. The consensus
shown on the flood insurance rate map; installation of a manufactured home. committee established pursuant to
or the area subject to flooding during the Lowest floor. The floor of the lowest section 604(a)(3) of the Act, 42 U.S.C.
design flood and shown on a LAHJ’s enclosed area of a manufactured home. 5403(a)(3).
flood hazard map, or otherwise legally An unfinished or flood-resistant Model Installation Standards. The
designated. enclosure, used solely for vehicle installation standards established in
Flood hazard map. A map delineating parking, home access, or limited storage, part 3285 of this chapter, pursuant to
the flood hazard area and adopted by a must not be considered the lowest floor, section 605 of the Act, 42 U.S.C. 5404.
LAHJ. provided the enclosed area is not Pier. That portion of the support
Footing. That portion of the support constructed so as to render the home in system between the footing and the
system that transmits loads directly to violation of the flood-related provisions manufactured home, exclusive of shims.
the soil. of this standard. Types of piers include, but are not
Foundation system. A system of Manufactured home. A structure, limited to: Manufactured steel stands;
support that is capable of transferring all transportable in one or more sections, pressure-treated wood; manufactured
design loads to the ground, including which in the traveling mode is 8 body concrete stands; concrete blocks; and
elements of the support system, as feet or more in width or 40 body feet or portions of foundation walls.
defined in this section, or a site-built more in length, or which when erected Ramada. Any freestanding roof or
permanent foundation that meets the on site is 320 or more square feet, and shade structure, installed or erected
requirements of 24 CFR 3282.12. which is built on a permanent chassis above a manufactured home or any
Ground anchor. A specific anchoring and designed to be used as a dwelling portion thereof.
assembly device designed to transfer with or without a permanent foundation Secretary. The Secretary of Housing
home anchoring loads to the ground. when connected to the required and Urban Development, or an official
Installation instructions. DAPIA- utilities, and includes the plumbing, of HUD delegated the authority of the
approved instructions provided by the heating, air-conditioning, and electrical Secretary with respect to the Act.
home manufacturer that accompany systems contained in the structure. This Skirting. A weather-resistant material
each new manufactured home and term includes all structures that meet used to enclose the perimeter, under the
detail the home manufacturer the above requirements, except the size living area of the home, from the bottom
requirements for support and anchoring requirements and with respect to which of the manufactured home to grade.
systems, and other work completed at the manufacturer voluntarily files a Stabilizing devices. All components of
the installation site to comply with certification, pursuant to § 3282.13 of the anchoring and support systems,
these Model Installation Standards and this chapter, and complies with the such as piers, footings, ties, anchoring
the Manufactured Home Construction MHCSS set forth in part 3280 of this equipment, anchoring assemblies, or
and Safety Standards in 24 CFR part chapter. The term does not include any any other equipment, materials, and
3280. self-propelled recreational vehicle. methods of construction, that support
Installation standards. Reasonable Calculations used to determine the and secure the manufactured home to
specifications for the installation of a number of square feet in a structure will the ground.
new manufactured home, at the place of include the total of square feet for each State. Each of the several states, the
occupancy, to ensure proper siting; the transportable section comprising the District of Columbia, the
joining of all sections of the home; and completed structure and will be based Commonwealth of Puerto Rico, Guam,
the installation of stabilization, support, on the structure’s exterior dimensions the Virgin Islands, and American
or anchoring systems. measured at the largest horizontal Samoa.
Labeled. A label, symbol, or other projections when erected on-site. These Support system. Pilings, columns,
identifying mark of a nationally dimensions will include all expandable footings, piers, foundation walls, shims,
recognized testing laboratory, inspection rooms, cabinets, and other projections and any combination thereof that, when
agency, or other organization concerned containing interior space, but do not properly installed, support the
with product evaluation that maintains include bay windows. Nothing in this manufactured home.
periodic inspection of production of definition should be interpreted to mean Tie. Straps, cable, or securing devices
labeled equipment or materials, and by that a manufactured home necessarily used to connect the manufactured home
whose labeling is indicated compliance meets the requirements of HUD’s to anchoring assemblies.
with nationally recognized standards or Minimum Property Standards (HUD Ultimate load. The absolute
tests to determine suitable usage in a Handbook 4900.1) or that it is maximum magnitude of load that a
specified manner. automatically eligible for financing component or system can sustain,
Listed or certified. Included in a list under 12 U.S.C. 1709(b) certification. limited only by failure.
published by a nationally recognized Manufactured Home Construction Utility connection. The connection of
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testing laboratory, inspection agency, or and Safety Standards or MHCSS. The the manufactured home to utilities that
other organization concerned with Manufactured Home Construction and include, but are not limited to,
product evaluation that maintains Safety Standards established in part electricity, water, sewer, gas, or fuel oil.
periodic inspection of production of 3280 of this chapter, pursuant to section Vertical tie. A tie intended to resist
listed equipment or materials, and 604 of the Act, 42 U.S.C. 5403. uplifting and overturning forces.

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Wind zone. The areas designated on hazard zone and base flood elevation at to § 3285.315 for Special Snow Load
the Basic Wind Zone Map, as further the site. Conditions.
defined in § 3280.305(c) of the (d) General elevation and foundation (c) Thermal zone. Manufactured
Manufactured Home Construction and requirements. homes must not be installed in a
Safety Standards in this chapter, which (1) Methods and practices. thermal zone that exceeds the thermal
delineate the wind design load Manufactured homes located wholly or zone for which the home has been
requirements. partly within special flood hazard areas designed, as evidenced by the thermal
Working load. The maximum must be installed on foundations zone indicated on the heating/cooling
recommended load that may be exerted engineered to incorporate methods and certificate and insulation zone map and
on a component or system determined practices that minimize flood damage as further defined by counties or local
by dividing the ultimate load of a during the base flood, in accordance governments within affected states, as
component or system by an appropriate with the requirements of the LAHJ, 44 applicable, in § 3280.504(b)(5) of the
factor of safety. CFR 60.3(a) through (e), and other Manufactured Home Construction and
provisions of 44 CFR referenced by Safety Standards in this chapter. The
§ 3285.6 Final leveling of manufactured
home.
those paragraphs. manufacturer may provide the heating/
(2) Outside appliances. cooling information and insulation zone
The manufactured home must be (i) Appliances installed on the map on the home’s data plate.
adequately leveled prior to completion manufactured home site in flood hazard
of the installation, so that the home’s areas must be anchored and elevated to § 3285.104 Moving manufactured home to
performance will not be adversely or above the same elevation as the location.
affected. The home will be considered lowest elevation of the lowest floor of Refer to § 3285.902 for considerations
adequately leveled if there is no more the home. related to moving the manufactured
than 1⁄4 inch difference between (ii) Appliance air inlets and exhausts home to the site of installation.
adjacent pier supports (frame or in flood hazard areas must be located at
perimeter) and the exterior doors and § 3285.105 Permits, other alterations, and
or above the same elevation as the on-site structures.
windows of the home do not bind and lowest elevation of the lowest floor of
can be properly operated. Refer to § 3285.903 for considerations
the home.
(3) Related guidance. Refer to FEMA related to permitting, other alterations,
Subpart B—Pre-Installation and on-site structures.
Considerations 85/September 1985, Manufactured
Home Installation in Flood Hazard Subpart C—Site Preparation
§ 3285.101 Fire separation. Areas, 1985 (incorporated by reference,
Fire separation distances must be in see § 3285.4). § 3285.201 Soil conditions.
accordance with the requirements of To help prevent settling or sagging,
§ 3285.103 Site suitability with design zone
Chapter 6 of NFPA 501A, 2003 edition maps.
the foundation must be constructed on
(incorporated by reference, see § 3285.4) firm, undisturbed soil or fill compacted
Prior to the initial installation of a to at least 90 percent of its maximum
or the requirements of the LAHJ. The
new manufactured home and as part of relative density. All organic material
installation instructions must clearly
making the certification of the such as grass, roots, twigs, and wood
indicate this requirement in a separate
installation required under part 3286, scraps must be removed in areas where
section and must caution installers to
upon effect, the installer is to verify that footings are to be placed. After removal
take into account any local requirements
the design and construction of the of organic material, the home site must
on fire separation.
manufactured home, as indicated on the be graded or otherwise prepared to
§ 3285.102 Installation of manufactured design zone maps provided with the ensure adequate drainage, in accordance
homes in flood hazard areas. home, are suitable for the site location with § 3285.203.
(a) Definitions. Except to the extent where the home is to be installed. The
otherwise defined in Subpart A, the design zone maps are those identified in § 3285.202 Soil classifications and bearing
terms used in this subpart are as defined part 3280 of this chapter. capacity.
in 44 CFR 59.1 of the National Flood (a) Wind zone. Manufactured homes The soil classification and bearing
Insurance Program (NFIP) regulations. must not be installed in a wind zone capacity of the soil must be determined
(b) Applicability. The provisions of that exceeds the design wind loads for before the foundation is constructed and
this section apply to the initial which the home has been designed, as anchored. The soil classification and
installation of new manufactured homes evidenced by the wind zone indicated bearing capacity must be determined by
located wholly or partly within a flood on the home’s data plate and as further one or more of the following methods,
hazard area. defined by counties or local unless the soil bearing capacity is
(c) Pre-installation considerations. governments within affected states, as established as permitted in paragraph (f)
Prior to the initial installation of a new applicable, in § 3280.305(c)(2) of the of this section:
manufactured home, the installer is Manufactured Home Construction and (a) Soil tests. Soil tests that are in
responsible for determining whether the Safety Standards in this chapter. accordance with generally accepted
manufactured home site lies wholly or (b) Roof load zone. Manufactured engineering practice; or
partly within a special flood hazard area homes must not be located in a roof load (b) Soil records. Soil records of the
as shown on the LAHJ’s Flood Insurance zone that exceeds the design roof load applicable LAHJ; or
Rate Map, Flood Boundary and for which the home has been designed, (c) Soil classifications and bearing
Floodway Map, or Flood Hazard as evidenced by the roof load zone capacities. If the soil class or bearing
Boundary Map, or if no LAHJ, in indicated on the home’s data plate and capacity cannot be determined by test or
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accordance with NFIP regulations. If so as further defined by counties or local soil records, but its type can be
located, and before an installation governments within affected states, as identified, the soil classification,
method is agreed upon, the map and applicable, in § 3280.305(c)(3) of the allowable pressures, and torque values
supporting studies adopted by the LAHJ Manufactured Home Construction and shown in Table to § 3285.202 may be
must be used to determine the flood Safety Standards in this chapter. Refer used.

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(d) A pocket penetrometer; or requires the use of lower values based geologist, registered professional
(e) In lieu of determining the soil on soil classification and type. engineer, or registered architect must
bearing capacity by use of the methods (f) If the soil appears to be composed determine the soil classification and
shown in the table, an allowable of peat, organic clays, or uncompacted maximum allowable soil bearing
pressure of 1,500 psf may be used, fill, or appears to have unusual capacity.
unless the site-specific information conditions, a registered professional

TABLE TO § 3285.202
Soil classification
ASTM D 2487–00 or Blow count Torque probe 3
D 2488–00 Allowable soil bear- value 4
Soil description ASTM D
Classifica- (incorporated by ref- ing pressure (psf) 1 1586–99 (inch-pounds)-
tion number erence, see
§ 3285.4)

1 ................ .................................. Rock or hard pan ....................................... 4000+ .......................


2 ................ GW, GP, SW, SP, Sandy gravel and gravel; very than dense 2000 ......................... 40+ More than 550.
GM, SM. and/or cemented sands; course gravel/
cobbles; preloaded silts, clays and coral.
3 ................ GC, SC, ML, CL ...... Sand; silty sand; clayey sand; silty gravel; 1500 ......................... 24–39 351–550.
medium dense course sands; sandy
gravel; and very stiff silt, sand clays.
4A .............. CG, MH 2 ................. Loose to medium dense sands; firm to 1000 ......................... 18–23 276–350.
stiff clays and silts; alluvial fills.
4B .............. CH, MH 2 .................. Loose sands; firm clays; alluvial fills ......... 1000 ......................... 12–17 175–275.
5 ................ OL, OH, PT ............. Uncompacted fill; peat; organic clays ....... Refer to 3285.202(e) 0–11 Less than 175.
Notes:
1 The values provided in this table have not been adjusted for overburden pressure, embedment depth, water table height, or settlement prob-
lems.
2 For soils classified as CH or MH, without either torque probe values or blow count test results, selected anchors must be rated for a 4B soil.
3 The torque test probe is a device for measuring the torque value of soils to assist in evaluating the holding capacity of the soil in which the
ground anchor is placed. The shaft must be of suitable length for the full depth of the ground anchor.
4 The torque value is a measure of the load resistance provided by the soil when subject to the turning or twisting force of the probe.

§ 3285.203 Site Drainage. (c) All drainage must be diverted (e) Refer to § 3285.902 regarding the
(a) Purpose. Drainage must be away from the home and must slope a use of drainage structures to drain
minimum of one-half inch per foot away surface runoff.
provided to direct surface water away
from the foundation for the first ten feet. (f) Gutters and downspouts.
from the home to protect against erosion
Where property lines, walls, slopes, or
of foundation supports and to prevent Manufacturers must specify in their
other physical conditions prohibit this
water build-up under the home, as installation instructions whether the
slope, the site must be provided with
shown in Figure to § 3285.203. home is suitable for the installation of
drains or swales or otherwise graded to
(b) The home site must be graded as drain water away from the structure, as gutters and downspouts. If suitable, the
shown in Figure to § 3285.203, or other shown in Figure to § 3285.203. installation instructions must indicate
methods, such as a drain tile and (d) Sloped site considerations. The that when gutters and downspouts are
automatic sump pump system, must be home, where sited, must be protected installed, the runoff must be directed
provided to remove any water that may from surface runoff from the away from the home.
collect under the home. surrounding area. BILLING CODE 4210–07–P
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§ 3285.204 Ground moisture control. engineering data that comply with § 3285.303 Piers.
(a) Vapor retarder. If the space under §§ 3285.301(c) and (d) and are capable (a) General. The piers used must be
the home is to be enclosed with skirting of resisting all design loads of the capable of transmitting the vertical live
or other materials, a vapor retarder must MHCSS. and dead loads to the footings or
be installed to cover the ground under (c) All foundation details, plans, and foundation.
the home, unless the home is installed test data must be designed and certified (b) Acceptable piers—materials
in an arid region with dry soil by a registered professional engineer or specification.
conditions. registered architect, and must not take
the home out of compliance with the (1) Piers are permitted to be concrete
(b) Vapor retarder material. A
MHCSS. (See 3285.2) blocks; pressure-treated wood with a
minimum of six mil polyethylene
(d) Alternative foundation systems or water borne preservative, in accordance
sheeting or its equivalent must be used.
designs are permitted in accordance with AWPA Standard U1–04
(c) Proper installation. (1) The entire
with either of the following: (incorporated by reference, see § 3285.4)
area under the home must be covered
(1) Systems or designs must be for Use Category 4B ground contact
with the vapor retarder, as noted in
manufactured and installed in applications; or adjustable metal or
§ 3285.204(a), except for areas under
accordance with their listings by a concrete piers.
open porches, decks, and recessed
entries. Joints in the vapor retarder must nationally recognized testing agency, (2) Manufactured piers must be listed
be overlapped at least 12 inches. based on a nationally recognized testing or labeled for the required vertical load
(2) The vapor retarder may be placed protocol; or capacity, and, where required by design,
directly beneath footings, or otherwise (2) System designs must be prepared for the appropriate horizontal load
installed around or over footings placed by a professional engineer or a capacity.
at grade, and around anchors or other registered architect or tested and (c) Design requirements.
obstructions. certified by a professional engineer or (1) Load-bearing capacity. The load
(3) Any voids or tears in the vapor registered architect in accordance with bearing capacity for each pier must be
retarder must be repaired. At least one acceptable engineering practice and designed to include consideration for
repair method must be provided in the must be manufactured and installed so the dimensions of the home, the design
manufacturer’s installation instructions. as not to take the home out of dead and live loads, the spacing of the
compliance with the Manufactured piers, and the way the piers are used to
Subpart D—Foundations Home Construction and Safety support the home.
Standards (part 3280 of this chapter). (2) Center beam/mating wall support
§ 3285.301 General.
(a) Foundations for manufactured § 3285.302 Flood hazard areas. must be required for multi-section
home installations must be designed homes and designs must be consistent
In flood hazard areas, foundations,
and constructed in accordance with this with Tables 2 and 3 to § 3285.303 and
anchorings, and support systems must
subpart and must be based on site Figures A, B, and C to § 3285.310.
be capable of resisting loads associated
conditions, home design features, and with design flood and wind events or (d) Pier loads.
the loads the home was designed to combined wind and flood events, and (1) Design support configurations for
withstand, as shown on the home’s data homes must be installed on foundation the pier loads, pier spacing, and roof
plate. supports that are designed and anchored live loads must be in accordance with
(b) Foundation systems that are not to prevent floatation, collapse, or lateral Tables 1, 2, and 3 to § 3285.303 and the
pier and footing type configurations movement of the structure. MHCSS. Other pier designs are
may be used when verified by Manufacturer’s installation instructions permitted in accordance with the
engineering data and designed in must indicate whether: provisions of this subpart.
accordance with § 3285.301(d), (a) The foundation specifications have (2) Manufactured piers must be rated
consistent with the design loads of the been designed for flood-resistant at least to the loads required to safely
MHCSS. Pier and footing specifications considerations, and, if so, the conditions support the dead and live loads, as
that are different than those provided in of applicability for velocities, depths, or required by § 3285.301, and the
this subpart, such as block size, metal wave action; or installation instructions for those piers
piers, section width, loads, and spacing, (b) The foundation specifications are must be consistent with Tables 1, 2, and
may be used when verified by not designed to address flood loads. 3 to this section.

TABLE 1 TO § 3285.303—FRAME BLOCKING ONLY/PERIMETER SUPPORT NOT REQUIRED EXCEPT AT OPENINGS


Roof live load
Pier spacing Location Load (lbs.)
(psf)

20 Frame ........................................................................... 2,900


4 ft. 0 in. ....................................................................... 30 Frame ........................................................................... 3,300
40 Frame ........................................................................... 3,600

20 Frame ........................................................................... 4,200


6 ft. 0 in. ....................................................................... 30 Frame ........................................................................... 4,700
40 Frame ........................................................................... 5,200

20 Frame ........................................................................... 5,500


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8 ft. 0 in. ....................................................................... 30 Frame ........................................................................... 6,200


40 Frame ........................................................................... 6,900

20 Frame ........................................................................... 6,800


10 ft. 0 in. ..................................................................... 30 Frame ........................................................................... 7,600

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TABLE 1 TO § 3285.303—FRAME BLOCKING ONLY/PERIMETER SUPPORT NOT REQUIRED EXCEPT AT OPENINGS


Roof live load
Pier spacing Location Load (lbs.)
(psf)

40 Frame ........................................................................... 8,500

Notes: psf roof dead load, 6 psf floor dead load, 35 loads and are not intended for use in flood
1. See Table to § 3285.312 for cast-in-place plf wall dead load, and 10 plf chassis dead or seismic hazard areas. In those areas, the
footing design by using the noted loads. load. foundation support system is to be designed
2. Table 1 is based on the following design 3. Interpolation for other pier spacing is by a professional engineer or architect.
assumptions: maximum 16 ft. nominal permitted. 5. See Table to § 3285.312 for sizing of
section width (15 ft. actual width), 12’’ eave, 4. The pier spacing and loads shown in the
footings.
10’’ I-beam size, 300 lbs. pier dead load, 10 above table do not consider flood or seismic

TABLE 2 TO § 3285.303—FRAME PLUS PERIMETER BLOCKING/PERIMETER BLOCKING REQUIRED


Roof live load
Maximum pier spacing Location Load (lbs.)
(psf)

Frame ........................................................................... 1,400


4 ft. 0 in. ....................................................................... 20 Perimeter ...................................................................... 1,900
Mating ........................................................................... 3,200

Frame ........................................................................... 1,400


4 ft. 0 in. ....................................................................... 30 Perimeter ...................................................................... 2,300
Mating ........................................................................... 3,800

Frame ........................................................................... 1,400


4 ft. 0 in. ....................................................................... 40 Perimeter ...................................................................... 2,600
Mating ........................................................................... 4,400

Frame ........................................................................... 1,900


6 ft. 0 in. ....................................................................... 20 Perimeter ...................................................................... 2,700
Mating ........................................................................... 4,700

Frame ........................................................................... 1,900


6 ft. 0 in. ....................................................................... 30 Perimeter ...................................................................... 3,200
Mating ........................................................................... 5,600

Frame ........................................................................... 1,900


6 ft. 0 in. ....................................................................... 40 Perimeter ...................................................................... 3,700
Mating ........................................................................... 6,500

Frame ........................................................................... 2,400


8 ft. 0 in. ....................................................................... 20 Perimeter ...................................................................... 3,500
Mating ........................................................................... 6,100

Frame ........................................................................... 2,400


8 ft. 0 in. ....................................................................... 30 Perimeter ...................................................................... 4,200
Mating ........................................................................... 7,300

Frame ........................................................................... 2,400


8 ft. 0 in. ....................................................................... 40 Perimeter ...................................................................... 4,800
Mating ........................................................................... 8,500

Frame ........................................................................... 2,900


10 ft. 0 in. ..................................................................... 20 Perimeter ...................................................................... 4,300
Mating ........................................................................... 7,600

Frame ........................................................................... 2,900


10 ft. 0 in. ..................................................................... 30 Perimeter ...................................................................... 5,100
Mating ........................................................................... 9,100

Frame ........................................................................... 2,900


10 ft. 0 in. ..................................................................... 40 Perimeter ...................................................................... 6,000
Mating ........................................................................... 10,600
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Notes: supporting roof loads. Refer to Figures A and 10’’ I-beam size, 300 lbs. pier dead load, 10
1. See Table to § 3285.312 for cast-in-place B to § 3285.310. psf roof dead load, 6 psf floor dead load, 35
footing design by using the noted loads. 3. Table 2 is based on the following design plf wall dead load, and 10 plf chassis dead
2. Mating wall perimeter piers and footings assumptions: maximum 16 ft. nominal load.
only required under full height mating walls section width (15 ft. actual width), 12’’ eave,

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4. Interpolation for other pier spacing is 6. See Table to § 3285.312 for sizing of § 3285.305 Clearance under homes.
permitted. footings.
5. The pier spacing and loads shown in the A minimum clearance of 12 inches
above table do not consider flood or seismic must be maintained between the lowest
§ 3285.304 Pier configuration.
loads and are not intended for use in flood member of the main frame (I-beam or
(a) Concrete blocks. Installation channel beam) and the grade under all
or seismic hazard areas. In those areas, the
foundation support system is to be designed instructions for concrete block piers areas of the home.
by a professional engineer or architect. must be developed in accordance with
6. See Table to § 3285.312 for sizing of the following provisions and must be § 3285.306 Design procedures for concrete
footings. consistent with Figures A and B to block piers.
§ 3285.306. (a) Frame piers less than 36 inches
(1) Load-bearing (not decorative) high.
TABLE 3 TO § 3285.303—RIDGE BEAM concrete blocks must have nominal
SPAN FOOTING CAPACITY dimensions of at least 8 inches × 8 (1) Frame piers less than 36 inches
inches × 16 inches; high are permitted to be constructed of
Mating wall Roof live load Pier and foot- (2) The concrete blocks must be single, open, or closed-cell concrete
opening (ft) (psf) ing load (lbs.) blocks, 8 inches ‘‘ 8 inches ‘‘ 16 inches,
stacked with their hollow cells aligned
when the design capacity of the block is
20 1,200 vertically; and
5 ................ 30 1,600 (3) When piers are constructed of not exceeded.
40 1,900 blocks stacked side-by-side, each layer (2) The frame piers must be installed
must be at right angles to the preceding so that the long sides are at right angles
20 2,300 one, as shown in Figure B to § 3285.306. to the supported I-beam, as shown in
10 .............. 30 3,100 (b) Caps. (1) Structural loads must be Figure A to this section.
40 3,800 evenly distributed across capped-hollow
(3) The concrete blocks must be
20 3,500 block piers, as shown in Figures A and stacked with their hollow cells aligned
15 .............. 30 4,700 B to § 3285.306. vertically and must be positioned at
40 5,800 (2) Caps must be solid concrete or right angles to the footings.
masonry at least 4 inches in nominal
(4) Horizontal offsets from the top to
20 4,700 thickness, or hardboard lumber at least
20 .............. 30 6,200 2 inches nominal in thickness; or be the bottom of the pier must not exceed
40 7,500 corrosion-protected minimum one-half one-half inch.
inch thick steel; or be of other listed (5) Mortar is not required, unless
20 5,800 specified in the installation instructions
25 .............. 30 7,800
materials.
(3) All caps must be of the same or required by a registered professional
40 9,700
length and width as the piers on which engineer or registered architect.
20 7,000 they rest. (b) Frame piers 36 inches to 67 inches
30 .............. 30 9,300 (4) When split caps are used on high and corner piers.
40 11,600 double-stacked blocks, the caps must be (1) All frame piers between 36 inches
installed with the long dimension across and 67 inches high and all corner piers
20 8,100 the joint in the blocks below.
35 .............. 30 10,900 over three blocks high must be
(c) Gaps. Any gaps that occur during constructed out of double, interlocked
40 13,600
installation between the bottom of the concrete blocks, as shown in Figure B to
main chassis beam and foundation this section, when the design capacity of
Notes: support system must be filled by: the block is not exceeded. Mortar is not
1. See Table to § 3285.312 for cast-in-place (1) Nominal 4 inch × 6 inch × 1 inch required for concrete block piers, unless
footing design by using the noted loads. shims to level the home and fill any
2. Table 3 is based on the following design otherwise specified in the installation
gaps between the base of the main instructions or required by a
assumptions: maximum 16 ft. nominal
section width (15 ft. actual width), 10″ I- chassis beam and the top of the pier cap; professional engineer or registered
beam size, 300 lbs. pier dead load, 10 psf roof (2) Shims must be used in pairs, as
architect.
dead load, 6 psf floor dead load, 35 plf wall shown in Figures A and B to § 3285.306,
dead load, and 10 plf chassis dead load. and must be driven in tightly so that (2) Horizontal offsets from the top to
3. Loads listed are maximum column loads they do not occupy more than one inch the bottom of the pier must not exceed
for each section of the manufactured home. of vertical height; and one inch.
4. Interpolation for maximum allowable (3) Hardwood plates no thicker than (c) All piers over 67 inches high. Piers
pier and column loads is permitted for mate- 2 inches nominal in thickness or 2 inch over 67 inches high must be designed by
line openings between those shown in the or 4 inch nominal concrete block must a registered professional engineer or
table. registered architect, in accordance with
5. The pier spacing and loads shown in the
be used to fill in any remaining vertical
above table do not consider flood or seismic gaps. acceptable engineering practice. Mortar
loads and are not intended for use in flood (d) Manufactured pier heights. is not required for concrete block piers,
or seismic hazard areas. In those areas, the Manufactured pier heights must be unless otherwise specified in the
foundation support system must be designed selected so that the adjustable risers do manufacturer installation instructions or
by a professional engineer or registered not extend more than 2 inches when by the design.
architect. finally positioned. BILLING CODE 4210–07–P
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§ 3285.307 Perimeter support piers. See § 3285.303(d)(2) for additional (b) Mate-line and column pier
(a) Piers required at mate-line requirements. supports must be in accordance with
supports, perimeter piers, and piers at (b) Metal or other manufactured piers this subpart and consistent with Figures
exterior wall openings are permitted to must be provided with protection A through C to this section, unless the
be constructed of single open-cell or against weather deterioration and pier support and footing configuration is
closed-cell concrete blocks, with corrosion at least equivalent to that designed by a registered professional
nominal dimensions of 8 inches × 8 provided by a coating of zinc on steel engineer or registered architect.
inches × 16 inches, to a maximum of .30 oz./ft.2 of surface coated. (c) Piers supporting the frame must be
height of 54 inches, as shown in Figure no more than 24 inches from both ends
A to this section, when the design § 3285.309 [Reserved] and not more than 120 inches center to
capacity of the block is not exceeded. center under the main rails.
§ 3285.310 Pier location and spacing.
(b) Piers used for perimeter support (d) Pier support locations. Pier
must be installed with the long (a) The location and spacing of piers support locations and spacing must be
dimension parallel to the perimeter rail. depends upon the dimensions of the presented to be consistent with Figures
home, the live and dead loads, the type A and B to § 3285.312, as applicable,
§ 3285.308 Manufactured piers. of construction (single-or multi-section), unless alternative designs are provided
(a) Manufactured piers must be listed I-beam size, soil bearing capacity, by a professional engineer or registered
and labeled and installed to the pier footing size, and such other factors as architect in accordance with acceptable
manufacturer’s installation instructions. the location of doors or other openings. engineering practice.
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Notes: 3. Single-stack concrete block pier loads 6. Piers are not required at openings in the
1. Bottom of footings must extend below must not exceed 8,000 lbs. mating wall that are less than 48 inches in
frost line depth, unless designed for 4. Prefabricated piers must not exceed their width. Place piers on both sides of mating
placement above the frost line. (See approved or listed maximum vertical or wall openings that are 48 inches or greater in
§ 3285.312(b)). horizontal design loads. width. For roof loads of 40 psf or greater, a
2. Piers may be offset up to 6 in. in either professional engineer or registered architect
5. When a full-height mating wall does not
direction along the supported members to must determine the maximum mating wall
support the ridge beam, this area is
allow for plumbing, electrical, mechanical, opening permitted without pier or other
equipment, crawlspaces, or other devices. considered an unsupported span—Span B. supports.
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Notes: 4. Piers are not required at openings in the 5. When a full-height mating wall does not
1. Bottom of footings must be below the mating wall that are less than 48 inches in support the ridge beam, this area is
frost line depth, unless designed for width. Place piers on both sides of mating considered an unsupported span—Span B.
placement above the frost line. (See wall openings that are 48 inches or greater in 6. In areas where the open span is greater
§ 3285.312(b)). width. For roof loads of 40 psf or greater, a than 10 ft., intermediate piers and footings
2. Piers may be offset 6 in. in either must be placed at maximum 10 ft. on center.
professional engineer or registered architect
direction along supported members to allow 7. Prefabricated piers must not exceed their
must determine the maximum mating wall
for plumbing electrical, mechanical approved or listed maximum horizontal or
equipment, crawlspaces, or other devices. opening permitted without pier or other vertical design loads.
3. Single stack concrete block pier loads supports. 8. Column piers are in addition to piers
must not exceed 8,000 lbs. required under full-height mating walls.
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Notes: (i) Located in accordance with Table § 3285.312 Footings.


1. Mate-line column support piers are 2 to § 3285.303; or (a) Materials approved for footings
installed with the long dimension of the
(ii) Provided by other means such as must provide equal load-bearing
concrete block perpendicular to the rim
joists. additional outriggers or floor joists. capacity and resistance to decay, as
2. Pier and footing designed to support When this alternative is used, the required by this section. Footings must
both floor sections. Loads as listed in Table designs required by § 3285.301 must be placed on undisturbed soil or fill
3 to § 3285.303 are total column loads for consider the additional loads in sizing compacted to 90 percent of maximum
both sections. the pier and footing supports under the relative density. A footing must support
main chassis beam. every pier. Footings are to be either:
§ 3285.311 Required perimeter supports. (1) Concrete.
(b) For roof live loads of 40 psf or
(a) Perimeter pier or other supports (i) Four inch nominal precast concrete
greater, a professional engineer or
must be located as follows: pads meeting or exceeding ASTM C 90–
architect must determine the maximum 02a, Standard Specification for
(1) On both sides of side wall exterior sidewall opening permitted without Loadbearing Concrete Masonry Units
doors (such as entry, patio, and sliding perimeter pier or other supports. (incorporated by reference, see
glass doors) and any other side wall (c) The location and installation of § 3285.4), without reinforcement, with
openings of 48 inches or greater in
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any perimeter pier support must not at least a 28-day compressive strength of
width, and under load-bearing porch take the home out of compliance with 1,200 pounds per square inch (psi); or
posts, factory installed fireplaces, and the Manufactured Home Construction (ii) Six inch minimum poured-in-
fireplace stoves). and Safety Standards (part 3280 of this place concrete pads, slabs, or ribbons
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strength of 3,000 pounds per square installation instructions and certified for characteristics, site preparation,
inch (psi). Site-specific soil conditions use in the soil classification at the site. ventilation, and insulative properties of
or design load requirements may also (ii) ABS footing pads must be listed or the under floor enclosure, are
require the use of reinforcing steel in labeled for the required load capacity. considered and anchorage requirements
cast-in-place concrete footings. (4) Other Materials. Footings may be are accommodated as set out in
(2) Pressure-treated wood. of other materials than those identified § 3285.401. The monolithic slab system
(i) Pressure-treated wood footings in this section, provided they are listed must be designed by a registered
must consist of a minimum of two for such use and meet all other professional engineer or registered
layers of nominal 2-inch thick pressure- applicable requirements of this subpart. architect:
treated wood, a single layer of nominal (b) Placement in freezing climates. (i) In accordance with acceptable
3⁄4-inch thick, pressure-treated plywood Footings placed in freezing climates engineering practice to prevent the
with a maximum size of 16 inches by 16 must be designed using methods and effects of frost heave; or
inches, or at least two layers of 3⁄4-inch practices that prevent the effects of frost (ii) In accordance with SEI/ASCE 32–
thick, pressure-treated plywood for sizes heave by one of the following methods: 01 (incorporated by reference, see
greater than 16 inches by 16 inches. (1) Conventional footings. § 3285.4).
Plywood used for this purpose is to be Conventional footings must be placed (3) Insulated foundations. An
rated exposure 1 or exterior sheathing, below the frost line depth for the site insulated foundation is permitted above
in accordance with PS1–95, unless an insulated foundation or the frost line, when all relevant site-
Construction and Industrial Plywood monolithic slab is used (refer to specific conditions, including soil
(incorporated by reference, see §§ 3285.312(b)(2) and 3285.312(b)(3)). characteristics, site preparation,
§ 3285.4). When the frost line depth is not ventilation, and insulative properties of
(ii) Pressure treated lumber is to be available from the LAHJ, a registered the under floor enclosure, are
treated with a water-borne adhesive, in professional engineer, registered considered, and the foundation is
accordance with AWPA Standard U1– architect, or registered geologist must be designed by a registered professional
04 (incorporated by reference, see consulted to determine the required engineer or registered architect:
§ 3285.4) for Use Category 4B ground frost line depth for the manufactured (i) In accordance with acceptable
contact applications. home site. This is not subject to the engineering practice to prevent the
(iii) Cut ends of pressure treated provisions in § 3285.2(c) that also effects of frost heave; or
lumber must be field-treated, in require review by the manufacturer and (ii) In accordance with SEI/ASCE 32–
accordance with AWPA Standard M4– approval by its DAPIA for any variations 01 (incorporated by reference, see
02 (incorporated by reference, see to the manufacturer’s installation § 3285.4).
§ 3285.4). instructions for support and anchoring. (c) Sizing of footings. The sizing and
(3) ABS footing pads. (2) Monolithic slab systems. A layout of footings depends on the load-
(i) ABS footing pads are permitted, monolithic slab is permitted above the bearing capacity of the soil, footings,
provided they are installed in frost line when all relevant site-specific and the piers. See §§ 3285.202 and
accordance with the pad manufacturer conditions, including soil 3285.303, and Table to 3285.312.
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Notes: 2. In addition to blocking required by measured from the outside edge of the floor
1. Refer to Table 1 of § 3285.303 for pier § 3285.311, see Table 2 to § 3285.303 for to the center of the pier.
and footing requirements when frame maximum perimeter blocking loads. 4. Place piers on both sides of sidewall
blocking only is used. 3. End piers under main I-beams may be exterior doors, patio doors, and sliding glass
set back a maximum of 24 inches, as doors; under porch posts, factory-installed
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fireplaces, and fireplace stoves; under jamb greater, a professional engineer or registered 3285.311 for additional requirements and for
studs at multiple window openings; and at architect must determine the maximum locating perimeter supports.
any other sidewall openings 48 inches or sidewall opening permitted without
greater in width. For roof loads of 40 psf or perimeter supports. See §§ 3285.307 and

1. Refer to Table 1 to § 3285.303 for pier 4. Place piers on both sides of sidewall supports or mating wall opening permitted
and footing requirements when frame exterior doors, patio doors, and sliding glass without pier or other supports. See
blocking only is used. doors; under porch posts, factory-installed §§ 3285.307 and 3285.311 for additional
2. In addition to blocking required by fireplaces, and fireplace stoves; under jamb information on requirements and for locating
§ 3285.311, see Tables 2 and 3 to § 3285.303 studs at multiple window openings; and at perimeter supports.
for maximum perimeter blocking loads. any other sidewall openings of 48 inches or 5. When an end pier under the mate-line
3. End piers under main I-beams may be greater in width. For roof loads of 40 psf or also serves as a column pier, it may be set
set back a maximum of 24 inches, as greater, a professional engineer or registered back a maximum of 6 in., as measured from
measured from the outside edge of the floor architect must determine the maximum side the inside edge of the exterior wall to the
to the center of the pier. wall opening permitted without perimeter center of the pier.

TABLE TO § 3285.312.—THE SIZE AND CAPACITY FOR UNREINFORCED CAST-IN-PLACE FOOTINGS


8 in. x 16 in. pier 16 in. x 16 in. pier

Minimum foot- Unreinforced Unreinforced


Soil capacity ing size Maximum foot- cast-in-place Maximum foot- cast-in-place
(psf) (in.) ing capacity minimum ing capacity minimum
(lbs.) thickness (lbs.) thickness
(in.) (in.)

1,000 .................................................................................... 16 x 16 1,600 6 1,600 6


20 x 20 2,600 6 2,600 6
24 x 24 3,700 6 3,700 6
30 x 30 5,600 8 5,800 6
36 x 36 7,900 10 8,100 8
42 x 42 4 10,700 10 10,700 10
48 x 48 4 13,100 12 13,600 10
1,500 .................................................................................... 16 x 16 2,500 6 2,500 6
20 x 20 4,000 6 4,000 6
24 x 24 5,600 8 5,700 6
30 x 30 4 8,500 10 8,900 8
36 x 36 4 12,400 10 12,600 8
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42 x 42 4 16,500 12 416,800 10
48 x 48 4 21,200 14 421,600 12
2,000 .................................................................................... 16 x 16 3,400 6 3,400 6
20 x 20 5,300 6 5,300 6
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24 x 24 7,600 8 7,700 6

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TABLE TO § 3285.312.—THE SIZE AND CAPACITY FOR UNREINFORCED CAST-IN-PLACE FOOTINGS—Continued


8 in. x 16 in. pier 16 in. x 16 in. pier

Minimum foot- Unreinforced Unreinforced


Soil capacity ing size Maximum foot- cast-in-place Maximum foot- cast-in-place
(psf) (in.) ing capacity minimum ing capacity minimum
(lbs.) thickness (lbs.) thickness
(in.) (in.)

30 x 30 4 11,700 10 11,900 8
36 x 36 4 16,700 15 4 16,900 10
42 x 42 4 21,700 18 4 22,700 12
2,500 .................................................................................... 16 x 16 4,300 6 4,300 6
20 x 20 6,700 6 6,700 6
24 x 24 4 9,600 8 9,700 6
30 x 30 4 14,800 10 15,000 8
36 x 36 4 20,700 12 4 21,400 10
3,000 .................................................................................... 16 x 16 5,200 6 5,200 6
20 x 20 8,100 8 8,100 6
24 x 24 4 11,500 10 11,700 6
30 x 30 4 17,800 12 4 18,100 8
36 x 36 4 25,400 14 4 25,900 10
4,000 .................................................................................... 16 x 16 7,000 6 7,000 6
20 x 20 4 10,800 8 10,900 6
24 x 24 4 15,500 10 15,600 8
30 x 30 4 23,300 12 4 24,200 10

Notes: instructions, a registered professional design for the lower requirements is


1. The footing sizes shown are for square engineer or registered architect must either provided in the installation
pads and are based on the area (in.2), shear design the foundation for the special instructions or the foundation and
and bending required for the loads shown. snow load conditions. anchorage system is designed by a
Other configurations, such as rectangular or (b) Ramadas. Ramadas may be used in
circular configurations, can be used,
professional engineer or registered
provided the area and depth is equal to or
areas with roof live loads greater than 40 architect.
greater than the area and depth of the square psf. Ramadas are to be self-supporting, (d) The installation instructions are to
footing shown in the table, and the distance except that any connection to the home include at least the following
from the edge of the pier to the edge of the must be for weatherproofing only. information and details for anchor
footing is not less than the thickness of the assembly-type installations:
footing. Subpart E—Anchorage Against Wind (1) The maximum spacing for
2. The 6 in. cast-in-place values can be installing diagonal ties and any required
used for 4 in. unreinforced precast concrete § 3285.401 Anchoring instructions.
vertical ties or straps to ground anchors;
footings. (a) After blocking and leveling, the (2) The minimum and maximum
3. The capacity values listed have been manufactured home must be secured angles or dimensions for installing
reduced by the dead load of the concrete against the wind by use of anchor diagonal ties or straps to ground anchors
footing. assembly type installations or by
4. Concrete block piers must not exceed
and the main chassis members of the
connecting the home to an alternative manufactured home;
their design capacity of 8,000 lbs. for 8″ x 16″ foundation system. See § 3285.301.
single stack block and 16,000 lbs. for 16″ x (3) Requirements for connecting the
(b) For anchor assembly type diagonal ties to the main chassis
16″ double stack block. installations, the installation
5. A registered professional engineer or members of the manufactured home. If
registered architect must prepare the design,
instructions must require the home to be the diagonal ties are attached to the
if the design loads exceed the capacity for secured against the wind, as described bottom flange of the main chassis beam,
single or double stack concrete block piers in this section. The installation the frame must be designed to prevent
shown in footnote 4. instructions and design for anchor type rotation of the beam;
assemblies must be prepared by a (4) Requirements for longitudinal and
§ 3285.313 Combination systems. registered professional engineer or mating wall tie-downs and anchorage;
Support systems that combine both registered architect, in accordance with (5) The method of strap attachment to
load-bearing capacity and uplift acceptable engineering practice, the the main chassis member and ground
resistance must also be sized and design loads of the MHCSS, and anchor, including provisions for swivel-
designed for all applicable design loads. § 3285.301(d). type connections;
(c) All anchoring and foundation (6) The methods for protecting
§ 3285.314 [Reserved] systems must be capable of meeting the vertical and diagonal strapping at sharp
loads that the home was designed to corners by use of radius clips or other
§ 3285.315 Special snow load conditions. withstand required by part 3280, means; and
(a) General. Foundations for homes subpart D of this chapter, as shown on (7) As applicable, the requirements for
designed for and located in areas with the home’s data plate. Exception: sizing and installation of stabilizer
roof live loads greater than 40 psf must Manufactured homes that are installed plates.
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be designed by the manufacturer for the in less restrictive roof load zone and
special snow load conditions, in wind zone areas may have foundation or § 3285.402 Ground anchor installations.
accordance with acceptable engineering anchorage systems that are capable of (a) Ground anchor certification and
practice. Where site or other conditions meeting the lower design load testing. Each ground anchor must be
prohibit the use of the manufacturer’s provisions of the Standards, if the manufactured and provided with

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installation instructions, in accordance conforming to ASTM D 3953—97, permitted between the diagonal strap
with its listing or certification. A Standard Specification for Strapping, and the ground; and
nationally recognized testing agency Flat Steel and Seals (incorporated by (ii) All ground anchors must be
must list, or a registered professional reference, see § 3285.4), Type 1, Grade installed in accordance with their listing
engineer or registered architect must 1, Finish B, with a minimum total or certification and the ground anchor
certify, the ground anchor for use in a capacity of 4,725 pounds (lbs.) and a manufacturer installation instructions;
classified soil (refer to § 3285.202), working capacity of 3,150 pounds (lbs.) and
based on a nationally recognized testing must be used. The tie-down straps must (iii) If required by the ground anchor
protocol, or a professional engineer or be provided with protection against listing or certification, the correct size
registered architect must certify that the weather deterioration and corrosion at and type of stabilizer plate is installed.
ground anchor is capable of resisting all least equivalent to that provided by a If metal stabilizer plates are used, they
loads in paragraph (b) of this section for coating of zinc on steel of not less than must be provided with protection
the soil type or classification. 0.30 oz./ft.2 of surface coated. Slit or cut against weather deterioration and
(b) Specifications for tie-down straps edges of coated strapping need not be corrosion at least equivalent to that
and ground anchors. zinc coated. provided by a coating of zinc on steel
(1) Ground anchors. Ground anchors (c) Number and location of ground of not less than 0.30 oz./ft.2 of surface
must be installed in accordance with anchors. coated. Alternatively, ABS stabilizer
their listing or certification, be installed (1) Ground anchor and anchor strap plates may be used when listed and
to their full depth, be provided with spacing must be: certified for such use.
protection against weather deterioration (i) No greater than the spacing shown (3) Longitudinal anchoring.
and corrosion at least equivalent to that in Tables 1 through 3 to this section and Manufactured homes must also be
provided by a coating of zinc on steel Figures A and B to this section; or stabilized against wind in the
of not less than 0.30 oz./ft.2 of surface (ii) Designed by a registered engineer longitudinal direction in all Wind
coated, and be capable of resisting a or architect, in accordance with Zones. Manufactured homes located in
minimum ultimate load of 4,725 lbs. acceptable engineering practice and the Wind Zones II and III must have
and a working load of 3,150 lbs., as requirements of the MHCSS for any longitudinal ground anchors installed
installed, unless reduced capacities are conditions that are outside the on the ends of the manufactured home
noted in accordance with note 11 of parameters and applicability of the transportable section(s) or be provided
Table 1 to this section or note 12 of Tables 1 through 3 to this section. with alternative systems that are capable
Tables 2 and 3 to this section. The (2) The requirements in paragraph (c) of resisting wind forces in the
ultimate load and working load of of this section must be used to longitudinal direction. See Figure C to
ground anchors and anchoring determine the maximum spacing of § 3285.402 for an example of one
equipment must be determined by a ground anchors and their accompanying method that may be used to provide
registered professional engineer, anchor straps, based on the soil longitudinal anchoring. A professional
registered architect, or tested by a classification determined in accordance engineer or registered architect must
nationally recognized third-party testing with § 3285.202: certify the longitudinal anchoring
agency in accordance with a nationally (i) The installed ground anchor type method or any alternative system used
recognized testing protocol. and size (length) must be listed for use as adequate to provide the required
(2) Tie-down straps. A 11⁄4 inch x in the soil class at the site and for the stabilization, in accordance with
0.035 inch or larger steel strapping minimum and maximum angle acceptable engineering practice.
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Notes: 2. Longitudinal anchors not shown for


1. Refer to Tables 1, 2, and 3 to this section clarity; refer to 3285.402(b)(2) for
for maximum ground anchor spacing. longitudinal anchoring requirements.
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Notes: 2. The frame must be designed to prevent diagonal ties are not attached to the top
1. Vertical Straps are not required in Wind rotation of the main chassis beam, when the flange of the beam. See § 3285.401(d)(3).
Zone I.
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TABLE 1 TO § 3285.402.—MAXIMUM DIAGONAL TIE-DOWN STRAP SPACING, WIND ZONE I


Max. height from ground to I-beam spacing I-beam spacing
Nominal floor width, single section/multi-section diagonal strap attachment 82.5 in. 99.5 in.

12/24 ft. 144 in. nominal section(s) ................................. 25 in ................................... 14 ft. 2 in ........................... N/A.
33 in ................................... 11 ft. 9 in ........................... N/A.
46 in ................................... 9 ft. 1 in ............................. N/A.
67 in ................................... N/A ..................................... N/A.

14/28 ft. 168 in. nominal section(s) ................................. 25 in ................................... 18 ft. 2 in ........................... 15 ft. 11 in.
33 in ................................... 16 ft. 1 in ........................... 13 ft. 6 in.
46 in ................................... 13 ft. 3 in ........................... 10 ft. 8 in.
67 in ................................... 10 ft. 0 in ........................... N/A.

16/32 ft. 180 in. to 192 in. nominal section(s) ................ 25 in ................................... N/A ..................................... 19 ft. 5 in.
33 in ................................... 19 ft. 0 in ........................... 17 ft. 5 in.
46 in ................................... 16 ft. 5 in ........................... 14 ft. 7 in.
67 in ................................... 13 ft. 1 in ........................... 11 ft. 3 in.

Notes: 8. Ground anchors must be certified for 11. A reduced ground anchor or strap
1. Table is based on maximum 90 in. these conditions by a professional engineer, working load capacity will require reduced
sidewall height. architect, or listed by a nationally recognized tie-down strap and anchor spacing.
2. Table is based on maximum 4 in. inset testing laboratory. 12. Ground anchors must not be spaced
for ground anchor head from edge of floor or 9. Ground anchors must be installed to closer than the minimum spacing permitted
wall. their full depth, and stabilizer plates, if
3. Table is based on main rail (I-beam) required by the ground anchor listing or by the listing or certification.
spacing per given column. certification, must also be installed in 13. Table is based on a 3,150 lbs. working
4. Table is based on maximum 4 in. eave accordance with the listing or certification load capacity, and straps must be placed
width for single-section homes and and in accordance with the ground anchor within 2 ft. of the ends of the home.
maximum 12 in. for multi-section homes. and home manufacturer instructions. 14. Table is based on a minimum angle of
5. Table is based on maximum 20-degree 10. Strapping and anchoring equipment 30 degrees and a maximum angle of 60
roof pitch (4.3⁄12). must be certified by a registered professional degrees between the diagonal strap and the
6. Table is based upon the minimum height engineer or registered architect, or listed by ground.
between the ground and the bottom of the a nationally recognized testing agency to
15. Table does not consider flood or
floor joist being 18 inches. Interpolation may resist these specified forces, in accordance
be required for other heights from ground to with testing procedures in ASTM D 3953–97, seismic loads and is not intended for use in
strap attachment. Standard Specification for Strapping, Flat flood or seismic hazard areas. In those areas,
7. Additional tie-downs may be required Steel and Seals (incorporated by reference, the anchorage system is to be designed by a
per the home manufacturer instructions. see § 3285.4). professional engineer or architect.

TABLE 2 TO § 3285.402—MAXIMUM DIAGONAL TIE-DOWN STRAP SPACING, WIND ZONE II.


Nominal floor width, Max. height from Near beam method I–beam spacing Second beam method I–beam spacing
single section/multi- ground to diagonal
section strap attachment 82.5 in. 99.5 in. 82.5 in. 99.5 in.

12 ft/24 ft. 144 in. 25 in .......................... 6 ft. 2 in ..................... 4 ft. 3 in ..................... N/A ............................ N/A
nominal section(s).
33 in .......................... 5 ft. 2 in ..................... N/A ............................ N/A ............................ N/A
46 in .......................... 4 ft. 0 in ..................... N/A ............................ N/A ............................ N/A
67 in .......................... N/A ............................ N/A ............................ 6 ft 1 in ...................... 6 ft 3 in

14 ft/28 ft. 168 in. 25 in .......................... 7 ft. 7 in ..................... 6 ft. 9 in ..................... N/A ............................ N/A
nominal section(s).
33 in .......................... 6 ft. 10 in ................... 5 ft. 9 in ..................... N/A ............................ N/A
46 in .......................... 5 ft. 7 in ..................... 4 ft. 6 in ..................... N/A ............................ N/A
67 in .......................... 4 ft. 3 in ..................... N/A ............................ N/A ............................ N/A

16 ft/32 ft. 180 in. to 25 in .......................... N/A ............................ 7 ft. 10 in ................... N/A ............................ N/A
192 in. nominal sec-
tion(s).
33 in .......................... 7 ft. 6 in ..................... 7 ft. 2 in ..................... N/A ............................ N/A
46 in .......................... 6 ft. 9 in ..................... 6 ft. 0 in ..................... N/A ............................ N/A
67 in .......................... 5 ft. 4 in ..................... 4 ft. 7 in ..................... N/A ............................ N/A

Notes: 3. Tables are based on main rail (I-beam) 6. All manufactured homes designed to be
1. Table is based on maximum 90 in. spacing per given column. located in Wind Zone II must have a vertical
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sidewall height. 4. Table is based on maximum 4 in. eave tie installed at each diagonal tie location.
2. Table is based on maximum 4 in. inset width for single-section homes and 7. Table is based upon the minimum height
for ground anchor head from edge of floor or maximum 12 in. for multi-section homes. between the ground and the bottom of the
wall. 5. Table is based on maximum 20-degree floor joist being 18 inches. Interpolation may
roof pitch (4.3/12).

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be required for other heights from ground to and in accordance with the ground anchor 13. Ground anchors must not be spaced
strap attachment. and home manufacturer instructions. closer than the minimum spacing permitted
8. Additional tie downs may be required 11. Strapping and anchoring equipment by the listing or certification.
per the home manufacturer instructions. must be certified by a registered professional 14. Table is based on a 3,150 lbs. working
9. Ground anchors must be certified by a engineer or registered architect or must be load capacity, and straps must be placed
listed by a nationally recognized testing within 2 ft. of the ends of the home.
professional engineer, or registered architect,
agency to resist these specified forces, in 15. Table is based on a minimum angle of
or listed by a nationally recognized testing
accordance with testing procedures in ASTM 30 degrees and a maximum of 60 degrees
laboratory. D 3953—97, Standard Specification for between the diagonal strap and the ground.
10. Ground anchors must be installed to Strapping, Flat Steel and Seals (incorporated 16. Table does not consider flood or
their full depth, and stabilizer plates, if by reference, see § 3285.4). seismic loads and is not intended for use in
required by the ground anchor listing or 12. A reduced ground anchor or strap flood or seismic hazard areas. In those areas,
certification, must also be installed in working load capacity will require reduced the anchorage system is to be designed by a
accordance with the listing or certification tie-down strap and anchor spacing. professional engineer or architect.

TABLE 3 TO § 3285.402.—MAXIMUM DIAGONAL TIE-DOWN STRAP SPACING, WIND ZONE III.


Near beam method I-beam spacing Second beam
method I-beam
Nominal floor width, single Max. height from ground to spacing
section/multi-section diagonal strap attachment 82.5 in. 99.5 in.
82.5 in. 99.5 in.

12 ft./24 ft. 144 in. nominal 25 in ..................................... 5 ft. 1 in ................................ N/A ....................................... N/A ...... N/A
section(s).
33 in ..................................... 4 ft. 3 in ................................ N/A ....................................... N/A ...... N/A
46 in ..................................... N/A ....................................... N/A ....................................... N/A ...... N/A
67 in ..................................... N/A ....................................... N/A ....................................... N/A ...... N/A
14 ft./28 ft. 168 in. nominal 25 in ..................................... 6 ft. 2 in. ............................... 5 ft. 7 in ................................ N/A ...... N/A
section(s).
33 in ..................................... 5 ft. 8 in ................................ 4 ft. 9 in ................................ N/A ...... N/A
46 in ..................................... 4 ft. 8 in ................................ N/A ....................................... N/A ...... N/A
67 in ..................................... N/A ....................................... N/A ....................................... N/A ...... N/A
16 ft./32 ft. 180 in. to 192 in. 25 in ..................................... N/A ....................................... 6 ft. 3 in ................................ N/A ...... N/A
nominal sections.
33 in ..................................... 6 ft. 1 in ................................ 5 ft. 11 in .............................. N/A ...... N/A
46 in ..................................... 5 ft. 7 in ................................ 5 ft. 0 in ................................ N/A ...... N/A
67 in ..................................... 4 ft. 5 in ................................ N/A ....................................... N/A ...... N/A

Notes: 1. Table is based on maximum 90 listed by a nationally recognized testing below the frost line, unless the
in. sidewall height. agency to resist these specified forces, in foundation system is frost-protected to
2. Table is based on maximum 4 in. inset accordance with testing procedures in ASTM
prevent the effects of frost heave, in
for ground anchor head from edge of floor or D 3953–97, Standard Specification for
wall. Strapping, Flat Steel and Seals (incorporated accordance with acceptable engineering
3. Table is based on main rail (I-beam) by reference, see § 3285.4). practice and § 3280.306 of this chapter
spacing per given column. 12. A reduced ground anchor or strap and § 3285.312.
4. Table is based on maximum 4 in. eave working load capacity will require reduced
width for single-section homes and tie-down strap and anchor spacing. § 3285.405 Severe wind zones.
maximum 12 in. for multi-section homes. 13. Ground anchors must not be spaced
5. Table is based on maximum 20-degree closer than the minimum spacing permitted When any part of a home is installed
roof pitch (4.3/12). by the listing or certification. within 1,500 feet of a coastline in Wind
6. All manufactured homes designed to be 14. Table is based on a 3,150 lbs. working Zones II or III, the manufactured home
located in Wind Zone III must have a vertical load capacity, and straps must be placed must be designed for the increased
tie installed at each diagonal tie location. within 2 ft. of the ends of the home. requirements, as specified on the
7. Table is based upon the minimum height 15. Table is based on a minimum angle of home’s data plate (refer to § 3280.5(f) of
between the ground and the bottom of the 30 degrees and a maximum angle of 60
floor joist being 18 inches. Interpolation may degrees between the diagonal strap and the this chapter) in accordance with
be required for other heights from ground to ground. acceptable engineering practice. Where
strap attachment. 16. Table does not consider flood or site or other conditions prohibit the use
8. Additional tie downs may be required seismic loads and is not intended for use in of the manufacturer’s instructions, a
per the home manufacturer instructions. flood or seismic hazard areas. In those areas, registered professional engineer or
9. Ground anchors must be certified by a the anchorage system is to be designed by a registered architect, in accordance with
professional engineer, or registered architect, professional engineer or architect.
or listed by a nationally recognized testing acceptable engineering practice, must
laboratory. § 3285.403 Sidewall, over-the-roof, mate-
design anchorage for the special wind
10. Ground anchors must be installed to line, and shear wall straps. conditions.
their full depth, and stabilizer plates, if
If sidewall, over-the-roof, mate-line, § 3285.406 Flood hazard areas.
required by the ground anchor listing or
certification, must also be installed in or shear wall straps are installed on the
accordance with the listing or certification home, they must be connected to an Refer to § 3285.302 for anchoring
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and per the ground anchor and home anchoring assembly. requirements in flood hazard areas.
manufacturer instructions.
11. Strapping and anchoring equipment § 3285.404 Severe climatic conditions.
must be certified by a registered professional In frost-susceptible soil locations,
engineer or registered architect or must be ground anchor augers must be installed

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Subpart F—Optional Features gain can be found on the home’s must ensure that the roof will support
comfort cooling certificate. the weight of the cooler.
§ 3285.501 Home installation manual (B) The BTU/hr. rated capacity of the (C) A rigid base must be provided to
supplements. site-installed air conditioning distribute the cooler weight over
Supplemental instructions for equipment must not exceed the air multiple roof trusses to adequately
optional equipment or features must be distribution system’s rated BTU/hr. support the weight of the evaporative
approved by the DAPIA as not taking capacity as shown on the home’s cooler.
the home out of conformance with the compliance certificate. (ii) An evaporative cooler that is not
requirements of this part, or part 3280 (ii) Circuit rating. If a manufactured roof-mounted is to be installed in
of this chapter, and included with the home is factory-provided with an accordance with the requirements of its
manufacturer installation instructions. exterior outlet to energize heating and/ listing or the equipment manufacturer’s
or air conditioning equipment, the instructions, whichever is the more
§ 3285.502 Expanding rooms. branch circuit rating on the tag adjacent restrictive.
The support and anchoring systems to this outlet must be equal to or greater (b) Fireplaces and wood-stoves. When
for expanding rooms must be installed than the minimum circuit amperage not provided by the home manufacturer,
in accordance with designs provided by identified on the equipment rating plate. fireplaces and wood-stoves including
the home manufacturer or prepared by (iii) A-coil units. chimneys and air inlets for fireplaces
a registered professional engineer or (A) A-coil air conditioning units must and wood stoves must be listed for use
registered architect, in accordance with be compatible and listed for use with with manufactured homes and must be
acceptable engineering practice. the furnace in the home and installed in installed in accordance with their
accordance with the appliance listings.
§ 3285.503 Optional appliances. manufacturer’s instructions. (c) Appliance venting.
(a) Comfort cooling systems. When (B) The air conditioner manufacturer
(1) All fuel burning heat producing
not provided and installed by the home instructions must be followed.
(C) All condensation must be directed appliances of the vented type except
manufacturer, any comfort cooling ranges and ovens must be vented to the
systems that are installed must be beyond the perimeter of the home by
means specified by the equipment exterior of the home.
installed according to the appliance (2) Upon completion, the venting
manufacturer’s installation instructions. manufacturer.
(2) Heat pumps. Heat pumps must be system must comply with all
(1) Air conditioners. Air conditioning requirements of §§ 3280.707(b) and
listed or certified by a nationally
equipment must be listed or certified by 3280.710 of the Manufactured Home
recognized testing agency for the
a nationally recognized testing agency Construction and Safety Standards in
application for which the unit is
for the application for which the unit is this chapter.
intended and installed in accordance
intended and installed in accordance (3) When the vent exhausts through
with the terms of its listing or
with the terms of its listing or the floor, the vent must not terminate
certification. (See § 3280.714 of this
certification (see § 3280.714 of this under the home and must extend to the
chapter).
chapter). home’s exterior and through any
(3) Evaporative coolers.
(i) Energy efficiency. (i) A roof-mounted cooler must be skirting that may be installed.
(A) Site-installed central air listed or certified by a nationally (d) Clothes dryer exhaust duct system.
conditioning equipment must be sized recognized testing agency for the A clothes dryer exhaust duct system
to meet the home’s heat gain application for which the unit is must conform with and be completed in
requirement, in accordance with intended and installed in accordance accordance with the appliance
Chapter 28 of the 1997 ASHRAE with the terms of its listing (see manufacturer instructions and
Handbook of Fundamentals § 3280.714 of this chapter). § 3280.708 of this chapter. The vents
(incorporated by reference, see § 3285.4) (A) Any discharge grill must not be must exhaust to the exterior of the
or ACCA Manual J, Residential Cooling closer than three feet from a smoke home, beyond any perimeter skirting
Load, 8th Edition (incorporated by alarm. installed around it, as shown in Figure
reference, see § 3285.4). Information (B) Before installing a roof-mounted to § 3285.503.
necessary to calculate the home’s heat evaporative cooler on-site, the installer BILLING CODE 4210–07–C
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Notes: mil polyethylene sheet material or other supplied and shipped loose ducts,
1. Installation of the exhaust system must acceptable vapor retarder is installed, plumbing, and fuel supply system parts
be in accordance with the dryer manufacturer according to § 3285.204, on the ground that are necessary to join all sections of
instructions. surface beneath the entire floor area of the home and are designed to be located
2. Dryer exhaust system must not contain
reverse slope or terminate under the home.
the home. underneath the home. The installation
(b) Ventilation openings must be instructions must be designed in
§ 3285.504 Skirting.
placed as high as practicable above the accordance with applicable
ground. requirements of part 3280, subparts G
(a) Skirting, if used, must be of (c) Ventilation openings must be and H, of this chapter, as specified in
weather-resistant materials or provided located on at least two opposite sides to this subpart.
with protection against weather provide cross-ventilation.
deterioration at least equivalent to that (d) Ventilation openings must be § 3285.602 Utility connections.
provided by a coating of zinc on steel covered for their full height and width Refer to § 3285.904 for considerations
of not less than 0.30 oz./ft.2 of surface with a perforated corrosion and for utility system connections.
coated. weather-resistant covering that is
(b) Skirting must not be attached in a § 3285.603 Water supply.
designed to prevent the entry of rodents.
manner that can cause water to be In areas subject to freezing, the (a) Crossover. Multi-section homes
trapped between the siding and trim or coverings for the ventilation openings with plumbing in both sections require
forced up into the wall cavities trim to must also be of the adjustable type, water-line crossover connections to join
which it is attached. permitting them to be in the open or all sections of the home. The crossover
(c) All wood skirting within 6 inches closed position, depending on the design requirements are located in, and
of the ground must be pressure-treated climatic conditions. must be designed in accordance with,
in accordance with AWPA Standard U1 (e) Access opening(s) not less than 18 § 3280.609 of this chapter.
(incorporated by reference, see § 3285.4) inches in width and 24 inches in height (b) Maximum supply pressure and
for Use Category 4A, Ground Anchor and not less than three square feet (ft.2) reduction. When the local water supply
Contact Applications, or be naturally in area must be provided and must be pressure exceeds 80 psi to the
resistant to decay and termite located so that any utility connections manufactured home, a pressure-
infestations. located under the home are accessible. reducing valve must be installed.
(d) Skirting must not be attached in a (f) Dryer vents and combustion air (c) Mandatory shutoff valve.
manner that impedes the contraction inlets must pass through the skirting to (1) An identified and accessible
and expansion characteristics of the the outside. Any surface water runoff shutoff valve must be installed between
home’s exterior covering. from the furnace, air conditioning, or the water supply and the inlet.
§ 3285.505 Crawlspace ventilation. water heater drains must be directed (2) The water riser for the shutoff
away from under the home or collected valve connection must be located
(a) A crawlspace with skirting must be by other methods identified in
provided with ventilation openings. The underneath or adjacent to the home.
§ 3285.203.
minimum net area of ventilation (3) The shutoff valve must be a full-
openings must not be less than one Subpart G—Ductwork and Plumbing flow gate or ball valve, or equivalent
square foot (ft.2) for every 150 square and Fuel Supply Systems valve.
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feet (ft.2) of the home’s floor area. The (d) Freezing protection. Water line
total area of ventilation openings may be § 3285.601 Field assembly. crossovers completed during
reduced to one square foot (ft.2) for Home manufacturers must provide installation must be protected from
every 1,500 square feet (ft.2) of the specific installation instructions for the freezing. The freeze protection design
ER19OC07.017</GPH>

home’s floor area, where a uniform 6– proper field assembly of manufacturer- requirements are located in, and must

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be designed in accordance with, completion at the site. The installation home, they must be installed and
§ 3280.603 of this chapter. instructions must provide testing supported in accordance with
(1) If subject to freezing temperatures, requirements that are consistent with § 3280.608 of this chapter.
the water connection must be wrapped § 3280.612 of this chapter. (c) Proper slopes. Drains must be
with insulation or otherwise protected (2) The water heater must be completed in accordance with
to prevent freezing. disconnected when using an air-only § 3280.610 of this chapter.
(2) In areas subject to freezing or test. (1) Drain lines must not slope less
subfreezing temperatures, exposed
§ 3285.604 Drainage system. than one-quarter inch per foot, unless
sections of water supply piping, shutoff
(a) Crossovers. Multi-section homes otherwise noted on the schematic
valves, pressure reducers, and pipes in
with plumbing in more than one section diagram, as shown in Figure to
water heater compartments must be
require drainage system crossover § 3285.604.
insulated or otherwise protected from
freezing. connections to join all sections of the (2) A slope of one-eight inch per foot
(3) Use of pipe heating cable. Only home. The crossover design may be permitted when a clean-out is
pipe heating cable listed for requirements are located in, and must installed at the upper end of the run.
manufactured home use is permitted to be designed in accordance with, (d) Testing procedures. The drainage
be used, and it must be installed in § 3280.610 of this chapter. system must be inspected and tested for
accordance with the cable manufacturer (b) Assembly and support. If portions leaks after completion at the site. The
installation instructions. of the drainage system were shipped installation instructions must provide
(e) Testing procedures. loose because they were necessary to testing requirements that are consistent
(1) The water system must be join all sections of the home and with § 3280.612 of this chapter.
inspected and tested for leaks after designed to be located underneath the BILLING CODE 4210–07–P

§ 3285.605 Fuel supply system. must be designed in accordance with, All ductwork connections, including
(a) Proper supply pressure. The gas § 3280.705 of this chapter. duct collars, must be sealed to prevent
piping system in the home is designed (2) Tools must not be required to air leakage. Galvanized metal straps or
for a pressure that is at least 7 inches of connect or remove the flexible tape and mastics listed to UL 181A
water column [4oz./in.2 or 0.25 psi] and connector quick-disconnect. (incorporated by reference, see
not more than 14 inches of water (c) Testing procedures. The gas § 3285.4), for closure systems with rigid
column [8 oz./in.2 or 0.5 psi]. If gas from system must be inspected and tested for air ducts and connectors, or UL 181B
any supply source exceeds, or could leaks after completion at the site. The (incorporated by reference, see
exceed this pressure, a regulator must be installation instructions must provide § 3285.4), for closure systems with
installed if required by the LAHJ. testing requirements that are consistent flexible air ducts and connectors, must
with § 3280.705 of this chapter. be used around the duct collar and
(b) Crossovers. secured tightly to make all connections.
sroberts on PROD1PC70 with RULES

(1) Multi-section homes with fuel § 3285.606 Ductwork connections. (b) If metal straps are used, they must
supply piping in both sections require (a) Multi-section homes with be secured with galvanized sheet metal
crossover connections to join all ductwork in more than one section screws.
sections of the home. The crossover require crossover connections to (c) Metal ducts must be fastened to
ER19OC07.018</GPH>

design requirements are located in, and complete the duct system of the home. the collar with a minimum of three

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galvanized sheet metal screws equally installation instructions. When straps crossover ducts are permitted, in
spaced around the collar. are used to support a flexible type duct, accordance with § 3285.606(g).
(d) Air conditioning or heating ducts the straps must be at least 1⁄2″ wider (f) Crossover ducts outside the
must be installed in accordance with than the spacing of the metal spirals thermal envelope must be insulated
applicable requirements of the duct encasing the duct. The ducts must be with materials that conform to designs
manufacturer installation instructions. installed such that the straps cannot slip consistent with part 3280, subpart F of
(e) The duct must be suspended or between any two spirals and arranged
supported above the ground by straps or this chapter.
under the floor to prevent compression
other means that are spaced at a (g) In-floor or ceiling crossover duct
or kinking in any location, as shown in
maximum distance not to exceed 4′–0″ connections must be installed and
Figures A and B to this section. In-floor
or as otherwise permitted by the sealed to prevent air leakage.

Notes: floor and the furnace is outside the I–Beam. 2. The crossover duct must be listed for
1. This system is typically used when a With this type of installation, it is necessary exterior use.
crossover duct has not been built into the for two flexible ducts to be installed.

Notes: crossover connections to join all listings and part 3280, subpart I of this
1. This system is typically used when a sections of the home. The crossover chapter.
crossover duct has not been built into the must be designed in accordance with (b) Grounding. (1) All the exterior
floor and the furnace is situated directly over part 3280, subpart I of this chapter, and
lighting fixtures and ceiling fans
the main duct in one section of the home. A completed in accordance with the
single flexible duct is then used to connect
installed per § 3285.702(a) must be
directions provided in the installation
the two sections to each other. grounded by a fixture-grounding device
instructions.
2. The crossover duct must be listed for or by a fixture-grounding wire.
exterior use. § 3285.702 Miscellaneous lights and (2) For chain-hung lighting fixtures, as
fixtures.
shown in Figure A to this section, both
Subpart H—Electrical Systems and (a) When the home is installed,
Equipment exterior lighting fixtures, ceiling-
suspended (paddle) fans, and chain-
ER19OC07.020</GPH>

§ 3285.701 Electrical crossovers.


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hung lighting fixtures are permitted to


Multi-section homes with electrical be installed in accordance with their
wiring in more than one section require
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a fixture-grounding device and a fixture- (4) The lighting fixture must be must be inspected and tested at the site,
grounding wire must be used. The caulked around its base to ensure a in accordance with the testing
identified conductor must be the neutral watertight seal to the sidewall. requirements of § 3280.810(b) of this
conductor. (5) The light bulb must be installed chapter.
(c) Where lighting fixtures are and the globe must be attached. (2) The installation instructions must
mounted on combustible surfaces such (e) Ceiling fans. (1) Ceiling-suspended indicate that each manufactured home
as hardboard, a limited combustible or (paddle) fans must be connected to must be subjected to the following tests:
noncombustible ring, as shown in junction box listed and marked for (i) An electrical continuity test to
Figures A and B to this section, must be ceiling fan application, in accordance ensure that metallic parts are effectively
installed to completely cover the with Article 314.27(b) of the National bonded;
combustible surface exposed between Electrical Code, NFPA No. 70–2005 (ii) Operational tests of all devices
the fixture canopy and the wiring outlet (incorporated by reference, see and utilization equipment, except water
box. § 3285.4); and heaters, electric ranges, electric
(2) The ceiling fan must be installed furnaces, dishwashers, clothes washers/
(d) Exterior lights. (1) The junction
with the trailing edges of the blades at dryers, and portable appliances, to
box covers must be removed and wire-
least 6 feet 4 inches above the finished demonstrate that they are connected and
to-wire connections must be made using
floor; and in working order; and
listed wire connectors.
(3) The wiring must be connected in (iii) For electrical equipment installed
(2) Wires must be connected black-to- accordance with the product or completed during installation,
black, white-to-white, and equipment manufacturer installation instructions. electrical polarity checks must be
ground-to-equipment ground. (f) Testing. (1) After completion of all completed to determine that
(3) The wires must be pushed into the electrical wiring and connections, connections have been made properly.
box, and the lighting fixture must be including crossovers, electrical lights, Visual verification is an acceptable
secured to the junction box. and ceiling fans, the electrical system electrical polarity check.
sroberts on PROD1PC70 with RULES

ER19OC07.021</GPH>

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§ 3285.703 Smoke alarms. with exterior sealant (see figure A to this all requirements of the Manufactured
Smoke alarms must be functionally section). Home Construction and Safety
tested in accordance with applicable (b) Joints and seams. All joints and Standards (24 CFR part 3280) and the
requirements of the smoke alarm seams in exterior wall coverings that Manufactured Home Procedural and
manufacturer instructions and must be were disturbed during location of the Enforcement Regulations (24 CFR part
consistent with § 3280.208 of this home must be made weatherproof. 3282). Unless exempted by the
chapter. (c) Prior to installing the siding, the following provisions, hinged roofs are
polyethylene sheeting covering exterior also subject to a final inspection for
§ 3285.704 Telephone and cable TV. walls for transit must be completely compliance with the Manufactured
Refer to § 3285.906 for considerations removed. Home Construction and Safety
pertinent to installation of telephone (d) Prior to completing the exterior Standards (24 CFR part 3280) by the
and cable TV. close-up, any holes in the roofing must IPIA or a qualified independent
be made weatherproof and sealed with inspector acceptable to the IPIA. Homes
Subpart I—Exterior and Interior Close- a sealant or other material that is with hinged roofs that are exempted
Up suitable for use with the roofing in from IPIA inspection are instead to be
which the hole is made. completed and inspected in accordance
§ 3285.801 Exterior close-up. (e) Mate-line gasket. The home with the Manufactured Home
(a) Exterior siding and roofing manufacturer must provide materials Installation Program (24 CFR part 3286).
necessary to join all sections of the and designs for mate-line gaskets or This includes homes:
home must be installed according to the other methods designed to resist the
product manufacturer installation entry of air, water, water vapor, insects, (1) That are designed to be located in
instructions and must be fastened in and rodents at all mate-line locations Wind Zone I;
accordance with designs and exposed to the exterior (see Figure B to (2) In which the pitch of the hinged
manufacturer instructions, consistent this section). roof is less than 7:12; and
with §§ 3280.305 and 3280.307 of this (f) Hinged roofs and eaves. Hinged (3) In which fuel burning appliance
chapter. Exterior close-up strips/trim roofs and eaves must be completed flue penetrations are not above the
must be fastened securely and sealed during installation in compliance with hinge.
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Notes: equivalent and protect all exposed materials 3. All home installers must ensure that all
1. Multi-section homes with horizontal-lap not designed for exposure to the weather field installed trim, windows, doors, and
siding can be shipped with no siding on the with plastic sheeting for transport. Siding, other openings are properly sealed according
front and rear end walls. starter trim, and vents may be shipped loose to the siding manufacturer installation
2. The manufacturer must install doors/ in the home for installation on set-up. instructions.
windows trimmed with J-rail or the

Note: On multi-section manufactured § 3285.802 Structural interconnection of (b) Structural interconnection must be
ER19OC07.024</GPH>

homes, install the sealer gasket on the multi-section homes. designed in accordance with the
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ceiling, end walls, and floor mate-line prior requirements located in § 3280.305 of
(a) For multi-section homes, structural
to joining the sections together. this chapter to ensure a completely
interconnections along the interior and
exterior at the mate-line are necessary to integrated structure.
ER19OC07.023</GPH>

join all sections of the home.

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(c) Upon completion of the exterior shimmed with dimensional lumber, and packaged or shipped with the home for
close-up, no gaps are permitted between fastener lengths used to make site installation.
the structural elements being connections between the structural (c) Shipped-loose wall paneling
interconnected along the mate-line of elements must be increased to provide necessary for the joining of all sections
multi-section homes. However, prior to adequate penetration into the receiving of the home must be installed by using
completion of the exterior close-up, member. polyvinyl acetate (PVA) adhesive on all
gaps that do not exceed one inch are
§ 3285.803 Interior close-up. framing members and fastened with
permitted between structural elements
provided: minimum 11⁄2 inch long staples or nails
(a) All shipping blocking, strapping, at 6 inches on center panel edges and 12
(1) The gaps are closed before
or bracing must be removed from inches on center in the field, unless
completion of close-up;
(2) The home sections are in contact appliances, windows, and doors. alternative fastening methods are
with each other; and (b) Interior close up items necessary permitted in the installation
(3) The mating gasket is providing a to join all sections of the home or items instructions (see Figure A to
proper seal. All such gaps must be subject to transportation damage may be § 3285.803).

Note: Specific designs must be approved (d) All edges of repaired areas must be manufactured home, as constructed in
by a DAPIA and included in the home taped or otherwise sealed. accordance with the MHCSS.
manufacturer installation instructions.
Subpart J—Optional Information for § 3285.902 Moving manufactured home to
location.
§ 3285.804 Bottom board repair. Manufacturer’s Installation
Instructions It is recommended that the
(a) The bottom board covering must
installation instructions indicate that
be inspected for any loosening or areas § 3285.901 General. the LAHJ be informed before moving the
that might have been damaged or torn
The planning and permitting manufactured home to the site. It is also
during installation or transportation.
processes, as well as utility connection, recommended that the installation
Any missing insulation is to be replaced instructions indicate that the
prior to closure and repair of the bottom access, and other requirements, are
outside of HUD’s authority and may be manufactured home is not to be moved
board. to the site until the site is prepared in
governed by LAHJs. These Model
(b) Any splits or tears in the bottom accordance with subpart C of this part
board must be resealed with tape or Installation Standards do not attempt to
and when the utilities are available as
patches in accordance with methods comprehensively address such
required by the LAHJ. Examples of
provided in the manufacturers requirements. However, HUD
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related areas that might be addressed in


installation instructions. recommends that the manufacturer’s the installation instructions for meeting
installation instructions include the this recommendation include:
(c) Plumbing P-traps must be checked information and advisories in this
to be sure they are well-insulated and (a) Access for the transporter. Before
Subpart J, in order to protect the
ER19OC07.025</GPH>

covered. attempting to move a home, ensure that

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the transportation equipment and home including any attached garage, carport, coupler or by other methods acceptable
can be routed to the installation site and deck, and porch, is to be attached to the to the LAHJ, as shown in Figure A to
that all special transportation permits manufactured home and is otherwise this section.
required by the LAHJ have been included in the installation instructions (d) Fuel supply system.
obtained. or designed by a registered professional (1) Conversion of gas appliances. A
(b) Drainage structures. Ditches and engineer or registered architect. service person acceptable to the LAHJ
culverts used to drain surface runoff must convert the appliance from one
meet the requirements of the LAHJ and § 3285.904 Utility system connections.
type of gas to another, following
are considered in the overall site (a) It is recommended that the instructions by the manufacturer of each
preparation. manufacturer’s installation instructions appliance.
indicate the following procedures be
§ 3285.903 Permits, alterations, and on- (2) Orifices and regulators. Before
used prior to making any utility system
site structures. making any connections to the site
connection:
It is recommended that the supply, the inlet orifices of all gas-
(1) Where an LAHJ and utility
installation instructions include the burning appliances must be checked to
services are available, that the LAHJ and
following information related to ensure they are correctly set up for the
all utility services each be consulted
permits, alterations, and on-site type of gas to be supplied.
before connecting the manufactured
structures: home to any utilities, or (3) Connection procedures. Gas-
(a) Issuance of permits. All necessary (2) Where no LAHJ exists and utility burning appliance vents must be
LAHJ fees should be paid and permits services are available, that the utilities inspected to ensure that they are
should be obtained, which may include be consulted before connecting the connected to the appliance and that roof
verification that LAHJ requirements manufactured home to any utility jacks are properly installed and have not
regarding encroachments in streets, service; or come loose during transit.
yards, and courts are obeyed and that (3) In rural areas where no LAHJ or (4) Gas appliance start-up procedures.
permissible setback and fire separation utility services are available, that a The LAHJ should be consulted
distances from property lines and public professional be consulted prior to concerning the following gas appliance
roads are met. making any system connections. startup procedures:
(b) Alterations. Prior to making any (b) Qualified personnel. Only (i) One at a time, opening equipment
alteration to a home or its installation, qualified personnel familiar with local shutoff valves, lighting pilot lights when
contact the LAHJ to determine if plan requirements are permitted to make provided, and adjusting burners and
approval and permits are required. utility site connections and conduct spark igniters for automatic ignition
(c) Installation of on-site structures. tests. systems, in accordance with each
Each accessory building and structure is (c) Drainage system. The main drain appliance manufacturer instructions.
designed to support all of its own live line must be connected to the site’s (ii) Checking the operation of the
and dead loads, unless the structure, sewer hookup, using an elastomeric furnace and water heater thermostats.

Note: Fittings in the drainage system that by reference, see § 3285.4) or the LAHJ, elevation, or anchored and designed to
are subject to freezing, such as P-traps in the whichever is more stringent. prevent flotation, collapse, or
floor, are protected with insulation by the (b) The oil burning furnace permanent lateral movement during the
manufacturer. Insulation must be replaced if manufacturer’s instructions should be design flood.
it is removed for access to the P-trap.
consulted for pipe size and installation (3) Leak test procedure. Before the
procedures. system is operated, it should be checked
§ 3285.905 Heating oil systems. (c) Oil storage tanks and pipe for leaks in the tank and supply piping,
It is recommended that the installations should meet all applicable in accordance with NFPA 31, Standard
installation instructions include the local regulations. for the Installation of Oil Burning
following information related to heating (d) Tank installation requirements. Equipment, 2001 (incorporated by
oil systems, when applicable: (1) The tank should be located where reference, see § 3285.4) or the
(a) Homes equipped with oil burning it is accessible to service and supply requirements of the LAHJ, whichever is
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furnaces should have their oil supply and where it is safe from fire and other more stringent.
tank and piping installed and tested on- hazards.
site, in accordance with NFPA 31, (2) In flood hazard areas, the oil § 3285.906 Telephone and cable TV.
Standard for the Installation of Oil storage tank should be anchored and It is recommended that the
ER19OC07.026</GPH>

Burning Equipment, 2001 (incorporated elevated to or above the design flood installation instructions explain that

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Federal Register / Vol. 72, No. 202 / Friday, October 19, 2007 / Rules and Regulations 59395

telephone and cable TV wiring should § 3285.907 Manufacturer additions to do not take the manufactured home out
be installed in accordance with installation instructions. of compliance with the MHCSS.
requirements of the LAHJ and the A manufacturer may include in its Dated: September 18, 2007.
National Electrical Code, NFPA No. 70– installation instructions items that are Brian D. Montgomery,
2005 (incorporated by reference, see not required by this chapter as long as Assistant Secretary for Housing—Federal
§ 3285.4). the items included by the manufacturer Housing Commissioner.
are consistent with the Model [FR Doc. 07–5004 Filed 10–18–07; 8:45 am]
Installation Standards in this part and BILLING CODE 4210–67–P
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