“Think Tank” Proposes New Manufactured Housing Rules: Another Step Toward Abundant Housing

The following comments are submitted on behalf of the Niskanen Center. The Niskanen Center is a non-partisan 501(C)(3) think tank in Washington, D.C., that works to promote an open society.

The Niskanen Center has proposed to HUD a multitude of rule changes, improvements, and clarifications, as well as further non-rule changes for improvements to the regulatory treatment of manufactured housing; the full text of these issues directed to HUD are available at www.niskanen.org/ new manufactured housing rules.

By Alex Armloich, Andrew Justos

November 1,2022

In progressive neighborhoods across the country, there is support for marginalized groups. But these same residents often protest and work to prevent efforts to build mixed-income affordable housing in their neighborhoods. Mobile homes, or technically manufactured homes, are among the most maligned forms of affordable housing. They are also the most economically accessible housing for many Americans.

Manufactured homes come in many forms. Entry-level models are broadly affordable for low and moderate-income Americans. Larger and higher-end models can meet the aesthetic and functional expectations in many communities across the country.

The Niskanen Center espouses more housing of all types, including manufactured homes. Recently, the Department of Housing and Urban Development (HUD) invited the public to comment on revisions to the Manufactured Home Construction and Safety Standards, also called the “HUD Code,” which regulates manufactured homes. In response, we offered our suggestions on how HUD can make it easier to build safer, more affordable, and higher quality manufactured homes – at least for the limited spaces where it is legal to place them.

The HUD Code works best when it reduces the cost of entry-level manufactured homes and allows improved quality for high-end models. HUD proposed streamlining the code to provide standard approval, rather than “alternative construction” approval, of modern construction methods that allow manufactured homes to provide the aesthetics and build quality of site-built homes. The code changes will allow manufacturers to offer higher-quality homes and install them faster. The attractive new designs will make it harder for communities to discriminate based on exterior aesthetics.

Unfortunately, some critical improvements are still outside HUD’s control. For example, existing federal legislation requires manufactured homes to retain the trailer chassis that sits beneath every manufactured home, even after the house is permanently installed onto the land and hooked up to utilities. That adds unnecessary cost to manufactured homes for no meaningful improvement in durability.

The proposed rule allows some multifamily manufactured housing, a critical step in the right direction of allowing manufactured housing to compete in regions with higher land costs. However, it is still determined how the agency arrived at a maximum of three units.

We applaud HUD’s intentions to improve access to and quality of manufactured housing and encourage the agency to continue improving the code, especially by clarifying regulations around multifamily manufactured housing.

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