HUD Will Not Finalize Proposed “Frost-Free” Interpretive Bulletin


OCTOBER 17, 2018

 TO:                 MHARR MANUFACTURERS

                        MHARR STATE AFFILIATES

                        MHARR TECHNICAL REVIEW GROUP (TRG)

 FROM:          MHARR

 RE:  HUD Will Not Finalize Proposed “Frost-Free” Interpretive Bulletin

HUD’s Installation contractor, SEBA Professional Services, Inc., (SEBA) announced during an open industry conference call on October 16, 2018, that the Department’s June 21, 2017 proposed Interpretive Bulletin (IB) concerning so-called “frost-free” foundations (designated IB I-1-17) — consistently and strenuously opposed by MHARR since its initial publication – will not be finalized or issued by HUD as a final, binding IB.

MHARR specifically opposed the IB – which would have substantively changed the underlying HUD installation standard concerning foundations for frost-prone soils — in written comments filed on August 17, 2017, following publication of the proposed IB in the Federal Register, and called again for its withdrawal in February 20, 2018 comments filed pursuant to HUD’s manufactured housing regulatory review process under Trump Administration Executive Orders 13771 and 13777.

MHARR also raised the proposed “frost-free” IB as an example of baseless HUD regulatory excesses in 2018 meetings with HUD Secretary Ben Carson and HUD Assistant Secretary Brian Montgomery.

Most recently, the Manufactured Housing Consensus Committee (MHCC), at its September 11-13, 2018 meeting, had voted to recommend to HUD that the pending IB, one of the last administrative actions of former program administrator Pamela Danner, be withdrawn.

MHARR continues to press for the invalidation or withdrawal of other “field guidance” and related HUD pseudo-regulatory memoranda and pronouncements that were issued (and have been enforced) without notice and comment rulemaking as required by applicable law.

cc: Other Interested HUD Code Industry Members

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