To: File 

From: Michael Jensen, DOE GC-71 

Date: August 17, 2010 

Re: Ex parte discussion with State of Georgia Manufactured Housing Division 

On August 17, 2010, Michael Jensen (GC-71), Saralyn Bunch (EE-2J), Harry Indig (EE2J), Bob Lucas (PNL), and Dave Conover (PNL) spoke with Chris Stephens, 

Commissioner of Insurance in the Georgia Manufactured Housing Section, and Nolan 

Courson, the Georgia Production Inspection Primary Inspection Agency (IPIA) designee, 

on Georgia’s role as both a State Administrative Agency (SAA) and as an IPIA under the 

U.S. Department of Housing and Urban Development (HUD) manufactured housing 

program. 

First, Mr. Stephens explained that Georgia fulfills three general responsibilities as an 

SAA: (1) monitoring the industry and assisting consumers in remedying defects in the 

construction of manufactured homes; (2) ensuring that homes comply with designs 

approved by design approval primary inspection agencies (DAPIAs); and (3) performing 

installation inspections. Mr. Stephens noted that each manufactured home sold contains a 

manual, which the public can use to contact a particular SAA to report a complaint with 

the home. He further noted that consumers often will contact the manufacturer or HUD 

with a complaint, but that the consumer is then referred to the SAA. Mr. Stephens 

mentioned that Georgia will perform site inspections based on complaints received and 

had investigated 128 of the 143 complaints to date that the state has received this year. 

Mr. Stephens noted that Georgia used to receive 700 to 800 consumer complaints in a 

year, but that this number had decreased to an average of 150 complaints per year due to 

decreases in manufactured home production. He noted that the two most common 

energy-related complaints were that HVAC system piping was not insulated or sealed 

properly and that the sections of multi-section homes were not placed together properly. 

Finally, Mr. Stephens mentioned that Georgia also performs monthly IPIA file reviews to 

ensure that manufacturers are adequately responding to in-state and out-of-state consumer 

complaints. 

Mr. Stephens acknowledged that Georgia has not undertaken an official enforcement 

action in roughly five years and that three enforcement actions had been pursued since 

1997. He explained that the low numbers were due to the ease with which problems were 

resolved in the state due, in part, to Georgia’s ability to fine manufacturers, revoke their 

licenses, and to mandate that a manufacturer perform multiple inspections of 

manufactured homes. Mr. Stephens stated that Georgia is required to inspect at least one 

home per year of a manufactured home license-holder. He noted that Georgia also 

requires installers to submit monthly reports of all homes installed within the state. 

Regarding the certification process, Mr. Stephens noted that manufactured homes have to 

meet stringent standards and that many manufacturers participate in the ENERGY STAR 

program. He suggested that, if DOE were to require third-party inspections, the agency 

should consider requiring manufacturers to submit designs to DOE for approval so that 

the agency could ensure that the manufacturer would build homes consistent with DOE’s 
energy standards. Mr. Stephens mentioned that the greatest cost to manufacturers is 

having to make repairs in the field and that a system where DOE would assess fines after 

performing random site inspections would give a strong incentive to the manufactured 

housing industry to comply quickly with DOE’s energy efficiency standards. Mr. 

Stephens also noted that Georgia performs joint SAA-IPIA site inspections and also 

authorizes other IPIAs to inspect manufactured homes as part of HUD’s alternative 

construction certification process. 

Mr. Stephens then discussed the issue of fees assessed both by HUD and by Georgia. He 

noted that HUD pays Georgia $2.50 for every manufactured home produced within the 

state and pays the state $9.00 for every manufactured home shipped to Georgia from 

another state. He also explained that manufacturers pay Georgia $30.00 per certification 

label (with a $15.00 re-inspection fee) per manufactured home floor and that Georgia 

assesses a fee of $60.00 per permit for every manufactured home that is installed in the 

state. He also noted that Georgia’s annual license fee for manufacturers is $440.00, the 

annual license fee for installers is $300.00, and that the annual license fee for retailers 

and retail brokers is $300.00 for each retail location. Mr. Stephens noted that, in total, 

Georgia received roughly $340,000 in fees to fund the SAA program and approximately 

$300,000 from manufacturers as part of Georgia’s role as an IPIA. Mr. Stephens stressed 

that Georgia has had difficulty operating under this purported self-sustaining budget and 

noted that private IPIAs often charge much higher inspection fees than does Georgia. He 

recommended that DOE ensure that any fees charged by the agency for its program 

would offset the costs of services in order to attract state agencies and state third-party 

inspectors to the DOE program. 

Mr. Stephens noted that six production lines and manufacturing facilities currently are in 

operation within the state, down from 48 production lines in 33 facilities in 1997. Mr. 

Stephens explained that every manufacturer must be certified by the Georgia IPIA before 

building manufactured homes, such that the state is responsible for certifying that 

manufacturers can build homes in compliance with the HUD Code. He explained that 

Georgia performs an initial certification of plants and requires recertification if certain 

changes are made in the plant or if the IPIA discovers that a manufacturer is incapable of 

building homes to the HUD standards. Mr. Stephens mentioned that Georgia currently is 

in the process of reevaluating each plant within the state. Mr. Stephens stated that 

installers in the state are required to undertake an initial training class and pass an exam 

given by the state. Installers also are required to perform a minimum of eight hours of 

continuing education each year based on common problems that Georgia has found in the 

field. Finally, Mr. Stephens noted that states that participate in the HUD program (as 

well as IBTS) are meeting in Washington, DC, in mid-September 2010, and that DOE 

might consider attending the conference in order to meet with and learn from other HUD 

program states. 

End of conversation.