59338 Federal Register / Vol. 72, No. 202 / Friday, October 19, 2007 / Rules and Regulations 

DEPARTMENT OF HOUSING AND 

URBAN DEVELOPMENT 

24 CFR Parts 3280 and 3285 

[Docket No. FR–4928–F–02] 

RIN 2502–AI25 

Model Manufactured Home Installation 

Standards 

AGENCY: Office of the Assistant 

Secretary for Housing—Federal Housing 

Commissioner, HUD. 

ACTION: Final rule. 

SUMMARY: This final rule establishes 

new Model Manufactured Home 

Installation Standards (Model 

Installation Standards) for the 

installation of new manufactured homes 

and includes standards for the 

completion of certain aspects necessary 

to join all sections of multi-section 

homes. The National Manufactured 

Housing Construction and Safety 

Standards Act of 1974 requires HUD to 

develop and establish Model 

Installation Standards after receiving 

proposed installation standards from the 

Manufactured Housing Consensus 

Committee (MHCC). HUD received and 

reviewed the MHCC’s recommended 

proposed model installation standards 

and published a proposed rule for 

public comment. Based on HUD’s 

review of the comments that were 

submitted, including those from the 

MHCC, a number of revisions to the 

proposed rule have been made in this 

final rule. This final rule also 

incorporates certain amendments to 

definitions contained in the 

Manufactured Home Construction and 

Safety Standards (MHCSS) that are 

affected by definitions provided in the 

Model Installation Standards. 

DATES: Effective Date: The effective date 

for this final rule will be October 20, 

2008. The date of approval by the 

Director of the Federal Register for 

incorporation by reference of certain 

publications listed in this rule is 

October 20, 2008. 

FOR FURTHER INFORMATION CONTACT: 

William W. Matchneer III, Associate 

Deputy Assistant Secretary for 

Regulatory Affairs and Manufactured 

Housing, Office of Manufactured 

Housing Programs, Department of 

Housing and Urban Development, 451 

Seventh Street, SW., Room 9164, 

Washington, DC 20410; telephone 

number (202) 708–6401 (this is not a 

toll-free number). Hearing-or speechimpaired individuals may access this 

number through TTY by calling the tollfree Federal Information Relay Service 

at (800) 877–8339. 

SUPPLEMENTARY INFORMATION: 

I. Background 

On April 26, 2005, HUD published in 

the Federal Register at 70 FR 21498 a 

proposed rule that would establish 

Model Manufactured Home Installation 

Standards (Model Installation 

Standards) for new manufactured 

homes, as required by the National 

Manufacture Housing Construction and 

Safety Standards Act of 1974 (42 U.S.C. 

5401–5426) (the Act). The Act gave the 

MHCC responsibility to develop and 

submit to the Secretary proposed Model 

Installation Standards. The MHCC’s 

proposal was provided to HUD in 

September 2004. The Department agreed 

with most of the proposal, and 

thoroughly involved the MHCC in the 

process by which the proposed rule for 

the Model Installation Standards was 

developed prior to its publication in the 

Federal Register. 

There were a total of 101 commenters 

on the April 26, 2005, proposed rule. 

Seventy-seven of the commenters were 

from the industry, including 

manufacturers, component suppliers, 

retailers, installers, realtors, trade 

associations, and community operators. 

Nineteen commenters came from the 

government, including HUD-approved 

Primary Inspection Agencies and State 

Administrative Agencies. Finally, four 

commenters were individual consumers 

and consumer groups and one was a 

private code organization. 

Among the recommendations most 

often made by the commenters were: (1) 

To codify the Model Installation 

Standards in existing part 3280 rather 

than new part 3285, in the belief that 

the installation standards would thereby 

become ‘‘preemptive’’ of state and local 

installation standards; (2) to make the 

installation standards applicable to 

secondary or other subsequent 

installations of manufactured homes; (3) 

to include provisions assuring that HUD 

will consult with the MHCC on future 

changes to the installation standards; (4) 

that manufacturers’ installation 

instructions be considered as evidence 

of compliance with the Model 

Installation Standards; (5) that the 

installation standards apply to the 

joining together and close-up of multisection homes and to certain other 

aspects of on-site completion that HUD 

had originally treated as part of the 

construction process. HUD has given 

these subjects particular attention in 

preparing the final rule. 

II.A. Analysis of Public Comments— 

Part 3280 

Comment: § 3280.302 Definitions. 

Two commenters wrote that the 

proposed definition of anchoring system 

should include forces on the foundation 

and anchorage systems, which may 

actually control the design in some 

instances. 

HUD Response: The definition of 

anchoring system includes a reference 

to the forces that are required to be 

resisted by foundation and anchorage 

systems. 

II.B. Analysis of Public Comments— 

Part 3285 

Subpart A—General 

Comment: § 3285.1(a) Scope. The 

Model Installation Standards should be 

preemptive of state and local 

requirements. 

HUD Response: HUD has concluded 

that a plain reading of Sections 604(d) 

and 605 of the Act indicates that 

Congress did not intend for these Model 

Installation Standards to be preemptive 

of more stringent state or local 

government requirements, only that 

they establish minimum national 

requirements for the installation of 

manufactured homes. This conclusion is 

strengthened by the statement from 

then-Chairman Jim Leach during his 

section-by-section comments on the 

floor of the House, that ‘‘the bill would 

reinforce the proposition that 

installation standards and regulations 

remain under the exclusive authority of 

each state.’’ (Dec. 5, 2000, 146 Cong. 

Rec. H11987). In earlier floor remarks, 

then-Ranking Member John LaFalce 

said, ‘‘States that wish to have their own 

installation standards may continue to 

do so, as long as they provide 

protections comparable to the model 

standards.’’ (Oct. 24, 2000, 146 Cong. 

Rec. H10685). HUD therefore believes 

that Congress has permitted any state 

that chooses to operate its own 

installation program to enforce 

installation standards more stringent 

than these Model Installation Standards, 

provided that those standards otherwise 

offer protection that equals or exceeds 

the minimum protection established by 

these Model Installation Standards. 

Comment: § 3285.1(a) Scope. The 

Model Installation Standards should be 

codified under 24 CFR part 3280, 

Manufactured Home Construction and 

Safety Standards. 

HUD Response: Contrary to the views 

expressed by some commenters, 

preemption authority can only come 

from Congress, and no decision that 

HUD could make regarding the 

codification of these Model Installation 

Standards could increase or diminish 

that authority. However, as indicated 

above, HUD believes there is good 

reason to conclude that Congress did 


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not intend to extend preemption 

authority to these Model Installation 

Standards. 

In any event, HUD has chosen, as a 

matter of administrative necessity, to 

codify these Model Installation 

Standards, as in new part 3285 of 24 

CFR, in order to maintain the clear 

distinctions the Act makes between 

installation and construction. The 

regulatory structure that Congress has 

given HUD for enforcement of these 

Model Installation Standards is entirely 

different from the enforcement authority 

it previously gave HUD for the federal 

MHCSS. As HUD reads the Act, section 

613 (42 U.S.C. 5412) and section 615 (42 

U.S.C. 5414), the principal sections 

requiring notification and correction of 

defects, do not apply to these Model 

Installation Standards. As HUD reads 

the Act, the primary enforcement 

authority for these Model Installation 

Standards is instead limited to section 

605 (42 U.S.C. 5404) itself, which not 

only provides more limited authority for 

these Model Installation Standards, but 

also adds entirely new requirements 

regarding the licensing and training of 

installers. 

Given these fundamental differences 

between the installation and 

construction and safety programs, 

publication of these Model Installation 

Standards in new part 3285 of 24 CFR 

will best allow HUD to maintain the 

regulatory separation necessary to 

administer two such different programs. 

Comment: § 3285.1(a) Scope. Work 

associated with the joining together and 

close-up of sections of multi-section 

homes and certain aspects of on-site 

completion should be considered as 

installation of the home and not as 

construction. 

HUD Response: Under the final rule, 

work necessary to join sections of a 

multi-section home, such as work 

identified in Subparts G, H, and I of the 

installation standards, and work 

associated with connecting exterior 

lights, ceiling-hung light fixtures, or 

fans, as identified in Subpart I, are 

treated as installation, and therefore is 

subject to these Model Installation 

Standards and any future requirements 

of the installation program regulations. 

Accordingly, close-up work completed 

on-site would require inspection under 

the Manufactured Home Installation 

Program Proposed Rule published in the 

Federal Register on June 14, 2006. 

However, features such as penetrated 

hinged roofs, high-pitched hinged roofs, 

and eave construction will remain 

subject to the MHCSS and the 

Procedural and Enforcement 

Regulations in 24 CFR part 3282. 

In early drafts of these Model 

Installation Standards, HUD treated all 

activities associated with close-up as 

part of construction of the home and, as 

such, subject to the MHCSS and the 

manufacturer’s certification label. 

However, HUD recognizes that 

installers, not manufacturers, typically 

perform close-up work. Therefore, HUD 

has concluded that the Model 

Installation Standards provide the best 

opportunity to address close-up 

activities and concerns. 

Further, under the final rule, home 

purchasers generally will look to 

installers or retailers who often employ 

or contract with installers to perform 

home installations, to remedy close-up 

problems that are not the result of 

inadequate or incorrect manufacturer 

instructions or of production errors that 

have resulted in the sections of the 

home not fitting together properly. 

Comment: § 3285.1(a) Scope. 

Compliance with the Manufacturer’s 

Installation Instructions should be 

accepted as compliance with the Model 

Installation Standards. Several 

commenters also recommended the 

section be rewritten as follows: ‘‘The 

manufacturer’s installation instructions 

shall apply under any of the following 

conditions where they do not take the 

home out of compliance with the 

Federal Manufactured Housing 

Construction and Safety Standards: (1) 

To items not covered by this standard; 

(2) Where the manufacturer’s approved 

installation instructions provide a 

specific method of performing a specific 

operation or assembly; (3) Where the 

manufacturer’s approved instructions 

exceed this standard.’’

HUD Response: § 3285.1(a) of the final 

rule recognizes that the Model 

Installation standards serve as the basis 

for the manufacturer’s installation 

instructions and accepts those 

instructions for compliance, as long as 

they meet or exceed the minimum 

requirements of the Model Installation 

Standards and do not take the home out 

of compliance with the MHCSS. 

However, the methods for performing 

operations that are included in a 

manufacturer’s installation instructions 

will be enforced by the Department, in 

their entirety. 

Furthermore, the final rule requires 

that manufactured home manufacturers 

include installation instructions with 

each new home. The instructions must 

be approved by a Design Approval 

Primary Inspection Agency (DAPIA) and 

must provide protection to the residents 

of manufactured homes that equals or 

exceeds the protections provided by the 

Model Installation Standards. 

Comment: § 3285.1(a) Scope. The 

Model Installation Standards should be 

applicable to subsequent installations 

beyond the initial siting and placement 

of the manufactured home. 

HUD Response: It is HUD’s position 

that Congress intended the installation 

standards to be applicable only to the 

initial installation of new manufactured 

homes, as indicated by references in 

Section 623(g) of the Act to the date of 

installation and by the definition of 

‘‘purchaser’’ as the first purchaser in 

Section 603 of the Act. A very small 

percentage of manufactured homes are 

ever relocated after the initial siting and 

placement of the homes. The 

Manufactured Home Procedural and 

Enforcement Regulations encourage 

states to establish procedures for the 

inspection of used manufactured homes 

and for monitoring of the installation of 

manufactured homes within each state 

(§ 3282.303), thus indicating the 

regulations’ intent to place the 

supervision of re-installments in the 

hands of the states. 

The final rule does not prevent state 

and local governments from enforcing 

standards for installations after the 

initial installation or from imposing 

higher installation standards than are 

required by HUD’s ‘‘minimum’’ Model 

Installation Standards for the initial or 

any subsequent installation of a 

manufactured home. State standards for 

initial installation must meet or exceed 

HUD’s minimum installation standards, 

while state standards for secondary 

installations do not have to adhere to 

the minimum HUD standards. HUD 

continues to believe that any subsequent 

installation of a manufactured home 

best resides with state authority. 

Notwithstanding all of the above, HUD 

will continue to study this issue in 

developing the final rule for its 

installation program regulations. 

Comment: § 3285.1(c) Consultation 

With the Manufactured Housing 

Consensus Committee. The 

Manufactured Housing Consensus 

Committee (MHCC) should have a 

continuing involvement in revising the 

installation standards. 

HUD Response: HUD agrees with 

comments received from the MHCC and 

others that the Committee should have 

a continuing role in reviewing and 

recommending future changes to the 

Model Installation Standards. HUD 

recognizes the valuable guidance and 

assistance provided by the MHCC 

throughout the rulemaking process with 

the development of these installation 

standards. Accordingly, a new section, 

§ 3285.1(c), ‘‘Consultation with the 

Manufactured Housing Consensus 

Committee,’’ has been included in the 


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final rule. That section provides that 

HUD will afford the MHCC with a 120- 

day opportunity to offer input and 

comment prior to proposing any 

changes to the installation standards. 

The new provisions also direct the 

MHCC to send its own suggested 

changes to the Department at least every 

2 years. The final rule also provides that 

HUD will accept, modify, or reject each 

recommendation and explain to the 

MHCC the reasons behind any 

modifications or rejections of those 

recommendations before publication of 

any new revised standard. 

Comment: 3285.1(d) Administration. 

One commenter wrote that certain 

permanent site-built foundations with 

manufacturer certification are not 

subject to the proposed rule. This 

recognizes that site-built foundations 

under state and local codes are suitable 

and that all localities have such codes. 

It also implies that state and local codes 

for non-permanent foundations are 

lacking and that HUD needs to 

intervene. This does not make sense, 

unless there is a significant difference 

between permanent and non-permanent 

foundation requirements and their 

administration and enforcement. 

HUD Response: This provision stems 

from Section 604(f) of the Act and 24 

CFR part 3282.12 of the Manufactured 

Home Procedural and Enforcement 

Regulations, which require HUD to 

exclude from coverage any structure 

which, among other things, is designed 

to be erected and installed upon a sitebuilt permanent foundation. 

Comment: §§ 3285.2, 3285.301(b), 

3285.401 HUD Question: Should the 

Model Installation Standards offer more 

performance-based equivalents instead 

of prescriptive requirements to facilitate 

the use of alternative installation 

methods? 

HUD Response: Based on the 

recommendations of the MHCC and the 

public comments, the final model 

installation standards are a combination 

of prescriptive and performance 

standards. While the minimum 

standards do offer prescriptive methods 

for compliance, they also provide for 

alternatives in design that will allow for 

innovation. Accordingly, manufacturers’

instructions may be based on either the 

minimum requirements in these model 

installation standards or may use 

performance-based design in 

demonstrating compliance with these 

standards. 

Comment: § 3285.2 Manufactured 

Installation Instructions/HUD Question. 

Should model-specific plans for 

installation be required and, if so, what 

minimum information should be 

required on the plans (i.e., pier 

capacities, minimum support and 

anchorage locations, other structural 

design requirements, plan-specific 

information for completion of utility 

systems, etc.)? 

Comment: This should be left up to 

each manufacturer to decide. 

Comment: There is no need to require 

model-specific home plan criteria for 

every conceivable single or multisection home design as there must be 

some reliance on the manufacturer’s 

installation manual for model-specific 

home designs as the model standard is 

the minimum necessary requirements. 

Comment: There is no need to require 

model-specific plan criteria for every 

conceivable floor plan and design under 

the Model Installation Standards. If 

there needs to be specialized criteria, 

the manufacturer can provide it in the 

installation manual that comes with the 

new home. The DAPIA will determine 

whether the specialized manufacturer’s 

manual has met or exceeds the Model 

Installation Standards. With regard to 

§ 3285.403, the best alternative might be 

to permit the mating line anchorage/ 

connection to be determined by the 

manufacturer’s installation manual. 

HUD Response: HUD has decided that 

model-specific foundation plans are not 

required, but that special foundation 

and anchorage plans are required to 

address site-specific conditions or when 

the support and anchorage methods in 

the manufacturer’s installation 

instructions are not suitable and vary 

from those included with the 

manufacturer’s installation instructions. 

Comment: § 3285.2 Manufactured 

Installation Instructions/HUD Question. 

Should the manufacturer’s installation 

instructions provide that a professional 

engineer or registered architect must be 

consulted when general site conditions 

are not covered by the installation 

instructions? 

Comment: When instructions do not 

address specific site conditions and 

hazards, the foundations and anchorage 

should be designed by a professional 

engineer or registered architect. 

Comment: There is no reason for the 

Model Installation Standards to require 

that a professional engineer or architect 

be consulted for site preparation, if the 

manufacturer’s manual does not cover 

this installation consideration. Such a 

requirement could substantially raise 

the cost of site preparation for the 

retailer/installer. 

Comment: It is not reasonable to 

expect the manufacturer to effectively 

give installation instructions and 

assume liability when they have no sitespecific knowledge. ‘‘A registered 

engineer is the right call.’’

Comment: The only way to get 

efficient and consistent installation 

compliance with both the Model 

Installation Standards and the 

manufacturer’s support requirements is 

to require manufacturers to take 

responsibility for the vertical support of 

their own designs and to provide 

foundation plans with all pier locations 

and minimum pad sizes specified and 

drawn to scale, in a graphical format 

serviceable for both the permit process 

and the foundation layout at the jobsite. 

Comment: All engineered foundations 

should be designed per SEI/ASCE 7, 

Loads for Buildings and Other 

Structures. This will allow engineers 

and architects to develop foundation 

designs that are capable of resisting all 

natural hazards at the site. 

Comment: Experience has shown that 

out-of-state registered professional 

engineers and architects unfamiliar with 

the conditions of the locality design 

foundation systems that fail, and that 

the engineer or architect should be 

registered in the state where the home 

is to be installed. 

HUD Response: Section 3285.2(c) of 

the final rule has been revised 

specifically to allow for variations to be 

made to installation instructions for site 

conditions that are not covered, 

provided that installers first attempt to 

obtain those variations for site-specific 

conditions from the manufacturer and, 

if not available from the manufacturer, 

the installer is to use designs prepared 

by a professional engineer or registered 

architect. The installer must have the 

professional engineer’s or registered 

architect’s design approved by the 

manufacturer and its DAPIA prior to 

installation. DAPIA approval is 

necessary to enable HUD to enforce 

such modifications to the 

manufacturer’s installation instructions. 

HUD has determined that the Model 

Installation Standards do not need to 

require that professional engineers or 

registered architects be licensed in the 

state where the home is to be installed, 

since they are responsible for only 

performing work or preparing designs in 

areas of construction in which they are 

competent and knowledgeable. 

However, a state that operates its own 

installation program may require that 

the engineer or architect be specifically 

licensed by that state. 

Comment: HUD requested comments 

on the efforts associated with checking 

installation instructions. One 

commenter wrote that since installation 

instructions vary by manufacturer and 

model, the estimates of number of 

respondents and responses per 

respondent were very low, while the 

number of hours spent on review was 


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high, unless the time includes back-andforth communication. If HUD does not 

intend to take action to ensure 

conformity with the Model Installation 

Standards (MIS), there is no need to 

collect this data. 

HUD Response: This issue will be 

addressed under the installation 

program regulations and any 

adjustments to the burden estimates will 

be made as part of those regulations. 

Comment: Section 3285.4

Incorporation by Reference. There is a 

more recent edition of the American 

Society of Heating, Refrigerating and 

Air-Conditioning Engineers 

Fundamentals Handbook and the 

Underwriters’ Laboratories (UL) 181 

standard has been separated into UL 

181, 181A, and 181B. 

Comment: Add the American Wood 

Preservers Association (AWPA) to the 

list of Referenced Publications. AWPA 

Publications, American WoodPreservers’ Association, P.O. Box 388, 

Selma, AL 36702. AWPA U1–04, Use 

Category System: User Specification for 

Treated Wood, 2004, and AWPA M4–

02, Standard for the Care of 

Preservative-Treated Wood Products, 

2002. The references to treated wood 

standards need to be updated because: 

(1) AWPA C2 and C9 are no longer 

updated by AWPA and will not include 

new preservative treatments that are 

appropriate for this application; (2) 

Standard U1 is currently referenced in 

the 2004 amendments to the 2003 

International Building Code (IBC) and 

International Residential Code (IRC) in 

place of standards C2 and C9 and will 

be referenced in the 2006 editions; and 

(3) the 0.60 lbs. per cubic foot is not the 

required retention level for all of the 

appropriate preservatives. Copper azole 

(CA–B) has a required retention of 0.31 

lbs. per cubic foot for this application 

that is equivalent to Chromated Copper 

Arsenate used at 0.60 lbs. per cubic foot. 

HUD Response: The editions of these 

standards that are adopted in this final 

rule are consistent with those recently 

updated by HUD in recent amendments 

to the Manufactured Home Construction 

and Safety Standards. HUD will 

consider issuing conforming 

amendments to more recent editions of 

these standards in future rulemaking. 

HUD also agrees there is a need to 

update and revise the reference 

requirements for treated wood materials, 

and the final rule incorporates the more 

recent AWPA U1–04 and AWPA M4–02 

standards into certain sections of the 

installation standards (§§ 3285.4, 

3285.303, 3285.312, and 3285.504). 

Comment: § 3285.5 Definitions. 

‘‘Design Flood.’’ The term ‘‘design 

flood’’ is used several times in the 

proposed rule and should be defined as 

the greater of either: (1) The base flood 

or (2) the flood so designated by the 

Local Authority Having Jurisdiction 

(LAHJ) as its regulatory flood, with a 

one percent chance or less of being 

equaled or exceeded in any given year. 

Comment: The term ‘‘design flood 

elevation’’ (DFE) should be added to the 

definitions as follows: ‘‘Design Flood 

Elevation. The elevation of the design 

flood, including wave height, relative to 

the datum specified on a LAHJ’s hazard 

map.’’

Comment: § 3285.5 Definitions. 

‘‘Lowest-Floor.’’ The definition of 

Lowest Floor should be revised, as 

follows: ‘‘Lowest floor. The floor of the 

lowest enclosed area of a manufactured 

home. For flood-resistant design 

purposes of these MIS, the term ‘‘lowest 

floor’’ shall mean the bottom of the 

longitudinal chassis frame beam in A 

zones, and the bottom of the lowest 

horizontal structural member 

supporting the home in V zones. An 

unfinished or flood resistant enclosure, 

used solely for vehicle parking, home 

access, or limited storage, must not be 

considered the lowest floor, provided 

the enclosed area is not constructed so 

as to render the home in violation of the 

flood related provisions of this 

standard.’’

HUD Response: Section 3285.102 of 

the final rule clarifies that the above 

terms are used as defined in 44 CFR part 

59.1 of the National Flood Insurance 

Program and, as such, are not required 

to be again defined in these installation 

standards. 

Comment: § 3285.5 Definitions. 

‘‘Labeled’’ and ‘‘Listed or certified.’’ The 

term ‘‘labeled’’ is very similar to the 

term ‘‘listed or certified,’’ except that 

‘‘listed or certified’’ requires that an 

approved product be on a published list. 

All of these terms could be read to 

require the contracting of an agency on 

a continuing basis to maintain product 

approval status rather than using a 

nationally recognized third-party testing 

agency for a one-time approval. 

HUD Response: Both terms remain in 

the final rule because certain 

components may not be required to be 

labeled but must still be listed under the 

purview of a nationally recognized 

testing laboratory. 

Comment: § 3285.5 Definitions. 

‘‘Crossovers.’’ The definition of 

crossovers should be amended to 

include ducting for both heating and 

cooling ducting, and not just ducting for 

heating. 

HUD Response: As recommended by 

the commenters, the final rule includes 

both heating and cooling ducts in the 

definition of ‘‘crossovers.’’

Comment: § 3285.5 Definitions. 

‘‘Local Authority Having Jurisdiction 

(LAHJ).’’ The definition of LAHJ should 

be rewritten to refer to local 

responsibilities in such a way that if 

they are within the coverage of the 

Model Installation Standards (MIS) they 

are applicable, but if outside the MIS 

they are not applicable. 

Comment: Having states included 

within the definition of an LAHJ seems 

to conflict with other provisions of the 

rule and means that a state or local 

government entity that does not have 

such requirements, even though they 

may be identical to the MIS, would not 

be considered an LAHJ. One commenter 

wrote that no level of government below 

the state level should be included in the 

definition of an LAHJ, because it 

implies that lower levels of 

government’s programs are sanctioned, 

which could result in the imposition of 

additional fees, thereby causing 

increased costs for consumers. 

HUD Response: The definition is 

essentially unchanged in the final rule 

because any entity or subdivision of 

state government is not restricted from 

establishing more stringent 

requirements than those in the MIS for 

states in which HUD will operate the 

installation program. The proposed rule 

for the installation program regulations 

in 24 CFR part 3286 includes detailed 

provisions for state-run installation 

programs and how those requirements 

will impact on local governmental 

entities within their state. However, the 

definition has been modified in the final 

rule to clarify that an LAHJ must have 

both responsibilities and requirements 

that must be complied with during the 

installation of a manufactured home. 

Comment: § 3285.5 Definitions. 

‘‘State.’’ The ‘‘Canal Zone’’ should be 

deleted from the definition of ‘‘State,’’

because the Panama Canal Zone has not 

been under United States control or 

jurisdiction for nearly 30 years. emsp; 

HUD Response: HUD has removed 

‘‘the Canal Zone’’ from the definition of 

‘‘State,’’ but recognizes that the statute 

has not been amended or updated to 

reflect this change. 

Comment: § 3285.5 Definitions. 

‘‘Foundation.’’ The term ‘‘foundation’’

should be a defined term in the MIS. 

HUD Response: A definition for a 

‘‘foundation system’’ has been included 

in the final rule in both the 

Manufactured Home Construction and 

Safety Standards and the MIS. 

Subpart B—Pre-Installation 

Considerations 

Comment: Seismic Safety/HUD 

Question: Should the MIS attempt to set 

forth minimum installation 


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requirements or pre-installation 

considerations to address seismic 

safety? If so, how should HUD establish 

seismic zones and what minimum 

requirements would be included in the 

Model Installation Standards? 

Comment: If seismic zones are to be 

considered in the future as a 

manufactured home design parameter, it 

is best that they first be introduced into 

part 3280 and then mentioned in set-up 

manuals. 

Comment: Part 3285 contains no 

criteria to protect homes from 

earthquakes, and this omission makes 

the standard incomplete. Other national 

consensus standards have seismic 

criteria, such as the IBC, the IRC, the 

National Fire Protection Association 

(NFPA) 5000 Building Construction and 

Safety Code, and the NFPA 225. 

Manufactured homes fall off this type of 

support at very moderate ground 

shaking levels, since such homes are 

typically installed using piers not 

designated for seismic resistance, which 

are not adequately attached and 

connected to the foundation and chassis 

of the home. This lack of seismic 

resistant provisions will result in 

significantly less protection than in 

other types of residential construction, 

and is technically inadequate in areas of 

high seismic activity. Congress 

authorized the Earthquake Hazard 

Reductions Program to develop seismic 

safety provisions suitable for use 

throughout the United States. The lack 

of seismic provisions is contrary to 

national policy. The approach for 

seismic detailing and design in NFPA 

225 should be accepted and used in part 

3285. 

Comment: HUD should not include 

any seismic requirements in the Model 

Installation Standards. When required, 

designs are handled by the retailer, the 

installer, the owner, or the 

manufacturer, in accordance with the 

requirements of the local building 

authority. This is working now and 

need not be covered in the installation 

standards. 

HUD Response: The final rule does 

not contain specific requirements for the 

design of foundation and anchorage 

systems in seismically active areas. This 

will allow states and local building code 

authorities in seismically active areas to 

establish or continue to enforce 

foundation and anchoring requirements 

for seismic design load considerations. 

However, HUD intends to continue to 

study this issue and may recommend 

requirements for seismic design in 

future rulemakings in the Manufactured 

Home Construction and Safety 

Standards and the Model Installation 

Standards. 

Comment: § 3285.101 Installation of 

Manufactured Homes in Flood Hazard 

Areas. The requirements for installation 

of manufactured homes in flood hazard 

areas should be included in Subpart D 

Foundations, § 3285.302, rather than in 

§ 3285.101(d). While § 3285.101 requires 

the installer to determine if flood 

hazards affect the site, it is more 

appropriate that more explicit design 

considerations be articulated in the 

section on foundations. 

Comment: States and communities in 

areas that are vulnerable to flood 

damage should adopt regulations that 

exceed the minimum National Flood 

Insurance Program (NFIP) requirements. 

Comment: The approach indicated in 

the proposed Model Installation 

Standards was considered and rejected 

by NFPA 225. Basic performance 

requirements related to floods can and 

must be included in the Model 

Installation Standards, and doing so will 

not conflict with, replace, or preempt 

NFIP and LAHJ flood requirements. 

Comment: Method and Practices. 

Manufactured homes located wholly or 

partly within special flood hazard areas 

must be installed using methods and 

practices that minimize flood damage 

during the base flood, including 

elevation and stability of the foundation 

for anticipated conditions and loads in 

accordance with the LAHJ; 44 CFR 

60.3(a) through (e), as applicable; and 

other provisions of 44 CFR referenced 

by those paragraphs. 

Comment: Section 3285.101(c) should 

be revised to read as follows: ‘‘(c) Preinstallation considerations. Prior to the 

initial installation of a new 

manufactured home, the installer is 

responsible to determine whether the 

manufactured home site lies wholly or 

partly within a special flood hazard area 

as shown on the LAHJ’s Flood Insurance 

Rate Map, Flood Boundary and 

Floodway Map, or Flood Hazard 

Boundary Map. If so located, the map 

and supporting studies and 

requirements adopted by the LAHJ or 

state should be used to determine the 

flood hazard zone and design flood 

elevation at the site. If the LAHJ has not 

adopted a Flood Hazard Map, the 

installer shall consult the LAHJ to 

determine flood-resistant installation 

requirements.’’

Comment: § 3285.101(d) Installation 

of Manufactured Homes in Flood 

Hazard Areas. LAHJs should be given 

the option to enforce requirements for 

flood hazards at whatever level they 

deem necessary. The section should 

provide two options for flood hazard 

criteria: (1) Per the LAHJ or (2) per the 

NFIP regulations. 

Comment: Paragraph (d)(2) should be 

renumbered as (d)(3) and a new section 

(d)(2) should be added, as follows: 

‘‘Performance requirements. 

Manufactured home installations shall: 

(a) Have the lowest floor elevated to or 

above the design installation; (b) elevate 

the home using support and anchorage 

systems designed and constructed to 

resist design flood loads in combination 

with other storage loads; (c) construct 

the support and anchorage system with 

flood damage resistant materials; (d) in 

A zones, use flood openings in 

permanent foundation walls and in 

other solid walls (excluding skirting) 

forming an enclosure below the DFE, to 

allow the automatic equalization of 

flood levels; and (e) in V zones, elevate 

the home on piles, columns, piers, or 

stands that minimize obstructions below 

the DFE, and use breakaway 

construction for any other nonstructural walls or elements.’’

Comment: Fill is often used as a 

method to elevate sites so that the 

lowest floors of manufactured homes are 

elevated to or above the design flood 

elevation. While compaction of fill used 

to elevate a manufactured home site is 

an important consideration, there are 

other particular considerations that are 

important so that flood conditions do 

not adversely affect the fill. In 

particular, it is recommended that the 

fill be sloped and protected with 

vegetation to minimize erosion that may 

undermine the home. This can be 

accomplished by adding 

§ 3285.101(d)(2) to read as follows: 

‘‘Installation on fill. Fill placed in flood 

hazard areas in order to elevate 

manufactured home sites shall be 

placed, compacted, and sloped to 

minimize shifting, slumping, and 

erosion during the rise and fall of 

floodwater.’’

Comment: A new paragraph, 

§ 3285.101(e), should be added to read 

as follows: ‘‘Alternate Flood-Resistant 

Installation Provisions. The floodresistant installation provisions 

contained in NFPA 225 shall be deemed 

to equal or exceed the flood 

requirements of the Model Installation 

Standards.’’

Comment: The only way to prevent 

flood damage is by elevating the home 

above the flood level on strong and 

durable stabilizing devices. Performance 

requirements to prevent flood damage 

must be included if the Model 

Installation Standards are to be 

effective. 

HUD Response: The final rule 

continues to reference the provisions of 

44 CFR 60.3(a) through (e) and Federal 

Emergency Management Agency 

(FEMA) 85, Manufactured Home 


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Installation in Flood Hazard Areas, as 

appropriate guidance for installation of 

manufactured homes in areas subject to 

flooding. A state or local community 

may adopt more stringent performance 

requirements than those specified under 

the Model Installation Standards for 

flood hazard areas. 

Comment: § 3285.102 Design Zone 

Maps. The design and construction of 

the foundation and anchoring systems 

addressed in part 3285 should be 

compatible with the design and 

construction of the home, but should 

not be restricted or limited by the 

outdated and obsolete design zone maps 

contained in part 3280. 

Comment: This section should require 

that a manufactured home cannot be 

installed in a higher wind zone, snow 

load, or thermal zone than the home’s 

original design for its initial installation. 

Comment: The referenced design 

maps identified in part 3280 should be 

included in this section. 

HUD Response: Section 3285.103(a) of 

the final rule requires that prior to the 

initial installation of a new 

manufactured home, the installer verify 

that the design and construction of the 

home, as indicated on the design zone 

maps provided with the home required 

by the Manufactured Home 

Construction and Safety Standards and 

regulations, are suitable for the site 

location where the home is to be 

installed. 

Subpart C—Site Preparation 

§ 3285.201 Soil Conditions/HUD 

Question. HUD sought comment on 

whether the standards should require 

that a minimum of six inches of soil, 

including the organic material, be 

removed under load bearing footings to 

ensure that footings are placed on 

undisturbed soil for at-grade footings. 

Comment: This would seem like a 

good practice in general to avoid 

detrimental effects to foundation 

support and anchoring systems; 

however, to specify a minimum depth of 

six inches of soil be removed may in 

some cases be too little or in other 

situations too excessive. To address this 

concern, the commenters recommend 

that the section be revised to indicate 

that topsoil is to be removed or that atgrade footings should be installed on 

undisturbed soil. 

HUD Response: HUD finds the 

comment to be reasonable, and the final 

rule does not specify a required depth 

of soil removal, thereby leaving the 

determination of firm, undisturbed soil 

as a site-specific matter. 

Comment: § 3285.202 Soil 

Classifications and Bearing Capacity. 

The pocket penetrometer should be 

included as an acceptable method to 

determine soil-bearing capacity. While 

penetrometers are not as precise a 

method for determining soil-bearing 

capacity at an individual location, they 

have proven to be workable devices 

where multiple readings are taken at an 

installation site. 

Comment: The proposed rule should 

offer a default approach to determine 

the soil bearing capacity such as 

permitted by other model codes. This 

default approach used in some state and 

model building codes, such as the 2003 

International Residential Code, 

generally recognizes a minimum soil 

bearing capacity of 1500 pounds per 

square foot (psf). 

HUD Response: The final rule now 

allows the use of the pocket 

penetrometer as one of the acceptable 

methods for determining soil 

classification and bearing capacity and 

permits the use of a 1500 psf soil 

bearing capacity, unless site-specific 

information requires the use of lower 

values based on soil classification and 

type. 

Comment: § 3285.203(a) Drainage. 

The section should be revised to read as 

follows: ‘‘Drainage must be provided to 

direct surface water away from the 

home.’’ This was suggested because the 

commenter believed it unnecessary to 

include a ‘‘laundry list’’ of possible 

problems, if proper drainage was not 

provided, that was identified in the 

proposed rule. 

Comment: As written, subsection (b) 

would be impossible to enforce within 

rental communities given their layout 

and design. The requirement should be 

revised to provide an exemption for 

homes sited within manufactured home 

rental communities, or by changing the 

drainage requirement ‘‘from under’’ to 

‘‘away from’’ the home. Further, in 

subsection (c) the first 10-foot provision 

would be impossible to enforce in rental 

communities, since lots only provide for 

5-foot sideyards and that the 

requirement should be revised to 

require drainage away from the 

foundation of the home for the first 5 

feet. 

HUD Response: The final rule has 

been revised to clarify that surface water 

must be directed away from the home to 

prevent water build-up under the home. 

Where property lines do not allow the 

drainage to be diverted for the first 10 

feet from the foundation, other methods 

are allowed to remove the surface water. 

However, statements on the adverse 

affects of not removing the water have 

been removed from this section, as 

suggested by commenters. 

Comment: § 3285.203(f) Gutters and 

Downspouts. Most home manufacturers 

do not provide additional support in the 

roof system in order to support gutters 

and downspouts. Installation could 

cause damage and take the home out of 

compliance with the MHCSS. However, 

if gutters and downspouts are provided, 

the runoff must be directed away from 

the manufactured home. 

Comment: Even though the Model 

Installation Standards require any 

runoff from gutters and downspouts to 

be diverted away from the home, not all 

HUD Code homes are required to have 

gutters and downspouts. If gutters and 

downspouts are provided, then 

installers should be required to ensure 

that adequate drainage is provided. 

HUD Response: The final rule has 

been revised to require manufacturers to 

specify in their installation instructions 

whether the manufactured home is 

suitable for the installation of gutters 

and downspouts and if so provided, the 

instructions are also to indicate that all 

roof water is to be directed away from 

the home. 

§ 3280.204 Ground Moisture 

Control/HUD Question: HUD is 

concerned that excessive voids and 

numerous tears in the vapor retarder can 

defeat the purpose of the requirement. 

Therefore, should limitations be placed 

on the number and size of voids and 

tears? If so, what specific limitations 

would be recommended? 

Comment: Some commenters 

advocated that the Model Installation 

Standards should state that all tears and 

voids in the ground vapor retarder be 

repaired. Others raised questions as to 

what would constitute a minor tear or 

void, as indicated in the proposed rule; 

how many tears or voids would be 

acceptable without repair; and how the 

regulation would be consistently 

enforced by states. The commenters also 

suggested this was one situation where 

a prescriptive provision is warranted in 

the standards. 

Comment: As it would be difficult to 

repair tears or defects in the ground 

vapor retarder around piers, the 

requirement should be revised to not 

require minor tears and voids at pier 

locations or other support to be 

repaired. 

Comment: The ground vapor retarder 

should be overlapped at least 12 inches 

at all joints to prevent weeds and grass 

from growing through deck slats, and to 

minimize the likelihood of moisture 

penetration. 

Comment: The reference to a six 

millimeter polyethylene is a 

typographical error in § 3285.204(b). A 

six millimeter polyethylene ground 

vapor retarder would be .039′′ thick, as 

opposed to the six mil polyethylene that 


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59344 Federal Register / Vol. 72, No. 202 / Friday, October 19, 2007 / Rules and Regulations 

was intended, which would be .006′′ 

thick. 

Comment: Ground vapor retarders 

should be required only in enclosed 

areas and paragraph (a) should be 

revised to read as follows: ‘‘(a) If space 

under the home is to be enclosed with 

skirting or other material, a vapor 

retarder is required in the following 

situations: (1) In humid regions (this 

region is considered to follow the very 

heavy termite infestation probability 

map, reference in the HUD Sept., 1996 

PFGMH); (2) in situations where the 

crawlspace soil elevation is below the 

natural surrounding surface elevation 

(i.e., pit set applications); (3) in 

installations where concrete decks, 

retaining walls or other solid barriers 

prevent venting on more than one side 

(refer to § 3285.505).’’

HUD Response: Section 3285.204 of 

the final rule does not permit any voids 

or tears in the ground vapor retarder, 

requires all joints to be overlapped at 

least 12 inches, and allows the vapor 

retarder to be installed around or over 

footings and other obstructions, as 

suggested by the commenters. The final 

rule also corrects the typographical error 

in the proposed rule in paragraph (b) by 

requiring the thickness of the vapor 

retarder to be a minimum of six mil 

polyethylene sheeting. The final rule 

also clarifies that all enclosed and 

skirted areas are to be provided with a 

ground vapor retarder, except in arid 

regions and areas for open porches, 

decks, and recessed entries. 

Subpart D—Foundations 

Comment: § 3285.301(b) Alternative 

Foundation Systems. The requirement 

that foundations that are not of the pier 

and footing type are to be designed by 

a professional engineer increases costs 

to the consumer. 

Comment: It is unnecessary for a 

professional engineer or architect to be 

consulted for site preparation, if the 

manufacturer’s manual does not cover 

the specific conditions for the site, 

because every manual has been 

reviewed by the industry’s national 

association and it always contains some 

information with regard to site 

preparation. If not, the LAHJ can be 

looked to for any other conforming 

requirements. 

Comment: § 3285.301(b) et al. The 

proposed rule’s requirements for 

‘‘acceptable engineering practice’’ are 

too broad to ensure uniformity. As 

written, the commenter finds four 

problems with the proposed language: 

(1) It suggests that all aspects of design 

require registered professionals, (2) the 

standard is not specific to the design 

and construction of manufactured 

homes, (3) it is not specified where the 

professional has to be registered, and (4) 

it will increase costs because services of 

engineers and architects will be 

required for each installation rather than 

having the manufacturer provide the 

information universally. The commenter 

proposes to change the language to 

read,*** Must be prepared by the 

manufacturer or by a registered 

professional engineer or a registered 

architect in accordance with the 

manufacturer’s home design and the 

Manufactured Home Construction and 

Safety Standards (3280).’’ [Same 

comment for §§ 3285.301(d), 

3285.306(c), 3285.310(c), 3285.312(c)(1) 

and (2), 3285.314(b), 3285.401(b) and 

(b)(2), 3285.402(c)] 

Comment: § 3285.301(c) General. 

Most registered professional engineers 

or registered architects are not aware of 

the federal standards or how 

manufactured homes are designed and 

constructed. They are also unaware of 

critical areas of support. If the designs 

fail, the federal program has no 

authority over these outside 

professionals. 

HUD Response: The requirements for 

the use of professional engineers or 

architects to certify various aspects of 

the manufacturer’s installation 

instructions for foundation and 

anchoring support, including alternative 

foundation systems, are retained in the 

final rule and are no different than what 

is currently required for certification of 

this information under the 

Manufactured Home Construction and 

Safety Standards. In addition, one of the 

responsibilities of a professional 

engineer or registered architect is to 

understand all aspects of any design, 

including critical areas of support, 

before certifying that it complies with 

the appropriate standards or 

requirements. The installer must have 

the professional engineer’s or registered 

architect’s design approved by the 

manufacturer and its DAPIA prior to 

installation. DAPIA approval is 

necessary to enable HUD to enforce 

such modifications to the 

manufacturer’s installation instructions. 

Comment: Installation Instructions for 

Perimeter and Permanent Foundations/ 

HUD Question: Should manufacturers 

who design their manufactured homes 

to be installed on perimeter or 

permanent foundations, in addition to 

pier, footing, and anchor foundations, 

be required to also provide DAPIAapproved installation instructions for 

perimeter and/or permanent 

foundations and the pier, footing, and 

anchor systems? 

Comment: Additional DAPIAapproved instructions for other 

foundation systems, including perimeter 

or permanent foundations, should not 

be required if a manufacturer has 

complied with either engineered plans 

or state-established standards for 

permanent foundations. 

HUD Response: DAPIA-approved 

installation instructions are required to 

be provided by manufacturers under 

section 605(b) of the Act. The final rule 

indicates that foundation systems that 

are not of pier and anchor type 

configurations may also be used, when 

substantiated by engineering design as 

being capable of resisting the design 

loads in the Manufactured Home 

Construction and Safety Standards. If 

alternative foundation designs are not 

provided in the installation instructions 

and are desired or needed for sitespecific conditions, installers are 

required to first contact manufacturers 

to obtain variations to the instructions 

or, if not available from the 

manufacturer, to use a design prepared 

by a professional engineer or architect 

(§ 3285.2(c)). The installer must have 

the professional engineer’s or registered 

architect’s design approved by the 

manufacturer and its DAPIA prior to 

installation. DAPIA approval is 

necessary to enable HUD to enforce 

such modifications to the 

manufacturer’s installation instructions. 

Comment: § 3285.301(a) General. 

The design of the foundation system 

should not be limited to the design 

loads required by the Manufactured 

Home Construction and Safety 

Standards, as indicated on the home’s 

data plate. Presently, manufactured 

homes are not designed for flood loads, 

but foundation and anchorage systems 

sited in flood hazard areas should be 

capable of resisting flood loads. 

Similarly, manufactured homes are not 

presently designed for seismic forces, 

but foundation and anchorage systems 

installed in areas subject to earthquake 

forces should be capable of resisting 

seismic loads. To remedy the above 

concerns, the section should be revised 

to read as follows: ‘‘(a) Foundations for 

manufactured home installations must 

be designed and constructed in 

accordance with this subpart and must 

be based on site conditions, home 

design features, and the greater of (1) the 

loads the home was designed to 

withstand as shown on the home’s data 

plate, and (2) design loads specified 

elsewhere in these Standards or by the 

LAHJ or state.’’

HUD Response: Under the final rule, 

states and localities are not prevented 

from establishing and enforcing seismic 

requirements or higher design 

requirements for foundations and 

anchorage to resist flood loads. 


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Comment: Test Protocol for 

Alternative Foundation Systems/HUD 

Question: What specific requirements 

should be included in the national test 

protocol for alternative foundation 

systems protocol referred to in the 

proposed Model Installation Standards? 

Comment: It would be best to delay 

providing any specific considerations or 

testing requirements in the final rule, 

because the MHCC has been tasked to 

develop a recommended test protocol 

for proprietary foundation systems. 

Further, any proprietary system can be 

evaluated by a manufacturer and 

included, at its option, in the 

installation manual, subject to DAPIA 

approval. 

Comment: Currently a de facto, 

nationally recognized protocol exists, 

which has been extensively used to 

evaluate most of the alternative 

foundation systems on the market. 

HUD Response: Section 3285.301(d) 

of the final rule includes provisions for 

a nationally recognized testing protocol 

for proprietary foundation systems or 

alternatively requires proprietary 

foundation system designs to be 

prepared or tested by a registered 

professional engineer or registered 

architect. Efforts are underway by the 

MHCC to develop recommendations for 

a national testing protocol, which will 

be considered by the Department of 

Housing and Urban Development upon 

its completion. Presently, states that are 

operating an installation program have 

differing requirements for the testing of 

proprietary foundation systems, and 

there is no universally accepted de facto 

method for testing, as suggested by one 

of the commenters. 

Comment: § 3285.302 Installation of 

Manufactured Homes in Flood Hazard 

Areas. Manufacturers should be 

required to either include flood-resistant 

considerations in their foundation 

specifications (and state the conditions 

under which the specifications are 

applicable in terms of specific ranges of 

velocities, depths, and wave action), or 

state that their foundation specifications 

do not address flood loads and shall not 

be used in flood hazard areas. 

HUD Response: Section 3285.302 of 

the final rule requires that the 

installation instructions identify 

whether the foundation specifications 

have been designed or not designed for 

flood-resistant considerations. 

Comment: § 3285.303(b)(1)

Acceptable Piers-Material 

Specifications. The section should be 

revised to read as follows: ‘‘Piers are 

permitted to be concrete blocks, 

pressure-treated wood treated with a 

water-borne preservative in accordance 

with AWPA Standard U1 for Use 

Category 4B ground contact 

applications, or adjustable metal or 

concrete piers.’’

HUD Response: Section 3285.301(b) 

of the final rule has been revised in 

accordance with the above comment to 

reference a more current standard 

permitting the use of water-borne 

preservatives for pressure treatment of 

wood members. 

Comment: § 3285.303 Piers/HUD 

Question: Should the Model Installation 

Standards include other design 

characteristics or standards for 

manufactured piers such as protection 

from the elements, material 

specifications, a testing protocol, or 

listing and labeling requirements? 

Comment: Piers and other support or 

anchorage devices should be designed 

and constructed to resist weathering, 

corrosion, and deterioration with 

minimal maintenance and upkeep on 

the part of the owner. This is especially 

important in coastal areas where salt 

spray corrosion is present, and in flood 

hazard areas where the supports and 

anchorage are subject to inundation. 

Comment: Manufactured piers are 

designed to withstand certain loads and, 

as long as the home manufacturer 

provides the loading requirements at 

each intended pier location, a 

manufactured pier that is capable of 

resisting those loads should be 

acceptable for use. 

Comment: The proposed rule 

specifies that manufactured home piers, 

other than concrete masonry units or 

steel jack stands, be listed and labeled 

for the required vertical loads and 

appropriate lateral loads. This appears 

to be a performance-based requirement. 

There does not seem to be any reason 

to provide a laundry list of design 

conditions. HUD should maintain the 

status quo until some nationally 

recognized material/testing protocol can 

be developed. 

HUD Response: The proposed rule 

did not exclude metal stands or piers 

from the requirement to be listed and 

labeled, as suggested by the commenter. 

This is further clarified in § 3285.308 of 

the final rule, which requires that any 

metal pier or other type of manufactured 

pier be listed, meet the pier load 

requirements of the Model Installation 

Standards in § 3285.303, and be 

protected against weather deterioration 

and corrosion. 

Comment: § 3285.303(d) Pier Loads. 

The word ‘‘poured’’ should be deleted, 

as it suggests that the footers for piers 

loads need to be poured. 

HUD Response: The term ‘‘poured’’

has been deleted in the final rule. 

Comment: § 3285.303 Tables 1, 2, 

and 3. The Tables are confusing and 

should be simplified by retaining only 

the ‘‘Pier and Footing Load’’ column 

and by deleting all references to the 

16′′x16′′ concrete footing /pyramid 

layout method in the Tables and by 

deleting Figure C to § 3285.312 in its 

entirety. 

Comment: The footnotes in the tables 

should indicate that flood or seismic 

loads were not considered in developing 

the tables and that the tables should not 

be used in determining foundation 

requirements in flood hazard areas or 

seismic hazard areas. 

HUD Response: The Tables in the 

final rule have been revised to delete the 

references to footing layouts, and Figure 

C to § 3285.312 has also been deleted in 

the final rule. A footnote has also been 

added to each of the Tables in the final 

rule indicating the Tables do not 

consider flood hazard or seismic design 

load requirements. 

Comment: § 3285.304 Pier 

Configuration. There are a number of 

inconsistencies between the text in this 

section and Figures A and B to 

§ 3285.306 with regard to cap thickness, 

size, and material callouts and 

specifications; shim size, use, thickness, 

and orientation; and gaps between the 

main chassis beam and foundation 

support system specifics. 

HUD Response: Figures A and B and 

the text of this section have been revised 

in the final rule to address comments 

regarding inconsistencies between them 

in cap requirements (i.e., 1⁄2′′-steel plate 

thickness has been used in both the text 

and Figures in the final rule), by 

requiring wood shims to be hardwood 

and by clarifying alternatives for filling 

gaps. 

Comment: § 3285.305 Clearance 

Under Homes/HUD Question: Should 

the Model Installation Standards 

include minimum clearances in areas 

such as those required for access or 

inspection? 

Comment: A minimum clearance 

under a home is required to install and 

inspect utility connections, bottom 

board repairs, etc. All of the area 

underneath a home should be accessible 

for that, and even if there are no utility 

connections in an area, bottom board 

repairs may still need to be made onsite. 

Comment: A 12-inch minimum 

clearance should be maintained beneath 

the lowest member of the main frame 

and the ground under 100 percent of the 

home. 

HUD Response: The final rule 

requires a minimum clearance of 12 

inches under the home to the ground, 

including areas between the lowest 

point of the frame and the grade. 


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Comment: § 3285.306(b) Frame Piers 

36 Inches to 80 Inches and Corner Piers. 

The MHCC and other commenters stated 

that mortar should not be required, 

unless specified in the manufacturer’s 

installation instructions. Further, if 

mortar is required for all frame or corner 

piers between 36 inches and 67 inches 

in height, it would add unnecessary 

costs to the installation of the home. 

Comment: When concrete block piers 

are required to use mortar, the type of 

mortar should be indicated in the 

standards. 

Comment: Section 3285.306(a)(5) 

should be changed to read as follows: 

‘‘Mortar is not required if a solid 4′′ cap 

block is placed on top of the hollow 

masonry blocks and the pier is not being 

considered as an anchoring point, 

unless otherwise specified in the 

installation instruction or required by a 

registered engineer or registered 

architect.’’

HUD Response: Paragraphs (a), (b), 

and (c) of § 3285.306 of the final rule 

have been revised to indicate that the 

use of mortar is only required when 

specified in the manufacturers 

installation instructions or required in 

designs prepared by a professional 

engineer or registered architect. 

Comment: § 3285.306(b)(2). The 

Model Installation Standards should 

address offsets in piers over 36′′ in 

height and the maximum tilt of piers 

from vertical for piers of any height. 

HUD Response: Horizontal offsets for 

piers over 36′′ and up to 67′′ in height 

are limited to 1′′ in § 3285.306(b)(1) of 

the final rule. 

Comment: Figure B to § 3285.306 

Typical Footing and Pier Installation, 

Double Concrete Block. The maximum 

pier height of 80 inches should be 

reduced to 67 inches, because the tiedown charts provided in this standard 

are limited to 67’’ and pier designs 

greater than 67’’ in height will require 

independent engineering designs. 

HUD Response: The requirements for 

frame and corner pier height in Figure 

B and the text of the final rule have been 

reduced from 80 inches to 67 inches to 

be consistent with other tables and 

figures in the Model Installation 

Standards. 

Comment: § 3285.309 Elevated 

Homes. Since information is provided 

for designing tie-downs and piers up to 

67’’ high, the ‘‘one-fourth of the area of 

a home’’ requirement should be deleted. 

HUD Response: The provisions for 

elevated homes have been deleted in the 

final rule, as recommended by the 

commenters. A professional engineer or 

registered architect would be required to 

prepare designs that exceed 67′′ in 

height or for other conditions not 

specifically addressed by these Model 

Installation Standards. 

Comment: § 3285.310 Figures/Tables 

for Marriage Line Pier Supports 

(Generally). The manufacturer’s 

installation manual would be easier to 

reference for these requirements rather 

than the specifications, Tables, and 

Figures in the proposed rule. 

HUD Response: As recommended by 

the MHCC and others, the Tables, 

Figures, and specifications are needed 

to establish the minimum requirements 

and guidance needed for preparing 

manufacturer’s installation instructions. 

Comment: § 3285.310 Typical MateLine Column Pier and Mating Wall 

Support. Footnote 1 of Figure A to 

§ 3285.310 requires all footings to 

extend below the frost line depth. This 

requirement is inconsistent with 

§ 3285.312(c), which allows footings to 

be located at grade, when insulated 

foundation systems are used in areas 

subject to freezing. Instead, Footnote 1 

should be revised to reference 

§ 3285.312(c) for footing requirements in 

frost-heave susceptible soils. This same 

comment also applies to Figure B. 

Comment: Figure A to § 3285.310

Typical Mate-Line Column Pier and 

Mating Wall Support When Frame-Only 

Blocking is Required and Figure B to 

§ 3285.310 Typical Mate-Line Column 

Pier and Mating Wall Support When 

Perimeter Blocking is Required. For 

locations more than two feet from the 

perimeter of the home, the frost line 

depth should be one half of that 

required for perimeter footings, because 

temperatures under the home are not 

low enough to cause severe soil frost 

line conditions. 

Comment: The pier capacity indicated 

in Footnote 3 for single dry stack 

concrete block piers should be reduced 

from 10,000 lbs. to 8,000 lbs., while 

another commenter recommended the 

capacity be reduced even further to 

5,725 lbs. 

Comment: Footnote 6 for Figure A 

and Footnote 4 for Figure B should be 

revised to indicate that pier or other 

supports are required for any opening 

48′′ or greater at either the mate-line or 

the side wall. 

HUD Response: Footnote 1 of the 

Figures A and B to § 3285.310 in the 

final rule have been revised to indicate 

that the bottom of the footings must 

extend below the frost line depth, 

unless designed for placement above the 

frost line. In addition, alternatives to 

locating footings below the frost line, 

such as by using an insulated 

foundation system, are provided in 

§ 3285.312(b) of the final rule. Other 

footnotes to the figures in § 3285.310 

have been revised, as recommended by 

the commenters to indicate that pier 

supports are required for any opening of 

48’’ or greater. The footnotes to the 

figures have also been revised by 

reducing the maximum load permitted 

on a single stack concrete block pier 

from 10,000 lbs. to 8,000 lbs., as 

determined by HUD’s analysis. 

Comment: § 3285.310(b). Paragraph 

(b) should be revised to read, ‘‘(b) Mateline and column pier supports must be 

in accordance with this subpart and 

consistent with Figures A through C to 

this section or located and sized to 

withstand the loads provided by the 

home manufacturer for the specific 

home.’’

HUD Response: Paragraph (b) has 

been revised in the final rule to indicate 

that the mate-line column and pier 

supports are required to be in 

accordance with the provisions of 

Subpart D, unless the pier support and 

footing configuration is designed by a 

registered professional engineer or 

architect. 

Comment: § 3285.311 Required 

Perimeter Supports. Piers are not the 

only means of perimeter support; other 

means such as additional outriggers or 

floor joists should also be permitted. 

Comment: The reference to wood 

stoves should be changed to fireplace 

stoves, since wood stoves have not been 

used in manufactured homes for many 

years. 

Comment: References in § 3285.311(b) 

to Tables 1 and 3 should be deleted, 

because only Table 2 addressed the use 

of perimeter piers. 

Comment: In recognition of 

mountainous areas where snow loads 

are greater than 40 psf, a new paragraph 

(c) should be added to read, as follows: 

‘‘Perimeter support in accordance with 

manufacturer’s installation instructions 

may be required for roof loads in excess 

of 40 psf.’’

HUD Response: Section 

3285.311(a)(2) of the final rule provides 

for other means of perimeter support, 

such as by additional outriggers or floor 

joists, and requires the sizing of pier and 

footing supports to consider the 

additional loads from these alternative 

supports. The final rule has also been 

revised to change the term ‘‘wood 

stoves’’ to ‘‘fireplace stoves’’ to be 

consistent with the Manufactured Home 

Construction and Safety Standards. For 

roof live loads in excess of 40 psf or 

greater, a professional engineer or 

architect must determine the maximum 

sidewall opening that is permitted. In 

addition, the references to Tables 1 and 

3 have been deleted in the final rule, as 

recommended by the commenters. 

Comment: § 3285.312(b)(1)(i)

Footings; Acceptable Types of Footings 


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Concrete/HUD Question: Should the 

Model Installation Standards provide 

minimum steel reinforcement 

specifications for cast-in-place footings? 

Comment: There should be minimum 

requirements for steel reinforcement of 

footings to prevent footing damage or 

failure. 

Comment: Footing design, including 

the amount and size of steel 

reinforcement, should be left up to the 

registered professional engineer or 

architect preparing the design. 

Comment: Steel reinforcement 

specifications for cast-in-place concrete 

footings are not necessary for inclusion 

in Model Installation Standards, since 

these are specified by the manufacturer 

and would exceed the minimum 

standard requirements. 

HUD Response: Section 

3285.312(a)(1)(ii) in the final rule has 

been revised to indicate that sitespecific soil conditions may require the 

use of reinforcing steel for design of 

cast-in-place footings. 

Comment: § 3285.312(b)(1)(i)

Acceptable Types of Footings. Concrete. 

The requirement for four-inch nominal 

precast concrete pads to have a 28-day 

compressive strength of at least 4,000 

psi is inconsistent with the industry 

practice of using 1,200 psi. Further, 

there is no explanation or engineering 

rationale provided as to why 1,200 psi 

cannot be used, and 4,000 psi precast 

footing pads are not currently available. 

The standard should be set at 1,200 psi 

and the same revision should be made 

to Figure C to § 3285.312. 

Comment: The word ‘‘must’’ should 

be stricken from § 3285.312(b)(1) to 

allow concrete footings to be either 

precast or poured-in-place, or both. 

HUD Response: The final rule has 

been revised to reduce the 28-day 

minimum compressive strength for 

precast concrete footings from 4,000 psi 

to 1,200 psi, in accordance with the 

recommendations of the commenters. 

While the rule permits either precast or 

poured-in-place concrete footings, 

because of different settlement rates for 

the different types of footings, the use of 

both at a particular site is limited to a 

design approved by a registered 

professional architect or engineer. 

Comment: § 3285.312(b)(2) Footings; 

Pressure-Treated Permanent Wood. This 

subsection should be reorganized into: 

(i) Physical requirements, (ii) treatment 

requirements, and (iii) field treatment of 

cut ends. The subsection, as designed 

and combined by the commenter, would 

read: ‘‘(2) Pressure-treated Wood. (i) 

Pressure-treated wood footings shall 

consist of a minimum of two layers of 

nominal 2′′ thick pressure-treated wood, 

or a single layer of pressure-treated 

plywood with a minimum thickness of 

three-quarters of inch and a maximum 

size of 16′′x16′′, or, for larger sizes two 

pieces of nominal three-quarter inch 

thick plywood. Plywood shall be 

American Plywood Association-rated 

sheathing, Exposure 1 or Exterior in 

accordance with PS1. (ii) Pressuretreated lumber and plywood shall be 

treated with a water-borne preservative 

in accordance with American Wood 

Presservers’ Association standard U1 for 

Use Category 4B ground contact 

applications. (iii) Cut ends of pressuretreated lumber shall be field treated in 

accordance with AWPA M4–02.’’

HUD Response: Section 

3285.312(a)(2) of the final rule for 

pressure-treated wood footings has been 

revised, in accordance with the above 

recommendations. 

Comment: § 3285.312(b)(3)

Acrylonitrile Butadiene Styrene (ABS) 

Footing Pads/HUD Question: Should 

ABS footing pads be listed and what 

type of criteria should be contained in 

the Model Installation Standards to 

ensure the products are durable and can 

be adequately and uniformly evaluated 

for review and approval? 

Comment: ABS footing pads should 

be certified for use by soil classification. 

ABS or other plastic type footing pads 

tend to deflect more in sandy soil 

conditions. 

Comment: ABS footing pads are 

currently being approved and used and 

should be permitted under the Model 

Installation Standards. States should 

continue to be responsible for 

determining the appropriate criteria and 

approval procedures for use of ABS 

footing pads until a nationally 

recognized material/testing standard is 

developed. 

Comment: The proposed rule does not 

mention that any limitations for use of 

ABS pads in areas subject to freezing or 

frost. 

Comment: ABS footing pads must be 

approved for the permitted load and soil 

bearing capacity since there are no 

requirements for listing or labeling. 

HUD Response: Section 

3285.312(a)(3) of the final rule permits 

the use of ABS footing pads, but 

requires they be listed and labeled as to 

their load capacity and adds the 

requirement that they also be certified 

for use in the soil classification at the 

site. 

Comment: § 3285.312 Footings. Any 

type of interior supports and pads that 

are deemed appropriate by the 

manufacturer should also be acceptable 

for use on interior supports of 

permanent foundations, where any 

material longevity issues are satisfied. 

HUD Response: A new paragraph, 

(a)(4), has been added to this section in 

the final rule to allow the use of other 

materials for footing pads, provided 

they are listed for such use and meet all 

other applicable requirements for 

footings in this subpart. 

Comment: § 3285.312(c) Placement 

in Freezing Climates. DAPIA-approved 

installation manuals should indicate 

that all footings must extend below the 

frost line or be protected from the effects 

of frost heave. 

Comment: Why are frost depths not 

established in the Model Installation 

Standards as they are in other model 

building codes, and instead determined 

by the LAHJ? 

Comment: The requirements for 

monolithic slab systems and insulated 

foundations in paragraphs (2) and (3) 

should be revised to permit the design 

to be prepared by a registered 

professional engineer or registered 

architect using acceptable engineering 

practice to prevent the effects of frost 

heave or in accordance with SEI/ASCE 

32–01, rather than requiring compliance 

to both of the above provisions. The 

commenters indicated that for 

monolithic slabs and insulated 

foundations there should be two ways to 

obtain approval, to avoid increasing the 

cost of installation. 

Comment: The reference to the SEI/ 

ASCE 32–01 design criteria should not 

be included because it is too stringent 

and would not allow perfectly 

acceptable installation alternatives to be 

used. Further, any installation system 

outlined by the manufacturer that meets 

or exceeds the requirements contained 

in the Model Installation Standards, is 

approved by a registered engineer, and 

provides for protection from the effects 

of frost heave should be allowed. 

Comment: If only SEI/ACSE 32–01 is 

referenced, it may effectively eliminate 

any type of insulated skirting system 

from being used to permit pier footings 

to be above the frost line. 

Comment: Four field test reports 

appeared to indicate that alternative 

strategies could be used to protect 

manufactured home foundation systems 

in freezing climates without requiring 

the foundations to be embedded below 

the frost line or conform to SEI/ASCE 

32–01. The above-referenced tests have 

shown that insulated skirting materials 

can keep the ground under the home 

above freezing temperatures. 

Comment: Requiring monolithic slabs 

to be approved by a registered 

professional engineer or a registered 

architect will have the consequence of 

adding thousands of dollars in costs to 

the purchase price of homes placed in 

manufactured home communities, not 


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to mention the additional costs resulting 

from either the relocation of, or damage 

and disruption to, the underground 

utility infrastructure such as water and 

sewer lines, electric supply lines, and 

cable and telephone lines. 

Comment: Manufactured home landlease communities do not have any 

flexibility in being able to shift a home 

even a few inches on a lot to avoid the 

intersection of the frost-free foundation 

system with the existing infrastructure. 

Further, frost-free foundation systems 

would require state-mandated lease 

agreements to be modified to reflect 

who the responsible party will be if a 

home’s concrete slab needs to be 

removed for emergency repairs or for 

maintenance work to the park’s 

infrastructure beneath the home. In 

addition, digging frost-free foundations 

could cause damage to existing utility 

services. Further, land-lease 

communities have allowed 

manufactured homes to be supported 

upon concrete block piers resting on 

either concrete ‘‘ribbons’’ or on concrete 

pads under the home. These systems 

have proven successful and provide an 

affordable alternative to supports 

embedded within the soil, if proper 

skirting and flexible utility connections 

were properly installed. The provisions 

of the proposed HUD standards 

requiring supports to be installed to or 

below frost depth should be limited to 

apply only to those homes permanently 

installed as real estate. 

Comment: If it is determined that 

interior footings at crawl space finished 

grade, or at least at a reduced depth, are 

appropriate in frost climates on 

perimeter-insulated foundation designs, 

then this determination should also 

extend to permanent foundations. 

Placing all interior footings at frost 

depth below grade is unnecessary and 

will make manufactured homes less 

affordable, as the cost is estimated to be 

between $3,000 and $5,000. 

HUD Response: The need to protect 

foundation and anchorage systems 

against the effects of frost heave is now 

specifically referred to in §§ 3285.312(b) 

and 3285.404 of the installation 

standard. HUD believes that, due to 

local variability in frost depth locations, 

local municipalities are the best sources 

for this information, and HUD will 

allow frost depth to be determined by 

the LAHJ in the final rule. Other costeffective alternatives are permitted in 

the final rule, such as monolithic slabs 

and insulated foundation systems, 

provided they are designed in 

accordance with either accepted 

engineering practice to address the 

effects of frost heave or in accordance 

with the SEI/ASCE 32–01, Design and 

Construction of Frost-Protected Shallow 

Foundations. By permitting the use of 

these alternative methods and not 

requiring foundations to be placed 

below the frost line, HUD believes that 

problematic situations with utilities and 

in existing land-lease communities, as 

described by the commenters, are 

reduced. 

Comment: Figure A to § 3285.312

Typical Blocking Diagram for Single 

Section Homes. Footnote 4 of this figure 

should be revised by changing the 

reference from ‘‘atrium doors’’ to 

‘‘sliding glass doors,’’ to maintain 

consistency with other requirements in 

the Model Installation Standards. 

HUD Response: Footnote 4 has been 

revised in the final rule to refer to patio 

doors and sliding glass doors instead of 

atrium doors. 

Comment: Figure C to § 3285.312

Footing Configuration Layout Designs. 

Figure C should be deleted from the 

final rule, since it is based on 16′′ x 16′′ 

footing pads; stacked footer layouts that 

could lead to poor foundation 

performance and that are inconsistent 

with the size and thickness of footing 

pads (i.e., 2′ x 2′ pre-cast concrete pads) 

typically used in installing 

manufactured homes. In addition, the 

use of footing layout configurations is 

overly conservative, not cost-effective, 

and should not be used as a minimum 

standard. 

HUD Response: HUD agrees with the 

commenters, and Figure C has been 

deleted from the final rule. 

Comment: § 3285.314 Permanent 

Foundations/HUD Question: Should the 

Model Installation Standards include a 

definition and expanded requirements 

for permanent foundations? If so, what 

specifics should be considered and 

included in the Model Installation 

Standards? 

Comment: The model (minimum) 

standard should not require 

manufacturers to provide DAPIAapproved designs for permanent 

foundations. This would be an added 

extra cost to these producers for 

complying with a requirement that their 

buyers may not even wish to consider. 

Comment: The model standard should 

make no mention of anything 

concerning how mortgage lenders or 

others can establish financing eligibility 

requirements for permanent 

foundations. This is for the financial 

institutions to decide, and this standard 

needs to stay focused on providing a 

model installation standard. Financing 

options are outside the scope of the rule, 

and such references should be deleted. 

Comment: A permanent foundation 

under a HUD-Code home should be 

subject to the same requirements as any 

modular, panelized, or stick-built home 

under an LAHJ. 

Comment: Without a clear definition 

for a permanent foundation, how will it 

be determined whether the proposed 

permanent foundation is adequate? 

Comment: ‘‘Designs for permanent 

foundations (such as basements, crawl 

spaces, or load-bearing perimeter 

foundations) may be permitted to be 

obtained from the home manufacturer, 

or designed by a registered professional 

engineer or architect, and constructed in 

accordance with local building code 

requirements.’’ This is the proper 

performance-based language for any 

section on permanent foundations. 

Comment: HUD has materially 

deviated from the intent of the MHCC 

language by allowing states and 

localities to mandate that permanent 

foundations be used. 

Comment: HUD should permit states 

or local governments to impose 

requirements for homes on permanent 

foundations in accordance with local 

governing codes, as long as the design 

exceeds the model standard, and HUD 

should not limit mortgage lenders from 

establishing financing eligibility 

requirements or underwriting standards 

that provide greater protection than the 

model standard. 

Comment: Section 3285.314(a) should 

be deleted and replaced with, ‘‘The 

placement of a manufactured home on 

a permanent foundation must be in 

accordance with state [or LAHJ] 

requirements, installed in accordance 

with the listing by a nationally 

recognized testing agency based on a 

nationally recognized testing protocol, 

or installed in accordance with the 

manufacturer’s approved permanent 

foundation installation instructions and 

in all cases, based on the home’s design 

and load requirements of the 

Manufactured Home Construction and 

Safety Standards.’’

HUD Response: As suggested by a 

majority of the commenters, the 

requirements for permanent foundations 

have been deleted in the final rule. 

HUD’s decision was based on a number 

of factors, including: (1) Under the Act, 

states and local governments are not 

restricted from establishing specific 

requirements for permanent 

foundations, provided they comply with 

the minimum requirements of the 

Model Installation Standards; (2) 

Mortgage lenders are not governed by 

the Model Standards; (3) HUD believes 

that these requirements may be better 

addressed as part of the national test 

protocol for alternative foundations 

referred to in § 3285.301(d) that HUD is 

developing together with the MHCC. 


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Comment: § 3285.315 Special Snow 

Load Conditions. The MHCC language 

regarding ramadas is preferable to that 

used in the proposed rule, because HUD 

unnecessarily limits the use of ramadas 

to areas where the snow load exceeds 40 

psf. Commenter asks why couldn’t a 

ramada be used on a home with a 20- 

psf roof where the snow load is 30 psf? 

Also, the MHCC language of ‘‘self 

supporting’’ is much clearer as to the 

intent than is the HUD language. 

HUD Response: The final rule is 

revised to clarify that ramadas are to be 

self-supporting. HUD’s installation 

program regulations will address 

requirements for placement of homes in 

accordance with the design 

requirements for roof loads and other 

geographic variations as indicated on 

the home’s data plate. 

Subpart E—Anchorage Against the 

Wind 

Comment: § 3285.401(c). This section 

lacks sufficient detail as to the 

information that needs to be included in 

the manufacturer’s installation 

instructions for anchor assembly type 

installations. Areas that need to be 

addressed include: strap attachment, 

strap angle, stabilizing plates, protection 

at the sharp corners, longitudinal 

anchoring methods, and alternative 

anchoring methods. 

HUD Response: A new paragraph (d) 

has been added in the final rule to 

clarify that all of the information is 

required to be provided for anchor 

assembly type installations. 

Comment: § 3285.401(a–c)

Anchoring Instructions. The Maximum 

Diagonal Tie-down Strap Spacing 

Tables for determining anchorage 

requirements to resist wind loads in 

§ 3285.401 are intended for use under 

specific circumstances. Since flood or 

seismic loads are not considered in the 

tables, a new footnote should be added 

at the end of each table to read as 

follows: ‘‘The maximum heights and 

strap spacing specified in the table 

assume no flood or seismic loads acting 

on the foundation or home. These tables 

shall not be used in flood hazard areas 

or seismic hazard areas. In these areas, 

the foundation and the anchorage 

design shall be specified by a registered 

engineer or professional architect.’’

HUD Response: The tables have been 

relocated to § 3285.402 in the final rule. 

A footnote has been added to each table 

indicating that flood or seismic loads 

have not been considered and that the 

tables are not intended for use in flood 

or seismic hazard areas. In those areas, 

the anchorage system must be designed 

by a registered professional engineer or 

architect. 

Comment: § 3285.401(c). The current 

wording sounds as if a home MUST be 

installed to the design loads. The 

language should be changed to read as 

follows: ‘‘(c) All anchoring and 

foundation systems must be capable of 

meeting the loads required by part 3280, 

Subpart D of the Manufactured Home 

Construction and Safety Standards 

(MHCSS), for the area in which the 

home is located. The home’s design 

must be based on the loads shown on 

the data plate, or higher.’’ Another 

commenter indicated that this provision 

would be unnecessarily burdensome 

and costly for foundation and anchoring 

requirements, if a home is to be sited in 

a roof load zone or wind zone that had 

less restrictive design load requirements 

than the home had been designed to 

resist. 

HUD Response: An exception has 

been added to this section in the final 

rule to indicate that when manufactured 

homes are installed in less restrictive 

roof load zone and wind zone areas, 

they may have foundation or anchorage 

systems that are capable of meeting the 

lower design load provisions of the part 

3280 standards. However, this is 

conditioned upon the availability of 

either a design for the lower 

requirements in the manufacturer’s 

installation instructions or having a 

foundation and anchorage system 

designed for the lower requirements by 

a professional engineer or registered 

architect. 

Comment: § 3285.401(d) Anchoring 

Instructions. A new paragraph should 

be added to 3285.401: ‘‘Compliance 

with the wind requirements of NFPA 

225 shall be deemed to comply with 

3285.401(a) through 3285.401(c). 

HUD Response: This comment was 

not accepted, as the requirements in the 

final rule for anchoring are different in 

certain respects than those contained in 

NFPA 225. 

Comment: § 3285.402(a) Ground 

Anchor Installations. The definition for 

‘‘ground anchor’’ should be changed to 

‘‘ground anchor assembly,’’ as all 

portions of the anchor, anchor head, 

bolts and nuts, stabilizer plates, etc., 

should be protected from corrosion. 

HUD Response: A new definition for 

anchor assembly is included in the 

revisions to parts 3280 and 3285. 

However, the final rule also contains a 

separate definition for ground anchors. 

Comment: § 3285.402(a). The 

requirements for a nationally recognized 

ground anchor test protocol should not 

be finalized until the MHCC 

recommendations for the test protocol 

are finalized and presented to HUD for 

its consideration. 

Comment: Proposed changes to 

ground anchor testing methods are not 

necessary because the testing protocols 

currently in place have worked well for 

many years. Failures are not a result of 

test requirements; they are a result of 

not following installation instructions. 

Changing the testing requirements 

would result in higher costs to 

homeowners. 

Comment: The rule does not address 

the capacity of ground anchors in wet or 

saturated soil. The lack of specific test 

standards and protocols in the rule will 

result in the actual performance of 

different anchors under the same 

conditions to vary greatly. This will 

impact the ground anchor spacing 

provided in the rule. 

Comment: Minimum spacing of 

anchors is not a requirement in the 

current anchor test protocol being 

developed by the MHCC Installation 

Subcommittee and should be 

considered. 

HUD Response: HUD disagrees with 

the comment that a national testing 

protocol is not needed, because anchor 

performance is dependent on a number 

of factors, including soil strength, angle 

of pull, and size of the stabilizer plate, 

which are not consistently being 

evaluated due to the unavailability of a 

national testing requirement. 

Recommendations for a nationally 

recognized testing protocol for anchors 

referred to in § 3285.402(a) of the final 

rule are currently being developed by 

the MHCC, and when completed, are 

expected to address testing and 

certification of anchors in saturated 

soils. 

As part of HUD’s current research 

program to evaluate the MHCC draft 

testing proposal and make 

recommendations for a national test 

method for anchoring systems, anchor 

resistance, and behavior when anchors 

are located in close proximity to each 

other will also be considered. 

During the interim, anchors are 

required to be capable of resisting an 

ultimate load of at least 4,725 pounds 

and a working load of at least 3,150 

pounds in any soil type or classification, 

including saturated soils, unless 

reduced ground anchor or strap 

capacities are used, as permitted in the 

final rule. 

Comment: 3285.402(b)(1) Ground 

Anchors. Ground anchors must be 

required to be installed to their full 

depth because when ground anchors are 

tested they are installed to their full 

depth. 

HUD Response: Section 3285.402(b) 

of the final rule has been revised to 

require that ground anchors be installed 

to their full depth. Ground anchors that 


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are not installed to their full depth have 

significantly reduced resistance to 

lateral, longitudinal, and uplift forces. 

Comment: § 3285.402 Ground 

Anchor Installations. This section of the 

proposed rule would require 

galvanizing of ground anchors, anchor 

equipment, and stabilizing plates to be 

zinc-coated in all instances. This is 

inconsistent with § 3280.306(g) of the 

Manufactured Home Construction and 

Safety Standards that permit anchoring 

equipment to have a resistance to 

weather deterioration at least equivalent 

to that provided by a coating of zinc on 

steel of not less than 0.30 oz./ft2. It also 

would preclude other acceptable forms 

of acceptable corrosion protection from 

being used, such as stainless steel, 

epoxy coatings, and even mill 

galvanizing, which are acceptable 

methods of corrosion protection in the 

site-building industry. Has HUD 

considered the economic impact of 

requiring all anchoring equipment to be 

zinc coated? 

Comment: Not all ground anchor 

assemblies will require the use of steel 

stabilizer plates. If a ground anchor 

assembly is tested to be listed or 

certified according to the Ground 

Anchor Test Protocol currently under 

consideration by the MHCC 

Subcommittee on Installation, that 

design should be able to be listed as a 

certified anchor assembly under that 

section. 

HUD Response: HUD agrees with the 

commenters and § 3285.402(c)(2) of the 

final rule has been revised to indicate 

that if metal stabilizer plates are used, 

they must be provided with protection 

against weather deterioration and 

corrosion at least equivalent to that 

provided by a coating of zinc on steel 

of not less than 0.30 oz./ft2 of surface 

coated. This paragraph of the final rule 

also indicates that ABS stabilizer plates 

may be used when listed and certified 

for such use. 

Comment: § 3285.402 Ground 

Anchor Installations. Longitudinal 

Anchoring. Longitudinal anchoring 

should not be required in wind zone 1 

locations. 

Comment: A figure illustrating the 

installation of longitudinal anchors and 

tie-down straps should be provided 

showing the correct and incorrect 

methods of attachment of the tie-down 

straps to the chassis beams, as indicated 

in note 2. Also, further illustrations 

should be included to show the correct 

and/or incorrect methods of ground 

anchor installations, such as stabilizer 

plates, strap attachment (swivel strap, 

frame tie w/hook, frame tie w/buckle), 

proper strap tensioning, and concrete 

slab anchors. 

Comment: Section 3285.402(b)(2) is 

overly prescriptive and restrictive and 

should be modified to permit panbracing or other types of bracing 

systems to be used for longitudinal 

anchoring. The standard should be 

modified to permit pan-bracing systems 

to be used, unless there is data 

indicating such systems are insufficient 

for this purpose. 

HUD Response: Longitudinal 

anchoring is required to be provided to 

resist the design wind forces in all wind 

zones in the final rule based on the 

recommendations of the MHCC, NFPA 

225, and engineering analysis. As 

suggested by the commenters, a new 

Figure C to § 3285.402 has been added 

in the final rule to provide an example 

method for providing the longitudinal 

anchoring required by the final rule. 

Section 3285.402(c)(3) has also been 

revised in the final rule to permit the 

use of alternative systems, such as panbracing type systems, provided they are 

capable of resisting the wind forces in 

the longitudinal direction. 

Comment: § 3285.402 Figure B 

Anchor Strap and Pier Relationship. 

Note 2 (the diagonal ties footnote) 

should be removed, as there are other 

methods of preventing rotation of the I 

beam, including cross member 

placement. The sentence should be 

reworded to state: ‘‘When strap is 

attached to bottom of I beam, the I beam 

must be designed to prevent rotation.’’

HUD Response: Section 

3285.401(d)(3) and Note 2 to Figure B 

on Anchor Strap and Pier Relationship 

have been revised in the final rule to 

indicate that when diagonal ties are not 

attached to the top flange of the main 

chassis beam, that the frame must be 

designed to prevent rotation of the 

beam. 

Comment: Tables 1–3 to § 3285.402. 

The information listed in the tables does 

not include tie-down strap spacing 

requirements for 36-foot-wide units. The 

tables should be expanded to also 

include 75.5′′ I-Beam spacing, because 

homes are currently being constructed 

to that specification. Also, the tables 

should be expanded to include other 

sidewall heights, such as 84′′, 96′′, and 

108′′, which are industry standards. 

Comment: Note 2 of the tables 

specifies maximum 4′′ inset of the 

anchor head, but an inset of 6′′ is more 

typical to allow for skirting and 

perimeter wall or piers. 

Comment: In Note 6 for Table 1 and 

Note 7 for Tables 2 and 3, the second 

sentence should be revised to read as 

follows: ‘‘Table based upon the 

minimum height between the ground 

and the bottom of the floor joist being 

18 inches.’’

Comment: The provision in Note 9 in 

Table 1 and Note 10 in Tables 2 and 3 

should be revised to require that ground 

anchors be installed in accordance with 

the ground anchor manufacturer’s 

instructions and not the home 

manufacturer’s instructions. 

Comment: The ‘‘second beam 

method’’ provided in Tables 2 and 3 is 

not a viable option because of potential 

damage to HVAC ducts, plumbing, etc., 

in the floor. If the ‘‘second beam 

method’’ is retained, a cautionary note 

should be added to the tables to warn 

of potential damage. 

Comment: The anchor test protocol 

currently being developed by the MHCC 

Installation Subcommittee is 

recommending a 30-degree minimum 

angle for testing anchors in the diagonal 

direction. As such, 18-foot-wide units at 

25′′ or less in height from the ground to 

the attachment point on the frame 

represent the only situation where the 

30-degree minimum angle from 

horizontal cannot be maintained. Rather 

than unnecessarily limiting anchor 

performance, HUD should require the 

minimum height for 18-foot sections to 

be 33 inches or higher. 

Comment: A footnote should be 

added to Tables 2 and 3 to indicate that 

the tables are based on a maximum force 

of 1,640 lbs. being resisted by vertical 

tie straps. This is the maximum tension 

in the vertical strap as a result of tiedown calculations used to develop the 

tables. This note is important to 

properly size sidewall strap attachment 

components and brackets. 

HUD Response: The tables for 

diagonal strap spacing are based on 

recommendations from the MHCC and 

represent the most commonly used 

main chassis beam spacing of 82.5 

inches and 99.5 inches and sidewall 

height of 90 inches. Other main beam 

spacing configurations or sidewall 

heights must be designed by a 

professional engineer or registered 

architect. The tables for diagonal strap 

spacing were developed based on a 4′′ 

maximum inset. Other insets for ground 

anchors are permitted, provided they 

are included in the installation 

instructions or designed by a 

professional engineer or registered 

architect. 

Note 6 in Table 1 and Note 7 in Tables 

2 and 3 on minimum height between the 

ground and floor joist has been revised 

in the final rule, in accordance with the 

above comments. Spacing requirements 

for 18-foot section widths were removed 

from the Tables 1 through 3 for 

consistency with other tables in other 

chapters of these installation standards. 

Tables 1 through 3 have also been 

revised in the final rule by providing 


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additional conditions for the minimum 

and maximum angles for their 

applicability and use in determining the 

maximum spacing of diagonal tie-down 

straps in Wind Zones I, II, and III. These 

limitations were recommended by the 

MHCC Installation Subcommittee based 

on the unfavorable results of anchor 

tests in weak soils, where the angle of 

pull on the anchor was 30 degrees or 

less. As a result, a number of the far 

beam spacing provisions are no longer 

applicable for use with the tables, 

although such provisions may be used 

in accordance with a site-specific design 

approved by an architect or engineer. 

In the final rule, HUD did not include 

information on vertical tie strap 

capacity for connections, as this needs 

to be considered in the manufacturer’s 

designs and installation instructions 

and is, therefore, not specified in the 

tables. 

Comment: § 3285.404 Severe 

Climatic Conditions. Under § 3285.404, 

it should be acceptable for ground 

anchors to be installed above the frost 

line, when the footings for the 

foundation system are frost-protected 

against the effects of frost heave. There 

should be a reference to § 3285.312(c), 

in which the approved alternate 

anchoring system may be included as 

part of a listed or labeled foundation 

support system (floating slab or 

insulated foundation). 

HUD Response: Section 3285.404 of 

the final rule has been revised to permit 

ground anchors to be installed above the 

frost line, provided the foundation 

system is frost protected to prevent the 

effects of frost heave, in accordance 

with acceptable engineering practice 

and §§ 3280.306 and 3285.312. 

Comment: § 3285.405 Severe Wind 

Zones. As more stringent anchorage 

design requirements may be specified 

elsewhere in these standards, by the 

LAHJ or the state, wind-resistant 

anchorage provisions contained in 

NFPA 225 should be deemed 

acceptable, and should be referenced for 

use by installers, designers, and LAHJs, 

if they so choose. The section should be 

revised to read as follows: ‘‘When any 

part of a home is installed within 1,500 

feet of a coastline in Wind Zones II or 

III, the manufactured home must be 

designed for the greater of the increase 

requirements as specified (1) on the 

home’s data plate (refer to § 3280.5(f) of 

this chapter), (2) elsewhere in these 

standards, or (3) by the LAHJ or state, 

and in accordance with acceptable 

engineering practice. Where site or other 

conditions prohibit the use of the 

manufacturer’s instructions, a registered 

professional engineer or registered 

architect in accordance with acceptable 

engineering practice must design 

anchorage for the special wind 

conditions. Compliance with the severe 

wind requirements of NFPA 225 shall 

be deemed to comply with 3285.405.’’

HUD Response: The final rule does 

not include a provision that recognizes 

the wind and anchoring provisions of 

NFPA 225 as deemed to comply with 

these standards, as those requirements 

are not consistent with these standards. 

For purposes of installation, a state or 

LAHJ can establish more stringent wind 

design provisions for anchoring than are 

required by these minimum standards. 

Comment: § 3285.406 Flood Hazard 

Areas. The section should be reworded 

to read as follows: ‘‘In flood hazard 

areas, the piers, anchoring, and support 

systems must be capable of resisting all 

combined loads associated with design 

flood and wind events.’’ This is 

particularly important in geographic 

areas susceptible to hurricanes where 

the homes will be subjected to high 

winds and saturated soil 

simultaneously. The scouring effects of 

both wind and water forces also need to 

be addressed regarding the anchoring 

and support system components. 

HUD Response: A reference to 

anchoring requirements in flood hazard 

areas has been included in § 3285.302 of 

the final rule. 

Subpart F—Optional Features 

Comment: § 3285.502 Expanding 

Rooms. The first sentence of this section 

should be revised to read as follows: 

‘‘The support and anchoring systems for 

expanding rooms must be installed in 

accordance with designs provided by 

the home manufacturer or prepared by 

a registered professional engineer or 

registered architect in accordance with 

acceptable engineering practice.’’ As 

proposed, the paragraph suggests that 

only a registered professional engineer 

or architect can design the installation. 

HUD Response: The final rule has 

been revised to also allow designs for 

support and anchoring of expanding 

rooms to be provided by the home 

manufacturer as an alternative to 

designs having to be prepared by a 

professional engineer or registered 

architect. 

Comment: § 3285.503 Optional 

Appliances. These items [all optional 

features] are clearly under the scope of 

state and local codes. It would seem that 

HUD would be preempting such 

authority by state and local government 

to address such items. 

Comment: Section 3285.503(a) should 

also include a reference to the LAHJ and 

local or state code requirements, in 

addition to requirements in the 

manufacturer’s instructions. The 

appliance manufacturer’s instructions 

may not address all requirements that 

would be included in local or state 

codes enforced by the LAHJ. 

Comment: The word ‘‘must’’ could be 

confusing when referring to optional 

appliances. These appliances are 

optional, but the language could be read 

to require them to be mandatory. 

Accordingly, the section should be 

clarified to read as follows: ‘‘Comfort 

cooling systems installed by someone 

other than the home manufacturer, must 

be done according to the appliance 

manufacturer installation instructions.’’

Comment: Minimum standards found 

in the International Residential Code 

(IRC) and International Fuel Gas Code 

should be referenced for various 

appliances and ventilation requirements 

in this chapter. 

Comment: While ventilation 

requirements should be consistent with 

model building codes, referencing the 

model codes in these standards would 

create yet another document that will 

need to be updated and revised. 

HUD Response: These installation 

standards are minimum requirements 

that a state or local jurisdiction must 

meet or exceed for any provision of 

these standards, including optional 

features covered by this subpart. 

Accordingly, HUD is not preempting 

state or local authority in these areas as 

suggested by the commenters, as states 

and municipalities may adopt 

additional requirements for the 

installation of optional appliances. 

References to the International 

Residential Code (IRC) or International 

Fuel Gas Code (IFGC) were not 

presented to the MHCC or suggested to 

the Department during the development 

and issuance of the proposed rule. 

Accordingly, they cannot be considered 

for introduction at this time into the 

final rule. However, the commenter may 

want to re-introduce them again when 

subsequent revisions to the installation 

standards are being considered by HUD. 

The final rule also indicates that 

when not provided and installed by the 

manufacturer, any comfort cooling 

system that is installed must be 

installed according to the appliance 

manufacturer’s instructions. 

Comment: § 3285.503(a)(1)(i) Energy 

Efficiency. The references within this 

section should be clarified as to what 

constitutes proper operation and energy 

efficiency and closely match, with 

regard to heat gain for sizing, siteinstalled air conditioning systems. Also, 

the requirements for determining heat 

gain do not appear to include a 

calculation for latent heat gain. 

Comment: ASHRAE and other energy 

standards require the calculation of the 


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design cooling load, provide the 

standards by which such load is 

calculated, and then require the 

equipment chosen to be the next size 

available that meets that load to be 

chosen. 

HUD Response: Section 

3285.503(a)(1)(i) of the final rule has 

been revised to eliminate the references 

to: (1) ‘‘For proper operation and energy 

efficiency’’ and (2) sizing site-installed 

air conditioning systems to ‘‘closely 

match’’ the home’s heat gain 

requirement. The final rule now 

provides that the air conditioning 

system must meet the heat gain 

requirement. In addition, the reference 

to the term ‘‘sensible’’ has been deleted 

in the final rule so that air conditioning 

systems are now required to be sized to 

meet the home’s overall heat gain. 

Comment: § 3285.503(a)(1)(iii) Acoil Units. Simply stating that the air 

conditioning unit is to be compatible for 

use with the furnace may not be enough 

to ensure safety and performance. What 

about the furnace’s manufacturer’s 

instructions and warranties? 

HUD Response: The final rule has 

been revised to require that A-coil air 

conditioning units must be compatible 

and listed for use with the furnace and 

also comply with the appliance 

manufacturer’s instructions, as 

recommended by the commenters. 

Comment: § 3285.503(a)(2) Heat 

Pumps. The section as proposed does 

not provide any sizing criteria for heat 

pumps and should refer to minimum 

standards that would apply to such 

equipment. 

HUD Response: Heat pumps must be 

sized to meet the requirements of the 

Manufactured Home Construction and 

Safety Standards, 24 CFR part 3280. 

Comment: § 3285.503(c) Appliance 

Venting. This section should be revised 

to be consistent with the wording in 24 

CFR 3280.707(b), as follows: ‘‘Heat 

producing appliances, except ranges 

and ovens, must exhaust to the exterior 

of the home.’’

HUD Response: Section 

3285.503(c)(1) and (2) of the final rule 

have been revised to be consistent with 

the requirements of the Manufactured 

Home Construction and Safety 

Standards, as recommended by the 

commenter. 

Comment: § 3285.503(d) Flood 

Hazard Areas/HUD Question. Where 

should the outside appliance air inlets 

and exhausts be located with respect to 

the base flood elevation in flood hazard 

areas? 

HUD Response: The requirements 

have been relocated to 

§ 3285.102(d)(2)(ii) in the final rule and 

revised to indicate that exterior 

appliance air inlets and exhausts in 

flood hazard areas are to be located at 

or above the lowest floor elevation of 

the home. 

Comment: § 3285.503(d) Figure 

Dryer Exhaust System. The illustration 

shows a reverse slope that does not 

agree with Note 2. 

HUD Response: The illustration has 

been corrected to eliminate the reverse 

slope. 

Comment: § 3285.504 Skirting. To 

ensure performance, uniformity, and 

repeatability, some standard should be 

referenced to determine that the 

materials used for skirting are weatherresistant. 

Comment: All wood skirting within 6′′ 

of the ground should be pressure-treated 

in accordance with the AWPA standard 

U1 for Use Category 4A ground contact 

applications or be naturally resistant to 

decay and termite infestations. This 

would allow a lower requirement for 

skirting materials than for footing pads, 

since it is a non-structural application. 

HUD Response: Performance criteria 

for protection against weather 

deterioration for skirting materials have 

been included in the final rule and 

pressure-treatment requirements for 

wood skirting have been revised, as 

suggested by the commenter. 

Comment: § 3285.505(a) Crawlspace 

Ventilation. Consider model building 

code requirements for ventilation 

requirements, as the proposed 

requirement for ventilation of one 

square foot for every 1,500 square feet 

is insufficient. There should also be not 

less than four vents in order to control 

humidity and for management of mold/ 

mildew and temperature handling. 

Comment: § 3285.505(b). The section 

should be revised to read as follows: 

‘‘Ventilation openings must be placed as 

high as practicable above the ground.’’

Comment: § 3285.505(d) Crawlspace 

Ventilation. The word ‘‘metal’’ should 

be eliminated from § 3285.505(d) to 

allow other materials to be used for 

ventilation openings that may perform 

equal to or better than metal. 

Comment: Ventilation openings 

should be covered with a perforated 

rodent resistant covering resistant to 

decay. 

Comment: Requirements for operable 

louvers should be addressed in cold 

climates. 

Comment: § 3285.505(e). A minimum 

access opening of not less than 24′′ by 

30′′ or five square feet should be 

required. An opening less than 18′′ in 

any dimension is typically not large 

enough for service personnel to access 

underneath the home. 

HUD Response: The ventilation 

requirements are generally consistent 

with other model codes and have not 

been changed in the final rule, with the 

exception of the minimum access 

opening dimensions and requirements 

for operable or adjustable type openings 

to be provided in areas subject to 

freezing. The access opening has been 

increased in § 3285.505(e) of the final 

rule from 18 inches in any direction to 

18′′ by 24′′ in height. In addition, the 

term ‘‘metal’’ has been deleted in 

paragraph (d) and replaced with 

‘‘corrosion and weather resistant’’

covering. The final rule also requires 

openings for ventilation to be placed as 

high as practicable above the ground. 

Subpart G—Ductwork and Plumbing 

and Fuel Supply Systems 

Comment: § 3285.601 Field 

Assembly. HUD should clarify if the 

section refers to manufacturer-supplied 

shipped loose duct systems, because, as 

presently written, any loose duct would 

be covered by the rule. 

HUD Response: The final rule now 

refers to ‘‘manufacturer-supplied 

shipped loose ducts,’’ to clarify the 

intent of this section. 

Comment: § 3285.603(c) Mandatory 

Shutoff Valve. This section should be 

modified to require the mandatory 

shutoff valve to be accessible and 

clearly identifiable. 

HUD Response: Section 3285.603(c) of 

the final rule has been revised to require 

the master shutoff valve to be both 

accessible and identifiable, as suggested 

by the commenter. 

Comment: § 3285.603(d) Freezing 

Protection. The term ‘‘heating cable’’

should be replaced with the more 

commonly used term, heat-tape. 

Comment: What is ‘‘normal 

occupancy,’’ as referred to in 

§ 3285.603(d), and what would then 

constitute ‘‘abnormal occupancy’’? 

HUD Response: Sections 

3285.603(d)(1) and (2) have been revised 

to delete reference to the term ‘‘under 

normal occupancy,’’ as suggested by the 

commenters. However, heating cable is 

the correct term to be used to describe 

this material and, accordingly, no 

change is being made to this section in 

the final rule. A conforming change to 

the term ‘‘heating cable’’ will also be 

made in future revisions now 

contemplated for the MHCSS. 

Comment: § 3285.605 Fuel Supply 

System. The first sentence of 

§ 3285.605(a) should be revised as 

follows in order to be consistent with 

the requirements specified in 24 CFR 

3280.705(a): ‘‘The gas piping system in 

the home is designed for a pressure that 

is at least 7 inches of water column 

* * * and not more than 14 inches of 

water column * * *’’. 


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HUD Response: The requirements for 

testing of gas piping systems in the final 

rule have been revised to be consistent 

with the testing requirements in the 

Manufactured Home Construction and 

Safety Standards. 

Comment: § 3285.606 Ductwork 

Connections. Mastics approved to UL 

181 should be used in all cases to seal 

connections to prevent air leakage. 

However, mastics should not be used as 

the only means of connection. Tapes, 

regardless of whether they are approved 

or not, should not be allowed, except to 

aid in the installation of the ductwork 

for temporary securement. 

Comment: UL standards 181A and 

181B should be referenced for the 

sealing of duct systems. 

Comment: The term metal plumber’s 

tape should be removed from 

§ 3285.606(a). 

HUD Response: The final rule has 

been revised to clarify the requirements 

for sealing of ductwork connections so 

that the appropriate type of tapes and 

mastics are specified, depending on the 

type of air duct being used. In addition, 

the final rule also clarifies that sheet 

metal ducts must be mechanically 

fastened, as suggested by the 

commenters. The reference to ‘‘metal 

plumber’s tape’’ has also been deleted. 

Comment: § 3285.606(e). The section 

should be revised to read as follows: 

‘‘The duct must be suspended or 

supported above the ground at 

maximum 4 feet-0 inches on center 

(unless otherwise noted) and arranged 

under the floor to prevent compression 

or kinking in any location, as shown in 

Figures A and B of this section.’’

Comment: When straps are used to 

support a flexible duct, the straps must 

be at least 1⁄2′′ wider than the metal 

spiral spacing of the duct, and installed 

such that the straps cannot slip between 

any two spirals. 

HUD Response: Section 3285.606(e) 

has been revised in the final rule, in 

accordance with the recommendations 

of the commenters. 

Comment: Figure A to § 3285.606 

Crossover Duct Installation With Two 

Connecting Ducts, Figure B to 

§ 3285.606 Crossover Duct Installation 

With One Connecting Duct. Note 2 

should be revised to read as follows: 

‘‘Note 2. Crossover duct should be listed 

for exterior use.’’

Comment: The concrete block support 

shown in both figures should be 

removed as an acceptable support for 

the crossover duct. 

HUD Response: HUD agrees with the 

commenters, and Figures A and B have 

been revised by deleting the concrete 

block support from each figure and by 

adding a note to each figure to indicate 

that the crossover duct must be listed 

for exterior use. 

Subpart H—Electrical Systems and 

Equipment 

Comment: § 3285.702(d) 

Miscellaneous Lights and Fixtures. 

Ceiling fans must be attached to a 

properly installed junction box that is 

listed for ceiling fan application. 

HUD Response: Section 

3285.702(e)(1) of the final rule has been 

revised to refer to Article 314.27(b) of 

the National Electrical Code, NFPA No. 

70–2005, for connection requirements of 

the ceiling fan to the electrical junction 

box and to require the junction box to 

be listed and marked as suitable for 

ceiling fan application. 

Comment: § 3285.702(e) Testing. 

Paragraph (e)(1) should be deleted in its 

entirety and (e)(2) should be changed to 

(e)(1) and revised to read as follows: 

‘‘After completion of all site 

connections of cross-overs, exterior 

lights, ceiling fans, etc., each 

manufactured home must be subjected 

to the following tests, consistent with 

§ 3280.810 of the MHCSS * * *’’. 

Comment: The section should be 

revised to refer to the electrical testing 

requirements in § 3285.810(b) of the 

MHCSS in order to clarify that dielectric 

tests are not required to be performed 

after setup. In addition, all of 

§ 3285.702(e)(2) should be deleted as it 

both duplicates and contradicts what is 

already required by § 3285.810(b). 

HUD Response: The final rule has 

been revised in a manner that is 

consistent with the recommendations of 

the commenters. 

Subpart I—Exterior and Interior Close 

Up 

Comment: Figure A to § 3285.801 

Installation of Field-Applied Horizontal 

Lap Siding. The notes and figure need 

to be less specific and revised to read as 

follows: Note 1 should be revised by 

changing the reference from ‘‘double 

section’’ to ‘‘multi-section.’’ Note 2 

should be revised to clarify that all 

doors and windows need not be covered 

with plastic sheeting, and the word 

‘‘fasteners’’ deleted, because installers, 

rather than manufacturers, generally 

provide fasteners so that they are 

compatible with their installation 

equipment. The note in Figure A should 

be revised to read as follows: ‘‘Windows 

installed with j-rail or brick mold 

around it,’’ because many windows are 

equipped with brick mold and it serves 

the same purpose as the j-rail. 

HUD Response: As suggested by the 

commenters, editorial revisions have 

been made to the section and Note 2 has 

been clarified to indicate that only 

materials that are not designed to be 

exposed to the weather are to be covered 

with plastic sheeting. 

Comment: § 3285.801(d) Joints and 

Seams. Any holes made in the roof must 

be sealed, utilizing approved methods 

and materials. 

Comment: The type of acceptable 

sealant should be specified in the Model 

Installation Standards for sealing the 

holes. 

HUD Response: Section 3285.801(d) 

has been revised in the final rule by 

clarifying that the roofing must be made 

weatherproof and any holes sealed with 

a sealant that is suitable for use with the 

type of roofing in which any hole is 

made. 

Comment: § 3285.801(e) Mate-line 

Gasket. Gaskets should also be capable 

of resisting the entry of water vapor in 

addition to air, water, insects, etc. 

Comment: Permit installers or 

homeowners to provide the mate-line 

gasket, provided the materials comply 

with the manufacturer’s installation 

instructions. 

HUD Response: The final rule has 

been revised by requiring the mate-line 

gasket to also be capable of providing 

resistance against water vapor entry. 

However, HUD does not agree with 

suggestions made by commenters that 

the mate-line gasket be allowed to be 

provided by parties other than the home 

manufacturer. This is because HUD 

deems the gasket material to be an 

integral part of the construction of the 

home to provide the resistance to the 

weather required by the MHCSS. 

Comment: § 3285.801(f) Hinged 

Roofs and Eaves/HUD Question. Should 

the requirements for hinged roofs and 

eaves be considered installation and 

subject to the Model Installation 

Standards and not construction, as 

proposed by HUD? 

Comment: A hinged roof should be 

treated as construction of the home’s 

roof assembly and subject to the 

requirements of the HUD Code. 

Comment: The Model Installation 

Standards should be extended to cover 

any hinged roof, regardless of wind 

zone, roof pitch, or flue penetration. 

This is a normal construction process 

that is occurring more routinely with 

HUD Code installations and would save 

considerable money with regard to 

Production Inspection Primary 

Inspection Agency (IPIA) inspection 

under the on-site completion rule and 

time under the alternative construction 

(AC) letter process. 

HUD Response: It continues to be 

HUD’s position that the on-site 

completion of hinged roofs with eaves is 

generally part of the construction 

process, and that hinged roofs with 


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eaves must comply with all 

requirements of the Manufactured Home 

Construction and Safety Standards (24 

CFR part 3280) and the Manufactured 

Home Procedural and Enforcement 

Regulations (24 CFR part 3282), even 

though this work is often completed 

during the set-up of the home. 

Accordingly, certain hinged roofs and 

other construction completed on-site 

will continue to be subject to the 

provisions for Alternative Construction 

in § 3282.14 of the Manufactured Home 

Procedural and Enforcement 

Regulations, and may be also subject to 

the provisions of the future rulemaking 

for on-site construction. However, 

manufactured homes with hinged roofs 

and eaves are not subject to these 

special requirements if the homes: (1) 

Are designed to be located in Wind 

Zone I; (2) have a pitch of the hinged 

roof that is less than 7⁄12; (3) have fuel 

burning appliance flue penetrations that 

are not above the hinge; and (4) have 

been completed and inspected as part of 

the installation process under future 

rulemaking being developed for the 

installation program regulations. 

Nevertheless, even for the abovedescribed conditions, manufacturers are 

still responsible for providing 

instructions on how to complete each 

hinged roof and/or eave construction, in 

accordance with the requirements of the 

Manufactured Home Construction and 

Safety Standards. 

Comment: § 3285.802 Structural 

Interconnection of Multi-Section 

Homes. As proposed, the section is 

unclear and needs to be clarified as to 

whether any gap is permitted along the 

mate-line between sections of multisection homes. 

Comment: The section needs to be 

clarified as to whether any gap between 

structural elements must be shimmed or 

only those gaps that exceed 11⁄2 inches. 

Comment: Fastener lengths would 

need to be increased to provide 

adequate protection and staples or nails 

need to be at least 11⁄2 inches in length 

at a minimum. 

Comment: A 11⁄2′′ gap is too much 

because these homes are built in a 

factory environment where conditions 

are controlled so that there should be 

tighter tolerance. The requirement 

should be reduced to no more than 3⁄4′′ 

gap between structural elements. 

Comment: When home sections are in 

contact and the mating gasket is sealed, 

then all gaps should be filled. 

HUD Response: Section 3285.802(c) of 

the final rule has been revised to clarify 

that upon completion of the close-up, 

no gaps are permitted between 

structural elements being 

interconnected at the marriage line of 

multi-section homes. However, prior to 

completion of the close-up, gaps of up 

to one inch are allowed between 

structural elements if they are closed 

upon completion of the set-up; the 

home sections are in contact with each 

other, and the mating gasket is 

providing a proper seal. Also, all gaps 

are to be shimmed with dimensional 

lumber and fastener lengths are to be 

increased to provide adequate 

penetration into the receiving member 

of the elements being joined. 

Comment: § 3285.803(b) Interior 

Close-up. This section should be revised 

or deleted. Polyvinyl acetate (PVA) 

adhesives should not be required for onsite fastening of shipped loose panels. 

Standard drywall fastening does not 

require adhesive and thus there is no 

reason for this excessive prescriptive 

requirement. When the home has been 

designed utilizing a structural adhesive 

for wall panels, the requirement should 

be specified in the installation 

instructions of the particular home 

manufacturer. 

HUD Response: Editorial revisions 

have been made to this paragraph in the 

final rule, and the final rule has been 

revised to permit alternative fastening 

methods to PVA adhesives for installing 

shipped-loose panels, if specified in the 

manufacturer’s installation instructions. 

Comment: Figure A to § 3285.803 

Installation of Field-Applied Panel. 

What is the intent of restricting the 

panel width to no less than 16′′ or no 

larger than 32′′? Further, if typical 

panels are 48′′ inches in width, how can 

a ‘‘full size’’ panel be over 16′′ but less 

than 32′′ in width? 

Comment: The panel size depicted in 

the figure and note should be changed 

to read as follows: ‘‘One full-sized panel 

48 inches or less in width.’’

HUD Response: As suggested by the 

commenters, the note in the figure has 

been revised in the final rule to indicate: 

‘‘One full-sized panel 48 inches or less 

in width.’’

Comment: § 3285.804 Bottom Board 

Repair. Prior to closure of the 

underbelly cavity of the home, any areas 

being repaired must be inspected and 

any missing insulation replaced before 

completing the repair of the bottom 

board material. 

Comment: Any splits or tears must be 

resealed in accordance with the 

manufacturer’s installation instructions. 

HUD Response: Section 3285.804(a) of 

the final rule has been revised to require 

any missing insulation to be replaced 

prior to closure and repair of any 

damage to the bottom board. Section 

3285.804(b) has been revised to require 

any split or tear in the bottom board to 

be resealed, in accordance with methods 

described in the installation 

instructions. 

Subpart J—Recommendations for 

Manufacturer Installation Instructions 

Comment: § 3285.901 

Recommendations for Manufacturer 

Installation Instructions. The reference 

to the ‘‘following cautions’’ in paragraph 

(c) should also include the cautions or 

recommendations in paragraphs (a) and 

(b), as they are as important as the 

remaining sections of Subpart J. 

Comment: The provisions of Subpart 

J do not relate to the content of 

manufacturer instructions. It is 

recommended that this subpart be 

reconsidered as follows: § 3285.901(a) 

and (b), § 3285.902, and § 3285.903 

could be relocated to subpart B; 

§ 3285.904 could be moved to 

§ 3285.203; and § 3285.905 could be 

consolidated at § 3285.602. 

HUD Response: This subpart of the 

final rule has been re-titled ‘‘Optional 

Information for Manufacturer 

Installation Instructions’’ and 

reorganized to include 

recommendations that may be provided 

as part of the installation instructions. 

The cautions have been removed in the 

final rule and replaced with 

recommendations for inclusion by 

manufacturers in their installation 

instructions. 

Comment: § 3285.903 Permits, 

Alterations, and On-site Structures. 

Planning and permitting processes, as 

well as utility connection requirements, 

are outside HUD’s authority, but in the 

proposed rule, HUD does provide 

standards for some of these items. 

HUD Response: The final rule makes 

recommendations, rather than 

mandatory directives, for inclusion of 

certain information in the installation 

instructions related to moving homes to 

locations; permits, alterations, and onsite structures; utility system 

connections; and telephone and cable 

TV wiring. It contains no requirements 

that these items be actually included in 

the instructions. The requirements for 

‘‘positioning the home’’ have been 

deleted in the final rule. 

Comment: § 3285.902(d). Fire 

separation distances should consider 

the requirements of the LAHJ, as well as 

distances required in NFPA 501A. 

HUD Response: The provisions for 

fire separation in the final rule have 

been relocated to subpart B, § 3285.101, 

and require installation instructions to 

indicate that fire separation distances 

must be in accordance with Chapter 6 

of NFPA 501A, 2003, or the 

requirements of the LAHJ. 

Comment: § 3285.902(a) Moving 

Manufactured Home to Location. One 


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commenter wrote that the following 

sentence should be added to the 

introductory paragraph: ‘‘Inform and 

contact the LAHJ before moving 

manufactured home to the site or 

location.’’

HUD Response: The final rule has 

been revised to indicate that the LAHJ 

should be informed before moving the 

manufactured home to the site. 

Comment: § 3285.903(c)(3). The 

section should be revised to read as 

follows: ‘‘Unless approved by the home 

manufacturer’s installation instructions, 

all buildings, structures, and accessory 

structures must be designed to support 

all their own live and dead loads.’’

Recent tornado and hurricane activities 

have caused many manufacturers to 

realize the importance of proper 

connections of site-installed structures 

to their homes and offer designs that 

incorporate the additional roof and 

wind loads imposed by those site 

additions. 

HUD Response: Section 3285.903(c) of 

the final rule has been revised to require 

any accessory building or structure to be 

capable of supporting its own live and 

dead loads, unless the structure is 

designed to be attached to the 

manufactured home by a professional 

engineer or registered architect or is 

otherwise specifically included in the 

manufacturer’s installation instructions. 

Comment: § 3285.905 Utility System 

Connections. If LAHJ requirements 

govern utilities and LAHJ standards 

vary, how can there be any meaningful 

installation instruction with regard to 

utilities? The instruction, at best, should 

refer installers and residents to consult 

with any serving utilities; and, as such, 

no regulation is necessary. 

HUD Response: The final rule has 

been revised by recommending the 

installation instructions suggest 

different procedures for the installer to 

follow prior to making any utility 

system connection, depending on the 

availability of utility services, an LAHJ, 

or both, as well as procedures to follow 

in rural areas where utility services are 

not available and there is no LAHJ. 

Comment: § 3285.905 Drainage 

Systems. The proposed language for 

making drainage-to-sewer system 

connections is too restrictive, as an 

installer may opt to ‘‘hard-pipe’’ the 

connection without the use of an 

elastomeric coupling device. 

HUD Response: The final rule has 

been revised by recommending the use 

of other methods acceptable to the LAHJ 

as an alternative to elastomeric 

couplings for connecting the main drain 

line to the site sewer hookup. 

Comment: § 3285.906 Heating Oil 

Systems. Since fuel oil supply tanks and 

systems installed at the site are not 

within the scope of HUD’s authority, 

what makes fuel oil different from 

propane, site installed air conditioning 

systems, etc? This will make it harder to 

determine who is responsible for 

installation and liability, should 

something go wrong. 

HUD Response: While HUD agrees 

that these provisions for site-installed 

oil fuel tanks and systems are outside of 

the scope of HUD’s authority, for fire 

safety and other considerations the final 

rule does recommend that installation 

instructions include information related 

to installation and testing of oil supply 

tank and piping, in accordance with 

NFPA 31, 2001, Standard for the 

Installation of Oil Burning Equipment, 

and oil furnace manufacturer 

instructions for pipe sizing and 

installation procedures. 

Comment: § 3285.907 Telephone 

and Cable TV. A reference to the 

applicable sections of the National 

Electrical Code, NFPA 70—2005 

Edition, should be incorporated in the 

manufacturer’s installation instructions 

for telephone and TV cable wiring and 

connections. 

HUD Response: A reference to the 

National Electrical Code has been added 

in the final rule to the recommendations 

for installing telephone and cable TV 

wiring. 

Miscellaneous Comments 

Comment: Enforcement and Program 

Operation Matters. HUD received a large 

number of comments and questions 

related to the operation and 

enforcement of its installation program. 

HUD Response: Comments and 

questions related to program operation 

and enforcement are not being 

addressed in this rulemaking. Instead, 

they will be duly considered by HUD, 

as appropriate, in response to the 

proposed rule for the Manufactured 

Home Installation Program, 24 CFR part 

3286, that was published in the Federal 

Register on June 14, 2006. 

Comment: § 3285.5 Definitions—

‘‘Installers.’’ One of the most glaring 

omissions from the proposed 

installation standards was a definition 

or identification of manufactured home 

installers since, as drafted, so many 

construction responsibilities are 

redistributed to installers. While the 

proposed rule speaks as if there is one 

installer per project, in reality there are 

many installers involved. By failing to 

define installers, responsibilities are 

being further fractured and protections 

are weakened. The commenters 

advocate that to ensure quality, 

durability, and safety, a single entity 

needs to take responsibility, which they 

believe should be the manufacturer. 

HUD Response: A definition for 

‘‘installer’’ is in the proposed rule for 

the installation program regulations in 

part 3286. 

Comment: Exclusivity of Model 

Installation Standards. It is important 

for the standards or their state-adopted 

counterparts to be the only federal 

installation standard recognized by 

HUD. Currently, HUD’s FHA Title II 

program references the Permanent 

Installation Guide for Manufactured 

Housing. 

HUD Response: HUD is considering 

whether to amend references in its 

current Title II program to specifically 

refer to these Model Installation 

Standards. 

Comment: Impact on Federal 

Agencies. One commenter wrote that 

HUD has not considered the impact of 

the proposed rule on other federal 

agencies that are engaged in purchasing 

and installing manufactured homes for 

federal purposes. Since the proposed 

rule does not address the regulations 

establishing an installation program, it 

is impossible to determine if this rule, 

as part of a larger program, imposes any 

mandates on state or local government. 

HUD Response: These issues will be 

considered as part of HUD’s federalism 

analysis on this final rule. 

Comment: Bay Windows. The 

Department deleted the MHCC draft 

recommendation for inclusion of bay 

window installation under the proposed 

Model Installation Standards. 

Commenters wrote that under 

§ 3285.801(f), a manufacturer would 

need to furnish installation instructions 

for a hinged roof so that the installer 

would know the necessary elements of 

field installation. Bay windows are 

similar, as they would be a ‘‘ship-loose’’

item. In the opinion of these 

commenters, as long as the home is 

designed properly for the product 

attachment, the manufacturer provides 

DAPIA-approved installation 

instructions, and the installer can follow 

those instructions, bay windows should 

be covered under the Model Installation 

Standards and not the Manufactured 

Home Construction and Safety 

Standards. 

HUD Response: HUD does not agree 

with these commenters, and will 

continue to treat the site completion of 

bay windows as construction that is 

subject to the Manufactured Home 

Construction and Safety Standards. A 

detailed discussion of the comments 

and HUD’s position on hinged roofs and 

eaves can be found above under the 

analysis of public comments for 

§ 3285.801. 


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Comment: Every other national design 

standard and code for residential 

construction, including NFPA 225 and 

NFPA 501, references more recent 

editions of ASCE 7 Standard for 

Minimum Design Loads for Buildings 

and Other Structures. The Model 

Installation Standards must also do this 

to achieve equivalent protection to 

manufactured homes and manufactured 

home residents. 

HUD Response: The ASCE 7–88 

standard is currently referenced in the 

HUD Manufactured Home Construction 

and Safety Standards and is used as the 

basis for establishing the design load 

requirements for the construction 

standards that are referenced in these 

installation standards. Accordingly, it is 

not necessary to again reference the 

ASCE 7 standards in these installation 

standards. 

III. Section-by-Section Revisions—

Changes to Proposed Rule 

In response to the public comments 

and subsequent reevaluation by HUD, 

the following is a summary by subpart 

of the section-by-section revisions being 

made to the proposed rule for the Model 

Installation Standards, 24 CFR part 

3285, published in the Federal Register 

on April 26, 2005. An overall editorial 

change made throughout the rule was to 

move all tables and figures within a 

section to the end of the section. This 

change will promote ease of reference 

and will simplify the process of 

amending the rule, as may be necessary, 

in the future. 

Subpart A—General 

Section 3285.1(a) in the final rule 

makes clear that the manufacturers’

installation instructions required by 

§ 3285.2, including any specific 

operation or assembly therein, are 

deemed to comply with the Model 

Installation Standards, provided they 

meet or exceed the minimum 

requirements in the installation 

standards and do not take the home out 

of compliance with the MHCSS. 

Further, clarifications are also being 

added to § 3285.1(a) with regard to the 

applicability of the installation 

standards to the work necessary to join 

sections of a multi-section home 

together. Specifically, work associated 

with the connection of exterior lights, 

ceiling-hung light fixtures, or fans, as 

identified in subpart I, is considered 

installation. This section is also being 

modified to clarify that work associated 

with hinged roofs and eaves in 

§ 3285.801 and other work done on-site 

and not specifically identified in this 

part as close-up is not covered by the 

installation standards and, as such, is 

subject to the MHCSS and Procedural 

and Enforcement Regulations. 

The applicability provisions in 

§ 3285.1(b) were modified to indicate 

that the installation standards are not to 

be construed as relieving manufacturers, 

retailers, or other parties of 

responsibility for compliance with other 

applicable ordinances, codes, 

regulations, and laws. In addition, the 

section was revised to indicate that 

manufactured homes are also subject to 

the requirements of the Manufactured 

Home Installation and Dispute 

Resolution Programs, upon effect. A 

new provision, § 3285.1(c), has been 

included in the final rule that requires 

HUD to seek input from the MHCC 

when considering future revisions to the 

installation standards. (See discussion 

in II, Analysis of Public Comments). 

Paragraph (a) of § 3285.2, 

Manufacturer Installation Instructions, 

is being revised to clarify that the 

installation instructions must include 

all topics covered in the installation 

standards. This paragraph is also being 

revised to require the installer to certify 

that it completed the installation in 

compliance with the manufacturer’s 

instructions or an alternate design (see 

paragraph (c)), prepared by the 

manufacturer or certified by a 

professional engineer or architect, that 

provides a level of protection equivalent 

to or greater than what is required by 

the installation standards. 

A new paragraph § 3285.2(b) is added 

to specify those circumstances when a 

professional engineer or registered 

architect must prepare and certify that 

the manufacturer’s installation 

instructions meet or exceed the Model 

Installation Standards for foundation 

support and anchoring. 

The recommended provisions for 

‘‘variations to manufacturer installation 

instructions’’ in subpart J of the 

proposed rule are being relocated to 

paragraph (c) of § 3285.2 in the final 

rule. This will require installers who 

intend to provide support and 

anchorage that is either different from 

the methods specified in the 

manufacturer’s instructions, or that 

encounter site or other conditions that 

prevent the use of the instructions, to 

first attempt to obtain site-specific 

instructions from the manufacturer or, if 

not available from the manufacturer, to 

obtain a design that has been prepared 

by a professional engineer or architect 

that is consistent with the design and 

the MHCSS. The installer must have the 

professional engineer’s or registered 

architect’s design approved by the 

manufacturer and its DAPIA prior to 

installation. DAPIA approval is 

necessary to enable HUD to enforce 

such modifications to the 

manufacturer’s installation instructions. 

A new paragraph (e) is being added to 

§ 3285.2 in the final rule to require the 

manufacturer to include, as part of its 

instructions, at least one method for 

temporarily storing each section of a 

manufactured home at the 

manufacturer’s facility, retailer’s lot, or 

the home site. 

Section 3285.4 is being revised to 

provide an updated list of the standards 

being incorporated by reference in the 

final rule. (See discussion in ‘‘V. 

Revisions to Standards Incorporated by 

Reference’’ in this preamble.) Reference 

standards have the same force and effect 

as the other Model Installation 

Standards, except that whenever 

reference standards and the Model 

Installation Standards are inconsistent, 

the requirements of the Model 

Installation Standards prevail to the 

extent of the inconsistency. 

Certain definitions have been added 

or modified in § 3285.5 of the final rule 

for terms used in the Model Installation 

Standards. 

A new section, § 3285.6, ‘‘Final 

leveling of the manufactured home,’’ is 

being added to require that a home be 

adequately leveled prior to completion 

of the installation. A manufactured 

home is considered to be adequately 

leveled if there is no more than a 1⁄4- 

inch difference between adjacent pier 

supports, and if the exterior windows 

and doors do not bind and can be 

operated properly. 

Subpart B—Pre-Installation 

Considerations 

The fire separation provisions have 

been relocated from the recommended 

provisions in subpart J of the proposed 

rule and incorporated as part of the 

minimum requirements in subpart B, 

§ 3285.101, as part of the preinstallation considerations. The final 

rule requires that fire separation 

distances be in accordance with NFPA 

501A or the requirements of the LAHJ, 

which could be more or less restrictive 

than NFPA 501A. This will require 

compliance with the fire separation 

distances in NFPA 501A, 2003 edition, 

whenever there are no requirements 

established by the LAHJ. Conversely, 

when the LAHJ has established fire 

separation distance requirements, the 

separation distances need not conform 

to the NFPA 501A provisions. 

Additional requirements were added 

for installation of manufactured homes 

in flood hazard areas in paragraph (d) of 

§ 3285.102 to include provisions for the 

installation of exterior appliances. 

Section 3285.103 is being revised to 

clarify that, prior to the initial 


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installation of a new manufactured 

home, the installer is to verify that the 

design and construction of the 

manufactured home, as indicated on the 

design zone maps provided with the 

home, are suitable for the site location 

where the home is to be installed. In 

addition, to assist the installer in 

verifying the appropriate zone location 

for the specific site, this section is being 

revised by referring to the county and 

local government references that further 

define the wind zone, roof load zone, 

and thermal zone in part 3280. 

Subpart C—Site Preparation 

Section 3285.201 is being revised in 

the final rule to indicate that, after 

removal of organic material, the home 

site must be graded or otherwise 

prepared to ensure adequate drainage. 

A pocket penetrometer is now 

included in the final rule as one of the 

acceptable methods for determining 

bearing capacity and soil classification 

in § 3285.202(d). Furthermore, a new 

paragraph (e) has also been included in 

this section that permits the use of an 

allowable default soil bearing pressure 

of 1,500 psf, unless site-specific 

information requires the use of lower 

soil bearing values. 

The site drainage provisions in 

paragraph (b) of § 3285.203 of the final 

rule have been revised by adding other 

alternatives than site grading to remove 

any water that may collect under the 

home. 

The provisions for gutters and 

downspouts in paragraph (f) of 

§ 3285.203 have been modified in the 

final rule to indicate that manufacturers 

specify in their instructions whether the 

home is suitable for the installation of 

gutters and downspouts. 

The provisions for ground moisture 

control have been revised in paragraph 

(c) of § 3285.204 of the final rule by 

allowing the required vapor retarder to 

be installed around or over footings 

placed at grade and around anchors and 

by requiring any void or tear in the 

vapor retarder to be repaired. 

Subpart D—Foundations 

Section 3285.301(b) of the final rule 

has been revised to also recognize metal 

piers as one of the possible variables to 

the pier and footing specifications and 

configurations in this subpart. 

Section 3285.302 of the final rule has 

been revised to require all manufactured 

homes in flood hazard areas to be 

installed on foundation supports that 

are designed and anchored to prevent 

floatation, collapse, or lateral movement 

of the structure. In addition, 

manufacturers’ instructions must 

indicate whether or not the foundation 

specifications have been designed to 

resist flood loads. 

Tables 1, 2, and 3 to § 3285.303 for 

pier loads have been modified in the 

final rule by removing all references to 

allowable soil bearing pressure and 

footing configurations that were 

previously associated with the tables 

and by deleting Figure C to § 3285.312—

Footing Configuration Layout Designs 

that was referenced in each of the tables. 

Paragraphs (b) and (c) in § 3285.304 of 

the final rule are being modified to be 

consistent with the provisions and notes 

shown in Figures A and B to 

§ 3285.306(b). 

Section 3285.305 has been modified 

in the final rule by requiring a minimum 

of 12′′ of clearance between the main 

chassis frame member and the grade and 

all other areas of the home. 

The maximum height for frame and 

corner piers in § 3285.306(b) and (c) of 

the final rule has been reduced from 80′′ 

to 67′′ to be consistent with the 

maximum heights shown in the tables 

for maximum diagonal tie-down strap 

spacing in Tables 1, 2, and 3 to 

§ 3285.402. Furthermore, mortar is no 

longer required for this range of pier 

heights, unless specified in the 

manufacturer’s instructions and the 

maximum horizontal offset from the top 

to the bottom of the pier is one inch. 

The provisions for elevated homes in 

the proposed rule are no longer needed 

and have been deleted and replaced 

with new paragraph (c) in § 3285.306, 

‘‘All piers over 67 inches high,’’ in the 

final rule. Mortar is not required for 

concrete block piers of this height, 

unless specified by the design. 

A new paragraph (b) has been added 

to § 3285.308 in the final rule that 

requires metal or other manufactured 

piers to be weather-protected against 

deterioration and corrosion with 

protection that is at least equivalent to 

a coating of zinc on steel of at least 0.30 

oz./ft2. 

Footnotes were added to Figures A 

and B to § 3285.310 to require piers to 

be placed on each side of any mating 

wall opening when the opening is 48′′ 

or greater in width and to indicate that 

for roof loads of more than 40 pfs, a 

professional engineer must determine 

the maximum mating wall opening 

permitted without piers or other 

supports. Footnote 3 was also revised in 

both figures to indicate that the 

maximum single stack concrete block 

pier loads cannot exceed 8,000 lbs. 

The requirements for perimeter pier 

supports are modified by adding a new 

paragraph (a)(ii) in § 3285.311 of the 

final rule permitting the use of 

alternative supports in lieu of perimeter 

piers such as outriggers or extra floor 

joists. However, when alternative 

supports are used, the designs must 

consider the additional loads in sizing 

the pier and footing supports under the 

main chassis beam. In addition, for roof 

live loads of 40 psf or greater, paragraph 

(b) of this section requires that a 

professional engineer or architect 

determine the maximum sidewall 

support opening permitted with 

perimeter pier or other supports. 

Footnotes are also modified in the 

final rule to Figures A and B to 

§ 3285.312, ‘‘Typical Blocking Diagrams 

for Single Section Homes and Multiple 

Section Homes,’’ to require piers on 

both sides of exterior sidewall doors, 

patio doors, sliding glass door openings, 

under jamb studs at multiple window 

openings, and other openings of 48′′ or 

greater in width. 

The requirements for footings in 

paragraph (a) and (b) of § 3285.312 of 

the proposed rule are incorporated into 

paragraph (a) of this section in the final 

rule by reducing the minimum 

compressive strength for 4′′ pre-cast 

concrete pads from 4,000 psi to 1,200 

psi; by noting that for 6′′ or greater 

poured-in-place concrete pads, slabs, or 

ribbons, reinforcing steel may be 

required for site-specific conditions; by 

revising the requirements for pressuretreated footings and by changing the 

specification for their pressure 

treatment to a water-borne adhesive, in 

accordance with AWPA Standard U1–

04; by requiring ABS footing pads to be 

certified for use in the soil classification 

at the site; and by adding new 

provisions to allow other types of 

footing materials, provided they are 

listed for such use and meet all other 

applicable provisions of the installation 

standards. 

The provisions for placement of 

footings in freezing climates is being 

relocated from paragraph (c) in the 

proposed rule to paragraph (b) in 

§ 3285.312 of the final rule and is being 

revised to require that footings be 

designed to resist the effects of frost 

heave by one of the methods specified 

in this section. The final rule requires 

that conventional footings be placed 

below the frost line, unless an insulated 

footing or monolithic slab is used. In 

addition, alternatives allowing insulated 

footings or monolithic slabs to be placed 

above and not below the frost line depth 

must be designed by a professional 

engineer or architect, in accordance 

with either acceptable engineering 

practice or SEI/ASCE 32–01, and not 

both, as previously indicated in the 

proposed rule. Furthermore, these 

alternatives are permitted only if all 

relevant site conditions such as soil 

characteristics, site preparation, 


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ventilation, anchorage requirements, 

and insulative properties of the underfloor enclosure are considered. 

Figure C to § 3285.312 in the 

proposed rule has been deleted in the 

final rule, as the footing configuration 

and layouts shown in the figure were 

determined to be non-typical of current 

practices used in installing 

manufactured homes. 

The table for the size and capacity of 

unreinforced cast-in-place footings in 

§ 3285.312(d) is revised by limiting the 

maximum capacity of certain footing 

sizes to 8,000 lbs. and 16,000 lbs., based 

on the maximum pier capacity of single 

or multiple stack concrete block piers. A 

footnote has been added to the table 

indicating that higher design load 

capacities may be permitted if a 

professional engineer or architect 

prepares the design. 

The provisions for permanent 

foundations in § 3285.314 of the 

proposed rule have been deleted in the 

final rule. The requirements for 

permanent foundations can be 

adequately considered and addressed 

under the provisions of the final rule for 

alternative foundation systems, 

including the requirement that such 

designs be prepared by a professional 

engineer or architect. 

Section 3285.315(b) for ramadas in 

the final rule is revised by requiring 

them to be self-supporting, except for 

any weatherproofing connection that is 

made to the home. 

Subpart E—Anchorage Against Wind 

A new paragraph (d) has been added 

to § 3285.401 in the final rule that 

provides the minimum information and 

details that must be included in the 

manufacturers installation instructions 

for anchor type installations necessary 

to secure manufactured homes against 

the wind. 

A new paragraph (a) has been added 

in reorganizing § 3285.402 in the final 

rule to require each ground anchor to be 

provided with installation instructions, 

in accordance with its listing or 

certification, and to be certified for use 

in a classified soil, based on a nationally 

recognized testing protocol. Paragraph 

(a) of § 3285.402 in the proposed rule 

has been renumbered as paragraph (b) 

and has been modified in the final rule 

to require that anchors be installed to 

their full depth and that anchors and 

tie-down straps be protected against 

corrosion at least equivalent to that 

provided by a coating of zinc on steel 

of 0.30 oz./ft2 of surface coated. This 

section now also requires that both the 

working and ultimate load of the ground 

anchors and anchoring equipment be 

determined by a professional engineer 

or registered architect. 

Paragraph (b) of § 3285.402 has been 

renumbered as paragraph (c) in the final 

rule, and paragraph (c)(1) is revised by 

indicating that the spacing for ground 

anchors and straps be no greater than 

the spacing in the Tables 1 through 3 of 

this section, unless designed by a 

professional engineer or registered 

architect. A professional engineer or 

registered architect must also prepare 

the design for any conditions where the 

tables are not applicable, such as for 

higher sidewall conditions, or diagonal 

strap angle-to-ground conditions that 

are below 30 degrees or exceed 60 

degrees, etc. Tables 1 through 3 are also 

revised by limiting the spacing to 

applicable conditions for the diagonal 

strap to between 30 degrees and 60 

degrees to the ground. 

Paragraph (c)(3) is renumbered as 

paragraph (c)(2) and the provisions of 

(ii) in the proposed rule are separated 

into (ii) and new (iii) of this paragraph 

in the final rule. In addition, (iii) is also 

revised to require the correct size and 

type of stabilizer plate to be installed, if 

required by the listing, and by allowing 

the use of ABS stabilizer plates when 

they are listed and certified for such 

use. 

Paragraph (c)(2) on longitudinal 

anchoring is renumbered as paragraph 

(c)(3) and is revised in the final rule by 

providing a new Figure C as an example 

of one acceptable method that may be 

used for longitudinal anchoring and for 

attaching the longitudinal strap to the 

ground anchor and main chassis beam 

of the home. 

Section 3285.404 of the final rule is 

revised to indicate that ground anchors 

must be installed below the frost line, 

unless the foundation system is frostprotected to resist the effects of frost 

heave, in accordance with acceptable 

engineering practice, § 3280.306 of the 

MHCSS, and § 3285.312 of these 

installation standards. 

The requirements for anchoring 

manufactured homes in flood hazard 

areas in § 3285.406 of the proposed rule 

have been revised by relocating the 

requirements to § 3285.102 in the final 

rule and by adding reference to the 

relocated section in § 3285.406 of the 

final rule. 

Subpart F—Optional Features 

The requirements for optional 

appliances in § 3285.503 of the final 

rule are being revised as follows: 

Paragraph (a)(1)(i) requires site-installed 

air conditioning equipment to be sized 

to ‘‘meet’’ the home’s heat gain rather 

than ‘‘closely match’’ the heat gain, as 

indicated in the proposed rule; 

paragraph (a)(1)(iii)(A) is revised by 

requiring A-coil air conditioning type 

units to be installed in accordance with 

the appliance manufacturer’s 

instructions and be compatible and 

listed for use with the furnace installed 

in the home; a new paragraph (a)(3)(ii) 

is added for evaporative coolers that are 

not roof-mounted to be installed in 

accordance with the more restrictive 

provisions of the listing or the appliance 

manufacturer’s instructions; and a new 

paragraph (c) is added for completion of 

appliance venting systems for 

compatibility with the requirements of 

the MHCSS. In addition, the provisions 

for outside appliances and air inlets in 

flood hazard areas have been relocated 

to § 3285.102(d)(2). 

The weather protection and pressure 

treatment requirements for metal and 

wood skirting are further clarified in 

§ 3285.504(a) and (c) of the final rule. 

The provisions for ventilation 

openings are revised in § 3285.505(d) of 

the final rule by requiring them to be 

corrosion- and weather-resistant and to 

be designed to resist the entry of 

rodents. In addition, in areas subject to 

freezing, the openings must be of the 

adjustable type permitting them to be 

open or closed, depending on the 

climatic conditions. 

Section 3285.505(f) of the final rule is 

being revised to require any surface 

water runoff from the furnace, air 

conditioning, or water heater drain to be 

directed away from the home or 

collected by other methods identified in 

§ 3285.503. 

Subpart G—Ductwork and Plumbing 

and Fuel Supply Systems 

Section 3285.606(c)(1) of the final rule 

is modified to require that the 

mandatory shutoff valve installed be 

identified, accessible, and installed 

between the water supply and inlet. 

The test pressure requirements for gas 

piping systems in § 3285.605(a) of the 

final rule are revised to be consistent 

with the testing provisions for fuel 

piping systems in the MHCSS. 

Paragraph (a) of § 3285.606 of the final 

rule for ductwork connections is revised 

to require all crossover connections to 

the main duct system to be sealed to 

prevent air leakage. Paragraph (e) is also 

revised to require the crossover duct to 

be supported by straps spaced at a 

maximum distance of 4 feet or as 

otherwise permitted by the installation 

instructions. In addition, for flexible 

type ducts, the straps must be at least 

1⁄2′′ wider than the metal spirals 

encasing the duct and be installed so 

that the duct cannot slip between any 

two spirals. 


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Subpart H—Electrical Systems and 

Equipment 

Paragraph (d) of § 3285.702 is revised 

in the final rule to require that a ceiling 

paddle fan be connected to a junction 

box that is listed and marked for ceiling 

fan application, in accordance with the 

requirements of the NEC, 2005 edition. 

The testing requirements in paragraph 

(e) of § 3285.702 are also being modified 

in the final rule to clarify that the 

electrical system must be inspected and 

tested at the site after completion of all 

electrical wiring and connections, 

lighting, and installation of any ceiling 

fans. 

Subpart I—Exterior and Interior Closeup 

Section 3285.801(d) is revised in the 

final rule to require any holes that are 

made in the roofing to be made 

weatherproof and sealed with an 

exterior sealant that is suitable for use 

with the roofing material. 

The requirements for hinged roofs and 

eaves in § 3285.801(f) of the final rule 

are revised to require compliance with 

all requirements of the MHCSS (24 CFR 

3280) and the Manufactured Home 

Procedural and Enforcement 

Regulations (24 CFR 3282). While this 

work is often completed during the setup of the home, it is not considered to 

be installation, but work associated with 

the construction of the home and 

therefore subject to HUD’s MHCSS. As 

such, certain hinged roofs continue to 

be subject, as appropriate, to the 

provisions of Alternative Construction 

in § 3282.14 and the provisions of the 

future rulemaking for on-site 

construction, upon effect. Currently, 

manufactured homes with hinged roofs 

are not subject to these special 

requirements, if the homes are: (1) 

Designed to be located in Wind Zone I, 

(2) the pitch of the hinged roof is less 

than 7/12, and (3) fuel burning 

appliance flue penetrations are not 

above the hinge. However, even for the 

above-described conditions, 

manufacturers are still responsible for 

providing instructions on how to 

complete each hinged roof or eave 

construction in accordance with the 

requirements of the MHCSS. 

Section 3285.802(c) of the final rule is 

revised by clarifying that no gaps are 

permitted between structural elements 

along the mate-line of multi-section 

homes upon completion of the exterior 

close-up. However, the final rule does 

permit minor gaps, up to one inch, prior 

to completion of the exterior close-up 

provided: (1) All such gaps are closed 

before completion, (2) the home sections 

are in contact with each other, (3) the 

mating gasket is providing a proper seal, 

and (4) all such gaps are shimmed and 

connected to the structural element(s) 

with properly sized fasteners. 

Section 3285.804 of the final rule is 

revised by requiring missing insulation 

to be replaced prior to making any 

bottom board repairs, any splits or tears 

to be resealed with tape or patches in 

accordance with the installation 

instructions, and by requiring all edges 

of repaired areas to be taped or 

otherwise sealed. 

Subpart J—Optional Information for 

Installation Instructions 

This subpart of the final rule has been 

re-titled and reorganized to include 

recommendations that may be provided 

as part of the installation instructions. 

The final rule also clarifies in a new 

section, § 3285.907, that any other 

information manufacturers may want to 

provide in their instructions that is not 

specifically addressed in this subpart 

must be consistent with the Model 

Installation Standards and not take the 

home out of conformance with the 

MHCSS. 

The general provisions in § 3285.901 

are revised by also including ‘‘access’’ to 

the site as another area that is outside 

of HUD’s authority and that may be 

governed by the LAHJ. 

Provisions addressing variations to 

manufacturers installation instructions 

in the proposed rule have been 

relocated to § 3285.2(b) in the final rule. 

Section 3285.902 of the final rule is 

revised by recommending that the 

installation instructions include 

recommendations that the home should 

not be moved to the site until: (1) The 

LAHJ is informed, (2) the site is 

prepared in accordance with Subpart C 

of the Model Installation Standards, and 

(3) utilities are available as required by 

the LAHJ. In addition, recommended 

provisions for: (1) Positioning the home 

in the proposed rule have been 

relocated to § 3285.6 of the final rule, (2) 

fire separation distances in the proposed 

rule have been relocated to § 3285.101 

in the final rule, and (3) requirements 

for drainage structures have been 

relocated under paragraph (b) of this 

section in the final rule. 

Encroachment and setback distances 

in the proposed rule have been 

relocated under § 3285.903, ‘‘Permits, 

alterations, and on-site structures,’’ in 

the final rule. In addition, paragraph (c) 

of this section in the final rule is 

modified to indicate that each accessory 

building and structure is to be designed 

to support its own live and dead loads, 

unless the structure is attached to the 

manufactured home and otherwise 

included in the installation instructions 

or designed by a professional engineer 

or registered architect. 

The provisions for utility service 

connections are renumbered as 

§ 3285.904 in the final rule, and 

recommendations for procedures to be 

used prior to making utility service 

connections are revised in the final rule, 

as follows: (1) Where both utility 

services and the LAHJ are available, 

both should be consulted prior to 

making any connections of the 

manufactured home to the utilities; (2) 

where no LAHJ exists and utility 

services are available, the utility should 

be consulted before connecting the 

manufactured home to any utility 

service; and (3) in rural areas where no 

LAHJ or utility services are available, a 

professional should be consulted prior 

to making any system connections. 

The provisions for heating oil systems 

are renumbered as § 3285.905 in the 

final rule and the recommendations for 

the installation instructions are revised 

in the final rule to indicate that homes 

with these systems and storage tanks be 

tested to in accordance with NFPA 31, 

Standard for Installation of Oil Burning 

Equipment, 2001 edition, or, if 

applicable, to the more stringent 

requirements of the LAHJ. 

The provisions for telephone and 

cable TV in the proposed rule are 

renumbered as § 3285.906 in the final 

rule and it is recommended that the 

installation instructions explain that 

these services should be installed in 

accordance with the requirements of the 

LAHJ or the NEC, NFPA No. 70–2005. 

IV. Revisions to Standards 

Incorporated by Reference (Reference 

Standards) 

The following is a list of the standards 

incorporated by reference that is being 

revised from those in the proposed rule 

by this final rule. 

Added: 

AWPA—American Wood-Preservers’

Association, P.O. Box 388, Selma, 

Alabama 36702. 

AWPA M4–02, Standard for the Care of 

Preservative-Treated Wood Products, 

2002. 

AWPA U1–04, Use Category System; 

User Specification for Treated Wood, 

2004. 

APA—The Engineered Wood 

Association, 7011 South 19th Street, 

Tacoma, Washington 98411, 

telephone number (253) 565–6600, fax 

number (253) 565–7265. 

PS1–95, Construction and Industrial 

Plywood (with typical APA 

trademarks), 1995 edition. 

NFPA Publications—National Fire 

Protection Association, 1 


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Batterymarch Park, Quincy, 

Massachusetts 02169–7471. 

NFPA No. 70, National Electrical Code, 

2005. 

U.L.—Underwriters Laboratories, 333 

Pfingsten Road, Northbrook, Illinois 

60062. 

UL 181A, Standard for Safety Closure 

Systems for Use with Rigid Air Ducts 

and Air Connectors, 1994, with 1998 

revisions. 

UL 181B, Standard for Safety Closure 

Systems for Use with Flexible Air 

Ducts and Air Connectors, 1995, with 

1998 revisions. 

Removed: 

AWPA—American Wood-Preservers’

Association, P.O. Box 388, Selma, 

Alabama 36702. 

AWPA C2, Standard for the Preservative 

Treatment of Lumber, Timber, Bridge 

Ties and Mine Ties, by Pressure 

Processes, 2001. 

AWPA C9, Plywood—Preservative 

Treatment by Pressure Processes, 

2000. 

V. Findings and Certifications 

Regulatory Planning and Review 

The Office of Management and Budget 

(OMB) reviewed this rule under 

Executive Order 12866 (entitled 

‘‘Regulatory Planning and Review’’). 

OMB determined that this rule is a 

‘‘significant regulatory action,’’ as 

defined in section 3(f) of the order 

(although not an economically 

significant regulatory action, as 

provided under section 3(f)(1) of the 

order). The docket file is available for 

public inspection between 8 a.m. and 5 

p.m. weekdays in the Office of the Rules 

Docket Clerk, Office of General Counsel, 

Department of Housing and Urban 

Development, 451 Seventh Street, SW., 

Room 10276, Washington, DC. Due to 

security measures at the HUD 

Headquarters building, please schedule 

an appointment to review the docket file 

by calling the Regulations Division at 

(202) 708–3055 (this is not a toll-free 

number). Hearing- or speech-impaired 

individuals may access this number 

through TTY by calling the toll-free 

Federal Information Relay Service at 1–

(800) 877–8339. 

Paperwork Reduction Act 

The information collection 

requirements contained in this rule are 

currently approved by OMB under 

section 3504(h) of the Paperwork 

Reduction Act of 1980 (44 U.S.C. 3501–

3520) and assigned OMB Control 

Number 2502–0253. An agency may not 

conduct or sponsor, and a person is not 

required to respond to a collection of 

information, unless the collection 

displays a currently valid control 

number. 

Unfunded Mandates Reform Act 

Title II of the Unfunded Mandates 

Reform Act of 1995 (2 U.S.C. 1531–

1538) (UMRA) establishes requirements 

for federal agencies to assess the effects 

of their regulatory actions on state, 

local, and tribal governments, and on 

the private sector. This rule does not 

impose any federal mandate on any 

state, local, or tribal government, or on 

the private sector, within the meaning of 

UMRA. 

Environmental Review 

A Finding of No Significant Impact 

(FONSI) with respect to the 

environment was made at the proposed 

rule stage, in accordance with HUD 

regulations at 24 CFR part 50, which 

implement section 102(2)(C) of the 

National Environmental Policy Act of 

1969 (42 U.S.C. 4332(2)(C)) and remains 

applicable to this final rule. The FONSI 

is available for public inspection during 

regular business hours in the Office of 

the Rules Docket Clerk, Office of 

General Counsel, Department of 

Housing and Urban Development, 451 

Seventh Street, SW., Room 10276, 

Washington, DC 20410. Due to security 

measures at the HUD Headquarters 

building, please schedule an 

appointment to review the docket file by 

calling the Regulations Division at (202) 

708–3055 (this is not a toll-free 

number). Hearing- or speech-impaired 

individuals may access this number 

through TTY by calling the toll-free 

Federal Information Relay Service at 

(800) 877–8339. 

Executive Order 13132, Federalism 

Executive Order 13132 (entitled 

‘‘Federalism’’) prohibits, to the extent 

practicable and permitted by law, an 

agency from promulgating a regulation 

that has Federalism implications and 

either imposes substantial direct 

compliance costs on state and local 

governments and is not required by 

statute, or preempts state law, unless the 

relevant requirements of section 6 of the 

Executive Order are met. This rule does 

not have Federalism implications and 

does not impose substantial direct 

compliance costs on state and local 

governments or preempt state law 

within the meaning of the Executive 

Order. 

HUD is required by statute to 

establish Model Manufactured Home 

Installation Standards through the 

National Manufactured Housing 

Construction and Safety Standards Act 

of 1974 (42 U.S.C. 5401–5426). 

However, in accordance with the 

language of the Act and as set forth in 

§ 3285.1 of this rule, these Model 

Installation Standards are not 

preemptive, but rather establish 

minimum levels of protection to 

residents of manufactured homes. 

The Model Installation Standards, 

without the implementing regulations to 

be developed for the federal installation 

program, establish requirements for 

installation instructions, but do not 

have an impact on state-based 

installation programs and standards. 

These minimum requirements do not 

affect governmental relationships or 

distribution of power. This rule does not 

establish any responsibilities for states 

and localities, but rather establishes 

minimum requirements to be used by 

home manufacturers in the design of 

manufactured home installation 

instructions. Therefore, HUD has 

determined that the Model Installation 

Standards, if adopted, have no 

federalism implications that warrant the 

preparation of a Federalism Assessment, 

in accordance with Executive Order 

13132. 

Regulatory Flexibility Act 

The Regulatory Flexibility Act (5 

U.S.C. 601 et seq.) requires that a 

regulation that has a significant 

economic impact on a substantial 

number of small entities, small 

businesses, or small organizations 

include an initial regulatory flexibility 

analysis describing the regulation’s 

impact on small entities. Such an 

analysis need not be undertaken if the 

agency has certified that the regulation 

will not have a significant economic 

impact on a substantial number of small 

entities. 

HUD has conducted a material and 

labor cost impact analysis for this rule. 

The completed cost analysis determines 

the cost difference between a typical 

installation conforming to the Model 

Installation Standards from an 

installation completed in accordance 

with current manufacturer installation 

instructions. A typical installation is 

defined by the traditional installation 

method consisting of concrete footings, 

masonry piers, and ground anchors. The 

cost difference was found to vary 

slightly depending upon whether the 

home is a single-section or multi-section 

home. HUD has determined the 

following recommended Installation 

Standards would potentially affect the 

cost of the installation of manufactured 

homes over and above the installation 

costs currently incurred using the 

manufacturer’s installation instructions: 

1. Manufacturer review and revision of its 

manufactured home installation manual 

(§ 3285.2). 


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2. Proper drainage slope away from the 

home (§ 3285.203). 

3. Vapor barrier lap at joints (§ 3285.204). 

4. Ensure proper configuration for concrete 

piers (§ 3285.304). 

5. Ensure proper orientation and location 

of pier supports (§ 3285.306). 

6. Certification and testing of ground 

anchors (§ 3285.402). 

7. Water line shut-off valve (§ 3285.603). 

8. Crossover duct collar hardware and 

fasteners (§ 3285.606). 

The cost impact for a single-section 

home is determined to be about $133 

per home and the cost impact for a 

multi-section home is determined to be 

about $151 per home. Current 

manufactured home production is about 

135,000 homes, consisting of about 

40,500 single-section homes and 94,500 

multi-section homes. The combined 

average cost impact is determined to be 

approximately $145.60 per home 

multiplied by a total of 135,000 homes 

produced in a year; this totals about 

$19.6 million annually. 

Based on a current installation cost of 

about $5,000 for a single-wide home, the 

$133 increase represents an increase of 

about 2.7 percent from the current cost 

of installing a single section home. 

Similarly, the current cost of installing 

a multi-section home is about $8,000. 

Therefore, the cost impact of $151 per 

multi-section home represents an 

increase of about 1.9 percent from the 

current cost. These estimated costs and 

cost impacts do not represent a 

significant economic effect on either an 

industry-wide or per-home basis. These 

estimates are further limited in the final 

rule by recognition of the 

manufacturer’s installation instructions, 

including specific methods for 

performing an operation or assembly, as 

being deemed to comply with the Model 

Installation Standards and, as a result, 

may avoid the need to possibly change 

certain practices in existing instructions 

in order to comply with the installation 

standards. 

This small increase in total cost 

associated with this rule would not 

impose a significant burden for a small 

business. The rule would regulate 

establishments primarily engaged in 

making manufactured homes (NAICS 

32991) and the mobile home set-up and 

tie-down establishments (installers) 

included within the definition of all 

other special trade contractors (NAICS 

23599). Of the 222 firms included under 

the NAICS 32991 definition, 198 are 

small manufacturers that fall below the 

small business threshold of 500 

employees. Of the 31,320 firms included 

under NAICS 23599 definition, only 53 

firms exceed the small business 

threshold of 500 employees and none of 

these are primarily mobile home set-up 

and tie-down establishments. The rule 

thus would affect a substantial number 

of small entities. However, the home 

manufacturers would only be subject to 

an associated labor cost necessary to 

revise its instructions, and the home 

installer would be subject to increased 

labor and material costs that would be 

passed through to the end user 

(manufactured home purchaser). 

Moreover, because the great majority of 

manufacturers and all installers are 

considered small entities, there would 

not be any disproportional impact on 

small entities. Therefore, although this 

rule would affect a substantial number 

of small entities, it would not have a 

significant economic impact on them. 

Further, the benefits to the consumer 

and public from the increase in cost 

may be summarized as follows: 

• Under the new standards, 

substantial damage due to moisture 

infiltration will be mitigated, thereby 

avoiding repair and remedy that could 

cost the homeowner hundreds to 

thousands of dollars, depending upon 

the severity of the damage. 

• The new standard will require 

proper configuration, location, and 

construction of piers to increase 

occupant and public safety. 

• The new provisions for certification 

and testing of ground anchors has the 

potential to prevent occupant injury or 

death resulting from ground anchor 

installations that utilize insufficient or 

under-performing ground anchors. 

• The new requirement for a water 

line shut-off valve provides both safety 

and convenience for the occupant. The 

absence of a water line shut-off valve 

can potentially cause hundreds to 

thousands of dollars in water damage. 

• The new standard will require 

galvanized screws and galvanized 

collars to secure site-installed ducting to 

factory provided connectors, thereby 

providing for a durable and weatherprotected connection that can withstand 

the elements without premature failure 

and replacement. Replacement of the 

connectors and fastenings per home can 

total about $30 per home, including $10 

in materials cost and $20 in labor costs. 

• The requirement for manufacturer 

review and revision of installation 

instructions and subsequent third-party 

approval of the installation instructions 

will provide a positive impact on 

occupant and general public safety. 

The Secretary, in accordance with the 

Regulatory Flexibility Act (5 U.S.C. 

605(b)), has reviewed and approved this 

rule and in so doing certifies that the 

rule would not have a significant 

economic impact on a substantial 

number of small entities. The rule does 

not provide an exemption for small 

entities. This rule does not establish any 

responsibilities for installers; rather, it 

establishes model requirements used by 

manufacturers in the design of 

manufactured home installation 

instructions. 

Catalogue of Federal Domestic 

Assistance 

The Catalogue of Federal Domestic 

Assistance number is 14.171. 

List of Subjects 

24 CFR Part 3280 

Construction, Housing standards, 

Incorporation by reference, 

Manufactured homes, Safety. 

24 CFR Part 3285 

Housing standards, Incorporation by 

reference, Installation, Manufactured 

homes. 

■ Accordingly, HUD amends 24 CFR 

part 3280 and adds 24 CFR part 3285 to 

read as follows: 

PART 3280—MANUFACTURED HOME 

CONSTRUCTION AND SAFETY 

STANDARDS 

■ 1. The authority citation for 24 CFR 

part 3280 continues to read as follows: 

Authority: 42 U.S.C. 3535(d), 5403, and 

5424. 

■ 2. In § 3280.302, add the definitions of 

anchor assembly, foundation system, 

and support system in alphabetical 

order and revise the definitions of 

anchoring equipment, anchoring 

system, diagonal tie, ground anchor, and 

stabilizing devices to read as follows: 

§ 3280.302 Definitions. 

* * * * * 

Anchor assembly means any device or 

other means designed to transfer home 

anchoring loads to the ground. 

Anchoring equipment means ties, 

straps, cables, turnbuckles, chains, and 

other approved components, including 

tensioning devices that are used to 

secure a manufactured home to anchor 

assemblies. 

Anchoring system means a 

combination of anchoring equipment 

and anchor assemblies that will, when 

properly designed and installed, resist 

the uplift, overturning, and lateral forces 

on the manufactured home and on its 

support and foundation system. 

Diagonal tie means a tie intended to 

resist horizontal or shear forces, but 

which may resist vertical, uplift, and 

overturning forces. 

* * * * * 

Foundation system means a system of 

support that is capable of transferring all 


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design loads to the ground, including 

elements of the support system as 

defined in this section, or a site-built 

permanent foundation that meets the 

requirements of 24 CFR 3282.12. 

Ground anchor means a specific 

anchoring assembly device designed to 

transfer home anchoring loads to the 

ground. 

* * * * * 

Stabilizing devices means all 

components of the anchoring and 

support systems, such as piers, footings, 

ties, anchoring equipment, anchoring 

assemblies, or any other equipment, 

materials, and methods of construction 

that support and secure the 

manufactured home to the ground. 

* * * * * 

Support system means any pilings, 

columns, footings, piers, foundation 

walls, shims, and any combination 

thereof that, when properly installed, 

support the manufactured home. 

■ 3. In § 3280.306, revise paragraphs 

(b)(2)(iii) and (iv) to read as follows: 

§ 3280.306 Windstorm protection. 

* * * * * 

(b) * * * 

(2) * * * 

(iii) That ground anchors are to be 

embedded below the frost line, unless 

the foundation system is frost-protected 

in accordance with §§ 3285.312(b) and 

3285.404 of the Model Manufactured 

Home Installation Standards in this 

chapter. 

(iv) That ground anchors must be 

installed to their full depth, and 

stabilizer plates must be installed in 

accordance with the ground anchor 

listing or certification to provide 

required resistance to overturning and 

sliding. 

* * * * * 

■ 4. In Chapter XX, add part 3285 to 

read as follows: 

PART 3285—MODEL MANUFACTURED 

HOME INSTALLATION STANDARDS 

Subpart A—General 

Sec. 

3285.1 Administration. 

3285.2 Manufacturer installation 

instructions. 

3285.3 Alterations during initial 

installation. 

3285.4 Incorporation by reference (IBR). 

3285.5 Definitions. 

3285.6 Final leveling of manufactured 

home. 

Subpart B—Pre-Installation Considerations 

3285.101 Fire separation. 

3285.102 Installation of manufactured 

homes in flood hazard areas. 

3285.103 Site suitability with design zone 

maps. 

3285.104 Moving manufactured home to 

location. 

3285.105 Permits, other alterations, and onsite structures. 

Subpart C—Site Preparation 

3285.201 Soil conditions. 

3285.202 Soil classifications and bearing 

capacity. 

3285.203 Site drainage. 

3285.204 Ground moisture control. 

Subpart D—Foundations 

3285.301 General. 

3285.302 Flood hazard areas. 

3285.303 Piers. 

3285.304 Pier configuration. 

3285.305 Clearance under homes. 

3285.306 Design procedures for concrete 

block piers. 

3285.307 Perimeter support piers. 

3285.308 Manufactured piers. 

3285.309 [Reserved] 

3285.310 Pier location and spacing. 

3285.311 Required perimeter supports. 

3285.312 Footings. 

3285.313 Combination systems. 

3285.314 [Reserved] 

3285.315 Special snow load conditions. 

Subpart E—Anchorage Against Wind 

3285.401 Anchoring instructions. 

3285.402 Ground anchor installations. 

3285.403 Sidewall, over-the-roof, mate-line, 

and shear wall straps. 

3285.404 Severe climatic conditions. 

3285.405 Severe wind zones. 

3285.406 Flood hazard areas. 

Subpart F—Optional Features 

3285.501 Home installation manual 

supplements. 

3285.502 Expanding rooms. 

3285.503 Optional appliances. 

3285.504 Skirting. 

3285.505 Crawlspace ventilation. 

Subpart G—Ductwork and Plumbing and 

Fuel Supply Systems 

3285.601 Field assembly. 

3285.602 Utility connections. 

3285.603 Water supply. 

3285.604 Drainage system. 

3285.605 Fuel supply system. 

3285.606 Ductwork connections. 

Subpart H—Electrical Systems and 

Equipment 

3285.701 Electrical crossovers. 

3285.702 Miscellaneous lights and fixtures. 

3285.703 Smoke alarms. 

3285.704 Telephone and cable TV. 

Subpart I—Exterior and Interior Close-Up 

3285.801 Exterior close-up. 

3285.802 Structural interconnection of 

multi-section homes. 

3285.803 Interior close-up. 

3285.804 Bottom board repair. 

Subpart J—Optional Information for 

Manufacturer’s Installation Instructions 

3285.901 General. 

3285.902 Moving manufactured home to 

location. 

3285.903 Permits, alterations, and on-site 

structures. 

3285.904 Utility systems connection. 

3285.905 Heating oil systems. 

3285.906 Telephone and cable TV. 

3285.907 Manufacturer additions to 

installation instructions. 

Authority: 42 U.S.C. 3535(d), 5403, 5404, 

and 5424. 

Subpart A—General 

§ 3285.1 Administration. 

(a) Scope. These Model Installation 

Standards provide minimum 

requirements for the initial installation 

of new manufactured homes, in 

accordance with section 605 of the Act 

(42 U.S.C. 5404). The Model Installation 

Standards are one component of the 

Manufactured Home Installation 

Program in Part 3286 of this chapter, 

upon effect, and serve as the basis for 

developing the manufacturers’

installation instructions required by 

§ 3285.2 of this subpart. The 

manufacturer’s installation instructions, 

including specific methods for 

performing a specific operation or 

assembly, will be deemed to comply 

with these Model Installation Standards, 

provided they meet or exceed the 

minimum requirements of these Model 

Installation Standards and do not take 

the home out of compliance with the 

Manufactured Home Construction and 

Safety Standards (24 CFR part 3280). 

Work necessary to join all sections of a 

multi-section home specifically 

identified in Subparts G, H, and I of this 

part, or work associated with connecting 

exterior lights, chain-hung light fixtures, 

or ceiling-suspended fans, as 

specifically identified in Subpart I, is 

not considered assembly or construction 

of the home, although the design of 

those elements of a manufactured home 

must comply with the Manufactured 

Home Construction and Safety 

Standards (MHCSS). However, work 

associated with the completion of 

hinged roofs and eaves in § 3285.801 

and other work done on-site and not 

specifically identified in this part as 

close-up is considered construction and 

assembly and is subject to the 

requirements of the Manufactured Home 

Construction and Safety Standards (24 

CFR part 3280) and the Manufactured 

Home Procedural and Enforcement 

Regulations (24 CFR part 3282). 

(1) States that choose to operate an 

installation program for manufactured 

homes in lieu of the federal program 

must implement installation standards 

that provide protection to its residents 

that equals or exceeds the protection 

provided by these Model Installation 

Standards. 

(2) In states that do not choose to 

operate their own installation program 


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for manufactured homes, these Model 

Installation Standards serve as the 

minimum standards for manufactured 

home installations. 

(b) Applicability. The standards set 

forth herein have been established to 

accomplish certain basic objectives and 

are not to be construed as relieving 

manufacturers, retailers, installers, or 

other parties of responsibility for 

compliance with other applicable 

ordinances, codes, regulations, and 

laws. The manufactured homes covered 

by this standard must comply with 

requirements of the U.S. Department of 

Housing and Urban Development’s 

(HUD) MHCSS Program, as set forth in 

24 CFR part 3280, Manufactured Home 

Construction and Safety Standards, and 

24 CFR part 3282, Manufactured Home 

Procedural and Enforcement 

Regulations, as well as with, upon 

effect, the Manufactured Home 

Installation Program, 24 CFR part 3286, 

and the Dispute Resolution Program, 24 

CFR part 3288. The requirements of this 

part do not apply to homes installed on 

site-built permanent foundations when 

the manufacturer certifies the home in 

accordance with § 3282.12 of this 

chapter. 

(c) Consultation with the 

Manufactured Housing Consensus 

Committee. The Secretary will seek 

input from the Manufactured Housing 

Consensus Committee (MHCC) when 

revising the installation standards in 

this part 3285. Before publication of a 

proposed rule to revise the installation 

standards, the Secretary will provide the 

MHCC with a 120-day opportunity to 

comment on such revision. The MHCC 

may send to the Secretary any of the 

MHCC’s own recommendations to adopt 

new installation standards or to modify 

or repeal any of the installation 

standards in this part. Along with each 

recommendation, the MHCC must set 

forth pertinent data and arguments in 

support of the action sought. The 

Secretary will either: 

(1) Accept or modify the 

recommendation and publish it for 

public comment in accordance with 

section 553 of the Administrative 

Procedure Act (5 U.S.C. 553), along with 

an explanation of the reasons for any 

such modification; or 

(2) Reject the recommendation 

entirely, and provide to the MHCC a 

written explanation of the reasons for 

the rejection. 

§ 3285.2 Manufacturer installation 

instructions. 

(a) Instructions required. A 

manufacturer must provide with each 

new manufactured home, installation 

designs and instructions that have been 

approved by the Secretary or DAPIA. 

The approved installation instructions 

must include all topics covered in the 

Model Installation Standards for the 

installation of manufactured homes. 

These installation instructions and any 

variations thereto that are prepared to 

comply with paragraph (c) of this 

section must provide protection to 

residents of the manufactured homes 

that equals or exceeds the protection 

provided by these Model Installation 

Standards and must not take the 

manufactured home out of compliance 

with the MHCSS. These instructions 

must insure that each home will be 

supported and anchored in a manner 

that is capable of meeting or exceeding 

the design loads required by the 

MHCSS. 

(b) Professional engineer or registered 

architect certification. A professional 

engineer or registered architect must 

prepare and certify that the 

manufacturer’s installation instructions 

meet or exceed the Model Installation 

Standards for foundation support and 

anchoring whenever: 

(1) The manufacturer’s installation 

instructions do not conform in their 

entirety to the minimum requirements 

or tables or their conditions for 

foundation support and anchoring of 

this Standard; or 

(2) An alternative foundation system 

or anchoring system is employed, 

including designs for basements and 

perimeter support foundation systems, 

whether or not it is included in the 

installation instructions; or 

(3) Materials such as metal piers or 

alternatives to concrete footing materials 

are required by the installation 

instructions; or 

(4) Foundation support and anchoring 

systems are designed for use in areas 

subject to freezing or for use in areas 

subject to flood damage or high seismic 

risk; or 

(5) Foundations support and 

anchoring systems are designed to be 

used in special snow load conditions or 

in severe wind design areas; or 

(6) Site conditions do not allow the 

use of the manufacturer’s installation 

instructions; or 

(7) There are any other circumstances 

in which the manufacturer’s installation 

instructions would not permit the home 

to be installed in conformance with the 

Installation Standards or the MHCSS. 

(c) Variations to installation 

instructions. 

(1) Before an installer provides 

support or anchorage that are different 

than those methods specified in the 

manufacturer’s installation instructions, 

or when the installer encounters site or 

other conditions (such as areas that are 

subject to flood damage or high seismic 

risk) that prevent the use of the 

instructions, the installer must: 

(i) First attempt to obtain DAPIAapproved designs and instructions 

prepared by the manufacturer; or 

(ii) If designs and instructions are not 

available from the manufacturer, obtain 

an alternate design prepared and 

certified by a registered professional 

engineer or registered architect for the 

support and anchorage of the 

manufactured home that is consistent 

with the manufactured home design, 

conforms to the requirements of the 

MHCSS, and has been approved by the 

manufacturer and the DAPIA. 

(2) The manufacturer’s installation 

instructions must include an 

explanation of the requirement in 

paragraph (c)(1) of this section. 

(d) Installer certification. In making 

the certification of the installation 

required under part 3286 of this chapter, 

upon effect, an installer must certify 

that it completed the installation in 

compliance with either the 

manufacturer’s instructions or with an 

alternate installation design and 

instructions that have been prepared by 

the manufacturer or prepared in 

compliance with paragraph (c) of this 

section. 

(e) Temporary storage. The 

installation instructions must provide at 

least one method for temporarily 

supporting each transportable section of 

a manufactured home, to prevent 

structural and other damage to the 

structure, when those section(s) are 

temporarily sited at the manufacturer’s 

facility, retailer’s lot, or the home site. 

§ 3285.3 Alterations during initial 

installation. 

Additions, modifications, or 

replacement or removal of any 

equipment that affects the installation of 

the home made by the manufacturer, 

retailer, or installer prior to completion 

of the installation by an installer must 

equal or exceed the protections and 

requirements of these Model Installation 

Standards, the MHCSS (24 CFR part 

3280) and the Manufactured Home 

Procedural and Enforcement 

Regulations (24 CFR part 3282). An 

alteration, as defined in § 3282.7 of this 

chapter, must not affect the ability of the 

basic manufactured home to comply 

with the MHCSS, and the alteration 

must not impose additional loads to the 

manufactured home or its foundation, 

unless the alteration is included in the 

manufacturer’s DAPIA-approved 

designs and installation instructions, or 

is designed by a registered professional 

engineer or architect consistent with the 

manufacturer’s design and that 


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conforms to the requirements of the 

MHCSS. 

§ 3285.4 Incorporation by reference (IBR). 

(a) The materials listed in this section 

are incorporated by reference in the 

corresponding sections noted. These 

incorporations by reference were 

approved by the Director of the Federal 

Register, in accordance with 5 U.S.C. 

552(a) and 1 CFR part 51. The materials 

are available for purchase at the 

corresponding addresses noted below, 

and all are available for inspection at 

the Office of Manufactured Housing 

Programs, U.S. Department of Housing 

and Urban Development, 451 Seventh 

Street, SW., Room 9164, Washington, 

DC 20410; or the National Archives and 

Records Administration (NARA). For 

information on the availability of this 

material at NARA, call (202) 741–6030, 

or go to: http://www.archives.gov/ 

federal-register/cfr/ibr-locations.html. 

(b) The materials listed below are 

available for purchase from the Air 

Conditioning Contractors of America 

(ACCA), 2800 Shirlington Road, Suite 

300, Arlington, Virginia 22206. 

(1) ACCA Manual J, Residential Load 

Calculation, 8th Edition, IBR approved 

for § 3285.503(a)(1)(i)(A). 

(2) [Reserved] 

(c) The materials listed below are 

available for purchase from APA—The 

Engineered Wood Association, 7011 

South 19th Street, Tacoma, Washington 

98411, telephone number (253) 565–

6600, fax number (253) 565–7265. 

(1) PS1–95, Construction and 

Industrial Plywood (with typical APA 

trademarks), 1995 edition, IBR approved 

for § 3285.312(a)(2)(i). 

(2) [Reserved] 

(d) The materials listed below are 

available for purchase from American 

Society of Heating, Refrigerating and Air 

Conditioning Engineers (ASHRAE), 

1791 Tullie Circle, NE., Atlanta, Georgia 

30329–2305. 

(1) ASHRAE Handbook of 

Fundamentals, 1997 Inch-Pound 

Edition, IBR approved for 

§ 3285.503(a)(1)(i)(A). 

(2) [Reserved] 

(e) The materials listed below are 

available for purchase from American 

Society for Testing and Materials 

(ASTM), 100 Barr Harbor Drive, West 

Conshohocken, Pennsylvania 19428–

2959. 

(1) ASTM C 90–02a, Standard 

Specification for Loadbearing Concrete 

Masonry Units, 2002, IBR approved for 

§ 3285.312(a)(1)(i). 

(2) ASTM D 1586–99, Standard Test 

Method for Penetration Test and SplitBarrel Sampling of Soils, 1999, IBR 

approved for the table at § 3285.202(c). 

(3) ASTM D 2487–00, Standard 

Practice for Classification of Soils for 

Engineering Purposes (Unified Soil 

Classification System), 2000, IBR 

approved for the table at § 3285.202(c). 

(4) ASTM D 2488–00, Standard 

Practice for Description and 

Identification of Soils (Visual-Manual 

Procedure), 2000, IBR approved for the 

table at § 3285.202(c). 

(5) ASTM D 3953–97, Standard 

Specification for Strapping, Flat Steel 

and Seals, 1997, IBR approved for 

§ 3285.402(b)(2) and Note 10 to Table 1 

to § 3285.402. 

(f) The materials listed below are 

available for purchase from American 

Wood-Preservers’ Association (AWPA), 

P.O. Box 388, Selma, Alabama 36702. 

(1) AWPA M4–02, Standard for the 

Care of Preservative-Treated Wood 

Products, 2002, IBR approved for 

§ 3285.312(a)(2)(iii). 

(2) AWPA U1–04, Use Category 

System; User Specification for Treated 

Wood, 2004, IBR approved for 

§§ 3285.303(b)(1), 3285.312(a)(2)(ii), and 

3285.504(c). 

(g) The materials listed below are 

available for purchase from the Federal 

Emergency Management Administration 

(FEMA), 500 C Street, SW., Washington, 

DC 20472. 

(1) FEMA 85/September 1985, 

Manufactured Home Installation in 

Flood Hazard Areas, 1985, IBR 

approved for § 3285.102(d)(3). 

(2) [Reserved] 

(h) The materials listed below are 

available for purchase from the National 

Fire Protection Association (NFPA), 1 

Batterymarch Park, Quincy, 

Massachusetts 02169–7471. 

(1) NFPA 31, Standard for the 

Installation of Oil Burning Equipment, 

2001 edition, IBR approved for 

§§ 3285.905(a) and 3285.905(d)(3). 

(2) NFPA 70, National Electrical Code, 

2005 edition, IBR approved for 

§§ 3285.702(e)(1) and 3285.906. 

(3) NFPA 501A, Standard for Fire 

Safety Criteria for Manufactured Home 

Installations, Sites, and Communities, 

2003 edition, IBR approved for 

§ 3285.101. 

(i) The materials listed below are 

available for purchase from the 

Structural Engineering Institute/ 

American Society of Civil Engineers 

(SEI/ASCE), 1801 Alexander Bell Drive, 

Reston, Virginia 20191. 

(1) SEI/ASCE 32–01, Design and 

Construction of Frost-Protected Shallow 

Foundations, 2001, IBR approved for 

§§ 3285.312(b)(2)(ii) and 

3285.312(b)(3)(ii). 

(2) [Reserved] 

(j) The materials listed below are 

available for purchase from 

Underwriters Laboratories (UL), 333 

Pfingsten Road, Northbrook, Illinois 

60062. 

(1) UL 181A, Closure Systems for Use 

With Rigid Air Ducts and Air 

Connectors, 1994, with 1998 revisions, 

IBR approved for § 3285.606(a). 

(2) UL 181B, Closure Systems for Use 

With Flexible Air Ducts and Air 

Connectors, 1995, with 1998 revisions, 

IBR approved for § 3285.606(a). 

§ 3285.5 Definitions. 

The definitions contained in this 

section apply to the terms used in these 

Model Installation Standards. Where 

terms are not included, common usage 

of the terms applies. The definitions are 

as follows: 

Act. The National Manufactured 

Housing Construction and Safety 

Standards Act of 1974, 42 U.S.C. 5401–

5426. 

Anchor assembly. Any device or other 

means designed to transfer home 

anchoring loads to the ground. 

Anchoring equipment. Ties, straps, 

cables, turnbuckles, chains, and other 

approved components, including 

tensioning devices that are used to 

secure a manufactured home to anchor 

assemblies. 

Anchoring system. A combination of 

anchoring equipment and anchor 

assemblies that will, when properly 

designed and installed, resist the uplift, 

overturning, and lateral forces on the 

manufactured home and on its support 

and foundation system. 

Approved. When used in connection 

with any material, appliance or 

construction, means complying with the 

requirements of the Department of 

Housing and Urban Development. 

Arid region. An area subject to 15 

inches or less of annual rainfall. 

Base flood. The flood having a one 

percent chance of being equaled or 

exceeded in any given year. 

Base flood elevation (BFE). The 

elevation of the base flood, including 

wave height, relative to the datum 

specified on a LAHJ’s flood hazard map. 

Comfort cooling certificate. A 

certificate permanently affixed to an 

interior surface of the home specifying 

the factory design and preparations for 

air conditioning the manufactured 

home. 

Crossovers. Utility interconnections in 

multi-section homes that are located 

where the sections are joined. Crossover 

connections include heating and cooling 

ducts, electrical circuits, water pipes, 

drain plumbing, and gas lines. 

Design Approval Primary Inspection 

Agency (DAPIA). A state or private 

organization that has been accepted by 

the Secretary in accordance with the 


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requirements of Part 3282, Subpart H of 

this chapter, which evaluates and 

approves or disapproves manufactured 

home designs and quality control 

procedures. 

Diagonal tie. A tie intended to resist 

horizontal or shear forces, but which 

may resist vertical, uplift, and 

overturning forces. 

Flood hazard area. The greater of 

either: The special flood hazard area 

shown on the flood insurance rate map; 

or the area subject to flooding during the 

design flood and shown on a LAHJ’s 

flood hazard map, or otherwise legally 

designated. 

Flood hazard map. A map delineating 

the flood hazard area and adopted by a 

LAHJ. 

Footing. That portion of the support 

system that transmits loads directly to 

the soil. 

Foundation system. A system of 

support that is capable of transferring all 

design loads to the ground, including 

elements of the support system, as 

defined in this section, or a site-built 

permanent foundation that meets the 

requirements of 24 CFR 3282.12. 

Ground anchor. A specific anchoring 

assembly device designed to transfer 

home anchoring loads to the ground. 

Installation instructions. DAPIAapproved instructions provided by the 

home manufacturer that accompany 

each new manufactured home and 

detail the home manufacturer 

requirements for support and anchoring 

systems, and other work completed at 

the installation site to comply with 

these Model Installation Standards and 

the Manufactured Home Construction 

and Safety Standards in 24 CFR part 

3280. 

Installation standards. Reasonable 

specifications for the installation of a 

new manufactured home, at the place of 

occupancy, to ensure proper siting; the 

joining of all sections of the home; and 

the installation of stabilization, support, 

or anchoring systems. 

Labeled. A label, symbol, or other 

identifying mark of a nationally 

recognized testing laboratory, inspection 

agency, or other organization concerned 

with product evaluation that maintains 

periodic inspection of production of 

labeled equipment or materials, and by 

whose labeling is indicated compliance 

with nationally recognized standards or 

tests to determine suitable usage in a 

specified manner. 

Listed or certified. Included in a list 

published by a nationally recognized 

testing laboratory, inspection agency, or 

other organization concerned with 

product evaluation that maintains 

periodic inspection of production of 

listed equipment or materials, and 

whose listing states either that the 

equipment or material meets nationally 

recognized standards or has been tested 

and found suitable for use in a specified 

manner. 

Local authority having jurisdiction 

(LAHJ). The state, city, county, city and 

county, municipality, utility, or 

organization that has local 

responsibilities and requirements that 

must be complied with during the 

installation of a manufactured home. 

Lowest floor. The floor of the lowest 

enclosed area of a manufactured home. 

An unfinished or flood-resistant 

enclosure, used solely for vehicle 

parking, home access, or limited storage, 

must not be considered the lowest floor, 

provided the enclosed area is not 

constructed so as to render the home in 

violation of the flood-related provisions 

of this standard. 

Manufactured home. A structure, 

transportable in one or more sections, 

which in the traveling mode is 8 body 

feet or more in width or 40 body feet or 

more in length, or which when erected 

on site is 320 or more square feet, and 

which is built on a permanent chassis 

and designed to be used as a dwelling 

with or without a permanent foundation 

when connected to the required 

utilities, and includes the plumbing, 

heating, air-conditioning, and electrical 

systems contained in the structure. This 

term includes all structures that meet 

the above requirements, except the size 

requirements and with respect to which 

the manufacturer voluntarily files a 

certification, pursuant to § 3282.13 of 

this chapter, and complies with the 

MHCSS set forth in part 3280 of this 

chapter. The term does not include any 

self-propelled recreational vehicle. 

Calculations used to determine the 

number of square feet in a structure will 

include the total of square feet for each 

transportable section comprising the 

completed structure and will be based 

on the structure’s exterior dimensions 

measured at the largest horizontal 

projections when erected on-site. These 

dimensions will include all expandable 

rooms, cabinets, and other projections 

containing interior space, but do not 

include bay windows. Nothing in this 

definition should be interpreted to mean 

that a manufactured home necessarily 

meets the requirements of HUD’s 

Minimum Property Standards (HUD 

Handbook 4900.1) or that it is 

automatically eligible for financing 

under 12 U.S.C. 1709(b) certification. 

Manufactured Home Construction 

and Safety Standards or MHCSS. The 

Manufactured Home Construction and 

Safety Standards established in part 

3280 of this chapter, pursuant to section 

604 of the Act, 42 U.S.C. 5403. 

Manufactured home gas supply 

connector. A listed connector designed 

for connecting the manufactured home 

to the gas supply source. 

Manufactured home site. A 

designated parcel of land designed for 

the installation of one manufactured 

home for the exclusive use of the 

occupants of the home. 

Manufactured Housing Consensus 

Committee or MHCC. The consensus 

committee established pursuant to 

section 604(a)(3) of the Act, 42 U.S.C. 

5403(a)(3). 

Model Installation Standards. The 

installation standards established in 

part 3285 of this chapter, pursuant to 

section 605 of the Act, 42 U.S.C. 5404. 

Pier. That portion of the support 

system between the footing and the 

manufactured home, exclusive of shims. 

Types of piers include, but are not 

limited to: Manufactured steel stands; 

pressure-treated wood; manufactured 

concrete stands; concrete blocks; and 

portions of foundation walls. 

Ramada. Any freestanding roof or 

shade structure, installed or erected 

above a manufactured home or any 

portion thereof. 

Secretary. The Secretary of Housing 

and Urban Development, or an official 

of HUD delegated the authority of the 

Secretary with respect to the Act. 

Skirting. A weather-resistant material 

used to enclose the perimeter, under the 

living area of the home, from the bottom 

of the manufactured home to grade. 

Stabilizing devices. All components of 

the anchoring and support systems, 

such as piers, footings, ties, anchoring 

equipment, anchoring assemblies, or 

any other equipment, materials, and 

methods of construction, that support 

and secure the manufactured home to 

the ground. 

State. Each of the several states, the 

District of Columbia, the 

Commonwealth of Puerto Rico, Guam, 

the Virgin Islands, and American 

Samoa. 

Support system. Pilings, columns, 

footings, piers, foundation walls, shims, 

and any combination thereof that, when 

properly installed, support the 

manufactured home. 

Tie. Straps, cable, or securing devices 

used to connect the manufactured home 

to anchoring assemblies. 

Ultimate load. The absolute 

maximum magnitude of load that a 

component or system can sustain, 

limited only by failure. 

Utility connection. The connection of 

the manufactured home to utilities that 

include, but are not limited to, 

electricity, water, sewer, gas, or fuel oil. 

Vertical tie. A tie intended to resist 

uplifting and overturning forces. 


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Wind zone. The areas designated on 

the Basic Wind Zone Map, as further 

defined in § 3280.305(c) of the 

Manufactured Home Construction and 

Safety Standards in this chapter, which 

delineate the wind design load 

requirements. 

Working load. The maximum 

recommended load that may be exerted 

on a component or system determined 

by dividing the ultimate load of a 

component or system by an appropriate 

factor of safety. 

§ 3285.6 Final leveling of manufactured 

home. 

The manufactured home must be 

adequately leveled prior to completion 

of the installation, so that the home’s 

performance will not be adversely 

affected. The home will be considered 

adequately leveled if there is no more 

than 1⁄4 inch difference between 

adjacent pier supports (frame or 

perimeter) and the exterior doors and 

windows of the home do not bind and 

can be properly operated. 

Subpart B—Pre-Installation 

Considerations 

§ 3285.101 Fire separation. 

Fire separation distances must be in 

accordance with the requirements of 

Chapter 6 of NFPA 501A, 2003 edition 

(incorporated by reference, see § 3285.4) 

or the requirements of the LAHJ. The 

installation instructions must clearly 

indicate this requirement in a separate 

section and must caution installers to 

take into account any local requirements 

on fire separation. 

§ 3285.102 Installation of manufactured 

homes in flood hazard areas. 

(a) Definitions. Except to the extent 

otherwise defined in Subpart A, the 

terms used in this subpart are as defined 

in 44 CFR 59.1 of the National Flood 

Insurance Program (NFIP) regulations. 

(b) Applicability. The provisions of 

this section apply to the initial 

installation of new manufactured homes 

located wholly or partly within a flood 

hazard area. 

(c) Pre-installation considerations. 

Prior to the initial installation of a new 

manufactured home, the installer is 

responsible for determining whether the 

manufactured home site lies wholly or 

partly within a special flood hazard area 

as shown on the LAHJ’s Flood Insurance 

Rate Map, Flood Boundary and 

Floodway Map, or Flood Hazard 

Boundary Map, or if no LAHJ, in 

accordance with NFIP regulations. If so 

located, and before an installation 

method is agreed upon, the map and 

supporting studies adopted by the LAHJ 

must be used to determine the flood 

hazard zone and base flood elevation at 

the site. 

(d) General elevation and foundation 

requirements. 

(1) Methods and practices. 

Manufactured homes located wholly or 

partly within special flood hazard areas 

must be installed on foundations 

engineered to incorporate methods and 

practices that minimize flood damage 

during the base flood, in accordance 

with the requirements of the LAHJ, 44 

CFR 60.3(a) through (e), and other 

provisions of 44 CFR referenced by 

those paragraphs. 

(2) Outside appliances. 

(i) Appliances installed on the 

manufactured home site in flood hazard 

areas must be anchored and elevated to 

or above the same elevation as the 

lowest elevation of the lowest floor of 

the home. 

(ii) Appliance air inlets and exhausts 

in flood hazard areas must be located at 

or above the same elevation as the 

lowest elevation of the lowest floor of 

the home. 

(3) Related guidance. Refer to FEMA 

85/September 1985, Manufactured 

Home Installation in Flood Hazard 

Areas, 1985 (incorporated by reference, 

see § 3285.4). 

§ 3285.103 Site suitability with design zone 

maps. 

Prior to the initial installation of a 

new manufactured home and as part of 

making the certification of the 

installation required under part 3286, 

upon effect, the installer is to verify that 

the design and construction of the 

manufactured home, as indicated on the 

design zone maps provided with the 

home, are suitable for the site location 

where the home is to be installed. The 

design zone maps are those identified in 

part 3280 of this chapter. 

(a) Wind zone. Manufactured homes 

must not be installed in a wind zone 

that exceeds the design wind loads for 

which the home has been designed, as 

evidenced by the wind zone indicated 

on the home’s data plate and as further 

defined by counties or local 

governments within affected states, as 

applicable, in § 3280.305(c)(2) of the 

Manufactured Home Construction and 

Safety Standards in this chapter. 

(b) Roof load zone. Manufactured 

homes must not be located in a roof load 

zone that exceeds the design roof load 

for which the home has been designed, 

as evidenced by the roof load zone 

indicated on the home’s data plate and 

as further defined by counties or local 

governments within affected states, as 

applicable, in § 3280.305(c)(3) of the 

Manufactured Home Construction and 

Safety Standards in this chapter. Refer 

to § 3285.315 for Special Snow Load 

Conditions. 

(c) Thermal zone. Manufactured 

homes must not be installed in a 

thermal zone that exceeds the thermal 

zone for which the home has been 

designed, as evidenced by the thermal 

zone indicated on the heating/cooling 

certificate and insulation zone map and 

as further defined by counties or local 

governments within affected states, as 

applicable, in § 3280.504(b)(5) of the 

Manufactured Home Construction and 

Safety Standards in this chapter. The 

manufacturer may provide the heating/ 

cooling information and insulation zone 

map on the home’s data plate. 

§ 3285.104 Moving manufactured home to 

location. 

Refer to § 3285.902 for considerations 

related to moving the manufactured 

home to the site of installation. 

§ 3285.105 Permits, other alterations, and 

on-site structures. 

Refer to § 3285.903 for considerations 

related to permitting, other alterations, 

and on-site structures. 

Subpart C—Site Preparation 

§ 3285.201 Soil conditions. 

To help prevent settling or sagging, 

the foundation must be constructed on 

firm, undisturbed soil or fill compacted 

to at least 90 percent of its maximum 

relative density. All organic material 

such as grass, roots, twigs, and wood 

scraps must be removed in areas where 

footings are to be placed. After removal 

of organic material, the home site must 

be graded or otherwise prepared to 

ensure adequate drainage, in accordance 

with § 3285.203. 

§ 3285.202 Soil classifications and bearing 

capacity. 

The soil classification and bearing 

capacity of the soil must be determined 

before the foundation is constructed and 

anchored. The soil classification and 

bearing capacity must be determined by 

one or more of the following methods, 

unless the soil bearing capacity is 

established as permitted in paragraph (f) 

of this section: 

(a) Soil tests. Soil tests that are in 

accordance with generally accepted 

engineering practice; or 

(b) Soil records. Soil records of the 

applicable LAHJ; or 

(c) Soil classifications and bearing 

capacities. If the soil class or bearing 

capacity cannot be determined by test or 

soil records, but its type can be 

identified, the soil classification, 

allowable pressures, and torque values 

shown in Table to § 3285.202 may be 

used. 


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(d) A pocket penetrometer; or 

(e) In lieu of determining the soil 

bearing capacity by use of the methods 

shown in the table, an allowable 

pressure of 1,500 psf may be used, 

unless the site-specific information 

requires the use of lower values based 

on soil classification and type. 

(f) If the soil appears to be composed 

of peat, organic clays, or uncompacted 

fill, or appears to have unusual 

conditions, a registered professional 

geologist, registered professional 

engineer, or registered architect must 

determine the soil classification and 

maximum allowable soil bearing 

capacity. 

TABLE TO § 3285.202 

Soil classification 

Soil description Allowable soil bearing pressure (psf) 1

Blow count 

ASTM D 

1586–99 

Torque probe 3

value 4

(inch-pounds)- Classification number 

ASTM D 2487–00 or 

D 2488–00 

(incorporated by reference, see 

§ 3285.4) 

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

2 ................ GW, GP, SW, SP, 

GM, SM.

Sandy gravel and gravel; very than dense 

and/or cemented sands; course gravel/ 

cobbles; preloaded silts, clays and coral.

2000 ......................... 40+ More than 550. 

3 ................ GC, SC, ML, CL ...... Sand; silty sand; clayey sand; silty gravel; 

medium dense course sands; sandy 

gravel; and very stiff silt, sand clays.

1500 ......................... 24–39 351–550. 

4A .............. CG, MH 2 ................. Loose to medium dense sands; firm to 

stiff clays and silts; alluvial fills.

1000 ......................... 18–23 276–350. 

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: 

1The values provided in this table have not been adjusted for overburden pressure, embedment depth, water table height, or settlement problems. 2For 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. 3The 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. 4The 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. 

(a) Purpose. Drainage must be 

provided to direct surface water away 

from the home to protect against erosion 

of foundation supports and to prevent 

water build-up under the home, as 

shown in Figure to § 3285.203. 

(b) The home site must be graded as 

shown in Figure to § 3285.203, or other 

methods, such as a drain tile and 

automatic sump pump system, must be 

provided to remove any water that may 

collect under the home. 

(c) All drainage must be diverted 

away from the home and must slope a 

minimum of one-half inch per foot away 

from the foundation for the first ten feet. 

Where property lines, walls, slopes, or 

other physical conditions prohibit this 

slope, the site must be provided with 

drains or swales or otherwise graded to 

drain water away from the structure, as 

shown in Figure to § 3285.203. 

(d) Sloped site considerations. The 

home, where sited, must be protected 

from surface runoff from the 

surrounding area. 

(e) Refer to § 3285.902 regarding the 

use of drainage structures to drain 

surface runoff. 

(f) Gutters and downspouts. 

Manufacturers must specify in their 

installation instructions whether the 

home is suitable for the installation of 

gutters and downspouts. If suitable, the 

installation instructions must indicate 

that when gutters and downspouts are 

installed, the runoff must be directed 

away from the home. 

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§ 3285.204 Ground moisture control. 

(a) Vapor retarder. If the space under 

the home is to be enclosed with skirting 

or other materials, a vapor retarder must 

be installed to cover the ground under 

the home, unless the home is installed 

in an arid region with dry soil 

conditions. 

(b) Vapor retarder material. A 

minimum of six mil polyethylene 

sheeting or its equivalent must be used. 

(c) Proper installation. (1) The entire 

area under the home must be covered 

with the vapor retarder, as noted in 

§ 3285.204(a), except for areas under 

open porches, decks, and recessed 

entries. Joints in the vapor retarder must 

be overlapped at least 12 inches. 

(2) The vapor retarder may be placed 

directly beneath footings, or otherwise 

installed around or over footings placed 

at grade, and around anchors or other 

obstructions. 

(3) Any voids or tears in the vapor 

retarder must be repaired. At least one 

repair method must be provided in the 

manufacturer’s installation instructions. 

Subpart D—Foundations 

§ 3285.301 General. 

(a) Foundations for manufactured 

home installations must be designed 

and constructed in accordance with this 

subpart and must be based on site 

conditions, home design features, and 

the loads the home was designed to 

withstand, as shown on the home’s data 

plate. 

(b) Foundation systems that are not 

pier and footing type configurations 

may be used when verified by 

engineering data and designed in 

accordance with § 3285.301(d), 

consistent with the design loads of the 

MHCSS. Pier and footing specifications 

that are different than those provided in 

this subpart, such as block size, metal 

piers, section width, loads, and spacing, 

may be used when verified by 

engineering data that comply with 

§§ 3285.301(c) and (d) and are capable 

of resisting all design loads of the 

MHCSS. 

(c) All foundation details, plans, and 

test data must be designed and certified 

by a registered professional engineer or 

registered architect, and must not take 

the home out of compliance with the 

MHCSS. (See 3285.2) 

(d) Alternative foundation systems or 

designs are permitted in accordance 

with either of the following: 

(1) Systems or designs must be 

manufactured and installed in 

accordance with their listings by a 

nationally recognized testing agency, 

based on a nationally recognized testing 

protocol; or 

(2) System designs must be prepared 

by a professional engineer or a 

registered architect or tested and 

certified by a professional engineer or 

registered architect in accordance with 

acceptable engineering practice and 

must be manufactured and installed so 

as not to take the home out of 

compliance with the Manufactured 

Home Construction and Safety 

Standards (part 3280 of this chapter). 

§ 3285.302 Flood hazard areas. 

In flood hazard areas, foundations, 

anchorings, and support systems must 

be capable of resisting loads associated 

with design flood and wind events or 

combined wind and flood events, and 

homes must be installed on foundation 

supports that are designed and anchored 

to prevent floatation, collapse, or lateral 

movement of the structure. 

Manufacturer’s installation instructions 

must indicate whether: 

(a) The foundation specifications have 

been designed for flood-resistant 

considerations, and, if so, the conditions 

of applicability for velocities, depths, or 

wave action; or 

(b) The foundation specifications are 

not designed to address flood loads. 

§ 3285.303 Piers. 

(a) General. The piers used must be 

capable of transmitting the vertical live 

and dead loads to the footings or 

foundation. 

(b) Acceptable piers—materials 

specification. 

(1) Piers are permitted to be concrete 

blocks; pressure-treated wood with a 

water borne preservative, in accordance 

with AWPA Standard U1–04 

(incorporated by reference, see § 3285.4) 

for Use Category 4B ground contact 

applications; or adjustable metal or 

concrete piers. 

(2) Manufactured piers must be listed 

or labeled for the required vertical load 

capacity, and, where required by design, 

for the appropriate horizontal load 

capacity. 

(c) Design requirements. 

(1) Load-bearing capacity. The load 

bearing capacity for each pier must be 

designed to include consideration for 

the dimensions of the home, the design 

dead and live loads, the spacing of the 

piers, and the way the piers are used to 

support the home. 

(2) Center beam/mating wall support 

must be required for multi-section 

homes and designs must be consistent 

with Tables 2 and 3 to § 3285.303 and 

Figures A, B, and C to § 3285.310. 

(d) Pier loads. 

(1) Design support configurations for 

the pier loads, pier spacing, and roof 

live loads must be in accordance with 

Tables 1, 2, and 3 to § 3285.303 and the 

MHCSS. Other pier designs are 

permitted in accordance with the 

provisions of this subpart. 

(2) Manufactured piers must be rated 

at least to the loads required to safely 

support the dead and live loads, as 

required by § 3285.301, and the 

installation instructions for those piers 

must be consistent with Tables 1, 2, and 

3 to this section. 

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

Pier spacing Roof live load 

(psf) Location Load (lbs.) 

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 

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

Pier spacing Roof live load 

(psf) Location Load (lbs.) 

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

Notes:

1. See Table to § 3285.312 for cast-in-place 

footing design by using the noted loads. 

2. Table 1 is based on the following design 

assumptions: maximum 16 ft. nominal 

section width (15 ft. actual width), 12’’ eave, 

10’’ I-beam size, 300 lbs. pier dead load, 10 

psf roof dead load, 6 psf floor dead load, 35 

plf wall dead load, and 10 plf chassis dead 

load. 

3. Interpolation for other pier spacing is 

permitted. 

4. The pier spacing and loads shown in the 

above table do not consider flood or seismic 

loads and are not intended for use in flood 

or seismic hazard areas. In those areas, the 

foundation support system is to be designed 

by a professional engineer or architect. 

5. See Table to § 3285.312 for sizing of 

footings. 

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

Maximum pier spacing Roof live load 

(psf) Location Load (lbs.) 

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 

Notes:

1. See Table to § 3285.312 for cast-in-place 

footing design by using the noted loads. 

2. Mating wall perimeter piers and footings 

only required under full height mating walls 

supporting roof loads. Refer to Figures A and 

B to § 3285.310. 

3. Table 2 is based on the following design 

assumptions: maximum 16 ft. nominal 

section width (15 ft. actual width), 12’’ eave, 

10’’ I-beam size, 300 lbs. pier dead load, 10 

psf roof dead load, 6 psf floor dead load, 35 

plf wall dead load, and 10 plf chassis dead 

load. 


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4. Interpolation for other pier spacing is 

permitted. 

5. The pier spacing and loads shown in the 

above table do not consider flood or seismic 

loads and are not intended for use in flood 

or seismic hazard areas. In those areas, the 

foundation support system is to be designed 

by a professional engineer or architect. 

6. See Table to § 3285.312 for sizing of 

footings. 

TABLE 3 TO § 3285.303—RIDGE BEAM

SPAN FOOTING CAPACITY

Mating wall 

opening (ft) 

Roof live load 

(psf) 

Pier and footing load (lbs.) 

20 1,200 

5 ................ 30 1,600 

40 1,900 

20 2,300 

10 .............. 30 3,100 

40 3,800 

20 3,500 

15 .............. 30 4,700 

40 5,800 

20 4,700 

20 .............. 30 6,200 

40 7,500 

20 5,800 

25 .............. 30 7,800 

40 9,700 

20 7,000 

30 .............. 30 9,300 

40 11,600 

20 8,100 

35 .............. 30 10,900 

40 13,600 

Notes:

1. See Table to § 3285.312 for cast-in-place 

footing design by using the noted loads. 

2. Table 3 is based on the following design 

assumptions: maximum 16 ft. nominal 

section width (15 ft. actual width), 10′′ Ibeam size, 300 lbs. pier dead load, 10 psf roof 

dead load, 6 psf floor dead load, 35 plf wall 

dead load, and 10 plf chassis dead load. 

3. Loads listed are maximum column loads 

for each section of the manufactured home. 

4. Interpolation for maximum allowable 

pier and column loads is permitted for mateline openings between those shown in the 

table. 

5. The pier spacing and loads shown in the 

above table do not consider flood or seismic 

loads and are not intended for use in flood 

or seismic hazard areas. In those areas, the 

foundation support system must be designed 

by a professional engineer or registered 

architect. 

6. See Table to § 3285.312 for sizing of 

footings. 

§ 3285.304 Pier configuration. 

(a) Concrete blocks. Installation 

instructions for concrete block piers 

must be developed in accordance with 

the following provisions and must be 

consistent with Figures A and B to 

§ 3285.306. 

(1) Load-bearing (not decorative) 

concrete blocks must have nominal 

dimensions of at least 8 inches × 8 

inches × 16 inches; 

(2) The concrete blocks must be 

stacked with their hollow cells aligned 

vertically; and 

(3) When piers are constructed of 

blocks stacked side-by-side, each layer 

must be at right angles to the preceding 

one, as shown in Figure B to § 3285.306. 

(b) Caps. (1) Structural loads must be 

evenly distributed across capped-hollow 

block piers, as shown in Figures A and 

B to § 3285.306. 

(2) Caps must be solid concrete or 

masonry at least 4 inches in nominal 

thickness, or hardboard lumber at least 

2 inches nominal in thickness; or be 

corrosion-protected minimum one-half 

inch thick steel; or be of other listed 

materials. 

(3) All caps must be of the same 

length and width as the piers on which 

they rest. 

(4) When split caps are used on 

double-stacked blocks, the caps must be 

installed with the long dimension across 

the joint in the blocks below. 

(c) Gaps. Any gaps that occur during 

installation between the bottom of the 

main chassis beam and foundation 

support system must be filled by: 

(1) Nominal 4 inch × 6 inch × 1 inch 

shims to level the home and fill any 

gaps between the base of the main 

chassis beam and the top of the pier cap; 

(2) Shims must be used in pairs, as 

shown in Figures A and B to § 3285.306, 

and must be driven in tightly so that 

they do not occupy more than one inch 

of vertical height; and 

(3) Hardwood plates no thicker than 

2 inches nominal in thickness or 2 inch 

or 4 inch nominal concrete block must 

be used to fill in any remaining vertical 

gaps. 

(d) Manufactured pier heights. 

Manufactured pier heights must be 

selected so that the adjustable risers do 

not extend more than 2 inches when 

finally positioned. 

§ 3285.305 Clearance under homes. 

A minimum clearance of 12 inches 

must be maintained between the lowest 

member of the main frame (I-beam or 

channel beam) and the grade under all 

areas of the home. 

§ 3285.306 Design procedures for concrete 

block piers. 

(a) Frame piers less than 36 inches 

high. 

(1) Frame piers less than 36 inches 

high are permitted to be constructed of 

single, open, or closed-cell concrete 

blocks, 8 inches ‘‘ 8 inches ‘‘ 16 inches, 

when the design capacity of the block is 

not exceeded. 

(2) The frame piers must be installed 

so that the long sides are at right angles 

to the supported I-beam, as shown in 

Figure A to this section. 

(3) The concrete blocks must be 

stacked with their hollow cells aligned 

vertically and must be positioned at 

right angles to the footings. 

(4) Horizontal offsets from the top to 

the bottom of the pier must not exceed 

one-half inch. 

(5) Mortar is not required, unless 

specified in the installation instructions 

or required by a registered professional 

engineer or registered architect. 

(b) Frame piers 36 inches to 67 inches 

high and corner piers. 

(1) All frame piers between 36 inches 

and 67 inches high and all corner piers 

over three blocks high must be 

constructed out of double, interlocked 

concrete blocks, as shown in Figure B to 

this section, when the design capacity of 

the block is not exceeded. Mortar is not 

required for concrete block piers, unless 

otherwise specified in the installation 

instructions or required by a 

professional engineer or registered 

architect. 

(2) Horizontal offsets from the top to 

the bottom of the pier must not exceed 

one inch. 

(c) All piers over 67 inches high. Piers 

over 67 inches high must be designed by 

a registered professional engineer or 

registered architect, in accordance with 

acceptable engineering practice. Mortar 

is not required for concrete block piers, 

unless otherwise specified in the 

manufacturer installation instructions or 

by the design. 

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§ 3285.307 Perimeter support piers. 

(a) Piers required at mate-line 

supports, perimeter piers, and piers at 

exterior wall openings are permitted to 

be constructed of single open-cell or 

closed-cell concrete blocks, with 

nominal dimensions of 8 inches × 8 

inches × 16 inches, to a maximum 

height of 54 inches, as shown in Figure 

A to this section, when the design 

capacity of the block is not exceeded. 

(b) Piers used for perimeter support 

must be installed with the long 

dimension parallel to the perimeter rail. 

§ 3285.308 Manufactured piers. 

(a) Manufactured piers must be listed 

and labeled and installed to the pier 

manufacturer’s installation instructions. 

See § 3285.303(d)(2) for additional 

requirements. 

(b) Metal or other manufactured piers 

must be provided with protection 

against weather deterioration and 

corrosion at least equivalent to that 

provided by a coating of zinc on steel 

of .30 oz./ft.2 of surface coated. 

§ 3285.309 [Reserved] 

§ 3285.310 Pier location and spacing. 

(a) The location and spacing of piers 

depends upon the dimensions of the 

home, the live and dead loads, the type 

of construction (single-or multi-section), 

I-beam size, soil bearing capacity, 

footing size, and such other factors as 

the location of doors or other openings. 

(b) Mate-line and column pier 

supports must be in accordance with 

this subpart and consistent with Figures 

A through C to this section, unless the 

pier support and footing configuration is 

designed by a registered professional 

engineer or registered architect. 

(c) Piers supporting the frame must be 

no more than 24 inches from both ends 

and not more than 120 inches center to 

center under the main rails. 

(d) Pier support locations. Pier 

support locations and spacing must be 

presented to be consistent with Figures 

A and B to § 3285.312, as applicable, 

unless alternative designs are provided 

by a professional engineer or registered 

architect in accordance with acceptable 

engineering practice. 


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Notes:

1. Bottom of footings must extend below 

frost line depth, unless designed for 

placement above the frost line. (See 

§ 3285.312(b)). 

2. Piers may be offset up to 6 in. in either 

direction along the supported members to 

allow for plumbing, electrical, mechanical, 

equipment, crawlspaces, or other devices. 

3. Single-stack concrete block pier loads 

must not exceed 8,000 lbs. 

4. Prefabricated piers must not exceed their 

approved or listed maximum vertical or 

horizontal design loads. 

5. When a full-height mating wall does not 

support the ridge beam, this area is 

considered an unsupported span—Span B. 

6. Piers are not required at openings in the 

mating wall that are less than 48 inches in 

width. Place piers on both sides of mating 

wall openings that are 48 inches or greater in 

width. For roof loads of 40 psf or greater, a 

professional engineer or registered architect 

must determine the maximum mating wall 

opening permitted without pier or other 

supports. 


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Notes:

1. Bottom of footings must be below the 

frost line depth, unless designed for 

placement above the frost line. (See 

§ 3285.312(b)). 

2. Piers may be offset 6 in. in either 

direction along supported members to allow 

for plumbing electrical, mechanical 

equipment, crawlspaces, or other devices. 

3. Single stack concrete block pier loads 

must not exceed 8,000 lbs. 

4. Piers are not required at openings in the 

mating wall that are less than 48 inches in 

width. Place piers on both sides of mating 

wall openings that are 48 inches or greater in 

width. For roof loads of 40 psf or greater, a 

professional engineer or registered architect 

must determine the maximum mating wall 

opening permitted without pier or other 

supports. 

5. When a full-height mating wall does not 

support the ridge beam, this area is 

considered an unsupported span—Span B. 

6. In areas where the open span is greater 

than 10 ft., intermediate piers and footings 

must be placed at maximum 10 ft. on center. 

7. Prefabricated piers must not exceed their 

approved or listed maximum horizontal or 

vertical design loads. 

8. Column piers are in addition to piers 

required under full-height mating walls. 


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Notes:

1. Mate-line column support piers are 

installed with the long dimension of the 

concrete block perpendicular to the rim 

joists. 

2. Pier and footing designed to support 

both floor sections. Loads as listed in Table 

3 to § 3285.303 are total column loads for 

both sections. 

§ 3285.311 Required perimeter supports. 

(a) Perimeter pier or other supports 

must be located as follows: 

(1) On both sides of side wall exterior 

doors (such as entry, patio, and sliding 

glass doors) and any other side wall 

openings of 48 inches or greater in 

width, and under load-bearing porch 

posts, factory installed fireplaces, and 

fireplace stoves). 

(2) Other perimeter supports must be: 

(i) Located in accordance with Table 

2 to § 3285.303; or 

(ii) Provided by other means such as 

additional outriggers or floor joists. 

When this alternative is used, the 

designs required by § 3285.301 must 

consider the additional loads in sizing 

the pier and footing supports under the 

main chassis beam. 

(b) For roof live loads of 40 psf or 

greater, a professional engineer or 

architect must determine the maximum 

sidewall opening permitted without 

perimeter pier or other supports. 

(c) The location and installation of 

any perimeter pier support must not 

take the home out of compliance with 

the Manufactured Home Construction 

and Safety Standards (part 3280 of this 

chapter). 

§ 3285.312 Footings. 

(a) Materials approved for footings 

must provide equal load-bearing 

capacity and resistance to decay, as 

required by this section. Footings must 

be placed on undisturbed soil or fill 

compacted to 90 percent of maximum 

relative density. A footing must support 

every pier. Footings are to be either: 

(1) Concrete. 

(i) Four inch nominal precast concrete 

pads meeting or exceeding ASTM C 90–

02a, Standard Specification for 

Loadbearing Concrete Masonry Units 

(incorporated by reference, see 

§ 3285.4), without reinforcement, with 

at least a 28-day compressive strength of 

1,200 pounds per square inch (psi); or 

(ii) Six inch minimum poured-inplace concrete pads, slabs, or ribbons 

with at least a 28-day compressive 


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strength of 3,000 pounds per square 

inch (psi). Site-specific soil conditions 

or design load requirements may also 

require the use of reinforcing steel in 

cast-in-place concrete footings. 

(2) Pressure-treated wood. 

(i) Pressure-treated wood footings 

must consist of a minimum of two 

layers of nominal 2-inch thick pressuretreated wood, a single layer of nominal 

3⁄4-inch thick, pressure-treated plywood 

with a maximum size of 16 inches by 16 

inches, or at least two layers of 3⁄4-inch 

thick, pressure-treated plywood for sizes 

greater than 16 inches by 16 inches. 

Plywood used for this purpose is to be 

rated exposure 1 or exterior sheathing, 

in accordance with PS1–95, 

Construction and Industrial Plywood 

(incorporated by reference, see 

§ 3285.4). 

(ii) Pressure treated lumber is to be 

treated with a water-borne adhesive, in 

accordance with AWPA Standard U1–

04 (incorporated by reference, see 

§ 3285.4) for Use Category 4B ground 

contact applications. 

(iii) Cut ends of pressure treated 

lumber must be field-treated, in 

accordance with AWPA Standard M4–

02 (incorporated by reference, see 

§ 3285.4). 

(3) ABS footing pads. 

(i) ABS footing pads are permitted, 

provided they are installed in 

accordance with the pad manufacturer 

installation instructions and certified for 

use in the soil classification at the site. 

(ii) ABS footing pads must be listed or 

labeled for the required load capacity. 

(4) Other Materials. Footings may be 

of other materials than those identified 

in this section, provided they are listed 

for such use and meet all other 

applicable requirements of this subpart. 

(b) Placement in freezing climates. 

Footings placed in freezing climates 

must be designed using methods and 

practices that prevent the effects of frost 

heave by one of the following methods: 

(1) Conventional footings. 

Conventional footings must be placed 

below the frost line depth for the site 

unless an insulated foundation or 

monolithic slab is used (refer to 

§§ 3285.312(b)(2) and 3285.312(b)(3)). 

When the frost line depth is not 

available from the LAHJ, a registered 

professional engineer, registered 

architect, or registered geologist must be 

consulted to determine the required 

frost line depth for the manufactured 

home site. This is not subject to the 

provisions in § 3285.2(c) that also 

require review by the manufacturer and 

approval by its DAPIA for any variations 

to the manufacturer’s installation 

instructions for support and anchoring. 

(2) Monolithic slab systems. A 

monolithic slab is permitted above the 

frost line when all relevant site-specific 

conditions, including soil 

characteristics, site preparation, 

ventilation, and insulative properties of 

the under floor enclosure, are 

considered and anchorage requirements 

are accommodated as set out in 

§ 3285.401. The monolithic slab system 

must be designed by a registered 

professional engineer or registered 

architect: 

(i) In accordance with acceptable 

engineering practice to prevent the 

effects of frost heave; or 

(ii) In accordance with SEI/ASCE 32–

01 (incorporated by reference, see 

§ 3285.4). 

(3) Insulated foundations. An 

insulated foundation is permitted above 

the frost line, when all relevant sitespecific conditions, including soil 

characteristics, site preparation, 

ventilation, and insulative properties of 

the under floor enclosure, are 

considered, and the foundation is 

designed by a registered professional 

engineer or registered architect: 

(i) In accordance with acceptable 

engineering practice to prevent the 

effects of frost heave; or 

(ii) In accordance with SEI/ASCE 32–

01 (incorporated by reference, see 

§ 3285.4). 

(c) Sizing of footings. The sizing and 

layout of footings depends on the loadbearing capacity of the soil, footings, 

and the piers. See §§ 3285.202 and 

3285.303, and Table to 3285.312. 

Notes:

1. Refer to Table 1 of § 3285.303 for pier 

and footing requirements when frame 

blocking only is used. 

2. In addition to blocking required by 

§ 3285.311, see Table 2 to § 3285.303 for 

maximum perimeter blocking loads. 

3. End piers under main I-beams may be 

set back a maximum of 24 inches, as 

measured from the outside edge of the floor 

to the center of the pier. 

4. Place piers on both sides of sidewall 

exterior doors, patio doors, and sliding glass 

doors; under porch posts, factory-installed 


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fireplaces, and fireplace stoves; under jamb 

studs at multiple window openings; and at 

any other sidewall openings 48 inches or 

greater in width. For roof loads of 40 psf or 

greater, a professional engineer or registered 

architect must determine the maximum 

sidewall opening permitted without 

perimeter supports. See §§ 3285.307 and 

3285.311 for additional requirements and for 

locating perimeter supports. 

1. Refer to Table 1 to § 3285.303 for pier 

and footing requirements when frame 

blocking only is used. 

2. In addition to blocking required by 

§ 3285.311, see Tables 2 and 3 to § 3285.303 

for maximum perimeter blocking loads. 

3. End piers under main I-beams may be 

set back a maximum of 24 inches, as 

measured from the outside edge of the floor 

to the center of the pier. 

4. Place piers on both sides of sidewall 

exterior doors, patio doors, and sliding glass 

doors; under porch posts, factory-installed 

fireplaces, and fireplace stoves; under jamb 

studs at multiple window openings; and at 

any other sidewall openings of 48 inches or 

greater in width. For roof loads of 40 psf or 

greater, a professional engineer or registered 

architect must determine the maximum side 

wall opening permitted without perimeter 

supports or mating wall opening permitted 

without pier or other supports. See 

§§ 3285.307 and 3285.311 for additional 

information on requirements and for locating 

perimeter supports. 

5. When an end pier under the mate-line 

also serves as a column pier, it may be set 

back a maximum of 6 in., as measured from 

the inside edge of the exterior wall to the 

center of the pier. 

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

Soil capacity 

(psf) 

Minimum footing size 

(in.) 

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

Maximum footing capacity 

(lbs.) 

Unreinforced 

cast-in-place 

minimum 

thickness 

(in.) 

Maximum footing capacity 

(lbs.) 

Unreinforced 

cast-in-place 

minimum 

thickness 

(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 

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 

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 

Soil capacity 

(psf) 

Minimum footing size 

(in.) 

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

Maximum footing capacity 

(lbs.) 

Unreinforced 

cast-in-place 

minimum 

thickness 

(in.) 

Maximum footing capacity 

(lbs.) 

Unreinforced 

cast-in-place 

minimum 

thickness 

(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:

1. The footing sizes shown are for square 

pads and are based on the area (in.2), shear 

and bending required for the loads shown. 

Other configurations, such as rectangular or 

circular configurations, can be used, 

provided the area and depth is equal to or 

greater than the area and depth of the square 

footing shown in the table, and the distance 

from the edge of the pier to the edge of the 

footing is not less than the thickness of the 

footing. 

2. The 6 in. cast-in-place values can be 

used for 4 in. unreinforced precast concrete 

footings. 

3. The capacity values listed have been 

reduced by the dead load of the concrete 

footing. 

4. Concrete block piers must not exceed 

their design capacity of 8,000 lbs. for 8′′ x 16′′ 

single stack block and 16,000 lbs. for 16′′ x 

16′′ double stack block. 

5. A registered professional engineer or 

registered architect must prepare the design, 

if the design loads exceed the capacity for 

single or double stack concrete block piers 

shown in footnote 4. 

§ 3285.313 Combination systems. 

Support systems that combine both 

load-bearing capacity and uplift 

resistance must also be sized and 

designed for all applicable design loads. 

§ 3285.314 [Reserved] 

§ 3285.315 Special snow load conditions. 

(a) General. Foundations for homes 

designed for and located in areas with 

roof live loads greater than 40 psf must 

be designed by the manufacturer for the 

special snow load conditions, in 

accordance with acceptable engineering 

practice. Where site or other conditions 

prohibit the use of the manufacturer’s 

instructions, a registered professional 

engineer or registered architect must 

design the foundation for the special 

snow load conditions. 

(b) Ramadas. Ramadas may be used in 

areas with roof live loads greater than 40 

psf. Ramadas are to be self-supporting, 

except that any connection to the home 

must be for weatherproofing only. 

Subpart E—Anchorage Against Wind 

§ 3285.401 Anchoring instructions. 

(a) After blocking and leveling, the 

manufactured home must be secured 

against the wind by use of anchor 

assembly type installations or by 

connecting the home to an alternative 

foundation system. See § 3285.301. 

(b) For anchor assembly type 

installations, the installation 

instructions must require the home to be 

secured against the wind, as described 

in this section. The installation 

instructions and design for anchor type 

assemblies must be prepared by a 

registered professional engineer or 

registered architect, in accordance with 

acceptable engineering practice, the 

design loads of the MHCSS, and 

§ 3285.301(d). 

(c) All anchoring and foundation 

systems must be capable of meeting the 

loads that the home was designed to 

withstand required by part 3280, 

subpart D of this chapter, as shown on 

the home’s data plate. Exception: 

Manufactured homes that are installed 

in less restrictive roof load zone and 

wind zone areas may have foundation or 

anchorage systems that are capable of 

meeting the lower design load 

provisions of the Standards, if the 

design for the lower requirements is 

either provided in the installation 

instructions or the foundation and 

anchorage system is designed by a 

professional engineer or registered 

architect. 

(d) The installation instructions are to 

include at least the following 

information and details for anchor 

assembly-type installations: 

(1) The maximum spacing for 

installing diagonal ties and any required 

vertical ties or straps to ground anchors; 

(2) The minimum and maximum 

angles or dimensions for installing 

diagonal ties or straps to ground anchors 

and the main chassis members of the 

manufactured home; 

(3) Requirements for connecting the 

diagonal ties to the main chassis 

members of the manufactured home. If 

the diagonal ties are attached to the 

bottom flange of the main chassis beam, 

the frame must be designed to prevent 

rotation of the beam; 

(4) Requirements for longitudinal and 

mating wall tie-downs and anchorage; 

(5) The method of strap attachment to 

the main chassis member and ground 

anchor, including provisions for swiveltype connections; 

(6) The methods for protecting 

vertical and diagonal strapping at sharp 

corners by use of radius clips or other 

means; and 

(7) As applicable, the requirements for 

sizing and installation of stabilizer 

plates. 

§ 3285.402 Ground anchor installations. 

(a) Ground anchor certification and 

testing. Each ground anchor must be 

manufactured and provided with 


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installation instructions, in accordance 

with its listing or certification. A 

nationally recognized testing agency 

must list, or a registered professional 

engineer or registered architect must 

certify, the ground anchor for use in a 

classified soil (refer to § 3285.202), 

based on a nationally recognized testing 

protocol, or a professional engineer or 

registered architect must certify that the 

ground anchor is capable of resisting all 

loads in paragraph (b) of this section for 

the soil type or classification. 

(b) Specifications for tie-down straps 

and ground anchors. 

(1) Ground anchors. Ground anchors 

must be installed in accordance with 

their listing or certification, be installed 

to their full depth, be provided with 

protection against weather deterioration 

and corrosion at least equivalent to that 

provided by a coating of zinc on steel 

of not less than 0.30 oz./ft.2 of surface 

coated, and be capable of resisting a 

minimum ultimate load of 4,725 lbs. 

and a working load of 3,150 lbs., as 

installed, unless reduced capacities are 

noted in accordance with note 11 of 

Table 1 to this section or note 12 of 

Tables 2 and 3 to this section. The 

ultimate load and working load of 

ground anchors and anchoring 

equipment must be determined by a 

registered professional engineer, 

registered architect, or tested by a 

nationally recognized third-party testing 

agency in accordance with a nationally 

recognized testing protocol. 

(2) Tie-down straps. A 11⁄4 inch x 

0.035 inch or larger steel strapping 

conforming to ASTM D 3953—97, 

Standard Specification for Strapping, 

Flat Steel and Seals (incorporated by 

reference, see § 3285.4), Type 1, Grade 

1, Finish B, with a minimum total 

capacity of 4,725 pounds (lbs.) and a 

working capacity of 3,150 pounds (lbs.) 

must be used. The tie-down straps must 

be provided with protection against 

weather deterioration and corrosion at 

least equivalent to that provided by a 

coating of zinc on steel of not less than 

0.30 oz./ft.2 of surface coated. Slit or cut 

edges of coated strapping need not be 

zinc coated. 

(c) Number and location of ground 

anchors. 

(1) Ground anchor and anchor strap 

spacing must be: 

(i) No greater than the spacing shown 

in Tables 1 through 3 to this section and 

Figures A and B to this section; or 

(ii) Designed by a registered engineer 

or architect, in accordance with 

acceptable engineering practice and the 

requirements of the MHCSS for any 

conditions that are outside the 

parameters and applicability of the 

Tables 1 through 3 to this section. 

(2) The requirements in paragraph (c) 

of this section must be used to 

determine the maximum spacing of 

ground anchors and their accompanying 

anchor straps, based on the soil 

classification determined in accordance 

with § 3285.202: 

(i) The installed ground anchor type 

and size (length) must be listed for use 

in the soil class at the site and for the 

minimum and maximum angle 

permitted between the diagonal strap 

and the ground; and 

(ii) All ground anchors must be 

installed in accordance with their listing 

or certification and the ground anchor 

manufacturer installation instructions; 

and 

(iii) If required by the ground anchor 

listing or certification, the correct size 

and type of stabilizer plate is installed. 

If metal stabilizer plates are used, they 

must be provided with protection 

against weather deterioration and 

corrosion at least equivalent to that 

provided by a coating of zinc on steel 

of not less than 0.30 oz./ft.2 of surface 

coated. Alternatively, ABS stabilizer 

plates may be used when listed and 

certified for such use. 

(3) Longitudinal anchoring. 

Manufactured homes must also be 

stabilized against wind in the 

longitudinal direction in all Wind 

Zones. Manufactured homes located in 

Wind Zones II and III must have 

longitudinal ground anchors installed 

on the ends of the manufactured home 

transportable section(s) or be provided 

with alternative systems that are capable 

of resisting wind forces in the 

longitudinal direction. See Figure C to 

§ 3285.402 for an example of one 

method that may be used to provide 

longitudinal anchoring. A professional 

engineer or registered architect must 

certify the longitudinal anchoring 

method or any alternative system used 

as adequate to provide the required 

stabilization, in accordance with 

acceptable engineering practice. 


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Notes:

1. Refer to Tables 1, 2, and 3 to this section 

for maximum ground anchor spacing. 

2. Longitudinal anchors not shown for 

clarity; refer to 3285.402(b)(2) for 

longitudinal anchoring requirements. 


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Notes:

1. Vertical Straps are not required in Wind 

Zone I. 

2. The frame must be designed to prevent 

rotation of the main chassis beam, when the 

diagonal ties are not attached to the top 

flange of the beam. See § 3285.401(d)(3). 


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TABLE 1 TO § 3285.402.—MAXIMUM DIAGONAL TIE-DOWN STRAP SPACING, WIND ZONE I 

Nominal floor width, single section/multi-section Max. height from ground to 

diagonal strap attachment 

I-beam spacing 

82.5 in. 

I-beam spacing 

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:

1. Table is based on maximum 90 in. 

sidewall height. 

2. Table is based on maximum 4 in. inset 

for ground anchor head from edge of floor or 

wall. 

3. Table is based on main rail (I-beam) 

spacing per given column. 

4. Table is based on maximum 4 in. eave 

width for single-section homes and 

maximum 12 in. for multi-section homes. 

5. Table is based on maximum 20-degree 

roof pitch (4.3⁄12). 

6. Table is based upon the minimum height 

between the ground and the bottom of the 

floor joist being 18 inches. Interpolation may 

be required for other heights from ground to 

strap attachment. 

7. Additional tie-downs may be required 

per the home manufacturer instructions. 

8. Ground anchors must be certified for 

these conditions by a professional engineer, 

architect, or listed by a nationally recognized 

testing laboratory. 

9. Ground anchors must be installed to 

their full depth, and stabilizer plates, if 

required by the ground anchor listing or 

certification, must also be installed in 

accordance with the listing or certification 

and in accordance with the ground anchor 

and home manufacturer instructions. 

10. Strapping and anchoring equipment 

must be certified by a registered professional 

engineer or registered architect, or listed by 

a nationally recognized testing agency to 

resist these specified forces, in accordance 

with testing procedures in ASTM D 3953–97, 

Standard Specification for Strapping, Flat 

Steel and Seals (incorporated by reference, 

see § 3285.4). 

11. A reduced ground anchor or strap 

working load capacity will require reduced 

tie-down strap and anchor spacing. 

12. Ground anchors must not be spaced 

closer than the minimum spacing permitted 

by the listing or certification. 

13. Table is based on a 3,150 lbs. working 

load capacity, and straps must be placed 

within 2 ft. of the ends of the home. 

14. Table is based on a minimum angle of 

30 degrees and a maximum angle of 60 

degrees between the diagonal strap and the 

ground. 

15. Table does not consider flood or 

seismic loads and is not intended for use in 

flood or seismic hazard areas. In those areas, 

the anchorage system is to be designed by a 

professional engineer or architect. 

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

Nominal floor width, 

single section/multisection 

Max. height from 

ground to diagonal 

strap attachment 

Near beam method I–beam spacing Second beam method I–beam spacing 

82.5 in. 99.5 in. 82.5 in. 99.5 in. 

12 ft/24 ft. 144 in. 

nominal section(s).

25 in .......................... 6 ft. 2 in ..................... 4 ft. 3 in ..................... N/A ............................ N/A

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. 

nominal section(s).

25 in .......................... 7 ft. 7 in ..................... 6 ft. 9 in ..................... N/A ............................ N/A

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 

192 in. nominal section(s).

25 in .......................... N/A ............................ 7 ft. 10 in ................... N/A ............................ N/A 

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:

1. Table is based on maximum 90 in. 

sidewall height. 

2. Table is based on maximum 4 in. inset 

for ground anchor head from edge of floor or 

wall. 

3. Tables are based on main rail (I-beam) 

spacing per given column. 

4. Table is based on maximum 4 in. eave 

width for single-section homes and 

maximum 12 in. for multi-section homes. 

5. Table is based on maximum 20-degree 

roof pitch (4.3/12). 

6. All manufactured homes designed to be 

located in Wind Zone II must have a vertical 

tie installed at each diagonal tie location. 

7. Table is based upon the minimum height 

between the ground and the bottom of the 

floor joist being 18 inches. Interpolation may 


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be required for other heights from ground to 

strap attachment. 

8. Additional tie downs may be required 

per the home manufacturer instructions. 

9. Ground anchors must be certified by a 

professional engineer, or registered architect, 

or listed by a nationally recognized testing 

laboratory. 

10. Ground anchors must be installed to 

their full depth, and stabilizer plates, if 

required by the ground anchor listing or 

certification, must also be installed in 

accordance with the listing or certification 

and in accordance with the ground anchor 

and home manufacturer instructions. 

11. Strapping and anchoring equipment 

must be certified by a registered professional 

engineer or registered architect or must be 

listed by a nationally recognized testing 

agency to resist these specified forces, in 

accordance with testing procedures in ASTM 

D 3953—97, Standard Specification for 

Strapping, Flat Steel and Seals (incorporated 

by reference, see § 3285.4). 

12. A reduced ground anchor or strap 

working load capacity will require reduced 

tie-down strap and anchor spacing. 

13. Ground anchors must not be spaced 

closer than the minimum spacing permitted 

by the listing or certification. 

14. Table is based on a 3,150 lbs. working 

load capacity, and straps must be placed 

within 2 ft. of the ends of the home. 

15. Table is based on a minimum angle of 

30 degrees and a maximum of 60 degrees 

between the diagonal strap and the ground. 

16. Table does not consider flood or 

seismic loads and is not intended for use in 

flood or seismic hazard areas. In those areas, 

the anchorage system is to be designed by a 

professional engineer or architect. 

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

Nominal floor width, single 

section/multi-section 

Max. height from ground to 

diagonal strap attachment 

Near beam method I-beam spacing Second beam 

method I-beam 

spacing 

82.5 in. 99.5 in. 

82.5 in. 99.5 in. 

12 ft./24 ft. 144 in. nominal 

section(s).

25 in ..................................... 5 ft. 1 in ................................ N/A ....................................... N/A ...... N/A 

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 

section(s).

25 in ..................................... 6 ft. 2 in. ............................... 5 ft. 7 in ................................ N/A ...... N/A 

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. 

nominal sections.

25 in ..................................... N/A ....................................... 6 ft. 3 in ................................ N/A ...... N/A 

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 

in. sidewall height. 

2. Table is based on maximum 4 in. inset 

for ground anchor head from edge of floor or 

wall. 

3. Table is based on main rail (I-beam) 

spacing per given column. 

4. Table is based on maximum 4 in. eave 

width for single-section homes and 

maximum 12 in. for multi-section homes. 

5. Table is based on maximum 20-degree 

roof pitch (4.3/12). 

6. All manufactured homes designed to be 

located in Wind Zone III must have a vertical 

tie installed at each diagonal tie location. 

7. Table is based upon the minimum height 

between the ground and the bottom of the 

floor joist being 18 inches. Interpolation may 

be required for other heights from ground to 

strap attachment. 

8. Additional tie downs may be required 

per the home manufacturer instructions. 

9. Ground anchors must be certified by a 

professional engineer, or registered architect, 

or listed by a nationally recognized testing 

laboratory. 

10. Ground anchors must be installed to 

their full depth, and stabilizer plates, if 

required by the ground anchor listing or 

certification, must also be installed in 

accordance with the listing or certification 

and per the ground anchor and home 

manufacturer instructions. 

11. Strapping and anchoring equipment 

must be certified by a registered professional 

engineer or registered architect or must be 

listed by a nationally recognized testing 

agency to resist these specified forces, in 

accordance with testing procedures in ASTM 

D 3953–97, Standard Specification for 

Strapping, Flat Steel and Seals (incorporated 

by reference, see § 3285.4). 

12. A reduced ground anchor or strap 

working load capacity will require reduced 

tie-down strap and anchor spacing. 

13. Ground anchors must not be spaced 

closer than the minimum spacing permitted 

by the listing or certification. 

14. Table is based on a 3,150 lbs. working 

load capacity, and straps must be placed 

within 2 ft. of the ends of the home. 

15. Table is based on a minimum angle of 

30 degrees and a maximum angle of 60 

degrees between the diagonal strap and the 

ground. 

16. Table does not consider flood or 

seismic loads and is not intended for use in 

flood or seismic hazard areas. In those areas, 

the anchorage system is to be designed by a 

professional engineer or architect. 

§ 3285.403 Sidewall, over-the-roof, mateline, and shear wall straps. 

If sidewall, over-the-roof, mate-line, 

or shear wall straps are installed on the 

home, they must be connected to an 

anchoring assembly. 

§ 3285.404 Severe climatic conditions. 

In frost-susceptible soil locations, 

ground anchor augers must be installed 

below the frost line, unless the 

foundation system is frost-protected to 

prevent the effects of frost heave, in 

accordance with acceptable engineering 

practice and § 3280.306 of this chapter 

and § 3285.312. 

§ 3285.405 Severe wind zones. 

When any part of a home is installed 

within 1,500 feet of a coastline in Wind 

Zones II or III, the manufactured home 

must be designed for the increased 

requirements, as specified on the 

home’s data plate (refer to § 3280.5(f) of 

this chapter) in accordance with 

acceptable engineering practice. Where 

site or other conditions prohibit the use 

of the manufacturer’s instructions, a 

registered professional engineer or 

registered architect, in accordance with 

acceptable engineering practice, must 

design anchorage for the special wind 

conditions. 

§ 3285.406 Flood hazard areas. 

Refer to § 3285.302 for anchoring 

requirements in flood hazard areas. 


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Subpart F—Optional Features 

§ 3285.501 Home installation manual 

supplements. 

Supplemental instructions for 

optional equipment or features must be 

approved by the DAPIA as not taking 

the home out of conformance with the 

requirements of this part, or part 3280 

of this chapter, and included with the 

manufacturer installation instructions. 

§ 3285.502 Expanding rooms. 

The support and anchoring systems 

for expanding rooms must be installed 

in accordance with designs provided by 

the home manufacturer or prepared by 

a registered professional engineer or 

registered architect, in accordance with 

acceptable engineering practice. 

§ 3285.503 Optional appliances. 

(a) Comfort cooling systems. When 

not provided and installed by the home 

manufacturer, any comfort cooling 

systems that are installed must be 

installed according to the appliance 

manufacturer’s installation instructions. 

(1) Air conditioners. Air conditioning 

equipment must be listed or certified by 

a nationally recognized testing agency 

for the application for which the unit is 

intended and installed in accordance 

with the terms of its listing or 

certification (see § 3280.714 of this 

chapter). 

(i) Energy efficiency. 

(A) Site-installed central air 

conditioning equipment must be sized 

to meet the home’s heat gain 

requirement, in accordance with 

Chapter 28 of the 1997 ASHRAE 

Handbook of Fundamentals 

(incorporated by reference, see § 3285.4) 

or ACCA Manual J, Residential Cooling 

Load, 8th Edition (incorporated by 

reference, see § 3285.4). Information 

necessary to calculate the home’s heat 

gain can be found on the home’s 

comfort cooling certificate. 

(B) The BTU/hr. rated capacity of the 

site-installed air conditioning 

equipment must not exceed the air 

distribution system’s rated BTU/hr. 

capacity as shown on the home’s 

compliance certificate. 

(ii) Circuit rating. If a manufactured 

home is factory-provided with an 

exterior outlet to energize heating and/ 

or air conditioning equipment, the 

branch circuit rating on the tag adjacent 

to this outlet must be equal to or greater 

than the minimum circuit amperage 

identified on the equipment rating plate. 

(iii) A-coil units. 

(A) A-coil air conditioning units must 

be compatible and listed for use with 

the furnace in the home and installed in 

accordance with the appliance 

manufacturer’s instructions. 

(B) The air conditioner manufacturer 

instructions must be followed. 

(C) All condensation must be directed 

beyond the perimeter of the home by 

means specified by the equipment 

manufacturer. 

(2) Heat pumps. Heat pumps must be 

listed or certified by a nationally 

recognized testing agency for the 

application for which the unit is 

intended and installed in accordance 

with the terms of its listing or 

certification. (See § 3280.714 of this 

chapter). 

(3) Evaporative coolers. 

(i) A roof-mounted cooler must be 

listed or certified by a nationally 

recognized testing agency for the 

application for which the unit is 

intended and installed in accordance 

with the terms of its listing (see 

§ 3280.714 of this chapter). 

(A) Any discharge grill must not be 

closer than three feet from a smoke 

alarm. 

(B) Before installing a roof-mounted 

evaporative cooler on-site, the installer 

must ensure that the roof will support 

the weight of the cooler. 

(C) A rigid base must be provided to 

distribute the cooler weight over 

multiple roof trusses to adequately 

support the weight of the evaporative 

cooler. 

(ii) An evaporative cooler that is not 

roof-mounted is to be installed in 

accordance with the requirements of its 

listing or the equipment manufacturer’s 

instructions, whichever is the more 

restrictive. 

(b) Fireplaces and wood-stoves. When 

not provided by the home manufacturer, 

fireplaces and wood-stoves including 

chimneys and air inlets for fireplaces 

and wood stoves must be listed for use 

with manufactured homes and must be 

installed in accordance with their 

listings. 

(c) Appliance venting. 

(1) All fuel burning heat producing 

appliances of the vented type except 

ranges and ovens must be vented to the 

exterior of the home. 

(2) Upon completion, the venting 

system must comply with all 

requirements of §§ 3280.707(b) and 

3280.710 of the Manufactured Home 

Construction and Safety Standards in 

this chapter. 

(3) When the vent exhausts through 

the floor, the vent must not terminate 

under the home and must extend to the 

home’s exterior and through any 

skirting that may be installed. 

(d) Clothes dryer exhaust duct system. 

A clothes dryer exhaust duct system 

must conform with and be completed in 

accordance with the appliance 

manufacturer instructions and 

§ 3280.708 of this chapter. The vents 

must exhaust to the exterior of the 

home, beyond any perimeter skirting 

installed around it, as shown in Figure 

to § 3285.503. 

BILLING CODE 4210–07–C 


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Notes:

1. Installation of the exhaust system must 

be in accordance with the dryer manufacturer 

instructions. 

2. Dryer exhaust system must not contain 

reverse slope or terminate under the home. 

§ 3285.504 Skirting. 

(a) Skirting, if used, must be of 

weather-resistant materials or provided 

with protection against weather 

deterioration at least equivalent to that 

provided by a coating of zinc on steel 

of not less than 0.30 oz./ft.2 of surface 

coated. 

(b) Skirting must not be attached in a 

manner that can cause water to be 

trapped between the siding and trim or 

forced up into the wall cavities trim to 

which it is attached. 

(c) All wood skirting within 6 inches 

of the ground must be pressure-treated 

in accordance with AWPA Standard U1 

(incorporated by reference, see § 3285.4) 

for Use Category 4A, Ground Anchor 

Contact Applications, or be naturally 

resistant to decay and termite 

infestations. 

(d) Skirting must not be attached in a 

manner that impedes the contraction 

and expansion characteristics of the 

home’s exterior covering. 

§ 3285.505 Crawlspace ventilation. 

(a) A crawlspace with skirting must be 

provided with ventilation openings. The 

minimum net area of ventilation 

openings must not be less than one 

square foot (ft.2) for every 150 square 

feet (ft.2) of the home’s floor area. The 

total area of ventilation openings may be 

reduced to one square foot (ft.2) for 

every 1,500 square feet (ft.2) of the 

home’s floor area, where a uniform 6–

mil polyethylene sheet material or other 

acceptable vapor retarder is installed, 

according to § 3285.204, on the ground 

surface beneath the entire floor area of 

the home. 

(b) Ventilation openings must be 

placed as high as practicable above the 

ground. 

(c) Ventilation openings must be 

located on at least two opposite sides to 

provide cross-ventilation. 

(d) Ventilation openings must be 

covered for their full height and width 

with a perforated corrosion and 

weather-resistant covering that is 

designed to prevent the entry of rodents. 

In areas subject to freezing, the 

coverings for the ventilation openings 

must also be of the adjustable type, 

permitting them to be in the open or 

closed position, depending on the 

climatic conditions. 

(e) Access opening(s) not less than 18 

inches in width and 24 inches in height 

and not less than three square feet (ft.2) 

in area must be provided and must be 

located so that any utility connections 

located under the home are accessible. 

(f) Dryer vents and combustion air 

inlets must pass through the skirting to 

the outside. Any surface water runoff 

from the furnace, air conditioning, or 

water heater drains must be directed 

away from under the home or collected 

by other methods identified in 

§ 3285.203. 

Subpart G—Ductwork and Plumbing 

and Fuel Supply Systems 

§ 3285.601 Field assembly. 

Home manufacturers must provide 

specific installation instructions for the 

proper field assembly of manufacturersupplied and shipped loose ducts, 

plumbing, and fuel supply system parts 

that are necessary to join all sections of 

the home and are designed to be located 

underneath the home. The installation 

instructions must be designed in 

accordance with applicable 

requirements of part 3280, subparts G 

and H, of this chapter, as specified in 

this subpart. 

§ 3285.602 Utility connections. 

Refer to § 3285.904 for considerations 

for utility system connections. 

§ 3285.603 Water supply. 

(a) Crossover. Multi-section homes 

with plumbing in both sections require 

water-line crossover connections to join 

all sections of the home. The crossover 

design requirements are located in, and 

must be designed in accordance with, 

§ 3280.609 of this chapter. 

(b) Maximum supply pressure and 

reduction. When the local water supply 

pressure exceeds 80 psi to the 

manufactured home, a pressurereducing valve must be installed. 

(c) Mandatory shutoff valve. 

(1) An identified and accessible 

shutoff valve must be installed between 

the water supply and the inlet. 

(2) The water riser for the shutoff 

valve connection must be located 

underneath or adjacent to the home. 

(3) The shutoff valve must be a fullflow gate or ball valve, or equivalent 

valve. 

(d) Freezing protection. Water line 

crossovers completed during 

installation must be protected from 

freezing. The freeze protection design 

requirements are located in, and must 


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be designed in accordance with, 

§ 3280.603 of this chapter. 

(1) If subject to freezing temperatures, 

the water connection must be wrapped 

with insulation or otherwise protected 

to prevent freezing. 

(2) In areas subject to freezing or 

subfreezing temperatures, exposed 

sections of water supply piping, shutoff 

valves, pressure reducers, and pipes in 

water heater compartments must be 

insulated or otherwise protected from 

freezing. 

(3) Use of pipe heating cable. Only 

pipe heating cable listed for 

manufactured home use is permitted to 

be used, and it must be installed in 

accordance with the cable manufacturer 

installation instructions. 

(e) Testing procedures. 

(1) The water system must be 

inspected and tested for leaks after 

completion at the site. The installation 

instructions must provide testing 

requirements that are consistent with 

§ 3280.612 of this chapter. 

(2) The water heater must be 

disconnected when using an air-only 

test. 

§ 3285.604 Drainage system. 

(a) Crossovers. Multi-section homes 

with plumbing in more than one section 

require drainage system crossover 

connections to join all sections of the 

home. The crossover design 

requirements are located in, and must 

be designed in accordance with, 

§ 3280.610 of this chapter. 

(b) Assembly and support. If portions 

of the drainage system were shipped 

loose because they were necessary to 

join all sections of the home and 

designed to be located underneath the 

home, they must be installed and 

supported in accordance with 

§ 3280.608 of this chapter. 

(c) Proper slopes. Drains must be 

completed in accordance with 

§ 3280.610 of this chapter. 

(1) Drain lines must not slope less 

than one-quarter inch per foot, unless 

otherwise noted on the schematic 

diagram, as shown in Figure to 

§ 3285.604. 

(2) A slope of one-eight inch per foot 

may be permitted when a clean-out is 

installed at the upper end of the run. 

(d) Testing procedures. The drainage 

system must be inspected and tested for 

leaks after completion at the site. The 

installation instructions must provide 

testing requirements that are consistent 

with § 3280.612 of this chapter. 

BILLING CODE 4210–07–P 

§ 3285.605 Fuel supply system. 

(a) Proper supply pressure. The gas 

piping system in the home is designed 

for a pressure that is at least 7 inches of 

water column [4oz./in.2 or 0.25 psi] and 

not more than 14 inches of water 

column [8 oz./in.2 or 0.5 psi]. If gas from 

any supply source exceeds, or could 

exceed this pressure, a regulator must be 

installed if required by the LAHJ. 

(b) Crossovers. 

(1) Multi-section homes with fuel 

supply piping in both sections require 

crossover connections to join all 

sections of the home. The crossover 

design requirements are located in, and 

must be designed in accordance with, 

§ 3280.705 of this chapter. 

(2) Tools must not be required to 

connect or remove the flexible 

connector quick-disconnect. 

(c) Testing procedures. The gas 

system must be inspected and tested for 

leaks after completion at the site. The 

installation instructions must provide 

testing requirements that are consistent 

with § 3280.705 of this chapter. 

§ 3285.606 Ductwork connections. 

(a) Multi-section homes with 

ductwork in more than one section 

require crossover connections to 

complete the duct system of the home. 

All ductwork connections, including 

duct collars, must be sealed to prevent 

air leakage. Galvanized metal straps or 

tape and mastics listed to UL 181A 

(incorporated by reference, see 

§ 3285.4), for closure systems with rigid 

air ducts and connectors, or UL 181B 

(incorporated by reference, see 

§ 3285.4), for closure systems with 

flexible air ducts and connectors, must 

be used around the duct collar and 

secured tightly to make all connections. 

(b) If metal straps are used, they must 

be secured with galvanized sheet metal 

screws. 

(c) Metal ducts must be fastened to 

the collar with a minimum of three 


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galvanized sheet metal screws equally 

spaced around the collar. 

(d) Air conditioning or heating ducts 

must be installed in accordance with 

applicable requirements of the duct 

manufacturer installation instructions. 

(e) The duct must be suspended or 

supported above the ground by straps or 

other means that are spaced at a 

maximum distance not to exceed 4′–0′′ 

or as otherwise permitted by the 

installation instructions. When straps 

are used to support a flexible type duct, 

the straps must be at least 1⁄2′′ wider 

than the spacing of the metal spirals 

encasing the duct. The ducts must be 

installed such that the straps cannot slip 

between any two spirals and arranged 

under the floor to prevent compression 

or kinking in any location, as shown in 

Figures A and B to this section. In-floor 

crossover ducts are permitted, in 

accordance with § 3285.606(g). 

(f) Crossover ducts outside the 

thermal envelope must be insulated 

with materials that conform to designs 

consistent with part 3280, subpart F of 

this chapter. 

(g) In-floor or ceiling crossover duct 

connections must be installed and 

sealed to prevent air leakage. 

Notes: 

1. This system is typically used when a 

crossover duct has not been built into the 

floor and the furnace is outside the I–Beam. 

With this type of installation, it is necessary 

for two flexible ducts to be installed. 

2. The crossover duct must be listed for 

exterior use. 

Notes: 

1. This system is typically used when a 

crossover duct has not been built into the 

floor and the furnace is situated directly over 

the main duct in one section of the home. A 

single flexible duct is then used to connect 

the two sections to each other. 

2. The crossover duct must be listed for 

exterior use. 

Subpart H—Electrical Systems and 

Equipment 

§ 3285.701 Electrical crossovers. 

Multi-section homes with electrical 

wiring in more than one section require 

crossover connections to join all 

sections of the home. The crossover 

must be designed in accordance with 

part 3280, subpart I of this chapter, and 

completed in accordance with the 

directions provided in the installation 

instructions. 

§ 3285.702 Miscellaneous lights and 

fixtures. 

(a) When the home is installed, 

exterior lighting fixtures, ceilingsuspended (paddle) fans, and chainhung lighting fixtures are permitted to 

be installed in accordance with their 

listings and part 3280, subpart I of this 

chapter. 

(b) Grounding. (1) All the exterior 

lighting fixtures and ceiling fans 

installed per § 3285.702(a) must be 

grounded by a fixture-grounding device 

or by a fixture-grounding wire. 

(2) For chain-hung lighting fixtures, as 

shown in Figure A to this section, both 


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a fixture-grounding device and a fixturegrounding wire must be used. The 

identified conductor must be the neutral 

conductor. 

(c) Where lighting fixtures are 

mounted on combustible surfaces such 

as hardboard, a limited combustible or 

noncombustible ring, as shown in 

Figures A and B to this section, must be 

installed to completely cover the 

combustible surface exposed between 

the fixture canopy and the wiring outlet 

box. 

(d) Exterior lights. (1) The junction 

box covers must be removed and wireto-wire connections must be made using 

listed wire connectors. 

(2) Wires must be connected black-toblack, white-to-white, and equipment 

ground-to-equipment ground. 

(3) The wires must be pushed into the 

box, and the lighting fixture must be 

secured to the junction box. 

(4) The lighting fixture must be 

caulked around its base to ensure a 

watertight seal to the sidewall. 

(5) The light bulb must be installed 

and the globe must be attached. 

(e) Ceiling fans. (1) Ceiling-suspended 

(paddle) fans must be connected to 

junction box listed and marked for 

ceiling fan application, in accordance 

with Article 314.27(b) of the National 

Electrical Code, NFPA No. 70–2005 

(incorporated by reference, see 

§ 3285.4); and 

(2) The ceiling fan must be installed 

with the trailing edges of the blades at 

least 6 feet 4 inches above the finished 

floor; and 

(3) The wiring must be connected in 

accordance with the product 

manufacturer installation instructions. 

(f) Testing. (1) After completion of all 

electrical wiring and connections, 

including crossovers, electrical lights, 

and ceiling fans, the electrical system 

must be inspected and tested at the site, 

in accordance with the testing 

requirements of § 3280.810(b) of this 

chapter. 

(2) The installation instructions must 

indicate that each manufactured home 

must be subjected to the following tests: 

(i) An electrical continuity test to 

ensure that metallic parts are effectively 

bonded; 

(ii) Operational tests of all devices 

and utilization equipment, except water 

heaters, electric ranges, electric 

furnaces, dishwashers, clothes washers/ 

dryers, and portable appliances, to 

demonstrate that they are connected and 

in working order; and 

(iii) For electrical equipment installed 

or completed during installation, 

electrical polarity checks must be 

completed to determine that 

connections have been made properly. 

Visual verification is an acceptable 

electrical polarity check. 


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§ 3285.703 Smoke alarms. 

Smoke alarms must be functionally 

tested in accordance with applicable 

requirements of the smoke alarm 

manufacturer instructions and must be 

consistent with § 3280.208 of this 

chapter. 

§ 3285.704 Telephone and cable TV. 

Refer to § 3285.906 for considerations 

pertinent to installation of telephone 

and cable TV. 

Subpart I—Exterior and Interior CloseUp 

§ 3285.801 Exterior close-up. 

(a) Exterior siding and roofing 

necessary to join all sections of the 

home must be installed according to the 

product manufacturer installation 

instructions and must be fastened in 

accordance with designs and 

manufacturer instructions, consistent 

with §§ 3280.305 and 3280.307 of this 

chapter. Exterior close-up strips/trim 

must be fastened securely and sealed 

with exterior sealant (see figure A to this 

section). 

(b) Joints and seams. All joints and 

seams in exterior wall coverings that 

were disturbed during location of the 

home must be made weatherproof. 

(c) Prior to installing the siding, the 

polyethylene sheeting covering exterior 

walls for transit must be completely 

removed. 

(d) Prior to completing the exterior 

close-up, any holes in the roofing must 

be made weatherproof and sealed with 

a sealant or other material that is 

suitable for use with the roofing in 

which the hole is made. 

(e) Mate-line gasket. The home 

manufacturer must provide materials 

and designs for mate-line gaskets or 

other methods designed to resist the 

entry of air, water, water vapor, insects, 

and rodents at all mate-line locations 

exposed to the exterior (see Figure B to 

this section). 

(f) Hinged roofs and eaves. Hinged 

roofs and eaves must be completed 

during installation in compliance with 

all requirements of the Manufactured 

Home Construction and Safety 

Standards (24 CFR part 3280) and the 

Manufactured Home Procedural and 

Enforcement Regulations (24 CFR part 

3282). Unless exempted by the 

following provisions, hinged roofs are 

also subject to a final inspection for 

compliance with the Manufactured 

Home Construction and Safety 

Standards (24 CFR part 3280) by the 

IPIA or a qualified independent 

inspector acceptable to the IPIA. Homes 

with hinged roofs that are exempted 

from IPIA inspection are instead to be 

completed and inspected in accordance 

with the Manufactured Home 

Installation Program (24 CFR part 3286). 

This includes homes: 

(1) That are designed to be located in 

Wind Zone I; 

(2) In which the pitch of the hinged 

roof is less than 7:12; and 

(3) In which fuel burning appliance 

flue penetrations are not above the 

hinge. 


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Notes:

1. Multi-section homes with horizontal-lap 

siding can be shipped with no siding on the 

front and rear end walls. 

2. The manufacturer must install doors/ 

windows trimmed with J-rail or the 

equivalent and protect all exposed materials 

not designed for exposure to the weather 

with plastic sheeting for transport. Siding, 

starter trim, and vents may be shipped loose 

in the home for installation on set-up. 

3. All home installers must ensure that all 

field installed trim, windows, doors, and 

other openings are properly sealed according 

to the siding manufacturer installation 

instructions. 

Note: On multi-section manufactured 

homes, install the sealer gasket on the 

ceiling, end walls, and floor mate-line prior 

to joining the sections together. 

§ 3285.802 Structural interconnection of 

multi-section homes. 

(a) For multi-section homes, structural 

interconnections along the interior and 

exterior at the mate-line are necessary to 

join all sections of the home. 

(b) Structural interconnection must be 

designed in accordance with the 

requirements located in § 3280.305 of 

this chapter to ensure a completely 

integrated structure. 


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(c) Upon completion of the exterior 

close-up, no gaps are permitted between 

the structural elements being 

interconnected along the mate-line of 

multi-section homes. However, prior to 

completion of the exterior close-up, 

gaps that do not exceed one inch are 

permitted between structural elements 

provided: 

(1) The gaps are closed before 

completion of close-up; 

(2) The home sections are in contact 

with each other; and 

(3) The mating gasket is providing a 

proper seal. All such gaps must be 

shimmed with dimensional lumber, and 

fastener lengths used to make 

connections between the structural 

elements must be increased to provide 

adequate penetration into the receiving 

member. 

§ 3285.803 Interior close-up. 

(a) All shipping blocking, strapping, 

or bracing must be removed from 

appliances, windows, and doors. 

(b) Interior close up items necessary 

to join all sections of the home or items 

subject to transportation damage may be 

packaged or shipped with the home for 

site installation. 

(c) Shipped-loose wall paneling 

necessary for the joining of all sections 

of the home must be installed by using 

polyvinyl acetate (PVA) adhesive on all 

framing members and fastened with 

minimum 11⁄2 inch long staples or nails 

at 6 inches on center panel edges and 12 

inches on center in the field, unless 

alternative fastening methods are 

permitted in the installation 

instructions (see Figure A to 

§ 3285.803). 

Note: Specific designs must be approved 

by a DAPIA and included in the home 

manufacturer installation instructions. 

§ 3285.804 Bottom board repair. 

(a) The bottom board covering must 

be inspected for any loosening or areas 

that might have been damaged or torn 

during installation or transportation. 

Any missing insulation is to be replaced 

prior to closure and repair of the bottom 

board. 

(b) Any splits or tears in the bottom 

board must be resealed with tape or 

patches in accordance with methods 

provided in the manufacturers 

installation instructions. 

(c) Plumbing P-traps must be checked 

to be sure they are well-insulated and 

covered. 

(d) All edges of repaired areas must be 

taped or otherwise sealed. 

Subpart J—Optional Information for 

Manufacturer’s Installation 

Instructions 

§ 3285.901 General. 

The planning and permitting 

processes, as well as utility connection, 

access, and other requirements, are 

outside of HUD’s authority and may be 

governed by LAHJs. These Model 

Installation Standards do not attempt to 

comprehensively address such 

requirements. However, HUD 

recommends that the manufacturer’s 

installation instructions include the 

information and advisories in this 

Subpart J, in order to protect the 

manufactured home, as constructed in 

accordance with the MHCSS. 

§ 3285.902 Moving manufactured home to 

location. 

It is recommended that the 

installation instructions indicate that 

the LAHJ be informed before moving the 

manufactured home to the site. It is also 

recommended that the installation 

instructions indicate that the 

manufactured home is not to be moved 

to the site until the site is prepared in 

accordance with subpart C of this part 

and when the utilities are available as 

required by the LAHJ. Examples of 

related areas that might be addressed in 

the installation instructions for meeting 

this recommendation include: 

(a) Access for the transporter. Before 

attempting to move a home, ensure that 


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the transportation equipment and home 

can be routed to the installation site and 

that all special transportation permits 

required by the LAHJ have been 

obtained. 

(b) Drainage structures. Ditches and 

culverts used to drain surface runoff 

meet the requirements of the LAHJ and 

are considered in the overall site 

preparation. 

§ 3285.903 Permits, alterations, and onsite structures. 

It is recommended that the 

installation instructions include the 

following information related to 

permits, alterations, and on-site 

structures: 

(a) Issuance of permits. All necessary 

LAHJ fees should be paid and permits 

should be obtained, which may include 

verification that LAHJ requirements 

regarding encroachments in streets, 

yards, and courts are obeyed and that 

permissible setback and fire separation 

distances from property lines and public 

roads are met. 

(b) Alterations. Prior to making any 

alteration to a home or its installation, 

contact the LAHJ to determine if plan 

approval and permits are required. 

(c) Installation of on-site structures. 

Each accessory building and structure is 

designed to support all of its own live 

and dead loads, unless the structure, 

including any attached garage, carport, 

deck, and porch, is to be attached to the 

manufactured home and is otherwise 

included in the installation instructions 

or designed by a registered professional 

engineer or registered architect. 

§ 3285.904 Utility system connections. 

(a) It is recommended that the 

manufacturer’s installation instructions 

indicate the following procedures be 

used prior to making any utility system 

connection: 

(1) Where an LAHJ and utility 

services are available, that the LAHJ and 

all utility services each be consulted 

before connecting the manufactured 

home to any utilities, or 

(2) Where no LAHJ exists and utility 

services are available, that the utilities 

be consulted before connecting the 

manufactured home to any utility 

service; or 

(3) In rural areas where no LAHJ or 

utility services are available, that a 

professional be consulted prior to 

making any system connections. 

(b) Qualified personnel. Only 

qualified personnel familiar with local 

requirements are permitted to make 

utility site connections and conduct 

tests. 

(c) Drainage system. The main drain 

line must be connected to the site’s 

sewer hookup, using an elastomeric 

coupler or by other methods acceptable 

to the LAHJ, as shown in Figure A to 

this section. 

(d) Fuel supply system. 

(1) Conversion of gas appliances. A 

service person acceptable to the LAHJ 

must convert the appliance from one 

type of gas to another, following 

instructions by the manufacturer of each 

appliance. 

(2) Orifices and regulators. Before 

making any connections to the site 

supply, the inlet orifices of all gasburning appliances must be checked to 

ensure they are correctly set up for the 

type of gas to be supplied. 

(3) Connection procedures. Gasburning appliance vents must be 

inspected to ensure that they are 

connected to the appliance and that roof 

jacks are properly installed and have not 

come loose during transit. 

(4) Gas appliance start-up procedures. 

The LAHJ should be consulted 

concerning the following gas appliance 

startup procedures: 

(i) One at a time, opening equipment 

shutoff valves, lighting pilot lights when 

provided, and adjusting burners and 

spark igniters for automatic ignition 

systems, in accordance with each 

appliance manufacturer instructions. 

(ii) Checking the operation of the 

furnace and water heater thermostats. 

Note: Fittings in the drainage system that 

are subject to freezing, such as P-traps in the 

floor, are protected with insulation by the 

manufacturer. Insulation must be replaced if 

it is removed for access to the P-trap. 

§ 3285.905 Heating oil systems. 

It is recommended that the 

installation instructions include the 

following information related to heating 

oil systems, when applicable: 

(a) Homes equipped with oil burning 

furnaces should have their oil supply 

tank and piping installed and tested onsite, in accordance with NFPA 31, 

Standard for the Installation of Oil 

Burning Equipment, 2001 (incorporated 

by reference, see § 3285.4) or the LAHJ, 

whichever is more stringent. 

(b) The oil burning furnace 

manufacturer’s instructions should be 

consulted for pipe size and installation 

procedures. 

(c) Oil storage tanks and pipe 

installations should meet all applicable 

local regulations. 

(d) Tank installation requirements. 

(1) The tank should be located where 

it is accessible to service and supply 

and where it is safe from fire and other 

hazards. 

(2) In flood hazard areas, the oil 

storage tank should be anchored and 

elevated to or above the design flood 

elevation, or anchored and designed to 

prevent flotation, collapse, or 

permanent lateral movement during the 

design flood. 

(3) Leak test procedure. Before the 

system is operated, it should be checked 

for leaks in the tank and supply piping, 

in accordance with NFPA 31, Standard 

for the Installation of Oil Burning 

Equipment, 2001 (incorporated by 

reference, see § 3285.4) or the 

requirements of the LAHJ, whichever is 

more stringent. 

§ 3285.906 Telephone and cable TV. 

It is recommended that the 

installation instructions explain that 


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telephone and cable TV wiring should 

be installed in accordance with 

requirements of the LAHJ and the 

National Electrical Code, NFPA No. 70–

2005 (incorporated by reference, see 

§ 3285.4). 

§ 3285.907 Manufacturer additions to 

installation instructions. 

A manufacturer may include in its 

installation instructions items that are 

not required by this chapter as long as 

the items included by the manufacturer 

are consistent with the Model 

Installation Standards in this part and 

do not take the manufactured home out 

of compliance with the MHCSS. 

Dated: September 18, 2007. 

Brian D. Montgomery, 

Assistant Secretary for Housing—Federal 

Housing Commissioner. 

[FR Doc. 07–5004 Filed 10–18–07; 8:45 am] 

BILLING CODE 4210–67–P 


sroberts on PROD1PC70 with RULES