Discussion Forum

Three Little Words
Original Comment:
As we get closer to Valentine’s Day, I want to remind you of the importance of three little words that can make a big difference. No, I’m not talking about “I love you” although those three words are quite powerful. I’m talking about “or modular units.”

Last week, I was sent a notice from the Missouri Public Service Commission announcing an upcoming workshop to discuss proposed changes to the Manufactured Housing and Modular Unit Program. Like many other states, Missouri has one agency that oversees both the HUD code manufactured housing industry as well as the IRC and IBC residential and commercial modular industries.

There was obviously some work being done behind the scenes, because when the announcement came out in early January, it included a whole array of proposed changes as well as two entirely new chapters to the program. In all, the changes impacted eight chapters of the program (Chapters 120-127). While some of the chapters were specific to manufactured housing, and thus, not areas we want to address, many other smaller changes were being proposed for residential and commercial modular applications.

These proposed changes were being driven by an internal audit on the program, which found that under its prior leadership, the program had a little too much discretion into determining who paid certain fees and who faced certain penalties. The additional driver behind the changes were problems that surfaced as a result of improper installation practices, as well as federal requirements on the manufactured housing side. For example, an entire new chapter (Chapter 125) is being proposed specifically to address tie down systems in manufactured housing. A second chapter (Chapter 126) addresses the new licensing requirements for installers of manufactured housing. But therein lies the issue. Buried within pages of regulations and contained within a chapter that seemingly has no impact on the modular industry were these three words: “or modular units.” To put this in context, the section in question was spelling out new requirements for installers of manufactured housing "OR MODULAR UNITS".

Those three little words impact the entire modular industry and any home or commercial modular unit installed in the state. We obviously plan to raise the question as to why modular was included in this chapter seemingly aimed at manufactured housing and plan to submit our comments addressing these three little words.

But I say this to bring up a bigger point. Often times we get caught up in the excitement and exposure generated by tantalizing headlines and emotional opinions in our industry. Anyone with a phone can now make videos, blogs, and offer commentary on how to improve the industry, and in many cases they offer good advice. But who is going to do the real work of reviewing hundreds of pages of regulations to make sure a state agency doesn’t sneak in language that will drive up your costs and delay your next project? These are often defensive strategies aimed at making sure the business climate doesn’t get worse than it is, and often we view these tactics in a less than favorable light. I can’t tell you how many times I have heard that “we need to be more proactive on our government affairs issues.” And I agree, we do.

One of the most exciting plays in all of sports is the “Hail Mary” pass at the end of the game. For those few seconds you watch as the outcome of the game hinges in the balance. But how often does that strategy result in victory? More often than not, it’s a solid defense that keeps you in the game. And no one plays defense better than us! To get more information on this specific issue or on other issues we are working on for the industry, email tom@modular.org
Started on January 18, 2016 by Tom Hardiman
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Additional Comments:
I very much appreciate the work MBI does in watching out for these type of regulatory "gotchas". Keep up the good work!!!
Updated on January 18, 2016 by Mark Atkins

Are we responding to people who may not even have the knowledge of what the modular industry really is? Those judgments could be a result of uninformed committee members.
Perhaps an invitation to the conference may open their eyes. I know my perception of modular construction drastically changed after attending my first conference. Perhaps we are dealing with ignorance and it is time to educate and inform?
Updated on January 18, 2016 by Shari Carlozzi

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