Federal Register Solicits Interested Organizations
August 1997
In the August 6, 1997 Federal Register, HUD published a notice
requesting statements of interest from private organizations
to administer a voluntary process for the development of suggested
manufactured housing standards. CABO finds it curious that HUD
will be seeking proposals when CABO had already been designated
by HUD for this purpose in 1988 (Federal Register February 16,
1988). Further, HUD Secretary Andrew Cuomo, recently received
correspondence from numerous members of both the U.S. House of
Representatives and the U.S. Senate urging that CABO be designated
as the private organization to develop model manufactured housing
standards, action that is currently within HUD's authority.
Proposed Changes Developed on Annual Basis
Since the 1988 agreement, CABO has been developing proposed
changes to the FMHCSS on an annual basis. Until 1994, these changes
were processed using the CABO Code Change Procedures that are
also used to maintain the CABO One and Two Family Dwelling Code,
which is recognized by HUD in their Minimum Property Standards
for conventional housing. The use of these procedures was agreed
to by HUD in 1988.
CABO Began Process of Revising FMHCSS
When the National Commission on Manufactured Homes issued
its report in 1994, it was recommended that the FMHCSS be updated
on a regular basis by a private sector organization using the
consensus procedures of the American National Standards Institute
(ANSI). In response to this recommendation, CABO immediately
formed a consensus committee with representation from all affected
and interested groups and began the process of revising the FMHCSS
using the ANSI-approved consensus process.
CABO has been complying with its agreement with HUD since
1988 and has not received any negative feedback from HUD. Many
of the organizations that have participated in this process since
1988 have openly expressed their support of the process.
CABO is preparing a response to the Federal Register Notice.
Additional Consumer Representation Sought
HUD has also expressed a concern that there be adequate representation
of consumers on the committee. CABO believes that the composition
of its MHCSS Consensus Committee has more than adequate representation
of consumers. Currently, on the 26-member committee, there are
five committee representatives who are classified in the consumer
category. Additionally, there are six individuals who are classified
as state and local public code officials whose primary function
in their daily employment is to serve the public (consumers)
in the interest of health, safety and welfare. To address HUD's
concerns, CABO is seeking additional consumer representation
on the committee.
©1997 Council of American Building
Officials
The CABO Newsletter
Volume 4 Number 2
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