Report on Comments — Copyright, NFPA NFPA 501€¦ · Electrical for Manufactured Housing (MAN-ELE) Robert A. McCullough, Chair Ocean County Construction Inspection Dept., NJ [E]

501-1

Report on Comments — Copyright, NFPA NFPA 501 Report of the Committee on

Manufactured Housing (MAN-AAC)

David Hilton Goins, ChairNorth Carolina Department of Insurance, NC [E]

William C. Farish, Fleetwood Homes, CA [M]Danny D. Ghorbani, Manufactured Housing Association for Regulatory Reform, DC [M]Martin C. Gilchrist, Urban Research & Development Corporation, PA [SE]Christopher P. Jones, Christopher P. Jones & Associates, NC [E] Rep. FEMA/Federal Insurance & Mitigation Admin. John V. Loscheider, Loscheider Engineering Company, WA [E] Rep. Building Seismic Safety Council/Code Resource Support Committee Mark C. Orellana, Penn Township, Indiana Fire Department, IN [E] Rep. International Fire Marshals Association John Pabian, Underwriters Laboratories Inc., IL [RT] Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [C] Rep. American Public Health Association George N. Porter, Manufactured Housing Resources, DE [IM] Janet Potter, Manufactured Home Owners Association of America, NC [C] Michael J. Slifka, PFS Corporation, WI [RT] Nader Tomasbi, Liberty Homes, Inc., IN [M] Frank Walter, Manufactured Housing Institute, VA [M]

Alternates

C. Edgar Bryant, Champion Enterprises, Inc., MI [M] (Alt. to William C. Farish)Clarence Cook, Shelby Township, MI [C] (Alt. to Janet Potter)Margaret R. Figueroa, Underwriters Laboratories Inc., IL [RT] (Alt. to John Pabian)Stanley C. Harbuck, School of Building Inspection, UT [C] (Alt. to Jake Pauls)David K. Low, Greenhorne & OʼMara, Inc., VA [E] (Alt. to Christopher P. Jones)Mark A. Nunn, Manufactured Housing Institute, VA [M] (Alt. to Frank Walter)

Nonvoting

John Lake, Marion County Fire Rescue, FL [E] Rep. TC on Fire Safety for Manufactured Housing Richard A. Mancini, Rhode Island State Building Commission, RI [E] Rep. TC on Plumbing for Manufactured Housing Robert A. McCullough, Ocean County Construction Inspection Dept., NJ [E] Rep. TC on Electrical for Manufactured Housing Jerome L. McHale, Federation of Manufactured Home Owners of Florida, Inc., FL [C] Rep. TC on Administration for Manufactured Housing Raymond F. Tucker, Consulting Professional Engineer/RADCO, CA [RT] Rep. TC on Structural for Manufactured Housing Michael L. Zieman, RADCO, CA [RT] Rep. TC on Mechanical for Manufactured Housing

Staff Liaison: Milosh T. Puchovsky

Committee Scope: This Correlating Committee shall have primary responsibility for documents or portions of documents that provide a safe and healthy environment for the occupant of a manufactured home.

Report of the Committee onAdministration for Manufactured Housing (MAN-ADM)

Jerome L. McHale, ChairFederation of Manufactured Home Owners of Florida, Inc., FL [C]

Danny D. Ghorbani, Manufactured Housing Association for Regulatory Reform, DC [M] Martin C. Gilchrist, Urban Research & Development Corporation, PA [SE] David Hilton Goins, North Carolina Department of Insurance, NC [E] Doug Gorman, Home-Mart, Incorporated, OK [M] Rep. Manufactured Housing Association of Oklahoma Jeffrey T. Inks, National Association of Home Builders, DC [U] Rep. National Association of Home Builders Christopher P. Jones, Christopher P. Jones & Associates, NC [E] Rep. FEMA/Federal Insurance & Mitigation Admin. Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [C] Rep. American Public Health Association Raymond F. Tucker, Consulting Professional Engineer/RADCO, CA [RT]

Alternates

Stanley C. Harbuck, School of Building Inspection, UT [C] (Alt. to Jake Pauls) David K. Low, Greenhorne & OʼMara, Inc., VA [E] (Alt. to Christopher P. Jones) Frank Walter, Manufactured Housing Institute, VA [M] (Alt. to Danny D. Ghorbani) Michael L. Zieman, RADCO, CA [RT] (Alt. to Raymond F. Tucker)


Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on administrative provisions and planning requirements for manufactured homes to assure the adequacy of architectural planning considerations and documentation of compliance for a safe and healthy environment for the occupants of a manufactured home.

Report of the Committee onElectrical for Manufactured Housing (MAN-ELE)

Robert A. McCullough, ChairOcean County Construction Inspection Dept., NJ [E]Rep. International Association of Electrical Inspectors

Thomas R. Brandt, Fairmont Homes Inc., IN [M] C. Edgar Bryant, Champion Enterprises, Inc., MI [M]Thomas L. Harman, University of Houston/Clear Lake, TX [SE]Daniel J. Kissane, Pass & Seymour/Legrand, NY [M]Robert L. La Rocca, Underwriters Laboratories Inc., NY [RT]Kent Pribyl, Nebraska Public Service Commission, NB [E]Clifford L. Rediger, Independent Electrical Contractors Training Fund, CO [IM] Rep. Independent Electrical Contractors, Inc. Frank Whittaker, Jr., City of Roanoke, VA [E] Michael L. Zieman, RADCO, CA [RT]

Alternates

David R. Keller, Champion Enterprises, Inc., MI [M] (Alt. to C. Edgar Bryant)

Staff Liaison: Jeffrey S. Sargent

Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on electrical conductors and electrical equipment installed within or on manufactured homes to provide a safe and healthy environment for the occupants of a manufactured home.

501-2

Report on Comments — Copyright, NFPA NFPA 501 Report of the Committee on

Fire Safety for Manufactured Housing (MAN-FIR)

John Lake, ChairMarion County Fire Rescue, FL [E]

Jim Blair, Foremost Insurance Group, MI [I] Kenneth E. Gaiser, City of Jackson Fire Department, MI [E] Rep. International Association of Fire Chiefs William M. Hug, Cavco Industries, LLC, AZ [M] M. L. “Larry” Maruskin, US Department of Homeland Security, MD [C] Richard A. Mendlen, US Department of Housing & Urban Development, DC [E]Dennis L. Pitts, American Forest & Paper Association, TX [M] Rep. American Forest & Paper Association James V. Ryan, Potomac, MD [SE] Michael J. Slifka, PFS Corporation, WI [RT] Randy E. Vogt, State of Minnesota, MN [E] Richard Weinert, State of California, CA [E] Robert A. Wessel, Gypsum Association, DC [M] A. Elwood Willey, FIREPRO Incorporated, MA [SE]

Alternates

Dennis Mapalo, State of California, CA [E] (Alt. to Richard Weinert) Jeffrey B. Stone, American Forest & Paper Association, FL [M] (Alt. to Dennis L. Pitts)

Staff Liaison: Kirsten Paoletti

Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on fire safety to the occupants of a manufactured home.

Report of the Committee onMechanical for Manufactured Housing (MAN-MEC)

Michael L. Zieman, ChairRADCO, CA [RT]

Devra R. Bachrach, Natural Resources Defense Council (NRDC), CA [C]Larry Boyce, NORDYNE, MO [M]John M. Halliwill, Intʼl. Assn. of Plumbing & Mechanical Officials, CA [E] Rep. International Association of Plumbing & Mechanical Officials Jordan Heiman, Jordan L. Heiman Inc., MO [SE] Michael Lubliner, Washington State University Energy Program, WA [U] Rep. Northwest Energy Efficiency Alliance John Mikel, Skyline Corporation, IN [M] Ivan T. Smith, Greenstone Industries, Inc., FL [M] John R. Stevens, US Department of Housing & Urban Development, DC [E]Frank Walter, Manufactured Housing Institute, VA [M]Alan Zimmerman, York International UPG/Evcon, KS [M]

Alternates

Denise Beach, National Propane Gas Association, DC [IM] (Voting Alt. to NPGA Rep.) Michael T. Kobel, Intʼl. Assn. of Plumbing & Mechanical Officials, CA [E] (Alt. to John M. Halliwill) Jeffrey T. Legault, Skyline Corporation, IN [M] (Alt. to John Mikel) Mark A. Nunn, Manufactured Housing Institute, VA [M] (Alt. to Frank Walter)


Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on condensation control; air infiltration; thermal insulation; certification for heating and comfort cooling; and heating, cooling, and fuel-burning equipment that is installed within, on, or external to a manufactured home.

Report of the Committee onPlumbing for Manufactured Housing (MAN-PLU)

Richard A. Mancini, ChairRhode Island State Building Commission, RI [E]

Marguerite E. Carroll, Underwriters Laboratories Inc., CA [RT]John M. Halliwill, Intʼl. Assn. of Plumbing & Mechanical Officials, CA [E]William C. Masters, Homes of Merit, Inc., FL [M]James R. Paschal, NSF International, MI [RT]Kent Pribyl, Nebraska Public Service Commission, NB [E]David Viola, Plumbing Manufacturers Institute, IL [M] Rep. Plumbing Manufacturers Institute Michael L. Zieman, RADCO, CA [RT]

Alternates

Michael T. Kobel, Intʼl. Assn. of Plumbing & Mechanical Officials, CA [E] (Alt. to John M. Halliwill)

Staff Liaison: Theodore C. Lemoff

Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on plumbing systems that provide a safe and healthy environment for the occupants of a manufactured home.

Report of the Committee onStructural for Manufactured Housing

Raymond F. Tucker, ChairConsulting Professional Engineer/RADCO, CA [RT]

John G. Bradfield, Composite Panel Association, MD [U] Bill Broecker, Foremost Corporation of America, MI [I] C. Edgar Bryant, Champion Enterprises, Inc., MI [M]William C. Farish, Fleetwood Homes, CA [M]Evor F. Johns, Progressive Engineering, Inc., IN [SE]Christopher P. Jones, Christopher P. Jones & Associates, NC [E] Rep. FEMA/Federal Insurance & Mitigation Admin. Michael A. Kinard, Kinro Incorporated, TX [M] John V. Loscheider, Loscheider Engineering Company, WA [E] Rep. Building Seismic Safety Council/Code Resource Support Committee Harry W. (Hank) Martin, American Iron and Steel Institute, CA [M] Rep. American Iron and Steel Institute Richard A. Mendlen, US Department of Housing & Urban Development, DC [E]John Pabian, Underwriters Laboratories Inc., IL [RT]Kanti Patel, Maryland Codes Administration, MD [E]Jeffrey B. Stone, American Forest & Paper Association, FL [M] Rep. American Forest & Paper Association John W. Weldy, NTA Incorporated, IN [RT]

Alternates

Gary L. Heroux, Composite Panel Association (CPA), MD [U] (Alt. to John G. Bradfield)David R. Keller, Champion Enterprises, Inc., MI [M] (Alt. to C. Edgar Bryant)David K. Low, Greenhorne & OʼMara, Inc., VA [E] (Alt. to Christopher P. Jones)Dennis L. Pitts, American Forest & Paper Association, TX [M] (Alt. to Jeffrey B. Stone) Jason Smart, Institute for Business & Home Safety, FL [I] (Voting Alt. to IBHS Rep.) Robert J. Wills, American Iron and Steel Institute, AL [M] (Alt. to Harry W. (Hank) Martin) Patrick Zeeveld, Underwriters Laboratories Inc., IL [RT] (Alt. to John Pabian)

Staff Liaison: Bonnie E. Manley

Committee Scope: This Committee shall have primary responsibility for documents or portions of documents on materials, products, equipment and workmanship and testing needed to ensure that there is a safe and healthy environment for the occupant of a manufactured home. The Committee shall also have the responsibility associated with the general requirements for designing the structure to fully withstand the adverse effects of transportation shock and vibration on a manufactured home.

501-3

Report on Comments — Copyright, NFPA NFPA 501 These lists represent the membership at the time each Committee was balloted on the text of this report. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of the document.

• Technical Correlating Committee on Manufactured Housing (MAN-AAC) • Technical Committee on Administration for Manufactured Housing (MAN-ADM) • Technical Committee on Electrical for Manufactured Housing (MAN-ELE) • Technical Committee on Fire Safety for Manufactured Housing (MAN-FIR) • Technical Committee on Mechanical for Manufactured Housing (MAN-MEC) • Technical Committee on Plumbing for Manufactured Housing (MAN-PLU) • Technical Committee on Structural for Manufactured Housing (MAN-STR)

The Committees on Manufactured Housing are presenting three Reports for adoption as follows:

Report I was prepared by the Technical Committees on Manufactured Housing, and documents its action on the comments received on its Report on Proposals on NFPA 225, Model Manufactured Home Installation Standard, as published in the Report on Proposals for the 2004 November Meeting.

This Report has been submitted to letter ballot of the individual Technical Committees. The results of the balloting, after circulation of any negative votes, can be found in the report.

This Report has also been submitted to letter ballot of the Technical Correlating Committee on Manufactured Housing, which consists of 14 voting members with 1 ballot not returned (Tomasbi). The ballot tally and reasons for negatives can be found below.

225-1 Log #6 Farish, Ghorbani, Gilchrist, Porter and Walter225-2 Log #7 Farish, Ghorbani, Gilchrist, Porter and Walter225-3 Log #11 Farish, Ghorbani, Gilchrist, Porter and Walter225-4 Log #12 Farish, Ghorbani, Gilchrist, Porter and Walter225-5 Log #13 Farish, Ghorbani, Gilchrist, Porter and Walter225-6 Log #14 Farish, Ghorbani, Gilchrist, Porter and Walter225-7 Log #15 Farish, Ghorbani, Gilchrist Porter and Walter225-8 Log #22 Farish, Ghorbani, Gilchrist, Porter and Walter225-9 Log #23 Farish, Ghorbani, Gilchrist, Porter and Walter225-10 Log #24 Farish, Ghorbani, Gilchrist, Porter and Walter225-11 Log #25 Farish, Ghorbani, Gilchrist, Porter and Walter225-12 Log #26 Farish, Ghorbani, Gilchrist, Porter and Walter225-13 Log #27 Farish, Ghorbani, Gilchrist, Porter and Walter225-14 Log #33 Farish, Ghorbani, Gilchrist, Porter and Walter225-15 Log #34 Farish, Ghorbani, Gilchrist, Porter and Walter225-16 Log #35 Farish, Ghorbani, Porter and Walter225-17 Log #41 Farish, Ghorbani, Gilchrist, Porter and Walter225-18 Log #42 Farish, Ghorbani, Gilchrist, Porter and Walter225-19 Log #32a Farish, Ghorbani, Gilchrist, Porter and Walter225-20 Log #32b Farish, Ghorbani, Gilchrist, Porter and Walter225-21 Log #39 Farish, Ghorbani, and Porter225-22 Log #1 Ghorbani, Gilchrist Porter and Walter225-23 Log #36 Farish, Ghorbani, Gilchrist, Porter and Walter225-24 Log #37 Farish, Ghorbani, Gilchrist, Porter and Walter225-25 Log #2 Farish, Ghorbani, Gilchrist, Porter and Walter225-26 Log #16 Ghorbani, Porter225-27 Log #28 Ghorbani, Porter225-28 Log #17 Farish, Ghorbani, Gilchrist, Porter and Walter225-29 Log #29 Farish, Ghorbani, Gilchrist, Porter and Walter225-30 Log #9 Farish, Ghorbani, Gilchrist, Porter and Walter225-31 Log #3 Farish, Ghorbani, Gilchrist, Porter and Walter225-32 Log #38 Farish, Ghorbani, Gilchrist, Porter and Walter225-33 Log #43 Farish, Ghorbani, Gilchrist, Porter and Walter225-34 Log #8 Farish, Ghorbani, Gilchrist, Porter and Walter225-35 Log #5a Ghorbani, Porter225-36 Log #5b Ghorbani, Porter225-37 Log #44 Farish, Ghorbani, Gilchrist, Porter and Walter225-38 Log #10 Ghorbani, Porter225-39 Log #18 Farish, Ghorbani, Gilchrist, Porter and Walter225-40 Log #30 Farish, Ghorbani, Gilchrist, Porter and Walter225-41 Log #19 Ghorbani, Porter225-42 Log #CC1 Ghorbani, Porter225-43 Log #4 Ghorbani, Porter225-44 Log #20 Ghorbani, Porter225-45 Log #31 Ghorbani, Porter225-46 Log #40 Ghorbani, Porter

Mr. Farrish voted negative stating: “I am being forced to vote negative on the entire ROC for the reasons cited

below. I am indicating my votes as if it were a segmented ballot so that it is clear I do not object to all of the issues.”

225-1 (Log #6) (ROP 225-2) See my Explanation of Negative on 225-8. 225-2 (Log #7) (ROP 225-3) See my Explanation of Negative on 225-8. 225-3 (Log #1) (ROP 225-2) See my Explanation of Negative on 225-8. 225-4 (Log #12) (ROP 225-3) See my Explanation of Negative on 225-8. 225-5 (Log #13) (ROP 225-6) I am voting negative for the following

reasons: • It still seems more reasonable to simply cite the proper references for flood-

resistive design (such as FEMA 85) rather than try to include with modification sections thought applicable.

• There should be no flood-resistive requirements considered until the heavily revised edition of FEMA 85 is finally published. The nearly 20-year old existing edition is no longer gives proper guidance.

• There are no provisions in NFPA 501 for designing the home at the point of connection to withstand any flood-induced forces.

225-6 (Log #14) (ROP 225-7) See my Explanation of Negative on 225-5. 225-7 (Log #15) (ROP 225-8) See my Explanation of Negative on 225-5. 225-8 (Log #22) (ROP 225-3) I am voting negative for the following

reasons: • The “Damage Prediction” study appears flawed and incomplete: • The seismic event chosen (Richter = 8.2) is too severe. • The cost of repairs is not thoroughly investigated. • The definition of a home with “complete structural damage”

ignores the studies that have shown the relatively minor costs to repair a home that has merely fallen off its supports.

• No cost/benefits ratio explored. • Not enough study has been done for the reaction of a home properly

secured in accordance with HUD Wind Zone I standards to a seismic event. Even the PD&R study of the 1994 Northridge earthquake admitted that most damage homes were not anchored.

• The three county-by-county proposals are confusing. Two appear identical but the third is different. All three have confusing explanations as to their application. (And the maps are still terrible quality.)

Chapter Z has many enforcement issues. • Water heaters can only be site installed with an Alternate

Construction standard under present HUD regulations. • Calculating the securement of 100 pound objects in accordance

with NFPA 5000 is to restrictive. • Calculating the attachment of all utilities for wind and seismic

displacements is unenforceable. • Incorporation of NFPA 5000 material in Annex F is commendable but

many difficulties must be resolved. • NFPA 225 is intended to be an installation inspection document,

yet now it contains detailed design and analysis tools far beyond the capabilities of anyone in the field.

• Annex F contains information on the design of the home and yet NFPA 501 contains no such requirements.

225-9 (Log #23) (ROP 225-2) See my Explanation of Negative on 225-8. 225-10 (Log #24) (ROP 225-3) See my Explanation of Negative on 225-8. 225-11 (Log #25) (ROP 225-6) See my Explanation of Negative on 225-5. 225-12 (Log #26) (ROP 225-7) See my Explanation of Negative on 225-5. 225-13 (Log #27) (ROP 225-8) See my Explanation of Negative on 225-5. 225-14 (Log #33) (ROP 225-8) See my Explanation of Negative on 225-5. 225-15 (Log #34) (ROP 225-7) See my Explanation of Negative on 225-5. 225-16 (Log #35) (ROP 225-6) See my Explanation of Negative on 225-5. 225-17 (Log #41) (ROP 225-28) See my Explanation of Negative on 225-32. 225-18 (Log #42) (ROP 225-2) See my Explanation of Negative on 225-8. 225-19 (Log #32a) (ROP 225-2 and 225-3) See my Explanation of Negative

on 225-8. 225-20 (Log #32b) (ROP 225-2 and 225-3) See my Explanation of Negative

on 225-8. 225-21 (Log #39) (ROP 225-75) See my Explanation of Negative on 225-32. 225-23 (Log #36) (ROP 225-3) See my Explanation of Negative on 225-8. 225-24 (Log #37) (ROP 225-6) See my Explanation of Negative on 225-5. 225-25 (Log #2) (ROP 225-8) See my Explanation of Negative on 225-5. 225-28 (Log #17) (ROP 225-28) See my Explanation of Negative on 225-32. 225-29 (Log #29) (ROP 225-28) See my Explanation of Negative on 225-32. 225-30 (Log #9) (ROP 225-29) See my Explanation of Negative on 225-32. 225-31 (Log #3) (ROP 225-28) See my Explanation of Negative on 225-32. 225-32 (Log #38) (ROP 225-29) I am voting negative for the following

reasons: • If the wind provisions of NFPA 501 (ROP 501-6 and 501-10) are rejected

in accordance with my votes on that ROC ballot then there is no need for the anchoring requirements for the rejected “new” zones.

• The new cost/benefit analysis, while appreciated, seems flawed. • The case of HUD Zone I to NFPA Zone 2 was omitted. The cost

of this case (from the Task Force study) was $900/hone and would affect over 18,000 homes/year (based on 2001 production numbers).

• The CBR determined in Table 5 is not applied to estimated home production to determine if the “benefit” is positive or negative.

501-4

Report on Comments — Copyright, NFPA NFPA 501 • The impact of additional zones in certain retail areas has not been

studied for its effect on the cost of housing. (If a retailer is too close to several wind zones will she have to stock units for the more stringent zone and thereby skew the assumption that all homes in a certain zone are designed for that zone rather over-designed for the worst conditions?)

225-33 (Log #43) (ROP 225-8) See my Explanation of Negative on 225-5. 225-34 (Log #8) (ROP 225-28) See my Explanation of Negative on 225-32. 225-37 (Log #44) (ROP 225-7) See my Explanation of Negative on 225-5. 225-39 (Log #18) (ROP 225-29) See my Explanation of Negative on 225-32. 225-40 (Log #43) (ROP 225-29) See my Explanation of Negative on 225-32.

Mr. Ghorbani voted negative stating: “We keep voting on these proposals — and they continue to be revised.

Frankly, more and more members of our industry are beginning to wonder whether the NFPA process is suitable to the unique character of our industryʼs product — manufactured homes. This is particularly true in recent years as the NFPA committees and subcommittees continue to be stacked against the industry, thus drowning the manufactured housing industry representatives ̓voices and votes on these crucial proposals.

As the separation between the Federal standards (3280/installation) and NFPA 501/NFPA 225 continues to widen — with the former maintaining a balance between affordability and consumer protection while the latter rapidly becoming gold-plated and unusable — the question that the industry and its consumers face is that whether or not the time, effort and money that they expend participating in the NFPA process are worth their while.

I, and my organization which represents nearly 90 percent of the industryʼs production, feel very strongly that the time has come to re-evaluate the industryʼs participation in the NFPA process for manufactured housing code development and maintenance.”

Mr. Gilchrist voted negative stating: “The following are my negative votes and the items they relate to. These

have been grouped in order to save duplicating reasons for the negative responses.”

Those items related to wind load updates and related issues include, items 225-17, 225-28, 225-29, 225-30, 335-31, 225-32, 225-34, 225-39, 225-40, and ROP items 225-28 and 225-29.

– feel that these items require further study before being incorporated for a number of reasons

– the cost benefit effect on the consumer, and the real effect on precluding families from being able to purchase and live in manufactured homes.

– the cost increases created for the manufacturer – the cost increases for retailing as it relates to multiple wind zones (as this

proposal is for four wind zones vs. the current 3 wind zones) – other than natural disasters (which no one can foresee), arenʼt the standards

in the industry for set up and tie down adequately handling most normal situations and wind conditions. This should be determined prior to changing all of the wind zones and criteria.

Those items related to flood provisions and related issues include, items 225-5, 225-6, 225-7, 225-11, 225-12, 225-13, 225-14, 225-15, 225-24, 225-25, 225-33, 225-37, and ROP items 225-6, 225-7, and 225-8. These have been grouped in order to save duplicating the reasons for the negative responses.

– have always felt that his should be left to the individual local governments to control as they are the ones implementing the flood plain provisions and any amendments that are adopted at the Federal level.

– the adoption of pieces of the National Flood Protection Program requirements are an invitation to difficulty in administration of them at the local government level.

– these provisions are also influenced by the individual states. – any standard developed and promulgated at a national level would appear

to take precedence over any other standard issuing agency and therefore it is felt that the NFPA should not be determining federal regulations issues.

Those items related to seismic design criteria and related issues include, items 225-1, 225-2, 225-3, 225-4, 225-8, 225-9, 225-10, 225-18, 225-19, 225-20, 225-22, 225-23 and ROP items 225-2 and 225-3. These have been grouped in order to save duplicating the reasons for the negative responses.

– it would appear that there is insufficient statistical or testing data to be creating standards for manufactured homes in lieu of site built homes.

– the entire issue of on-site foundation systems is handled at the local governmental level and is also subject to the various individual state standards.

– the cost benefit to the ultimate consumer is a concern if all units have to be sited to meet these requirements.

– further the manufactured home it typically a one story dwelling with steel frame constructed strong enough to handle on the road delivery from factory to site. If the unit were to shift on a foundation it is felt that the unit has sufficient structural integrity to handle any seismic events that can be reasonably expected.

Mr. Porter voted negative stating:“Recent events have shown that when properly done our present 3 zones are

good enough – i.e., Palm Beach, FL – Providence – KY – and others. More details do not equal good enforcement.”

Mr. Walter voted negative stating: “My negative vote corresponds to three main issues addressed during the

current Fall 2004 revision cycle for NFPA 225, which are 1) wind load updates per ASCE 7 – 2002; 2 new flood hazard provisions per the NFIP; and 3) new seismic requirements per the IRC 2003 and NFPA 5000.

The TCC discussed these three issues at their meeting on June 16, 2004, in Washington, DC. There were a number of comments submitted to each issue. The comments corresponded to the Report on Proposal (ROP) items that were discussed on two occasions by the NFPA 501 Technical Committees (September 2003 and April 2004).

The following lists the comments voted on at the June 16th TCC meeting that I do not support that pertain to the three main issues highlighted above. The corresponding ROP item numbers are shown in quotations.

Wind load updates 225-17, 225-28, 225-29, 225-30, 225-31, 225-32, 225-34, 225-39 and 225-40

(ROP items 225-28 and 225-29) Flood provisions 225-5, 225-6, 225-7, 225-11, 225-12, 225-13, 225-14, 225-15, 225-16, 225-

24, 225-25, 225-33 and 225-37 (ROP items 225-6, 225-7 and 225-8) Seismic design criteria 225-1, 225-2, 225-3, 225-4, 225-8, 225-9, 225-10, 225-18, 225-19, 225-20,

225-22 and 225-23 (ROP items 225-2 and 225-3) The reasons for my negative to release the NFPA 225 ROC are as follows:Wind load updates: These proposals provide for four wind zones where the

present NFPA 501-2003 edition only has three wind zones. This can present problems for certain retailers when they market and install homes in three different wind zones. For instance, in certain areas of Florida, three wind zones (proposed WZ II, WZ III and WZ IV) occur within a 50-mile radius. These retailers will need to be trained in the art of installing homes to higher wind requirements.

Not only does the home cost increase but also the affect on the entire industry has to be determined by the proponent (cost/benefit analysis) before these proposals should go further through the NFPA process. What is the cost to train plant personnel to build to higher wind standards, to train installers on higher wind requirements, and to actually install the home to higher wind requirements?

While these proposals are based on ASCE 7-2002, do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual of State-based installation standards are performing well? It is generally the older manufactured homes and pre-HUD Code homes (mobile homes) with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena.

These proposals need further study, as there is the expected increase area of coverage of the new Wind Zone II area that causes the most concern. This is probably the largest single impact.

There are a number of ripple effects for these proposals. – Model floor designs will be deleted because of increased wind load

requirements (shear walls specification will undoubtedly change) – Costs increase to re-engineer all home designs that are affected – Increase costs associated but what are the benefits gained? – How does increased cost affect the potential homeownerʼs ability to

purchase the home? – DAPIA re-approval will be necessary for any floor plan affected by the

change and that cost will be borne to the consumer. – The cost analysis provided only applies to the home itself. However, other

costs associated with the change have not been considered such as cost to revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and training installers who install homes in higher wind zone areas where they have no experience.

Flood provisions: It is the manner in which the flood hazard criteria are being proposed for inclusion in NFPA 225 that presents a problem. The proposed chapter that contains the flood hazard area (FHA) requirements is basically one interpretation of the document the chapter was derived from the National Flood Insurance Program (NFIP) requirements. A proposal submitted on behalf of the MHI/MHARR Industry Task Force, attempted to provide the preferable method to incorporate FHA requirements by a straight reference to the NFIP regulations at 44 CFR 60.3.

If accepted, various provisions of the NFIP will be piece-mealed into the NFPA 225. The task force, which developed the proposed chapter on FHA requirements, only took what they thought was necessary to include in NFPA 225. There are still NFIP regulations contained in 44 CFR 60.3 that are not covered, and the proponent should identify why those provisions are not contained in the complete rewrite of the NFIP into the NFPA 225 document.

The AHJ already requires FHA assessment and conformance with the NFIP requirements. There is no reason to specify the detail provided in this proposal, as the AHJ would require enforcement of these or similar requirements on a State-by-State basis.

How will this document correlate with existing State promulgated FHA requirements? AHJs should have the ability to enforce what they consider necessary based on local experience. It is the authority of the AHJ to enforce these NFIP requirements, and not for an NFPA standard to require these NFIP regulations within its requirements, unless a straight reference is the choice of action.

One of the biggest fears is that these requirements will always be subject to

501-5

Report on Comments — Copyright, NFPA NFPA 501 change within the NFPA standards framework. If changes occur, the NFPA 225 could conceivably be more stringent than the current NFIP regulations. Any changes to NFIP regulations should follow the federal rulemaking process, and not be privy to a standards writing organization.

Seismic design criteria: The only analysis provided (on the day of the April 2004 TC-STR meeting) was a seismic event damage prediction for Sonoma, CA, the highest seismic design category proposed by these proposals. This minimal analysis, at best, was based on a HAZUS damage prediction software. It is unknown how manufactured homes are treated in this design tool as compared to other form of residential housing. Pre-code versus High Code buildings were used to translate to HUD Code homes. Pre-code are buildings under no seismic criteria, while High-code were buildings dedicated to resist the highest seismic requirements.

The proponent used foundation systems designs that are being considered under the FEMA 85 as a cost estimate. That average cost estimate between 1x and 2x HUD Code homes was $5,500. A typical installation cost is in the neighborhood of $1,500. Without a more extensive cost/benefit analysis, it appears that cost is of no consequence to the proponents, as a $4,000 increase in installation costs would certainly prevent many families from obtaining their own home.

The AHJ presently requires seismic design for foundation support systems, if necessary, and it may be best to leave this design consideration in this manner until a complete series of proposals with economic justification is available. This would be the first instance where seismic design for manufactured homes would be codified.

At present, the inclusion of the prescriptive pier/connection details may not be feasible to construct. If they are not feasible or workable solutions to the appropriate seismic connections necessary for proper support, then the only manner would be an engineered design for every home installation. This cost would be borne by the homeowner.

Report II was prepared by the Technical Committees on Manufactured Housing, and documents its action on the comments received on its Report on Proposals on NFPA 501, Standard on Manufactured Housing, 2003 edition as published in the Report on Proposals for the 2004 November Meeting.


This Report has also been submitted to letter ballot of the Technical Correlating Committee on Manufactured Housing, which consists of 14 voting members with 1 ballot not returned (Tomasbi). The ballot tally and reasons for negatives can be found below.

501-1 Log #4 Ghorbani, and Porter501-2 Log #35 Farish, Ghorbani, Gilchrist, Porter and Walter501-3 Log #2 Ghorbani, and Porter501-3a Log #45 (now TCC note to Comment 501-3 Log #2)501-4 Log #5 Ghorbani, and Porter501-5 Log #26 Ghorbani, and Porter501-6 Log #1a Ghorbani, and Porter501-7 Log #1b Ghorbani, and Porter501-8 Log #6 Farish, Ghorbani, Gilchrist, Porter and Walter501-9 Log #15 Farish, Ghorbani, Gilchrist, Porter and Walter501-10 Log #18 Farish, Ghorbani, Gilchrist, Porter and Walter501-11 Log #36 Farish, Ghorbani, Gilchrist, Porter and Walter501-12 Log #7 Farish, Ghorbani, Gilchrist, Porter and Walter501-13 Log #8 Farish, Ghorbani, Gilchrist, Porter and Walter501-14 Log #17 Farish, Ghorbani, Gilchrist, Porter and Walter501-15 Log #19 Farish, Ghorbani, Gilchrist, Porter and Walter501-16 Log #20 Farish, Ghorbani, Gilchrist, Porter and Walter501-17 Log #16 Farish, Ghorbani, Gilchrist, Porter and Walter501-18 Log #3 Ghorbani, and Porter501-19 Log #30 Farish, Ghorbani, Gilchrist, Porter and Walter501-20 Log #44 Farish, Ghorbani, Gilchrist, Porter and Walter501-21 Log #37 Farish, Ghorbani, Gilchrist, Porter and Walter501-22 Log #14 Ghorbani and Porter501-23 Log #CC1 Ghorbani and Porter501-24 Log #31 Ghorbani and Porter501-25 Log #39 Ghorbani and Porter501-26 Log #28 Ghorbani and Porter501-27 Log #29 Ghorbani and Porter501-28 Log #32 Ghorbani and Porter501-29 Log #40 Ghorbani and Porter501-30 Log #9 Farish, Ghorbani, Gilchrist, Porter and Walter501-31 Log #10 Ghorbani, Gilchrist, Porter and Walter501-32 Log #11 Ghorbani and Porter501-33 Log #21 Farish, Ghorbani, Gilchrist, Porter and Walter501-34 Log #22 Farish, Ghorbani, Gilchrist, Porter and Walter501-35 Log #23 Ghorbani and Porter501-36 Log #33 Ghorbani and Porter501-37 Log #34 Ghorbani and Porter501-38 Log #42 Ghorbani and Porter501-39 Log #43 Ghorbani and Porter

501-40 Log #38 Ghorbani and Porter501-41 Log #12 Farish, Ghorbani, Gilchrist, Porter and Walter501-42 Log #13 Farish, Ghorbani, Gilchrist, Porter and Walter501-43 Log #24 Farish, Ghorbani, Gilchrist, Porter and Walter501-44 Log #25 Farish, Ghorbani, Gilchrist, Porter and Walter501-45 Log #41 Ghorbani and Porter501-46 Log #27 Ghorbani and Porter

Mr. Farrish voted negative stating: 501-2 (Log #35) (ROP 501-6) I am voting negative on this for the same

reasons I did as a member of the TC: • I do not feel the difficulties in similar proposals have been resolved (ROP

501-6 vs. 501-10 vs. 501-49) • I am uncomfortable with the apparently poor resolution of single issues

given to multiple TCʼs. Additional problems have arisen since: • The new cost/benefit analysis, wile appreciated, seems flawed. • The case of HUD Zone I to NFPA Zone 2 was omitted. The cost

of this case (from the Task Force study) was $900/hone and would affect over 18,000 homes/year (based on 2001 production numbers).

•The CBR determined in Table 5 is not applied to estimated home production to determine if the “benefit” is positive or negative.

• The impact of addition zones in certain retail areas has not been studied for its effect on the cost of housing. (If a retailer is too close to several wind zones will she have to stock units for the more stringent zone and thereby skew the assumption that all homes in a certain zone are designed for that zone rather over-designed for the worst conditions?)

• The impact on home design has not been evaluated. Some design features (such as 9 foot sidewalls and/or 7:12 or higher roof pitches) are virtually impossible to convert to the existing HUD Zone II much less the new Zones 2, 3 or 4.

501-8 (Log #6) (ROP 501-10) See my Explanation of Negative on 501-2. 501-9 (Log #15) (ROP 501-10) See my Explanation of Negative on 501-2. 501-10 (Log #18) (ROP 501-10) See my Explanation of Negative on 501-2. 501-11 (Log #36) (ROP 501-10) See my Explanation of Negative on 501-2. 501-12 (Log #7) (ROP 501-11) While the hard work of some individuals

have addressed my major concerns as a member of the TC (cost/benefit, county-by-county breakdown, cross-references, etc.) I still must cast a negative vote for the following reasons:

• The “Damage Prediction” study appears flawed and incomplete: • The seismic event chosen (Richter = 8.2) is too severe. • The cost of repairs is not thoroughly investigated. • The definition of a home with “complete structural damage”

ignores the studies that have shown the relatively minor costs to repair a home that has merely fallen off its supports.

• No cost/benefits ratio explored. • Not enough study has been done for the reaction of a home properly

secured in accordance with HUD Wind Zone I standards to a seismic event. Even the PD&R study of the 1994 Northridge earthquake admitted that most damage homes were not anchored.

• While it is commendable that this proposal does not require approvals that show demonstrate that the home itself can withstand seismic loads it leaves the designer with insufficient guidance on how to prove that the connections to the foundation will withstand the loads.

501-13 (Log #8) (ROP 501-12) See my Explanation of Negative on 501-12. 501-14 (Log #17) (ROP 501-11) See my Explanation of Negative on 501-12. 501-15 (Log #19) (ROP 501-11) See my Explanation of Negative on 501-12. 501-16 (Log #20) (ROP 501-12) See my Explanation of Negative on 501-12. 501-17 (Log #16) (ROP 501-12) See my Explanation of Negative on 501-12. 501-19 (Log #30) (ROP 501-12) See my Explanation of Negative on 501-12. 501-20 (Log #44) (ROP 501-12) See my Explanation of Negative on 501-12. 501-21 (Log #37) (ROP 501-11) See my Explanation of Negative on 501-12. 501-30 (Log #9) (ROP 501-39) See my Explanation of Negative on 501-12. 501-33 (Log #21) (ROP 501-39) See my Explanation of Negative on 501-12. 501-34 (Log #22) (ROP 501-40) See my Explanation of Negative on 501-12. 501-41 (Log #12) (ROP 501-48) See my Explanation of Negative on 501-2. 501-42 (Log #13) (ROP 501-49) See my Explanation of Negative on 501-2. 501-43 (Log #24) (ROP 501-48) See my Explanation of Negative on 501-2. 501-44 (Log #25) (ROP 501-49) See my Explanation of Negative on 501-2.




I, and my organization which represents nearly 90 percent of the industryʼs

501-6

Report on Comments — Copyright, NFPA NFPA 501 production, feel very strongly that the time has come to re-evaluate the industryʼs participation in the NFPA process for manufactured housing code development and maintenance.”

Mr. Gilchrist voted negative stating: “The following are my negative votes and the items they relate to. These

have been grouped in order to save duplicating reasons for the negative responses.” Those items related to wind load updates and related issues include, items 501-2, 501-8, 501-9, 501-10, 501-11, 501-41, 501-42, 501-43, 501-44 and ROP items 501-6, 501-10, 501-48 and 501-49.

– feel that these items require further study before being incorporated for a number of reasons

– the cost benefit effect on the consumer, and the real effect on precluding families from being able to purchase and live in manufactured homes.

– the cost increases created for the manufacturer – the cost increases for retailing as it relates to multiple wind zones (as this

proposal is for four wind zones vs. the current 3 wind zones) – other than natural disasters (which no one can foresee), arenʼt the standards

in the industry for set up and tie down adequately handling most normal situations and wind conditions. This should be determined prior to changing all of the wind zones and criteria.

Those items related to seismic design criteria and related issues include, items 501-12, 501-13, 501-14, 501-15, 501-16, 501-17, 501-19, 501-20, 501-21, 501-30, 501-31, 501-33, 501-34 and ROP items 501-11, 501-12, 501-39, and 501-40.

– it would appear that there is insufficient statistical or testing data to be creating standards for manufactured homes in lieu of site built homes.

– the entire issue of on-site foundation systems is handled at the local governmental level and is also subject to the various individual state standards.

– the cost benefit to the ultimate consumer is a concern if all units have to be sited to meet these requirements.

– further the manufactured home is typically a one story dwelling with steel frame constructed strong enough to handle on the road delivery from factory to site. If the unit were to shift on a foundation it is felt that the unit has sufficient structural integrity to handle any seismic events that can be reasonably expected.

Mr. Pauls voted negative stating: “Regarding Comment 501-3a, (now TCC note to Comment 501-3) after a

long history of debate on the topic of manufactured housing stair requirements, especially step geometry, the Administration Technical Committee and Technical Correlating Committee are apparently deadlocked or at an impasse. One group of committee members feels that the step geometry requirement should be consistent with the International Residential Code (IRC)—the 7 3/4 by 10 riser-tread requirement; one group does not even tolerate the IRCʼs compromised requirement and is tied to industryʼs insistence on a much lower standard—8 1/4 by 9 riser-tread requirement; and I (occasionally joined by other committee members) argue that there should be consistency in NFPA codes and standards which means that the NFPA 501 requirement should be the same as current editions of NFPA 5000, NFPA 101 and NFPA 101B—that is the 7 by 11 riser-tread requirement. Those arguing for a standard lower than other current NFPA documents have not presented good evidence for the lower standards.

The attempt to go with the compromise standard (similar to IRCʼs) failed Technical Committee ballot because of the combined opposition of those wanting something better and those wanting something less stringent. (In at least two cases, those opposing positions were taken as a result of explicit organizational policy.) Personally, I would have been willing to go with the compromise requirement if it were explicitly presented to consumers as a standard unsupported by research on usability and safety—plus a standard inconsistent with stair requirements applicable to almost all other new stairs, AND those consumers were given the clear option, by requirement, to have the “7-11” step geometry installed in their home. (In other words, truly informed consent would be the rule.) However some industry representatives refuse to budge on the matter of step geometry (except that NAHB, for other than manufactured homes, recently submitted a proposal—not accepted for NFPA 101 and NFPA 5000—for the compromise, 7 3/4 by 10 requirement to be used in place of the 7 by 11 requirement). Industry continues to misrepresent the space implications of step geometry; for example, at the TCC meeting, one member noted a 100 sq ft opening requirement whereas, in fact it is less than half this size—41.25 sq ft, even for the 7 by 11 step geometry with a 16-riser (15-tread), 9-ft floor-to-floor height. (The industry-favored 8 1/4 by 9 step geometry rule would require a 29.25 sq ft opening and the IRC-based compromise would require 32.5 sq ft.)

Three additional considerations; two-story manufactured houses are very rare and, with the rapidly dropping number of new manufactured homes built now, the issue of stairs internal to a manufactured housing unit may almost disappear. However, there will be cases on one-story manufactured homes over site-built basements. Also, there is the matter of many jurisdictions not even having an adopted “applicable building code.” Finally, there is the whole matter of the NFPA standards for manufactured housing simply being used as inputs to HUDʼs consensus standards process for revising its requirements; thus industry will have another “kick at this can” and will be able to gut the requirements in that relatively industry-dominated process. NFPA should stick

to what is best justified technically (and, moreover, consistent with its other standards) and leave the political compromises to the more political HUD process. Clearly, by the latest research (as well as other studies), the “7-11” standard is the best justified of the three standards within the current debate. The latest research, performed at the UK Building Research Establishment (BRE), clearly shows that the “7-11” gives the best performance when space is a significant restraint but it is not optimum for usability or safety. According to the BRE study, optimum performance is only seen with tread depths of about 13 to 15 inches; 11 inches of tread depth is merely a widely used minimum criterion that marks an apparent transition between a steeply sloping curve and a less-steeply sloped curve relating performance and tread depth.

For all these reasons, I vote negatively on the TCCʼs desperate effort to achieve a consensus on the stair requirements issue within the manufactured housing project. The matter should now go before the NFPA membership for its opinion and, for this, I believe it should consider recommending acceptance of my original proposal 501-7 which simply states, “4.14.1 General. Stairs shall comply with NFPA 5000 requirements applicable to one- and two-family dwellings.” For this, I urge those considering the matter to examine my comment 501-5 which provides the extensive rebuttal I prepared for the recent NAHB proposal, to NFPA 5000 and NFPA 101, to have the “7-11” rule changed to the compromise rule used in the IRC. This NAHB proposal failed badly within the NFPA 5000/NFPA 101 Residential Occupancies Technical Committee and will be out for public comment before the NFPA Fall Meeting where NFPA 501 will come before the NFPA membership generally.”

Mr. Porter voted negative stating: “There is simply no need to rebuild the box when the real problem is on

site. These boxes go down the road fine at 60+ mph. Redesigning the box will not improve set-up.”

Mr. Walter voted negatively stating: “My negative vote corresponds to two main issues addressed during the

current Fall 2004 revision cycle for NFPA 501, which are 1) wind load updates per ASCE 7 – 2002 and 2) new seismic requirements per the IRC 2003 and NFPA 5000.

The TCC discussed these two issues at their meting n June 16, 2004, in Washington, DC. There were a number of comments submitted to each issue. The comments corresponded to the Report on Proposal (ROP) items that were discussed on two occasions by the NFPA 501 Technical Committees (September 2003 and April 2004).

The following lists the comments voted on at the June 16th TCC meeting that I do not support that pertain to the two main issues highlighted above. The corresponding ROP item numbers are shown in quotations.

Wind load updates 501-2, 501-8, 501-9, 501-10, 501-11, 501-41, 501-42, 501-43, and 501-44

(ROP items 501-6, 501-10, 501-48 and 501-49) Seismic design criteria 501-12, 501-13, 501-14, 501-15, 501-16, 501-17, 501-19, 501-20, 501-21,

501-30, 501-31, 501-33 and 501-34 (ROP items 501-11, 501-12, 501-39 and 501-40)

The reasons for my negative to release the NFPA 501 ROC are as follows:Wind load updates: These proposals provide for four wind zones where the

present NFPA 501-2003 edition only has three wind zones. This can present problems for certain retailers when they market and install homes in three different wind zones. For instance, in certain areas of Florida, three wind zones (proposed WZ II, WZ III and WZ IV) occur within a 50-mile radius. These retailers will need to be trained in the art of installing homes to higher wind requirements.

Not only does the home cost increase but also the affect on the entire industry has to be determined by the proponent (cost/benefit analysis) before these proposals should go further through the NFPA process. What is the cost to train plant personnel to build to higher wind standards, to train installers on higher wind requirements, and to actually install the home to higher wind requirements?

While these proposals are based on ASCE 7-2002, do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual of State-based installation standards are performing well? It is generally the older manufactured homes and pre-HUD Code homes (mobile homes) with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena.

These proposals need further study, as there is the expected increase area of coverage of the new Wind Zone II area that causes the most concern. This is probably the largest single impact.

There are a number of ripple effects for these proposals. – Model floor designs will be deleted because of increased wind load

requirements (shear walls specification will undoubtedly change) – Costs increase to re-engineer all home designs that are affected – Increase costs associated but what are the benefits gained? – How does increased cost affect the potential homeownerʼs ability to

purchase the home? – DAPIA re-approval will be necessary for any floor plan affected by the

change and that cost will be borne to the consumer. – The cost analysis provided only applies to the home itself. However, other

costs associated with the change have not been considered such as cost to revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and training

501-7

Report on Comments — Copyright, NFPA NFPA 501 installers who install homes in higher wind zone areas where they have no experience.

Seismic design criteria: The only analysis provided (on the day of the April 2004 TC-STR meeting) was a seismic event damage prediction for Sonoma, CA, the highest seismic design category proposed by these proposals. This minimal analysis, at best, was based on a HAZUS damage prediction software. It is unknown how manufactured homes are treated in this design tool as compared to other forms of residential housing. Pre-code versus High Code buildings were used to translate to HUD Code homes. Pre-code are buildings under no seismic criteria, while High-code were buildings dedicated to resist the highest seismic requirements.

The proponent used foundation systems designs that are being considered under the FEMA 85 as a cost estimate. That average cost estimate between 1x and 2x HUD Code homes was $5,500. A typical installation cost is in the neighborhood of $1,500. Without a more extensive cost/benefit analysis, it appears that cost is of no consequence to the proponents, as a $4,000 increase in installation costs would certainly prevent many families from obtaining their own home.

The AHJ presently requires seismic design for foundation support systems, if necessary, and it may be best to leave this design consideration in this manner until a complete series of proposals with economic justification is available. This would be the first instance where seismic design for manufactured homes would be codified.

At present, the inclusion of the prescriptive pier/connection details may not be feasible to construct. If they are not feasible or workable solutions to the appropriate seismic connections necessary for proper support, then the only manner would be an engineered design for every home installation. This cost would be borne by the homeowner.

In another TCC comment, the manufacturer is already required to provide one method to install the manufactured home in its installation manual. This particular proposal would require an additional installation method to be contained in that document to cover seismic design even if the home will not be installed in a seismic active area, such as SDC D or E. The manufacturer has no way of knowing where the home final installation will be. Why should the manufacturer have to spend the time to perform this function for every single floor plan, since the final installation site is not known? This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual. These costs will ultimately be borne by the potential homeowner.

States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seismic active areas, such as California, but they use a system that will not be recognized by these series of changes implement seismic criteria. One such system is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensure that during a seismic event, the home may displace from its pier supports but will be prevented from falling to the ground by the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 TCC. Provisions should be included in the seismic proposal for an alternate method of construction to include the ERBS system, if all the seismic proposals move forward through the process.”

Report III was prepared by the Technical Committees on Manufactured Housing, and documents its action on the comments received on its Report on Proposals on NFPA 501A, Standard for Fire Safety Criteria for Manufactured Home Installations, Sites, and Communities, 2003 edition as published in the Report on Proposals for the 2004 November Meeting.


This Report has also been submitted to letter ballot of the Technical Correlating Committee on Manufactured Housing, which consists of 14 voting members with 1 ballot not returned (Tomasbi). The ballot tally can be found below.

501A-1 Log #1 Ghorbani501A-2 Log #2 Ghorbani




I, and my organization which represents nearly 90 percent of the industryʼs product, feel very strongly that the time has come to re-evaluate the industry s̓ participation in the NFPA process for manufactured housing code development and maintenance.”

501-8

Report on Comments — Copyright, NFPA NFPA 501 _______________________________________________________________501-1 Log #4 MAN-ADM Final Action: Reject(4.5.2.2) _______________________________________________________________Submitter: Jon Nisja, Northcentral Regional Fire Code Development CommitteeComment on Proposal No: 501-5Recommendation: Reconsider the original proposal as submitted.Substantiation: NFPA 101 and NFPA 5000 and all the national model build-ing codes have required a minimum hallway width for years. There has been no technical substantiation for why these housing units should be considered dif-ferently than any other dwelling unit. Committee Meeting Action: Reject Committee Statement: The substantiation does not support the recommenda-tion. Proposal 501-5 pertains to doors and the substantiation addresses hallway width. Number Eligible to Vote: 9Ballot Results: Affirmative: 9 _______________________________________________________________501-2 Log #35 MAN-STR Final Action: Reject(4.5.3.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-6Recommendation: Reconsider the action on this proposal. Substantiation: This comment has been generated because the TCC ballot did not confirm the Technical Committee action on respective proposal. The reason for negative votes are as follows: Mr. Farish voted negatively stating: Since this was not a segmented ballot I am forced to vote negative due to the problems with only a few of the proposals. • I do not feel the difficulties in similar proposals have been resolved (such as the two wind proposals, 501-6 (Log #1), and 501-10 (Log #29), and 501-49 (Log #15a). • I am uncomfortable with the apparently poor resolution of single issues given to multiple TCʼs (such as 501-41 (Log #5b). • There is not a good correlation between proposals that addressed similar issues in different areas (such as the seismic proposals in 501-11 (Log #30), 501-40 (Log #5a), and 501-41 (Log #5b). Mr. Ghorbani voted negatively on the entire document stating: Represing the views and interest of MH producers, I continue to remain uncomfortable with what these changes would do to the affordability aspect of these homes. To vote affirmative on these proposals, I need to see more data and factual numbers on cost vs. benefits that these changes would bring to these homes. In addition, there are several discrepencies on these proposals on such things as correlating with related items and imposition on the authority of the local jurisdictions. Mr. Tomasbi voted negatively stating: 501-6 and 501-10: Wind updates are not based on most current ASCE7. Mr. Walter voted negatively stating: More than one Technical Committee had the opportunity to comment on the changes that involve wind requirements, and their reactions and decisions were not coordinated between them. In addition, there are no economic benefit-cost analyses to accompany the proposed significant increases in standards for wind and seismic safety. The following items are particularly troublesome, and therefore I am com-pelled to vote negative on the package, since there was not a segmented ballot: Proposal 501-6 (Log #1) 1. This proposal should be rejected since it is based on the provisions of ASCE 7-1998. 2. A TC-STR task group was formed to develop a package of proposals for the current F2004 cycle to address the topic of wind design for NFPA 501. That task group proposal was submitted as item 501-10 (Log #29). 3. If there is to be any update of the current NFPA 501 standard for wind load design, the most current nationally recognized consensus document should be used. That happens to be ASCE 7-2002. Item 501-10 used this document as the basis for proposed wind load revisions.Committee Meeting Action: Accept in Principle The Technical Committee has followed the TCCʼs recommendation to recon-sider the action on Proposal 501-6. By voting accept in principle on Comment 501-2 (Log #35), the Technical Committee reaffirms the Technical Committee ROP ballot action taken on Proposal 501-6, as reflected in the ROP.Committee Statement: In this comment, the Technical Committee reaffirms their commitment to providing the most current wind requirements in NFPA 225 and NFPA 501. Since Proposal 501-6 recommended using up-to-date wind requirements, the Technical Committee accepted the proposal in principal, but, in their Committee Statement, deferred to the complete set of coordinated pro-posals developed by the Wind Task Group for the F2004 cycle, which included Proposal 501-10 (Log #29) and Proposal 225-29 (Log #72a). By taking this action on Comment 501-2- (Log #35), the Technical Committee is, again, effectively eliminating Proposal 501-6 in favor of Proposal 225-29 and Proposal 501-10.

In addition, the Technical Committee has the following responses to each of the TCCʼs negative votes. Mr. Farish: The Committee Statement on Proposal 501-6 indicates that the Technical Committee has put forward two coordinated wind design proposals which are based upon ASCE 7-02 -- Proposal 501-10 (Log #29) and Proposal 225-29 (Log #72a). In addition, Proposal 501-49 (Log #15a) adopts ASCE 7-02. By ʻaccepting in principal ̓Proposal 501-6, the Technical Committee was calling attention only to the fact that they were committed to updating the wind requirements to the latest standard. Mr. Ghorbani: An economic analysis is provided in committee statement on Comment 501-11 (Log #36). The Technical Committee notes that the proposed wind requirements do not adversely affect the AHJʼs authority. Mr. Tomasbi: See explanation above. Mr. Walter: Introductory comment: It is this Technical Committeeʼs understanding that MAN-ADM has deferred to MAN-STR on these topics. The economic analysis is provided in committee statement on Comment 501-11 (Log #36). Item 1: See explanation above. Item 2: See explanation above. Item 3: See explanation above.Number Eligible to Vote: 16Ballot Results: Affirmative: 12 Negative: 2 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: Clearly the TCC believes that the proposed change is not in the best interest of affordable housing. The TC has disregarded the signals from the TCC and the needs of affordable housing in favor of overly burdensome requirements. KINARD: Wind zone changes not supported by substantial cost benefit anal-ysis. No economic impact analysis performed See comments on 501-10._______________________________________________________________501-3 Log #2 MAN-ADM Final Action: Accept in Principle(4.14) _______________________________________________________________ TCC Note: The TCC (MAN-AAC) directs that the final action on com-ment 501-3 be reported as Accept in Principal and specifically adds a new section to read “4.14 Stairs. Stairs shall comply with the applicable building code.” The remaining sections are to be renumbered accordingly. In taking this action the TCC notes that NFPA 501 lacked requirements regarding stairs. The TCC submitted public comment 501-3 which direct-ed the Technical Committee on Administration (MAN-ADM) to specifically address requirements concerning stairs. While MAN-ADM addressed this comment and developed language for inclusion in NFPA 501, the comment was rejected because the ballot was not successful. To provide needed information concerning stairs for manufactured housing, the TCC directed this action during its ROC meeting. This TCC action supersedes the actions of MAN-ADM on this comment.

Note: The Technical Committee on Administration (MAN-ADM) letter ballot did not support the meeting action on this comment. Therefore, the action of MAN-ADM on this comment is Reject. Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-7Recommendation: The TCC directs that MAN-ADM specifically address requirements concerning stairs for NFPA 501 during the ROC stage of the documentʼs revision cycle. Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Accept in Principle Add a new section 4.1.4 entitled Stairways to read as indicated below and renumber existing sections 4.1.4 through 4.1.7 accordingly. 4.1.4 Stairways 4.1.4.1 Dimensional Criteria. Dimensional criteria for stairs shall be as fol-lows: Maximum height of riser: 7 3/4 inches Minimum height of riser: 4 inches Minimum tread depth: 10 inches Minimum headroom: 6 feet 8 inches Maximum height between landings: 12 feet Minimum width clear of all obstructions, except projections not more than 4 1/2 inches at or below handrail height on each side: 36 inches 4.1.4.2 Winders. Winders shall be permitted in stairs. Winders shall have a tread depth of not less than 6 in. (15.2 cm) and a tread depth of not less than 10 in. at a point 12 in. (30.5 cm)from the narrowest edge. Committee Statement: The committee proposes the following requirements on stairways as a compromise between the current requirements of NFPA 5000 and requirements currently imposed by various state building regulations regarding residential construction. The proposed dimensions regarding stair-ways are also provide a degree of consistency with prevailing codes regarding 1 and 2 family dwellings. Number Eligible to Vote: 9Ballot Results: Affirmative: 5 Negative: 4 Explanation of Negative: GHORBANI: We keep voting on these proposals - and they continue to be revived. Frankly, more and more members of our industry are beginning to wonder whether the NFPA process is suitable to the unique character of our

501-9

Report on Comments — Copyright, NFPA NFPA 501 industryʼs product - manufactured homes. This is particularly true in recent years as the NFPA committees and subcommittees continue to be stacked against the industry, thus drowning the manufactured housing industry repre-sentatives ̓voices and votes on these crucial proposals. As the separation between the Federal standards (3280/installation) and NFPA (501/225) continues to widen - with the former maintaining a balance between affordability and consumer protection while the latter rapidly becom-ing gold-plated and unusable - the question that the industry and its consumers face is that whether or not the time, effort and money that they expend partici-pating in the NFPA process are worth their while. I, and my organization which represents nearly 90 percent of the industryʼs production, feel very strongly that the time has come to reevaluate the indus-tryʼs participation in the NFPA process for manufactured housing code devel-opment and maintenance. GILCHRIST: No justification or economic benefit to user. GORMAN: No justification exists for such radical geometry. Too many floor plans would be eliminated as a result. PAULS: The ADM TC actions on both Comment 501-3 and Comment 501-5 are unacceptable. This is especially the case as the step geometry standard recommended by the TC is exactly the one that was rejected overwhelmingly when it was proposed for NFPA 101 and NFPA 5000 (both of which are on cycles six months behind that of NFPA 501). It is interesting that the proposals rejected for NFPA 101 and 5000 had more justification than the ADM TC has provided for its actions on 501-3 and 501-5 yet, even then, the proposal was soundly disapproved. Thus, if there is to be a different standard for manufac-tured housing, it should be much better justified than done by the Technical Committee. See also the detailed statement given by Jake Pauls in Comment 501-5 for fuller information on the recent action for NFPA 101 and 5000.Comment on Affirmative JONES: 1. The numbering scheme shown in the committee action on this comment is incorrect. “4.1.4” should be “4.14”, etc. 2. As directed at the April 20th MAN-ADM meeting, I have drafted addi-tional stair geometry language for consideration by the TC and TCC, shown below. The plain text was accepted at the April 20, 2004 MAN-ADM meeting. Underlined text has been proposed by Jones in this ballot comment: 4.14 Stairways 4.14.1 Dimensional criteria for stairs shall be as follows.Maximum height of risers: 7 3/4 in. (19.7 cm)Minimum height of risers: 4 in. (10.2 cm)Minimum tread depth: 10 in. (25.4 cm)Minimum headroom: 6 ft 8 in. (203 cm)Maximum height between landings: 12 ft (3.7 m)Minimum width clear of all obstructions, except projections not more than 4 1/2 in. (11.4 cm) at or below handrail height on each side: 36 in. (91 cm)Riser and tread dimensions shall be measured in accordance with 4.14.4.4. 4.14.2 Winders. Winders shall be permitted in stairs. Winders shall have a tread depth of not less than 6 in. (15.2 cm) and a tread depth of not less than 10 in. (25.4 cm) at a point 12 in. (30.5 cm) from the narrowest edge. 4.14.3 Curved Stairs. Curved stairs shall be permitted as a component in a means of egress, provided that the depth of tread is not less than 10 in. (25.4 cm) at a point 12 in. (30.5 cm) from the narrower end of the tread and the smallest radius is not less than twice the stair width. 4.14.4 Stair Details 4.14.4.1 Permanent Construction. All stairs serving as required means of egress shall be of permanent fixed construction. All walking surfaces of a stair-way, including platforms and landings, shall be capable of supporting the same live and dead loads as the floors of the home. 4.14.4.2 Tread and Landing Surfaces. Stair treads and landings shall be solid, without perforations, and free of projections or lips that could trip stair users. Exception: The requirement for solid treads and landings shall not apply to noncombustible grated stair treads and landings 4.14.4.3 Profile. Where solid risers are used and where the tread depth is less than 11 in (27.9 cm), a nosing not less than 3/4 inch (19 mm) but not more than 1 1/4 inch (32 mm) shall be provided. Beveling or rounding of tread nosings shall not exceed 1/2 in. (1.3 cm) in horizontal dimension. Where non-vertical risers are used, risers shall be permitted to slope under the tread at an angle not to exceed 30 degrees from vertical, but the permitted projection of the nosing shall not exceed 1 1/2 in. (3.8 cm). 4.14.4.4 Riser Height and Tread Depth. Riser height shall be measured as the vertical distance between tread nosings. Tread depth shall be measured horizontally between the vertical planes of the foremost projection of adjacent treads, and at a right angle to the treadʼs leading edge, but shall not include beveled or rounded tread surfaces that slope more than 20 degrees (a slope of 1 in 2.75). 4.14.4.5 Tread Slope. Tread slope shall not exceed 1/4 in./ft (2 cm/m) (a slope of 1 in 48). 4.14.4.6 Dimensional Uniformity. There shall be no variation in excess of 3/16 in. (0.5 cm) in the depth of adjacent treads or in the height of adjacent risers, and the tolerance between the largest and smallest riser or between the largest and smallest tread shall not exceed 3/8 in. (1 cm) in any flight. The greatest nosing projection shall not exceed the smallest nosing projection by more than 3/8 inch (9.5mm) between two stories, including the nosing at the level of floors and landings.

Substantiation and Discussion: Stair geometry arguments in NFPA 501 have been long-standing and divisive, with the net result being NFPA 501 contains no explicit stair geometry require-ments. This omission is unacceptable and unsafe. The arguments can be sum-marized as follows: 1) the industry believes the 8 1/4 – 9 riser-tread geometry currently in use is adequate and justified, and 2) the NFPA membership has gone on record supporting the 7 – 11 geometry, and this is contained in NFPA 5000 and NFPA 101. The 7 3/4 - 10 language accepted at the April 20, 2004 MAN-ADM meeting (plain text above), and the additions proposed above (underlined text), strive to achieve a compromise that provides stair geometry provisions generally consis-tent with NFPA 5000/101, except for the riser-tread dimension which is consis-tent with that contained in the prevailing one-and two-family dwelling code. The 7 3/4 - 10 requirement may not be identical to that contained in NFPA 5000 and 101, but the language proposed for NFPA 501 section 4.14 should be supported by members as a viable compromise which eliminates a dangerous stair geometry omission from the 501 document._______________________________________________________________501-4 Log #5 MAN-ADM Final Action: Reject(4.14) _______________________________________________________________Submitter: Jon Nisja, Northcentral Regional Fire Code Development CommitteeComment on Proposal No: 501-7Recommendation: Reconsider the original proposal as submitted.Substantiation: NFPA 101 and NFPA 5000 and all the national model build-ing codes have required a minimum hallway width for years. There has been no technical substantiation for why these housing units should be considered differently than any other dwelling unit. Committee Meeting Action: Reject Committee Statement: The substantiation does not support the recommenda-tion. Proposal 501-7 pertains to stairs and the substantiation addresses hallway width. Also see Committee Action and statement for Comment 225-25 (Log #2).Number Eligible to Vote: 9Ballot Results: Affirmative: 9 _______________________________________________________________501-5 Log #26 MAN-ADM Final Action: Reject(4.14) _______________________________________________________________Note: The Technical Committee on Administration (MAN-ADM) letter ballot did not support the meeting action on this comment. Therefore, the final action on this comment is Reject. Submitter: Jake Pauls, Jake Pauls Consulting ServicesComment on Proposal No: 501-7Recommendation: Add new text as follows: 4.14 Stairs. 4.14.1 General. Stairs shall comply with NFPA 5000 requirements applicable to one- and two-family dwellings. Substantiation: As suggested by the TCC Action, there are deficiencies with the MAN-ADM Technical Committee action on proposal 501-7 that warrant TC reconsideration of the proposal during the public comment period. This public comment echoes the TCC action but more strongly and provides infor-mation on recent consideration of the step geometry issue (which is only one part of proposal 501-7—and the only part addressed by the TC) by the RES TC in response to a proposal on the step geometry issue from the National Association of Home Builders. That NAHB proposal recommended that NFPA 101 and NFPA 5000 revert to the prior rule for new dwelling unit stairs in NFPA 101, calling for a maximum rise of 7.75 inches and a minimum tread run of 10 inches. (Notably this NAHB proposal called for a better rule for step geometry than NAHB has otherwise been on record as supporting and advocat-ing nationally.) The result, at the ROP stage in terms of TC balloting was a 20 to one vote against the NAHB proposal so, unless there is a major reversal at the ROC stage, the “7-11” will remain the minimum requirement for new stairs in NFPA 5000, the specific code referenced in Proposal 501-7. Thus, the RES TC has moved dramatically from its earlier ballots on this issue in prior years. Perhaps one reason for the dramatic reversal of the RES position on the step geometry issue is the following written comment provided to RES TC members at its ROP meeting in February 2004. It is provided here as additional information for the MAN-ADM TC and for others interested in the topic of stairs in multi-level manufactured housing. A key issue relates to “Burden of Proof.” Much evidence in favor of the improved step geometry in particular was provided to the MAN ADM TC at the ROP stage of proposal 501-7 and, for reasons of length, it is not repeated in this comment. NAHB Proposal on NFPA 101 with Interspersed Comments (shown in Bold Text with a “JP” at the front of comment text) by Jake Pauls. The comments also apply equally to NAHBʼs proposal on NFPA 5000, the requirements for which have been printed with NFPA 501 proposal 501-7. Report on Proposals – May 2005 NFPA 101 101- Log #506 SAF-RES (24.2.5.1) Submitter: Matthew D. Dobson, National Association of Home Builders NAHB Recommendation: Riser heights not exceeding 7 3/4 in. (19.7 cm) and tread depths of not less than 10 in. (25.4 cm) shall be permitted. JP: How can it be that NAHB, which has a public policy of not advocat-ing anything better than the 8 1/4 - 9 riser-tread for adopted and enforced

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Report on Comments — Copyright, NFPA NFPA 501 code requirements,* is now recommending 7 3/4 – 10? Is it now prepared to drop such public policies that have effectively prevented not only enforced code requirements for 7 3/4 – 10, but has also apparently pre-vented builders from even giving home buyers the option of this step geometry or, even better, the option of the 7 – 11 step geometry for their new home stairs? Or is this proposal simply part of a scheme to degrade any stair safety requirement with which NAHB does not agree? * NAHB Policy, as of January 2004 when it was quoted from the NAHB web site (www.nahb.org/generic.aspx?sectionID=192&genericContentID=3093): “Support the adoption of traditional BOCA and CABO stair geome-try standards that set the maximum riser height at 8 1⁄4 inches and the minimum thread depth at 9 inches.” NAHB Substantiation: (1) During the last revision cycle NFPA̓ s 101 TCC overturned the NFPA SAF- RES TCʼs (TC) vote to reject a proposal to remove the exception that allows a 7 3/4” x 10” stair geometry in one- and two-family dwellings. This was done in part to coordinate with NFPA 5000. However, the TCC also justified their action based on the response to their request that the TC provide substantiation for maintaining the one- and two-family exception -- a request made despite the fact that the exception has been well established in the code and without any indication that the exception in any way compromises occupant safety. (1) JP: First, the claim that the exception had been “well established in the code” is inconsistent with the facts as the 1981 code had removed the exception and, repeatedly over more than 20 years the Means of Egress Technical Committee, has voted for a single standard for new stair geome-try, including the latest edition of NFPA 101B, the Means of Egress Code, for which the Means of Egress TC had jurisdiction over stairs in dwellings. Moreover, NFPA membership has repeatedly—and most recently, five times in succession, voted in favor of a single standard—the “7-11” rule—for step geometry. Secondly, this claim that there was no indication that the exception compromised safety is inconsistent with facts. There had been repeated proposals over a period of about 20 years for upgrading the residential stair geometry requirement based on safety; the most recent of the proposals was especially extensive and detailed with lots of documenta-tion. This included information showing that, for stairs—notably in homes, comprehensive, societal injury costs greatly exceeded the cost of new stair construction—by about a factor of ten! Thus there has been ample evi-dence—and recognition of that evidence by a larger group in NFPA than its Residential TC—that the exception indeed did compromise occupant safety. (2) Why was a request made of a technical committee to substantiate a provi-sion that was already a part of the code? Such a request was unreasonable and inappropriate especially given the TC had already provided the proper substan-tiation in support of their action to reject the proposal to remove the exception. That decision was based on the obvious lack of substantiation for removing the exception to begin with. (2) JP: As noted above, the Residential TC has repeatedly failed to pro-vide adequate substantiation for rejecting proposals to remove the excep-tion and this was proving an embarrassment within NFPA generally, espe-cially when the Means of Egress TC has consistently confirmed the validity of the “7-11” requirement for stair safety generally—and no proponent, including NAHB, has successfully attempted to dissuade the Means of Egress TC from this position. Thus the behavior of the Residential TC has become increasingly inconsistent with the more-knowledgeable Means of Egress TC as well as with the broader judgment of Technical Correlating Committees (and the Task Group set up by the BLD TCC), the Standards Council and repeated NFPA membership votes. Even when specifically requested, by the Standards Council, to do a better job of justifying the exception, the Residential TC failed to do so. Compounding the TCʼs error is NAHBʼs ludicrous claim (repeated in the current proposal) that the “decision was based on the obvious lack of substantiation for removing the exception to begin with.” The proposals which finally led to the changes in the 2003 editions of NFPA 101 and NFPA 5000, as well as an earlier change to NFPA 101B, were all more extensive than NAHB has put together for the current proposal to significantly reduce the NFPA requirement. (3) During the last revision cycle the TC overwhelmingly supported main-taining the exception by a vote of 17 to 2. In fact, upon evaluation of substan-tial information submitted by the proponent on this issue the TC concluded, “No technical justification has been provided to indicate the proposed 7:11 stair geometry will reduce the number of injuries occurring on stairs.” (3) JP: The noted 17-2 vote was not the only vote. Others show better support for deletion of the exception. Also, see previous comment on the problem with the TC statement about “No technical justification.” These claims about the quality of TC opposition are inconsistent with the facts. (4) The burden of proof is the obligation of the proponent of a proposed code amendment. The TC clearly, appropriately and with proper substantiation deter-mined that that burden was not met when deliberating over the proposal to remove the exception for one- and two-family occupancies. (4) JP: If “ the burden of proof is the obligation of the proponent of a pro-posed code amendment ” then surely that criterion also applies to NAHB. But, with this current proposal, NAHB appears to ignore this criterion or, alternatively, NAHB sees itself as being immune from fair procedures for code development. Given that NAHB has such unfair advantages in the ICC process as well as in the state and local code adoption process, it is not surprising that it wants a similar set of trump cards in the NFPA process.

As more evidence of the latter, see for example the NAHB web site for a letter (April 2002) and a policy resolution (#5, September 2003) regarding NAHBʼs opposition to NFPA 5000 because NAHB did not get the same unfair power in the NFPA process as ICC gave it for the IRC. Key in all of this is NAHBʼs inability to understand, in any but an apparent selfish or short-sighted fashion, the true nature of benefit, cost and affordability issues. (See also last comment below on the affordability issue.) (5) This exception has been in place for years without any specific data indi-cating that the 7 3/4” x 10” geometry is a problem or that a 7” x 11” geometry will result in any improvement to life safety. Furthermore, with respect to the issue of different geometries for different occupancies, different requirements for similar elements in different occupancies is a fundamental aspect of build-ing codes and standards. (5) JP: NAHB fails to recognize that NFPA has differing requirements based on the assumption that no significant life safety problems result from a lower standard for certain situations such as low-occupancy, limit-ed-use industrial stairs. It has become increasingly clear to many in NFPA (not including some members of the Residential TC) that the lower stan-dard of stair design for means of escape in residential occupancies is not without severe consequences to life safety as well as growing consequences for usability of homes for the aging population (a factor especially relevant to NFPA 5000 in which usability is an explicit goal). Thus NFPA is simply the first of the model code groups to recognize that the “fundamental aspect of building codes and standards” cannot be applied indiscriminate-ly. Indeed this was a recommendation of American Public Health Association Public Policy 200019 directed to both NFPA and ICC. NAHB has not challenged the growing technical consensus, based for example on testing of various step geometries in the USA, Canada, Britain and elsewhere, documenting the improved usability and safety of increased tread depths and reduced riser heights. The current proposal does not rec-ognize, for example, the recent—and continuing—work being done by Mike Roys at the Building Research Establishment in the UK, with fund-ing from UK building code authorities which has been noted in recent pro-posals by Pauls on the step geometry topic. NAHB has not even given the home buying public the opportunity to choose between homes built to the traditional “fundamental” assumption that home stairs had to be worse than found in other buildings used by consumers and the homes built to meet the usability and safety needs of their users. Thus NAHBʼs claims that it merely builds what the buyers want is false and, in such cases, code-making bodies like NFPA have a soci-etal obligation to step in and impose requirements. (6) The codes governing the interior of dwelling units have many provisions that vary from those for public spaces and other occupancies for very justifi-able reasons and stair geometry is no different. JP: See foregoing comments (on item 5). Also, if there are “justifiable reasons” why does NAHB not provide them and document them? After all, it was NAHB—in this very proposal (item 4)—that stated : “The burden of proof is the obligation of the proponent of a proposed code amendment.” Stair geometry is different and NAHB apparently cannot demonstrate other-wise—especially in the more-fair process offered by NFPA in contrast to the NAHB-dominated ICC IRC process development and the builder-dom-inated state and local code-adoption process. Moreover, quite aside from the disproportionate number of builders on the IRC committees, there is the severe restriction of testimony time in the ICC process: two minutes for presentation and one minute for rebuttal—significantly less than the ten minutes permitted in the NFPA process. In effect ICC has a system of sound-bit code development which means that larger issues like step geom-etry simply get short shrift. (7) Finally, the removal of the exception was in complete disregard to hous-ing affordability which is especially disturbing when, like in this instance, no demonstrated improvement to occupant safety has been made. Unjustified increases in the cost of housing is a disservice to public welfare. (7) JP: If it were correct that “ Unjustified increases in the cost of housing is a disservice to public welfare ,” then how does the NAHB justify the rela-tively huge increases that are associated with the builders ̓increase in average home size over the last few decades. Such increases—of about 1200 square feet on average combined with more-recent increases in aver-age ceiling height of a foot or two or more—amount to about a one hun-dred times greater impact than the several square feet of additional home area required for the “7-11” step geometry (as clearly documented in all of Pauls ̓recent proposals). If, as NAHB now claims, the increases in the cost of housing from the change to “7-11” are a “disservice to public welfare, then how does it justify a hundred times greater impact—with no resulting improvement in building safety—from the greatly increased home sizes and ceiling heights? Specifically, neither NAHB nor Residential TC members have challenged the benefit-cost analyses that were provided in very extensive form in Pauls ̓proposals that led to the change to the “7-11” step geometry for dwellings. Nor have they challenged in detail the extensive information provided in Pauls ̓proposals related to the increased usability and safety of stairs with the better step geometry. (8) We therefore respectfully request the TC accept this proposal and rein-state the exception based on the long history of sound justification for the exception and because there is no proper justification for the removal of it.

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Report on Comments — Copyright, NFPA NFPA 501 (8) JP: How are certain members of the Residential TC going to deal with the TCC, the Standards Council and NFPA members (let alone Jake Pauls and other TC members) if they vote to accept this proposal with its dearth of justification, its inconsistent claims about fairness as well as its disregard for the relatively well-justified proposals that led to the current NFPA requirements? Arguing that there has been a “ long history of sound justification for the exception ” is not consistent with the evidence and it will, again and ultimately, not be convincing. (See for example, the justifi-cation provided for the 1985 edition of the Life Safety Code when the Residential TC (then a subcommittee) reversed the direction taken in the 1981 edition where the exception was removed as part of the change to the “7-11” step geometry rule in the Life Safety Code. This proposal—and the similar proposal for NFPA 5000 (log #898)— should be rejected for multi-ple reasons as provided in this comment. Generally, would the NAHB proponent and NAHB member of the NFPA Residential TC please explain why NAHB proposed the change for NFPA 5000 as well as for NFPA 101 when NAHB has publicly declared it would not participate in the development of NFPA 5000? Has NAHB had second thoughts on its policy of fighting against NFPA development of a model building code as well as its adoption? If so, why? Moreover, in the unlikely event that this proposal is accepted by NFPA, will NAHB then rescind its policy which calls for a much lower standard of stair geometry?Committee Meeting Action: Accept in Principle See Committee Action on Comment 225-25 (Log #2). Some provisions from NFPA 5000 are proposed for incorporation into NFPA 501. Committee Statement: See Committee Statement for Comment 225-25 (Log #2). The committee further notes its concern with the implication of all the requirements of NFPA 5000 regarding stairways for manufactured homes. The requirements of NFPA 5000 regarding stairways exceed those that are currently implemented in many parts of the United States for 1 and 2 family residences. Number Eligible to Vote: 9Ballot Results: Affirmative: 5 Negative: 4 Explanation of Negative: GHORBANI: See my Explanation of Negative Vote on Comment 501-3 (Log #2). GILCHRIST: No justification or economic benefit to user. GORMAN: See my Explanation of Negative on Comment 501-3 (Log #2). PAULS: See my Explanation of Negative Vote on Comment 501-3 (Log #2).

_______________________________________________________________501-6 Log #1a MAN-FIR Final Action: Accept in Part(5.3.1.1, 5.7.1.21, 10.2.14) _______________________________________________________________Submitter: Marcelo M. Hirschler, GBH InternationalComment on Proposal No: 501-8Recommendation: Revise text to read as follows: 5.3.1.1 The surface flame-spread index of interior-finish material shall not exceed the values shown in 5.3.2 when tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials. The surface flame-spread rating of interior-finish materials required by 5.3.2.5 and 5.3.2.6 shall be permitted to be determined in accordance with ASTM E 162, Standard Test Method for Surface Flammability of Materials Using a Radiant Heat Energy Source. Instead of determining a surface flame spread index of interior-finish materials in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, as required by 5.3.2.5 and 5.3.2.6, a radiant panel index of the same value shall be permitted to be determined in accordance with ASTM E 162, Standard Test Method for Surface Flammability of Materials Using a Radiant Heat Energy Source. 5.7.1.2.1 Loose-fill insulation, other than cellulose loose-fill insulation, that cannot be mounted in the NFPA 255 test apparatus without a screen or other artificial support, shall have a flame-spread rating flame spread index of 25 or less and a smoke-development factor smoke developed index of 450 or less when tested in accordance with CAN/ULC-S102.20M88. Cellulose loose fill shall comply with 5.7.1.2.2. 10.2.14 Class 1 Air Ducts and Air Connectors. Air ducts and air connectors having a flame spread index rating of not over 25 without evidence of contin-ued progressive combustion and a smoke-developed rating smoke developed index of not over 50 when tested in accordance with UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors. Substantiation: Flame spread index is used as the correct term instead of flame spread rating for NFPA 255. When dealing with ASTM E 162, the cor-rect term is radiant panel index and not flame spread index or flame spread rat-ing. This was changed in order to avoid confusing the terms. This comment contains the correct terminology and is not associated with any proposal. The Technical Committee should act on it when appropriate.Committee Meeting Action: Accept in Part Revise text to read as follows: 5.3.1.1 The surface flame-spread index of interior-finish material shall not exceed the values shown in 5.3.2 when tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials . The surface flame-spread rating index of interior-finish materials required by 5.3.2.5 and 5.3.2.6 shall be permitted to be determined in accor-dance with ASTM E 162, Standard Test Method for Surface Flammability of Materials Using a Radiant Heat Energy Source.

5.7.1.2.1 Loose-fill insulation, other than cellulose loose-fill insulation, that cannot be mounted in the NFPA 255 test apparatus without a screen or other artificial support, shall have a flame-spread rating flame spread index of 25 or less and a smoke-development factor smoke developed index of 450 or less when tested in accordance with CAN/ULC-S102.20M88. Cellulose loose fill shall comply with 5.7.1.2.2. 10.2.14 Class 1 Air Ducts and Air Connectors. Air ducts and air connectors having a flame spread index rating of not over 25 without evidence of contin-ued progressive combustion and a smoke-developed rating smoke developed index of not over 50 when tested in accordance with UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors . Committee Statement: The Technical Committee agrees with submitterʼs intent, but feels that the language provided by Technical Committee provides more clarity than the language offered by the submitter.Number Eligible to Vote: 13Ballot Results: Affirmative: 8 Abstain: 1Ballot Not Returned: 4 MENDLEN, RYAN, SLIFKA, WESSELExplanation of Abstention: MARUSKIN: Per instructions of FEMA General Council, I am not permitted to vote on Committee Actions.

_______________________________________________________________501-7 Log #1b MAN-MEC Final Action: Reject(5.3.1.1, 5.7.1.21, 10.2.14) _______________________________________________________________Submitter: Marcelo M. Hirschler, GBH InternationalComment on Proposal No: 501-8Recommendation: Revise text to read as follows: 5.3.1.1 The surface flame-spread index of interior-finish material shall not exceed the values shown in 5.3.2 when tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials. The surface flame-spread rating of interior-finish materials required by 5.3.2.5 and 5.3.2.6 shall be permitted to be determined in accordance with ASTM E 162, Standard Test Method for Surface Flammability of Materials Using a Radiant Heat Energy Source. Instead of determining a surface flame spread index of interior-finish materials in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, as required by 5.3.2.5 and 5.3.2.6, a radiant panel index of the same value shall be permitted to be determined in accordance with ASTM E 162, Standard Test Method for Surface Flammability of Materials Using a Radiant Heat Energy Source. 5.7.1.2.1 Loose-fill insulation, other than cellulose loose-fill insulation, that cannot be mounted in the NFPA 255 test apparatus without a screen or other artificial support, shall have a flame-spread rating flame spread index of 25 or less and a smoke-development factor smoke developed index of 450 or less when tested in accordance with CAN/ULC-S102.20M88. Cellulose loose fill shall comply with 5.7.1.2.2. 10.2.14 Class 1 Air Ducts and Air Connectors. Air ducts and air connectors having a flame spread index rating of not over 25 without evidence of contin-ued progressive combustion and a smoke-developed rating smoke developed index of not over 50 when tested in accordance with UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors. Substantiation: Flame spread index is used as the correct term instead of flame spread rating for NFPA 255. When dealing with ASTM E 162, the cor-rect term is radiant panel index and not flame spread index or flame spread rat-ing. This was changed in order to avoid confusing the terms. This comment contains the correct terminology and is not associated with any proposal. The Technical Committee should act on it when appropriate.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-ject matter of the comment is outside the committeeʼs scope and all action associated with this comment regarding the appropriateness of the term smoke developed index in section 10.2.14 is deferred to MAN-FIR. See Comment 501-6 (Log #1a) which was addressed by MAN-FIR for action on the subject matter associated with this comment. Number Eligible to Vote: 12Ballot Results: Affirmative: 10 Abstain: 2Explanation of Abstention: HEIMAN: I abstain from voting on the Document except 501-26 (Log #28), 501-27 (Log #29), and 501-46 (Log #27) that I vote “Affirmative with Comment” on because I have obligated myself through membership on the Heating Task Force. My reason for voting “Abstain” applies to the entire document because the membership of the NFPA 501 MAN-MEC does not meet the requirement for Consensus as required by the NFPA document, “Regulations for Annual 2005 and all preceding Revision cycles, Sections 3-2.4.2(C), and 3-2.5. Specifically, the present Committee of 11 members of which 9 are VOTING MEMBERS consists of 5 VOTING MEMBERS - 55.5% classified as “M” for “manufacturers interest. For purposes of clarification, Michael Zieman, Chair does not vote, nor has John Stevens of HUD ever voted. The maximum allow-able voting membership of a particular classification of a Technical Committee cannot exceed 33.3% of the voting members. The following copied from: NFPA “Regulations for Annual 2005 and all pre-ceding Revision cycles”

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Report on Comments — Copyright, NFPA NFPA 501 3-2.4.2 Action of the Council on Applications for Membership. The Council may appoint a nominee, hold the application pending further information, reject an application, or take such other action as it deems necessary. Appointment shall be based on: (a) Qualifications of the applicant under the provisions of 3-2.3 (b) Limiting the size of each TC and/or TCC to a manageable working group (c) Maintaining a balance of interests within the membership If any individual or organization has applied for and has been denied mem-bership, the individual or organization may, within a 60-day period after notifi-cation, file an appeal with the Council for purposes of reconsideration (see 1-6). 3-2.5 Representation of Interests. The Council shall determine the interests to be represented on TCs and TCCs. The Council may seek the recommendation of the TCC Chair and TC Chair in discharging this responsibility. No more than one-third of the voting Members shall represent any one interest. (Taken from Page 12 of 38 “Regulations for Annual 2005 and all preceding Revision cycles”) I HAVE PREVIOUSLY VOTED NO BECAUSE OF THIS PROBLEM ON THE PREVIOUS BALLOT OF NFPA 501, AND I HAVE NOT YET RECEIVED A RESPONSE. IT IS UNFORTUNATE THAT THE WORK AND COST OF THE PARTICIPATION OF THE MEMBERS OF THE COMMITTEE SHOULD NOT BE VALIDATED BECAUSE ACTION WAS NEVER TAKEN TO MEET THE REQUIREMENTS FOR TECHNICAL COMMITTEES SET BY THE ASSOCIATION. STEVENS: As a matter of policy, HUD personnel are directed not to vote but abstain due to potential conflict with the Improvement Act of 2000. Therefore record my vote across the board as “abstain” on all ballot items for MEC 225. _______________________________________________________________501-8 Log #6 MAN-STR Final Action: Reject(Chapter 6) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-10Recommendation: This proposal (all nine parts, pages 903-913) should be rejected.Substantiation: 1. These proposals provide for four wind zones where the present NFPA 501-2003 edition only has three wind zones. 2. These proposals are based on ASCE 7-2002 whereas the current NFPA 501 Standard is based on ASCE 7-1988. 3. Do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual or State-based installation standards are performing well. It is generally the older manu-factured homes with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena. 4. There are a number of ripple effects for these proposals. • Model floor designs will be deleted because of increased wind load require-ments (shear walls specification will undoubtedly change). • Costs increase to re-engineer all home designs that are affected. • Increase costs associated but what are the benefits gained? • How does increased cost affect the potential homeownerʼs ability to pur-chase the home? • A cost analysis (including C/B ratios) was provided by one producer, and how will other manufacturers be affected? • Cost to producers may increase considerably if the company uses engineer-ing consultants (contractors) to design homes. Some companies do not have an engineering staff like most large HUD Code home producers. • DAPIA re-approval will be necessary for any floor plan affected by the change and that cost will be borne to the consumer. • Is this criterion more stringent than the current criteria used to design mod-ular homes under the International Residential Code (IRC)? • The cost analysis provided only applies to the home itself. However, other costs associated with the change have not been considered such as cost to revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and train-ing installers who install homes in higher wind zone areas where they have no experience. 5. This item needs further study, as there is the expected increase area of cov-erage of the new Wind Zone II area that causes the most concern.Committee Meeting Action: Reject Committee Statement: Please note, the commenter has asked that the com-mittee action on Proposal 501-10 changed to ʻreject. ̓However, the TCC ROP ballot failed to uphold the Technical Committee ROP ballot action, so the cur-rent action on Proposal 501-10 is ʻreject. ̓However, in Comment 501-11 (Log #36), the Technical Committee reaffirms the technical committee ballot action taken on Proposal 501-10, as reflected in the ROP. Therefore, the Technical Committee has chosen to reject this comment, based upon the commenterʼs original intent. See Committee Statement on Comment 501-11 (Log #36) for responses to individual issues brought up by commenter. Number Eligible to Vote: 16Ballot Results: Affirmative: 9 Negative: 4 Abstain: 1Ballot Not Returned: 2 FARISH, MENDLEN

Explanation of Negative: BRYANT: Four wind zones would present unreasonable hardships for retail-ers when they market and install homes in perhaps three different wind zones (e.g., in certain areas of Florida, three wind zones would occur within a 50-mile radius. Cost/benefit analysis does not satisfactorily address the needs of affordable housing. The added cost of such a significant expansion of a revised “Wind Zone II” geographic area is excessive, especially in light of actual expe-rience in these areas. The cost analysis provided (on the day of the TC-STR meeting) was a wind event damage prediction. The analysis was said to be based on a HAZUS damage prediction software. It is not clear how manufac-tured homes are treated in this design tool as compared to other forms of resi-dential housing. HEROUX: •This proposal provides for four wind zones where the present NFPA 501-2003 edition only has three wind zones. This can present problems for certain retailers when they market and install homes in three different wind zones. For instance, in certain areas of Florida, three wind zones (proposes WZ II, WZ III and WZ IV) occur within a 50-mile radius. These retailers will need to be trained in the art of installing homes to higher wind requirements.• Not only does the home cost increase but also the affect on the entire industry has to be determined by the proponent (cost/benefit analysis) before this pro-posal should go further through the NFPA process. What is the cost to train plant personnel to build to higher wind standards, to train installers in higher wind requirements, and to actually install the home to higher wind require-ments?• While this proposal is based on ASCE 7-2002, do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual or State-based installation standards are per-forming well? It is generally the older manufactured homes and pre-HUD Code homes (mobile homes) with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena.• This item needs further study, as there is the expected increase area of cover-age of the new Wind Zone II area that causes the most concern. This is proba-bly the largest single impact of the wind proposal.• There a number of ripple effects for this proposal.- Model floor designs will be deleted because of increased wind load require-ments (shear walls specification will undoubtedly change)- Costs increase to re-engineer all home designs that are affected- Increase costs associated but what are the benefits gained?- How does increased cost affect the potential homeownerʼs ability to purchase the home?- A cost analysis (including C/B ratios) was provided by one producer, and how will others be affected?- DAPIA re-approval will be necessary for any floor plan affected by the change and that cost will be borne to the consumer.-The cost analysis provided only applies to the home itself. However, other costs associated with the change have not been considered such as cost to revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and train-ing installers who install homes in higher wind zone areas where they have no experience.• The only other cost analysis provided (on the day of the TC-STR meeting) was a wind event damage prediction. This minimal analysis, at best, was based on a HAZUS damage prediction software. It is unknown how manufactured homes are treated in this design tool as compared to other forms of residential housing.• Wind speeds looked at were HUD Code WZ II and WZ III. NFPA proposed wind speeds were Zone II, Zone III and Zone IV. There were a number of com-parisons run with one exception. This is what would be the effect by this mini-mal analysis (at best) of the changes from HUD Code WZI to NFPA Zone II, the biggest affected areas of coverage by this proposal. This analysis was not provided.• The wind zone changes compared to cost increases was performed by one member of the task force. But to make such a sweeping change based on one company should not be permitted. A full-blown analysis, like the one per-formed when the HUD Code changed from two wind zones to three wind zones needs to be undertaken. KINARD: The change from three wind zones to four wind zones causes increased cost to the customer without an extensive Cost/Benefit study. One manufacturer submitted some preliminary figures that show cost increases that I believe will put buyers of our homes out of the market without a substantial reason or justification. Also there is an increase in the coverage area of the new zone 2 that needs to be justified. All areas of building the home will experience increased cost and new training for plant personnel as well as set-up personnel. WELDY: •This proposal provides for four wind zones where the present NFPA 501-2003 edition only has three wind zones. This can present problems for certain retailers when they market and install homes in three different wind zones. For instance, in certain areas of Florida, three wind zones (proposes WZ II, WZ III and WZ IV) occur within a 50-mile radius. These retailers will need to be trained in the art of installing homes to higher wind requirements.• Not only does the home cost increase but also the affect on the entire industry has to be determined by the proponent (cost/benefit analysis) before this pro-posal should go further through the NFPA process. What is the cost to train plant personnel to build to higher wind standards, to train installers in higher wind requirements, and to actually install the home to higher wind require-ments?

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Report on Comments — Copyright, NFPA NFPA 501 • While this proposal is based on ASCE 7-2002, do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual or State-based installation standards are per-forming well? It is generally the older manufactured homes and pre-HUD Code homes (mobile homes) with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena.• This item needs further study, as there is the expected increase area of cover-age of the new Wind Zone II area that causes the most concern. This is proba-bly the largest single impact of the wind proposal.• There a number of ripple effects for this proposal.- Model floor designs will be deleted because of increased wind load require-ments (shear walls specification will undoubtedly change)- Costs increase to re-engineer all home designs that are affected- Increase costs associated but what are the benefits gained?- How does increased cost affect the potential homeownerʼs ability to purchase the home?- A cost analysis (including C/B ratios) was provided by one producer, and how will others be affected?- DAPIA re-approval will be necessary for any floor plan affected by the change and that cost will be borne to the consumer.-The cost analysis provided only applies to the home itself. However, other costs associated with the change have not been considered such as cost to revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and train-ing installers who install homes in higher wind zone areas where they have no experience.• The only other cost analysis provided (on the day of the TC-STR meeting) was a wind event damage prediction. This minimal analysis, at best, was based on a HAZUS damage prediction software. It is unknown how manufactured homes are treated in this design tool as compared to other forms of residential housing.• Wind speeds looked at were HUD Code WZ II and WZ III. NFPA proposed wind speeds were Zone II, Zone II and Zone IV. There were a number of com-parisons run with one exception. This is what would be the effect by this mini-mal analysis (at best) of the changes from HUD Code WZI to NFPA Zone II, the biggest affected areas of coverage by this proposal. This analysis was not provided.• The wind zone changes compared to cost increases was performed by one member of the task force. But to make such a sweeping change based on one company should not be permitted. A full-blown analysis, like the one per-formed when the HUD Code changed from two wind zones to three wind zones needs to be undertaken.Explanation of Abstention: JOHNS: See my Explanation of Abstention for Comment 501-11 (Log #36).Comment on Affirmative PABIAN: Although these comments would create a fourth wind zone, it brings the 501 standard in compliance with the more current ASCE-7 wind cri-teria. In areas where there may be as much as 3 different zones within one state there is certainly a training and information campaign that needs to take place in order to effectively implement the standard changes. There was a cost analy-sis submitted to committee for consideration however, the impact analysis need to be expanded to included the impact of the present Zone I change to the NFPA Zone II and a more broader analysis that may need to be performed sim-ilar to the one conducted for the ʻ94 wind changes to the HUD Standards. The analysis submitted by a committee member based on the HAZUS damage pre-diction software is a start but this should be expanded. Making changes to the Standard during difficult economic times is not a pleasant one but updating the requirements to the newer wind criteria does enhanced the Standard any vali-dates compliance with existing practices that are or have been adopted for other new buildings or structures. The impact cost analysis should also include the seismic and wind analysis, as there may be homes that can be installed in areas of the country where wind and seismic considerations may be impacted. The cost analysis should include the cost associated with engineering and training costs, and costs to revise design packages._______________________________________________________________501-9 Log #15 MAN-STR Final Action: Reject(Chapter 6) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: William Hug, CAVCO Industries, Inc.Comment on Proposal No: 501-10Recommendation: This proposal should be rejected.Substantiation: 1. There has been no economic analysis done to show that there is a cost benefit for this proposal. Specifically “The Act, as revised n 2000”, states in 602(b)(1), (2) and (5) state that Congress ̓purpose for the improvement of “The Act” was to protect affordability, facilitate the availabili-ty of affordable homes and to protect the residents of the homes with respect to personal injury, insurance costs, and property damage. This proposal is only looking at the last element of the equation. The entire Law must be looked at and the cost benefit is part of that. 2. Where is the burden of proof that there is a problem with the current stan-dard? Where is the facts that show this is needed other than it just isnʼt addressed. Where have there been problems with the homes that are installed in

Zone 1 and the new zone that is being proposed? Both of these will require large amounts of engineering work and cost for what benefit? There is no insurance savings since there hasnʼt been any major reported damage from nor-mal wind incidents. There needs to be a reason for this otherwise it is just an overkill that is only going to affect the consumer and not give him any benefit. 3. There will be engineering costs with this that smaller manufacturers will need to bear, since most do not have engineers on their staff, if they are to sell into these areas. This is a cost that will be passed onto the consumer, and may be out of proportion to the cost that larger manufacturers will pay. 4. This will change floor plans that currently can be built and will eliminate some. The cost of time and money just to update to the new zone 1 and 2 will be a drain on this industry that still hasnʼt recovered from the current downturn. 5. This needs to have further study to identify the cost benefits and what the real impacts are especially in the new Zone 1 and 2.Committee Meeting Action: Reject Committee Statement: Please note, the commenter has asked that the com-mittee action on Proposal 501-10 changed to ʻreject. ̓However, the TCC ROP ballot failed to uphold the Technical Committee ROP ballot action, so the cur-rent action on Proposal 501-10 is ʻreject. ̓However, in Comment 501-11 (Log #36), the Technical Committee reaffirms the technical committee ballot action taken on Proposal 501-10, as reflected in the ROP. Therefore, the Technical Committee has chosen to reject this comment, based upon the commenterʼs original intent. In addition, the Technical Committee has the following responses to each of the commenterʼs provided reasons. Item 1: An economic analysis is provided in committee statement on Comment 501-11 (Log #36). Item 2: The comment presents an opinion, which has not been substantiated by a design level event. Also, economic analysis shows that there is limited economic impact to Wind Zone 1. Item 3: There will be a one-time cost to reevaluate the designs. Item 4: See comment on Item 3. Item 5: An economic analysis is provided in committee statement on Comment 501-11 (Log #36). Number Eligible to Vote: 16Ballot Results: Affirmative: 9 Negative: 4 Abstain: 1Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-8 (Log #6). HEROUX: See my Explanation of Negative for Comment 501-8 (Log #6). KINARD: See my Explanation of Negative on Comment 501-8 (Log #6). WELDY: See my Explanation of Negative for Comment 501-8 (Log #6).Explanation of Abstention: JOHNS: See my Explanation of Abstention for Comment 501-11 (Log #36).Comment on Affirmative PABIAN: See my Affirmative with Comment on Comment 501-8 (Log #6)._______________________________________________________________501-10 Log #18 MAN-STR Final Action: Reject(Chapter 6) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-10Recommendation: This proposal (all nine parts, pages 903-913) should be rejected.Substantiation: 1. These proposals provide for four wind zones where the present NFPA 501-2003 edition only has three wind zones. 2. These proposals are based on ASCE 7-2002 whereas the current NFPA 501 Standard is based on ASCE 7-1988. 3. Do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual or State-based installation standards are performing well. It is generally the older manu-factured homes with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena. 4. There are a number of ripple effects for these proposals. • Model floor designs will be deleted because of increased wind load require-ments (shear walls specification will undoubtedly change). • Costs increase to re-engineer all home designs that are affected. • Increase costs associated but what are the benefits gained? • How does increased cost affect the potential homeownerʼs ability to pur-chase the home? • A cost analysis (including C/B ratios) was provided by one producer, and how will other manufacturers be affected? • Cost to producers may increase considerably if the company uses engineer-ing consultants (contractors) to design homes. Some companies do not have an engineering staff like most large HUD Code home producers. • DAPIA re-approval will be necessary for any floor plan affected by the change and that cost will be borne to the consumer. • Is this criterion more stringent than the current criteria used to design mod-ular homes under the International Residential Code (IRC)? • The cost analysis provided only applies to the home itself. However, other costs associated with the change have not been considered such as cost to

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Report on Comments — Copyright, NFPA NFPA 501 revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and train-ing installers who install homes in higher wind zone areas where they have no experience. 5. This item needs further study, as there is the expected increase area of cov-erage of the new Wind Zone II area that causes the most concern.Committee Meeting Action: Reject Committee Statement: See Committee Statement on Comment 501-8 (Log #6).Number Eligible to Vote: 16Ballot Results: Affirmative: 9 Negative: 4 Abstain: 1Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative on Comment 501-8 (Log #6). HEROUX: See my Explanation of Negative for Comment 501-8 (Log #6). KINARD: See my Explanation of Negative on Comment 501-8 (Log #6). WELDY: See my Explanation of Negative for Comment 501-8 (Log #6).Explanation of Abstention: JOHNS: See my Explanation of Abstention for Comment 501-11 (Log #36).Comment on Affirmative PABIAN: See my Affirmative with Comment on Comment 501-8 (Log #6).

_______________________________________________________________501-11 Log #36 MAN-STR Final Action: Reject(Chapter 6) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-10Recommendation: Reconsider the action on this proposal. Substantiation: This comment has been generated because the TCC ballot did not confirm the Technical Committee action on respective proposal. The rea-sons for TCC negative votes are as follows: Mr. Farish voted negatively stating: Since this was not a segmented ballot I am forced to vote negative due to the problems with only a few of the proposals. • I do not feel the difficulties in similar proposals have been resolved (such as the two wind proposals, 501-6 (Log #1), and 501-10 (Log #29), and 501-49 (Log #15a). • I am uncomfortable with the apparently poor resolution of single issues given to multiple TCʼs (such as 501-41 (Log #5b). • There is not a good correlation between proposals that addressed similar issues in different areas (such as the seismic proposals in 501-11 (Log #30), 501-40 (Log #5a), and 501-41 (Log #5b). Mr. Ghorbani voted negatively on the entire document stating: Represing the views and interest of MH producers, I continue to remain uncomfortable with what these changes would do to the affordability aspect of these homes. To vote affirmative on these proposals, I need to see more data and factual numbers on cost vs. benefits that these changes would bring to these homes. In addition, there are several discrepencies on these proposals on such things as correlating with related items and imposition on the authority of the local jurisdictions. Mr. Tomasbi voted negatively stating: 501-6 and 501-10: Wind updates are not based on most current ASCE7. Mr. Gilchrist voted negatively stating: Proposal 501-10 (Log #29) reject because this proposal provides for 4 wind zones when the existing NFPA 501 current edition uses 3 wind zones. Need to update together or in a coordinated fashion. Mr. Walter voted negatively stating: More than one Technical Committee had the opportunity to comment on the changes that involve wind and seismic requirements, and their reactions and votes were not coordinated between them. In addition, there are no econonmic benefit-cost analyses to accompany the proposed significant increases in stan-dards for wind, seismic and flood safety. Proposal 501-10 (Log #29) 1. These proposals provide for four wind zones where the present NFPA 501-2003 edition only has three wind zones. 2. These proposals are based on ASCE 7-2002 whereas the current NFPA 501 standard is based on ASCE 7-1998. 3. Do we really need to revise when homes subjected to natural disasters that are installed appropriately to the manufacturerʼs installation manual or state-based installation standards are performing well. It is generally the older manu-factured homes with non-maintained supporting mechanisms that fail or those involved in the direct path of the disaster phenomena. 4. There are a number of ripple effects for these proposals. • Model floors designs will be deleted because of increased wind load requirements (shear walls specification will undoubtedly change). • Costs increase to re-engineer all homes designs that are affected. • Increase costs associated but what are the benefits gained? • How does increased cost affect the potential homeownerʼs ability to pur-chase the home? • A cost analysis (including C/B ratios) was provided by one producer, and how will other manufacturers be affected? • Cost to producers may increase considerably if the company uses engineer-

ing consultants (contractors) to design homes. Some companies do not have an engineering staff like most large HUD Code producers. • DAPIA re-approval will be necessary for any floor plan affected by the change and that cost will be borne to the consumer. • Is this criterion more stringent than the current criteria used to design mod-ular homes under the International Residential Code (IRC)? • The cost analysis provided only applies to the home itself. However, other costs associated with the change have not been considered such as cost to revise design packages, DAPIA approval costs, engineering/training necessary for certain plants to comply with the higher wind zone requirements, and train-ing installers who install homes in higher wind zone areas where they have not experience. 5. This item needs further study, as there is the expected increase area of cov-erage of the new Wind Zone II area that causes the most concern.Committee Meeting Action: Accept in Principle The Technical Committee has followed the TCCʼs recommendation to recon-sider the action on Proposal 501-10. By voting accept in principle on Comment 501-11 (Log #36), the Technical Committee reaffirms the Technical Committee ROP ballot action taken on Proposal 501-10, as reflected in the ROP.Committee Statement: In this comment, the Technical Committee reaffirms their commitment to providing current wind requirements in NFPA 501. As part of this committee statement, the Technical Committee has included a prelimi-nary cost-benefit analysis on these recommended modifications. In addition, the Technical Committee has the following responses to each of the TCCʼs negative votes. 1. Mr. Farish: The Committee Statement on Proposal 501-6 indicates that the Technical Committee has put forward two coordinated wind design proposals which are based upon ASCE 7-02 -- Proposal 501-10 (Log #29) and Proposal 225-29 (Log #72a). In addition, Proposal 501-49 (Log #15a) adopts ASCE 7-02. By ʻaccepting in principal ̓Proposal 501-6, the Technical Committee was calling attention only to the fact that they were committed to updating the wind requirements to the latest standard. 2. Mr. Ghorbani: An economic analysis is provided with this committee state-ment. The Technical Committee notes that the proposed wind requirements do not adversely affect the AHJʼs authority. 3. Mr. Tomasbi: See explanation above. 4. Mr. Gilchrist: The Technical Committee has coordinated the proposed changes to the wind design requirements to incorporate the 4 wind zones. 5. Mr. Walter: Introductory comment: It is this Technical Committeeʼs understanding that MAN-ADM has deferred to MAN-STR on these topics. The economic analysis is provided with this committee statement. Ballot Comment 1: Agree. Ballot Comment 2: Agree. Ballot Comment 3: The comment presents opinion, which has not been sub-stantiated by a design level event. Ballot Comment 4: See economic analysis provided in committee statement on Comment 225 -32 (Log #38). Ballot Comment 5: Nonpersuasive argument -- commenter has not identified items to be studied further. A cost analysis was developed in support of this Comment and is included here.The Technical Committee would welcome additional cost information from industry on the potential impacts of these modifications.Manufactured Housing

Manufactured HousingEconomic Analysis

for theProposed Wind Standard Update

Purpose: Provide estimated benefits for Manufactured Housing available from updating the wind design criteria from its current ASCE 7-88 based standard to the ASCE 7-02 based standard proposed by the NFPA 225/501 Wind Task Group.

This Benefit Analysis compliments the Cost Analysis previously developed by the NFPA Manufactured Home Structural Technical Wind Task Group and pre-sented during the September 2003 ROP meetings in San Francisco.

BackgroundPresently, Manufactured Housing units are designed to resist the wind loads determined by ASCE 7-88 Minimum Design Loads for Building and Other Structures. That standard has been updated 4 times since 1988 (ʻ93, ʼ95, ʼ98 and ʼ02). From a wind standpoint, the most significant update occurred in 1995 when major changes were made in the methods used to predict design wind speeds and to calculate wind loads. While the wind standard has been updated numerous times, the wind criteria in HUDʼs regulatory standard have not been revised.

In the development of NFPA Manufactured Home Standard NFPA 225 and NFPA 501, several proposals have been made to update the Manufactured Home wind design criteria from ASCE 7-88 to either ASCE 7-98 or ASCE 7-02 (the wind provisions of ʼ98 and ʼ02 are nearly identical). In 2003, the Manufactured Home Wind Task investigated the issue and the group proposed code language to update the wind criteria.

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Report on Comments — Copyright, NFPA NFPA 501 Their proposal suggested changing the existing ASCE 7-88 based HUD Wind Zones I, II and III to NFPA Zones 1, 2, 3, and 4. Zone 1 would include areas with 3 second gusts design wind speeds up to 90 mph; Zone 2 would include areas between 90 mph and 110 mph; Zone 3 between 110 and 130 and Zone 4 would include areas between 130 and 150 mph.

MethodologyHAZUS (Loss Estimation Software) was used to predict wind damages to Manufactured Housing Inventory designed to the existing HUD Wind Standards and to the proposed ASCE 7-02 Wind Standards.

Six analyses were performed to determine estimated benefit for the each of the proposed wind change scenarios. The scenarios were selected to match those used in the development of the Wind Task Groupʼs Cost Analysis.

For efficiency, one county in the US was selected to model each of the wind revision scenarios. For each case, a county that was relatively large in land area, population and number of manufactured home inventory was selected.

1. HUD Zone II to NFPA Zone 12. HUD Zone II to NFPA Zone II3. HUD Zone II to NFPA Zone III4. HUD Zone II to NFPA Zone IV5. HUD Zone III to NFPA Zone III6. HUD Zone III to NFPA Zone IV7. HUD Zone I to NFPA Zone 1

Assumptions The analysis was based on the HAZUS-MH hurricane model. The following assumptions were used:• Winds developed from a hurricane originating in the Atlantic Ocean

(32.90N, -78.33W) and arriving at the center of the county nine hours later.

• Origin of storm is assumed to be the same for all six cases;• Storm passes through the center of each county;• Storm duration is 9 hours• A radius to maximum winds of (RMW) of 20 miles (RMW is the distance

in miles from the center of the storm to the location of highest winds. Typical values range from 6 to 60 miles and intense storms generally have smaller radii)

• Wind speeds analyzed were the maximum for the wind speed zone (e.g., the 90-110mph wind zone was analyzed at 110 mph)

• Central pressure is based on the Saffir-Simpson scale (pressure is lower with the higher wind speeds) and is indicated in Table 1. Pressure is based on maximum 1-minute sustained winds and a conversion factor of 1.23 was used for the corresponding 3-second gust.

Wind speeds: Wind speed inputs are 3-second gust wind speeds.

• NFPA Zone II (90-110 mph) 110 mph• NFPA Zone III (110-130 mph) 130 mph• NFPA Zone IV (130-150 mph) 150 mph• HUD Zone II (100 mph – fastest mile) = 115 mph • HUD Zone III (110 mph – fastest mile) = 125 mph

The analyses were completed for each of the existing HUD and the proposed NFPA wind zones. The results are been tabulated in Table 2. Table 2 includes data on the number of homes affected,

the predicted damages to structures (in dollars) and for structures and their con-tents. Dollar losses from the structures themselves generally account for 85% to 90% of the total structure and content loss.Table 2 – Total (Structure & Content) and Structure (Building Only) Damages for Existing HUD & Proposed NFPA Wind Zone1

(See Table below)

Table 1Max 1-minute 3-sec gust Central Pressure

Category 1 74-95 mph 91-117 mph >979 mbarCategory 2 96-110 mph 118-135 mph 965-970 mbarCategory 3 111-130 mph 135-160 mph 945-964 mbrCategory 4 131-155 mph 161-190 mph 920-944 mbarCategory 5 >155 mph 190 mph <920 mbar

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Report on Comments — Copyright, NFPA NFPA 501 As an example, homes in Palm Beach County are presently required to be built to HUD Zone III standards (which specify a 110 mph fastest mile/125 mph 3 second gust design wind speed). Exposing that housing inventory to that design speed will produce a total estimated loss of $212,000. The design wind speed specified in ASCE 7-02 is 150 mph (the proposed NFPA Zone IV). Exposing Manufactured Homes to that speed will produce total losses estimated at $3,470,000 an increase of $3,258,000.

1TCC Note: HUD Zone I to NFPA 1 analyses were completed sepa-rately and their results are not included in the table above. Macon County Georgia was selected for those analyses. HAZUS estimated upgraded the wind standard in that area would reduce economic loss-es by $33,910. 1,512 manufactured homes exist in the area studied.

Updating the wind standards provide other benefits that have not been included in these analyses. These incidental benefits include reductions in costs for:

• temporary housing• disruption time to residents• death and injuries• emergency or rescue costs• debris removal and clean up costs.

Table 3 includes the damage estimates in Table 2 plus data on the total amount of housing units in each county. From this data, per unit cost have been calcu-lated.

Table 3 – Total Loss (Building & Content Damage) and Total MH Inventory

Building Manufactured Homes to resist the higher wind speeds specified by ASCE 7-02 increases construction costs. Table 4, developed by the NFPA 225/501 Wind Task Group estimates the increased cost of manufacturing and installation.

Wind Zone Changes Cost Increase/(Decrease)HUD Zone I to NFPA Zone 1 (90 mph) $290HUD Zone II to NFPA Zone 2 (90-110 mph) ($330)HUD Zone II to NFPA Zone 3 (110-130 mph) $50HUD Zone III to NFPA Zone 3 (110-130 mph)

($1,350)

HUD Zone III to NFPA Zone 4 (130-150 mph)

$1,400

Table 4 – Construction Cost Increases (from the NFPA Wind Task Group)

Benefit Cost Results

The costs developed are one-time costs associated with the increase (or decrease) in manufacturing costs required to resist the new wind loads. These costs (or cost reductions) will exist whether the home is exposed to high winds or not. The benefits result from future deferred damages achieved during any high wind events that approaches or exceeds a design wind event. While it is not mathematically precise to compare the present cost and future benefits directly, it has been done here. If a more detailed analysis is desired, these costs should be converted to a common time basis (present, future or annuity); more detailed cost on the effects of installation should be developed and the incidental benefits discussed earlier should be included in the analysis.

Wind Zone Change Unit Cost Unit Benefit

BCR

HUD Zone I to NFPA Zone 1 $290 $22 .07

HUD Zone II to NFPA Zone 2 ($330) $460 N/A1

HUD Zone II to NFPA Zone 3 $50 $3,854 77

HUD Zone III to NFPA Zone 3 ($1,350) ($33) 40

HUD Zone III to NFPA Zone 4 $1,400 $364 0.26

1 BCR (Benefit Cost Ratios) for wind changes the result in reduced manufactur-ing costs and an increase in benefits were not calculated.

Table 5 Cost and Benefit Summary

Number Eligible to Vote: 16Ballot Results: Affirmative: 11 Negative: 2 Abstain: 1Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-2 (Log #35). KINARD: Is not enough cost benefit study to justify such a great expense as this whole section provides. The large dollar increase that would be added to the setup of the house would put potential buyers out of the market for our manufactured home. The foundations of newer HUD code homes have per-formed well and should not be wholesale discounted by these new code requirements. I think the AHJ should continue handling installation requirements when homes are placed in seismic zones. This is working now and they have the most knowledge as to specific requirements for their local. We have never had seismic requirements in the HUD code and until a proper Cost/Benefit study is done it should not be added at this time.Explanation of Abstention: JOHNS: Upon review of our mandate, I must voice my feeling that the impact of the proposed wind chapter changes has not been adequately addressed. The submitted economic analysis is incomplete. The Economic impact of the present HUD wind zone I change to NFPA wind zone II is not included. This omission should be the largest ʻtotal ̓cost effect due to the vol-ume of units now shipping into this area.Use of the newest (current) ASCE-7 data and methodology is preferred.

_______________________________________________________________501-12 Log #7 MAN-STR Final Action: Reject(6.2.5, 6.3, 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-11Recommendation: This proposal should be rejected.Substantiation: 1. If NFPA 225-3 (Log #71a) is rejected, then this change should follow suit as it applies to the same subject matter, e.g., seismic require-ments for manufactured homes. 2. This change is for additional requirements for seismic design consider-ations that extend beyond the design of the home itself. This represents addi-tional cost for development of a foundation support system to resist seismic forces. 3. The manufacturer is already required to provide one method to install the manufactured home in its installation manual. This change would require an additional installation method to be contained in that document to cover seis-mic design even if the home will not be installed in a seismic active area. 4. This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual, any increase in cost to be borne by the homeowner. 5. States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seis-mic active areas, such as California, but they use a system that will not be rec-ognized by these series of changes to implement seismic criteria. One such sys-tem is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensures that during a seismic event, the home may displace from its pier supports but will be prevented from falling to the ground by the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 MAN-STR.Committee Meeting Action: Reject Committee Statement: Please note, the commenter has asked that the com-mittee action on Proposal 501-11 be changed to ʻreject. ̓However, the TCC ROP ballot failed to uphold the Technical Committee ROP ballot action, so the current action on Proposal 501-11 is ʻreject. ̓However, in Comment 501-21 (Log #37), the Technical Committee reaffirms the technical committee ballot action taken on Proposal 501-11, as reflected in the ROP. Therefore, the

501-17

Report on Comments — Copyright, NFPA NFPA 501 Technical Committee has chosen to reject this comment, based upon the com-menterʼs original intent. See Committee Statement on Comment 501-21 (Log #37) for responses to individual issues brought up by commenter. Number Eligible to Vote: 16Ballot Results: Affirmative: 10 Negative: 4 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: The AHJs adequately address this potential need. Additional bur-densome regulations are not cost effective. HEROUX: • If NFPA ROP item 225-3 (Log #71a) is rejected, then this change should follow suit as it applies to the same subject matter.• This change is for additional requirements for seismic design considerations that extend beyond the design of the home itself. This represents additional cost for development of a foundation support system to resist seismic forces, wheth-er it is a connection method or not.• The manufacturer is already required to provide one method to install the manufactured home in its installation manual. This change would require an additional installation method to be contained in that document to cover seis-mic design even if the home will not be installed in a seismic active area, such as SDCD or E as required by the ROP item 225-3 (Log #71a).• The manufacturer has no way of knowing where the home final installation will be. Why should the manufacturer have to spend the time to perform this function for every single floor plan, since the final installation site is not known?• This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual. These costs will ultimately be borne by the potential homeowner.• States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seismic active areas, such as California, but they use a system that will not be recog-nized by these series of changes to implement seismic criteria. One such sys-tem is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensures that during a seismic event, the home may displace from its pier supports but will be prevented from falling to the ground by the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 MAN-STR. Provisions should be included in the seismic proposal for an alternate method of construction to include the ERBS system, if the whole seis-mic issue moves forward through the process. JOHNS: I have not seen any data that shows the impact of a seismic event on manufactured homes. The cost/benefit report given is based on site constructed light wood framed homes ̓located in an 8.2 Richter scale seismic event. The hard connection and dependence with the ground that the wood framed home has does not match the structural independence of a ʻbox structure ̓capable of moving down a highway. FEA analysis using hard connections vs spring con-nections show major changes in harmonic loads.Antidotal information is that a strong seismic event can cause the manufactured home to shift off its foundation, thereby causing a condition that could sharply increased damage costs. More analysis is needed. KINARD: This part of the standard introduces additional requirements for costly foundational connections and designs which in turn adds additional cost to the homeowner. The homebuilder provides their recommended method of installation and the states have installation guidelines that will have authority of this area and should be left at that. Besides the home builder does not know where the final set-up location of the home will be. So the home builder can not address this without doing this to every home which is not cost effective. All of this adds up to more cost for the homeowner without due justification.Comment on Affirmative PABIAN: These comments should include the acceptance of the ERBS sys-tem and other recognized systems. This is a start but additional work is needed to fine-tune the proposal to address the technical and logistical issues as well as the economic impacts stated above._______________________________________________________________501-13 Log #8 MAN-STR Final Action: Reject(6.2.5, 6.3, 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-12Recommendation: This proposal should be rejected.Substantiation: 1. If NFPA 225-2 (Log #71) is rejected, then this change should follow suit as it applies to the same subject matter, e.g., seismic require-ments for manufactured homes. 2. This change is for additional requirements for seismic design consider-ations that extend beyond the design of the home itself. This represents addi-tional cost for development of a foundation support system to resist seismic forces. 3. The manufacturer is already required to provide one method to install the manufactured home in its installation manual. This change would require an additional installation method to be contained in that document to cover seis-mic design even if the home will not be installed in a seismic active area. 4. This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual, any increase in cost to be borne by the homeowner.

5. States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seis-mic active areas, such as California, but they use a system that will not be rec-ognized by these series of changes to implement seismic criteria. One such sys-tem is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensures that during a seismic event, the home may rotate or displace off its pier supports but will be prevented from falling to the ground by the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 MAN-ADM.Committee Meeting Action: Reject Committee Statement: See Committee Statement on Comment 501-12 (Log #7).Number Eligible to Vote: 16Ballot Results: Affirmative: 10 Negative: 4 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: The AHJs adequately address this subject. Additional burdensome regulations are not cost effective. HEROUX: See my Explanation of Negative for Comment 501-12 (Log #7). JOHNS: See my Explanation of Negative for Comment 501-12 (Log #7). KINARD: See my Explanation of Negative on Comment 501-12 (Log #7).Comment on Affirmative PABIAN: See my Affirmative with Comment on Comment 501-13 (Log #8).

_______________________________________________________________501-14 Log #17 MAN-STR Final Action: Reject(6.2.5, 6.3, 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: William Hug, CAVCO Industries, Inc.Comment on Proposal No: 501-11Recommendation: This proposal should be rejected.Substantiation: 1. There has been no economic analysis done to show that there is a cost benefit for this proposal. Specifically “The Act, as revised in 2000”, states in 602(b)(1), (2) and (5) state that Congress ̓purpose for the improvement of “The Act” was to protect affordability, facilitate the availabili-ty of affordable homes and to protect the residents of the homes with respect to personal injury, insurance costs, and property damage. This proposal is only looking at the last element of the equation. The entire Law must be looked at and the cost benefit is part of that. 2. Where is the burden of proof that there is a problem with the current stan-dard? This proposal was put together relatively fast and there was little thought as to if it was needed. Where is the facts that show this is needed other than it just isnʼt addressed. 3. In 6.2.5.5,, the specific use of NFPA 5000 is required and smacks of favor-itism. This will force people to buy books that may only be used in a few spe-cific installations. If a book is to be used it should be something that can be used of other items such as ASCE7 or as an alternate add the reference to the IBC or IRC. 4. There will be engineering costs with this that smaller manufacturers will need to bear, since most do not have engineers on their staff, if they are to sell into these areas. This is a cost that will be passed onto the consumer, and may be out of proportion to the cost that larger manufacturers will pay. 5. Because a manufacturer doesnʼt know where the building may be going he would have to build to the more stringent code, over build/added cost, just to be able to sell the home and feel conformable about the placement of it at a future time. In addition to this how is a consumer or dealer going to know what they need or will they even be knowledgeable enough to be able to ask the question? This needs to be broken down into a county or area format with zones or it will never work to any reasonable degree of certainty.Committee Meeting Action: Reject Committee Statement: Please note, the commenter has asked that the com-mittee action on Proposal 501-11 be changed to ʻreject. ̓However, the TCC ROP ballot failed to uphold the Technical Committee ROP ballot action, so the current action on Proposal 501-11 is ʻreject. ̓However, in Comment 501-21 (Log #37), the Technical Committee reaffirms the technical committee ballot action taken on Proposal 501-11, as reflected in the ROP. Therefore, the Technical Committee has chosen to reject this comment, based upon the com-menterʼs original intent. In addition, the Technical Committee has the following responses to each of the commenterʼs provided reasons. Item 1: An economic analysis is provided in committee statement on Comment 501-21 (Log #37). Item 2: An evaluation of the seismic performance of manufactured housing is available in two separate reports: “The Effect of Earthquakes on Manufactured Home Installations,” prepared for HUD in August 1995, and “The Effectiveness of Manufactured Home Support Systems During Earthquakes,” prepared for the State of California in April 1992. These reports justify the Technical Committeeʼs decision to incorporate seismic design and construction requirements into NFPA 225 and NFPA 501. Item 3: This notation indicates that the text has been extracted from ASCE 7 and NFPA 5000. It is not a reference out to either document. Item 4: There will be a one-time cost to reevaluate the designs. Item 5: Please see the Committee Action on Comment 225-8 (Log #22).

501-18

Report on Comments — Copyright, NFPA NFPA 501 Number Eligible to Vote: 16Ballot Results: Affirmative: 10 Negative: 4 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-13 (Log #8). HEROUX: See my Explanation of Negative for Comment 501-12 (Log #7). JOHNS: See my Explanation of Negative for Comment 501-12 (Log #7). KINARD: See my Explanation of Negative on Comment 501-12 (Log #7).Comment on Affirmative PABIAN: See my Affirmative with Comment on Comment 501-13 (Log #8).

_______________________________________________________________501-15 Log #19 MAN-STR Final Action: Reject(6.2.5, 6.3, 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-11Recommendation: This proposal should be rejected.Substantiation: 1. If NFPA 225-3 (Log #71a) is rejected, then this change should follow suit as it applies to the same subject matter, e.g., seismic require-ments for manufactured homes. 2. This change is for additional requirements for seismic design consider-ations that extend beyond the design of the home itself. This represents addi-tional cost for development of a foundation support system to resist seismic forces. 3. The manufacturer is already required to provide one method to install the manufactured home in its installation manual. This change would require an additional installation method to be contained in that document to cover seis-mic design even if the home will not be installed in a seismic active area. 4. This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual, any increase in cost to be borne by the homeowner. 5. States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seis-mic active areas, such as California, but they use a system that will not be rec-ognized by these series of changes to implement seismic criteria. One such sys-tem is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensures that during a seismic event, the home may displace from its pier supports but will be prevented from falling to the ground by the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 MAN-STR.Committee Meeting Action: Reject Committee Statement: See Committee Statement on Comment 501-12 (Log #7).Number Eligible to Vote: 16Ballot Results: Affirmative: 10 Negative: 4 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-13 (Log #8). HEROUX: See my Explanation of Negative for Comment 501-12 (Log #7). JOHNS: See my Explanation of Negative for Comment 501-12 (Log #7). KINARD: See my Explanation of Negative on Comment 501-12 (Log #7).Comment on Affirmative PABIAN: See my Affirmative with Comment on Comment 501-13 (Log #8). _______________________________________________________________501-16 Log #20 MAN-ADM Final Action: Reject(6.2.5, 6.3, 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-12Recommendation: This proposal should be rejected. Substantiation: 1. If NFPA 225-2 (Log #71) is rejected, then this change should follow suit as it applies to the same subject matter, e.g., seismic require-ments for manufactured homes. 2. This change is for additional requirements for seismic design consider-ations that extend beyond the design of the home itself. This represents addi-tional cost for development of a foundation support system to resist seismic forces. 3. The manufacturer is already required to provide one method to install the manufactured home in its installation manual. This change would require an additional installation method to be contained in that document to cover seis-mic design even if the home will not be installed in a seismic active area. 4. This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual, any increase in cost to be borne by the homeowner. 5. States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seis-mic active areas, such as California, but they use a system that will not be rec-

ognized by these series of changes to implement seismic criteria. One such sys-tem is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensures that during a seismic event, the home may rotate or displace off its pier supports but will be prevented from falling to the ground by the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 MAN-ADM.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-ject matter of the comment is outside the committeeʼs scope. See Comment 501-14 (Log #17) which was addressed by MAN-STR for action on the subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-12 which was to defer all action on the proposal to MAN-STR. Also see Proposal 501-11.Number Eligible to Vote: 9Ballot Results: Affirmative: 7 Abstain: 2Explanation of Abstention: GHORBANI: We keep voting on these proposals - and they continue to be revived. Frankly, more and more members of our industry are beginning to wonder whether the NFPA process is suitable to the unique character of our industryʼs product - manufactured homes. This is particularly true in recent years as the NFPA committees and subcommittees continue to be stacked against the industry, thus drowning the manufactured housing industry repre-sentatives ̓voices and votes on these crucial proposals. As the separation between the Federal standards (3280/installation) and NFPA (501/225) continues to widen - with the former maintaining a balance between affordability and consumer protection while the latter rapidly becom-ing gold-plated and unusable - the question that the industry and its consumers face is that whether or not the time, effort and money that they expend partici-pating in the NFPA process are worth their while. I, and my organization which represents nearly 90 percent of the industryʼs production, feel very strongly that the time has come to reevaluate the indus-tryʼs participation in the NFPA process for manufactured housing code devel-opment and maintenance. GORMAN: I am abstaining due to lack of knowledge regarding cost impact to product._______________________________________________________________501-17 Log #16 MAN-ADM Final Action: Reject(6.2.5, 6.3, 8.14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: William Hug, CAVCO Industries, Inc.Comment on Proposal No: 501-12Recommendation: This proposal should be rejected.Substantiation: 1. There has been no economic analysis done to show that there is a cost benefit for this proposal. Specifically “The Act, as revised in 2000”, states in 602(b)(1), (2) and (5) state that Congress ̓purpose for the improvement of “The Act” was to protect affordability, facilitate the availabil-ity of affordable homes and to protect the residents of the homes with respect to personal injury, insurance costs, and property damage. This proposal is only looking at the last element of the equation. The entire Law must be looked at and the cost benefit is part of that. 2. Where is the burden of proof that there is a problem with the current stan-dard? This proposal was put together relatively fast and there was little thought as to if it was needed. Where is the facts that show this is needed other than it just isnʼt addressed. 3. In 6.2.5.5,, the specific use of NFPA 5000 is required and smacks of favoritism. This will force people to buy books that may only be used in a few specific installations. If a book is to be used it should be something that can be used of other items such as ASCE7 or as an alternate add the reference to the IBC or IRC. 4. There will be engineering costs with this that smaller manufactures well need to bear, since most do not have engineers on their staff, if they are to sell into these areas. This is a cost that will be passed onto the consumer, and may be out of proportion to the cost that larger manufactures will pay. 5. Because a manufacture doesnʼt know where the building may be going he would have to build to the more stringent code, over build/added cost, just to be able to sell the home and feel conformable about the placement of it at a future time. In addition to this how is a consumer or dealer going to know what they need or will they even be knowledgeable enough to be able to ask the question? This needs to be broken down into a county or area format with zones or it will never work to any reasonable degree of certainty.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The subject matter of the comment is outside the committeeʼs scope. See Comment 501-14 (Log #17) which was addressed by MAN-STR for action on subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-12 which was to defer all action on the proposal to MAN-STR. Also see Proposal 501-11.Number Eligible to Vote: 9Ballot Results: Affirmative: 7 Abstain: 2Explanation of Abstention: GHORBANI: See my reason for abstaining on Comment 501-16 (Log #20). GORMAN: See my Explanation of Abstnetion on Comment 501-16 (Log #20).

501-19

Report on Comments — Copyright, NFPA NFPA 501 _______________________________________________________________501-18 Log #3 MAN-STR Final Action: Accept in Principle(6.2.5, 6.3 and 14.1.1) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-11Recommendation: The TCC directs that MAN-STR clarify the intent of para-graph 6.2.5.5, which is currently understood to be that the seismic requirements do not apply to the design of the overall structure but rather to the interface between the foundation and the anchoring system. Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Accept in Principle Modify Section 6.3.4 of Proposal 501-11 as follows: 6.3.4 “... the manufacturer shall provide drawings and printed instructions for at least one system method of anchoring securing the manufactured home to its foundation...” Committee Statement: The Technical Committee prefers that the modifica-tion be to Section 6.3.4 and not 6.2.5.5. The modification clarifies that the Technical Committee intends this requirement to affect the connection interface only, and not the design of the home or the foundation.Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN _______________________________________________________________501-19 Log #30 MAN-ADM Final Action: Reject(6.2.5, 6.3, and 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-12Recommendation: The TCC directs that the action on this proposal be Accept-in-Principal as originally proposed by those members of MAN-ADM present at their ROP meeting, and that the final action on the subject matter raised by this proposal be addressed by MAN-STR. The subject matter of this proposal is not within the scope of MAN-ADM.Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Accept Committee Statement: By accepting this comment the committee reafirms its ROP meeting action on proposal 501-12 which was to defer all action on the proposal to MAN-STR. Also, see associated action on Comment 501-15 (Log#19) which was addressed by MAN-STR. Also see Proposal 501-11.Number Eligible to Vote: 9Ballot Results: Affirmative: 9 _______________________________________________________________501-20 Log #44 MAN-ADM Final Action: Reject(6.2.5., 6.3 and 14.1.1) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Technical Committee on Administration for Manufactured HousingComment on Proposal No: 501-12Recommendation: Reconsider the action on this proposal. Substantiation: This comment has been generated because the Technical Committee ballot did not confirm the Technical Committee meeting action on the respective proposal. GHORBANI: Manufactured homes are some of the safest structures in earth-quake and seismic conditions. I am not convinced that cost (no details of which were presented) vs. benefits, which is one of the key factors for changes to manufactured home standards, would justify these changes. GILCHRIST: Negative response for following reasons, even though it is rec-ognized that this has been deferred to the technical committee on structural. 1. Feel this relates to specific areas of the country and is very locational relat-ed. Therefore should be dependent upon alternatives provided by the manufac-turer and approved by the local jurisdictional agency approving the installation. 2. Each state may also have jurisdictional requirements for seismic design that have to be complied with. 3. A majority of areas in the nation are not seismic related conditions. GORMAN: Requires considerations beyond the actual design of the home. Increases costs unnecessarily. Already covered by DAPIA requirements. ROBERTS: While this proposal has been deferred to the TC-STR for its consideration, I am voting negative on this item. This change is dependent on NFPA 225-2 (Log #71). Reasons for this negative are listed below. 1. The proponent has the proposal backwards. If the manufactured home is designed to withstand seismic loads, then the foundation needs to be able to transfer those loads to the ground. 2. If seismic loads are to be considered, than language is needed in the con-struction standard to determine which loads govern. Most often wind loads would govern over seismic. 3. As part of any proposal to consider seismic loads in the construction of the home, the proponent needs to discuss the issue of cost and how that effects the affordability of the home. 4. the proponent did not provide any supporting documentation that current problems in the construction of the home would be resolved through adoption

of this proposal.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-ject matter of the comment is outside the committeeʼs scope. See Comment 501-21 (Log #37) which was addressed by MAN-STR for action on the subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-12 which was to defer all action on the proposal to MAN-STR. Also see Proposal 501-11.Number Eligible to Vote: 9Ballot Results: Affirmative: 9 _______________________________________________________________501-21 Log #37 MAN-STR Final Action: Reject(6.2.5, 6.3 and 14.11) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-11Recommendation: Reconsider the action on this proposal.Substantiation: This comment has been generated because the TCC ballot did not confirm the Technical Committee action on respective proposal. The rea-sons for TCC negative votes are as follows: Mr. Farish voted negatively stating: Since this was not a segmented ballot I am forced to vote negative due to the problems with only a few of the proposals. • I do not feel the difficulties in similar proposals have been resolved (such as the two wind proposals, 501-6 (Log #1), and 501-10 (Log #29), and 501-49 (Log #15a). • I am uncomfortable with the apparently poor resolution of single issues given to multiple TCʼs (such as 501-41 (Log #5b). • There is not a good correlation between proposals that addressed similar issues in different areas (such as the seismic proposals in 501-11 (Log #30), 501-40 (Log #5a), and 501-41 (Log #5b). Mr. Ghorbani voted negatively on the entire document stating: Represing the views and interest of MH producers, I continue to remain uncomfortable with what these changes would do to the affordability aspect of these homes. To vote affirmative on these proposals, I need to see more data and factual numbers on cost vs. benefits that these changes would bring to these homes. In addition, there are several discrepencies on these proposals on such things as correlating with related items and imposition on the authority of the local jurisdictions. Mr. Tomasbi voted negatively stating: 501-11: Does not correlate with rejection of NFPA 225-3. Mr. Gilchrist voted negatively stating: Proposal 501-11 (Log #11) reject because it is my understanding that the affected individual states enforce the seismic design requirements in addition to the manufacturerʼs provided methods of installation. Further, this is getting into requirements beyond the design of the home itself and why should manufactur-ers be required to establish systems when they donʼt know where a home will be sited. Mr. Walter voted negatively stating: More than one Technical Committee had the opportunity to comment on the changes that involve wind and seismic requirements, and their reactions and votes were not coordinated between them. In addition, there are no econonmic benefit-cost analyses to accompany the proposed significant increases in stan-dards for wind, seismic and flood safety. Proposal 501-11 (Log #30) 1. If NFPA 225-3 (Log #71a) is rejected when this change should suit as it applies to the same subject matter. 2. This change is for additional requirements for seismic design consider-ations that extend beyond the design of the home itself. This represents addi-tional cost for development of a foundation support system to resist seismic forces. 3..The manufacturer is already required to provide one method to install the manufactured home in its installation manual. This change would require an additional installation method to be contained in that document to cover seis-mic design even if the home will not be installed in a seismic active area. 4. This design must be approved by the DAPIA as a condition of acceptance of the manufacturerʼs installation manual. 5. States reserve the right to enforce seismic design requirements, as they deem necessary. Some presently do require special foundation designs for seismic active areas, such as California, but they use a system that will not be recognized by these series of changes to implement seismic criteria. One such system is referred to as an Earthquake Resistant Bracing System (ERBS), which essentially ensures that during a seismic event, the home may displace from its pier supports but will be prevented from falling to the ground b y the ERBS system. This system is not recognized by the seismic proposal before the NFPA 501 MAN-STR.Committee Meeting Action: Accept in Principle The Technical Committee has followed the TCCʼs recommendation to recon-sider the action on Proposal 501-11. By voting accept in principle on Comment 501-21 (Log #37), the Technical Committee reaffirms the Technical Committee ROP ballot action taken on Proposal 501-11 as reflected in the ROP.Committee Statement: In this comment, the Technical Committee reaffirms their commitment to providing seismic requirements in NFPA 501. In addition, as part of the committee statement, the Technical Committee has included a preliminary cost-benefit analysis on these recommended modifications. In addi-tion, the Technical Committee has the following responses to each of the

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Report on Comments — Copyright, NFPA NFPA 501 TCCʼs negative votes. 1. Mr. Farish: This Technical Committee will make recommendations to ensure coordination between the cited proposals. 2. Mr. Ghorbani: An economic analysis is provided with this committee state-ment. The Technical Committee notes that the proposed seismic requirements do not adversely affect the AHJʼs authority. 3. Mr. Tomasbi: See explanation above. 4. Mr. Gilchrist: The Technical Committee sees this as similar to the tie-down connection requirements for wind load. It is the intent of this requirement to affect the connection interface only, and not the design of the home or the foundation. 5. Mr. Walter: Introductory comment: It is this Technical Committeeʼs understanding that MAN-ADM has deferred to MAN-STR on these topics. The economic analysis is provided in this committee statement. Ballot Comment 1: In the ROC meeting, the Technical Committee reaffirmed their commitment to having seismic requirements in both documents. See com-mittee statements on Proposal 225-3 and Proposal 501-11 for additional techni-cal justification. Ballot Comment 2: See explanation above. Ballot Comment 3: Agree. Ballot Comment 4: Agree. Ballot Comment 5: It is the intent of this requirement to affect the connection interface only, and not the design of home or the foundation. A preliminary cost analysis was developed in support of this comment and is included here. The Technical Committee would welcome additional cost infor-mation from industry on the potential impacts of this comment.Manufactured Housing

Seismic Event Damage Prediction Background

At its September 2003 ROP meeting, the NFPA Structural Committee for Manufactured Housing reviewed the Seismic Task Groupʼs proposal to include seismic criteria in the Manufactured Home Installation standard (NFPA 225). During that meeting, the committee voted to accept the Seismic Task Groupʼs proposal in principal but requested the following

1. A cost-benefit analysis be performed for a typical single- and double- section installation in the four proposed seismic zones

2. The proposal be written to minimize cross references to other NFPA standards by either extracting text or by including NFPA 5000 material as an annex

3. The proposal be written to locate the seismic language in a separate chapter and provide appropriate cross refer-ences to the standard

4. A list the seismic zones by county be provided

Items 2, 3 and 4 were completed and submitted as a public comment to the ROP. This document has been provided to address Item 1.

Analysis

The analyses were conducted to predict the cost and benefits associated with adopting the Seismic Task Groupʼs proposal. Due to limited resources, these analyses concentrate on predicting the reduction in damages to manufactured housing inventory from a design seismic event. Only costs from building and content damages have been addressed here. Other benefits like debris removal and clean up, temporary housing and relocation and benefits to emergency man-agement and first responders have not been included.

Damages to homes in Sonoma County California were analyzed for this report. According to the 2000 Census, there are 10,600 manufactured homes in that area.The analyses were conducted using HAZUS (Hazard US) damage prediction software. The software was developed to predict damage from natural hazards from high winds (hurricanes), seismic events, etc. The HAZUS software can predict damages to numerous styles of buildings from single story wood framed structures to multi-story concrete and steel framed buildings.

These analyses were based on damages to site constructed light wood framed homes (Type W1) since the HAZUS model for that style of construction has had more historical data used for to calibrate the model. The Manufactured Home model (Type MH) was not used since it is believed to overstate damages. The MH results have, however, been included for comparison. It is felt that using the W1 model will provide sufficiently accurate results for this study and will likely underestimate the benefits somewhat.

The analyses were performed for pre-code buildings and for high code buildings. These designations relate to fragility curves built into the model. As the name implies, pre-code buildings are those designed and constructed with no codes governing seismic resistance. High code buildings are designed to resist code dictated seismic forces.

The following cases were been analyzed, for Manufactured Homes in Sonoma County of California for a seismic event (8.2 on the Richter scale), to estimate the losses of manufactured homes (MH) using the Hazus-MH software:

1. W1 High: MH run per the high-code parameters (capacity and fragil-ity curves) of one story wood structures (W1) across all the three seismic design levels (i.e. high, moderate and low).

2. MH Pre: MH run per pre-code design parameters (capacity and fra-gility curves) of MH across all the three seismic design levels (i.e. high, moderate and low).

3. W1 Pre: MH run per the pre-code parameters (capacity and fragility curves) of one story wood structures (W1) across all the three seismic design levels (i.e. high, moderate and low).

Costs

The cost for the seismic resistant foundation was developed from a cost study performed by the Manufactured Housing Research Alliance (MHRA). In that study, several pre-engineered foundation designs, developed for FEMA 85 Manufactured Homes in Flood Hazard Areas, were constructed to determine actual construction costs.

One of the pre-engineered foundation, title the Braced Masonry Pier design, is very similar to the pier design proposed for NFPA 225. Like the seismic design, it consists of reinforced masonry piers and discrete poured-in-place concrete footings. The Braced Masonry Pier design differed from the seismic design in two areas. The Braced Masonry Pier design used smaller footings and contained metal strapping and cast-in-place anchors that are not present in the seismic design. It is felt that the cost of the two differences in design would offset each other and the Braced Masonry Pier design would provide a cost estimate accurate enough for this analysis.

In the MHRA study, the Braced Masonry Pier foundation costs approximately $6,000 ($5,892) for a 44 foot long by 28 foot wide double unit. From their data, we estimate the foundation for a single unit would cost approximately $3,500. Since HAZUS uses census data and does not distinguish between single and mul-tiple units, we developed a weighted average foundation cost. For this analysis we estimated 20% of the homes in Sonoma County were single units and 80% were double units. This weighting provided us with an average unit cost for the seismically resistant pier foundation of $5,500.

Results

The HAZUS Models predict that incorporating seismic provisions will have a profound effect at reducing damages from a design event. Per home economic losses will be reduced by approximately $10,000. Approximately 5 times as many homes will survive an event with no or only slight damages and the num-ber of extensively damaged or destroyed homes will be reduced by over 80%.

The following tables summaries the results of the HAZUS Model. Table 1 includes economic ($) losses for structural and non-structural components. Table 2 lists the number of homes damaged for each category of damage extent. Table 3 lists the percentage of damages homes for each damage category HAZUS

ModelStructural

($)Non-Structural

($) Damages

Total ($) Per Unit ($)

W1 Pre-Code $41,798,000 $122,435,000 $164,233,000 $15,463

W1 High Code $11,032,000 $43,114,000 $54,146,000 $5,100

MH Pre Code $45,189,000 $126,799,000 $171,988,000 $16,200

Table 1 – Economic Losses

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HAZUS Model # of Buildings Damaged None Slight Moderate Extensive Complete Total

W1 Pre-Code 351 875 2633 2929 3830 10,618

W1 High-Code 2131 4248 2818 627 797 10,621

MH Pre-Code 391 567 1897 3682 4081 10,618Tanle 2 – Damaged Building Count

HAZUS Model % of Buildings Damaged

None Slight Moderate Extensive Complete Total

W1 High-Code 20.06% 40.00% 26.53% 5.90% 7.50% 10,621

W1 Pre-Code 3.31% 8.24% 24.80% 27.59% 36.07% 10,618

MH Pre-Code 3.68% 5.34% 17.87% 34.68% 38.43% 10,618

Table 3 – Percentage Damaged Buildings

TCC Note: The slight difference in the total number of MH is due to round off.

Damage Descriptions for Manufactured Homes:

Slight Structural Damage: Damage to some porches, stairs or other attached components.

Moderate Structural Damage: Major movement of the mobile home over its supports resulting in some damage to metal siding and stairs and requiring reset-ting of the mobile home on its supports.

Extensive Structural Damage: Mobile home has fallen partially off its supports, often severing utility lines.

Complete Structural Damage: Mobile home has totally fallen off its supports; usually severing utility lines, with steep jack stands penetrating through the floor. Approximately 3% of the total area of MH buildings with complete damage is expected to be collapsed.

Damage Descriptions for Light Framed (W1) Structures:

Slight Structural Damage: Small plaster or gypsum-board cracks at corners of door and window openings and wall-ceiling intersections; small cracks in masonry chimneys and masonry veneer.

Moderate Structural Damage: Large plaster or gypsum board cracks at corners of door and window openings; small diagonal cracks across shear wall panels exhibited by small cracks in stucco and gypsum wall panels; large cracks in brick chimneys; toppling of tall masonry chimneys.

Extensive Structural Damage: Large diagonal cracks across shear wall panels or large cracks at plywood joints; permanent lateral movement of floors and roof; toppling of most brick chimneys; cracks in foundations; splitting of wood sill plates and or slippage of structure over foundations; partial collapse of “room-over-garage” or other “soft-story” configurations; small foundation cracks.

Complete Structural Damage: Structure may have large permanent lateral dis-placement, may collapse, or be in imminent danger of collapse due to cripple wall failure or the failure of the lateral load resisting system; some structures may slip and fall off the foundations; large foundation cracks. Approximately 3% of the total area of W1 buildings with complete damage is expected to be collapsed.

Number Eligible to Vote: 16Ballot Results: Affirmative: 13 Negative: 1

Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-2 (Log #35).

_______________________________________________________________501-22 Log #14 MAN-STR Final Action: Accept(6.2.5.2 and 6.5.4.1) _______________________________________________________________Submitter: John V. Loscheider, Loscheider Engineering Company / Rep. MAN-STR Live Load Task Group Comment on Proposal No: 501-13Recommendation: This comment was prepared by the MAN-STR Live Load Task Group chaired by John Loscheider. 1. Revise as follows: 6.2.5.2 Live Load. The weight superimposed by the use and occupancy of the manufactured home , including wind load and snow load, but not including dead load . 2. Revise as follows: 6.5.4 Design Load Deflection. 6.5.4.1 When a structural assembly is subjected to total design live loads, but not including dead load, the deflection for structural framing members shall not exceed the following... (No changes to remainder of section.) Substantiation: The existing definition of live load conflicts with common usage and virtually all building codes. It also appears to conflict with NFPA 501, 6.5.2.2, which currently distinguishes between live loads and wind loads. Section 6.5.4.1 appears to be the only section that actually relies on the existing incorrect definition, so that provision has been modified to keep its meaning unchanged.Committee Meeting Action: Accept Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN

501-22

Report on Comments — Copyright, NFPA NFPA 501 _______________________________________________________________501-23 Log #CC1 MAN-STR Final Action: Accept(6.4) _______________________________________________________________Submitter: Technical Committee on Structural for Manufactured HousingComment on Proposal No: 501-15Recommendation: Add the following language to Section 6.4 6.4 Minimum Standards. Structural design and construction in manufac-tured homes shall conform to applicable standards in Table 6.4 unless other-wise specified in this standard. When more than one standard is referenced, compliance with any one such standard shall meet the requirements of this standard. Substantiation: Upon reflection, the Technical Committee realized that Table 6.4 needed to be referenced within the body of NFPA 501 This Committee Comment provides that reference, based upon the language used in Section 10.3.Committee Meeting Action: Accept Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN _______________________________________________________________501-24 Log #31 MAN-STR Final Action: Hold(Table 6.4) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-16Recommendation: The TCC directs that MAN-STR identify which refer-enced documents are standards and which are guides. The TCC further directs that MAN-STR identify which reference documents are mandatory for compli-ance for NFPA 501 and which are advisory in nature. Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Hold Committee Statement: While sympathetic to the TCCʼs general concerns, the Technical Committee, upon further discussion, realized that there are additional deficiencies in NFPA 501 with respect to reference standards, which cannot be addressed within the time frame of the F2004 Comment period. Therefore, the Technical Committee has chosen to hold this comment for next cycle. In the interim, the Technical Committee has established a Task Group on Reference Standards to identify and recommend any necessary action on the following topics: 1. Guides versus standards -- review documents to determine whether they are written as a guide or a standard. 2. Mandatory versus advisory -- review standards to determine which should be mandatory references versus advisory references within NFPA 501. 3. Overlooked standards and guides -- review industry documents to deter-mine if any are missing from NFPA 501. 4. Obsolete standards and guides -- review listed documents to determine if they are still available. 5. Updates to standards and guides -- review updates to documents and deter-mine their possible impact on NFPA 501. 6. Applicability to manufactured housing -- review listed standards to ensure that they still apply to NFPA 501. Also, this Task Group should make recommendations on the ultimate format and nature of these references -- e.g. should these references be incorporated into text instead of a table? The Technical Committee recommends that the TCC consider charging other Technical Committees with a similar task in the next cycle. In addition, they should provide guidelines on how best to cite the references in NFPA 501.Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN _______________________________________________________________501-25 Log #39 MAN-MEC Final Action: Accept in Principle(8.5) _______________________________________________________________Submitter: Technical Committee on Mechanical for Manufactured HousingComment on Proposal No: 501-23Recommendation: Reconsider the aciton on this proposal.Substantiation: This comment has been generated because the Technical Committee ballot did not confirm the Technical Committee meeting action on the respective proposal. The reasons for Technical Committee negative votes are as follows: HEIMAN: See my Explanation of Negative on 501-22 (Log #CP100). LUBLINER: By rejecting this proposal the committee is again ignoring The Manufactured Housing Research Alliance (MHRA) publication “Moisture Problems in Manufactured Homes- understanding Causes and Finding Solutions which states “Specify production details that minimize moisture dam-ageʼ”. The proposal seeks to specify moisture details because often moisture damage and molds result when “devils are in the details”. The committee rejection is based on the notion that the proposal is unen-forceable. The committee ignores the fact that this level of detail is currently enforced on thousands of Energy Star homes in the Pacific Northwest. The

attached in-plant Energy Star Quality Assurance checklist is an example of how one might implement this proposal. Since the committee believes that the requirement proposed by the submitter would be more appropriately located in 24 CFR 3282. 203, I request the com-mittee formally forwarding this proposal to HUDʼs consensus committee as part of the rejection. I will change accept the rejection of this proposal, if and when it is accepted in HUD in 24 CFR 3282.203. TCC Note: Supporting material is available for review at NFPA headquarters. SMITH: Agree with Committee. The proposed change incorrectly references Appendix A. Rather, it should be Annex A. Material in an Annex is explanatory and, as such, should not include mandatory language such as “shall”.Committee Meeting Action: Accept in Principle The committee has reconsidered its action on Proposal 501-23 and reaffirms its ROP meeting action of reject for Proposal 501-23 for the reasons stated in the ROP. Committee Statement: The committee reaffirms its reasons for rejecting Proposal 501-23 as indicated in the ROP. Number Eligible to Vote: 12Ballot Results: Affirmative: 10 Abstain: 2Explanation of Abstention: HEIMAN: See my Explanation of Abstention on Comment 501-7 (Log #1b). STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b).

_______________________________________________________________501-26 Log #28 MAN-MEC Final Action: Accept(8.6.1.1) _______________________________________________________________Submitter: Christopher Early, US Department of Energy / Rep. UO TAsk group of Technical Committee on Mechanical For Manufactured HousingComment on Proposal No: 501-25Recommendation: Revise to read as follows:

Substantiation: The Department of Energy submitted a proposal to revise the maximum Overall U-values (U o ), also known as Coefficient of Heat Transmission, in NFPA 501. The Proposal 510-25 (Log #33) would have revised Table 8.6.1.1 and Figure 8.6 of NFPA 501. The original proposal was rejected. However a U o Task Group of the Technical Committee on Mechanical for Manufactured Housing was formed to explore whether a revised U o more acceptable to a broad range of stakeholders, including home manufacturers, could be developed. This comment proposes a change to revise U o requirements in the NFPA 501. This comment is supported by all members of the Task Group. MHIʼs support is provisional, presuming the support of most of their members. Some Task Group members ̓support is provisional pending consultation with oth-ers. The Task Group included the proponents of the original comment; Chris Early (DOE) as chairman and Craig Conner of the Pacific Northwest National Laboratory; and four committee members, Larry Boyce (Nordyne), Jordan Heiman, John Mikel (Skyline Corp.), and Mark Nunn (Manufactured Housing Institute). TCC Note: Supporting material is available for review at NFPA Headquarters. Committee Meeting Action: Accept Number Eligible to Vote: 12Ballot Results: Affirmative: 11 Abstain: 1Explanation of Abstention: STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b).Comment on Affirmative HEIMAN: On Comments 501-26 (Log #28), 501-27 (Log #29), and 501-46 (Log #27) I vote “Affirmative with Comment” on because I have obligated myself through membership on the Heating Task Force.

Table 8.6.1.1 Coefficient of Heat transimission (Uo) and Figure 8.6

Uo Value Zone Maximum Coefficient of Heat Transmission

1 0.116 0.098 Btu/hr ft2°F2 0.096 0.090 Btu/hr ft2°F3 0.079 0.073 Btu/hr ft2°F

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_______________________________________________________________501-27 Log #29 MAN-MEC Final Action: Reject(8.6.1.1, Figure 8.6) _______________________________________________________________Submitter: Christopher Early, US Department of EnergyComment on Proposal No: 501-25Recommendation: Revise to read as follows:

Substantiation: The Department of Energy submitted a proposal to revise the maximum Overall (Uo), also known as Coefficient of Heat Transmission, in NFPA 501. The Proposal 510-25 (Log #33) would have revised Table 8.6.1.1 and Figure 8.6 of NFPA 501. The original proposal was rejected. However a Uo Task Group of the Technical Committee on Mechanical for Manufactured Hosing was formed to explore whether a revised Uo more acceptable to a broad range of stakeholders, including home manufacturers, could be devel-oped. As a supplemental response separate from the Task Group, the DOE revised the analysis that lead to the initial recommendations. DOE made several chang-es to the data and assumptions used as input for the analysis, most in response to concerns that arose in the Task Group were not included in this analysis. This analysis minimized a consumerʼs total cost; however, it sometimes used different assumptions than the Task Group. The analysis was done with the Automated Residential Energy Standard (ARES) software. Calculations were done for double-section homes with five different equipment/fuel types in 881 cities in ARES, the resulting Uo values were aggregated into large geographi-cal zones based on home sales and equipment/fuel distribution. The three exist-ing zones used in NFPA 501 were not modified. Several inputs to the least cost analysis were modified based on comments received in discussion with the Task Group. The period of analysis was short-ened to 30 years (from 50). More recent home shipment data from MHI was incorporated. A crossover duct was added to the Uo computation. Fuel costs were updated to assume the most recent Energy Information Agency projec-tions. In contrast to the Task Group proposal, several elements of the original DOE inputs were retained. The original EEM U-values and costs were retained. The double-section prototype was deemed to be representative, given it represents 80 percent of the homes. After 30 years, a discounted resale value was assumed. The furnace AFUE remained at the Federal minimum of 75 AFUE. Equipment and fuel type assumptions by state were based on census data. The resulting Uo is shown in the freommendation for this comment and com-pared with the existing requirements and DOEʼs original proposal. This revised proposal would improve the NFPA 501 and the new analysis addresses the concerns raised by the Mechanical Committee when it rejected the original proposal.Committee Meeting Action: Reject Committee Statement: See Committee Action and Statement on Comment 501-26 (Log #28). The committee further notes that representatives from the U.S. Department of Energy (DOE) participated in good faith in the task group identified in Comment 501-26 (Log #28). DOE representatives at the ROC meeting were in favor of the committeeʼs action to accept Comment 501-26 (Log #28) and were not opposed to the motion to this Comment 501-27 (Log #29). Number Eligible to Vote: 12Ballot Results: Affirmative: 10 Negative: 1 Abstain: 1Explanation of Negative: BACHRACH: I disagree with the Committeeʼs recommendation to reject this proposal. The DOE analysis shows that these U 0 values would result in cost-effective energy savings and should be adopted. Moreover, the DOE analysis does not include the reduction in pollution emissions that would result from the proposed standard in its analysis of the benefits of the proposal; from a societal perspective, these benefits should be considered and would result in an even tighter standard. I support the proposal by the U 0 Task Group (in 501-26) to incrementally improve the standard, but consumers and the environment would benefit even more from this proposal.Explanation of Abstention: STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b).Comment on Affirmative HEIMAN: See my Affirmative with Comment on Comment 501-26 (Log #28).

_______________________________________________________________501-28 Log #32 MAN-PLU Final Action: Accept in Principle(9.5.4) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-32Recommendation: The TCC directs that MAN-PLU clarify its intent with regard to the proposed reference to the Uniform Plumbing Code and that MAN-PLU consider Mr. Ziemanʼs negative comment to proposal 501-34 (log #26) in this regard. ZIEMANʼs comment is as follows:This proposal was taken directly from the UPC apparently without any attempt by the submitter to revise the content to make it compatible with Manufactured Housing. As can be seen the committee had to make numerous revisions to this proposal to try and adopt it to factory built Manufactured Housing. In hindsight the committee should have just rejected the proposal. I now urge the committee to reject the proposal and allow the submitter to resubmit it for consideration at the ROC. Besides the numerous changes made by the committee additional changes need to be made to make this proposal acceptable. They include: 1. At 9.9.4 Delete the term “UPC 604.0”. It was agreed by the committee during our discussions on this and other proposals that a reference to other codes, such as the UPC should not be included due to the confusion such refer-ences would create with the users of the standard. 2. At 9.9.4.1 first sentence delete the phrase “...building supply water pipe...” This standard (NFPA-501) does not cover water pipe outside the house. Similar references were deleted by the committee, however, this one was missed. Editorial correction to the Committee Statement item 5. The reference to 9.9.11.2 should read 9.9.4.11.2.Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Accept in Principle Accept the proposed text in proposal 501-34 as modified by the committee, and: 1. Delete “[UPC 604.4] in two places 2. In 9.9.4.1 delete “building supply water pipe”, and delete the second sen-tence 9.9.4.1 Water distribution pipe, and fitting s shall be of brass copper, copper, cast iron, CPVCCommittee Statement: The proposal as revised by the committee is accepted with the revisions recommended in the negative ballot comment and a sentence fragment is also deleted.Number Eligible to Vote: 8Ballot Results: Affirmative: 5 Ballot Not Returned: 3 CARROLL, MASTERS, PASCHAL _______________________________________________________________501-29 Log #40 MAN-PLU Final Action: Accept in Principle(9.9.4) _______________________________________________________________Submitter: Technical Committee on Plumbing for Manufactured HousingComment on Proposal No: 501-34Recommendation: Reconsider the action on this proposal. Substantiation: This comment has been generated because the Technical Committee ballot did not confirm the Technical Committee meeting action on the respective proposal. The reasons for Technical Committeeʼs members nega-tive vote are as follows: VIOLA: I agree with the comments made to 501-34 and would like to revise my vote from approve to negative. ZIEMAN: This proposal was taken directly from the UPC apparently without any attempt by the submitter to revise the content to make it compatible with Manufactured Housing. As can be seen the committee had to make numerous revisions to this proposal to try and adopt it to factory built Manufactured Housing. In hindsight the committee should have just rejected the proposal. I now urge the committee to reject the proposal and allow the submitter to resub-mit it for consideration at the ROC. Besides the numerous changes made by the committee additional changes need to be made to make this proposal accept-able. They include: 1. At 9.9.4 Delete the term “UPC 604.0”. It was agreed by the committee during our discussions on this and other proposals that a reference to other codes, such as the UPC should not be included due to the confusion such refer-ences would create with the users of the standard. 2. At 9.9.4.1 first sentence delete the phrase “...building supply water pipe...” This standard (NFPA-501) does not cover water pipe outside the house. Similar references were deleted by the committee, however, this one was missed. Editorial correction to the Committee Statement item 5. The reference to 9.9.11.2 should read 9.9.4.11.2. Committee Meeting Action: Accept in Principle Committee Statement: Refer to Committee Action on Comment 501-28 (Log # 32). Number Eligible to Vote: 8Ballot Results: Affirmative: 5

Zone UoZone Existing Uo Initial DOE Proposed Uo

Revised Proposed Uo1 0.116 0.86 0.089

2 0.096 0.076 0.0773 0.079 0.064 0.064

501-24

Report on Comments — Copyright, NFPA NFPA 501 Ballot Not Returned: 3 CARROLL, MASTERS, PASCHAL _______________________________________________________________501-30 Log #9 MAN-MEC Final Action: Reject(10.8.1.4(e)) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-39Recommendation: This proposal should be rejected.Substantiation: 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulat-ed is the concern. This proposal just lists the States where this provision needs to be implemented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would likely be a requirement for the retailer, and may have to be an aftermarket provision required after the homeʼs production, which the manufacturer cannot control. NFPA 501 does not cover this type of aftermarket issue and deals with the ini-tial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The subject matter of the comment is outside the committeeʼs scope. See Comment 501-31 (Log #10) which was addressed by MAN-STR and comment 501-32 (Log #11) which was addressed by MAN-PLU for action on the subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on proposal 501-39 which was to defer all action on the proposal to MAN-STR and MAN-PLU. Number Eligible to Vote: 12Ballot Results: Affirmative: 9 Abstain: 3Explanation of Abstention: HEIMAN: See my Explanation of Abstention on Comment 501-7 (Log #1b). STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b). WALTER: This seems to be better handled by the states as an on-site require-ment in certain areas. Typically, manufacturers brace water heaters for over the road movement of the home. Should a seismic design apply at identified sites, little additional construction would be required. _______________________________________________________________501-31 Log #10 MAN-STR Final Action: Reject(10.8.1.4(e)) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-40Recommendation: This proposal should be rejected. Substantiation: 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulated is the concern. This proposal just lists the States where this provision needs to be implemented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer. It would appear to be an aftermarket requirement that the manufacturer may have no control over after the homeʼs production. NFPA 501 does not cover this type of aftermarket issue and deals with the ini-tial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Committee Meeting Action: Reject Committee Statement: Please note, the commenter has asked that the com-mittee action on Proposal 501-40 be changed to ʻreject. ̓However, the TCC ROP ballot failed to uphold the Technical Committee ROP ballot action, so the current action on Proposal 501-40 is ʻreject. ̓However, in Comment 501-38 (Log #42), the Technical Committee reaffirms the technical committee ballot action taken on Proposal 501-40, as reflected in the ROP. Therefore, the Technical Committee has chosen to reject this comment, based upon the commenterʼs original intent. See Committee Statement on Comment 501-38 (Log #42) for responses to individual issues brought up by commenter. Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN

_______________________________________________________________501-32 Log #11 MAN-PLU Final Action: Reject(10.8.1.4(e)) _______________________________________________________________Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-41Recommendation: This proposal should be rejected based on the following reasons: 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulated is the con-cern. This proposal just lists the States where this provision needs to be imple-mented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer. It would appear to be an aftermarket requirement that the manufacturer may have no control over after the homeʼs production. NFPA 501 does not cover this type of aftermarket issue and deals with the ini-tial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation. Substantiation: None.Committee Meeting Action: Reject Committee Statement: Refer to Committee Action on Comment 501-37 (Log # 34). The committee agrees that this is a regional requirement, but the refer-ence to seismic design areas accommodates this. Because water heaters are supplied with the manufactured housing, the local AHJ is not involved.Number Eligible to Vote: 8Ballot Results: Affirmative: 5 Ballot Not Returned: 3 CARROLL, MASTERS, PASCHAL _______________________________________________________________501-33 Log #21 MAN-MEC Final Action: Reject(10.8.1.4(e)) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-39Recommendation: This proposal should be rejected. Substantiation: 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulat-ed is the concern. This proposal just lists the States where this provision needs to be implemented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would likely be a requirement for the retailer, and may have to be an aftermarket provision required after the homeʼs production, which the manufacturer cannot control. NFPA 501 does not cover this type of aftermarket issue and deals with the ini-tial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The subject matter of the comment is outside the committeeʼs scope. See Comment 501-34 (Log #22) which was addressed by MAN-STR and Comment 501-35 (Log #23) which was addressed by MAN-PLU for action on the subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-39 which was to defer all action on the proposal to MAN-STR and MAN-PLU. Number Eligible to Vote: 12Ballot Results: Affirmative: 9 Abstain: 3Explanation of Abstention: HEIMAN: See my Explanation of Abstention on Comment 501-7 (Log #1b). STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b). WALTER: See my Explanation of Abstention on Comment 501-30 (Log #9). _______________________________________________________________501-34 Log #22 MAN-STR Final Action: Reject(10.8.1.4(e)) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-40Recommendation: This proposal should be rejected.Substantiation: 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulat-ed is the concern. This proposal just lists the States where this provision needs to be implemented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer. It would appear to be an aftermarket requirement that the manufacturer may have no control over after the homeʼs production.

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Report on Comments — Copyright, NFPA NFPA 501 NFPA 501 does not cover this type of aftermarket issue and deals with the ini-tial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Committee Meeting Action: Reject Committee Statement: See Committee Statement on Comment 501-31 (Log#10).Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN _______________________________________________________________501-35 Log #23 MAN-PLU Final Action: Reject(10.8.1.4(e)) _______________________________________________________________Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-41Recommendation: This proposal should be rejected based on the following reasons: 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulated is the con-cern. This proposal just lists the States where this provision needs to be imple-mented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer. It would appear to be an aftermarket requirement that the manufacturer may have no control over after the homeʼs production. NFPA 501 does not cover this type of aftermarket issue and deals with the ini-tial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Substantiation: None.Committee Meeting Action: Reject Committee Statement: Refer to Committee Action on Comment 501-37 (Log # 34). The committee agrees that this is a regional requirement, but the refer-ence to seismic design areas accommodates this. Because water heaters are supplied with the manufactured housing, the local AHJ is not involved.Number Eligible to Vote: 8Ballot Results: Affirmative: 5 Ballot Not Returned: 3 CARROLL, MASTERS, PASCHAL _______________________________________________________________501-36 Log #33 MAN-STR Final Action: Reject(10.8.1.4(e) (New) ) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-40Recommendation: The TCC directs that MAN-STR consider revising pro-posed paragraph 10.8.1.4(e) so that all water heater appliances installed in manufactured homes be braced, anchored or strapped regardless of where the manufactured home is intended to be sold. The TCC believes that this load requirement is generally not difficult to meet, and it would eliminate the neces-sity for having to define the seismic design categories in NFPA 501.Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Reject Committee Statement: The Technical Committee does not agree that water heaters in homes in SDC A, B and C should be required to be strapped for the 200 lb. static lateral load. However, the Technical Committee recognizes that this load requirement is not difficult to meet and that many manufacturers may chose to strap all water heaters as a result of this modification. In addition, the new seismic design requirements in NFPA 501 define SDC within the confines of NFPA 501 -- the user is not referenced out to ASCE 7. In Comment 501-38 (Log #42), the Technical Committee reaffirms their commitment to have this provision in NFPA 501.Number Eligible to Vote: 16Ballot Results: Affirmative: 14 Ballot Not Returned: 2 FARISH, MENDLEN _______________________________________________________________501-37 Log #34 MAN-PLU Final Action: Accept(10.8.1.4(e) (New) ) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-41Recommendation: The TCC notes that this proposal pertains to the bracing, anchoring and strapping of water heater appliances and that it is the same as proposal 501-40 (log#5a) which was addressed by MAN-STR. The action taken by MAN-PLU is not consistent with the action taken by MAN-STR. The TCC believes that since proposal 501-41 pertains to structural requirements, it is not within the scope of MAN-PLU and that MAN-STR should hold respon-

sibility for action on this proposal. Therefore, the TCC directs that action on this proposal be Accept-in-Principal with all action on the proposal deferred to proposal 501-40 (log#5a). Substantiation: This comment is a result of a TCC note that was generated during the TCCʼs ROP meeting.Committee Meeting Action: Accept The committee affirms its action on Proposal 501-41 as shown in the ROP.Committee Statement: The committee believes that this a plumbing item, not a structural item, because it is specific to one plumbing appliance, not the building structure. This is consistent with plumbing code requirements. The committee prefers the prescriptive requirement to the performance requirement proposed by the structural committee because it would be consis-tent with plumbing codes. The committee notes that the specific detail of the strap and its attachment is part of the manufactures design approval package, and is not needed in NFPA 501.

Number Eligible to Vote: 8Ballot Results: Affirmative: 5 Ballot Not Returned: 3 CARROLL, MASTERS, PASCHAL _______________________________________________________________501-38 Log #42 MAN-STR Final Action: Accept in Principle(10.8.1.4(e) (New) ) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-40Recommendation: Reconsider the action on this proposal. Substantiation: This comment has been generated because the TCC ballot did not confirm the Technical Committee meeting action on the respective proposal.The reason for negative votes are as follows: Mr. Farish voted negatively stating: Since this was not a segmented ballot I am forced to vote negative due to the problems with only a few of the proposals. • I do not feel the difficulties in similar proposals have been resolved (such as the two wind proposals, 501-6 (Log #1), and 501-10 (Log #29), and 501-49 (Log #15a). • I am uncomfortable with the apparently poor resolution of single issues given to multiple TCʼs (such as 501-41 (Log #5b). • There is not a good correlation between proposals that addressed similar issues in different areas (such as the seismic proposals in 501-11 (Log #30), 501-40 (Log #5a), and 501-41 (Log #5b).Mr. Ghorbani voted negatively on the entire document stating: Represing the views and interest of MH producers, I continue to remain uncomfortable with what these changes would do to the affordability aspect of these homes. To vote affirmative on these proposals, I need to see more data and factual numbers on cost vs. benefits that these changes would bring to these homes. In addition, there are several discrepencies on these proposals on such things as correlating with related items and imposition on the authority of the local jurisdictions. Mr. Tomasbi voted negatively stating: 501-39 and 501-40: This may have conflict with AHJ authority for other installation. Mr. Gilchrist voted negatively stating: Proposals 501-39 (Log #5), 501-40 (Log #5a), and 501-41 (Log #5b) all relate to water heaters and question whether NFPA 501 should deal with this aftermarket issue when perhaps it is better addressed within each state or local jurisdiction, other wise all homes have to meet these requirements when many may not in reality have to. Mr. Walter voted negatively stating: More than one Technical Committee had the opportunity to comment on the changes that involve wind and seismic requirements, and their reactions and votes were not coordinated between them. In addition, there are no econonmic benefit-cost analyses to accompany the proposed significant increases in stan-dards for wind, seismic and flood safety. Proposal 501-40 (Log #5a) 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulated is the con-cern. This proposal just lists the states where this provision needs to be imple-mented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer, and would have to be a provision after-the fact of the homeʼs production. NFPA 501 does not cover this type of aftermarket issues and deals with the initial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Committee Meeting Action: Accept in Principle The Technical Committee has followed the TCCʼs recommendation to recon-sider the action on Proposal 501-40. By voting accept in principle on Comment 501-38 (Log #42), the Technical Committee reaffirms the Technical Committee

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Report on Comments — Copyright, NFPA NFPA 501 ROP ballot action taken on Proposal 501-40, as reflected in the ROP.Committee Statement: In this comment, the Technical Committee reaffirms their commitment to specifying water heater strapping requirements in SDCs D0, D1, D2 and E of NFPA 501. In addition, the Technical Committee has the following responses to each of the TCCʼs negative votes. 1. Mr. Farish: This Technical Committee will make recommendations to ensure coordination between the cited proposals. 2. Mr. Ghorbani: An economic analysis is provided with the committee state-ment on Comment 501-21 (Log #37). The Technical Committee notes that the proposed seismic requirements do not adversely affect the AHJʼs authority. 3. Mr. Tomasbi: The Technical Committee is unclear on commenterʼs con-cern. 4. Mr. Gilchrist: The Technical Committee believes that water heater bracing should be done by the manufacturer, since he is familiar the specifications of the involved products. 5. Mr. Walter: Introductory comment: The economic analysis is provided in Comment 501-21 (Log #37). Ballot Comment 1: Agree -- listing should be based upon SDCs and not states. Ballot Comment 2: See explanation above. Ballot Comment 3: See explanation above. Number Eligible to Vote: 16Ballot Results: Affirmative: 13 Negative: 1 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-2 (Log #35).

_______________________________________________________________501-39 Log #43 MAN-PLU Final Action: Reject(10.8.1.4(e) (New) ) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-41Recommendation: Reconsider the action on this proposal. Substantiation: This comment has been generated because the TCC ballot did not confirm the Technical Committee meeting action on the respective pro-posal. The reson for negative votes are as follows: Mr. Farish voted negatively stating: Since this was not a segmented ballot I am forced to vote negative due to the problems with only a few of the proposals. • I do not feel the difficulties in similar proposals have been resolved (such as the two wind proposals, 501-6 (Log #1), and 501-10 (Log #29), and 501-49 (Log #15a). • I am uncomfortable with the apparently poor resolution of single issues given to multiple TCʼs (such as 501-41 (Log #5b). • There is not a good correlation between proposals that addressed similar issues in different areas (such as the seismic proposals in 501-11 (Log #30), 501-40 (Log #5a), and 501-41 (Log #5b). Mr. Ghorbani voted negatively on the entire document stating: Represing the views and interest of MH producers, I continue to remain uncomfortable with what these changes would do to the affordability aspect of these homes. To vote affirmative on these proposals, I need to see more data and factual numbers on cost vs. benefits that these changes would bring to these homes. In addition, there are several discrepencies on these proposals on such things as correlating with related items and imposition on the authority of the local jurisdictions. Mr. Gilchrist voted negatively stating: Proposals 501-39 (Log #5), 501-40 (Log #5a), and 501-41 (Log #5b) all relate to water heaters and question whether NFPA 501 should deal with this aftermarket issue when perhaps it is better addressed within each state or local jurisdiction, other wise all homes have to meet these requirements when many may not in reality have to. Mr. Walter voted negatively stating: More than one Technical Committee had the opportunity to comment on the changes that involve wind and seismic requirements, and their reactions and votes were not coordinated between them. In addition, there are no econonmic benefit-cost analyses to accompany the proposed significant increases in stan-dards for wind, seismic and flood safety. Proposal 501-41 (Log #5b) 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulated is the con-cern. This proposal just lists the states where this provision needs to be imple-mented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer, and would have to be a provision after-the-fact of the homeʼs production. NFPA 501 does not cover this type of aftermarket issues and deals with the initial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.

Committee Meeting Action: Reject Committee Statement: Refer to Committee Action on Comment 501-28 (Log # 32). In addition, the committee notes that economics is always an issue, but that the safety aspects of water heaters in seismic events is the primary consider-ation. Number Eligible to Vote: 8Ballot Results: Affirmative: 5 Ballot Not Returned: 3 CARROLL, MASTERS, PASCHAL _______________________________________________________________501-40 Log #38 MAN-MEC Final Action: Reject(10.8.1.4(e), 6.3 and 14.11 (New) ) _______________________________________________________________Submitter: Technical Correlating Committee on Manufactured HousingComment on Proposal No: 501-39Recommendation: Reconsider the action on this proposal.Substantiation: This comment has been generated because the TCC ballot did not confirm the Technical Committee action on the respective proposal. The reasons for negative votes are as follows: Mr. Ghorbani voted negatively on the entire document stating: Repressing the views and interest of MH producers, I continue to remain uncomfortable with what these changes would do to the affordability aspect of these homes. To vote affirmative on these proposals, I need to see more data and factual numbers on cost vs. benefits that these changes would bring to these homes. In addition, there are several discrepancies on these proposals on such things as correlating with related items and imposition on the authority of the local jurisdictions. Mr. Tomasbi voted negatively stating: 501-39 and 501-40: This may have conflict with AHJ authority for other installation. Mr. Gilchrist voted negatively stating: Proposals 501-39 (Log #5), 501-40 (Log #5a), and 501-41 (Log #5b) all relate to water heaters and question whether NFPA 501 should deal with this aftermarket issue when perhaps it is better addressed within each state or local jurisdiction, other wise all homes have to meet these requirements when many may not in reality have to. Mr. Walter voted negatively stating: More than one Technical Committee had the opportunity to comment on the changes that involve wind and seismic requirements, and their reactions and votes were not coordinated between them. In addition, there are no economic benefit-cost analyses to accompany the proposed significant increases in stan-dards for wind, seismic and flood safety. Proposal 501-39 (Log #5) 1. While there may be agreement that water heaters should be braced against seismic events, the manner in which the requirement is stipulated is the con-cern. This proposal just lists the states were this provision needs to be imple-mented. 2. This can be a problem for manufacturers when, in most instances, they have no idea where the home final installation site will be. This would be a requirement for the retailer, and would have to be a provision after the fact of homeʼs production. NFPA 501 does not cover this type of aftermarket issues and deals with the initial design and construction of the home itself. 3. Since this appears to be a regional requirement, it might be better to have this provision required by the local jurisdiction. This could be a requirement for the “installation of the home at its final destination site.” In this manner, the AHJ has the authority to stipulate certain additional installation features since they are responsible for the homeʼs installation.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-ject matter of the comment is outside the committeeʼs scope. See Comment 501- 38 (Log #42) which was addressed by MAN-STR and Comment 501-39 (Log #43) which was addressed by MAN-PLU for action on the subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-39 which was to defer all action on the proposal to MAN-STR and MAN-PLU. Number Eligible to Vote: 12Ballot Results: Affirmative: 9 Abstain: 3Explanation of Abstention: HEIMAN: See my Explanation of Abstention on Comment 501-7 (Log #1b). STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b). WALTER: See my Explanation of Abstention on Comment 501-30 (Log #9). _______________________________________________________________501-41 Log #12 MAN-ADM Final Action: Reject(14.1.2.10) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-48Recommendation: This proposal should be rejected. Substantiation: This change is dependent on NFPA proposal number 225-2 (Log #71) and other proposals submitted to various NFPA 501 Technical Committees that relate to updating the seismic and wind provisions within the 501 Standard to the ASCE 7-2002 edition. 1. A simple update of this reference standard should not be permitted because of the ramifications it could have with the design provisions contained within

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Report on Comments — Copyright, NFPA NFPA 501 NFPA 501. 2. Updating this reference standard will increase various loads for manufac-tured home design that are not required by the present HUD Code, or what manufactured home producers are requiring for todayʼs design processes. 3. The present HUD Code and NFPA 501 base their wind load design on the ASCE 7-1988 edition. 4. This change should only be approved if other changes, being considered by the other NFPA 501 Technical Committees, are approved during this current revision cycle. Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-ject matter of the comment is outside the committeeʼs scope. See Comment 501-42 (Log #13) which was addressed by MAN-STR for action on subject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-48 which was to defer all action on the proposal to MAN-STR. Also, see Proposal 501-49.Number Eligible to Vote: 9Ballot Results: Affirmative: 7 Abstain: 2Explanation of Abstention: GHORBANI: See my reason for abstaining on Comment 501-16 (Log #20). GORMAN: See my Explanation of Abstnetion on Comment 501-16 (Log #20). _______________________________________________________________501-42 Log #13 MAN-STR Final Action: Reject(14.1.2.10) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Mark A. Nunn, Manufactured Housing Inst.Comment on Proposal No: 501-49Recommendation: This proposal should be rejected. Substantiation: 1. This change is dependent on NFPA proposal number 225-3 (Log #71a) and other proposals submitted to various NFPA 501 Technical Committees that relate to updating the seismic and wind provisions within the 501 Standard to the ASCE 7-2002 edition. 2. A simple update of this reference standard should not be permitted because of the ramifications it could have with the design provisions contained within NFPA 501. 3. Updating this reference standard will increase various loads for manufac-tured home design that are not required by the present HUD Code, or what manufactured home producers are requiring for todayʼs design processes. 4. The present HUD Code and NFPA 501 base their wind load design on the ASCE 7-1988 edition. 5. This change should only be approved if other changes being considered are approved during this current revision cycle.Committee Meeting Action: Reject Committee Statement: The Technical Committee chose to reject this com-ment, since they remain committed to using the 2002 edition of ASCE 7. Actions by the Technical Committee in the ROC meeting have called for the use of ASCE 7-02 as the basis for wind and seismic design loads.Number Eligible to Vote: 16Ballot Results: Affirmative: 11 Negative: 3 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: On the surface, update to a more current reference standard might appear to be a reasonable thing to do. However, this should be delayed until there is adequate analysis of the total implications of the proposed change. HEROUX: • This change is dependent on NFPA proposal number ROP item 225-2 (Log #71) and/or 225-3 (Log #71a) and other proposals submitted to various NFPA 501 Technical Committees that relate to updating the seismic and wind provisions within the 501 Standard to the ASCE 7-2002 edition.• A simple update of this reference standard should not be permitted because of the ramifications it could have with the design provisions contained within NFPA 501/• This change should only be approved if other wide sweeping changes being considered (wind and seismic updates) are approved during this current revi-sion cycle. KINARD: See my Explanation of Negative on Comment 501-12 (Log #7).

_______________________________________________________________501-43 Log #24 MAN-ADM Final Action: Reject(14.1.2.10) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-48Recommendation: This proposal should be rejected.Substantiation: This change is dependent on NFPA proposal number 225-2 (Log #71) and other proposals submitted to various NFPA 501 Technical Committees that relate to updating the seismic and wind provisions within the 501 Standard to the ASCE 7-2002 edition. 1. A simple update of this reference standard should not be permitted because of the ramifications it could have with the design provisions contained within NFPA 501.

2. Updating this reference standard will increase various loads for manufac-tured home design that are not required by the present HUD Code, or what manufactured home producers are requiring for todayʼs design processes. 3. The present HUD Code and NFPA 501 base their wind load design on the ASCE 7-1988 edition. 4. This change should only be approved if other changes, being considered by the other NFPA 501 Technical Committees, are approved during this current revision cycle.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-ject matter of the comment is outside the committeeʼs scope. See Comment 501- 44 (Log #25) which was addressed by MAN-STR for action on the sub-ject matter associated with this comment. By taking this action the committee also affirms its ROP meeting action on Proposal 501-48 which was to defer all action on the proposal to MAN-STR. Also see Proposal 501-49.Number Eligible to Vote: 9Ballot Results: Affirmative: 7 Abstain: 2Explanation of Abstention: GHORBANI: See my reason for abstaining on Comment 501-16 (Log #20). GORMAN: See my Explanation of Abstnetion on Comment 501-16 (Log #20)._______________________________________________________________501-44 Log #25 MAN-STR Final Action: Reject(14.1.2.10) _______________________________________________________________TCC Note: This comment did not receive the required three-fourths affir-mative vote, and therefore, this comment is being reported as reject.Submitter: Doug Gorman, Home-Mart, IncorporatedComment on Proposal No: 501-49Recommendation: This proposal should be rejected.Substantiation: 1. This change is dependent on NFPA proposal number 225-3 (Log #71a) and other proposals submitted to various NFPA 501 Technical Committees that relate to updating the seismic and wind provisions within the 501 Standard to the ASCE 7-2002 edition. 2. A simple update of this reference standard should not be permitted because of the ramifications it could have with the design provisions contained within NFPA 501. 3. Updating this reference standard will increase various loads for manufac-tured home design that are not required by the present HUD Code, or what manufactured home producers are requiring for todayʼs design processes. 4. The present HUD Code and NFPA 501 base their wind load design on the ASCE 7-1988 edition. 5. This change should only be approved if other changes being considered are approved during this current revision cycle.Committee Meeting Action: Reject Committee Statement: See Committee Statement on Comment 501-42 (Log #13).Number Eligible to Vote: 16Ballot Results: Affirmative: 11 Negative: 3 Ballot Not Returned: 2 FARISH, MENDLENExplanation of Negative: BRYANT: See my Explanation of Negative Vote on Comment 501-42 (Log #13). HEROUX: See my Explanation of Negative for Comment 501-42 (Log #13). KINARD: See my Explanation of Negative on Comment 501-12 (Log #7).

_______________________________________________________________501-45 Log #41 MAN-ADM Final Action: Reject(14.1.2.10) _______________________________________________________________Submitter: Technical Committee on Administration for Manufactured HousingComment on Proposal No: 501-48Recommendation: Reconsider the action on this proposal.Substantiation: This comment has been generated because the Technical Committee ballot did not confirm the Technical Committee meeting action on the respective proposal. The reasons for TC members negative votes are as fol-lows: GHORBANI: The proposed change would affect many other aspects of a manufactured home. The details of which (particularly cost vs. benefits) are unknown at this time. More details/information on these other factors are nec-essary before this change can be considered. GILCHRIST: Negative response for following reasons, even though it is rec-ognized that this has been deferred to the technical committee on structural. 1. Any changes in this item relate to a number of other factors that should also be coordinated and reviewed at the same time, including wind loading requirements, HUD requirements and the normal manufacturing design and approval process. GORMAN: Increases load designs not required by HUD code. ROBERTS: While this proposal has been deferred to the TC-STR for its con-sideration, I am voting negative on this item. 1. There needs to be careful consideration for changes to any of the design loads in the standards. Simply updating a reference standard without consider-ing the affect on the changes in design should not be permitted.Committee Meeting Action: Reject Committee Statement: This comment is rejected without prejudice. The sub-

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Report on Comments — Copyright, NFPA NFPA 501 ject matter of the comment is outside the committeeʼs scope. See Comment 501-42 (Log #13) and Comment 501-44 (Log #25) which were addressed by MAN-STR for action on the subject matter associated with these comments. By taking this action the committee also affirms its ROP meeting action on Proposal 501-48 which was to defer all action on the proposal to MAN-STR. Also see Proposal 501-49.Number Eligible to Vote: 9Ballot Results: Affirmative: 9 _______________________________________________________________501-46 Log #27 MAN-MEC Final Action: Accept in Principle(A.8.7.1, 8.6.1.4) _______________________________________________________________Submitter: Christopher Early, US Department of Energy / Rep. UO TAsk group of Technical Committee on Mechanical For Manufactured HousingComment on Proposal No: 501-53Recommendation: Revise text to read as follows: To minimize the cooling load in hot climates [1500 Cooling Degree Days Base 65°F (18.3°C) consideration should be given to using windows with a the glazing in windows of homes located in Zone 1 of Figure 8.6 shall have with an average solar heat gain coefficient no greater than 0.60 0.40, based on tests using NFRC 100, Procedure for Determining Fenestration Product Thermal Properties. Homes designed and constructed with overhangs, awnings, or other permanent shading devices that limit heat gain through the window by an amount equivalent to a 0.40 SHGC window without any shading devices shall be considered to comply with this section. Substantiation: The major committee concern seems to be the price of the windows required to achieve a low SHGC in the southern zone. The ability of low SHGC windows to save cooling energy was not disputed. Perceptions of the price of low-E coatings, used to achieve a low SHGC, vary a great deal. The price of such coatings is falling fast as low-E coatings become the norm in many areas; for example, these coatings have become much more available and economical for site-built homes in Texas in the last two years. Although it is fair to admit low-E pricing in the windows industry is in transition, DOE believes the prices assumed in its original analysis were reasonable and requests a reconsideration of the requirement for a 0.40 SHGC in zone 1. This proposed requirement is very similar to the SHGC requirement for site-built homes that has been in the IECC since 1989 and would significantly reduce manufactured home cooling loads.Committee Meeting Action: Accept in Principle 1. Do not accept the submitterʼs recommendation to revise Section 8.6.1.4. 2. Delete existing text to section A.8.7.1 and replace with the following: “A.8.7.1 To minimize the cooling load of homes located in zone 1 of figure 8.6, consideration should be given to overhangs, awnings or other permanent shading devices or the use of glazing with 0.40 solar heat gain coefficient (SHGC) for double pane windows, and 0.60 SHGC for single pane windows with or without storm windows. SHGC should be based on tests using NFRC-200, Procedures for Determining Fenstration Product Thermal Properties. “Committee Statement: The committee does not believe that the language pro-posed by the submitter is appropriate for inclusion as a mandatory requirement. A significant degree of variability exists with regard to the actual placement of the manufactured home on the home site with respect to the position of the sun at the home site.. Additionally, no cost benefit analysis was completed. However, the committee agrees that guidance on available and accepted prac-tices for improving energy efficiency should be included in the standard. Number Eligible to Vote: 12Ballot Results: Affirmative: 10 Negative: 1 Abstain: 1Explanation of Negative: BACHRACH: The requirements should be mandatory.Explanation of Abstention: STEVENS: See my reason for abstaining on Comment 501-7 (Log #1b).Comment on Affirmative HEIMAN: See my Affirmative with Comment on Comment 501-26 (Log #28).

Report on Comments — Copyright, NFPA NFPA 501€¦ · Electrical for Manufactured Housing (MAN-ELE) Robert A. McCullough, Chair Ocean County Construction Inspection Dept., NJ [E]

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