Increasing Minimum Entry Door Width in Manufactured Housing

TxLIHIS recently submitted Comments to the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee to HUD on the regulation of manufactured housing, regarding its review of the minimum exterior door and interior hallway widths allowed in the building code for such homes.  These comments follow:

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April 8, 2011

Mark J. Mazz, AIA

General Subcommittee Chair, MHCC

Via Email.

RE: Comments on MHCC Log items #2, #3, #11, related to increasing the minimum width of exterior doors and interior hallways of HUD-code homes.

Dear Mr. Mazz:

The Texas Low Income Housing Information Service has compiled the following analysis and commentary related to the minimum width of entry doors and interior hallways of manufactured homes built to the HUD code.  We submit this information for consideration by the Manufactured Housing Consensus Committee (MHCC) during its evaluation of log items #2, #3, and #14.

1) Currently, the HUD-code allows for exterior door and interior hallways (“passageways”) to be as narrow as 28-inches, significantly narrower than the minimum width requirements of the International Residential Code, a building code commonly adopted by localities to regulate site-built housing.  A 28-inch passageway prevents entry and use by people with disabilities who rely upon the use of mobility aids such as wheelchairs.

2) Data from the American Housing Survey indicates 13% of MH units contain at least one person that has a “serious difficulty walking or climbing stairs.”  This rate of walking disability is higher than the rate of 9% in the nation’s house stock as a whole.  Residents who “age in place” in their homes have an higher chance of having, or living with someone with, a walking disability: 21% of MH households who have lived in their unit for 10 years or more include someone with a walking disability.[1]

3) The HUD-code and initial design approval only addresses the initial, in factory, construction, complicating post-construction modifications widen doorways or interior hallways.  While these modification must technically be made to local codes, the impact of these modifications to the health and safety standards (such as wind resistance) addressed by the HUD code are unlikely to be evaluated at the time of modification.  Many companies specializing in accessibility remodeling avoid working on manufactured homes due to their non-conventional construction.[2]

4) Post-construction modifications to widen doors are significantly more expensive than incorporating wider passageways in the initial design and construction.  While the production cost of increasing door width is negligible,[3] invoice data from the Amy Young Barrier Removal Program, a Texas home-modification program addressing the accessibility needs of low-income Texans, documents a cost of over slightly over $1000 per door to widen exterior doors on a manufactured home.[4]

5) Giving consumers “the choice” of inaccessible doors and hallways effectively increases the end-cost to consumers of more accessible design in the retail process.  This is due to “versioning,” a marketing technique that uses any consumer choice opportunity to extract additional value from consumers.[5] Under versioning, retailers may offer a less-accessible door solely to justify increasing the markup on more-accessible options.  This appears to occur in manufactured home sales today: While the difference in production cost to increase the entry door width is negligible,[6] a retailer gave us a $300-500 quote for this “upgrade.”[7]

6) Design limitations on the ability of residents to age in place increases lifetime healthcare costs to the purchaser and, thorough Medicaid, state and federal governments.  Community Based Care provides home-based services and supports for older people and those who have disabilities, and costs, on average, $51.30 per day in Texas.  For those who cannot age in place in their homes, perhaps due to inaccessible design, Nursing Home care costs, on average, $127.14 per day in Texas.  This is an increase of $75.84 per day.[8]

7) Maintaining 28-inch doors and hallways in the HUD-code encourages the manufacture of homes designed to exclude use by a significant portion of the US population.  Building codes address the fact that a building is a durable good that must anticipate use over the life of the building.  Not only does narrow entry and interior passage negatively impact the changing needs of the first purchaser of the home[9] and exclude potential visitors to the home, such design inherently limits the housing choice of disabled Americans who wish to buy a used manufactured home.  HUD has a responsibility, under Executive Order 12892, to administer its programs and activities (including its “exercise of regulatory responsibility”) to affirmatively further fair housing.  28-inch entry doors and interior hallways are an impediment to housing choice for people with disabilities, and HUD has a responsibility to take action to address this impediment.

Based on the facts and analysis above, the Texas Low Income Housing Information Service strongly encourages HUD and the MHCC to adopt proposals to increase the minimum width of the passageways of Manufactured Homes built under the HUD code.

Sincerely,

Kevin Jewell