In part 1 we looked at tiny homes as site built homes; in part 2 we asked the question, “Are tiny homes RVs?” Now we will look to see if we can find a spot for our tiny homes in the manufactured home industry.
In the last installment we looked at some reasons why the RV industry might not be the best place for tiny home manufacturers to end up.
This time we will look into the manufactured and modular home industries and see if we can find a home for our tiny home companies. For this blog I spoke with Lois Starkey at the Manufactured Housing Institute (MHI). MHI is the trade organization for the factory built home industry, this would include both manufactured (formerly mobile homes) and modular homes.
We spoke at length about the differences between manufactured and modular homes. The most important difference is that manufactured homes are built to a standard set by HUD (Housing and Urban Development, a federal level organization) and modular homes are built to comply with the standards of the municipality in which they will reside — oftentimes being the International Residential Building Code (mentioned in part 1) along with some local amendments.
Other differences include the distinct difference that manufactured homes can be moved to a new site at a later time. Modular homes are designed to be setup permanently at one location; for those unfamiliar with the term modular home, it is a single or multiple section home that is constructed in a factory setting and then delivered to a site, setup and attached permanently to a foundation. Since modular homes are more like site built we are going to focus on manufactured homes for the rest of this post.
If we look in the Code of Federal Regulations in 24 CFR 3280 under section:
Section 3280.2 Definitions
Manufactured home means a structure, transportable in one or more sections, which in the traveling mode is 8 body feet or more in width or 40 body feet or more in length or which when erected on-site is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained in the structure. This term includes all structures that meet the above requirements except the size requirements and with respect to which the manufacturer voluntarily files a certification pursuant to § 3282.13 of this chapter and complies with the construction and safety standards set forth in this part 3280.
This is great information looks like our tiny homes can fit right into this HUD program.
Section 3280.10 Use of alternative construction.
Requests for alternative construction can be made pursuant to 24 CFR 3282.14 of this chapter.
This section, according to Ms. Starkey, will allow us to request the use of tankless water heaters, composting and incinerating toilets and other green modifications.
Below are the sections I found that cover minimum sizes.
Section 3280.109 Room requirements.
(a) Every manufactured home shall have at least one living area with not less than 150 square feet (sq. ft.) of gross floor area.
(b)(1) All bedrooms shall have at least 50 sq. ft. of floor area.
(b)(2) Bedrooms designed for two or more people shall have 70 sq. ft. of floor area plus 50 sq. ft.
This is not all that big — seems tiny to me; there are a couple of other sections that we need to concern ourselves with though section 3280.102 (b) states that bathrooms are not included in the calculation of habitable space.
Section 3280.104 sets the minimum ceiling height of 7 feet, but allows up to 50% of the floor space to have a 5 foot ceiling height.
Hmm, does this mean that we could build a home on a trailer that set with a low ride height and under the 13 feet 6 inches maximum of the DOT we could have a room that is 7 feet in an above section and 5 feet in the section below?
Say maybe if we had a bedroom room over a really snuggly living room type area? There are a lot of possibilities here.
Section 3280.110 lets us have rooms that are as narrow as 5 feet wide and refers back to section 3280.102(a) which excludes bathrooms from this minimum width requirement.
Section 3280.111 sets our minimum bath width at 30 inches and the distance from the front of the toilet to any other object at 21 inches; this still allows for a fairly small restroom at around 30 inches wide by about 60 inches long.
There are a multitude of other things in 24 CFR 3280, and you can download that for free if you want to peruse it; it makes great bedtime reading for those with insomnia.
So taking into account the minimum requirements to get our tiny homes certified as manufactured homes leaves us with a home in the 208 sq. ft. range, 150 sq. ft. living area + 50 sq. ft. bedroom + 8 sq. ft. for a bathroom.
Not an insurmountable obstacle in my opinion at 8 feet 6 inches this is a 24-1/2 foot trailer and could easily be towed by a ¾ or 1 ton truck, for initial delivery and relocation.
If the community heads this direction then I envision that companies will arise in the marketplace that will be willing to move and setup your tiny home for you or you can use a regular mobile home moving company; they can be a bit pricey as they are accustomed to moving the larger homes around.
If this seems like too large of a home then my suggestion to the community is that we engage the powers that be in a dialogue of bringing it more in line with the International Residential Code that allows for a smaller home. But until we engage government as a group it is pretty easy for government to outlive the tenacity of even the most persistent of individuals.
So to bring this right back around to where we started let’s discuss as a community the defining a tiny home as a dwelling with a minimum of 120 sq. ft. of living space; I know this leaves those ultra micro 50 sq. ft. homes out of the definition, but realize that our goal here is to start to provide a definition so that we can move towards acceptance in local government for tiny homes in our cities.
I say cities here because in my experience when you are out in the rural areas outside of a city’s jurisdiction then county/parish governments lack the manpower and desire to attempt to regulate building codes for structures in rural areas unless they are compelled by a large number of people raising a concern based on the structure being a nuisance or hazard to the general health and welfare of other folks.
As Modular Homes
I decided to dig just a little bit farther since the state of Texas, where we are located, regulates manufactured homes and modular homes differently. Texas regulates modular homes through the Texas Department of Licensing and Regulation under the Industrialized Housing program. After a long discussion this seems like the best program to build tiny homes under if you want your product accepted easily into municipalities as permanent housing. There is a small loophole that was pointed out to me in Section 1202.002 of the Texas Occupational Code, (c) industrialized housing does not include (3) a ready-built home constructed in a manner in which the entire living area is contained in a single unit or section at a temporary location for the purpose of selling and moving the home to another location.
It was pointed out to me that if you were to build under this section of the code that a municipality does not have to accept your tiny home into their jurisdiction.
All in all, every program that I researched had the same basic mission: to ensure that the end user is paying for housing that is safe and functional. I did not find any glaring differences as I poured through the codes that were used to define how the building was constructed. I do think that I would like to work with other Tiny Home Builders in Texas and other parts of the US to figure out which program we want to participate in together so that we can start to become a well-respected sector of the housing industry and be allowed into municipalities as a viable housing option for home ownership.
Links to codes referenced in this blog post:
Manufactured Home Construction and Safety Standards – 24 CFR 3280
Texas Industrialized Housing and Buildings Section
Bulletin on Definition of Industrialized Housing