Date: April 7, 2011
To: Manufactured Housing Consensus Committee
Re: Accessibility-related Standards for Manufactured Housing
Thank you the opportunity to comment on the proposal to develop Accessibility-related Standards for Manufactured Housing. The Texas Council for Developmental Disabilities (TCDD) is established by federal law in the Developmental Disabilities Assistance and Bill of Rights Act and consists of a 27 member board, appointed by the Governor, 60% of whom are individuals with developmental disabilities or family members of individuals with disabilities. The Council’s purpose in law is to encourage policy change so that people with disabilities have opportunities to be fully included in their communities and exercise control over their own lives.
We understand the Manufactured Housing Consensus Committee (MHCC) is considering a proposal to HUD to increase the minimum clearance for
- Entry Doors.
- Interior Hallways in manufactured homes and is seeking input on the cost of increasing access, as well as the cost of not moving forward with the proposal.
TCDD will address the cost of not providing accessibility in manufactured housing from the viewpoint of residents or potential residents of manufactured homes with disabilities. TCDD also has specific recommendations regarding proposed minimum standards.
1. Costs of Not Providing Minimum Accessibility-Related Standards in Manufactured Housing
According to the U.S. Department of Housing and Urban Development the greatest housing needs are among people with disabilities for two primary reasons: affordability and accessibility.1 People with disabilities and their families have lower incomes on average when compared with the national average. A recent study reported that the adjusted gross income of a taxpayer with a disability was $19,100 compared to $33,800 for a worker without a disability and that wages for a taxpayer with a disability were $15,000 compared to $39,300 for a worker without a disability.2
Adults in poor families are more than twice as likely as adults in families that were not poor to have severe difficulty in each of the nine physical activities included in the Survey of Vital and Health Statistics collected annually by the Centers for Disease Control (CDC).3
The number of middle-aged Americans with certain mobility-related disabilities is on the rise, according to CDC study. More than 40 percent of people aged 50 to 64 reported having problems with at least one of nine physical functions, and many reported difficulty with more than one4.
Harvard University’s Joint Center for Housing Studies states that manufactured housing must be considered as an opportunity for affordable housing for poor and low-income families. While two-story homes and the upscale appliances in many new manufactured homes are meant to diversify the industry’s customer base, low-income families still dominate the market for manufactured homes. In a survey of 21,866 residents of manufactured homes the mean household income for those in owner-occupied manufactured homes is $28,874 compared to $66,699 for homeowners.5
Manufactured housing represents an affordable housing opportunity for individuals with disabilities. However, if manufactured housing is not built with minimum accessibility, it will not meet the needs of families of and people with disabilities, who will continue to struggle to find affordable, accessible housing options.
2. Proposed Minimum
The clearance proposed for hallway width is not sufficient to address minimum accessibility needs of individuals with disabilities who use wheelchairs.
The MCAC proposal for hallways is a minimum horizontal dimension of 30 inches (762 mm) measured from the interior finished surface to the opposite wall. This width will not accommodate the average wheelchair user. The average width of a wheelchair allowing for elbows of the user to propel the chair is commonly 35.4 inches (900 mm). That is reflected in the ADA Accessibility Guidelines (ADAAG), which state that the minimum clear passage width for a single wheelchair must be 36 inches.
To be truly accessible, the proposed minimum standards for hallway width should mirror the requirements in the ADAAG.
Thank you for the opportunity to provide input on this important matter. TCDD appreciates the work you are doing to make all affordable housing options accessible to people with disabilities and we look forward to working with you in this process.
Public Policy Specialist
- 2009 Worst Case Housing Needs of People with Disabilities: Supplement Findings of the Worst Case Housing Needs 2009: Report to Congress. March 2011. U.S. Department of Housing and Urban Development: Office of Policy Development and Research. ↩
- Creating a Roadmap Out of Poverty for Americans with Disabilities (PDF). U.S. Department of Labor. 2009. Retrieved April 7, 2011. ↩
- Summary Health Statistics for U.S. Adults: National Health Interview Survey, 2003 (PDF). U.S. Department Of Health And Human Services Centers for Disease Control and Prevention National Center for Health Statistics. Retrieved April 7, 2011. ↩
- Ibid. ↩
- Manufactured Homes a Big Factor in Rural Homeownership in U.S. Population Reference Bureau. Retrieved April 7, 2011. ↩