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Modify Maui code to promote manufactured, modular homes

The following testimony was submitted by the Grassroot Institute of Hawaii for consideration by the Maui County Council on June 7, 2024.
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June 7, 2024, 9 a.m.
Council Chamber
Kalana O Maui Building

To: Maui County Council
       Alice Lee, Chair
       Yuki Lei Sugimura, Vice-Chair

From: Jonathan Helton, Policy Researcher
           Grassroot Institute of Hawaii

RE: COMMENTS ON BILL 98 — A BILL FOR AN ORDINANCE AMENDING CHAPTERS 16.18B, 16.20C, AND 16.25, MAUI COUNTY CODE, ON MANUFACTURED AND MODULAR HOMES

Aloha Chair Lee, Vice-Chair Sugimura and other Councilmembers,

The Grassroot Institute of Hawaii would like to offer its support for Bill 98 (2024), which would modify the county building code to promote the construction of manufactured and modular homes.

Specifically, the bill would define both “manufactured home” and “modular home” for the purpose of providing a predictable building permit process for each type of dwelling that recognizes how each differs from traditional on-site builds.

Manufactured homes would include dwellings built completely in a factory, while modular homes would comprise dwellings 75% or more of which have been constructed off-site and then assembled on-site.

Manufactured homes that meet the federal Department of Housing and Urban Development’s Manufactured Home Construction and Safety Standards would not need permits for certain electrical, plumbing or building work performed in the process of constructing the home in a factory. Hawaii and Honolulu counties both regulate manufactured homes in a similar fashion.[1]

The Manufactured Housing Institute describes HUD’s Manufactured Home Construction and Safety Standards as regulating “all aspects of construction, including design and construction strength, durability, transportability, fire resistance, and energy efficiency.”[2]

The Harvard University Joint Center for Housing Studies analyzed existing research into manufactured housing and found that the quality of manufactured housing has improved as regulations and market practices have changed.[3]

According to the study: “The share of manufactured homes built in the previous decade deemed inadequate (that is, exhibiting a range of structural inadequacies, such as poorly functioning systems or significant maintenance problems) fell consistently from the 1980s through the first part of the 2000s, differing little from site-built homes after the improvements in the 1990s.”

Under Bill 98, modular homes also would be exempt from needing a traditional building permit, provided that the modular home manufacturers certify that their buildings meet applicable electrical, plumbing and residential codes.

To help ensure safety, this exemption would not eliminate the need for inspections for any on-site construction needed to finish the home.

Research indicates that modular homes offer improvements in safety and efficiency compared to traditional on-site builds, partly because they tend to involve fewer worker injuries.[4]

Because of Maui County’s slow permitting process,[5] this measure could provide certainty to anyone seeking to install manufactured or modular housing on Maui, Molokai or Lanai, while still ensuring safety.

The permit exemptions provided in the bill also would allow the county’s Departments of Planning and Public Works to focus their time on permits that need more in-depth review.

Overall, the Grassroot Institute believes this bill could be a powerful tool for individuals and homebuilders looking to help solve the county’s housing shortage.

Thank you for the opportunity to testify.

Jonathan Helton
Policy Researcher
Grassroot Institute of Hawaii
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[1] See: ARTICLE 3: FACTORY-BUILT BUILDINGS, Revised Ordinances of Honolulu, accessed June 4, 2024; and “Chapter 5B, Division 2, APPENDIX U FACTORY-BUILT HOUSING,” Hawaii County Code, accessed June 4, 2024.
[2]HUD Manufactured Housing Construction and Safety Standards,”Manufactured Housing Institute, June 12, 2023.
[3] Christopher Herbert, Alexander Hermann, Daniel McCue and Chadwick Reed, “A Review of Barriers to Greater Use of Manufactured Housing for Entry-Level Homeownership,” Harvard University Joint Center for Housing Studies, January 2024, p. 13.
[4] Gilsu Jeonga, Hyunsoo Kim, Hyun-Soo Lee, Moonseo Park and Hosang Hyun, “Analysis of safety risk factors of modular construction to identify accident trends,” Journal of Asian Architecture and Building Engineering, Feb. 24, 2021; and Jen Miller, “Modular building creates fewer jobsite hazards, but isn’t without dangers,” Construction Dive, Sept. 7, 2023.
[5] Daniela Bond-Smith, Rachel Inafuku and Justin Tyndall, “The Hawaii Housing Factbook 2024,” Economic Research Organization at the University of Hawai‘i, May 20, 2024, p. 9.

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