To:     Mr. Chris Stephens, Assistant Fire Marshal
           Manufactured Housing Division

Abbreviations
MHI - Manufactured Housing Institute
MHRA - Manufactured Housing Research Alliance

Terms
KIP - 1000 pounds

It was brought to our attention that some felt that our previous report/response was not specific to the MHI/MHRA proposal. We felt that it fully addressed the MHI/MHRA proposal, case, and point. We will however restructure to address specific statements in the MHI/MHRA proposal. This paper is as well intended for others, with a lesser understanding of manufactured home anchoring practices, so some of these statements, and/or information may seem rudimentary to some.

We will start by dealing directly with the fallacy of calculating an average load value to determine an anchor load capacity that will be good, anywhere in the United States.

Doing away with the need for determining soil characteristics is presumably, what this MHI/MHRA test program is intended to accomplish. In short, the MHI/MHRA is stating, while at the same time, disavowing responsibility for the "anchor spacing chart", and the publication used to design this chart, that if these values are used, then there is no need to determine the classification of the soil, at any home site, anywhere in the United States.

To determine the nominal load capacity for anchors, where ever they are used in the United States, the MHRA tested anchors, at six different locations, with similar soil conditions, in the Southern and South Eastern United States. They tested three (3) anchors of each combination of length, and stabilizer plate at five of the locations, and nine (9) anchors of each combination of length and stabilizer plate at one of the locations. This equates to twenty-four (24) anchors of each of the five (5) different lengths and stabilizer plates combinations for determining what will work at any location, in the United States. They then took the average from all six sites, for each anchor length, stabilizer plate combination to determine the recommended load value. Their premise is that if these MHI/MHRA recommended load values are used, then a home anchored in Live Oak, FL will be anchored in a manner that will ensure the safety of the user, and the public.

We will demonstrate the fallacy of this approach by taking each site individually and calculating the percentage of ground anchors that fall below the MHI/MHRA recommended values, and will do this respectively for each different combination of anchor and stabilizer plate combination, at each test site.

NOTE: The Values in RED italics in all subsequent tables indicate a value below the load value recommended by MHI/MHRA. This will be the same throughout all test site/load tables.

Beaumont, TX

The previous exercise for Beaumont, TX will be carried out for each test site.

Live Oak, FL

Note: For some undisclosed reason, a 4^th test subject was added to this one particular set of load values, at this one test site, for this anchor and stabilizer plate combination. Without the 4^th test subject, the average load value is 2183 pounds, and the percentage below the recommended value is 100%.

Baxley, GA