Sent: 1/16/01 2:26 PM
Subject: Commentary on Consumer Representative Report
Revision to my comments - Re: Consumer Anchor Response
In the fourth line of the fifth paragraph, please revise my message to read as
follows:
"...legislation, we may be able to address these issues in the future."
Subject: Commentary on Consumer Representative Report
Attached, please find HUD Commentary on the consumer sector report distributed to the Task Group and Installation Committee Members. This has been copied to you for your information and records of the group.
Mr. Taylor: Please let me inform you that I was not able to participate in the recent COSAA Committee Anchor conference call. Accordingly, I do not know what comments Frank Walter of MHI made regarding your comments on a proposed MHRA test protocol for soil anchors that were attributed to certain statements in your response pertaining to anchor studies, one of which was sponsored by HUD.
While I do not know what Mr. Walter said, I am concerned that you were drawing conclusions, in your comments, with respect to the Department's position, based on an initial July report (WJE NO. 901798) sponsored by HUD and not the final reports that were subsequently issued on the project in September 1993 (WJE NO. 931299) and January 1995 (WJE NO.931299) [These reports are available from the HUD USER Service (800) 245-2691 for a nominal fee].
In particular, certain statements in your report suggesting the Department was ignoring the anchor embedment issue or permitting large horizontal deflections that would affect pier stability are simply not correct. The final reports, referenced above, indicate the importance of correct anchor installation and indicates that anchor resistance is limited by the depth of embedment and suggest methods to improve on current anchor installation practices; recommend limiting horizontal deformations to 3"; and, recommend use of stabilizer plates and significantly reduced working strength values of anchors in weak soils, among several other recommendations (the larger deflections were only permitted in the initial report to determine ultimate resistance characteristics of the anchors in the loose sandy soil at the test site, because of the surprising low values found @ 4" horizontal deformation). It also addressed the importance of anchor preloading, time dependent affects on anchor resistance, and lower capacities from load reversal tests than found in monotonic testing, etc. While the Department did not author any of these reports or taken any official position on them, they were certainly developed in consultation with HUD and we are certainly aware of the recommendations there-in.
With respect to your final note, we can certainly agree that more anchor system testing is needed in the future to better define the performance requirements for them and investigate issues such as the cone of influence affects on anchor spacing. While 93 WJE report did provide some insights into anchoring system behavior, it did not assess the behavior of groups of anchors. It is my understanding that such testing is being considered by MHRA.
In addition, until very recently the Department did not have any site installation authority. As a result, the Department previously has been unable to address many of the concerns listed in your comments including those regarding affordability and weaknesses of the current tie down systems. However, as a result of the new manufactured home legislation, we will be able to address these issues in the future.
Finally, I do agree that comments should be made on-the-record, so please consider the above, my on- the-record comments on your remarks.
Rick Mendlen
By copy of this message I am asking Jason McJury of HBT to include this message in the upcoming minutes and make it available to all COSAA Anchor Committee members.