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HUD permanent foundations

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I'm caught in a pickle with a family trying to buy a
mobile home with FHA funding.  The 48' long
double-wide is set masonry block piers on a concrete
slab in northeast PA.  There is also an unreinforced
8" skirt wall around the perimeter to create crawl
space.

HUD's permanent foundation guide seems to require that
frost footings be in place under these structures.  Is
this absolutely the case in any frost zone?  There are
so many trailer parks around here and I would be
surprised if 1% of them had a real permanent
foundation.

The home does have required bracing and tie-downs per
the requirements.  My thought to get out of the frost
footing requirement was to insulate the skirt wall,
thereby keeping the piers on ground that was not
seccessptible to frost.

I appreciate any help I can get on this.  I hate to be
held responsible for tanking a real estate deal!

Jim Wilson
Stroudsburg, PA

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