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Question about minimum crawlspace height requirement

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lshoop

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Oct 19, 2019
Professional Status
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State
Mississippi
I'm just wondering if the part of the crawl that contains system components is well over 18 inches, but a portion of the crawl that does not contain any system components is not, does that mean the house doesn't meet mpr and mps requirements? That portion is easily viewed and has proper ventilation.
So right now the appraiser marked that the house does not meet FHA guidelines because the foundation is not at least 18 inches off the ground. This is the case on the front of the foundation but not at the back of the foundation where all of the mechanical systems are at least 3 feet off the ground and are accessible. I had the appraiser go back and revise but he only revised and commented on the mechanics being accessible. He still marked it as not being our meeting FHA guidelines.
 
m. Crawl Space Observation Requirements​
The Appraiser must visually observe all areas of the crawl space and notify the Mortgagee of​
the deficiency of MPR and MPS when the crawl space does not satisfy any of the following​
criteria:​
• The floor joists must be sufficiently above ground level to provide access for​
maintaining and repairing ductwork and plumbing.​
• If the crawl space contains any system components, the minimum required vertical​
clearance is 18 inches between grade and the bottom of the floor joists.​
• The crawl space must be properly vented unless the area is mechanically conditioned.​
• The crawl space must be free of trash, debris, and vermin.​
• The crawl space must not be excessively damp and must not have any water pooling.​
If moisture problems are evident, a vapor barrier and/or prevention of water​
infiltration must be required.​

I read that to mean you may be correct. Complain to FHA underwriting via your lender.
 
m. Crawl Space Observation Requirements​
The Appraiser must visually observe all areas of the crawl space and notify the Mortgagee of​
the deficiency of MPR and MPS when the crawl space does not satisfy any of the following​
criteria:​
• The floor joists must be sufficiently above ground level to provide access for​
maintaining and repairing ductwork and plumbing.​
• If the crawl space contains any system components, the minimum required vertical​
clearance is 18 inches between grade and the bottom of the floor joists.​
• The crawl space must be properly vented unless the area is mechanically conditioned.​
• The crawl space must be free of trash, debris, and vermin.​
• The crawl space must not be excessively damp and must not have any water pooling.​
If moisture problems are evident, a vapor barrier and/or prevention of water​
infiltration must be required.​

I read that to mean you may be correct. Complain to FHA underwriting via your lender.
Thank you for your input. We are trying to work with the appraiser first, but I don't wish to ask him to do anything he may consider unethical.
 
FHA could have written that better. I've heard instructors claim that the crawl space must be 18" but I think that only applies to where plumbing and duct work exists. 9 of 10 hillside homes would not comply with the minimum anywhere standard.
 
In the "old days" (perhaps 10 or more years ago) it HAD to be 18". That has since been revised. See the prior post. Your appraiser needs to review HUD Handbook 4000.1.

FWIW... MRP (minimum property requirements) is for existing housing (like your property. MPS (minimum property standards) refers to the regulatory requirements for new (or proposed) construction.
 
I'm just wondering if the part of the crawl that contains system components is well over 18 inches, but a portion of the crawl that does not contain any system components is not, does that mean the house doesn't meet mpr and mps requirements? That portion is easily viewed and has proper ventilation.
So right now the appraiser marked that the house does not meet FHA guidelines because the foundation is not at least 18 inches off the ground. This is the case on the front of the foundation but not at the back of the foundation where all of the mechanical systems are at least 3 feet off the ground and are accessible. I had the appraiser go back and revise but he only revised and commented on the mechanics being accessible. He still marked it as not being our meeting FHA guidelines.
Sorry to hear your situation , unfortunately this is where common sense "V" guidelines comes into play. Based on your description there is no problem. But 18" is in the handbook and some of th enewer FHA appraisers will baclk if its 17.5 inches. Personally I am an-old school FHA appraiser and we had been trained to use common sense and that guidelines are not a law they are a way to keep us in the middle of the lane but today if the book says 18" then it better not be 17.5". The funny part is nobody is skinny enough to even crawl through an- 18" space unless they are a midget or extremely small person. FHA needs to revise there 40 year old 18" and expand it to 40 inches . Anyway when a contractor does need access he/she takes a reciprocal saw and simply cuts a larger opening and makes a new screen door cover so mice, rats, animals do not live under the house, also metal screens allow for vantilation and so Mr 18" could make an-issue out of a sold cover.

SO WHAT DO YOU DO ? I am going to assume this guy/gal is not budging.
Hopefully he made it a repair condition meaning the property will meet FHA Minimum Property Standards once the crawl space is enlarged to over 18"- I personally would try and go at least 2" larger on all sides just to have a little more room just in case he can't read his tape measure. A local contractor or good handyman for a few hundred bucks will normally open the area up and make a new cover plate or screen for $200.00 bucks or so. Once thi sis done the lender can send the appraiser back out and he can measure it and take a photo and do whats called a 1004D which is a reinspection form . The Property Will Now meet FHA ( MPR ) and your done. If that is your only issue and he won't comply then your lenders Underwriter can contact her/his housing centers appraisal department and explain whats going on.
 
Note too that the appraiser is to call the mortgagee when this happens. They are not to complete the report until the mortgagee decides.
 
Sorry to hear your situation , unfortunately this is where common sense "V" guidelines comes into play. Based on your description there is no problem. But 18" is in the handbook and some of th enewer FHA appraisers will baclk if its 17.5 inches. Personally I am an-old school FHA appraiser and we had been trained to use common sense and that guidelines are not a law they are a way to keep us in the middle of the lane but today if the book says 18" then it better not be 17.5". The funny part is nobody is skinny enough to even crawl through an- 18" space unless they are a midget or extremely small person. FHA needs to revise there 40 year old 18" and expand it to 40 inches . Anyway when a contractor does need access he/she takes a reciprocal saw and simply cuts a larger opening and makes a new screen door cover so mice, rats, animals do not live under the house, also metal screens allow for vantilation and so Mr 18" could make an-issue out of a sold cover.

SO WHAT DO YOU DO ? I am going to assume this guy/gal is not budging. Hopefully he made it a repair condition meaning the property will meet FHA Minimum Property Standards once the crawl space is enlarged to over 18"- I personally would try and go at least 2" larger on all sides just to have a little more room just in case he can't read his tape measure. A local contractor or good handyman for a few hundred bucks will normally open the area up and make a new cover plate or screen for $200.00 bucks or so. Once thi sis done the lender can send the appraiser back out and he can measure it and take a photo and do whats called a 1004D which is a reinspection form . The Property Will Now meet FHA ( MPR ) and your done. If that is your only issue and he won't comply then your lenders Underwriter can contact her/his housing centers appraisal department and explain whats going on.


This is what the appraisal says-
This subject DOES NOT meet FHA MPR (Minimum Property Requirements) per HUD Handbook 4000.1 nor meet FHA MPS (Minimum Property Standards) per and including 24 CFR 200.926.D. Subject foundation in the front is LESS THAN the minimum 18" required from the ground to the bottom of the floor joists (see attached crawl space photos). This is considered incurable due to cost to raise foundation to required height. Although the front of the subject house technically does not meet MPR and MPS for minimum clearance from bottom of floor joist-to-ground of 18", the mechanical and plumbing equipment and lines, etc are located at the rear (at 3 ft approx), there is not a reasonable concern for access to these items. Therefore, the appraiser agrees that reasonable access can be obtained from the rear of the house for maintenance and repair to these items. Additionally, there is no cause for ventilation concerns as the subject does not have any foundation walls to prevent adequate and sufficient air flow under the subject. (See photos below)
 
The appraiser is a nut. He contradicted himself. The OP should call the HUD ROC and speak with someone there. The appraiser needs to read up on the 4000.1 handbook.
 
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