FR-6537-P-01 Revising the Definition of ‘‘Manufactured Home’’ to Lower Housing Costs

The commenter, identifying as a veteran and expert in the manufactured housing industry, supports the proposed action to revise the definition of "manufactured home" to align with the 21st Century ROAD to Housing Act. They argue that HUD has failed to adequately facilitate affordable housing and criticize the awarding of research grants to the Manufactured Housing Institute (MHI) when the solutions—removing zoning barriers and enforcing existing laws—are already well-documented.

A managing member of LifeStyle Factory Homes, LLC, supports the proposed rule change to lower housing costs by removing the permanent chassis requirement for multi-story manufactured homes. The commenter argues that the current regulatory framework is obsolete and calls for HUD to use its authority to preempt discriminatory zoning and improve consumer financing.

Janet Thome, President of Tiny House Alliance USA, provides a nuanced perspective on the proposal, noting that while the goal of lowering housing costs is positive, there are significant practical hurdles. She highlights concerns regarding increased lumber costs for structural requirements and the complex, multi-state implementation timeline required for the changes to become operational.

Janet Thome, President of Tiny House Alliance USA, opposes the proposed revisions to the definition of "Manufactured Home." She argues that moving toward ICC-dominated standards rather than preserving the unique role of the HUD Code will lead to higher costs, reduced competition, and a "de facto takeover" by standards development entities.

The commenter supports the proposed rule to revise the definition of "Manufactured Home" because it could lower housing costs and provide manufacturers with more design flexibility. They argue that the change allows for innovation in multi-story homes while maintaining necessary safety and construction standards.

The commenter, identifying as a member of the mortgage community, supports the proposed revision to the definition of "Manufactured Home." They argue that updating the definition will reflect modern home production and help provide more affordable housing options for families.

Marion Anglin, a Realtor in Southwest Florida, supports the action to make manufactured homes more affordable. However, she also expresses concern regarding the high cost of insurance for older manufactured homes and requests assistance in addressing the insurance monopoly for these properties.

Janet Thome, President of Tiny House Alliance USA, is commenting on a specific Alternative Construction (AC) letter issued by HUD to Clayton Homes. She expresses concern and questions why HUD granted Clayton Homes permission to remove upper floor chassis before the formal rulemaking process was completed.

A private individual expresses frustration over the current housing crisis and the high cost of rent. They advocate for the construction of more affordable housing in Camden and Gloucester Counties to help people who cannot afford current market rates.