FR-6616-N-01 Request for Information Regarding Products and Categories of Products Used in Housing Programs Pursuant to the Build America, Buy America Act

DuPont Performance Building Solutions supports the objectives of the Build America, Buy America Act (BABA) but urges HUD to provide clear, practical guidance that avoids administrative burdens. They emphasize that HUD should prioritize domestic finished product manufacturing while ensuring access to high-performance, energy-efficient materials to support long-term housing affordability and durability.

Next Step Network, a nonprofit housing intermediary, opposes applying the Build America, Buy America Act (BABA) to HUD housing programs. They argue that the act creates an insurmountable documentation burden, lacks consistent enforcement, and provides negligible benefits to domestic manufacturing while significantly increasing costs and delays for affordable housing projects.

Tim Casey, Director of City Development for the City of Kenosha, argues that strict Build America, Buy America (BABA) requirements would make affordable housing projects financially unattainable. He cites specific price premiums for domestic lumber and building materials that would significantly increase construction costs.

The American Iron and Steel Institute (AISI) supports HUD's request for information regarding the implementation of the Build America, Buy America Act (BABA) in housing programs. They urge HUD to recognize the critical role of steel in construction, maintain predictable procurement expectations, and ensure a transparent, project-specific waiver process that rewards domestic investment.

A developer involved in multifamily affordable housing in North Carolina opposes the application of the Build America, Buy America Act (BABA) to LIHTC projects. They argue that BABA compliance significantly increases costs and reduces the number of affordable units produced, and they suggest either a full exemption or limiting compliance to the portion of the project funded by HUD.

The Squaxin Island Tribe supports the Build America, Buy America (BABA) Act but requests specific policy adjustments to accommodate tribal housing programs. They advocate for automatically extending grant performance periods for delayed projects, creating a centralized BABA product directory, and increasing federal funding to offset the higher costs of BABA-compliant materials.

The American Chemistry Council (ACC) Plastics Division supports HUD's effort to understand products used in housing programs to implement Build America, Buy America (BABA) requirements. They advocate for a practical implementation framework that protects domestic manufacturing of plastic building materials while ensuring affordable housing and lower utility costs for residents.

Mitsubishi Electric US, Inc. supports HUD's efforts to improve the efficiency of the Build America, Buy America Act (BABA) implementation. The company argues that HUD should establish a general product-specific nonavailability waiver for commercial Variable Refrigerant Flow (VRF) systems because domestic production is currently insufficient and project-specific waivers create unnecessary administrative burdens.

The commenter opposes the proposed restrictions on products used in housing programs, arguing that the requirements will increase costs and hinder the development of low and affordable housing. They suggest that the "best buy" products for budget-conscious projects are often not American-made.

The Executive Director of a small public housing agency opposes the requirements of the Build America, Buy America Act, arguing that it creates an administrative burden and increases costs for small-scale maintenance and urgent repairs. The commenter notes that limited purchasing options and the time required for research strain their already tight budget.