Comment Submitted by Tiny House Alliance USA
AnonymousOpposeAdvocacy
Summary: Janet Thome, President of Tiny House Alliance USA, opposes the proposed rule because it fails to adequately address transportation safety risks associated with reducing permanent chassis requirements. She argues that HUD must coordinate with federal transportation agencies (like NHTSA and FMCSA) to ensure safety standards, accountability, and liability are maintained for factory-built structures on public highways.
My name is Janet Thome, Founder and President of Tiny House Alliance USA. I appreciate the opportunity to submit comments regarding HUD's proposed rule to modify the permanent chassis requirements for upper-floor transportable sections of multistory manufactured homes.
While the proposed rule focuses primarily on affordability, design flexibility, and construction cost savings, I am concerned that it does not adequately address transportation safety implications. Transportation is an essential part of the manufactured housing lifecycle. Before reducing permanent chassis requirements, HUD should fully evaluate the potential impacts on highway safety, transportation integrity, inspection, certification, enforcement, and public risk.
One of my primary concerns is that the proposed rule may create unintended transportation consequences if transportation requirements are not coordinated with existing federal transportation regulations. The most effective way to address this concern is to ensure that HUD's transportation-related provisions are harmonized with applicable federal transportation requirements.
Accordingly, I respectfully recommend that HUD coordinate and harmonize transportation-related provisions with applicable requirements contained in Title 49 of the Code of Federal Regulations and consult with transportation stakeholders, including NHTSA, FMCSA, the Commercial Vehicle Safety Alliance (CVSA), state motor carrier enforcement agencies, and other transportation professionals before implementing the proposed changes.
Please see the attached comments and supporting documentation for additional information regarding transportation safety, cargo securement, braking systems, carrier systems, accountability, transportation incidents, and related transportation concerns.
Temporary Transportation Task Group
HUD should establish a Temporary Transportation Task Group before implementing the proposed changes.
The Task Group should include representatives from NHTSA, FMCSA, the Commercial Vehicle Safety Alliance (CVSA), state motor carrier enforcement agencies, transportation safety professionals, manufacturers, inspection agencies, transporters, insurers, and other stakeholders with expertise in highway transportation.
The Task Group should evaluate transportation-related issues including braking systems, running gear, axles, recycled axles, wheels, couplings, lighting, cargo securement, vehicle identification, certification, inspection, enforcement, crash data, carrier system accountability, liability, and harmonization with applicable transportation requirements contained in CFR Title 49 Transportation.
The Task Group should also evaluate documented transportation incidents involving manufactured homes, modular homes, mobile structure trailers, office modules, data center modules, and other factory-built structures transported on public highways.
HUD should complete this transportation review before reducing permanent chassis requirements for upper-floor transportable sections of multistory manufactured homes.
I have long appreciated HUD's regulation of manufactured home transportation systems, including requirements related to permanent chassis construction, road testing, identification, certification, and traceability.
If this rulemaking is adopted and upper-floor sections are no longer required to be constructed on a permanent chassis, I respectfully request that HUD align its requirements with applicable federal motor vehicle and transportation laws. This should include any manufactured home or modular home that utilizes a temporary carrier system for transportation on public highways.
Any temporary carrier system utilized for the transportation of a factory-built structure should be a legally recognized motor vehicle trailer and should comply with all applicable federal transportation requirements, including identification, certification, inspection, operational, and safety requirements administered by the appropriate federal transportation agencies.
Thank you for your consideration.
Janet Thome
President
Tiny House Alliance USA
Attachments
- New Hampshire_ Fatal Wheel Assembly Separation Involving Modular Home Transport (PDF)
- Misplaced Liability on Truck Drivers (PDF)
- Need for a Transition Period and Transportation Review (PDF)
- Temporary Transportation Task Group (PDF)
- Recycled Axles and Transportation Components (PDF)
- Cargo Securement (PDF)
- Transportation by USDOT-Regulated Motor Carriers Using Recognized Transportation Motor Vehicle Trailers (PDF)
- NHTSA Interpretation Letter_ Modular Transport (PDF)
- Harmonization With CFR Title 49 Transportation Requirements (PDF)
- Safeguards When Manufacturers Also Transport Their Own Product (PDF)
- Same Transportation Laws For Modular And Manufactuered Homes (PDF)
- Coordination With Federal Transportation Agencies (PDF)
- Unintended Consequences of 24 CFR 3282 (PDF)
- Analysis of Modular and Manufactured Home Transport Incidents and Mechanical Failures (PDF)