Comment Submitted by Tiny House Alliance USA

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. This comment is focused on on this statement from the proposed rule making: "There must be a minimum of two axles equipped with brake assemblies on each transportable section of the manufactured home including any transportation system used for an upper floor of a multistory manufactured home." The proposed requirement addresses transportation systems, axles, and brake assemblies used to transport manufactured home sections on public highways. The proposed requirement establishes a fixed minimum axle requirement without reference to transportation weight, axle spacing, the federal bridge formula calculations, or permitting requirements. However, FHWA regulations and guidance demonstrate that axle configurations are determined through the relationship between weight, axle quantity, and axle spacing. As a result, transportation equipment carrying upper-floor sections may require different axle configurations depending upon the characteristics of the transported load. The proposed requirement addresses brake assemblies utilized on transportation equipment operating on public highways. Federal transportation regulations contain specific requirements governing emergency braking and breakaway braking systems for trailers. I have attached two documents to support my comment, including the Federal Bridge Formula. The statutory definition of a manufactured home: Manufactured home means a structure, transportable in one or more sections, which in the traveling mode, is eight body feet or more in width or forty body feet or more in length, or, when erected on site, is three hundred twenty or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained therein. Calculations used to determine the number of square feet in a structure will be based on the structure's exterior dimensions measured at the largest horizontal projections when erected on site. These dimensions will include all expandable rooms, cabinets, and other projections containing interior space, but do not include bay windows. This term includes all structures which meet the above requirements except the size requirements and with respect to which the manufacturer voluntarily files a certification pursuant to 24 CFR 3282.13 and complies with the standards set forth in 24 CFR part 3280. Chassis is defined as The load-supporting frame of a commercial motor vehicle, exclusive of any appurtenances which might be added to accommodate cargo. 49 CFR § 393.5 - Definitions. Aligning and harmonizing the HUD code with transportation and motor vehicle law will prevent more wrecks, protect the public, and save HUD valuable time in rule making. At fabrication, a manufactured home is a vehicular structure, it should comply with all federal laws regarding the chassis, altering a chassis, and for movement on public roads and highways. Thank you for your consideration, Janet Thome President Tiny House Alliance USA