Comment Submitted by Adro
AnonymousOpposeOther
Summary: The commenter argues that the proposed rule fails to address the primary barrier to affordable housing, which is local zoning restrictions. They also express significant safety concerns regarding the structural integrity and wind resistance of multi-story manufactured homes if upper-floor chassis requirements are eliminated.
See comments below:
* LOCAL ZONING RESTRICTIONS *
While the rule successfully addresses manufacturing costs, it does not address the primary barrier limiting affordable manufactured housing supply in markets with greatest need: local zoning restrictions.
The proposal acknowledges that manufactured homes are currently concentrated in rural and lower-density suburban areas. However, the acute affordability crisis exists in urban and higher-density suburban markets.
*STRUCTURAL PERFORMANCE CONCERNS*
The proposed elimination of upper-floor chassis requirements raises unresolved questions regarding structural performance and wind resistance. Removing the permanent chassis from upper floors fundamentally alters lateral load dynamics by shifting wind and lateral force resistance to inter-story connections.
* LIFTING INSTRUCTIONS *
Manufacturers should be mandated to provide these instructions. Upper-floor modules of multistory manufactured homes lack an attached lower chassis during site placement, requiring crane or hoist installation. Without clear lift points and center-of-gravity specifications, modules risk structural warping or catastrophic failure during rigging.