Copyright Comment Submitted by Kenneth Krantz

NOTE: Full formatted comment attached as PDF supporting document. Docket No. FR-6537-P-01 | RIN 2502-AJ80 Kenneth R. Krantz, Founder & CEO | TeraSun Systems LLC / TeraSun IP Holdings LLC Fernandina Beach, Florida | kenkrantz@terasunsystems.com --- OPENING --- TeraSun Systems LLC supports HUD's proposed rule removing the permanent chassis requirement for upper-floor sections of multi-story manufactured homes. The commenter is a certificated building contractor with 43 years of experience, an ASTM International contributor, and inventor of a pending portfolio of five utility patents and two provisional applications covering real-time compliance verification, digital lifecycle tracking, and chassis-free transport systems for factory-built housing assigned to TeraSun IP Holdings LLC. We support this rule's cost-reduction objectives and urge HUD to fill the critical gap it creates: no standard governs the transport systems that will carry chassis-free sections over the nation's highways. --- THE REGULATORY GAP --- The permanent chassis served two functions: factory-floor structural substrate AND a regulated highway transport system. The rule correctly eliminates the post-placement chassis requirement. It does not establish what replaces the chassis as the transport safety anchor during road transit -- the moment of greatest public risk. Amended sections 3280.901, 3280.902, and 3280.904 exempt upper-floor sections from existing chassis and braking axle transport requirements with no replacement certification, roadworthiness inspection, or monitoring requirement proposed. This is a structural liability gap. --- THE LIABILITY PROBLEM --- Liability in manufactured home transport falls across multiple parties: motor carrier, equipment owner, driver, manufacturer, and transport system designer. No universal federal certification exists for the carrier systems themselves. State oversize-load permits address road dimensions -- not carrier structural integrity. The rule expands chassis-free transport configurations with no corresponding increase in verification requirements. Without a roadworthiness certification standard, insurers cannot price coverage confidently. Higher premiums and coverage gaps will offset the cost savings HUD projects. --- RESPONSE TO HUD QUESTION #4: TRANSPORTATION REQUIREMENTS --- No -- the amended requirements are not sufficient. HUD should establish a Transport System Verification Standard requiring: (1) PE certification of any chassis-free carrier before commercial use; (2) a documented pre-departure inspection for every transport event; and (3) real-time monitoring covering GPS compliance, load distribution, brake status, and arrival confirmation. The TeraSun portfolio (TeraVault App. 19/699,266; TeraVerify App. 19/630,015; ModuHAUL provisionals 64/085,428 and 64/085,207) demonstrates this architecture is engineered, not theoretical. A technology-neutral performance standard achieves the same result without mandating any proprietary system. --- RESPONSES TO HUD QUESTIONS #1, #2, AND #3 --- Further chassis reduction: we do not oppose expanding chassis-free configurations to single-story homes, but only alongside the transport verification framework above. Installation and lifting: engineered lift point identification must be mandatory for all chassis-free upper sections, codified in 24 CFR Part 3285, and embedded in the unit's digital lifecycle record -- accessible at the installation site, not only on paper. --- SIX RECOMMENDATIONS --- 1. Establish a Transport System Certification Standard requiring PE certification before commercial use. 2. Require a pre-departure inspection record for every chassis-free transport event. 3. Establish a technology-neutral performance standard for real-time transport monitoring. 4. Require transport records in the unit's permanent file alongside the HUD Data Plate. 5. Initiate formal coordination with FMCSA and DOT on carrier certification. 6. Require engineered lifting instructions embedded in the unit's digital lifecycle record. --- CLOSING --- This rule's direction is right. What these comments urge is that HUD establish what replaces the chassis as the transport safety anchor before chassis-free sections move down the highway at scale. The technology exists. The regulatory authority exists. The timing is right. Full supporting analysis, tables, and patent portfolio reference are in the attached PDF. Respectfully submitted, Kenneth R. Krantz | TeraSun Systems LLC | Fernandina Beach, Florida (c) 2026 TeraSun Systems LLC. Docket No. FR-6537-P-01.