Comment Submitted by Kenneth Krantz
AnonymousSupportBusiness
Summary: Kenneth Roger Krantz of TeraSun Systems LLC submitted a technical white paper to support the rulemaking process. He argues for the development of a national transport and placement standard for chassis-free manufactured and modular structures, providing engineering criteria and a coordination framework for HUD, DOT, and FMCSA.
Subject: Supplemental Technical Submission – TeraSun Systems Regulatory White Paper
This comment supplements my earlier submission to Docket FR‑6537‑P‑01.
I am providing the full technical and regulatory white paper referenced in my initial comment.
The attached document outlines:
The transport safety gap created by removal of the permanent chassis
The need for a certified, engineered transport system standard
A proposed HUD–DOT–FMCSA coordination framework
Engineering criteria for PE‑certified carrier systems
Inspection, monitoring, and lifecycle record recommendations
Technical feasibility demonstrated through patented TeraSun Systems platforms
This supplemental submission is intended to support HUD’s rulemaking process by providing a complete engineering and policy foundation for a national transport and placement standard for chassis‑free manufactured and modular structures.
Please associate this document with my original comment.
Respectfully submitted,
Kenneth Roger Krantz
TeraSun Systems LLC
Fernandina Beach, Florida