Comment Submitted by Tiny House Alliance USA

Revising the Definition of "Manufactured Home" to Lower Housing Costs There are many moving parts to this proposal: removing the chassis requirement from the upper floor of multi-story manufactured homes, and ultimately making chassis removal optional on the ground floor as well. This change sounds great on the surface, but several important factors aren't being discussed — including the added cost of lumber when construction shifts to 2x8 and 2x10 framing with additional bracing to meet structural requirements without a chassis. Permit Pushers published an article on July 14, 2026 that raises some strong points about the 21st Century ROAD to Housing Act and its proposal to remove the permanent chassis requirement for manufactured homes. Here's a key excerpt: "The catch: it is not immediate. The definition changed in the law, but the change did not become operational nationwide as soon as the law took effect. HUD still has to implement it through rulemaking. On top of that, each state has to certify that its laws treat manufactured homes without a permanent chassis consistently with those built on a permanent chassis, making updates where necessary. If a state does not certify by the required deadline, chassis-free manufactured homes could actually be blocked from being built, installed, or sold there. So the timeline and the on-the-ground reality will vary from state to state, which makes it worth watching how your state responds rather than assuming the change applies everywhere at once." The article also outlines what this means in practice for the people affected: "What this means for builders, developers, and homeowners: The takeaway is that both changes are intended to remove barriers that can increase housing costs, but neither provision creates a new nationwide code path that every project can use today. The chassis reform requires HUD implementation and state certification, while the single-stair provision requires HUD guidelines and voluntary adoption by individual jurisdictions. For the near term, that means a couple of practical things. Plan your current projects around the code that is actually in force in your jurisdiction today, not a code change that may be adopted in the future. At the same time, keep an eye on how your state and locality respond, because that is where these changes become buildable. The chassis reform in particular will move at different speeds in different states, depending on how quickly each one submits the required certification, and the single-stair guidelines will only matter for your projects if your local jurisdiction chooses to adopt them. For homeowners and buyers, the practical effect is further out but worth watching. As chassis-free manufactured homes enter the market, they may look and sit more like site-built houses and could narrow some of the differences in valuation and financing over time. That could create more housing options at lower prices, but the results will depend on implementation, state laws, financing, land costs, and local requirements." — James Gardner, Permit Pushers Janet Thome President, Tiny House Alliance USA