FR-6537-P-01 Revising the Definition of ‘‘Manufactured Home’’ to Lower Housing Costs

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.

TeraSun Systems LLC supports the proposed rule to remove the permanent chassis requirement for multi-story manufactured homes to reduce costs. However, the company argues that HUD must also establish new transport system verification standards and certification requirements to ensure safety during highway transit.

Janet Thome, representing the Tiny House Alliance USA, opposes the proposed rule because it establishes a fixed minimum axle requirement without accounting for transportation weight, axle spacing, or the Federal Bridge Formula. She argues that the rule fails to harmonize with existing federal transportation laws and safety regulations, potentially compromising highway safety and infrastructure integrity.