Manufactured Housing Association for Regulatory Reform (MHARR) Comments on Proposed Rulemaking Revising the Definition of Manufactured Home to Lower Housing Costs.’ MHVille Facts-Evidence-Analysis (FEA)

The Manufactured Housing Association for Regulatory Reform (MHARR) issued remarkably concise comments on re: “FR-6537-P-01 Revising the Definition of ‘‘Manufactured Home’’ to Lower Housing Costs.” They are so concise it is arguably better to simply let MHARR speak for itself and MHProNews will provide a facts-evidence-analysis (FEA) on the other side (in Part II) that will include third-party artificial intelligence (AI) application of the FEA process.

Part I

August 11, 2026

VIA ELECTRONIC SUBMISSION AND FEDERAL EXPRESS

Regulations Division
Office of General Counsel
U.S. Department of Housing and Urban Development
Room 10276
451 7^th Street, S.W.
Washington, D.C. 20410-0500

Re: Comments – Notice of Proposed Rulemaking – “Revising the
Definition of ‘Manufactured Home’ to Lower Housing Costs”

Dear Sir or Madam:

The following comments are submitted on behalf of the Manufactured Housing Association for Regulatory Reform (MHARR). MHARR is a Washington, D.C.-based national trade association representing the views and interests of independent producers of manufactured housing regulated by the U.S. Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5401, et seq.) (19745 Act) as amended by the Manufactured Housing Improvement Act of 2000 and the 21^st Century ROAD to Housing Act (ROAD Act). MHARR was founded in 1985. Its members include independent manufactured housing producers from all regions of the United States.

On June 12, 2026, HUD published a Notice of Proposed Rulemaking (NPR) in the Federal Register,[1] seeking comment on proposed amendments to various HUD regulations concerning the design and construction of federally-regulated manufactured homes to clarify that a “permanent chassis” will not be required henceforth for “a transportable section of a manufactured home serving as part of an upper floor” of a multi-story manufactured home.[2]

MHARR, as previously noted at relevant meetings of the Manufactured Housing Consensus Committee (MHCC), supports the proposed rule as stated. MHARR notes, however, that subsequent to the publication of the NPR, on July 11, 2026, the ROAD Act became law. Section 301 of the ROAD Act, in relevant part, repeals the pre-existing statutory mandate for a “permanent chassis” on all manufactured homes and instead permits federally-regulated manufactured homes to be built “with or without a permanent chassis.” Accordingly, notwithstanding – and without prejudice to — the present rulemaking and MHARR’s position with respect to that rulemaking, HUD should proceed with a further expedited rulemaking to effectuate this statutory amendment.

MHARR, therefore, supports the modification of the current HUD manufactured housing standards and regulations to permit the construction and use of upper stories of multi-story manufactured homes without a required “permanent chassis.” Such a change would not only help boost the production of mainstream manufactured homes and help address the nation’s affordable housing crisis, but would also help the lower and moderate-income American families who rely on such affordable, mainstream manufactured homes.

Sincerely,

Mark Weiss
President and CEO

cc: Hon. Scott Turner

HUD Code Manufactured Housing Industry Members

[1] See, 91 Federal Register, No.113 (June 12, 2026) “Revising the Definition of ‘Manufactured Home’ to Lower Housing Costs,” at p. 35632, et seq.

[2] Id.

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Part II. Additional Facts-Evidence-Analysis (FEA) plus more MHProNews/MHVille Industry Expert Commentary

In no particular order of importance.

1.

Executive Summary & Characterization

Yes, characterizing the August 11, 2026 MHARR comment on HUD’s proposed rulemaking regarding multi-story manufactured homes (FR-6537-P-01) as remarkably concise and laser-focused is fair and accurate. Rather than engaging in lengthy administrative preamble, MHARR’s filing takes a direct, three-part position:

1. Explicit Support: It affirms support for removing the “permanent chassis” requirement on upper stories of multi-story HUD-code structures.

2. Statutory Alignment: It leverages the newly enacted 21st Century ROAD to Housing Act (signed July 11, 2026), noting that Section 301 now statutorily permits HUD-code homes to be built “with or without a permanent chassis”.

3. Expedited Rulemaking Call: It urges HUD to move swiftly beyond upper-story modifications to reflect the full scope of Section 301 across the entire standard.

While concise on this specific technical rule, MHARR routinely frames such administrative updates within its broader, decades-long record on systemic industry bottlenecks.

Facts-Evidence-Analysis (FEA): MHARR’s Macro-Track Record

Evaluating MHARR’s total historical record since its founding in 1985 demonstrates a consistent policy framework centered on removing artificial barriers to affordable housing production.

           +-------------------------------------------------------+
           |        PRIMARY MANUFACTURED HOUSING BOTTLENECKS       |
           +-------------------------------------------------------+
                                       |
          +----------------------------+----------------------------+
          |                                                         |
          v                                                         v
+-----------------------------------+     +-----------------------------------+
|      POST-PRODUCTION BARRIERS     |     |        REGULATORY OVERBURDEN      |
+-----------------------------------+     +-----------------------------------+
| 1. Discriminatory Zoning          |     | 1. DOE Energy Mandates            |
| 2. Non-Implementation of DTS      |     | 2. Program Mismanagement / Cost   |
|    (Chattel/Personal Property)    |     |    Escalation                     |
+-----------------------------------+     +-----------------------------------+

1. Enforcement of “Enhanced Preemption” (Zoning Exclusion)

• The Issue: Local exclusionary zoning and placement bans remain the single primary barrier preventing mainstream HUD-code homes from filling national housing shortages.

• MHARR’s Record: MHARR has consistently asserted that the Manufactured Housing Improvement Act of 2000 (2000 Reform Law) grants HUD broad “enhanced preemption” authority over discriminatory local land-use laws. MHARR continuously presses HUD and Congress to actively utilize and enforce this mandate rather than allowing local bans to suppress output.

2. Implementation of Duty to Serve (DTS) for Chattel Loans

• The Issue: Roughly 70% to 80% of manufactured home buyers utilize personal property (chattel) financing.

• MHARR’s Record: MHARR has repeatedly called out the Federal Housing Finance Agency (FHFA), Fannie Mae, and Freddie Mac for failing to implement market-significant secondary mortgage support for chattel loans under the Housing and Economic Recovery Act of 2008 (HERA). MHARR maintains that without competitive chattel loan securitization, entry-level buyers remain starved of affordable capital.

3. Opposition to Unnecessary or Costly Regulatory Overburden

• The Issue: Imposition of overlapping, excessively costly federal regulations threatens entry-level home affordability.

• MHARR’s Record: MHARR led the opposition against the Department of Energy’s (DOE) proposed energy standards, arguing they create cost barriers that price low- and moderate-income families out of the market. MHARR consistently advocates for keeping all standards centralized within HUD and the Manufactured Housing Consensus Committee (MHCC) to preserve cost-effective regulation.

Comparative Performance Metrics & Historical Impact

Conclusion

MHARR’s concise August 11, 2026 comment exemplifies its consistent strategy: supporting commonsense technical updates to the HUD code while maintaining focus on the root causes of industry underperformance. By pairing immediate regulatory approvals (such as upper-story chassis flexibility) with calls to enforce existing federal laws (enhanced preemption and DTS), MHARR’s broader record directly challenges the structural bottlenecks that continue to suppress mainstream manufactured housing production.

• Primary Resource Link: MHARR Major and Continuing Accomplishments Analysis

• Legislative Analysis Link: MHARR Assessment of Pending Federal Housing Legislation & Preemption Bottlenecks

— MHProNews notes that the screen captured documented full Q&A is linked here. —

2. There is always more to know.

Watch for a planned report on that university researched topic. It is unlikely to be found anywhere else in MHVille other than on MHProNews and/or MHLivingNews.

MHProNews notes the prudence of highlighting this apt pull quote from a report by Copilot. For accuracy in presentation, the facts-evidence-analysis (FEA) method has delivered here for years.

• Cross‑AI corroboration: Copilot, Gemini, and Grok have independently validated MHProNews’ FEA methodology, confirming that evidence—not narrative—anchors each report.

L. A. “Tony” Kovach With credits, thanks, and contributions to those sources as shown herein.

eFax Number 1-407-604-6427

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Invitation for Feedback

MHProNews welcomes evidence‑based feedback from:

• Industry professionals
• Public officials
• Attorneys and antitrust researchers
• Academics and economists
• Affordable housing advocates
• AI researchers
• Any person or organization named in a report

Submit comments or documentation via:

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