MHI Comments on HUD’s Proposed Rules for On-Site Completion of Construction of Manufactured Homes

On August 23, 2010, MHI submitted comments to HUD’s proposed rule to establish a procedure allowing manufacturers to deviate from the existing alternative construction (AC) requirement to conduct on-site completion of aspects of construction that cannot reasonably be completed in the factory.

In its comments, MHI said, “while we are pleased that HUD has issued a proposed rule to amend the current AC process, we strongly believe that a number of changes are necessary to ensure a more streamlined process for on-site construction.” MHI said that significant changes are needed in order to achieve HUD’s stated goal to “simplify the process and obviate the need for HUD approval” and to “expand regulatory flexibility and facilitate the timely completion of manufactured homes on-site.”

MHI proposed that HUD adopt the following procedures for on-site completion of construction for manufactured homes:

  • Incorporate the existing procedural and enforcement regulations for on-site inspections and consider the on-site work as an extension of the factory inspection process.
  • Maintain current procedures for certain types of hinged roofs, which don’t require on-site inspection of each installation.
  • Prohibit State Administrative Agencies that are not approved State-IPIAs from inspecting on-site work.
  • Adopt a more streamlined, less redundant labeling and reporting system to ensure that the buyer has complete knowledge of the status of the home’s construction and completion and rely on existing requirements for a “certificate of occupancy” to be provided to the buyer at closing.

Click here to view MHI’s comments to HUD.

If you are a member and have questions, contact MHI Vice President of Regulatory Affairs Lois Starkey at

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