MHI Submits Comments to HUD Regarding Regulatory Reform of HUD’s Manufactured Housing Program

Earlier this week, MHI submitted comments to the Department of Housing and Urban Development’s (HUD’s) recent request for information regarding Executive Order (E.O.) 13563. The E.O. requires federal agencies to seek more affordable, less intrusive ways to achieve policy goals and give careful consideration to the benefits and costs of those regulations. The E.O. requires agencies to “coordinate, simplify and harmonize regulations to reduce costs and promote certainty for business and the public.”

MHI made seven recommendations to HUD relating to regulatory reform of the Manufactured Housing program.

1. HUD’s rulemaking process under the Administrative Procedures Act (APA), must be streamlined to ensure that the consensus process for the development, revision and interpretation of the standards and its enforcement regulations can function as envisioned by Congress.

2. HUD should abandon efforts to finalize its proposed rule to revise test procedures for roof trusses in the MHCSS (24 CFR 3280.402).

3. HUD must take an active and aggressive role to work with the Department of Energy (DOE) to ensure HUD’s authority over the enforcement and compliance of new energy efficiency standards under consideration at the DOE.

4. HUD must consider the cumulative effect of the various proposed changes to the code that it has initiated since January 2010, including changes to the energy standards under consideration by DOE.

5. HUD should implement MHI’s recommendations for changes to its quality assurance regulations under §3282.203 of the HUD Procedural and Enforcement Regulations (24 CFR Part 3282).

6. HUD should completely revise its 1997 Policy Statement on zoning for manufactured housing to reflect changes to the “supremacy” provisions of the Manufactured Home Improvement Act (MHIA) of 2000.

7. HUD must consider manufactured housing when it proposes new rules or changes to existing program regulations that impact other HUD programs.

For additional information, members can contact Lois Starkey at 703-558-0654 or

MHI is the preeminent national trade association for the manufactured and modular housing industries, representing all segments of the industry before Congress and the Federal government. From its Washington, D.C. area headquarters, MHI actively works to promote fair laws and regulation for all MHI members and the industry. 

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