Attached for your review, consideration and input is a proposed revision to section 3282.8(g) of the Procedural and Enforcement Regulations (PER) that HUD has submitted to the Manufactured Housing Consensus Committee (MHCC). This language is reproduced exactly as provided by HUD.

Section 3282.8(g) of the regulations, entitled “Applicability,” defines who and what the PER regulations apply to, and who and what the PER regulations and the Federal Manufactured Housing Construction and Safety Standards (FMHCSS) and installation standards apply to.

At present, section 3282.8(g) exempts “recreational vehicles” (RVs) from the Part 3280 standards and PER regulations, and defines what constitutes an RV for purposes of the exemption. The change proposed by HUD would, among other things, more broadly exempt RVs from coverage under the manufactured housing “Act,” and would remove the current size limitation of section 3282(g)(2), which defines an excluded RV as being “400 square feet or less….”

The proposal would also, for the first time, define “recreational park trailers” and exempt such trailers from the PER regulations, the FMHCSS standards and the installation standards.

The MHCC has scheduled a conference call meeting on April 16, 2010 to address this proposal. Accordingly, please provide us with any input, observations, or concerns that you may have regarding this proposal and the issues it addresses, by January 29, 2010, so that MHARR can develop its official position in advance of the planned meeting.

If you have any questions concerning this, or require any additional information, please contact us.

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Danny D. Ghorbani, President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: mharrdg@aol.com