MHARR Comments on Proposed On-Site Rule

Attached, for your information, review and use, are MHARR’s comprehensive comments in response to the proposed rule on “On-Site Completion of Construction of Manufactured Homes” published by HUD on June 23, 2010. MHARR, as with its comments on proposed rules concerning the “Duty to Serve Underserved Markets” and “Test Procedures for Roof Trusses”, has prepared and filed these comments at an early stage in the rulemaking process so that they are available as a model, basis, or support, as needed, for individual comments filed by industry members. Comments in response to the proposed rule must be filed no later than August 23, 2010. A copy of the proposed rule can be downloaded for your convenience.

As the attached comments indicate, MHARR supports the proposed rule, but with significant conditions attached, that involve key clarifications and modifications of the rule as proposed. Simply put, on-site completion under this rule could either be extremely beneficial for the industry and its consumers, or could backfire on both. If properly finalized and implemented by HUD, with the clarifications and modifications identified by MHARR, a timely, cost-effective on-site completion process could expand existing markets for the industry and open new ones. Conversely, if the industry does not provide HUD with the input that it needs to develop such a proper final rule, and the final published rule does not contain the necessary clarifications and modifications, the on-site process could actually do more harm than good, leaving the industry and consumers with no choice but to oppose the final rule.

Consequently, it is important that industry members review and familiarize themselves both with the proposed rule and with MHARR’s comprehensive comments and submit their own individual comments accordingly.

MHARR extends its thanks and gratitude to the industry members and, particularly, the manufacturer regulatory, legal and technical executives, and retailers, who were instrumental in analyzing the proposed HUD rule and assisting MHARR in the development of its attached comments.

MHARR will continue to keep you apprised as this rulemaking process advances.

Download – MHARR Comments on Proposed On-Site Rule

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