Revising the Definition of “Manufactured Home” to Lower Housing Costs
The Department of Housing and Urban Development (HUD) has proposed a high-stakes amendment to the Manufactured Home Construction and Safety Standards (MHCSS) that represents a radical departure from long-standing regulatory interpretation. The proposal seeks to allow transportable sections of multi-story manufactured homes—specifically those serving as upper floors—to be constructed and transported without a permanent chassis.
Link To The Federal Register
A Proposed Rule by the Housing and Urban Development Department on 06/12/2026
Summary
This proposed rule would amend the definition of “manufactured home” in HUD’s Manufactured Home Construction and Safety Standards (MHCSS), Model Manufactured Home Installation Standards (MMHIS), and Manufactured Home Installation Program (MHIP) to provide that a transportable section of a manufactured home serving as part of an upper floor of a manufactured home would not need to be transported or built on a permanent chassis.
Interested Parties May Submit Comments: Due By August 11, 2026
Interested persons are invited to submit comments regarding this proposed rule. There are two methods for submitting public comments. All submissions must refer to the above docket number and title. To receive consideration as public comments, comments must be submitted through one of the two methods specified below.
1. Electronic Submission of Comments. Interested persons may submit comments electronically through the Federal eRulemaking Portal at www.regulations.gov. There, interested parties may also find a plain language summary of the proposed rule.
Tips For Submitting Your Comments Online
After You Click On The Link To www.regulations.gov
1) Add Docket # To Search Box: FR-6537-P-01
2) Click On: FR-6537-P-01 Revising the Definition of ‘‘Manufactured Home’’ to Lower Housing Costs
3) You Will See A Clickable Link That Says Open For Comments
4) After You Click On The Link You Will Then See A Clickable Link To The Lower Right Of The Page That Says Comment
5) There Is A 5000 Word Limitation
6) You May Upload Up 20 Documents
Mail In Your Comments
2. Submission of Comments by Mail. Comments may be submitted by mail to the Regulations Division, Office of General Counsel, U.S. Department of Housing and Urban-Development, 451 7th Street SW, Room 10276, Washington, DC 20410-0500
Video Explainer
Summary Of Janet Thomes's Comments
My name is Janet Thome, Founder and President of Tiny House Alliance USA. I appreciate the opportunity to submit comments regarding HUD’s proposed rule to modify the permanent chassis requirements for upper-floor transportable sections of multistory manufactured homes. While the proposed rule focuses primarily on affordability, design flexibility, and construction cost savings, I am concerned that it does not adequately address transportation safety implications. Transportation is an essential part of the manufactured housing lifecycle.
Before reducing permanent chassis requirements, HUD should fully evaluate the potential impacts on highway safety, transportation integrity, inspection, certification, enforcement, and public risk. One of my primary concerns is that the proposed rule may create unintended transportation consequences if transportation requirements are not coordinated with existing federal transportation regulations. The most effective way to address this concern is to ensure that HUD’s transportation-related provisions are harmonized with applicable federal transportation requirements. Accordingly, I respectfully recommend that HUD coordinate and harmonize transportation-related provisions with applicable requirements contained in Title 49 of the Code of Federal Regulations and consult with transportation stakeholders, including NHTSA, FMCSA, the Commercial Vehicle Safety Alliance (CVSA), state motor carrier enforcement agencies, and other transportation professionals before implementing the proposed changes.
Please see the attached comments and supporting documentation for additional information regarding transportation safety, cargo securement, braking systems, carrier systems, accountability, transportation incidents, and related transportation concerns. Temporary Transportation Task Group HUD should establish a Temporary Transportation Task Group before implementing the proposed changes. The Task Group should include representatives from NHTSA, FMCSA, the Commercial Vehicle Safety Alliance (CVSA), state motor carrier enforcement agencies, transportation safety professionals, manufacturers, inspection agencies, transporters, insurers, and other stakeholders with expertise in highway transportation.
The Task Group should evaluate transportation-related issues including braking systems, running gear, axles, recycled axles, wheels, couplings, lighting, cargo securement, vehicle identification, certification, inspection, enforcement, crash data, carrier system accountability, liability, and harmonization with applicable transportation requirements contained in CFR Title 49 Transportation. The Task Group should also evaluate documented transportation incidents involving manufactured homes, modular homes, mobile structure trailers, office modules, data center modules, and other factory-built structures transported on public highways. HUD should complete this transportation review before reducing permanent chassis requirements for upper-floor transportable sections of multistory manufactured homes.
A Manufactured Home Is Heavily Regulated
I have long appreciated HUD’s regulation of manufactured home transportation systems, including requirements related to permanent chassis construction, road testing, identification, certification, and traceability. If this rulemaking is adopted and upper-floor sections are no longer required to be constructed on a permanent chassis, I respectfully request that HUD align its requirements with applicable federal motor vehicle and transportation laws.
This should include any manufactured home or modular home that utilizes a temporary carrier system for transportation on public highways. Any temporary carrier system utilized for the transportation of a factory-built structure should be a legally recognized motor vehicle trailer and should comply with all applicable federal transportation requirements, including identification, certification, inspection, operational, and safety requirements administered by the appropriate federal transportation agencies. Thank you for your consideration. Janet Thome President Tiny House Alliance USA
Janet Thome Uploaded 14 Documents
New Hampshire_ Fatal Wheel Assembly Separation Involving Modular Home Transport.pdf
Misplaced Liability on Truck Drivers.pdf
Need for a Transition Period and Transportation Review.pdf
Temporary Transportation Task Group.pdf
Recycled Axles and Transportation Components.pdf
Cargo Securement.pdf
Transportation by USDOT-Regulated Motor Carriers Using Recognized Transportation Motor Vehicle Trailers.pdf
NHTSA Interpretation Letter_ Modular Transport.pdf
Harmonization With CFR Title 49 Transportation Requirements.pdf
Safeguards When Manufacturers Also Transport Their Own Product.pdf
Same Transportation Laws For Modular And Manufactuered Homes.pdf
Coordination With Federal Transportation Agencies.pdf
Unintended Consequences of 24 CFR 3282.pdf
Analysis of Modular and Manufactured Home Transport Incidents and Mechanical Failures.pdf
Folder Of Janet Thome's Comments
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