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On Tuesday, the Manufactured Housing Consensus Committee (MHCC) convened a special teleconference to review and comment on HUD’s proposed standards for multi-story manufactured homes that would not require a permanent chassis on upper floors.

MHI commends HUD for initiating this important discussion and appreciates the opportunity to contribute. The MHCC used MHI’s comment letter as the basis for its deliberations. This document proved instrumental in advancing a productive and focused conversation.

MHI’s CEO, Dr. Lesli Gooch, responded to some of the concerns raised in letters in opposition to this proposal – noting that many of the arguments continue an outdated and incorrect stigma against HUD Code homes. Congress established the manufactured housing program fifty years ago to create a distinct category of housing built to a federal construction and safety standard.

“Our homes are built to that (HUD Code) standard and carry a federal seal of approval,” Gooch said. “The notion that these homes are somehow substandard is not only inaccurate—it undermines the very purpose of the HUD Code and the progress this industry has made.”

The MHCC expressed broad support for the intent and direction of the proposed changes, particularly the removal of the chassis requirement from upper floors. The committee recognized this as a cost-effective step that could enhance architectural flexibility and design. Members also noted that expanding the availability of multi-story HUD-Code homes could increase consumer choice and play a meaningful role in addressing the nation’s affordable housing needs.

In addition, the MHCC aligned with MHI’s concerns regarding proposed changes to the definition of “manufactured home” in Section 3280.2. The committee cautioned that altering the format of this definition could create confusion, especially if it diverges from the statutory definition. Such changes could result in multiple, potentially conflicting definitions at the federal and state levels.

MHI will continue advocating to change the definition of manufactured housing in federal law so that homes built without a permanent chassis can be constructed to the HUD Code. As the legislative process continues, HUD’s effort to change the HUD Code regulations around chassis requirements for upper floors is a positive first step and MHI will work with HUD to make it a reality as quickly as possible.

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