Comment Submitted by Ross Kinzler, Wisconsin Housing Alliance

The Wisconsin Housing Alliance represents the factory built housing industry in Wisconsin. The increase in engineered solutions to physical limits on home designs means that HUD must either extend its AC process or permit under its authority on-site completion of homes. The Alliance supports the latter. The types of on-site construction anticipated involve the completion of the home itself which the rule properly designates as falling under federal not state or local jurisidiction. Some commenters argued for state or local jurisdiction but that would create a hodgepodge of regulations for the very same construction from state to state or even city to city. Issues for comment: 1. The rule should retain a broad definition of "substantial completion" so as not to limit future technological advances. For example, an external heating/cooling technology may be available some day that would differ based upon the geography or other physical feature of the job site. This type of completion might go beyond the "box" of the home. Flexibility by the agency should be retained. 2. Extending on-site completion to certain installation work such as hinged roof is appropriate since this work is done under the guidance of the manufacturer. 3. no comments 4. The paper work on completion should not interfere with the labeling of the home. A self certification should be adequate. 5. The inspection process needs to be uniform nationally. 6. The IPIA should inspect homes to a percentage that convinces them that the process is being completed as directed. Not every home needs to be inspected. This mirrors the in-plant process. 7. The IPIA should designate who acts on their behalf. 8. Designating those aspects subject to local inspection would be helpful provides some consistency is maintained. 9. The DAPIA should designate the design and competion details. 10. The rule should address completion timelines and not permit non-uniform deadlines.