Comment Submitted by Richard Weinert, Dept of Housing & Community Development

This proposed rule affecting significant change to the on-site assembly of manufactured homes will create confusion with the consumer, retailers and may add unnecessary cost. The completion of manufactured homes on-site must be left to the state or local authority having jurisdiction, working from manufacturer / DAPIA-approved methods of site assembly. The current HUD label method must be viewed by HUD to (only) signify compliance at that point of construction prior to delivery from the factory. The label placed on the unit at the factory cannot signify compliance to future site construction and inspections that haven't occurred yet. Assembly compliance should only be provided by the AHJ which could be local, State or HUD depending on each states manufacfactured housing installation laws For those states that do not have a program for inspection of the asseembly of manufactured homes, this program could be used only if simplified in its proposed procedures and methods of tracking.