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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations roofs which can easily exceed the size of a carport. The commenter also stated that current HUD policy under Interpretive Bulletin H177 conflicts with paragraph fthere is no assurance that the manufacturer would be including these additional instructions.
Another commenter requested HUD
delete the following: Paragraph b about maximum roof slope for the carport, on the basis that carports cannot exceed the height of the home; paragraph c on beam designs, on the basis that beam designs would be part of the approved design by the Design Approval Primary Inspection Agency DAPIA; and paragraph d on shear wall and uplift strapping design, on the basis that the carport design would not be known.
One commenter stated that paragraph fs reference to 3285.201 should be changed to 3285.301.
Another commenter said 3280.213
for factory or site-built attached carports should emphasize the distinction between attached and self-supported structures and that striking unnecessary or superfluous rules would also streamline the requirements. The commenters suggested edits include:
Deleting the maximum roof slope requirement from the list of design characteristics for carports, because given that the height of the carport cannot exceed the height of the home, the carports roof slope is never a relevant factor in home design; adding a provision that, as an alternative to specifying the unique design characteristics of the carport and the home, manufacturers may provide the maximum loads that the home is designed to resist from the carport;
removing the provisions specifying where splices in the host beam can be located, because narrowly defining this provision with such detailed, prescriptive requirements could have unanticipated consequences, especially if there are continued advancements in anchoring technology. According to the commenter, specific design characteristics should remain subject to review and approval by the manufacturers DAPIA.
The commenters recommendations continued with: Removing the shear wall requirements for homes designed for Wind Zone II and III installations in favor of manufacturers specifying anchor requirements for uplift forces in Wind Zones II and III as part of the homes DAPIA-approved design, because if the manufacturer and its DAPIA specify these requirements at the design stage, the size of any attached carport would be limited by the load capacity of the anchor system installed
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in the factory. This would limit the design options available to any third party responsible for installing an attached carport at the jobsite; and removing the cone of influence provision, because this requirement is dependent on the type of anchor, and should be determined by the installer.
The manufacturer should not be expected to know this information without knowing exactly where a manufactured home would be sited and how it would be installed; and confirming that a site-built, selfsupported carport is considered an addon and clarifying that add-ons do not affect a manufactured homes ability to comply with the Construction and Safety Standards.
Another commenter also supported deleting paragraph c1, because this paragraph was covered in paragraphs a and c, and additional details on the acceptable engineering load path are not required. The commenter also suggested deleting paragraph d because the load path requirements should apply to all wind zones as specified in paragraphs a and c. The commenter also stated that the accepted engineer anchor test protocol does not test for cone of influence and it is not defined within the Construction and Safety Standards.
Therefore, it should be removed from 3280.213f1.
HUD Response: HUD did not add requirements for patio covers and porch roofs, as such specific code change text and supporting information be submitted to the MHCC for consensus review and deliberation. It is not appropriate for HUD to integrate these changes at the final rule stage. Further, HUD disagreed with comments that installation instructions are not required by the standard, as it is clearly addressed in 3280.213b and e.
Upon placing a label certification on each transportable section of a manufactured home, the manufacturer self-certifies its compliance with the Construction and Safety Standards.
HUD notes the added information required on the Data Plate more clearly identifies whether the home has been designed for an attached carport. HUD
agreed with all comments providing specific textual changes and HUD
modified the standards accordingly.
Subpart D, Body and Frame Requirements 3280.305 Structural Design Requirements One commenter stated that proposed 3280.305h5 expands areas of construction that could be deferred to the job site and imposed on the installer
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under On-Site Completion Requirements. The commenter stated that installers were not included in deliberations on the proposed changes, and that since the On-Site Completion rule is relatively new, and given that HUD has failed to monitor or measure compliance, this provision should be deleted until the success of the On Site Completion process can be evaluated.
Another commenter stated that HUD
should delete the words connections between sections, after hinged roof sections, and before sheathing, in paragraph h5 because connections between sections is covered as part of standard installation.
Another commenter stated that paragraph h5iii requires inspection at an installation site in stages but does not clarify who would provide inspections. The commenter also suggested that HUD clearly define inspection of the work at the installation site in stages, and stated that this new requirement would add costs to the home, drive up the cost of affordable housing, and would financially burden the commenter.
Two commenters stated that HUD
strike 3280.305h5 iii, iv, and v, because these proposals generally apply to onsite installation and appear to overstep Subpart Ds bounds. The commenters believed these requirements, if necessary, would be more appropriate under Part 3282, Subpart M, On-site Completion of Construction of Manufactured Homes.
HUD Response: HUD disagreed with the commenter that revisions to this standard expand areas of construction that can be completed on site. The changes to this standard were already implemented with the On-Site Completion of Construction Rule and these changes are conforming. Further, HUD conducted limited monitoring of procedures and approvals related to On Site Completion of Construction and has not concluded any adverse or significant findings.
HUD modified this section to address other comments received including removing any references to installation activities. HUD also modified the inspection requirements but has retained the intent that inspections occur prior to covering up additional aspects or otherwise allowing for inspection panels so that inspection can take place. This aspect is important to assure that the work completed on site conforms to the design standards, so that the home is completed in accordance with the Construction and Safety Standards, and the home is not taken out of compliance through the work done at the home site. Further,
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