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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations
these standards are established to work in concert with the regulations for On Site Completion of Construction and will help to ensure that appropriate designs are provided to address the work that is expected to happen in the factory, the work that is expected to happen at the home site, and the factory and or inspections at the site necessary for conformance.
3280.307
Use
Resistance to Elements and
A commenter stated that the expansion of field installation of exterior coverings means the requirement for the manufacturer to provide all needed materials siding, fasteners, channels, etc. should be added to this list. Another commenter agreed and suggested adding and the required materials after Complete installation instructions. A commenter suggested adding attached garages to the list of exemptions in paragraph e, given the amount of onsite work required to complete the installation of an attached garage, and as long as the manufacturer is complying with HUDs list of conditions.
HUD Response: HUD reviewed and generally agreed with the comments.
HUD modified the standard accordingly.
Subpart F, Thermal Protection
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3820.504 Condensation Control and Installation of Vapor Retarders One commenter stated that the proposed requirements under 3820.504b and .506c are not needed, and HUD should delete them.
The commenter stated its mating walls are located in a conditioned area, gaskets are installed in the factory to prevent air infiltration, and the commenter has not witnessed a mating wall with damage from condensation.
Another commenter stated that mating walls are interior walls and should not be treated as exterior walls which require a vapor barrier.
Furthermore, many homes have single mating walls, and this section does not define on which side the vapor barrier should be applied.
Another commenter stated that HUD
should delete these proposals until certain issues are evaluated. There will be a concern if the connection between floors is not effectively sealed from allowing cold outside air to enter between the ceiling of the first floor and floor system of the upper floor. If cold air is entering this area, a vapor retarder should be applied to the ceiling on the first floor. Another concern would be if the bottom board is still required to be placed under the upper floors, this may
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add to additional condensation between the floors if the vapor retarder is not installed on the ceiling on the lower floor.
HUD Response: HUD disagreed with the commenters regarding the need for 3280.504b and c to be deleted or amended, and that the affected walls are interior walls. These commenters may not understand that the subject standards apply to the fire walls separating attached manufactured homes; rather than, mating walls between two sections of the same manufactured home. Multi-story manufactured homes have been designed and built for more than two decades prior to the rulemaking and under Alternative Construction processes. These homes have been designed and built, and significantly, HUD has not received information indicating these homes, without a ceiling vapor retarder on the first floor, are not performing.
3820.506 Heat Loss/Heat Gain Two commenters suggested revising paragraph c by replacing the mating wall of each with the fire separation wall between each. Mating walls between two or more sections of a multi-section home are not the same as firewalls separating two or more attached, single-family manufactured homes. Mating walls are aligned at installation to create a cohesive singlefamily residencethey are not exterior walls. However, fire separation walls, which separate attached single-family homes, should be classified as exterior walls because they act as a health-safety barrier between distinct residential dwellings. The commenters believed these edits clarify the distinction between mating walls and fire separation walls.
HUD Response: HUD reviewed and generally agreed with the comments.
HUD modified the standard to incorporate the public comment where those changes have not significantly altered the intent as proposed.
Subpart G, Plumbing Systems A commenter suggested clarifying the definition of indirect waste receptor, a new term being introduced to the Standards. Second, in 3280.608, strike Hangars and replace it with Hangers as in the original. Third, by incorporating additional safety considerations from the Uniform Plumbing Code, the commenter saw an opportunity to protect the general public from the risk of burn or scald.
The commenter believed a homes relief drain, should it terminate outside the home, must terminate between six and
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twenty-four inches above the finished grade and face down at termination;
high enough to prevent backflow, but low enough to reduce the risk of injury or accident.
HUD Response: HUD reviewed and generally agreed with the comments.
HUD modified the standard to incorporate the public comment where those changes have not significantly altered the intent as proposed.
3280.609 Water Distribution Systems One commenter stated that the requirement that installers extend water heater relief valve piping to beyond the skirting of the home would very likely create an imminent safety hazard because it carries superheated, pressurized water, so it should be deleted. Another commenter stated that if the relief valve is directed to outside the crawl space, there would be a possibility of personal injury to those nearby. The commenter explained that water heater manufacturers do not allow additional piping to be installed directly on the pressure relief valve. They require air gaps when directing into additional piping. The commenter concluded that HUD should reject these changes.
Another commenter stated that HUD
should add discharge pipe turndown requirements taken from the Uniform Plumbing Code which adds a higher level of scald protection. This revision will increase consumer safety.
Two commenters proposed changes to HUDs regulatory text.
HUD Response: HUD reviewed and generally agreed with the comments and addressed the protections to residents by accepting comments regarding relief pipe turndowns. HUD also modified the standard to incorporate the public comment where those changes have not significantly altered the intent as proposed.
3280.612 Tests and Inspection One commenter opposed the changes to this section because they would reduce the required pressure needed to perform water supply testing and, as a result, a revision of the manufacturers installation instructions would be needed along with oversight by the IPIA
agencies to assure that the proper instructions are provided with the home. Another commenter recommended that, in the last sentence, potable water source should replace potable source of supply.
HUD Response: HUD generally agreed with the comments regarding wording changes to the standard. HUD modified the standard to incorporate the public comment where those changes have not
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