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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations significantly altered the intent as proposed. HUD disagreed with opposition to the proposed change as the changes have been vetted by the MHCC and are consistent with many state requirements for testing potable water supply systems. While this change may require revisions to manufacturers installation instructions, the system of design approvals will ensure the instructions conform to the revised requirements by the rules effective date.
Subpart H, Heating, Cooling and Fuel Burning Systems 3280.705

Gas Piping Systems
One commenter suggested HUD
eliminate hard pipe in paragraph i8iii, as the industry uses a flex gas connector and not a quick-disconnect.
HUD Response: HUD reviewed and generally agreed with the commenter and modified the standard to incorporate the commenters proposed change.

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3280.709

Installation of Appliances
A commenter stated that 3280.709a and 3280.711 require that manufacturers currently ship two sets of installation instructions for each appliance with every home; the MHCC
voted to strike this requirement from section 3280.709a by letter ballot in 2015 Log 92.
Some commenters noted the importance of inspection but stated that it is unclear who is to perform on-site inspections and testing related to paragraph a1ii. One commenter stated that HUD should clarify that the installation is to comply with the local building code requirements and be subject to inspection by state or local code officials. This commenter noted that the language in 3280.709a1
would allow for the installation of direct vent space heating appliances on-site following approved instructions and the installation and inspection procedures provided.
A commenter was concerned with changes to the vent system termination provisions in paragraph d because the commenter was unaware of any healthsafety risks that would necessitate expanding the permissible range from 3
to 10 feet. The commenter stated the IRC
has a similar requirement, but it only applies to the vent system of a fuelburning appliance. Consequently, the commenter recommended adding the clarifying phrase of fuel-burning appliances. In addition, the commenter replacing the phrase habitable areas with habitable rooms because this term is defined in the Standards.

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HUD Response: HUD agreed that the MHCC voted to eliminate the requirement for the home manufacturer to provide two sets of appliance manufacturers instructions with each home. This recommended change is anticipated to be addressed in a future rulemaking. HUD also reviewed the comments concerning the site installed direct vent appliances and has made changes to clarify that testing of the homes fuel supply and electrical systems are the responsibility of the home manufacturer. HUD also reviewed the comment regarding separation of intake and exhaust vents and made changes to address the comment by clarifying that the placement restrictions apply to exhausts of fuel burning appliances and using the defined term, habitable rooms.

explained that wiring ceiling-mounted and wall-mounted light fixtures to one switch has been standard practice for decades. A commenter stated they were unaware of any health-safety risk associated with having multiple bathroom lights controlled by the same switch, HUD has not provided any information to suggest otherwise, and consumers preference and other building codes or standards support the commenters position.
HUD Response: HUD disagreed with the comments. The intent of the requirement for separate switches allows an occupant to use one or both lights at their discretion. This allows potential energy consumption savings by allowing the occupant to energize one light rather than both if both are not necessary.

3280.710 Venting, Ventilation, and Combustion Air
Subpart J, Transportation Systems
One commenter stated that the new requirement at paragraph d is not needed and that, to follow the proposed requirement, the commenter would have vent pipes above allowable transport height. The commenter requested that HUD delete the requirement because it would be forced to have vent pipes site installed, revise vent runs, or eliminate some floor plans completely, which would drive up the cost of affordable housing and cause financial burden. Another commenter stated that HUD should clarify that 3280.710 applies to fuel-burning combustion appliances, to be consistent with the IRC. Two commenters proposed changes to HUDs regulatory text.
HUD Response: HUD disagreed with the comment that the changes to separate intake and exhaust vents are not needed. The proposed standard was recommended by the MHCC and HUD
refers the commenter to U.S.
Government Accountability Office GAO audit report GAO1352, Testing and Performance Evaluation Could Better Ensure Safe Indoor Air Quality.
HUD also reviewed the comment regarding separation of intake and exhaust vents and has made changes to address the comment by clarifying that the placement restrictions apply to exhausts of fuel burning appliances and using the defined term, habitable rooms.
Subpart I, Electrical Systems 3280.807

Fixtures and Appliances
Some commenters stated that the new requirement at paragraph g has no safety benefit to the consumer and HUD
should delete it. The commenters
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3280.902

Definitions
One commenter stated that the proposed change to the Drawbar and coupling mechanism definition, by removing A frame and adding in its place rigid substructure, is not justified and should be discarded.
Another commenter suggested deleting the parenthetical from the Drawbar and coupling mechanism definition for clarity. The commenter stated the parenthetical is unnecessary, and usually an A frame rigid structure only creates confusion where the defined term Frame also uses the phrase rigid structure in its definition.
HUD Response: HUD disagreed with these comments. The added term is consistent with the same use in other definitions and is intended to reflect the structure to which the coupling mechanism is mounted.
3280.903 General Requirements for Designing the Structure To Withstand Transportation Shock and Vibration One commenter suggested that HUD
reject the proposed changes to paragraph a. The commenter stated that to remove during its intended life is unacceptable. To alter the language to function after set-up now establishes a time frame on how long chassis have to last and many manufactured homes will no longer be transportable which is required under 3280.2. The commenter did not suggest where HUD
should reinclude the phrase during its intended life if HUD kept its proposed changes to 3280.903.
For paragraph b1, commenters stated that HUD should provide more guidance on the road test requirements and clarify what constitutes an effective
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