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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations
and stairway illumination, would free manufacturers from having to follow various state and local requirements that vary from jurisdiction to jurisdiction and bring uniformity to manufactured home construction nation-wide. The rule would also incorporate five new reference standards that are already standards used in the design, listing, and evaluation of the respective materials or components.
In addition, HUD has concluded that this rule provides manufacturers more flexibility in the ability to pursue design options and, more importantly, cost savings as the result of eliminating the need to obtain HUD approval through the Alternative Construction AC
process see 3282.14. More specifically, manufacturers need to engage the AC process to design and construct manufactured homes that incorporate innovations that have not yet been codified in HUDs Construction and Safety Standards. For example, addressing the design and construction of multi-story homes, attached homes, or homes that are designed to accommodate an attached garage or carport that is not factory constructed but added to the home during the home installation process, may create regulatory confusion between state, local, and Federal authorities and may sometimes require HUD approval through the AC process prior to the manufacturer being able to incorporate these design features. After review of an AC request, HUD establishes specific terms and conditions for use of the design through an AC letter. While the AC process serves a useful purpose, including encouraging the use of new
technology in the construction of manufactured homes, HUD believes that codification of certain design features that already were reviewed can provide cost savings for manufacturers and consumers, and reduce regulatory confusion when directly addressed within the code. In fact, HUDs final rule is based primarily on the MHCCs recommendations and integrates some aspects of specific AC letters that have been issued in the past. Specifically, regulatory costs that are currently borne by the manufactured home manufacturer associated with preparing an AC request and maintaining the AC
approvals include:
1. Manufacturers engineers preparation of designs, calculations, or tests for aspects that do not conform with outdated building standards for past innovations that have become more commonplace but have not yet been incorporated into the Construction and Safety Standards;
2. DAPIA review and approval of the designs, calculations, and or tests to be submitted on behalf of the manufacturers requesting HUDs approval;
3. Preparation of a submission package for the AC request, including all designs, calculations, and tests to be sent to HUD for approval;
4. Lost opportunity costs and actual manufacturer and DAPIA staff time to respond to HUD throughout the review and approval process, which, depending on the specific AC request, may take as few as 30 days or as long as 6 months;
5. Time and travel associated with third-party inspections at each affected homes site for manufactured homes
built under an AC that requires a site inspection be conducted in order to verify conformance with specific terms and conditions of the AC approval; and 6. Maintaining and providing copies of AC-specific production reports, inspection reports, and other administrative burdens required to maintain the AC approval.
This rule would also require that carbon monoxide detectors be installed in homes with fuel burning appliances or designed by the home manufacturer for an attached garage. These provisions are intended to be consistent with other single-family dwelling construction requirements and are intended to provide early warning alerts to occupants of the presence of carbon monoxide within the living space of the manufactured home. Specifically, this rule would require that carbon monoxide alarms be installed in accordance with the Standard for the Installation of Carbon Monoxide Detection Equipment, NFPA 7202015, and be listed and conform to the requirements of Single and Multiple Station Carbon Monoxide Alarms, ANSI/UL 20342016 edition.
In sum, the one-time annual costs of this proposed rule range from $2.19
million to $4.122 million. Total valued benefits range from $8.515 million to $12.517 million. Unvalued benefits include reduced home damage and injuries from piping water heater relief valves to outside of the home and from the avoided delay during the AC review.
The total estimated annual costs and benefits are described in the chart below.

3 percent Estimate: low
khammond on DSKJM1Z7X2PROD with RULES2

Total Annual Costs See Figure 3:
Carbon Monoxide Detector Requirement
Water heater relief valves
Wet-vented drains
Separate Bathroom Light Switches

7 percent
Estimate: high
Estimate: low
Estimate: high
$258,000
1,352,400
483,000
96,600

$1,032,000
1,932,000
772,800
425,040

$258,000
1,352,400
483,000
96,600

$1,032,000
1,932,000
772,800
425,040

Total
Present Value of Benefits Carbon Monoxide Detector Requirement See Figure 4:
Value of Injuries Prevented
Value of Deaths Prevented
Wet-vented drains See Figure 7
Separate Bathroom Light Switches See Figure 5
Deregulatory See Figure 6:
Whole-House Ventilation
2-Story Homes
Attached Garages

2,190,000

4,161,840

2,190,000

4,161,840

166,818
8,908,186
483,000
326,796

166,818
8,908,186
772,800
2,614,366

142,688
7,619,651
483,000
214,929

142,688
7,619,651
772,800
1,719,434

3,540
12,640
38,836

3,540
12,640
38,836

3,540
12,640
38,836

3,540
12,640
38,836

Total

9,939,816

12,517,187

8,515,285

10,309,589

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