AGA Files Comments on the HUD Proposed Changes to the Manufactured Home (MH) Construction and Safety Standards Proposals Impacting Natural Gas Applications.
On Monday, AGA filed timely comments (attached) on the proposed changes to the Federal Manufactured Home Construction and Safety Standards (MHCSS) that impact natural gas and propane applications. As a reminder, we previously reported on the July 19th HUD Federal Register Notice  ( September 2, 2022 Update) that is proposing changes to the MHCSS requesting public comments by September 19, 2022.  The proposal is adopting the fourth and fifth group of recommendations made to HUD by the Manufactured Housing Consensus Committee (MHCC) and includes many changes that impact the installation of fuel gas into manufactured homes. These include updating the references for gas appliance standards and components that are permitted in newly built manufactured homes, references to the installation codes for MH’s including the National Fuel Gas Code (ANS 223.1/NFPA 54), interior fuel gas materials (steel, copper, CSST, etc.) and specific installation requirements, etc.  Even though there are proposals to update many of the reference standards and codes in the , the proposed references are still outdated when compared to current versions. The AGA comments recommend updating the reference standards to the latest editions of the applicable for gas appliances and components standards referenced in the HUD code. The AGA comments also identified some provisions in the HUD proposal that would conflict with the requirements for minimum efficiency requirements for gas appliances that are outdated need to be deleted with a replacement of the requirements established under the DOE appliance minimum efficiency regulations. We will provide the HUD response to our comments when available.

September 21-22, 2022, BECS Committee Meeting at AGA in Washington, DC .
Thanks to everyone who attended in-person or virtually in this week’s very productive September 21-22, 2022, BECS Committee meeting held at AGA in Washington, DC.   The draft minutes of the meeting will be sent out soon.