Manufactured Home Construction and Safety Standards Act Park Model RV Exemption Notice

Forms and Documents

Document Name	Status
2502-NEW Supporting Statement CLEAN 20181206.docx Supporting Statement A	2019-08-05
Approved PTA Form for Collection 2502-NEW, 11-30-18.pdf Supplementary Document	2018-12-14
24 CFR Part 3282.pdf Supplementary Document	2018-12-14
24 CFR Part 3280.pdf Supplementary Document	2018-12-14
MHCSS Act (w- Legal Authorities highlighted).pdf Supplementary Document	2018-12-14

IC Document Collections

IC ID	Document Title	Status
234523	Manufacturer's Notice for Exempt Park Model Recreational Vehicles (PMRVs)	New

ICR Details

OMB Control No: 2502-0616	ICR Reference No: 201812-2502-003
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: HUD/OH	Agency Tracking No:
Title: Manufactured Home Construction and Safety Standards Act Park Model RV Exemption Notice
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 08/30/2019
OIRA Conclusion Action: Approved without change	Conclusion Date: 11/12/2019
	Date Received in OIRA: 08/15/2019
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	05/31/2020	6 Months From Approved
Responses	4,000	0	0
Time Burden (Hours)	22	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: To carry out its responsibilities under the Act, HUD has issued the Federal Manufactured Home Construction and Safety Standards (the Standards), 24 CFR 3280. The Department has also issued the Manufactured Home Procedural and Enforcement Regulations (the Regulations), 24 CFR 3282, to enforce these standards. The Regulations incorporate an exemption from HUD regulation for recreational vehicles (RV) if they are: built on a single chassis; 400 square feet or less when measured at their largest horizontal projections; self-propelled or permanently towable by a light duty truck; and designed primarily not for use as a permanent dwelling but as temporary living quarters for recreational, camping, travel, or seasonal use. Through recent rulemaking, HUD is adopting a recommendation of the Manufactured Housing Consensus Committee (MHCC), a Federal Advisory Committee, and is clarifying the definition of recreational vehicle (RV) and modifying it to require certification with either the American National Standards Institute’s (ANSI) standard for Park Model Recreational Vehicles (PMRV), A119.5–15 or the National Fire Protection Association’s NFPA 1192, Standard on Recreational Vehicles, 2015 Edition. Since Park Model RVs built to ANSI A119.5-15 may exceed the RV exemption’s 400 square foot threshold, a manufacturer must post notice in the home that the structure is only designed for recreational purposes and is not designed as a primary residence or for permanent occupancy.

Emergency Justfication: The collection of information is essential to the mission of the agency.

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Authorizing Statute(s): US Code: 24 USC 3280 Name of Law: Federal Manufactured Home Construction and Safety Standards
   US Code: 24 USC 3282 Name of Law: Manufactured Home Procedural and Enforcement Regulations
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
2502-AJ33	Final or interim final rulemaking	83 FR 57677	11/16/2018

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Manufacturer's Notice for Exempt Park Model Recreational Vehicles (PMRVs)

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	4,000	0	0	4,000	0	0
Annual Time Burden (Hours)	22	0	0	22	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Changing Regulations

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a new information collection package. Through recent rulemaking, HUD is adopting a recommendation of the Manufactured Housing Consensus Committee (MHCC), a Federal Advisory Committee, and is clarifying the definition of recreational vehicle (RV) and modifying it to require certification with either the American National Standards Institute’s (ANSI) standard for Park Model Recreational Vehicles (PMRV), A119.5–15 or the National Fire Protection Association’s NFPA 1192, Standard on Recreational Vehicles, 2015 Edition. Since Park Model RVs built to ANSI A119.5-15 may exceed the RV exemption’s 400 square foot threshold, a manufacturer must post notice in the home that the structure is only designed for recreational purposes and is not designed as a primary residence or for permanent occupancy. The proposed rule for this requirement published in the Federal Register on February 9, 2016 at 81 Fed. Reg. 6806 included an estimate of the information collection burdens at the time of the publication. The Department did not receive any substantive comment from either the public or the from OMB regarding the proposed information collection or burden estimates included in the proposed rule. More recent discussion with the RV Industry Association has informed this information collection burden estimate as the number of RV manufacturers building Park Model RVs has increased slightly since the proposed rule. Therefore, for this submission of this new information collection, HUD is identifying the burden hours resulting from the requirement for PMRV manufacturers that produce exempt products to provide specific consumer notifications. HUD has determined that this information collection burden does not fit within other information collections for the Manufactured Housing program. Therefore, this information collection is being submitted as a new collection. This information collection: • Includes the PMRV manufacturers as respondents (22 PMRV manufacturers building to the A119.5–15 Standard) • Includes the burden hours associated with the time and cost for delivering a Manufacturer’s Notice to prospective consumers prior to the completion of the sales transaction and placing the same notice inside the exempted PMRV. This is estimated at approximately 20 seconds per notice, the time incurred in developing a template notice, and using that template to create copies for delivery and posting in affected PMRVs.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 08/15/2019

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