FR-4928-P-01 Model Manufactured Home Installation Standards

This Section refers to a Section 3280.705 that doesn't appear to be in the proposal. American Gas Association (AGA)

Section 3285.503 (pages 21545 and 46) has a section called "Optional Appliances". Under thatsection, part "C" is titled "Appliance Venting". This section requires all heat producing appliances to be exhausted to the outside. This provision is confusing since it would require all heat producing appliances "exhausted" to the outside. A literal interpretation of that provision could apply to any heat producing appliance such as a cooking range. If the intent of his provision is to require exhusting of clothes dryers to the outside, it should state that. As proposed the provision is confusing since vented gas appliances are required to be vented to the outside, not exhausted. Domestic cooking ranges are not required to be exhausted in the current HUD MHSS and there is no reason to require it in this standard. Finally, this entire provision appears to be out of place in the section that it is located. It appears to be a subpart of Section (3) Evaporative coolers which does not seem appropriate. American Gas Association