Montana roadmap: where we stand and what happens next

Written 13 Sep 2026. This is the front door to docs/montana/. It does not do new research. It synthesises the four research documents in this folder and tells you what to do with them.

Nothing here is legal advice. Every rule number traces back to one of the four documents, and every one of those carries a source URL and a fetch date. Where the research says NOT CONFIRMED, this document keeps it not confirmed. Where two of the research documents disagree, section 7 says so and says which one I believe.

1. Executive summary#

Where you stand. You have two products and no approvals. Nothing has been built, no cylinders have been broken, no engineer has stamped anything, and no plant exists with named stations. That is not a criticism, it is the starting position, and it matters because most of the Montana program is gated on things that only exist once a plant exists.

What the program requires. Montana runs a Factory-Built Building program out of the Building and Commercial Measurements Bureau at the Department of Labor and Industry. There is no manufacturer licence and no registration fee. You become an approved manufacturer by getting a model plan approved (ARM 24.301.1217(2)). To get there you need, in this order: an in-plant quality assurance manual approved by the bureau, then a model plan approved, then a contracted third-party inspection agency's initial plant certification, then a built unit with every deficiency closed, then a $40 insignia tied to that specific serial number and a named Montana destination. Then you can sell. There is no provisional label and no way to sell a unit while the plan is in review (02-approval-process.md section 9).

The whole rule set was rewritten on 21 September 2024. The old ARM subchapter 24.301.5 was repealed or transferred into a new subchapter 24.301.12, and Montana adopted ICC/MBI 1200-2021 and ICC/MBI 1205-2021 by reference at ARM 24.301.1203. The bureau's own web page and its paper forms still cite repealed rule numbers and still print the old eleven-item quality control manual list. Your manual has to be written to chapter 5 of ICC/MBI 1205, not to the web page. You have to buy both standards from ICC, because the state adopted them and does not republish them, and until you do, nobody can tell you what your submittal or your manual must actually contain (01-statute-and-rules.md section 0 and 3.4).

The single biggest open question. Is the skid-mounted shower house a "factory-built building" under ARM 24.301.1205(4) and MCA 50-60-101(9)(a)? The definition wants a factory assembled structure with service connections, "but not made so as to be readily movable as a unit or units and designed to be used with a permanent foundation." Your shower house meets the first half cleanly. It is built complete in the plant with plumbing, DWV, a 100 A panel and branch circuits all installed. It arguably fails the second half on both legs: it sits on a welded steel skid with fork pockets and four 10,000 lb lifting lugs, it is marketed as movable, and as designed it sits on "whatever the park gives it: gravel pad, blocks, or piers," which is not a permanent foundation system under ICC/MBI 1200 and is not a permanent foundation under the DPHHS campground rule at ARM 37.111.1201(16) either (03-codes-and-classification.md section 3.3).

What it costs you if the answer is no. A "no" does not mean no rules apply. It means there is no state route, which is worse than being in the program:

• You lose ARM 24.301.1245(1), the rule that makes an insignia-bearing unit acceptable anywhere in Montana "without further inspection or fees except for zoning, utility connections, and foundation permits." That statewide acceptance is the entire product proposition for a unit you want to sell repeatedly across the state.
• Every destination becomes a conventional building permit with a local inspector asked to sign off on plumbing and wiring cast into concrete they cannot open. Some will refuse (03-codes-and-classification.md section 8). There is no rough-in for them to look at.
• The fallback is ugly. ARM 24.301.1245(2) says a new unit delivered to Montana without an insignia is in violation of Title 50, chapter 60, MCA, and "shall be treated as an existing building and required to meet all requirements of the authority having jurisdiction." That is a local inspector opening up your finished work. On top of that, MCA 50-60-402(1) bars you from even offering an unapproved new factory-built building for sale, and MCA 50-60-110 makes a knowing violation a misdemeanour.
• The commercial practical outcome is that you either redesign so the MEP is inspectable on site, which means not building it complete in the plant, which is the product, or every sale becomes a separate negotiation with a separate building official.

There is a lever you control. If the PE designs and stamps the skid as the permanent foundation system, with a bearing diagram, a maximum support spacing, a minimum bearing pressure and an anchorage detail with a device capacity, then the unit is "designed to be used with a permanent foundation" and the second leg of the definition flips from a fail to a pass. The "readily movable" leg still argues the other way, but the two legs are joined by "and," and a unit designed for a permanent foundation is far more likely to be treated as a factory-built building. That is one stamped sheet, and it also answers the DPHHS "permanent construction" test and a gap in the PE package at the same time (03-codes-and-classification.md sections 3.3 and 7). It is the cheapest high-leverage item in this whole file.

The second biggest open question, which is easy to miss. The house is the mirror image. It ships as 34 flat panels with no service connections in them, so on the plain words of MCA 50-60-101(9)(a) the house is probably not a factory-built building. But those panels are a "panelized system" under ICC/MBI 1200, which Montana adopted, and ARM 24.301.1221(1) expressly reaches "modular buildings or modular building components," and ARM 24.301.1205(2) defines "Components" as "the prefabricated wall, floor, ceiling, or roof panels." So the panel line may well need plan review, a quality manual and third-party inspection even though the finished house never gets an insignia. That question goes in the same letter.

2. Reading guide#

3. The critical path#

Numbered in the order you do them. "Gated" means it cannot finish until we get an answer we do not have yet. The structure comes from 02-approval-process.md section 9, the rule numbers are reconciled against 01-statute-and-rules.md, and the manual gate and its ten preconditions come from 04-quality-manual-requirements.md section 8.

Phase 0, unblocked, do now

Phase 1, engineering and plant, partly gated

Phase 2, the state process

Phase 3, first unit

What blocks what, in one table#

Two timing traps sit across the whole path. First, ARM 24.301.1201(3) closes the out-of-state delivery dodge: a buyer cannot take delivery elsewhere to avoid the Montana insignia. Second, ARM 24.301.1233(2)(a) revokes a plan review when the department adopts a different code version, and ARM 24.301.1231(3) says plans reviewed under the old codes cannot be renewed at all. You get 90 days from a new code's effective date to buy insignia on the old approval (ARM 24.301.1233(3)). That is why the status of the rulemaking heard on 28 August 2026 is a question you ask before you submit anything, not after.

Realistic budget for the whole of phase 2: a quarter, not a month. The manual has to clear before the plan can, and the initial plant certification sits after plan approval and before your first labelled unit (02-approval-process.md section 5).

4. What it costs#

State fees, in rule#

On the published schedule, standing up one model costs a few hundred dollars in state fees. The state is not the expensive part of this. Two cautions on that arithmetic:

1. 02-approval-process.md section 3 computes the house as "2 modules," which gives $325 plus $105 plus a $20 manual, so $450. The house is not two modules. It ships as 34 flat panels and nothing volumetric leaves the plant. That $450 depends entirely on the answer to the fee-counting question below, and the plausible answers range from $450 to something that ends the panelized product as designed. Treat the number as a placeholder, not a budget.
2. You cannot stockpile insignia. Each one is tied to a known unit going to a known Montana address and goes void 12 months after issue with no refund and no credit (ARM 24.301.1243(3)). A void one is not replaced (ARM 24.301.1247(2)).

Costs nobody has quoted, all quote needed#

Do not put a number against any of these until somebody quotes it.

5. Decision register#

Every open question across the four documents, deduplicated, with who decides, what it blocks, and what each plausible answer costs you. This is the part to read twice.

D1. Is the skid shower house a factory-built building?#

Decides: the Building Codes Bureau, in writing, on your question. Turns on: MCA 50-60-101(9)(a), ARM 24.301.1205(4). Blocks: the entire shower house path. Manufacturer application, quality manual applicability, third-party agency, insignia, and the whole sales proposition.

If yes: you are in the program. Roughly $430 of state fees for the first model, $40 an insignia, a third-party agency in your plant, and in return ARM 24.301.1245(1) makes the unit acceptable anywhere in Montana without further inspection or fees except zoning, utilities and the foundation permit. That acceptance is the product.

If no: there is no other state-level pigeonhole for a complete occupiable building that arrives on a truck. It is not a mobile home, not a manufactured home, and ARM 24.301.1207 flatly bars using an RV or a manufactured home for commercial occupancy, so you cannot solve it by buying a park model and calling it a bathhouse. What you get instead is a conventional site permit at every destination, with an inspector asked to approve plumbing and wiring cast into concrete they cannot open. Some will refuse. The economics of building it complete in a plant do not survive that.

If it depends: the most likely real answer. See D7.

D2. Does the off-site construction adoption reach the house panel line?#

Decides: the Building Codes Bureau. Turns on: ARM 24.301.1203 (adopting ICC/MBI 1200 and 1205), ARM 24.301.1221(1) ("modular buildings or modular building components"), ARM 24.301.1205(2) (components are "the prefabricated wall, floor, ceiling, or roof panels"), against ARM 24.301.1241, whose insignia requirement is written around "units," and ARM 24.301.1205(6), which now makes "unit" mean "module." Blocks: whether the panel line needs manufacturer registration, model plan review, a quality manual and third-party in-plant inspection, or only the documents ICC/MBI 1200 §103.3 requires.

If the panel line is in the program: a second review track, a second set of fees, third-party inspection of the panel bed, and a panel that any Montana jurisdiction has to accept. Note that ARM 24.301.1237 already speaks of "panelized system reviews" as a thing the bureau transmits, so a panel review product plainly exists in this program.

If out: the panels are still off-site construction under a standard Montana adopted, so the documents are still required. The site building official cannot inspect a cured panel: the stud-to-channel screws, the mesh position and the skin pour depth are all invisible once it sets. They will want the special inspection list, the construction sequence statement, the panel-to-panel connection detail and the installation tolerances anyway. So the documentation work is the same either way. Only the fees and the inspection regime change.

Note the disagreement between the research documents here. See section 7.

D3. How does the bureau count parts, sections, units and modules?#

Decides: the Building Codes Bureau. Turns on: ARM 24.301.1261 prices plan review by "parts," ARM 24.301.1263 prices insignia at "$40 per section," and ARM 24.301.1205(6) defines "unit" as "module" per chapter 2 of the ICC/MBI standards. The repealed .566 said "per part." Four words, possibly four meanings. Blocks: the entire cost model for the house, and the per-unit insignia cost for both products.

If per building: $325 structural plus $105 trades plus a $40 insignia. The number in 02-approval-process.md section 3 holds.

If per panel: 34 panels puts the house in the "five or more parts" tier at $650 structural plus $225 trades, and if insignia are counted the same way, $1,360 of labels per house. That ends the panelized product as currently priced.

If the house is not a unit at all (see D2): the question only bites the shower house, where the answer is almost certainly one section, $40.

This is the single biggest unknown in the cost model and the September 2024 vocabulary shift made it more urgent, not less.

D4. What is the status of the rulemaking heard on 28 August 2026?#

Decides: the bureau, dli.mt.gov/rules, or the Secretary of State's ARM register. Turns on: ARM 24.301.1233(2)(a) (a new code version revokes a plan review), ARM 24.301.1231(3) (old-code plans cannot be renewed at all), ARM 24.301.1233(3) (90 days from the new code's effective date to buy insignia on the old approval). Blocks: when you submit. Not what you submit, when.

If adopted and imminent: submitting to the 2021 editions buys an approval that gets revoked, and you pay new-application fees to redo the whole thing. Better to design to the incoming editions and ask the bureau to review against them.

If not adopted, or far out: submit now under the 2021 editions with the June 2022 Montana amendments.

This is the highest-leverage question per minute spent in the whole letter, because it is a one-line answer that can save a full re-review cycle and several months. Note the trap flagged in 01-statute-and-rules.md section 0: the ProposedRuleAmendments.pdf still sitting on DLI's server is the 2024 proposal, already adopted. Do not read it as pending.

D5. IBC or IRC for the house, and does the small-residential exemption change anything?#

Decides: the bureau. Turns on: ARM 24.301.1201(2)(a) says the IBC "or, as applicable" the IRC. MCA 50-60-102(1)(a) exempts residential buildings with fewer than five dwelling units from the state building code, which is Part 2, while the "may not manufacture, sell, or offer for sale" rule is MCA 50-60-402(1) in Part 4. Different sentences, different parts. Blocks: the code path the PE designs to, and therefore the snow load route and the energy path.

The two routes are not the same numbers. On the IBC route ARM 24.301.146(26) sends the design snow load to ASCE 7-22 outside certified jurisdictions. On the IRC route ARM 24.301.154 replaces R301.6 with ASCE 7-22 plus a minimum 30 psf design roof snow load unless a lower value is justified. Either way it is not ASCE 7-16, which is what the model code points at and what docs/engineering/standards-register.md currently says.

On the exemption: the research reading is that the exemption does not free you from the insignia requirement, because 50-60-402(1) is not conditioned on the state building code applying, because ARM 24.301.1201(2)(a) expressly contemplates IRC review, and because the application form has a "Residential" model type box. That reading is not confirmed. Do not spend a dollar on it.

D6. Is the non-site-specific load floor sellable, or is every unit site-specific?#

Decides: the bureau on the legal half; you and the PE on the business half. Turns on: ARM 24.301.1221(3): where the permanent site is unknown, the building must meet 115 MPH wind, seismic design category D, and 30 psf snow. ARM 24.301.1221(2)(e) requires those four figures on the first page of the construction document. Blocks: whether you can build to stock or must build to order. That is the difference between a product and a project, and it changes the business, not just the paperwork.

If the floor is genuinely sellable statewide: you cast units, stock them, and ship on order.

If not: every unit carries a site-specific load statement, which is a plan supplement at $20 per unit under ARM 24.301.1261 or, if it goes far enough, a new model. Every sale becomes an engineering event.

The honest read is that 30 psf ground snow is a floor, not a pass, and much of Montana carries a materially higher ground snow load. Ask the bureau whether an AHJ can reject a floor-compliant unit at a higher-load site. Then decide your own envelope and design above the floor to it, because that is what makes it a product.

D7. Skid as permanent foundation: stated, or disclaimed?#

Decides: you. Executed by the PE as one stamped sheet: bearing diagram, maximum support spacing, minimum bearing pressure, anchorage detail with a device capacity, for a stated wind and snow envelope. Turns on: MCA 50-60-101(9)(a), ICC/MBI 1200 §802.2 and §804.1, and ARM 37.111.1201(16). Blocks: D1's answer, the DPHHS "permanent construction" test at ARM 37.111.1216(1)(a), and gap 3 in 03-codes-and-classification.md.

If stated: the factory-built building classification collapses cleanly to yes, you have an argument for the campground service building rule, and the anchorage is engineered rather than improvised by whoever unloads the truck. You give up some of the "pick it up and move it" pitch.

If disclaimed: you keep the movable pitch and you are probably outside the factory-built building definition with no state route, and probably fail ARM 37.111.1216(1)(a) as a campground service building as designed.

One caution: ground anchors and earth augers do not help. ICC/MBI 1200's permanent foundation system definition expressly excludes them as uplift or sliding resistance. And the DPHHS definition names concrete, concrete block or wood pier on embedded footings, so a steel skid is not on that list either and may need a variance under ARM 37.111.1231 or an approval inside the 37.111.1204 plan review.

This is one drawing that answers three questions. Do it early.

D8. Who owns the accessible route, the landing and the ramp?#

Decides: you. It is a product decision, not a code question. Turns on: ADA 206.2.1, ARM 24.301.904 (site accessibility), ARM 24.301.903 as amended 9/21/2024 ("required toilet rooms and bathing facilities shall be accessible"). Blocks: the first campground sale, and the honesty of the word "accessible" in the brochure.

Today the product prices an accessible room and prices no way to get into it. The unit is 113.5 inches from skid bottom to roof top, it sits on the skid, and the pad allowance is "gravel base, levelled." That is a step up at the door and a gravel approach, and neither is an accessible route.

Three options: ship a steel landing and ramp loose, priced with the unit; specify a site-built concrete approach in the installation instructions and make it a condition of sale; or detail the skid so the floor sits near grade with a recessed pad.

Consequence of leaving it: the ADA is federal civil rights law and no building official enforces it, so a Montana insignia protects you from nothing here. An accessible room nobody can reach, in a place of public accommodation, advertised as accessible, is the shape of complaint that does real damage.

D9. Quality manual: chapter 5 of 1205, the bureau's eleven items, or both? Is there a checklist?#

Decides: the bureau. One phone call to (406) 841-2056. Turns on: ARM 24.301.1223(2) says chapter 5 of ICC/MBI 1205. The bureau's own web page still prints the old eleven-item quality control list. They disagree. Blocks: the manual's structure, and possibly a whole rejection round.

All four research documents land in the same place: write to chapter 5, fold the eleven items in anyway because they overlap heavily and the old list is a good checklist, and ask. North Carolina publishes a QC Manual Checklist and rejects manuals that arrive without it; if Montana has an equivalent, asking for it is free.

D10. What is the approval route for cellular concrete as a material?#

Decides: the bureau. Turns on: ARM 24.301.519 (product standards) and .520 (alternatives) were both repealed on 21 September 2024 with no direct successor, yet ARM 24.301.1233(2)(c) still revokes a plan review for "materials not listed and reviewed by a listing agency, or reviewed as an alternate or equivalent by the bureau." The concept survives; the rule describing the route is gone. MCA 50-60-103(4) lets the department require testing and approval of materials and issue certification of acceptability. Blocks: whether the panel can be approved at all, and by which route. There is no IRC chapter for a cast cellular concrete panel on cold-formed steel studs, and no Montana amendment addresses one.

If the answer is "the third-party agency and your PE handle it inside the plan review": cheap, and it is what you are already set up for.

If the answer is "get it listed by a listing agency": that is an evaluation report, which is real money and a long lead. You want to know that now, not when the plan review comes back.

D11. Does the bureau require a Montana-licensed PE seal, and on which documents?#

Decides: the bureau. Turns on: ARM 24.301.1205(3) defines "Engineer" but no live rule found in the research states when a seal is required. Blocks: PE scope, PE cost, and whether an out-of-state engineer can do any of it.

D12. Are data plates and unit identification still required?#

Decides: the bureau. Turns on: ARM 24.301.525 (data plate: model, serial number, date of completion, design load maximums) and .549 (manufacturer's serial number, insignia placement on the exterior wall adjacent to the rear or side exit) were both repealed with no visible successor. They may now live in ICC/MBI 1200 or 1205. Blocks: your production and labelling process, and section 10 of the recommended manual structure. Small, but it is a physical thing that has to be on the building.

D13. Panel dimensional tolerances and surface defect acceptance criteria#

Decides: you draft them with photographs, the PE stamps them, the third-party agency accepts them. Nobody else can, because no published source exists for this product. ICC/MBI 1200 §308.4 is titled "Tolerances for panelized system construction" and §803.1 puts on-site fit tolerances on the registered design professional, but neither gives numbers for a cellular concrete panel, and ACI 523.1R-06 is a cast-in-place guide. Blocks: the manual, directly. ICC/MBI 1205 §501.7 requires accept/reject criteria, and an inspection section with no accept/reject criteria and no frequency is the most commonly cited reason a manual gets sent back (04-quality-manual-requirements.md section 6).

It matters more here than in ordinary precast, because the cast face is the interior finish face of the building. The acceptance criteria are partly structural and partly cosmetic, and you want to agree them with the PE and the agency before the first customer does.

D14. Mix qualification#

Decides: a lab, on the lab's schedule, not yours. Turns on: AC157 §4.5.6.2 requires the mix verified before use with representative batching, equipment, methods and curing. standards-register.md currently says the strength at 35 pcf is unknown until C495 cylinders exist. Blocks: the concrete chapter of the manual, the PE's allowable stresses, and the density acceptance band that every dead load, every pick weight and the 33,366 lb transport figure in the model rests on.

This is the longest lead item on the whole critical path and it is unblocked today. The manual is a four to six week drafting job. The 28-day breaks and the shrinkage prisms are not compressible. Start the lab work first.

D15. Reciprocity and out-of-state sales#

Decides: the bureau chief, who holds the agreements under ARM 24.301.1235(2). Blocks: quoting anything outside Montana. Nothing inside Montana.

Worth knowing before you promise anything: a Montana insignia is worth nothing outside Montana. Washington requires its own L&I insignia before the unit leaves your factory. Idaho requires its own Division insignia unless there is a written signed reciprocal agreement. North Dakota runs through the Interstate Industrialized Buildings Commission compact and an IIBC label. Wyoming has no state modular programme that the research could find, which is NOT CONFIRMED and needs a call to the Wyoming State Fire Marshal before you quote a Wyoming job. Ask the reciprocity question in the same letter, but do not wait on it.

D16. Anything else Montana wants from the business itself#

Decides: the bureau, plus Montana business licensing. Blocks: being listed as an approved manufacturer. Cheap to ask, embarrassing to discover late. Contractor registration is the obvious candidate.

D17. IBC occupancy of the shower house: Group U or Group B?#

Decides: the code official at the first site, asked once and written on the drawings. Blocks: very little. At 250 square feet, allowable area and construction type are not constraints either way, accessibility applies either way, the energy path is commercial either way, and the ventilation rates do not change. The trade genuinely has no consensus on this. Ask once, write the answer on the drawing, and move on.

D18. Does the third-party agency review the manual before the bureau does?#

Decides: the agency you pick. Blocks: your drafting sequence. In North Carolina the third party reviews and stamps the manual first. ARM 24.301.1223(2) says the Montana bureau reviews and approves it. Either way, pick the agency before you start drafting, because they will tell you the format they want and they may want to see it first.

6. What you can do this week#

None of this is blocked on anything.

1. Send the bureau letter. bureau-questions.md is drafted and ready. It is free and it is the longest queue in the whole file.
2. Start the lab work. C796 foaming agent qualification and C495 cylinders at 7 and 28 days. Longest lead item on the path, and the manual and the PE both wait on it.
3. Buy the two standards. ICC/MBI 1200-2021 and ICC/MBI 1205-2021 from ICC. Everything downstream is written against them and you are working blind until you have them.
4. Phone the bureau on (406) 841-2056 and ask whether they have an internal quality manual checklist or a preferred format. One call, possibly saves a rejection round.
5. Get three third-party agency quotes, including travel per visit, and ask each whether they review the manual before the bureau and what format they want.
6. Decide the shower house delivery envelope. The range of snow and wind you intend to sell into. Nobody else can decide it and the PE cannot start without it.
7. Fix four wrong code citations in the engineering docs, which are wrong today in documents the PE will read: the plumbing code is UPC 2021, not the IPC (ARM 24.301.301); the electrical code is NEC 2020, not 2021 (ARM 24.301.401); the snow load hazard source is ASCE 7-22, not ASCE 7-16 (ARM 24.301.146(26) and 24.301.154); and the residential zone 6 ceiling U target is 0.026, not the model code's 0.024 (ARM 24.301.161). Free, and half an hour.
8. Add the janitorial sink and the towel dispenser or hand dryer to the shower house design. ARM 37.111.1216(1)(a) requires a janitorial sink in a campground service building and (1)(i) requires hand cleaner, disposable towels or hot air dryers and toilet tissue. Neither is in the items file. Cheap now, awkward after the floor panel is cast with its sleeves.
9. Buy the three reference books that have not been read: ACI 523.2R-96 (the only published document specifically about precast cellular concrete floor, roof and wall units at this density), PCI MNL-116-21, and a licensed copy of ACI 523.1R-06.
10. Check dli.mt.gov/rules and the Secretary of State's ARM register for the 28 August 2026 rulemaking, in parallel with asking the bureau. It may already be answered in public.

7. Where the research documents disagree#

The four documents were researched separately. They agree on every rule number, every fee figure, every deadline and the old-to-new rule mapping. Five places where they differ, with my call on each.

1. Is the house a factory-built building? This is the substantive one.

01-statute-and-rules.md section 8.1 reads the house as likely a factory-built building, residential model type: panels are cast in a factory, the finished structure is designed for a permanent foundation and is not readily movable once assembled, and ARM 24.301.1221(1) reaches "modular building components."

03-codes-and-classification.md section 3.2 reads the house as not a factory-built building: what leaves the plant is a panel, not a structure, and it carries no service connections, so it fails two of the four elements of MCA 50-60-101(9)(a) on the plain words. The wire and the plumbing go in on site in the open cavity. The finished house is site-built from manufactured components. But the panels are a "panelized system" under ICC/MBI 1200, which Montana adopted, so they are off-site construction regardless.

02-approval-process.md does not take a position but its cost arithmetic assumes the house goes through the program as "2 modules," which the product contradicts.

I believe 03 on the insignia and 01 on the application obligation, and I think they reconcile. 03 is right that nothing volumetric leaves the plant, so there is no "module," so there is no "unit" under ARM 24.301.1205(6), so the insignia rule at ARM 24.301.1241, which is written entirely around "units," does not obviously reach the finished house. But 01 is right that ARM 24.301.1221(1) says "Any manufacturer of modular buildings or modular building components shall apply to the bureau for plan review," that ARM 24.301.1205(2) defines components as exactly your wall, floor and roof panels, and that ARM 24.301.1237 speaks of "panelized system reviews" as something the bureau transmits. So a panel review path plainly exists in this program. The most likely truth is that the panel line is in the program and the finished house is not insignia-bearing. That is question 2 in the bureau letter and it is framed to get exactly that distinction answered.

2. The bureau's division, and which Helena address is the office.

02-approval-process.md says Business Standards Division and gives 301 South Park Ave., Floors 4 and 5. 01-statute-and-rules.md says the pages carry an Employment Standards Division header, gives 2705 Skyway Drive as the walk-in office, and flags the division name NOT CONFIRMED. Both readings come off DLI's own site. I believe neither until it is confirmed. The mailing address is the same in both, PO Box 200517, Helena MT 59620-0517, so use the PO Box, put no division name in a manual, and confirm before driving anywhere.

3. How many third-party agencies are approved.

01 and 02 both transcribe a table with 17 rows. 03 section 8 says 16 and 04 section 1.3 says 16. I believe 17, because the two documents that actually transcribed the table both got 17 rows and the other two report a count rather than a list. Immaterial either way: pull the live list off the bureau's page before you contract anyone, and note the page's own "last updated 1/28/26" stamp.

4. The wording of ARM 24.301.1207.

01 quotes the live rule as reaching "manufactured homes, mobile homes, and recreational vehicles" and explicitly notes the wording changed when .513 became .1207. 03 quotes it as "Mobile homes and recreational vehicles." I believe 01, because it did the old-versus-new comparison deliberately. It makes no difference to the conclusion: either way the rule closes the door on solving the shower house by calling it an RV or a park model.

5. The certified local jurisdiction list.

02 section 8 and 03 section 1.3 give overlapping but not identical lists, and 03 says DLI puts the total at 54 while neither list reaches that. Both documents flag their own list as a summary needing a check. Believe neither for a specific job. Pull the live page before you quote a site, because whether a site is inside a certified jurisdiction changes the snow load source and who writes the foundation permit.