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The National Association of RV Parks & Campgrounds (ARVC) is urging Department of Housing and Urban Development (HUD) Secretary Julian Castro to withdraw a memo that redefines most of the nation’s existing park model RVs as manufactured housing.

ARVC President and CEO Paul Bambei has co-signed a letter to Secretary Castro with Recreation Vehicle Industry Association (RVIA) President Richard Coon and Recreation Vehicle Dealers Association (RVDA) President Phil Ingrassia in which they urged him to withdraw HUD’s regulatory interpretation memorandum until Congress has a chance to amend HUD law to protect the current status of park models.

Park model RVs have previously been technically defined as recreational vehicles according to the HUD, the American National Standards Institute (ANSI) A119.5 standard and a majority of states’ laws.

Park models have traditionally been defined as having a maximum of 400 square feet of living space, with factory-added porches being excluded from the 400-square-foot limitation.

But HUD issued a new regulatory interpretation memorandum Oct. 1 that requires factory-added porches to be included in the 400-square-foot living space calculation, effective April 1, 2015. Since most of the nation’s park model RVs have factory added porches, the HUD memorandum would effectively reclassify most existing park model RVs as manufactured homes, while requiring manufacturers to build smaller park model RVs after April 1.

“All this new interpretation does is disrupt an American manufacturing industry that is still rebounding from the Great Recession,” Bambei, Coon and Ingrassia wrote in their Oct. 2 letter to Secretary Castro, adding, “Park model RV owners could find their units condemned or forced to be removed from campgrounds by state or local officials. Campgrounds could be cited for allowing ‘non-RVs’ in their RV campgrounds.”

RVIA has worked with legislators to introduce legislation to clarify the status of park models and exempt them from the manufactured housing code.

HR 5658 was introduced in September by Republican Reps. Marlin Stutzman and Jackie Walorski of Indiana and Republican Rep. Sean Duffy of Wisconsin. The legislation, which is endorsed by ARVC and RVDA, would exempt park models of 400 square feet or less from the Manufactured Housing Construction and Safety Standards Act of 1974, which forms part of the HUD code. It would also protect the legal status of park models that have been placed in campgrounds during the past