Campground and RV industry representatives failed to persuade the Department of Housing and Urban Development (HUD) to withdraw its plan to redefine park model RVs with factory built porches as manufactured homes, according to a news release from the National Association of RV Parks and Campgrounds (ARVC).
In an e-mail to ARVC and other industry partners summarizing the Oct. 22 meeting with HUD staff, Matt Wald of the Recreation Vehicle Industry Association (RVIA) said HUD officials were indifferent to campground and RV industry concerns about HUD’s reclassification of park model RVs, which it outlined in an Oct. 1 memorandum.
Maryland Association of Campgrounds Executive Director Deb Carter said HUD’s new interpretation of park models leaves campgrounds and campers in legal limbo with regard to park model RVs that were bought and installed under HUD’s previous park model guidelines.
While HUD might not take enforcement action against existing units, Carter said it was likely that local tax, zoning and building officials will. She asked HUD staff whether they had considered what would become of these units when it was time to renew insurance, registration, titling, or financing for these RVs now that the HUD memo says they are no longer RVs. She asked what she could tell a local tax authority who decided to change the tax classification of park models in her campground from RVs to housing based on the HUD memo.
HUD staff had no answer for any of these concerns, Wald said. “In fact,” he said, “it appeared to be the first time they had heard or even considered these unintended consequences of their action. And yet they still continued to insist that this memorandum would not be withdrawn, stating that it was their ‘statutory obligation to enforce the memorandum’s interpretation,’ regardless of the effect the memo would have on the campground industry.”
Speaking on behalf of park model RV manufacturers, Dick Grymonprez of Champion/Athens Park Homes asked what possible safety concerns triggered HUD to issue a memorandum that makes factory added park model porches illegal.
“HUD’s counsel conceded that the agency did not issue the memo out of a health or safety concern, but instead that it was ‘a purely legal distinction’ that HUD staff felt compelled to make and that as such it would be enforced no matter whether it is needed or not,” he said.
Wald told ARVC that industry participants left the meeting frustrated and felt that the only way they can protect park model RVs is to support HR 5658, which 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 two decades.
Park model RVs have previously been technically defined as recreational vehicles according to HUD, the American National Standards Institute (ANSI) A119.5 standard and a majority of states’ laws. This makes park model RVs exempt from property taxes. But the descriptions of park model RVs in the HUD code are not as clear as they could be and not every state clearly defines park models as a type of RV.