The National Association of RV Parks & Campgrounds (ARVC) is supporting legislation sponsored by the Recreation Vehicle Industry Association (RVIA) that would clarify the definition of a manufactured home to exclude park model RVs.
ARVC reported in a news releases that the legislation, HR 5658, was introduced in September by Republican Reps. Marlin Stutzman and Jackie Walorski of Indiana and Republican Rep. Sean Duffy of Wisconsin. It 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.
Park model RVs are technically defined as recreational vehicles, according to the U.S. Department of Housing and Urban Development (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.
As a result, ARVC and RVIA representatives spend a considerable amount of time on the phone each week with municipalities across the country that question whether park model RVs should be subject to property taxes. ARVC maintains that park model RVs should only be taxed as personal property.
HUD is also revisiting its interpretation of some of its enforcement positions with regard to the line between RVs and manufactured housing, according to Matt Wald, RVIA’s executive director for park model RVs.
“It is RVIA’s position that RVs, built for recreational, seasonal and camping use, belong in campgrounds or other recreational areas while manufactured housing, built as permanent residences, belongs in housing communities,” Wald said.
While the distinction between park model RVs and manufactured housing is well understood by those with intimate knowledge of HUD law, the language of existing law is not clear enough for lenders, zoning and tax officials, who often try to tax park models as manufactured housing, Wald said.
“RV lenders are concerned that, given new banking regulations, they need more clarity as to where the line between RVs and manufactured housing is drawn if they are going to continue to make consumer loans for some types of RVs,” Wald said.
ARVC and RVIA are also collaborating in an effort to identify states where legislation can be developed specifically to exempt park models from property taxes. Such legislation became law in Utah last year, for example.
Jeff Sims, ARVC’s director of state relations and program advocacy, said he often provides park operators with talking points and code sections they can share with city officials to clarify their questions about park models. In others, Sims reaches out to city officials directly to inform them that park models are a type of RV.
Sometimes, however, private park operators bring problems on themselves when they fail to register their park models with their state’s Department of Motor Vehicles. While they may think they are saving money by avoiding the DMV registration fee, the tactic can backfire on them later if local officials question whether their park model is indeed a type of vehicle and they do not have a DMV registration form to prove that it is.
Private park operators can also create problems for themselves and for the RV and outdoor hospitality industries in general if they allow people to live in park model RVs on a permanent basis. Park model RVs are designed and legally permitted for seasonal or part-time use.