The California Association of RV Parks and Campgrounds (CalARVC) released an update today (Nov. 5) on the push by various outdoor recreation organizations to show Congress support for H.R 5658, the “Recreational Vehicle Certainty Act of 2014” sponsored by Reps. Jackie Walorski, R-Ind., and Marlin Stutzman, R-Ind., to clarify the definition of RVs – and most relevant to campgrounds and RV parks – park model RVs.

So far the state that’s seen the most RV park and campground owners reach out to Congress is Florida, with 88 people sending 285 messages to representatives and senators. California was next, followed by Wisconsin, New Jersey and Texas.

In all, according to CalARVC, 655 campground and RV park owners nationwide have sent nearly 2,200 messages to 307 members of Congress.

“We urge the other three hundred CalARVC members to send their letters today,” CalARVC continued and quoted Deb Carter, executive director of the Maryland Association of Campgrounds “In Maryland, we are already having issues with processing titles to park model RVs. Even though the HUD ruling is not in effect until April, at least one of our Department of Motor Vehicle divisions is questioning how to title a unit with a porch manufactured on it. What I find amazing is how quickly this has become a ‘real world’ problem.”

As CalARVC continued in its message, “Not all of you have park models or park models with factory installed porches; however, you still need to make sure your voice is heard. Simply because you do not have park model RVs today does not mean you don’t want the ability to choose them in the future. Whenever a government agency overreaches, we need to be there to stop them in their tracks.”

Once the message is sent, CalARVC suggested, “Take the next step and visit his or her district office. Now that elections are over, your rep will be headed back to Washington. Try to see them before they leave. If you can’t see them, make an appointment with a staff member. The staff member will communicate your visit and your request to your Congressman.  ARVC has made talking points available to help you speak to the subject. Need more information, feel free to call Debbie Sipe at CalARVC, (530) 885-1624 or Jeff Sims at ARVC, (303) 681-0401 ext. 110. Either staff member can help clarify any details. “

CalARVC offered talking points on the issue, listed below:

Background

– In the early 1970s, Congress established a preemptive building code for manufactured housing. In that law it established a RV exemption that set the maximum size of an RV at no more than 320 square feet and a manufactured home at no less than 400 square feet.

– In the late 1970s the park model RV was developed. The early designs were under 400 square feet and greater than 320 square feet.

– There was a debate as to whether park models were house-like and thus should be regulated as housing. Ultimately, a 1980 law established a statutory definition for park models as less than 400 square feet and gave HUD authority to issue regulations.

– In 1982, HUD issued guidance in which it exempted large RVs (under 400 square feet) and established four definitional tests:

• On a single chassis.

• 400 square feet or less measured at the largest horizontal projections.

• Towable by a light-duty truck.

• Designed for seasonal or vacation use.

– Over time, porches began to be added to park models. The porches are added in addition to the 400 square feet of interior space. Today, about 85% of park models have porches.

HUD Action

– On Oct. 1, HUD issued a memorandum in which it stated that the RV industry had been misinterpreting HUD rules for many years. It stated that the porch area on a park model must be included in the calculation of the 400 square feet if the unit was to be classified as a park model RV.

– HUD claims that this is not a change in policy despite the fact that HUD officials consistently told industry officials that porches were not to be included in the calculation and that park models have had porches for many years.

– HUD did not grandfather existing park models.

Impact on Campgrounds

– With HUD’s action to deny RV status to existing park models with porches, there are about 20,000 units that face an uncertain future. If they are not RV’s, then:

• We fear that park models will not be permitted in campgrounds.

• They are structures that should have been built to a construction code. Will local officials condemn them?

• Many campground owners have purchased park models and rent them. Is their investment now worthless

• Many campgrounds have developed sites specifically for park models. This investment is now worthless.

Message
– HUD has taken this action without cause. HUD officials admit that there is not a health or safety problem.

– Co-sponsor HR 5658.