On Oct. 1, the U.S. Department of Housing and Urban Development’s (HUD) Office of Manufactured Housing Programs Administrator Pamela Danner issued a memorandum regarding the way in which park model RVs (PMRVs) are measured, effectively rolling back decades of precedent and threatening the future of the RV class.
According to a statement issued by the Recreation Vehicle Industry Association (RVIA), the memorandum asserts that HUD views the 400-square-foot park model RV limit as including porches, a common feature of PMRVs.
“HUD suggests that this interpretation is in keeping with past guidance from the department,” said Matt Wald, RVIA’s executive director of park model RVs. “For over 20 years, RV manufacturers, dealers, campgrounds and consumers operated in good faith under the guidance of the HUD Office of Manufactured Housing’s repeated assurances that, because they are exterior space, porches were not included in the square footage calculation of park model RVs. This position was consistently repeated to the industry and is clearly captured in minutes from a HUD meeting.”
According to Wald, RVIA yesterday confirmed with the former Office of Manufactured Housing Programs Administrator, Bill Matchneer, that when he was in charge of the office for 10 years it was HUD’s policy that porches on PMRV chassis were not counted toward the 400-square-foot limit for park model RVs.
The memorandum states that HUD will commence reviewing for compliance to this new interpretation on units that enter the first stage of production on or after April 1, 2015.
The RV and campground industries have not enjoyed solid legislative or regulatory certainty on these types of issues and have instead been forced to rely on a series of HUD administrators continuing to interpret rules as their predecessors had. Understanding this tenuous situation, RVIA has, since 2008, been working with HUD in attempts to clarify the definition of RVs under the RV exemption to make it crystal clear what an RV is and is not. While HUD chose not to provide that clarity, until this recent development, the industry was allowed to continue operating as it always had.
“As a consequence of this lack of clarity and certainty, Administrator Danner clearly felt authorized to shift HUD’s interpretation of regulations and guidance, creating a sudden change in policy that will have a significant negative impact on the RV industry as well as America’s campgrounds and especially our shared customers: the American camper,” added Wald. “This new interpretation of HUD policy, issued as a simple memorandum has proven just how vulnerable the RV industry is to the whims of HUD regulators.”
In response to HUD’s actions, RVIA, RVDA and ARVC and the entire RV and campground industries have come together to appeal to HUD Secretary Julian Castro to withdraw this memorandum and give Congress an opportunity to clarify, once and for all, a bright line between RVs and manufactured housing.
The issue has already gained traction in Congress, where Indiana Representatives Marlin Stutzman and Jackie Walorski recently introduced legislation (H.R. 5658) to do just that.
“Congressman Stutzman and Congresswoman Walorski are true champions for the RV industry,” said Wald. “Their bill would clearly define all RV types and establish clear lines between RVs and manufactured housing in a way that cannot be reinterpreted every time there is a personnel change at HUD.”
Wald said that the RV and campground industries will be calling on RV manufacturers, dealers, campground owners and consumer groups to push for enactment of the legislation as quickly as possible.