RV industry scores a victory with revised federal rules

New language in federal rules distinguishes larger, park model RVs from manufactured housing

Posted on Feb. 13, 2016 at 4:00 a.m.

ELKHART — A muddied definition of recreational vehicles that alarmed the industry two years ago — classifying park model RVs as permanent rather than temporary housing — is being cleaned up in a revised U.S. Department of Housing and Urban Development rule. 

The proposed rule, published this week, is intended to draw a bright and distinct line between large park model RVs and manufactured housing. 

“What we have now is a very complex set of criteria that is ill-defined,” explained Matt Wald, executive director of park model RVs at the Recreational Vehicle Industry Association. “These new rules would allow manufacturers, campground owners, RV owners and dealers to know what exactly a park model RV is.”

In a joint statement, RVIA, The National RV Dealers Association and the National Association of RV Parks & Campgrounds said that without this new rule change, the RV lifestyle could be “regulated out of existence.”

“This proposed rule provides a critical solution to the regulatory uncertainty that has plagued RV manufacturers, dealers and campgrounds for decades,” the statement said.

The issue sounded alarms within the RV industry in October 2014, when HUD issued a memorandum that put park model RVs in the same category as manufactured housing. HUD’s 2014 memo stated that attached porches should be included in the square footage calculation for park model RVs.  

In order to be considered an RV, the structure would have had to be 400 square feet or less, according to a 1982 HUD definition.


Adding in porches would push park model RVs past the 400-square-foot maximum that exempts RVs from being classified and taxed as manufactured housing, creating a scenario that opened up some campgrounds to potential liability.

“If the RV went past the allowed square footage for a park model RV, then it would have been classified a manufactured home and these campgrounds could have had illegal housing on their sites,” Wald said. 

Industry officials also said the revisions would change both the types of loans needed for financing RVs and how the units are taxed once they’re owned.

The memo also raised concerns that other large RVs, such as fifth-wheels, could be lumped into the manufactured housing category.  

Eventually, an advisory panel to HUD came up with a consensus proposal to define and exempt RVs from manufactured housing standards based on the fact that they are built to the industry standards for RVs.

What the proposed rule will change:

The proposed rule gives RV manufacturers the critical regulatory clarity and certainty they have long sought: so long as they build to the nationally-recognized RV standards, the modern RVs they are building do not and will not fall under HUD’s jurisdiction.

The proposed rule gives RV dealers additional critical regulatory clarity they have long sought: the proper paperwork, forms, and disclosures the RV dealer needs to provide during a sales transaction are based on the design intent of the recreational vehicle.

The proposed rule also gives RV campgrounds the critical regulatory clarity and certainty that they have long sought: in many cases the business license for RV parks and campgrounds only allows them to accommodate recreational vehicles, not manufactured homes, so under the proposed rule they would be able to accommodate any unit that is certified to an RV standard without running afoul of local regulations.

HUD’s latest revision to the definition of RVs, which is open for comment through April 11, restores park model RVs to temporary housing status. 

Park model RVs most often are used in campgrounds and may be owned by the campground and rented to guests, or brought in and used exclusively by RV owners on a site rented or leased from the campground. Park model RVs are up to 15 feet wide and 36 feet long with a peaked and shingled or metal roof.

A park model RV offers the comforts of home for individuals who may travel to one place for a few months a year, but are not intended to be a long-term residence.


A number of area lawmakers praised the rule change, saying it was a step in the right direction. 

U.S. Rep. Jackie Walorski said she is thrilled with HUD’s proposed revision and pleased the the agency is backing the RV industry. Walorski co-sponsored the Recreational Vehicle Certainty Act of 2014 in September 2014, a month before the controversial HUD memo. The act addresses many of the same issues as HUD’s proposed revision fixes.  

“This is just another example of Hoosier common sense coming to D.C. and fixing a problem,” Walorski told The Truth. “This proposal will give a sense of relief to manufacturers and protect jobs for Hoosier workers.”

U.S. Sens. Dan Coats and Joe Donnelly had previously included language in a Senate Appropriations bill in July 2014 urging HUD to update this definition.

“HUD’s RV regulations date back to 1982,” said Coats. “Since that time, the industry has made dramatic improvements to its vehicles. An update to these regulations has been long overdue, and HUD has taken a positive step forward by proposing a new rule.”

Under HUD’s proposed rule, each park model RV must be marked with a seal that states it meets park model RV standards and is intended for temporary housing.

“No one wants people living long term in RVs,” Wald said. “That is not good for the manufactured housing industry or the RV industry.” 

Wald said HUD still has questions before it will finalize the proposal, and the RVIA is working to answer those questions as quickly as possible.

“We all want to be on the same page,” he said. 

Follow Ben Quiggle on Twitter @BenQuiggle


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