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(Update) Escapees Advocacy News 02/15/2016

Update 03/09/2016

Dear Escapees Members,

In an effort to keep you informed, here is another update on the proposed HUD rule entitled “Manufactured Home Procedural and Enforcement Regulations; Revision of Exemption for Recreational Vehicle.”
 
We firmly believe that HUD should not regulate the building or usage of recreational vehicles. In addition, the RV manufacturing industry believes that HUD should not be involved in the regulation of RVs.
 
Therefore, we posted a letter to HUD’s Website advocating for RV owners’ rights. If you would like to read our letter to HUD, please view it here.

As this proposed rule progresses through the Washington Forum, we will keep you informed of any changes.

Jim Koca
Advocacy Director


Dear Escapees Members,

We want to alert the membership of a proposed rule entitled “Manufactured Home Procedural and Enforcement Regulations; Revision of Exemption for Recreational Vehicle” published by the U.S. Department of Urban Affairs (HUD). We are making contact with all of the involved parties, financial institutions and HUD for more information on the proposed rule and will continue to monitor the process. For an overview of the issue, please read this joint statement from RVIA, RVDA and ARVC:  http://www.rvbusiness.com/2016/02/joint-statement-hud-move-critical-to-industry/

The complete proposed rule can be viewed at: https://federalregister.gov/a/2016-02387

In summary, this proposed rule would modify the current exemption for recreational vehicles in the Manufactured Home Procedural and Enforcement Regulations. Under the current exemption, questions have arisen regarding whether park model recreational vehicles are regulated by HUD’s manufactured home program. These park models are being produced with patio roofs, screened in porches, and other extensions that exceed the 400 square foot maximum exemption in the current regulations. Additionally, some of these models are being marketed as suitable for year round living.

HUD’s proposed rule would permit recreational vehicle manufactures to certify that a unit is exempted from HUD’s regulations. Specifically, HUD’s proposed rule would define a recreational vehicle as a factory build vehicular structure, not certified as a manufactured home, designed only for recreational use and not as a primary residence or for permanent occupancy, and built and certified in accordance with either the National Fire Protection Association (NFPA) 1192-2015, Standard for Recreational Vehicles, or the American National Standards Institute (ANSI) A119.5-15, Recreational Park Trailer Standard.

In addition, to provide consumers notice regarding the manufacturing standards used to construct the unit, HUD’s rule would require that units claiming the exemption display a notice that identifies the standards used to construct the unit and states that the unit is designed only for recreational use, and not as a primary residence or permanent dwelling.

Escapees RV Club takes RV Advocacy very seriously and we will continue to keep you apprised. 

Jim Koca
Advocacy Director

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