On 2/13/2016 at 4:03 AM, Zulu said:

 

RVs are covered by NFPA 1192-15 and ANSI A119.5-09. I believe that's it for RVIA compliance.

 

I have a 2011 edition of NFPA 1192 and it looks like a set of minimum requirements. For example, if you have a propane-fueled fridge, there are venting requirements. I didn't find anything saying saying you could not have a residential fridge.

 

However, I don't have the latest version of NFPA 1192 or the ANSI standard.

 

What, specifically, in these standards precludes innovation?

Well, for example, use of any cooktop NOT approved by RVIA will cause failure during an RVIA inspection. That is the specific reason New Horizons stopped using Verona cooktops. Just as a minor example.

Of course, you do not have to have an RVIA compliant coach. Mine is not, and it does not have an RVIA sticker. But if that then makes it fall under HUD guidelines what is a manufacturer to do?

  On 2/12/2016 at 10:48 PM, Jack Mayer said:

Most custom RVs utilize appliances and other fixtures not "certified" under RVIA regulations. Use of those residential fixtures - that ARE certified under other regulatory agencies for use in homes, ships or planes - precludes the builder from obtaining an RVIA certification (sticker) for the unit. Thus the unit does not meet the definition of an RV (it does not meet the "standards" mentioned in the regulation). It thus defaults to be a HUD regulated trailer.

Remember what RVIA stands for. It is the organization of RV manufacturers and as such it's purpose is mostly to protect their own members. They set standards in an effort to keep government regulations out and have had great success in delaying the implementation of federal highway safety standards to the RV industry. They self regulate in an effort to prevent government entry into their industry and while I have empathy for that practice, they do not always have the best interest of the customers in mind and they tend to protect their members from competition from nonmember companies. All of us form groups mostly to protect ourselves and the RV builders are no different. Protectionism can sometimes inhibit innovation.

I didn't see anything in the HUD proposal that requires RVIA certification and labeling, only that the RV meets the appropriate NFPA and ANSI minimum standards. Did I miss that?

  On 2/13/2016 at 11:29 PM, Jack Mayer said:

Well, for example, use of any cooktop NOT approved by RVIA will cause failure during an RVIA inspection. That is the specific reason New Horizons stopped using Verona cooktops. Just as a minor example.

 

Of course, you do not have to have an RVIA compliant coach. Mine is not, and it does not have an RVIA sticker. But if that then makes it fall under HUD guidelines what is a manufacturer to do?

So what is it about the Verona cooktops that causes them to fail? And has New Horizon challenged RVIA on this item? And where in the HUD regulations does it say that RVs must have a RVIA sticker, because I sure missed that.

  On 2/14/2016 at 12:58 AM, Barbaraok said:

 

So what is it about the Verona cooktops that causes them to fail? And has New Horizon challenged RVIA on this item? And where in the HUD regulations does it say that RVs must have a RVIA sticker, because I sure missed that.

The way I read the activity going on is that if you do not fall into the proposed standards then you by default fall into the HUD requirements. Since HUD seems to be the blanket coverage organization and the "escape" from that is the RV standards (and modular housing). So if you are not an RV then you are covered by HUD, assuming the trailer falls into he category HUD covers....and all trailers seem to - other than those "exempted" as RVs.

It is an interesting issue....I'm glad they are doing things to exempt "RV's", and I'm certainly not arguing they should not. But as an example, my trailer does not seem to be an "RV" by a cursory reading of their requirements. It has no RVIA sticker, it is larger than the RV "standards", and it certainly falls into the HUD area. I'm not proposing a solution, only saying that things that a "normal person" would consider to be an RV may not be judged as such by regulation.

It appears to me that the only change being made is a clearer distinction between park model RV's and manufactured housing. HUD has clearly stated that 5th wheels are exempt RV's for instance.

From the OP's Federal Register link:

"Subsequently, HUD also discovered that some Fifth Wheel Travel Trailers could also fall within HUD regulations. A Fifth-Wheel Travel Trailer is a towable recreational vehicle mounted on wheels and designed to be towed by a motorized vehicle by means of a towing mechanism that is mounted above or forward of the tow vehicle's rear axle. However, HUD has not exercised regulatory oversight over Fifth Wheel Travel Trailers and considered them as falling within the regulatory exemption." (emphasis added)

I think we may be overlooking the fact that the RVIA created ANSI A119.5 Standard only covers PMRV's (park models), and can pretty much be ignored for this discussion.

ANSI A119.5 Recreational Park Trailer Standard - Scope

NFPA 1192 and the applicable NHTSA requirements apply to our readily mobile RV's. I can find nothing in the related RVIA standards about certifying individual appliance brands or models.

After reading the RVIA press release, which was linked to in the email issued by Escapees, I agree with those, including the RVIA that it heads off a confrontation between HUD and parts of the RV industry. I am not sure of the contention of if you are not certified as an RV then you are automatically a manufactured home.

What it doesn't do is acknowledge the 500 lb gorilla sitting and snorting over in the corner of the room. And that is those individuals(like lots of us) who are without a doubt living full time and using as a permanent residence a structure clearly defined as an RV, which by the standards are not designed or intended for that purpose. The RV industry routinely points that out, and then is perfectly happy to sell is units that are clearly marketed as "full time units" against the caution in the fine print.

We are still in limbo on that one, and at the mercy of state and local statutes. This issue is running absolutely parallel to the "Tiny House Movement". Their needs and desires overlap ours in many ways. If our organization wants to work towards an acceptance of "non traditional housing" unifying with the Tiny House Movement might prove beneficial.

In the meantime, the clarifying of definitions, HUD vs RV industry seems to be a chance for many legal beagles to fatten the hours charged, and then go out and buy an RV, a big one.

One thing the RVIA and the story is failing entirely to mention is the real reason this matters so much to them.. Not the building codes/standards, which are rather insignificant in difference, but instead the issue's heavy relation to property taxes. Or rather the ability of permanent, non-moving RV dwellers to NOT pay property taxes at all.

Park models are specifically designed right up to the limits, essentially to be a way to sell the (smaller) equivalent to manufactured homes, but by calling park models "RVs", it allows discussion around whether its a permanent structure, requiring property taxes to be paid or not.
Especially in states like Texas, with huge property taxes.. Many people living permanently in park-models or fifth-wheels (and never moving) very specifically do so because it saves them $$ thousands every year in property taxes.

Counties (including I believe Polk County, of Escapees fame) have tried before to deem especially park-models (with permanent utility connections) as permanent structures, and hence liable for property tax payments. With varied luck.

If some RVs (especially Park models) suddenly under HUD fall into the Mobile Home category, it will

1. Likely immediately make them liable for standard property taxes,
2. Make some "RV Parks" with many permanent residents fall further into the Mobile Home park category, which can have heavy implications in some areas.
3. Make the segment of RVIA creating semi- or fully-permanent "RVs" (park-models especially) loose sales.

If that happens, the RV industry will lose a significant segment of their customers.. Assuming prices on park-model "RVs" to be approximately the same as an equivalent mobile home to buy, and both of them suddenly liable for property taxes, why would anyone living stationary then buy a park model from the RV industry?? They might as well buy a mobile home from any other mobile home manufacturer. Clear competition for that RVIA segment. So a dividing line that need some clear definition, but not one that will necessarily make the "RV manufacturer" industry happy.
Hence the big push from RVIA and similar.. Not because its important to real RVers (on the move), but because its important to permanent dwellers, the main customer segment for these structures.

As far as advocacy goes, it might raise the question of who the Escapees should advocate for. Whether this is a discussion to get involved in. Less of an RVer discussion, than a "protect the park model industry from property taxes".

Remember the term "RV": RECREATIONAL Vehicle.. As in on the move, at least seasonally... Whether in constant travel mode or as snow birds moving maybe only a few times a year, but NOT sitting still permanently, living in an RV only because that avoids paying property taxes on their living structure.

You can usually clearly recognize the latter category, and I see it many times.. The outside furniture, grills, parasols, and other objects are not designed for travel at all.. Not collapsible, heavy, purchased at the local Home store. Residences movable only by calling in a moving truck; not by simply stowing a few objects in the RV and moving on. Also frequently recognized in parks I visit by the fact that there is no vehicle, able to move the RV, present at all.. Someone with for example a Park Model or a Fifthwheel, but no ownership of a truck that could ever move that home anywhere..

Also why some (real?) RV parks in their rules state that at all times, there must be a vehicle present capable of hauling that RV out.. (As in "Don't have your parents haul in their old RV and make this your permanent home. )

You also see the same in some of the "RV" Facebook groups... If you look at the profiles of people asking questions, many of them have never actually RVed (moved around) in their lives. They just happen to live in a Fifth-wheel or trailer.
Groups such as "Fulltime RVers" over time seem to move to be largely populated by (100%) permanent dwellers, and the discussion around "what is a real full-time RVer" have come up multiple times.

Not all states have the same tax structure when it comes to manufactured houses vs S&B. So the HUD determination doesn't determine tax structures, that is up to the states. And some states like AZ and Washington already tax park models as personal property. In fact we pay personal property taxes on our park model to Maricopa County each year. So a change in HUD determination would have no affect on us. You can't use one state as an example for all states.

In fact, I'm having a hard time figuring out what your rationale for the above treatise might be? You seem to be angry about something, but not sure what it is.

Barb