(Editor’s Note: this document and attachment was sent to state association executives, and was provided to MHProNews by MHI with their expressed, written permission to republish.)

TO:                   State Association Executives

FROM:              Dick Jennison, President

Jason Boehlert, Senior Vice President, Government Affairs

Jenny Hodge, Vice President, National Communities Council

Lois Starkey, Vice President, Regulatory Affairs

MHI has been asked by Members of the House and Senate to comment on RVIA’s proposal regarding park models and recreational vehicles.

As you know, this has been an issue of debate for a number of years.  MHI has hosted several conference calls with State Association Executives and has considered the issue in the Manufactured Housing Division and Technical Activities Committee.

MHI’s supports RVIA’s objective to make it clear that RVs are not “manufactured homes”.  MHI is on record as opposing any language that would not limit the size of Park Models and RVs.   At the request of the Manufacturers Division of MHI, this past February  RVIA presented its views on the issue and again asked MHI to support a clarification of the definition of manufactured housing to specifically exclude all types of recreational vehicles.

The Board did set clear policy on this issue in 2011, which MHI has adhered to in this process. Both the Technical Activities Committee and the Manufacturers received another briefing at the February 2014 MHI meeting.  The TAC committee considered the proposed RVIA language, and agreed that it did address the concerns raised by the MHI Board in 2011.  MHI plans to bring the issue before the Board again at the June meeting, and anticipates that all those interested and concerned will have a chance to provide input.

MHI has suggested a clarification (in red) to explicitly define RVs for temporary, recreational use.  We have also suggested that the “permanent chassis” requirement be deleted in the definition of manufactured home.  Please see the proposed language below.

MHI believes that the language will provide more clarity to consumers, regulators, and the industry to ensure that recreational vehicles are regulated as such.

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Proposed Language for Adoption:

(6) “manufactured home” means a structure, transportable in one or more sections, which, in the traveling mode, is eight body feet or more in width or forty body feet or more in length, or, when erected on site, is three hundred twenty or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained therein; except that such term shall include any structure which meets all the requirements of this paragraph except the size requirements and with respect to which the manufacturer voluntarily files a certification required by the Secretary and complies with the standards established under this chapter; and except that such term shall not include any self-propelled recreational vehicle, which is designed as temporary living quarters for recreational, camping, travel or seasonal use and built in compliance with consensus standards for such products, including (i) a motorhome or recreational vehicle trailer that either has its own motive power or is towed by another vehicle without a special highway use permit and is regulated by the National Highway Traffic Safety Administration as a vehicle or (ii) a park model RV that has a gross area of not greater than 400 square feet based on the exterior dimensions of the unit measured at the largest horizontal projections in the setup mode, including all floor space that has a ceiling height of more than 5 feet.

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The attached document includes the MHI Board resolution. 

 

Clayton Homes’ Keith Holdbrooks, Deer Valley Homebuilders’ (DVLY) Chet Murphree Honored