The attached self-explanatory communication to Recreational Vehicle Industry Association (RVIA) President Richard Coon is for your review and information.

As was decided at the MHARR Board of Directors meeting on November 7, 2014, MHARR has prepared proposed amendments for consideration by the Manufactured Housing Consensus Committee (MHCC) and HUD to create a function-based firewall of separation between HUD-regulated manufactured homes and recreational vehicles (RVs) in the HUD standards and Procedural and Enforcement Regulations.

Through this communication, MHARR is advising RVIA of its intent to address this matter on a regulatory basis – as urged by the Senate Appropriations Committee in its report on the 2015 HUD appropriations bill – and inviting RVIA to participate in this process involving HUD and all affected stakeholders.

As MHARR’s communication indicates, a definitive regulatory approach to the issue of creating a strong firewall between regulated manufactured homes and non-regulated, non-residential RVs would be more workable and would carry fewer potential pitfalls than further amendments to the federal law, where additional RV language in a housing law could have unintended consequences and lay the groundwork for even more problematic language and interpretation disputes in the future as technology evolves.

 

communication to Recreational Vehicle Industry Association (RVIA) President Richard Coon(pdf)