RV Industry Effort to expand statutory Exemption – Status Report and Updates

MHARRA May 21, 2014 mark-up hearing by the House Appropriations Committee to consider amendments to the Fiscal Year 2015 Transportation, HUD and Related Agencies (THUD) appropriations bill, has concluded without the inclusion of any RV definition language that would further tamper with the federal manufactured housing law. Neither the omnibus “Manager’s Amendment” to the bill originally approved by the THUD appropriations subcommittee on May 6, 2014, nor subsequent amendments offered verbally during the mark-up session, addressed this RV definition issue.

Although the congressional process to pass a final 2015 HUD appropriations bill will continue in the House and the Senate — which is still developing its own 2015 HUD appropriations bill – and there will be further opportunities for the RV industry to still seek a definition change amendment, including on the floor of each house, the adoption of the 2015 THUD bill by the full Appropriations Committee, without the RV definition amendment, represents an important milestone for MHARR and HUD Code industry efforts to prevent such tampering with the HUD Code industry’s federal law.

Nevertheless, because of the continuing possibility of action on such an amendment, particularly now in the Senate, MHARR will continue to monitor developments very closely and industry members, as well as state associations, should continue to engage with their congressional representatives and Senators to make them aware of the HUD Code industry’s major concerns with any such definition amendment.

Having been successful, however, thus far, in slowing-down or blocking an RV definition amendment, MHARR extends its sincere thanks and gratitude to the HUD Code industry’s state associations, but particularly to the Mississippi, Alabama, Florida, Wisconsin and Maine state associations for their efforts to inform and educate Congress on this matter, as well as to manufactured home owners represented by the National Manufactured Home Owners Association (NMHOA).

As MHARR has emphasized all along, every time that this issue has been raised by the RV industry, it does not oppose a resolution of the legitimate concerns raised by the RV industry. But such a resolution cannot: (1) further undermine the federal manufactured housing law – as a housing law; (2) threaten the well-being of the HUD Code industry; or (3) ignore the major concerns of consumers.

MHARR, over a considerable period of time, has presented ideas and concepts to the RV industry for such a resolution of its legitimate concerns including — (1) deletion of any and all references to RVs in the federal manufactured housing law and related HUD regulations, or (2) an adjustment of the pertinent existing HUD regulations (that could use some updating in any event) through the HUD regulatory process. That said however, a proper solution does not lie in further tampering with the HUD Code industry’s federal housing law, which would be unacceptable to the HUD Code industry and consumers. Unfortunately, though, this issue will not go away until the entire manufactured housing industry makes it clear that the only proper resolution of this matter is through one of these two venues.

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