By Greg Gerber
Editor, RV Daily Report
The RV and manufactured housing industries have been battling for years over the definition of a “recreation vehicle.” Today, the federal government jumped in with both feet to propose a new rule that could end the lifestyle for a million people who use RVs full-time to live, work and play.
The manufactured housing industry has been extremely jealous of the RV industry for a long time because RVs don’t have to be built to the same hyper-regulatory and expensive requirements as sticks-and-bricks homes. RVs, after all, are homes on wheels.
Manufactured homes are also built on frames with wheels. But, rather than seeking to exempt those homes from the same building requirements as traditional dig-a-hole-in-the-ground-and-erect-a-foundation homes, the MH industry whines that RVs should be built to the same standards as a three-story, tri-level home.
The RV industry has avoided HUD regulation for years by winking and claiming that recreation vehicles aren’t really designed for full-time use, but rather as places for people to live and sleep for a long weekend or a week or two of summer travel. You know, like when they’re recreating.
So, today, the federal government formalized that notion. The RV and MH industries bought into that and consumers are supposed to buy it, too.
But, the industry has also spent $100 million to promote RVs as “freedom” vehicles in that people can take their homes-on-wheels virtually anywhere. For generations, the RV industry has sold the dream of retiring and traveling all over the country to explore new cultures, historical sites and seeing everything America has to offer.
Here’s the rub. It’s impossible to “see America” unless you’re living in an RV full time.
For the RV industry to agree that a notice must be prominently displayed in every RV offered for sale stating “this unit is designed only for recreational use, and not as a primary residence or permanent dwelling,” is, when you think about it, an incredibly silly thing to say.
Does that rule apply to RVs sold by private owners? Will regulators see it that way?
How much time do people have to spend in an RV for it to be considered a “primary residence?” Because, without a sticks-and-bricks home to return to, full-time RVers consider their motorhome or fifth wheel to be their “primary residence.” There has to be a magical line somewhere that people cross.
If people use an RV all day, every day for a year, does it become their “primary residence?” What if they live in the vehicle all day, every day for just six months? That’s still using an RV full time during that period, which makes it the primary residence, doesn’t it? What about using it all day, every day for 90 days?
Can we get the RV Industry Association and the federal government to agree on a definition of “primary residence?” Because, without it, the RV industry has just inadvertently thrust a knife into the heart of the RV dream.
How so? Right now, thanks to some ridiculous banking regulations, it is almost impossible for full-time RVers to get a loan to finance the purchase of a recreation vehicle. Government regulations require that people getting loans for such purchases must have a permanent address. This new agreement reinforces that line of thinking.
So, if you are buying a living room, bedroom, bathroom and kitchen on wheels, banking rules require that the borrowers also have a living room, bedroom, bathroom and kitchen secured firmly to the ground before they can get a loan. No wonder bureaucrats want to legalize marijuana.
That rationale means people looking to travel the country full time must lie to bankers about the purpose of the loan.
“Yes, sir, we are only going to use this RV to visit the Jellystone Park up the road a few times a year. No, sir, we would never dream of living it in full-time. It’s way too small for us to do that. Can we have a loan, please?”
More importantly, saying an RV can’t be used as a “permanent residence” suggests that there is a planned obsolescence to the RV. Some argue that RVs are already intentionally built to be used a maximum of 500 nights before they’re trashed. The construction quality and service frequency of some brands lend credence to that claim.
Now, thanks to the proposed rule being adopted in cooperation with the RV industry, manufactured housing industry and the U.S. Department of Housing and Urban Development, banks are specifically being told that an RV is not designed for extended living.
Does that mean consumers will soon face additional scrutiny when applying for a $200,000 loan — which is more than the cost of a good size home in much of the country — to buy a vehicle in order to enjoy a comfortable home while they “see America?”
When the industry tells the world that its products are designed only for recreational use, and not as a primary residence or permanent dwelling,” it signals that there is a problem with the vehicles being sold.
Why can’t they be used as a “primary residence?” Is there a safety issue? Or a product quality issue?
A catalyst for discrimination
Perhaps interpreting this new rule comes down to necessity of use. Does a family living in an RV full time because they can’t afford a house or an apartment equate to a different situation than grandpa and grandma living in an RV full time as they tour the country “recreating” for a few years while looking for the ideal place to settle down?
Maybe it matters if the vehicle moves. So, living in an RV parked at the same spot for three years makes it a “permanent residence,” but living in the same RV for three years and moving to a different state every month is considered recreational use.
Chances are the industry would embrace one type of family and shun the other.
This whole issue puts the industry in a tough spot because RVers already battle the perception of being “trailer trash” and nobody likes to see RV parks overrun by dilapidated vehicles that haven’t moved in years. But, RV parks are also full of wholesome, fun-loving people of all ages with money to support themselves and keep their “recreation vehicles” in tip top condition as their permanent residence.
There are plenty of legitimate reasons as to why people would want to live and work in an RV full time. Here are a few:
- Highway construction workers or pipeline builders who must move to different locations every few weeks.
- People who race horses or show dogs and travel the country to do so.
- Medical professionals and RV technicians who follow the annual snowbird migration seeking work.
- Sales professionals moving from one show to another who don’t want to lug suitcases into a hotel every night.
- Journalists who travel the country reporting on the activities of various businesses within their industries.
- Parents who think it is better to teach kids about history and other cultures by experiencing it directly rather than watching a video in a crowded classroom.
- Missionaries or disaster relief workers who deliver needed supplies or assistance to distressed people and communities.
- Or, my favorite, people who think it’s really nobody’s @#$%& business where they chose to live or how they chose to work.
Now that government has an official definition of a recreation vehicle as being “a unit designed only for recreational use, and not as a primary residence or permanent dwelling,” it will be interesting to see what other state and federal regulators jump all over it.
This new definition waves a red flag in front of power hungry bureaucrats to heap more unnecessary regulation on companies supporting the RV lifestyle and people living the RV dream. For example:
- Must RV parks reject guests without a permanent residence to avoid “trailer trash?”
- Will service centers be told they can’t fix RVs unless the customer has a permanent residence? Otherwise the customer is using the vehicle in a way that was not intended by the manufacturer. Think of the warranty claims that could be denied on rationale that alone!
- Will parents be told they can no longer homeschool kids in an RV because the vehicles aren’t safe as a primary residence? But, those same vehicles are safe enough to use for week-long vacations.
Oh, what a tangled web we weave when trying to appease the insatiable appetites of career bureaucrats.
Perhaps there is a silver lining in all this nonsense. Maybe a whole new industry will crop up to create mobile “permanent residences” that are built tougher, and will last longer without breaking down every couple of months.
Instead of being designed to sleep a dozen people for a maximum of 20 days a year, they’ll be built to support the lifestyle of two or four people wherever they go for as long as they want to travel.
The only problem is that some other bureaucrat will probably rule those families won’t be allowed to use the homes for “recreation” because that’s not how they were designed to be used.