You may or may not have been following the recent proposed HUD rule change concerning RV definitions. It has been in the news a lot and in fact if you go to www.RVDailyReport.com and search for “HUD Rule” you can get a flavor for all sides of this issue. We provided a link below to the actual proposed rule. You can find reason to argue several sides to this issue, whether you are a manufacturer, dealer, campground or end user.
The TACO board thinks this rule has the potential to trump many state laws / definitions that we have worked hard to put on the books in Texas. Furthermore, we generally think that if you give the federal government the right to control how an RV is classified or used then by extension they have the right to claim where and how that use occurs – namely campgrounds. We saw it in the George Toon transvestite case and this rule wasn’t on the books, imagine if HUD could claim they had the right to go after a park owner because the RV in question falls under HUD rule.
We were surprised by ARVC’s support, but we think national associations view our industry more at a ‘perfect world’ level than a real world level. For example, it would be great if every park were full of daily and weekly RVers who paid the highest rates and drove compact motorhomes.
Unfortunately, the rule of thumb in Texas for many parks is – the ‘monthlies’ pay the bills and the dailies provide a modest profit, while some parks are exclusively seasonal or monthly stays. Kill the monthlies and what are you left with? If you kill monthly workers, seasonal travelers and full timers – what are left with? We are afraid that this is where this rule is heading because even the rule itself brings up controlling other forms of RVs other than just park models and really only exempts motorhomes from HUD control. Could the campground industry live on motorhome travel alone?
Our legislative consultant, Ron Hinkle, along with the board, have studied this issue and read all viewpoints. For those who think the feds should butt out of the RV industry and by extension the campground industry in Texas, we would propose that you send this letter or the communication of your choice to your state and federal elected officials. You can find out who your local and federal elected officials are, along with their contact information, at http://www.fyi.legis.state.tx.us/Home.aspx.
What we need from you is – read the enclosed letter and, if it meets your approval put it on your letterhead and send it or email it to your state and federal representatives. Separately, and more urgently, the deadline to provide official commentary straight to HUD is Monday, April 11th. If you visit https://www.federalregister.gov/ and enter 2016-02387 in the Search Documents box in the top right-hand corner, you can find the space to leave your commentary. Register for the TACO Spring Meeting by April 11th to take advantage of the extended early-bird special and to discuss this critical matter.