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Proposal based on recommendation from industry/consumer advisory committee

WASHINGTON – February 9, 2016 – (RealEstateRama) — The U.S. Department of Housing and Urban Development today (HUD) announced a proposed rule to exempt certain recreational vehicles from HUD’s Manufactured Housing Procedural and Enforcement Regulations.  HUD’s proposed rule seeks to revise the exemption for recreational vehicles that are not self-propelled and is based upon a recommendation from an advisory committee made up of manufactured housing producers, retailers, consumers and the general public. Read HUD’s proposed rule.

The Manufactured Housing Consensus Committee (MHCC) recommended that HUD define a recreational vehicle as one built on a vehicular structure, not certified as a manufactured home, designed only for recreational use and not as a primary residence or for permanent occupancy, and built and certified in accordance with either the National Fire Protection Association (NFPA) or American National Standards Institute (ANSI) consensus standards for recreational vehicles.

HUD is proposing to adopt the MHCC’s recommendation but modifying it to require certification with the updated ANSI standard, A119.5-15, and by including a requirement that units claiming this exemption prominently display a notice stating that the unit is designed only for recreational use, and not as a primary residence or permanent dwelling.  This notice reflects the intent of the MHCC in its recommendation to draw a clear distinction between the two products.

The Manufactured Housing Consensus Committee (MHCC) is a statutory Federal Advisory Committee body charged with providing recommendations to the Secretary on the revisions and interpretation of HUD’s manufactured home construction and safety standards and related procedural and enforcement regulations.


The National Manufactured Housing Construction and Safety Standards Act of 1974 authorized HUD to establish and amend the Federal Manufactured Home Construction and Safety Standards.  The Act as amended defines “manufactured home” as “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;…”

Over the intervening years, HUD sought to clarify and simplify this exemption.  In December of 2014, the MHCC recommended that HUD adopt language that more clearly distinguishes recreational vehicles and manufactured housing.

There are two methods for submitting comments to the proposed rule published today*:

1. By Mail.  Comments may be submitted by mail to the Regulations Division, Office of General Counsel, Department of Housing and Urban Development, 451 7th Street, SW, Room 10276, Washington, DC  20410-0500.

2. Electronic Submission of Comments.  Interested persons may submit comments electronically through the Federal eRulemaking Portal at  HUD strongly encourages commenters to submit comments electronically.  Electronic submission of comments allows the commenter maximum time to prepare and submit a comment, ensures timely receipt by HUD, and enables HUD to make them immediately available to the public.  Comments submitted electronically through the website can be viewed by other commenters and interested members of the public.  Commenters should follow the instructions provided on that site to submit comments electronically.

* All submissions must refer to Docket No. FR-5877-P-01 Manufactured Home Procedural and Enforcement Regulations; Revision of Exemption for Recreational Vehicles


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Brian Sullivan