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HUD definition of RV going to make it difficult to full time..


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Gregg Fore, president of Dicor, was on the committee that drafted the new definition. I found his take on the reasoning quite interesting and enlightening: "Fore clarifies reasons behind HUD RV definition"

Dutch
2001 GBM Landau 34' Class A
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2011 Toyota RAV4 4WD/Remco pump
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Not all states have the same tax structure when it comes to manufactured houses vs S&B. So the HUD determination doesn't determine tax structures, that is up to the states. And some states like AZ and Washington already tax park models as personal property. In fact we pay personal property taxes on our park model to Maricopa County each year. So a change in HUD determination would have no affect on us. You can't use one state as an example for all states.

 

The HUD determination was whether to include external structures, such as covered porches, sun-rooms, ... into the sq ft of the "home".. Most tax authorities follow HUD definitions on the 400 sqft limitation and would love it to see the higher value.

True.. Not all states.. And some states split between Personal Property Tax, and Real Estate (property) Tax, depending on registration type (vehicle or Real Estate). Virginia is one, I think. I am for this discussion mainly talking about Real Estate property taxes. Compared to vehicle taxes, its a different revenue stream for the counties.

Texas for example do not tax normal personal property taxes, but has an enormous Real Estate property tax compared to other states (but no income tax). About 80% of Real Estate taxes goes to the school districts.

If property taxes were to be added to all the Park models in Livingston for example, that would both severely change costs and probably also reclassify Escapees headquarters as a mobile-home park.

Notice, that when I say high taxes in Texas, I am referring to my yearly old S&B taxes in Texas being well into 5-figures/year.. Not a mere couple hundred $$/year like in some states.

 

When I lived in South Carolina on the other hand, they taxed personal property, including all vehicles. A Motorhome/RV registered in states with personal property taxes can be very expensive to drive.

 

Arizona stand out in that it has an immense amount of "park model" manufactured homes, with many Snowbird-parks and 55+ (RV-)parks listing as having 75-80% park-models across the park.

Hence Arizona has already make a point of property taxing any semi-permanent (normally unlicensed) structure. A change they specifically introduced in a State Bill around the 2010/2011 time-frame, I believe.

 

Their definition of what constitutes a taxable unit also differ somewhat from many other states/areas. As in including all "factory built structures". Independent of HUD definitions. As it states:

"The Arizona Department of Revenue acknowledges those definitions provided by A.R.S. § 41-2142 as current terminology used in the manufactured housing industry, but maintains its general use of the term "mobile home" for property tax purposes. Mobile homes and other factory-built structures are subject to assessment for property taxes, including manufactured housing, unlicensed recreational travel trailers and fifth-wheels, mobile offices, and park models."

Notice, that Arizona even include unlicensed Fifth Wheels and Travel-trailers in their definition of factory-built housing.

Generally in Arizona, "Park Model" regulation switch on the 400 sq ft HUD limit.. Under 400 sqft is there titled/taxed by the Motor Vehicle office, Over 400 sqft is done as residences (Real Estate).. Hence the difficulties when and if one started counting all the sun-rooms and other surrounding structures people add to these Park Models. Similar problem to what Texas is having. A 400 sqft "Park Model" easily grows to several times the 400 sqft limit if all the external structures are added in. In Texas, they even tried to distinguish based on whether a unit had permanent Utility connections or not.

 

BTW.. This is not a "manufactured houses" versus "S&B" thing.. Mostly states have moved to view a full-size Mobile Home (not RV) as an S&B home and is assessed Real Estate property taxes like an S&B. (Again.. Not all.. Virgina is one place I think does otherwise.)

 

My rationale? I personally could not care less about which kind of "RV" others choose..

Merely pointing out, that there is more to the RV industry's opposition to HUD specs, than merely building standards. As pointed out in the link Dutch_12078 added, its about classification.

And local impacts, such as census counts, school allocations, AND property taxes. Probably even local voting rights, as we are seeing in South Dakota right now, and as the several year law-suit between Polk County and Escapees back in 2002 showed.

 

Hence the RV industry's significant interest in staying away from landing in HUD space, when it comes to park models. Deer in the head-lights thing. :-)

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Gregg Fore, president of Dicor, was on the committee that drafted the new definition. I found his take on the reasoning quite interesting and enlightening: "Fore clarifies reasons behind HUD RV definition"

 

That IS a very interesting and enlightening write-up.. Quite a bit better than the official "combined statement" released by the RV industry.

He also specifically mention some of the other local state/county impacts of an unclear classification.

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Gregg Fore, president of Dicor, was on the committee that drafted the new definition. I found his take on the reasoning quite interesting and enlightening: "Fore clarifies reasons behind HUD RV definition"

 

 

Mmmmm . . . this is Gregg Fore's reasoning as told by Greg Gerber, RV Daily Report editor.

 

I've only read two articles by Mr Gerber, but in each one it seems as soon as the word "government" is mentioned, the wailing and gnashing of teeth begins.

 

Mr Gerber uses a tortured logic to explain his case that the new HUD regulation is precursor to the Four Horseman. For instance, Mr Gerber cites this example as evidence of the bad mojoness of the RVIA/HUD cabal (BTW, for "full timers" substitute "Mr Gerber")"

 

. . . full-timers are not convinced that the new definition can’t be used by overzealous bureaucrats to enforce the definition in a way the RV industry, manufactured housing industry or HUD ever imagined.

 

For example, full-time RVers who travel the country with their children are fearful that a child protective services agency will latch on to the new definition that an RV isn’t designed as a permanent residence as a justification to remove children from the home.

 

Right.

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Mmmmm . . . this is Gregg Fore's reasoning as told by Greg Gerber, RV Daily Report editor.

 

 

I didn't find it difficult at all to separate Gerbers editorial comments from Fore's direct quotes. I expect Fore would speak up if the quotes attributed to him were not correct.

Dutch
2001 GBM Landau 34' Class A
F-53 Chassis, Triton V10, TST TPMS
2011 Toyota RAV4 4WD/Remco pump
ReadyBrute Elite tow bar/brake system

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Well, for example, use of any cooktop NOT approved by RVIA will cause failure during an RVIA inspection. That is the specific reason New Horizons stopped using Verona cooktops. Just as a minor example.

 

Of course, you do not have to have an RVIA compliant coach. Mine is not, and it does not have an RVIA sticker. But if that then makes it fall under HUD guidelines what is a manufacturer to do?

 

The cooktop issue falls under NFPA 1192 5.4.1--fuel burning appliances have to be listed for use in an RV. An electric cooktop or electric-only refrigerator need not meet any RV-specific requirements--so long as it isn't a low-voltage appliance. Seems odd--a propane refrigerator and a 12V DC "marine" refrigerator would have to be listed for use in an RV. But any refrigerator you can get at Home Depot would meet the standard.

 

Where the RVIA thing gets a little more interesting is that RVIA requires that any of it's manufacturers build all units to RVIA standards--which they don't appear to be aggressively monitoring/enforcing--and there are some jurisdictions that mandate RVIA compliance during construction as a matter of law (e.g. Oregon).

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  • 3 weeks later...

I can't help but wonder if the homeless issues in Seattle area are an example of why HUD is getting involved in RVs, This winter I have encountered a new experience in state parks in Washington as well. Besides the RVs parked on streets in Seattle that is creating discussion (some drug and sanitations issues with these areas but some employed fulltime and choosing this lifestyle to save money), I am finding tiny homes on wheels that are self constructed which travel max days at one park, move to another and max days back again at the first park.

 

Hard to distinguish people by the reason they are choosing to live in an RV. For those not familiar with the RV lifestyle I am sure they may not see much difference other than maybe by the price and look of our RVs.

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  • 3 months later...

Hello,

 

Lori from Escapees just published an article on the subject:

https://escapees.com/articles-and-blogs?view=entry&id=1439

 

Cheers,

--

Vall.

 

My take is that Lori's article is more about the Escapees advocacy program as a whole and how we as members can help than it is about the overblown HUD definition issue.

Dutch
2001 GBM Landau 34' Class A
F-53 Chassis, Triton V10, TST TPMS
2011 Toyota RAV4 4WD/Remco pump
ReadyBrute Elite tow bar/brake system

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My take is that Lori's article is more about the Escapees advocacy program as a whole and how we as members can help than it is about the overblown HUD definition issue.

Not sure what article you mean, but the link leads to one by Shawn Loring, attorney and a member of the management team. Having just read the article again, I really see nothing there which is not accurate and could be documented.

Good travelin !...............Kirk

Full-time 11+ years...... Now seasonal travelers.
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If I owned a non-movable RV in Texas, I would be more concerned about the inspection/registration issue than the new HUD requirements.

 

I have not looked into the Texas Real Estate Tax issue since the passing of the combined inspection/registration legislation. At that time it was my understanding that a currently registered RV, even a park model, was not subject to Real Estate Taxes. Little was ever mentioned about the issue on this forum as the overwhelming concern was from traveling RVers who did not want to return to Texas every registration/inspection cycle. As far as I am aware, the remedy for registration with a delayed inspection upon return to Texas did not include any remedy for continued registration of in-state RVs that could not or would not move to get inspected. Unless the issue has been addressed and resolved, I suspect it will start to impact owners now that the new inspection/registration rules took effect March 1 and tax collects start to see expired registrations on non-moving RVs.

The one that dies with the most toys is still dead!

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Not sure what article you mean, but the link leads to one by Shawn Loring, attorney and a member of the management team. Having just read the article again, I really see nothing there which is not accurate and could be documented.

 

My error, Kirk... The article is indeed Shawn's not "Lori's". As I said though, the article is more about the advocacy program specifically, with the HUD definition issue this thread is about just one of the examples given.

Dutch
2001 GBM Landau 34' Class A
F-53 Chassis, Triton V10, TST TPMS
2011 Toyota RAV4 4WD/Remco pump
ReadyBrute Elite tow bar/brake system

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