The National Association of RV Parks & Campgrounds (ARVC) has alerted members of Congress that cash-strapped cities, counties and states are increasingly attempting to impose property taxes on recreational park trailers or “park models” in violation of federal law.
“This is probably the biggest single state and national issue facing our industry today,” said Jeff Sims, ARVC’s director of state relations & program advocacy, in a press release.
Sims joined 27 private campground operators and industry officials in personally alerting 123 members of Congress and their staffs about illegal state and local efforts to tax park trailers during their May 8-9 visits to legislators on Capitol Hill. The meetings were arranged in conjunction with ARVC’s annual National Issues Conference.
The ARVC delegation also personally briefed members of Congress on ARVC positions regarding a variety of other issues ranging from onerous rules and requirements involving the Americans with Disabilities Act (ADA) to de-funding of national parks, highways and tourism promotion.
“We had two days worth of very productive meetings,” Sims said, adding that private park operators and industry officials prefaced their congressional meetings by reviewing their talking points with David Ransom of McDermott, Will & Emery, ARVC’s government relations counsel.
Sims said it was important to brief legislators on state and local attempts to circumvent congressional mandates and impose property taxes on recreational park trailers because they are increasingly being used by consumers as vacation cottages and by private park operators as rental accommodations.
“The intent is to educate legislators so they know what’s going on,” Sims said. “Recreational park trailers are for recreational purposes only. They are not meant to be affixed to the property in any way. They do not improve property values in any way, and they are neither designed nor intended by their manufacturers to be used as permanent residences. In fact, recreational park trailers are titled and licensed as motor vehicles by the various states.”
And unlike real property, which can appreciate over time, park trailers depreciate over time, Sims said. “A recreational park trailer is like a pickup,” he said. “It’s a vehicle that’s licensed. It’s not meant to enhance the value of a property.”
In fact, Sims said, recreational park trailers are built in accordance with the American National Standards Institute (ANSI) A119.5 Recreational Park Trailer Standard, not the HUD requirements that manufactured homes are mandated to comply with. “Recreational park trailers are not manufactured housing,” Sims said. “There is no practical difference between the use of recreational park trailers and travel trailers or fifth-wheels.”
In addition to briefing legislators on illegal efforts to tax recreational park trailers, private campground operators outlined ARVC’s positions on several other issues, including:
• Fair implementation of ADA guidance on swimming pools and spas: ARVC believes that public accommodations should be permitted to store portable pool lifts and deploy them when they are requested by disabled people. ARVC also supports H.R. 203, introduced by Rep. Mike Mulvaney, R-S.C., which would explicitly state that portable pool lifts are ADA compliant.
• Support for the national parks: The national parks could face a reduction in visitor services, hours of operation and a shortening of seasons as a result of federal budget sequestration. ARVC supports funding that allows national parks to be properly staffed and maintained.
• Promotion of travel and tourism: ARVC supports legislation and policies intended to increase travel and tourism in the U.S., including visa waiver programs that allow foreign visitors to experience America’s national treasures. The U.S. travel and tourism industry is a major component of the nation’s GDP and employment, representing 2.7% of GDP and 7.4 million jobs directly connected to the travel and tourism industry.
• Support for America’s roads and highways: ARVC supports funding for federal highways and urges Congress to maintain support for the Scenic Byways Program.
Today’s Video No. 1 comes from WNDU TV, South Bend, Ind., as representatives from the Recreational Park Trailer Industry Association (RPTIA) discuss the impact of gas prices.
Members of the RPTIA are concerned about gas prices but remain hopeful that RVers will continue to enjoy camping. The association is currently holding its quarterly board meeting at the RV/MH Hall of Fame in Elkhart, Ind.
“Obviously as discretionary spending gets tighter because of the gas prices, it does create a little bit of a tough situation for consumers looking to purchase a model whether it be a park model or travel trailer,” said John Soard, general manager of Fairmont Park Trailers in Nappanee, Ind.
In the meantime efforts are being made to allow people to “test out trailers.” Recently, Kampgrounds of America (KOA) campsites started renting out park trailers, which they call lodges.
“As the economy has faltered a bit, what we’ve found is that people still want to camp,” said KOA’s Director of Lodging Mike Atkinson. “They still want that experience but don’t want to afford that huge investment.”
Locally, the park trailers or lodges at the KOA campsite in Granger, Ind., are usually booked for the entire summer and during the University of Notre Dame football season. They cost about $99 a night.
The Recreational Park Trailer Industry Association (RPTIA) is warning campground and RV park operators to be wary of investing in used park trailers that are being offered for sale by the General Services Administration (GSA).
Some 2,000 park trailers, which were built for the Federal Emergency Management Administration (FEMA) for use as temporary housing for hurricane evacuees, are being auctioned by the GSA. However, these units have not been inspected by RPTIA and could pose various liability risks to park operators, according to a news release.
“Park operators should think twice before purchasing these used FEMA units,” said William Garpow, RPTIA executive director, “It may not be in their best interest to purchase these units with the idea of using them as a rental product.”
In addition to lacking an RPTIA inspection seal, many of the FEMA units also have visible sustained water and mold damage as a result of improper installation and maintenance by FEMA contractors. Others may have water damage that remains out of sight.
“While the cost of these FEMA units being auctioned by the GSA looks like a financial winner, the possibility of losing a liability case over a public safety issue can place a long-term dent into your bottom line that could be very painful,” Garpow said.
Mike Atkinson, facilities development manager for Billings, Mont-based Kampgrounds of America Inc. (KOA), said KOA guidelines prohibit its franchisees from investing in park trailers that do not have an RPTIA inspection seal.
Garpow said FEMA contracts to purchase recreational park trailers for emergency housing units required manufacturer to be responsible for verifying that these units were built to the requirements of the ANSI A119.5 Standard. However, any inspection process that took place to verify compliance before the units are placed into service were minimal at best. “FEMA encourages these contractors to be members of the RPTIA and also encourages them to use the RPTIA inspection program, but it stops short of making either of these a contractual requirement,” Garpow said.
RPTIA members, on the other hand, pledge as a condition of their membership that they will construct any recreational park trailers they build to be in conformance with the ANSI A119.5 Standard. The RPTIA inspection program to verify the pledge mandates a certification inspection as a pre-condition for a manufacturer’s membership and also imposes at least four unannounced verification inspections annually to confirm, to the association, that the member firm still has the capability to build units meeting the standard as the manufacturer pledged. All RPTIA inspections are accomplished by RPTIA independent third party agencies, who typically are the same firms used by government agencies to verify compliance with laws and regulations that cover public safety requirements.
For more information, contact Garpow at (770) 251-2672 or e-mail him at firstname.lastname@example.org.