The state government affairs team of the RV Industry Association (RVIA) has laid out policy priorities for 2022.
The team serves to protect and promote the RV industry in state legislatures and regulatory agencies by advocating on behalf of the industry.
As per RVIA’s News & Insights report, core state priorities for this year include preserving the industry’s ability to get plans approved in the two states which still have RV codes in place, fair and balanced treatment of manufacturers and suppliers under franchise laws, promoting campground modernization and expansion, establishing outdoor recreation offices, providing a voice for manufacturers and suppliers on critical environmental issues, and guarding against encroachment on the industry’s RV standards to ensure continued self-regulation.
RV Plan Approvals
Legislation proposed by the state government affairs team to remove a size limitation (430 sqft.) for fifth-wheels from the definition in Nebraska Code has been introduced and approved by the Nebraska Transportation Committee. It was approved for its first reading on the floor unanimously and should gain final approval soon.
The size limitation in fifth-wheel travel trailers in the set-up mode has been causing the Public Service Commission not to approve any plans for RVs over that size. Many manufacturers have started making larger fifth-wheels after RVIA’s board’s decision in 2020 to abolish the square foot limitation from its program requirements for manufacturers.
In Washington, manpower shortages at the state Department of Labor and Industries have caused a backlog of more than 2,000 plan approvals at one point. Many of those plans in the backlog were RV plans submitted by RV manufacturers.
Plan approval by the state of RV plans is needed for those unit floor plans to be sold within the state by Washington state RV dealers. The state has implemented an emergency rule using outside “Licensed Professionals” to expedite the backlog and focused on hiring more staff.
RVIA’s government affairs and standards staff have had and will continue to have, meetings with the Department of Labor and Industries to make sure the RV industry is well represented with the state and aware of the dynamic situation.
Franchise Laws
RVs are covered under the automobile franchise legislation in many states, even though auto dealers and RV dealers have different business models.
Unlike the automobile industry, there are no true franchises in the RV business.
The unique character of the RV sales and distribution model is based on one-dealer-to-many-manufacturers versus the auto industry’s one-dealer-to-one-manufacturer model.
In addition, the RV industry isn’t vertically integrated among manufacturers, parts, and suppliers as is in the auto industry, resulting in significant differences in the warranty obligations of both industries.
When the relationship between the RV manufacturer and dealer is incorporated into the franchise laws of the auto industry, the result is a misunderstanding.
Implementing a law that is specific to the RV industry, such as the model law negotiated and approved through members of the RV Industry Association and the National RV Dealers Association, means that the RV business isn’t out of compliance with inapplicable auto franchise law.
RV-specific laws allow the RV industry to continue its business model with no interference in the auto sector. It also ensures consistency for manufacturers to design and manage dealer agreements across states.
Campground Modernization and Expansion
Campground modernization, specifically in RV camping, is necessary across both local and state campgrounds. While many states have started updating their campgrounds, many campgrounds weren’t constructed or designed to accommodate today’s motorhomes or travel trailers.
The demographics that define the next generation of campers which comprises a diverse mix of millennials, minorities, and urban dwellers, are also causing changes in preferences and usage of RV campgrounds.
For instance, those who love outdoor activities also desire modern, full-service amenities and the ability to share their resources.
They prefer electronic means to book reservations, plan activities, and purchase equipment. RV campgrounds must meet these standards to remain a reliable source of recreational experiences for present and future generations.
Campgrounds are at risk of being irrelevant without significant enhancements to keep their status as popular destinations.
State Offices of Outdoor Recreation
Outdoor recreation accounts for 1.8% of U.S. GDP and supports more than 4.3 million jobs. However, this booming segment of the economy has the potential to expand even more when states are focused on strategically growing the outdoor recreation economy within their respective states.
Offices of Outdoor Recreation (OREC) do just that by increasing the business opportunities for outdoor recreation while also helping to protect and open up access to iconic public lands that millions of Americans can enjoy each year.
OREC offices play a crucial part in promoting outdoor recreation by working with local communities to enhance infrastructure, coordinate recreation activities across the state, and promote the benefits of taking part in outdoor recreation for the people of their respective states. OREC offices have proven to be extremely effective in increasing participation in outdoor recreation, which means a boost in the economy.
State Environmental Issues
Led by California and its Air Resources Board (CARB), several states are considering phasing out internal combustion engines and requiring all vehicles to be zero-emission by a certain date, generally 2035, although some states are considering 2030.
California has also approved a new regulation on small off-road engines (SORE), including engines that power RV generators. This will require these engines to be completely emission-free by the 2028 model year and introduce new evaporative emission standards beginning in the model year 2024.
The RV Industry Association formed an alliance of manufacturers, suppliers, and dealers who testified before CARB during the December 2021 hearing against the proposed regulation.
Despite the efforts of these groups to get RV generators exempted from regulations, the 2028 ban was accepted by the Board as proposed by CARB staff. However, the resolution was modified to reflect the RV industry’s concerns at the hearing.
The RV Industry Association vows to continue leading efforts to exempt fixed-mount RV generators from these draconian regulations.
Safeguarding the RV Standards
The key to the long-running self-regulation approach of the RV industry has been the successful maintenance of RV standards by external organizations, including the National Fire Protection Association and the American National Standards Institute.
Makers of other products than RVs, like small home manufacturers, have recognized the importance of these standards and have proposed legislation that would allow these standards to be applied to their products. The state government affairs team watches for these bills and opposes them vigorously.
For instance, in Colorado, the state government affairs team was able to intervene in a previously filed bill and block the RV standards to be used as permanency residency standards, as the legislation would have allowed.
By contacting the bill’s sponsor and providing a description of the standards and what they were designed to accomplish, the sponsor confirmed that RV residence and its mentions throughout the legislation had been removed.
Keeping the fine line between housing and RVs and protecting the standards from being misused is key to keeping that line bright.
For more details on state government priority issues, contact Michael Ochs at [email protected].
