New Jersey and Park Trailer Industry Reconcile

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March 20, 2008 by   - () Leave a Comment

The New Jersey Department of Community Affairs (DCA) is finalizing its rules on recreational park trailers in the Garden State and appears to be moderating its controversial proposal that first aired in 2006.
DCA officials, including DCA Commissioner Joseph V. Doria Jr., Deputy Commissioner Charles A. Richman, and Director of the DCA Division of Codes and Standards Cynthia A Wilk, met Feb. 19 in Trenton, N.J., with Jay Otto, executive director of the New Jersey Campground Owners Association (NJCOA), William Garpow, executive director of the Recreational Park Trailer Industry Association (RPTIA), and the group’s lobbyist, Aladar G. Komjathy, to seek an agreement amendable to both sides. DCA establishes and enforces the state’s building codes.
The former Division of Codes and Standards director had proposed to institute tougher standards on park models and make them conform to International Energy Conservation Codes. NJCOA and RPTIA maintained that the state should accept the American National Standards Institute (ANSI) 119.5 park model standards, as does the rest of the country. Otto, Garpow and park model manufacturers and dealers feared that the unique energy standards will ruin the destination camping business in New Jersey as the requirements would make units smaller, less usable and more expensive than the units being offered in the other 49 states. The state’s park model dealers purchased 297 units in 2007, the 9th best market in the country, according to RPTIA figures.
“It was a pretty good meeting,” said Otto in an interview with Woodall’s Campground Management (WCM). “We felt comfortable, especially with the information we heard afterward.” Garpow also was encouraged by DCA’s latest overtures, he told WCM.
4 Concerns Raised
According to Otto, DCA raised four concerns during the meeting: energy efficiency, carbon monoxide detection, snow load and tie-down wind requirements. Otto said DCA said it would relax its plan to increase insulation requirements after it realized during the meeting that the park models are generally not used in the winter in New Jersey and could not by state law be used as a domicile. The detector issue became moot when Garpow noted that detectors will be required in the next round of ANSI standards, and many manufacturers install them already, Otto said.
Following the meeting, Otto and Garpow discovered that park models had already achieved the state’s snow load requirements statewide.
Common Ground Found
DCA’s version of the hour-long meeting suggests the sides found some common ground.
“The department has listened to the comments made during the public comment period on this rule, and to the supporting arguments presented by the commenters, and has researched standards that might reasonably be applied to park models,” said Chris Donnelly, a DCA spokesman, in an e-mail to WCM.
Donnelly said, “The snow load levels will be revised based on comments received and research done; the insulation requirement will be revised because these units cannot comply with the International Energy Conservation Code.”
Otto said he also heard favorable reactions from DCA on the need for tie-downs for the unit and permits to place park models in campgrounds. Garpow presented engineering evidence that park models are built to withstand most high winds typically recorded in New Jersey. Likewise, the DCA commissioner said that as long as the wheels and axles remain on park models, meaning that they remain mobile, permits would not be needed. However, DCA reiterated that if other structures, such as add-ons are affixed to park models, they might require tie-downs and impose other requirements. RPTIA discourages consumers from affixing add-ons to park models.
“RPTIA agreed with this DCA concept and has always discouraged parks or jurisdictional authorities from affixing add-ons to park models if the addition uses the park model as a structural member or as a linkage to any of the park model’s utilities that that addition might require,” Garpow told WCM. “A recreational park trailer is and should always remain a trailer and as such it needs to remain mobile. Additions however that are independently sited adjacent to the park model with nothing more that flashing connecting the two units would be acceptable to RPTIA, provided that both the park and the jurisdictional authority agree.”
New Ruling Due by July 2
Otto and Garpow agreed to get back to DCA with some details on tie-downs and wind speeds to help make their case. “We hope we can take care of this in the next few months,” Otto said.
Donnelly said DCA staff members are finalizing the notice of adoption and have until July 2 to adopt the ruling.
“DCA’s concern was and is that these homes provide for the safety of the occupants,” Donnelly said. “This is the same concern that the department has in addressing any homes, regardless of whether they are site built or (pre)manufactured.”

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