Interpretation ID: nht94-1.49

TYPE: INTERPRETATION-NHTSA

DATE: February 9, 1994

FROM: James H. Shuff -- President, Freedom Trailers

TO: Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 7/14/94 from John Womack to James H. Shuff (A42; STD 120; VSA 102(3))

TEXT: I was advised by Mr. George Shifflet of the D.O.T. to contact you and request a ruling on the Park Model Travel Trailers that I am building.

I am custom building park model travel trailers. These units, by ANSI code 119.5, are limited to a maximum of 400 sq, ft. There are park models that are recognized by H.U.D. but they are 500sq. ft. They are intended for recreational use only and no t for year round living. These units can be used in the same manner as conventional travel trailers for winter camping in the year round parks. These units can be as wide as 12'.

The units that I am building are to order only. Once they are constructed they will be towed to their campsite and set up. The tires and the rims will be retained by me and used over again. Mr. Shifflet did not seem to think that there would be a p roblem with this, but suggested that I contact you for an opinion.