Effort to permit RV conversions in Kentucky again

[Unfettered Might]

After going over my state's statutes and determining that RV conversions were and should still be allowed, then figuring out the reason why they weren't, I sent out some emails arguing the legal standpoints of the matter. I've received a response that they are researching the issue. Hopefully this can be corrected in a way that's reasonable for both parties.

I do get why they have the issue. you can't just screw together some plywood on a lot, throw a bed in it, and call it a house. Standards have to be met for housing, and a RV is no less a function of housing than any other in regards to basic habitability and safety. The problem is the way they are going about it in regards to only a particular group of people, and government can't do that. I think they have a word for it? Oh that's right, it's called discrimination.

I would have never thought my legal studies would some day be used to fight for people's freedom to make their own RV, but here we are. Let's just hope I don't have to get the judicial branch involved, I really hate paperwork.

 

[nikitis]

Your legal skills will most certainly be used in the future, guaranteed.

Know your rights!

Simply show them the law in statute, and cite it to them and then at that time demand it get done. If they hesitate or refuse, get their management involved. If that fails, then proceed to get a court order. You have the statute in hand. they must follow it.

 

[Unfettered Might]

Your legal skills will most certainly be used in the future, guaranteed.

Know your rights!

Simply show them the law in statute, and cite it to them and then at that time demand it get done. If they hesitate or refuse, get their management involved. If that fails, then proceed to get a court order. You have the statute in hand. they must follow it.

Since this does result from law written and voted on by the General Assembly, it's a little more complicated than they just have to follow the statute permitting a home built RV. But the policy by the Dept. of Housing to not even inspect them, which doesn't have statutory authority, is where they've misapplied their directive. They can fail them, but they have to inspect them. If 1000 of them fail in a row, they still have to inspect the 1001st, and reinspect the first 1000 should anyone request another inspection and pay the fee, and as many times as they request and pay the fee. They can't simply refuse to perform their function.

 

[nikitis]

They cannot simply fail their inspection either if you meet the requirements. If they do, you ask for the inspection report after the first failure and ask that they put it in writing what needs to be corrected to pass, make those corrections, and then get a second inspection. If those items are corrected they have to pass you, if they don't and keep making things up, take it to court. In court, point out when the defendant states "Well on the 3rd inspection we found another issue", you state to the judge in reply, there were 2 prior inspections and those new issues were not caught? They are dragging this along. It will look bad for them for not catching those items on the first 2 inspections and you will eventually get your RV status.

Costly though.

 

[DeMac]

Oops.

Oops. Accidental post

 

[Unfettered Might]

They cannot simply fail their inspection either if you meet the requirements. If they do, you ask for the inspection report after the first failure and ask that they put it in writing what needs to be corrected to pass, make those corrections, and then get a second inspection. If those items are corrected they have to pass you, if they don't and keep making things up, take it to court. In court, point out when the defendant states "Well on the 3rd inspection we found another issue", you state to the judge in reply, there were 2 prior inspections and those new issues were not caught? They are dragging this along. It will look bad for them for not catching those items on the first 2 inspections and you will eventually get your RV status.

Costly though.

I think anyone with half a brain would know they were being messed with. But if you want to avoid it all together, just build using the code they've adopted. There may be more referenced publications, but that's as far as I've gotten in NFPA so far.

NFPA 1192 - Officially adopted
NEC - Referenced by NFPA 1192
ANSI/RVIA LV - Referenced by NFPA 1192

 

[LargeMarge-TC]

Bureaucrats exceeding their legitimate authority... and/or refusing to do their job.
We have a word for that -- TREASON.

 

[n240sxguy]

When did KY say you couldn’t do a conversion? I was under the impression that the fire marshall had to inspect it and make sure it had a bed and toilet basically, and it was good to go. That’s what they told me a couple years ago anyway.

 

[Unfettered Might]

When did KY say you couldn’t do a conversion? I was under the impression that the fire marshall had to inspect it and make sure it had a bed and toilet basically, and it was good to go. That’s what they told me a couple years ago anyway.

It all stems from a pretty major overhaul to housing statutes in 2017. Fire marshal no longer does inspections on manufactured houses, mobile homes, or RVs, the Dept. of Housing does. Then at some point a few years ago they just up and decided they weren't inspecting conversions of any kind anymore. No inspection means no B seal, no B seal means no transfer(or title conversion). County clerks just started telling people "Kentucky doesn't do title conversions anymore.", but that's actually not an accurate answer why, just an easy one to get people to go away. There are several comments regarding the change on this very website. Whoever you talked to just wasn't up to date on things.

It's been over a week since I've gotten any updates, and I don't see anything filed with the 2024 session yet that would indicate a decision to try and make their position lawful. I can only assume they are considering the options I outlaid and/or are determining what provisions in the habitability and safety standards that could reasonably be expected of a conversion as opposed to a factory manufactured RV. The good thing is I've apparently carved out a good position of legal standing, or I would have already gotten a "No" from their legal department. I'm just hoping they find a middle ground of expectation, comply with the law as written, and I don't have to bring judicial review into it. But I absolutely will if they make me.

It should be noted, the way the statute is written, "...for personal use...", they would be within their authority to deny any transfers of title in KY once the title was converted. Though I did suggest a transfer be allowed through inheritance to beneficiaries in KY.

Any updates will be posted as soon as they are available.

 

[n240sxguy]

I started looking at conversions around 2019 or 2020. When I called the courthouse they said the fire marshall had to inspect it, or their designee. Basically the local camper dealer has their permission to inspect. Apparently every rv coming into KY has to be inspected. It’s so backward apparently that I could sell a camper out of state, and buy it back, and it would have to be inspected again. Money grab BS. Since I wasn’t gonna have mine converted in 30 days to be able to have it inspected and registered, and I didn’t want to have to get a cdl to drive it, I registered it in Vermont to do the conversion.

 

[GoEddieGo]

Wow, all you have to do in Georgia is fill out an affidavit, and have it notorized.
State to state laws sure are bonkers sometimes.

https://dor.georgia.gov/t-24-bus-motor-home-conversion-affidavit

 

[Ozbozz57]

RV "building codes"

It's a bummer that you're having to go through all this with the State of Kentucky. Kentucky, of all places. The land of outhouses and tarpaper shacks.

I think part of the problem is that they aren't really set up to do inspections of individual vehicles. I seriously doubt they inspect every single factory-built RV - likely just the designs themselves, or maybe an occasional model here and there.

I DID build my conversion to the standards set forth in NFPA 1192, the related NEC articles, and ANSI rules. Codes provide useful guidelines, and as someone who has built two houses, I realize that building codes are MINIMUM standards. A good builder will often exceed those minimums.

I live in Washington State. I understand that here, "tiny homes" are inspected through the Department of Labor and Industries. Fortunately, I didn't build one of those, just an RV to go camping in.

Best of luck to you, Unfettered Might. I'm interested to see how this turns out.

 

[nikitis]

I live in Washington State. I understand that here, "tiny homes" are inspected through the Department of Labor and Industries. Fortunately, I didn't build one of those, just an RV to go camping in.

To the government, there isn't a difference between a "Tiny Home" and an "RV".

 

[Sp4098]

I just found this forum with my research on how to get an rv title in ky. To my unhappy surprise stupid Commonwealth.
If I can help lobby this, I'm happy to, my representative lives in my home town, I'm not afraid to bend his ear and send letters and emails. Thanks for your work.

 

[onex]

I seriously doubt they inspect every single factory-built RV - likely just the designs themselves, or maybe an occasional model here and there.

Having worked in an RV-related industry, what I've seen on the floor is that NTA comes through once in a while and checks out a couple things on some of the units in production, and leaves.
It's more frequent and thorough if the plant has had issues during inspections recently.

I live in Washington State. I understand that here, "tiny homes" are inspected through the Department of Labor and Industries. Fortunately, I didn't build one of those, just an RV to go camping in.

Here at least tiny houses are built and inspected to the same code as RVs.

 

[Sp4098]

Having worked in an RV-related industry, what I've seen on the floor is that NTA comes through once in a while and checks out a couple things on some of the units in production, and leaves.


There is a mobile home manufacturer here in town, I know they used to do there own plumbing pressure test and some electrical tests as it went ou the door, not sure how there allowed to install there own stickers

 

[Unfettered Might]

It's a bummer that you're having to go through all this with the State of Kentucky. Kentucky, of all places. The land of outhouses and tarpaper shacks.

I think part of the problem is that they aren't really set up to do inspections of individual vehicles. I seriously doubt they inspect every single factory-built RV - likely just the designs themselves, or maybe an occasional model here and there.

I DID build my conversion to the standards set forth in NFPA 1192, the related NEC articles, and ANSI rules. Codes provide useful guidelines, and as someone who has built two houses, I realize that building codes are MINIMUM standards. A good builder will often exceed those minimums.

I live in Washington State. I understand that here, "tiny homes" are inspected through the Department of Labor and Industries. Fortunately, I didn't build one of those, just an RV to go camping in.

Best of luck to you, Unfettered Might. I'm interested to see how this turns out.

Hey now, that's only in certain parts of Kentucky, and most Kentuckians won't go there either lol. :ermm:

Hard to say, there are several county contacts (120) where a manufactured housing inspection can be done, I'm sure the inspectors are working multiple counties. But you're right, it would be problematic to keep up with every new unit, if there were several manufacturers here(there isn't). There are several retailers for manufactured homes and RVs here though. The inspectors would be involved in any setup of a manufactured home, new or used. New RVs are already inspected from the factory, used RVs sold by retailers would be inspected, as would any used ones coming from out of state. But sales of used RVs between residents would not. There are probably a few exceptions here and there I'm missing, but that's the pretty much the gist of it. I believe that any manufacturer in state or selling in state has to submit plans for approval, and cannot change the plan without the change being approved. They also have to agree to be subject to surprise inspections, as well as sharing of their proprietary information and financials. Hell, who wouldn't want to do that....

I have no issue with minimum standards being required or enforced, no one should. Building codes generally just create a basic margin of safety to protect others from those(and also those from themselves) that would otherwise be a danger to life and limb.

Stay tuned to the end for an update.

I just found this forum with my research on how to get an rv title in ky. To my unhappy surprise stupid Commonwealth.
If I can help lobby this, I'm happy to, my representative lives in my home town, I'm not afraid to bend his ear and send letters and emails. Thanks for your work.

When I observe the big picture, I'm not feeling that all aspects of implementation are aligning with intent. There are certainly rank and file in Frankfort who aren't happy about it. One of them that I emailed to get information about title conversions dropped a breadcrumb. I would have come to the same conclusion anyway, but I still respect the fact they were trying to put me on the right path. I appreciate your willingness to get involved with this. DC is and forever will be a lost cause, but state and local governments are far more receptive to their constituents. I'll PM you at some point soon and we can discuss this further.

Having worked in an RV-related industry, what I've seen on the floor is that NTA comes through once in a while and checks out a couple things on some of the units in production, and leaves.


There is a mobile home manufacturer here in town, I know they used to do there own plumbing pressure test and some electrical tests as it went ou the door, not sure how there allowed to install there own stickers

It's RVIA you should be watching, closely.


UPDATE
So yesterday I spoke with someone at the housing department who stated that the entire time they've been in their position there, and it wasn't a short period of time, they've never had someone request a B Seal inspection for a bus conversion and this guy would know. I can't say there was any indication that he was being deceitful, and nothing I can think of him gaining for doing so. But can anyone reading this confirm they had a B Seal inspection done on a bus in Kentucky?

He also stated that he would perform the inspection, but that it would fail. Considering the only standard applicable to a motorhome(description in the housing statutes that matches a bus conversion) is NFPA 1192, and everything it covers is really just utility, fire, and safety related, I find that assertion highly unlikely so long as the regulations are followed. Not to mention there's this at the beginning of it. So can you adopt a standard for something the standard tells you not to adopt it to?

 

[Jdavidson-SKO]

Any updates with this would.be awesome I'm in ky and got the same answer no title changes

 

[tomrasdf]

Am about 2 months from wrapping up my conversion, and called DMV to innocently ask about inspections for an RV. Was passed off to the fire department who passed me off to a fire marshal in Lexington, who said that I wasn't in his jurisdiction (I'm in Louisville), but gave me the number of a local inspector.

When I posed the question about conversions, he said (as exact as I can remember), "It depends on who you talk to. You might be able to find someone who will inspect a conversion, but it'd technically be illegal for us to do so. We have no way of knowing whether it was made up to RVIA standards."

I haven't called the local inspector yet. When I do, I'll post what I find.

 

[Ozbozz57]

hmmm, really?

"It depends on who you talk to. You might be able to find someone who will inspect a conversion, but it'd technically be illegal for us to do so. We have no way of knowing whether it was made up to RVIA standards."

RVIA standards should be the NFPA 1192,et al previously cited. These are known codes.

This is like a building inspector - whose job it is to determine if a structure meets specific codes - saying there's no way to tell if it meets code.

What???