(UPDATE—10/07/19) In a continued effort to ensure the National Electric Code (NEC) works in favor of all RV parks and campgrounds, the National Association of RV Parks and Campgrounds (ARVC) has officially submitted a Tentative Interim Amendment (TIA) as a formal request to change the existing code language regarding GFCI protection on 30- and 50-amp RV electrical services.
A TIA allows emergency changes to be put in place between publication dates of the written NEC. Upon adoption, this TIA (TIA 1474) would change the NEC to specifically prohibit the requirement of GFCI protection on the 30- and 50-amp RV electrical services.
ARVC, and its industry partners RVIA and RVDA, are requesting all members join a grassroots effort to show support for TIA 1474. You can join this effort by customizing the email template below and emailing it to TIAs_Errata_FIs@nfpa.org:
PLEASE SUBMIT LETTERS OF SUPPORT BY NOVEMBER 7, 2019.
Dear Secretary, Standards Council,
I strongly support the adoption of TIA 1474 concerning NFPA 70 551.71(F).
As a RV park and campground owner, I support TIA 1474 for the following reasons:
1. 30- and 50-amp devices are feeders and not subject to 210.8(B);
2. The additive leakage allowed by multiple GFCI devices in an RV could easily exceed the limits of a Class A GFCI device;
3. The Code Making Panel did not have the opportunity to review and correlate Article 551 during the 2017 code process; and
4. The 2020 code now has conflicts within Article 551.71 concerning weather-resistant 20-amp receptacles, as well as with other special occupancy sections of the NEC.
Furthermore, the approval of TIA 1474 should be considered an urgent matter because the NEC in its current form has created ambiguous and possibly unenforceable code sections.Thank you for your attention to this matter.
(DENVER—8/22/19) Advocacy efforts led by the National Association of RV Parks and Campgrounds (ARVC) continue following the latest decision by the National Electric Code (NEC) regarding the use of GFCI protection on 30- and 50-amp receptacles on RV park site equipment.
The National Fire Protection Association’s NEC was considering language that would require GFCI protection on 30- and 50-amp receptacles on RV park site equipment
The National Fire Protection Association’s NEC was considering language that would require GFCI protection on 30- and 50-amp receptacles on RV park site equipment, but has decided instead to revert to language from the 2017 code which leaves this portion of the standard open to interpretation. This decision was after a concerted effort by equipment manufacturers to require GFCI protection on the 30- and 50-amp services on RV pedestals. A decision to require the GFCI protection could have cost RV park and campground owners an estimated $400 for each electric pedestal on their campground—or $40,000 for a 100-site park to get up to code.
“We aren’t satisfied with simply reverting back to the 2017 standard and leaving this open to interpretation,” says Paul Bambei, president and CEO of ARVC. “Our advocacy efforts to specifically prohibit the requirement for GFCI protection will continue and ARVC is entrenched in the fight for our members and the outdoor hospitality industry. We will not rest on this until a standard is in place that protects our member parks from unnecessary regulation.”
The next course of action will be for ARVC to submit a Tentative Interim Amendment (TIA) in the coming weeks. A TIA allows emergency changes to be put in place between publication dates of the written NEC. Upon adoption, a TIA would change the NEC to specifically prohibit the requirement of GFCI protection on the 30- and 50-amp RV electrical services.
In addition to these direct advocacy efforts, ARVC is also providing its members with a detailed, but brief talking-points document they can use in the event an Authority Having Jurisdiction (AHJ) in their area confronts them about the standard. This information is currently posted on the Document Library (in both the "News You Can Use" and "Public Affairs/Advocacy" folders) on arvc.org accessible when an ARVC member logs into their member profile.
“In this case an industry group with a profit motive sought to install this GFCI requirement into the standard through unconventional methods, but the advocacy efforts we are leading continue to make a difference for ARVC members and the outdoor hospitality industry on this issue,” says Wade Elliott, who, is ARVC’s representative to the NEC Code Making Panel as well as being an ARVC representative on public affairs issues. He is also owner of Utility Supply Group and member of the NFPA Technical Committee responsible for overseeing NFPA 1194.
Working closely together with Elliott on this important advocacy issue for RV parks and campgrounds was Jeff Sims, ARVC’s senior director of state relations and program advocacy. Advocacy efforts included direct talks with the NEC as well as a grassroots letter campaign that resulted in more than 450 letters submitted in support.
“In the arenas that Wade and I work in, not all circumstances can be anticipated,” says Sims. “This short notice grassroots call to action demonstrated the importance of the industry to take action and proves the industry and ARVC have great leverage when we are united. Our collective voices were definitely heard and our efforts will continue to make a difference. I applaud all of the park owners who took the time out of their busy schedule to support an industry-wide issue.”
Sims and Elliott both keep a close watch on issues, serving as advocacy experts for all outdoor hospitality industry members. They have been especially busy in 2019, with Sims already reporting more industry-related bills and issues researched by the ARVC public affairs team through July of 2019 than there were in all of 2018.
“Situations like this one prove our members do have a real voice in industry issues,” says Sims. “There is a place for all members who would like to be involved in advocacy and I encourage them to contact me if they would like to serve on the ARVC Public Affairs subcommittee to participate in an active role in these activities.
Other recent advocacy highlights include the passage of the School Turnaround Act in Missouri, which allows for an extended summer vacation for schools, and a letter to congress urging it to preserve RV access to network programming.
“Our industry is lucky to have Jeff and Wade in our corner,” says Bambei. “The ability for ARVC to offer these local, state and national advocacy efforts as a benefit to our members is invaluable. Advocacy is extremely important and the work our public affairs team is doing makes our industry stronger and makes our members more successful.”
Interested in learning more about important legislation in your state and nationally? ARVC members can stay up to date on ARVC’s advocacy updates by logging in at arvc.org/current-legislation.