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Maryland State Code Issues

Last Changed 2/11/2007

Our goal as HDT owners is to have adequate tow vehicles for our recreational trailers that we can also use as personal vehicles.  This need is apparent, as the sizes and weights of fifth-wheel trailers are increasing.  As usual, law follows evolution; it seldom leads the way.

Before going any further, we want it to be very clear that we are not lawyers.  The information we are presenting was found in the Maryland Transportation Code and from discussions with administrators for the Maryland Motor Vehicle Administration (MVA).  We present this for information and discussion.  We do not promote violating any laws.  We offer suggestions to evolve state laws to fit the changing RV world.

Our research into the Maryland Transportation Code uncovered the complexities that our state governments face.  Most state vehicle code definitions follow the Federal definitions.  The differences among the states will be in the interpretations of definitions, and more importantly, in the establishment of fee structures.  You will find that state rules are generally driven by two issues, safety and revenue.

Motorhome Registration

The general trend among HDT owners is to register our trucks as motorhomes.  As a motorhome, our truck becomes a personal vehicle, free from the restrictions normally placed on commercial vehicles.

In Maryland, you find in the MD Code 11.15.03 Multipurpose Definitions, the definition of a "motor home".  In short, a motorhome is a vehicle that provides temporary living quarters built as an integral part of a self propelled motor vehicle chassis or van and has four of the following seven facilities: cooking, refrigeration, self-contained toilet, heating/air conditioning, potable water with sink and faucet, electrical power supply and an LP gas supply.  In almost all other places in the MD Code, a motor home is called a multipurpose vehicle, and the registration class is Class M.  Most states have a similar definition.

The general response you will get from a state agency when you try to register a converted sleeper tractor as a motorhome is, No, it isn't really a motorhome!"  There may be arguments on the extent of changes made to the tractor with a sleeper.

Trailers

As in most states, Maryland defines travel trailers as temporary living quarters, etc. in the MD Code 11.170 Travel Trailer Definition.  Fifth-wheel trailers are treated the same as travel trailers in the rest of the Code.  All trailers registered in Maryland are a Class G registration as defined in MD Code 13.927 Class G Trailers.  For registration, trailers are divided into two major classes, Freight and Non-Freight.  The assumption is that travel trailers fall into the non-freight category.  But, that is not always the case.

The main reason for the Freight and Non-Freight categories is that Non-Freight trailers are licensed by weight, and the trailer's weight does not affect the towing vehicle's weight classification.  Freight trailers have a flat registration fee, because the weight of the trailer is added to the tow vehicle's weight for the purpose of determining the registration fee.

Now for the fun part.

A non-freight trailer is limited to 10,000 lbs.  GVWR when towed behind a Class A (car) or Class M (multipurpose) vehicle.  Behind a Class E (straight truck), a non-freight trailer can have a GVWR of up to 20,000 lbs.  Over 20,0000 lbs. GVWR, the trailer is categorized as a freight trailer.

For the record, in the Maryland code, boats on trailers are treated the same as travel trailers.

In Maryland, a heavy trailer, like a Newmar fifth-wheel, can have a GVWR of 21,000 lbs. is classified as a freight trailer.

The conflict

We were fighting the battle to get Red Rover registered as a Class M motorhome.  The killer was that as a Class M, the heaviest trailer we could legally tow with Red Rover would be 10,000 lbs. GVWR.  The reason we acquired Red Rover in the first place was to pull a large fifth-wheel trailer.

So be aware, that in other states there may be similar conflicts between registration requirements and usage needs.

Class E Truck

We did not want Red Rover registered as a tractor.  There are just too many commercial connotations to a tractor, especially driver's license requirements and insurance costs.

Given the weight of the fifth-wheel trailers we are considering, it looks like the only vehicle that we can use under current Maryland Codes is a Class E truck.  What would it take to make Red Rover a Class E truck?  Basically, the definition of a tractor in MD Code 11.172 Truck Tractor Definition is a truck that carries no cargo and only tows.  So it looks like Red Rover will have to at least have a cargo carrying bed to be a Class E truck.

We had intended to put a deck on the back of Red Rover.  The question now is to what extent our deck has to be "cargo carrying."

Other Recreational Code Conflicts.

The fact that a 21,000 lbs. GVWR trailer does not fit into the non-freight trailer category is a problem.  Manufacturers New Horizons, Newmar, and Teton Homes make trailers that are 40' or less in length, the limit imposed in Maryland for travel trailers, and weigh more than 20,000 lbs.,

A travel trailer in the 10,000 to 20,000 lbs. GVWR bracket needs a Class E truck.  This is generally considered a commercial vehicle. (note - most trailer manufacturers have started to limit the GVWR rating to 20,000 no matter how much the trailer weights and to 40' in length no matter how long the trailer really is to avoid these licensing issues)

Code Evolution Needs

We found the administrators at the Maryland MVA to be receptive to the idea of HDTs towing recreational vehicles.  The safety factor is a real driving force.  The issue to them will be how to implement changes in the Codes without losing the necessary controls on commercial usage.

We see a need to raise the weight classifications of travel trailers to fit current models.  We feel that better definitions on what is a "recreational" trailer need to be made.  The current definitions are vague and can include a bunk in a trailer that carries race cars and has a workshop.  Perhaps a definition of "recreational" that includes a minimum percentage of the trailer floor space that must be dedicated to "living quarters" would be a better description.

For towing a recreation travel trailer, a new class of vehicle registration is needed.  For description purposes, let us call it a "recreational tower," one that allows vehicles of sufficient capacity to pull the larger travel trailers without having to be in the commercial truck classification.  By necessity, this vehicle class would have to have restrictions that limit it to personal usage and to pulling recreational travel trailers.

There is a fine line separating personal usage and commercial usage.  The definition of the allowable trailers for this recreational tower has to be very narrow.  Travel trailers and boats are about as far as you can go without leaving so many loopholes as to be unenforceable.


Disclaimer: The information in this site is a collection of data we derived from the vendors and from our personal experiences.  This information is meant as a learning guide for you to  make your own decisions  Best practices and code should always be followed.  The recommendations we make are from our personal experiences and we do not receive any compensation for those recommendations.
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