RVDA Submits Comments on Joint EPA/NHTSA Greenhouse Gas Emissions Standards and Fuel Efficiency Standards

RVDA has submitted comments to both the Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) to address dealer concerns about proposed greenhouse gas regulations and how the rules would impact the RV industry. 

The agencies are developing rules addressing greenhouse gas emissions on medium and heavy duty trucks. NHTSA exempts motorhomes from the rule; however, EPA decided to specifically include motorhomes under the same regulations that would apply to the commercial truck industry. 

In the comments filed on January 31, RVDA said the RV industry should not be regulated using rules intended for the trucking industry because motorhome uses and commercial trucking uses are extremely different.  The end users are different, the vehicles intended purpose is different, and the economics and scale of the two industries is completely different.  The EPA will need to look at the number of motorhome owners, duration of trips by motorhome owners, the number of hours they are on the road, and the number of miles driven by motorhome owners. Following RVIA's lead, RVDA noted the price sensitivity of RV purchasers on these discretionary purchases, and the risks of additional injury to a recovering RV industry and RV employment.

RVDA also emphasized that the EPA should perform a separate Regulatory Flexibility Act analysis specifically for non-commercial motor vehicles and to pay particular attention to a recent Presidential Executive Order directing federal agencies that propose rules to reduce unnecessary burdens on small businesses.  For the complete text of RVDA's comments, click here.

RVDA coordinated its comments with RVIA and will keep members informed on the status of the proposed EPA and NHTSA rulemaking process.