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RVIA Comments on Newly Proposed Greenhouse Gas and CAFE Standards

RVIA is urging the Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA) to exclude RVs from the agencies’ joint proposed rulemaking to establish greenhouse gas emissions and fuel efficiency standards for medium- and heavy-duty engines and vehicles.

Under the Notice of Proposed Rulemaking (NPRM) issued by EPA and NHTSA, the first-ever Corporate Average Fuel Economy (CAFE) and greenhouse gas standards would be set for medium and heavy-duty vehicles, which are in general commercial type vehicles.  NHTSA exempts motorhomes from the rule; however, EPA specifically includes motorhomes under the same regulations that would apply to the commercial truck industry.

In comments to the NPRM provided by RVIA on Jan. 31, 2011, the association argues that if these standards developed primarily for commercial vehicles are applied to the RV industry, it will increase the cost of motorhomes and work trucks used as tow vehicles, leading to lower RV sales, due to the highly discretionary nature of RV purchases, as well as potential job loss in the RV industry.

“We are concerned about the negative impact that standards developed for the commercial motor vehicle industry would have on the RV industry,” said Jay Landers, RVIA’s senior director of government affairs. “The two industries are vastly different in terms of market economics, end users, and vehicle usage.”

“RVs are discretionary products, and people who are considering purchasing a motorhome or larger truck to tow an RV are more likely to delay or abandon that purchase due to price sensitivity,” he added. “This could be damaging to the RV industry at a time when it is recovering and hiring back workers.”

RVIA is also urging that a separate economic impact study for non-commercial medium- and heavy-duty vehicles be conducted by the agencies as the rule-making process proceeds.

For the complete comments filed by RVIA on the NRPM, click here.


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