EPA

Greenhouse Gas Emissions

Both the Environmental Protection Agency (EPA) and the National Highway Traffic and Safety Administration (NHTSA) have jurisdiction over federal standards for greenhouse gas reduction and tailpipe emissions from motor vehicles. In 2016, EPA and NHTSA released the joint Phase 2 final rule establishing greenhouse gas (GHG) and fuel consumption standards for medium- and heavy-duty vehicles.  The rule impacts 2021-2027 model year motor home chassis sold in the U.S. As a result of RVIA’s lobbying efforts, motor home chassis will be subject to much less stringent standards than most other types of medium- and heavy-duty vehicles by being included in the vocational custom chassis class.

In 2023, EPA released its Notice of Proposed Rulemaking on Phase 3 greenhouse gas emissions standards for heavy-duty vehicles for model years 2027 to 2032. The RV Industry Association is pleased that EPA has retained the inclusion of motor homes in the “custom vocational chassis” category and has established the allowable CO2 standard for these vehicles at 226 grams/ton-mile.

EPA stated that “the vocational chassis categories also recognize that many manufacturers of these custom chassis are not full-line heavy-duty vehicle companies and thus do not have the same flexibilities as other firms in the use of the Phase 2 program emissions averaging program which could lead to challenges in meeting the standards EPA established for the overall vocational vehicle and combination tractor program.” This analysis makes clear that it is crucial that EPA retain the inclusion of motor homes in the vocational chassis classification.

In March 2024, EPA released its final rule on “Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles,” which will have a negative impact on smaller motor homes. Unlike the rule on heavy-duty vehicles, the Multi-Pollutant rule does not classify motor homes into a vocational vehicle chassis category, thus subjecting motor homes weighing less than 14,000 pounds to the same stringent rules as all other vehicles in that class. The RV Industry Association filed comments opposing the Multi-Pollutant rule in July of 2023 since the rule is intended to push vehicle manufacturers to produce a greater percentage of electric vehicles, despite the fact that motor homes are not used in a similar manner to most other light- and medium-duty vehicles.

While RVIA believes that reduction of emissions is well-intentioned, it should be done in such a way that accounts for the normal usage of a vehicle by consumers, not by forcing a technology that is both cost-ineffective and unfeasible under the current industry state.