3930 University Drive

Fairfax, Virginia 22030 

(703) 591-7130

January 31, 2011

Submitted Online @ Regulations.gov

Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460

Attention Docket: EPA-HQ-OAR-2010-0162

National Highway Traffic Safety Administration

U.S. Department of Transportation

West Building, Rm. W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Attention Docket: NHTSA-2010-0079

Re: Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium-

 and Heavy-Duty Engines and Vehicles

To Whom It May Concern:

A. Statement of Interest

RVDA – the National RV Dealers Association -- represents an industry with over 3,100 RV dealerships 

with annual sales over $19 billion dollars employing almost 43,000 individuals with a payroll in excess 

of $1.6 billion dollars (2007 Economic Census). RVDA’s membership sells roughly 80% of national 

travel trailer sales, and 90% of motor home sales. The vast majority of our dealer members are small 

businesses as defined by the Small Business Administration.

RVDA is supportive of the efforts to make our country cleaner and our vehicles more fuel efficient. 

The RV lifestyle is complementary with EPA’s goals of a healthy outdoors environment and 

appreciation for the natural beauty of the United States. A cleaner environment benefits all of us. 

However, RVDA believes that this regulation, as proposed, will have a material negative impact on RV 

industry sales, and related RV industry jobs.
RVDA Comments – January 31, 2011– EPA/NHTSA Greenhouse Gas Emission Standards for RVs

2

B. RVs are a Discretionary Recreation Lifestyle, Not A Commercial Enterprise

Recreation vehicles are not commercial vehicles. Unlike commercial trucks, RV enthusiasts are not on 

the road in the same manner as commercial vehicle drivers. RVs driven by their owners are not subject 

to federal FMCSA requirements requiring special licenses, logs of hours, safety inspections and health 

and alcohol/drug related certifications. Individuals who purchase an RV enjoy the ability to travel to 

their favorite locations with their own personal belongings. RVs contain beds, bathrooms, kitchens, 

entertainment systems, and offer people the ability to travel with their pets and the ability to sleep in a 

remote location, or to camp in an RV park with all the electric and plumbing hookups. Industry 

estimates are that the average RV user will take four to five trips per year. This is in no way analogous 

to a commercial enterprise or commercial purpose for an RV.

There is a niche RV lifestyle for fulltime RV enthusiasts, nicknamed “fulltimers,” who travel from 

place to place to enjoy different locations. Of all the RV owners, fulltimers are the individuals who 

travel most extensively on the nation’s highways. According to a 2005 Escapees’ RV Club 

demographic survey, the average number of miles traveled per year by their fulltimer members was 

only 11,821 miles (10,000 median).1 This is in stark contrast to the sheer number of commercial truck 

drivers on the road, and their annual mileage. According to the American Trucking Association, Class 

8 truck drivers will average over 45,000 miles behind the wheel, and most individual long-haul drivers 

average from 100,000 to 110,000 miles driving per year.2 Therefore, the highest users of RVs, which is 

a very small niche of the RV industry, drive only a quarter of the annual mileage of a Class 8 Driver, 

and one-tenth the mileage of a long-haul driver.

Motorhome sales in 2007, 2008 and 2009 were 55,400, 28,300 and 13,200, respectively3

Medium- and heavy-duty trucks sales in 2007, 2008 and 2009 were 8,668,292, 6,526,974, and 

4,966,803, respectively4

RVs are discretionary purchases and this is a critical difference because potential motorhome buyers 

are much more likely to defer or abandon purchasing a motorhome due to economics. This was evident 

during the recent recession when motorhome sales fell 49% in 2008 and 53% in 2009 while sales for 

medium- and heavy duty trucks in total fell only 25% and 24%, respectively during the same period.

C. EPA’s Regulation Further Injures the Recovering RV Industry

The RV industry lost tens of thousands of jobs during the recession and is only now slowly refilling 

those positions. Creating unnecessary regulatory burdens on small businesses which produce and retail 

discretionary vehicles that average some 4,500 to 5,000 miles per year is unreasonable.

In 2009, President Barack Obama visited Elkhart County, Indiana, the so-called RV manufacturing 

capital of the world, to pitch his stimulus package. White House spokesman Robert Gibbs said Obama 

wanted to go where the nation's economic problems are “acute” as part of “his effort to convince 

 

1

http://www.escapees.com/edocs/demographics.pdf

2

http://www.truckline.com/Programs/Documents/Image%20Tools%20and%20Information/Trucking%20Industry.pdf

3 RVIA Industry Profile 2009. 

4 Automotive News Data Center.
RVDA Comments – January 31, 2011– EPA/NHTSA Greenhouse Gas Emission Standards for RVs

3

Congress to move swiftly” to pass the stimulus package. At the time of the president's visit, the 

unemployment rate in Elkhart County was 17.5 percent. Last year in 2010, the unemployment rate was 

down to 14 percent, still well above the national average, but moving in the right direction.

D. EPA Should Strongly Consider President Obama’s Recent Executive Order

President Obama’s Presidential Memoranda - Regulatory Flexibility, Small Business, and Job Creation

dated January 18, 2011, in part states...

Accordingly, I hereby direct executive departments and agencies and request independent 

agencies, when initiating rulemaking that will have a significant economic impact on a 

substantial number of small entities, to give serious consideration to whether and how it is 

appropriate, consistent with law and regulatory objectives, to reduce regulatory burdens on 

small businesses, through increased flexibility. As the RFA recognizes, such flexibility may take 

many forms, including:

•extended compliance dates that take into account the resources available to small 

entities;

•performance standards rather than design standards;

•simplification of reporting and compliance requirements (as, for example, through 

streamlined forms and electronic filing options);

•different requirements for large and small firms; and

•partial or total exemptions.

I further direct that whenever an executive agency chooses, for reasons other than legal 

limitations, not to provide such flexibility in a proposed or final rule that is likely to have a 

significant economic impact on a substantial number of small entities, it should explicitly justify 

its decision not to do so in the explanation that accompanies that proposed or final rule.

EPA’s proposal will have an impact on a substantial number of RV manufacturers, and a substantial 

impact on RV sales. NHTSA has already chosen to exempt RVs from this regulation, and EPA’s 

inclusion of RVs is very surprising considering the small size of the RV market served in comparison 

to the size of the commercial trucking industry. 

Given the fact that EPA has decided to apply its standards to non-commercial vehicles while NHTSA 

has decided to do exactly the opposite, the proposal is clearly not in keeping with the President’s 

directive that federal agencies harmonize their requirements. If the agencies are going to comply with 

the Executive Order, they must have a common position with respect to the treatment of noncommercial vehicles. 

E. The Energy and Independence Security Act of 2007

The issue of non-commercial vehicles was addressed by Congress when it created the Energy and 

Independence Security Act of 2007 (EISA). By limiting the medium- and heavy-duty vehicle fuel 

consumption mandate to commercial trucks, EISA reflected and appropriately dealt with the important 

distinctions that exist between commercial and non-commercial vehicles. 
RVDA Comments – January 31, 2011– EPA/NHTSA Greenhouse Gas Emission Standards for RVs

4

RVDA recognizes that EPA is not bound by the EISA mandate, however, for the reasons discussed 

previously we believe that the rule will impact private individuals (purchasers of non-commercial 

vehicles) in a manner that is very different from the way in which it will impact commercial businesses 

and that it would therefore be inappropriate to extend the applicability of the requirements to noncommercial vehicles.

F. Regulatory Flexibility Act Requirements

EPA will need to address the Regulatory Flexibility Act (“RFA”) requirements for this proposal on the

RV industry, including RV manufacturers and RV dealers. The key requirement of the law is that 

federal agencies must analyze the impact of their regulatory actions on small businesses and, where the 

regulatory impact is likely to be "significant", affecting a "substantial number" of these small entities, 

seek less burdensome alternatives for them. This regulation will have an impact on the entire RV

industry, made up of RV manufacturers and RV dealers.

RVDA feels that should EPA intend to cover recreational vehicles under this proposal, then it must 

perform a separate and detailed Regulatory Flexibility Analysis on the rules impact on non-commercial 

industries, i.e. the RV industry. The EPA must assess the economic impact that is specific to noncommercial vehicles and it should not attempt to apply a cost-benefit assessment for commercial 

vehicles to personal use vehicles such as motorhomes. 

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.

Likewise the EPA will need to address the costs for a limited non-commercial market segment to

comply with the costs the EPA intends place on the commercial trucking industry. Using industry

estimates, the average RV owner takes four to five trips per year, for generally less than 5000 miles

total. RVDA believes that once the EPA performs this analysis, it will find that the dramatic costs to

the RV industry do not outweigh the limited environmental benefits.

Respectfully Submitted,

Wm. Brett Richardson

_____________________________

Wm. Brett Richardson, Esq., MBA, CAE

RVDA Director of Legal & Regulatory Affairs

3930 University Dr., Fairfax VA 22030

Brichardson@RVDA.org

(703) 591-7130