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OAR Box 1142 

Prepped by Ollie Stewart 

Document Number: 

8) IV-F-6 

Docket Number: 

A-87-11 

Printed 4/23/2008 10:21:21 AM Sheet 8 of 30 
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A-87-11 

Recreation Vehicle Industry Association 

P.O. Box 2999 • 1896 Preston White Drive • Reston, Virginia 22090-0999 

TELEPHONE (703) 620-6003 • TELEFAX (703)620-5071 

SEPTEMBER 26,1991 

^TESTIMONY OF THE RECREATION VEHICLE INDUSTRY ASSOCIATION 

\ ON THE CONTROL OF AIR POLUTION FROM NEW MOTOR VEHICLES 

AND NEW MOTOR VEHICLE ENGINES; REFUELING EMISSION 

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 REGULATIONS FOR GASOLINE-FUELED LIGHT DUTY VEHICLES AND 

~ W n # : TRUCKS AND HEAVY DUTY VEHICLES 

%A A , 

< ^ (Public Docket No. A-87-11) 

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•> /Iam Edward F. Conway, Jr., and I serve as Assistant General Counsel of the 

Recreation Vehicle Industry Association. 

RVIA is the national trade association representing over 500 manufacturers 

of recreation vehicles and their related suppliers. Its 209 manufacturer 

members produce approximately 95 percent of all recreation vehicles (RVs) 

purchased in the United States. RVIA's 71 motor home manufacturer 

members, many of which are small business entities, produce approximately 

99 percent of the motor homes produced in the United States. 

RVIA's 118 custom van conversion members, most of which are small 

business entities, produce approximately 80 percent of the custom van 

conversions produced in the United States. The remaining 20 percent of 

custom van conversions are produced by more than 2000 non-member 

manufacturers, most of whom presumably are also small business entities. 

Motor homes are vehides that provide temporary living quarters for 

camping, recreation and seasonal use. They are manufactured on chassis 

supplied by the automotive companies. They are, in fact, motorized "houses" 

on wheels with living facilities powered by 12-volt and 110 volt electrical 

systems and by LP-Gas systems. Motor home living facilities include cooking 

stoves and microwave ovens, refrigerators, television sets and VCRs, stereos 

and compact disc players, self-contained toilets, showers, heating and air 

conditioning, and potable water supply systems that have sinks and faucets 

and waste water holding tanks. Many motor homes also have two large fuel 

tanks and an electric generator. 

Custom van conversions are passenger vans that have been modified to 

provide minimum living facilities such as an LP-gas fueled refrigerator and 

stove and 110-volt electrical systems or to provide sleeping or other 

temporary living quarters for recreation or travel. 

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WESTERN OFFICE: 1748 W.Katella Ave., Suite 108 • Orange. CA 92667-3429 • PHONE (714)532-1688 • FAX (714) 532-9573 
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Accordingly, the fuel systems of these complex, compact vehicles must be 

carefully designed so that in the event of a collision or other accident the 

likelihood of fire is minimized. 

In recent years, motor home and customized van conversion manufacturers 

have with considerable effort and expense devised protective measures to 

safeguard the electrical and LP-Gas systems and the "house" furnishings of 

their vehicles (such as beds, sofas, carpeting, wooden cabinets and accessories) 

from the high temperatures generated by the currently required air pollution 

control devices that could otherwise produce fires. 

To require a large, complex onboard refueling vapor recovery system in these 

already complex, compact vehicles that are also used to provide sleeping 

and/or temporary living quarters would greatly increase the danger of 

disastrous fires that could result in numerous fatalities. 

It is our understanding that the onboard refueling vapor recovery system 

would require additional valves, including a nozzle-actuated tank vent valve 

assembly, a vapor-liquid separator, a vent/rollover valve, and also a large 

cannister (or cannisters) which, depending on the size of the fuel tank, would 

be three to twelve times the volume of the currently required cannister. 

Moreover, the vapor recovery lines would be much larger than those 

currently in use. 

The onboard refueling vapor recovery system would severely reduce the 

already limited availability of adequate and safe space for the motor home 

and custom van conversion manufacturer to install LP-Gas, electrical and 

other vital systems. As a result, the unavoidably close proximity of those 

systems to a required onboard refueling vapor recovery system would greatly 

increase the danger of disastrous fires if that system malfunctions or the 

vehicle is involved in an accident. For example, outwardly undetectable 

impairment of the recovery system's mechanical nozzle seals, vapor liquid 

discriminators, or pressure relief valves could result in loss of fuel system 

integrity during vehicle impact. 

Each manufacturer develops its own floor plans and production methods. 

The packaging and placement of an onboard refueling vapor recovery system 

for permanent installation when the chassis is manufactured or of a system 

designed to be subsequently installed during a vehicle's final stage of 

manufacture, poses severe difficulties for which there is no apparent 

solution. 

There is very little free space available for a practical, permanent installation 

when the chassis is manufactured that would not seriously impair the ability 

of final stage manufacturers to produce varied floor plans to meet consumer 
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needs. Moreover, the lack of complete and adequate information on how the 

onboard system would affect other systems and components of their vehicles 

would thwart the efforts of both chassis and final stage manufacturers to 

produce a safe product. This in turn would greatly increase their exposure to 

product liability lawsuits. 

The alternative of having the motor home or custom van conversion 

manufacturer develop refueling vapor recovery systems tailored to 

accommodate varying floor plans would be inordinately time-consuming and 

cost-prohibitive and would be beyond the expertise of most manufacturers. 

The alternative of having the motor home or custom van conversion 

manufacturer complete the installation of refueling vapor recovery systems 

that were partially installed by chassis manufacturers would also be beyond 

their expertise. 

The safety assessment of onboard refueling vapor recovery systems conducted 

by the National Highway Traffic Safety Administration found that these 

systems would not only significantly increase the amount of fuel vapor stored 

onboard vehicles in cannisters but would also increase the risk of a fire 

occurring. 

That assessment also found that control of gasoline vapors at the fuel pump 

("Stage II") is a viable alternative to onboard refueling vapor recovery systems 

and that gasoline stations equipped with Stage II have a lower risk of fire than 

non-equipped gasoline stations. It also noted that a 1985 study by the 

California Air Resources Board found that the Stage II systems are more 

effective in controlling refueling vapors. Stage II systems have been in use in 

California since 1976. 

Onboard refueling vapor recovery systems that impose an unreasonable 

safety risk on consumers and are cost prohibitive to vehicle manufacturers 

and would also greatly increase their product liability exposure should not be 

required, especially when a safe, practical, cost-efficient and proven 

alternative such as "Stage II" is readily available. 

Accordingly, RVIA strongly urges that onboard refueling vapor recovery 

systems not be required on motor homes, custom van conversions and other 

vehicles. 

Thank you for your attention and for the opportunity to present the concerns 

of the manufacturers of motor homes and custom van conversions.