"The RV.NET discussion I referred to, Andy, revolves around this
document where the NHTSA became involved in the definitions of CCC..."

Thanks for the clarification, Ed! I read that rv.net thread several
times and *thought* I'd followed all the links, but somehow I missed
the one to the 26-page NHTSA rulemaking.

Meanwhile, this reply from Steve Newton at Lazy Daze confirms what you
said:

"The previous weight standards and weight labels were mandated by
RVIA. All RVIA members were required to post labels in each coach
using their format. However last year NHTSA determined that since not
all RV manufacturers are in RVIA they wanted to level the playing
field. Consequently, they mandated their own standards which apply to
all manufacturers. Their requirements are completely different than
the now defunct RVIA standard previously in use."

I question the argument that the new system more accurately reflects
the way we used to do the calculations. Before, you took the CCC and
subtracted 154 pounds times the number of unoccupied seats. Now, you
take the CCC and add 154 pounds times the number of *occupied* seats.
Similarly, if you travel with a half-empty water tank, you used to add
the weight of half a tank of water to the CCC. Now you subtract it.
You're doing exactly the same calculations--just changing plus to
minus and vice versa. There's no advantage to the consumer that I can see.

There's a big advantage to the RV industry, though: the new NHTSA
rules allow them to revise their CCC numbers drastically upward,
without doing a thing to improve the actual cargo capacities. ;-) Lazy
Daze didn't need any help in that regard, but some RVs from other
makers had CCC numbers so pathetic that they'd do anything to conceal
them. Now they won't have to try as hard. In fact, popup camper
manufacturers won't have to try at all: as I read the new NHTSA rules,
they're exempted from posting CCCs. I'll bet they love that!

I suggested to Steve that it would be a good idea to add a note to the
2009 LD datasheet, explaining that the CCC numbers have changed but
the cargo capacity hasn't. Otherwise people who are trying to decide
between buying a used 2008 and a new 2009 are going to get a VERY
wrong impression. :-(

Andy Baird
http://www.andybaird.com/travels/