Central Valley Chrysler-Jeep, Inc. v. Goldstene (2007)

State AGs intervened in lawsuit to defend California’s greenhouse gas emission standards for motor vehicles against challenge alleging that the standards are preempted by the Energy Policy and Conservation Act (EPCA).

Citation: Central Valley Chrysler-Jeep, Inc. v. Goldstene, 529 F. Supp.2d 1151 (2007)

Topic: Climate Change Mitigation

Type of Action: Defense of State Rule

States involved: California, Connecticut, Maine, Massachusetts, New Jersey, New York, Oregon, Rhode Island, Vermont, Washington

Summary: Automobile manufacturers filed lawsuit contending that California’s proposed motor vehicle greenhouse gas emission standards were preempted by the exclusive grant of fuel efficiency standard setting granted to the National Highway Traffic Safety Administration (NHTSA) under the EPCA. One key question in this case was whether the standards qualified as “emission standards” under the Clean Air Act (CAA) or “fuel economy standards” under the EPCA. Both the CAA and EPCA contain express preemption provisions which forbid states from adopting more stringent standards than those established by the federal government. However, the CAA contains a provision allowing California to apply for a waiver to establish more stringent emission standards, whereas the EPCA does not provide for any such waiver. The court held that California’s proposed standards were ultimately aimed at reducing emissions and not regulating fuel economy, and thus they were emission standards that were not preempted by the EPCA. The court also noted that a waiver from the EPA under the Clean Air Act gives this regulation a federal stamp-of-approval which insulates it from any preemption concerns.

Key Documents:

• Decision