Jump to Navigation
Jump to Content

Central Valley Chrysler Jeep v. Goldstene

ELR Citation: 37 ELR 20309
Nos. No. CV F 04-6663, 529 F. Supp. 2d 1151/(E.D. Cal., 12/11/2007)

A federal district court upheld California’s authority to regulate greenhouse gas emissions from motor vehicles, rejecting an industry association's challenge based on the preemptive effect of both the Energy Policy and Conservation Act (EPCA) and federal foreign policy. Where the U.S. Environmental Protection Agency (EPA) regulations under the Clean Air Act (CAA) incidentally require greater fuel efficiency than that required by the National Highway Traffic Safety Administration (NHTSA) pursuant to the EPCA, such overlap does not preclude EPA from promulgating emissions control regulations. Where a regulation promulgated by California is granted a waiver of preemption under §209 of the CAA, it becomes a "law of the Government" under the EPCA and must be considered by NHTSA in setting fuel economy standards. The EPCA does not invalidate the California regulations through either express or conflict preemption, and there is not sufficient evidence to support a claim of foreign policy preemption. The court's analysis does not consider the extent to which California’s standards are "federalized" when approved by EPA as set forth by the Vermont federal district court in Green Mountain Chrysler Plymouth, but describes the approach as an alternative ground for upholding California’s regulations.