## Facts

- California adopted regulations limiting greenhouse gas (GHG) emissions from new passenger vehicles and light trucks beginning with model year 2009.
- The regulations set emissions limits using an emissions metric (e.g., grams per mile of CO₂ and other GHGs).
- Because CO₂ emissions from gasoline combustion correlate with fuel consumption, compliance would generally require manufacturers to improve fuel economy.
- California’s program depended on obtaining an EPA waiver under Clean Air Act (CAA) § 209(b), which permits California to enforce more stringent motor-vehicle emission standards if EPA grants a waiver.
- Automobile dealers, manufacturers, and an industry association sued the CARB executive officer seeking declaratory and injunctive relief, arguing the regulations were preempted by the Energy Policy and Conservation Act (EPCA) and by federal foreign-affairs powers.
- The parties filed cross-motions for summary judgment addressing EPCA preemption and foreign policy preemption.

## Issues

1. Whether EPCA expressly or impliedly preempts California’s vehicle GHG emission standards as state fuel-economy standards or laws “related to” fuel economy.
2. Whether the California standards are preempted because they intrude on the federal government’s control over foreign affairs and international climate policy.

## Decision

- The court denied plaintiffs’ summary judgment motions on EPCA and foreign policy preemption and granted summary judgment for the state defendant and environmental intervenors on those claims.
- The court held the California standards, if implemented pursuant to a valid CAA § 209(b) waiver, are not categorically preempted by EPCA.
- The court concluded the standards regulate emissions, not fuel economy as such, even though they have a substantial practical effect on fuel economy.
- The court rejected foreign policy preemption, finding no concrete conflict with a specific federal foreign-policy instrument and noting that the federal statutory scheme contemplates California’s regulatory role.
- The enforceability of the standards remained contingent on EPA granting the CAA waiver.

## Legal Principles

- EPCA preempts state laws that directly regulate automobile fuel economy, but does not automatically preempt state emission standards adopted under the CAA framework.
- A state vehicle standard expressed as an emissions limit can qualify as an “emission standard” even if compliance typically requires fuel-economy improvements.
- Courts should construe overlapping federal statutes to avoid unnecessary conflict; EPCA should not be read to nullify CAA § 209(b)’s waiver mechanism absent a clear, irreconcilable clash.
- EPCA’s “related to” fuel economy language does not preempt every state measure that incidentally affects fuel economy; the focus is whether the state rule functionally regulates fuel economy itself.
- Foreign policy preemption requires more than a generalized foreign-affairs subject matter; it ordinarily demands a demonstrated conflict with an identifiable federal policy, agreement, or action requiring one national voice.

## Conclusion

The court held California’s vehicle GHG limits operate as emission standards within the Clean Air Act’s waiver scheme and, if supported by an EPA waiver, are not displaced by EPCA’s fuel-economy preemption clause; the court also found no basis to invalidate the standards on foreign policy preemption grounds.


Central Valley Chrysler-Jeep, Inc. v. Goldstene, 529 F. Supp. 2d 1151 (E.D. Cal. 2007)