In a challenge to 2016 greenhouse gas emissions and fuel efficiency standards for medium- and heavy-duty engines and vehicles brought by the Truck Trailer Manufacturers Association, the D.C. Circuit Court of Appeals held that neither the U.S. Environmental Protection Agency (EPA) nor the National Highway Traffic Safety Administration (NHTSA) had authority to adopt standards that apply to trailers. With respect to the greenhouse gas emissions standards, the court concluded that trailers are not “motor vehicles” under Section 202 of the Clean Air Act because trailers are not “self-propelled.” EPA therefore could not rely on Section 202(a)(1) to set emission standards for trailers and require trailer manufacturers to comply with the standards. With respect to the fuel efficiency standards, the court rejected NHTSA’s argument that the term “vehicles” in the Energy Independence and Security Act of 2007 provision authorizing NHTSA to set fuel economy standards for “commercial medium- and heavy-duty on-highway vehicles” could reasonably be interpreted to include trailers. The majority determined that “[b]ecause a trailer uses no fuel, it doesn’t have fuel economy” and that in the statutory context, “nothing is a vehicle unless it has fuel economy.” Judge Millett dissented from the majority’s conclusion that NHTSA lacked authority to issue fuel economy regulations that apply to commercial trailers. She wrote that NHTSA “acted well within its delegated regulatory authority in establishing fuel efficiency requirements for the trailer portion of tractor-trailers that regularly travel the Nation’s highways.”

Challenge to greenhouse gas emissions and fuel efficiency standards for medium- and heavy-duty engines and vehicles.

Truck Trailer Manufacturers Association, Inc. v. EPA

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D.C. Circuit Vacated Greenhouse Gas and Fuel Economy Standards for Truck Trailers

Filed

United States of America

District of Columbia

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D.C. Circuit Vacated Greenhouse Gas and Fuel Economy Standards for Truck Trailers

Policy instrument

Risk

Impacted group

Fossil fuel

Greenhouse gas

Economic sector