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Truck Trailer Mfrs. Ass'n v. EPA

Truck Trailer Mfrs. Ass'n v. EPA

United States Court of Appeals for the District of Columbia Circuit

September 15, 2020, Argued; November 12, 2021, Decided

No. 16-1430

Opinion

 [**469]  [*1200]  Walker, Circuit Judge: In 2016, the Environmental Protection Agency issued a rule for trailers pulled by tractors based on a statute enabling the EPA to regulate "motor vehicles." In that same rule, the National Highway Traffic Safety Administration issued fuel efficiency standards for trailers based on a statute enabling NHTSA to regulate "commercial medium-duty or heavy-duty on-highway vehicles."

Trailers, however, have no motor. They are therefore not "motor vehicles." Nor are they "vehicles" when that term is used in the context of a vehicle's fuel economy, since motorless vehicles use no fuel.

We therefore grant the petition and vacate all portions of the rule that apply to trailers.

The most widely recognized "tractor-trailer" combination is what a layperson calls a semitruck. A trailer is the back portion attached [***4]  to a motorized tractor in the front. Trailers include tanks, car carriers, logging trailers, and platforms. Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, 81 Fed. Reg. 73,478, 73,640 (Oct. 25, 2016).

In 2016, the EPA and NHTSA jointly created a rule called "Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2." Id. at 73,478. Under that rule, for the first time, those agencies set greenhouse gas emissions and fuel efficiency standards for heavy-duty trailers. The rule requires trailer manufacturers to adopt some combination of fuel-saving technologies, such as side skirts and automatic tire pressure systems.

Truck Trailer Manufacturers Association, Inc. objected to the rule and timely petitioned for review. In 2017, this court granted the Association's motion to stay [*1201]   [**470]  the EPA's portion of the rule to the extent it applies to trailers. In 2020, we stayed the compliance dates in NHTSA's portion.

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17 F.4th 1198 *; 454 U.S. App. D.C. 467 **; 2021 U.S. App. LEXIS 33585 ***; 51 ELR 20196

TRUCK TRAILER MANUFACTURERS ASSOCIATION, INC., PETITIONER v. ENVIRONMENTAL PROTECTION AGENCY, ET AL., RESPONDENTS, CALIFORNIA AIR RESOURCES BOARD, ET AL., INTERVENORS

Prior History:  [***1] On Petition for Review of an Action of the United States Environmental Protection Agency and the National Highway Traffic Safety Administration.

CORE TERMS

trailers, fuel, regulations, heavy-duty, trucks, motor vehicle, tractor-trailers, on-highway, fuel economy, manufacturers, tractor, highway, transporting, emissions, majority opinion, medium-and, rating, Independence Act, consumption, Greenhouse, self-propelled, agencies, Dictionary, compliance, medium, semitrailer, engines, new motor vehicle, authority to regulate, medium-duty

Administrative Law, Judicial Review, Standards of Review, Exceeding Statutory Authority, Transportation Law, Private Vehicles, Fuel Economy