Motor & Equipment Manufacturers Association v. Environmental Protection Agency

Section 209 of the Clean Air Act (CAA) required the administrator of the Environmental Protection Agency (EPA) (defendant) to waive federal preemption of motor vehicle emission control regulations for the state of California unless he found that waiver was inappropriate. Section 202 of the CAA established nationwide motor vehicle emission standards for three major pollutants, set long-term emissions goals, and authorized the EPA administrator to prescribe standards consistent with those goals for years not covered by the statute. Under Section 206 of the CAA, the administrator was required to test or have tested any new motor vehicle or new motor vehicle engine to determine whether it conformed to Section 202 standards. Section 207 of the CAA required manufacturers to warrant to purchasers that each new motor vehicle conformed to Section 202 standards and provide a performance warranty and written maintenance instructions. One of the ways motor vehicles and engines were tested was a durability test. There were EPA regulations that limited the amount of scheduled maintenance that could be performed on the prototype during its durability test. In 1977, pursuant to Section 209, the California Air Resources Board (CARB) adopted similar regulations to the EPA limiting the amount of scheduled maintenance that could be performed on a prototype used in durability testing. CARB also decided to impose in-use maintenance regulations that limited the maintenance a manufacturer could require from a purchaser in the written instructions manufacturers had to furnish with each new motor vehicle. Under these regulations, a manufacturer could not require a purchaser to perform more maintenance than what the manufacturer could perform during the certification process. Motor & Equipment Manufacturers Association (Manufacturers) (plaintiff) requested that the administrator’s division be set aside, arguing that in-use maintenance regulations violated the federal regulatory scheme embodied in Section 207 and were not subject to waiver under subsection (b) of Section 209.