Truck Trailer Manufacturers Association, Inc. v. Environmental Protection Agency, No. 16-1430 (D.C. Cir. 2021)Annotate this Case
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.” The “Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2.” 81 Fed. Reg. 73,478, requires trailer manufacturers to adopt some combination of fuel-saving technologies, such as side skirts and automatic tire pressure systems. Truck Trailer Manufacturers Association sought review.
The D.C. Circuit vacated all portions of the rule that pertain to trailers. Trailers have no motor and art 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.