• With the LEV program, California has used its authority as Congress envisioned: to implement more aggressive measures than the rest of the country and to serve as a laboratory for technological innovation. There have been successes, such as CARB’s early recognition of the need to couple fuel composition with emissions control, and failures, such as the promotion of widespread use of electric vehicles.

  • As a rationale for adopting California LDV standards, some states expect that California will continue to reduce standards earlier than the federal program. Some states have also adopted or expressed interest in adopting the California GHG emissions standards.

  • To date, CAA section 177 authority has been used primarily by various northeastern states to adopt California LDV standards. Manufacturers of mobile sources have raised objections to the adoption of California standards by other states. Up to this point, adopting states and manufacturers have turned to the courts to resolve their technical and legal disputes when direct negotiations have failed. Although EPA is an appropriate entity to comment on some of these disputes, it has no authority over states’ adoption decisions.



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