Comments submitted to EPA on behalf of CAELP, NRDC, and EDF opposing the agency’s proposed disapproval of California’s state plan submission including its heavy duty inspection/maintenance regulation (“Clean Truck Check”). Comments argue that EPA misapplied the provision of the Clean Air Act requiring state plans to include “necessary assurances” that included measures are not prohibited by law. Comments further refute EPA’s claims that the Clean Truck Check contravenes the Clean Air Act, the dormant Commerce Clause, and the federal government’s foreign-affairs authority.
This resource was commissioned by or produced by staff of the Center for Applied Environmental Law and Policy before the organization rebranded as Ridgeline Center for Law and Policy in 2026.