The Second Circuit Court of Appeals has upheld a district court ruling that New York City does not have authority under the Energy Policy and Conservation Act (EPCA) or the Clean Air Act (CAA) to force taxicab fleet owners to switch to hybrid vehicles. Metro. Taxicab Bd. of Trade v. City of New York, No. 09-2901 (2d Cir. 7/27/10). The city appealed a district court order imposing a prelimi-nary injunction on the enforcement of the city’s amended lease-rate rules for taxicabs that essen-tially mandated fuel-economy and emissions levels achievable by hybrid vehicles only. The district court held that the lease rates related to fuel-economy standards and new-vehicle emissions and were thus preempted under EPCA and the CAA. Metro Taxicab Bd. v. City of New York, 633 F. Supp. 2d 83 (S.D.N.Y. 2009).
The appellate court agreed, ruling that the lease-rate rules were preempted by EPCA, which preempts state laws that are “related to fuel economy standards,” 49 U.S.C. § 32919(a), and the CAA, 42 U.S.C. § 7543(a), which forbids states from setting emission standards for new motor vehicles. The court therefore concluded that the preliminary injunction was appropriate.