ILMA Compoundings – October 2019 - 48

WASHINGTON LANDSCAPE

How Automakers Deal
With California May
Spread to Other States
By Matthew Levetown

A

s part of my duties for ILMA, I
regularly read a broad crosssection of news, looking for and
then reporting on items that are important to members. The sources I check
range from regulatory actions to court
decisions to geopolitical situations affecting base oil pricing. Back in July, I wrote a
piece about something I find particularly
interesting as a young lawyer: automakers
bypassing looser federal regulations to
deal directly with state regulatory bodies
for more stringent requirements.
The article back then, "California
Signs Deal with Automakers to Produce
Fuel-Efficient Cars"1 detailed four major
automakers' (Ford, BMW, Honda and
Volkswagen) agreement with California
to adhere to strict vehicle emissions
requirements. The deal followed the
Trump administration's announcement
of a plan to freeze Obama-era emissions
rules, and California was unsurprisingly
unable to convince the EPA otherwise.
The Obama-era rule was designed to
prevent confusion over dueling state and
federal requirements, which are allowed
under the provisions of the Clean Air Act.
HONING THE RULE
California's agreement requires the four
automakers to reach a mileage standard
of around 50 miles per gallon (mpg)
by 2026 through a combination of climate-friendly technology adaptation and
the development of new vehicle parts.
The California plan is less restrictive

48

OCTOBER 2019

| COMPOUNDINGS | ILMA.ORG

than the Obama EPA rules, which did
not provide credits and required a corporate average of 54.5 mpg by 2026.
Under the Clean Air Act, California
is able to implement its own emissions
rules, which since then have been
adopted by about a dozen states. The
Trump administration's proposal
would freeze the federal emissions
standards at 37 mpg for autos built
after 2020, far below the agreement.
Instead, by working with the state,
the automakers came out somewhere
between the Obama and Trump emissions standards, with more options
and alternatives to meeting the rule
with purely increased engine efficiency.
Negotiating with a state or local
regulatory body is nothing new. After

all, it was ILMA's work with the South
Coast Air Quality Management District that led to a Rule 1144 that was
more finely tuned than the agency's
original proposal. If a governing entity
is going to regulate anyway, it makes
sense to work with it to craft a rule
that meets everyone's objectives -
the agency regulates, and businesses
manufacture without undue burden.
The question is whether subnational
governments and coalitions will
continue to take the lead in passing
environmental rules, similar to states
forming the U.S. Climate Alliance
after the federal government left the
2015 Paris Agreement.
In California's case, it manages
to make deals because it is the most


http://www.ILMA.ORG

ILMA Compoundings – October 2019

Table of Contents for the Digital Edition of ILMA Compoundings – October 2019

LETTER FROM THE PRESIDENT
LETTER FROM THE CEO
INSIDE ILMA
WHAT’S COMING UP
NEW MEMBERS
INDUSTRY RUNDOWN
In the Know
International Insight
Market Report
THE ART OF APPRENTICESHIPS
SPEAKING A DIFFERENT LANGUAGE
ANNUAL MEETING SPEAKER SPOTLIGHT
BUSINESS HUB
COUNSEL COMPOUND
WASHINGTON LANDSCAPE
IN NETWORK
Member Connections
Cross Connections
PORTRAIT
ILMA Compoundings – October 2019 - Cover1
ILMA Compoundings – October 2019 - Cover2
ILMA Compoundings – October 2019 - 1
ILMA Compoundings – October 2019 - 2
ILMA Compoundings – October 2019 - 3
ILMA Compoundings – October 2019 - 4
ILMA Compoundings – October 2019 - LETTER FROM THE PRESIDENT
ILMA Compoundings – October 2019 - 6
ILMA Compoundings – October 2019 - LETTER FROM THE CEO
ILMA Compoundings – October 2019 - 8
ILMA Compoundings – October 2019 - 9
ILMA Compoundings – October 2019 - INSIDE ILMA
ILMA Compoundings – October 2019 - 11
ILMA Compoundings – October 2019 - WHAT’S COMING UP
ILMA Compoundings – October 2019 - 13
ILMA Compoundings – October 2019 - 14
ILMA Compoundings – October 2019 - NEW MEMBERS
ILMA Compoundings – October 2019 - INDUSTRY RUNDOWN
ILMA Compoundings – October 2019 - 17
ILMA Compoundings – October 2019 - 18
ILMA Compoundings – October 2019 - In the Know
ILMA Compoundings – October 2019 - International Insight
ILMA Compoundings – October 2019 - 21
ILMA Compoundings – October 2019 - 22
ILMA Compoundings – October 2019 - 23
ILMA Compoundings – October 2019 - Market Report
ILMA Compoundings – October 2019 - 25
ILMA Compoundings – October 2019 - THE ART OF APPRENTICESHIPS
ILMA Compoundings – October 2019 - 27
ILMA Compoundings – October 2019 - 28
ILMA Compoundings – October 2019 - 29
ILMA Compoundings – October 2019 - 30
ILMA Compoundings – October 2019 - 31
ILMA Compoundings – October 2019 - SPEAKING A DIFFERENT LANGUAGE
ILMA Compoundings – October 2019 - 33
ILMA Compoundings – October 2019 - 34
ILMA Compoundings – October 2019 - 35
ILMA Compoundings – October 2019 - 36
ILMA Compoundings – October 2019 - 37
ILMA Compoundings – October 2019 - ANNUAL MEETING SPEAKER SPOTLIGHT
ILMA Compoundings – October 2019 - 39
ILMA Compoundings – October 2019 - BUSINESS HUB
ILMA Compoundings – October 2019 - 41
ILMA Compoundings – October 2019 - 42
ILMA Compoundings – October 2019 - 43
ILMA Compoundings – October 2019 - COUNSEL COMPOUND
ILMA Compoundings – October 2019 - 45
ILMA Compoundings – October 2019 - 46
ILMA Compoundings – October 2019 - 47
ILMA Compoundings – October 2019 - WASHINGTON LANDSCAPE
ILMA Compoundings – October 2019 - 49
ILMA Compoundings – October 2019 - Member Connections
ILMA Compoundings – October 2019 - 51
ILMA Compoundings – October 2019 - Cross Connections
ILMA Compoundings – October 2019 - 53
ILMA Compoundings – October 2019 - 54
ILMA Compoundings – October 2019 - 55
ILMA Compoundings – October 2019 - 56
ILMA Compoundings – October 2019 - 57
ILMA Compoundings – October 2019 - 58
ILMA Compoundings – October 2019 - 59
ILMA Compoundings – October 2019 - PORTRAIT
ILMA Compoundings – October 2019 - Cover3
ILMA Compoundings – October 2019 - Cover4
https://www.nxtbook.com/ygsreprints/ILMA/G124996_ILMA_vol71_no4
https://www.nxtbook.com/ygsreprints/ILMA/G123886_ILMA_vol71_no3
https://www.nxtbook.com/ygsreprints/ILMA/G123315_ILMA_vol71_no2
https://www.nxtbook.com/ygsreprints/ILMA/G122980_ILMA_vol71_no1
https://www.nxtbook.com/ygsreprints/ILMA/G121540_ILMA_vol70_no11
https://www.nxtbook.com/ygsreprints/ILMA/G120882_ILMA_vol70_no10
https://www.nxtbook.com/ygsreprints/ILMA/G120035_ILMA_vol70_no9
https://www.nxtbook.com/ygsreprints/ILMA/G121XXX_ILMA_vol70_no8
https://www.nxtbook.com/ygsreprints/ILMA/G120XXX_ILMA_vol70_no7
https://www.nxtbook.com/ygsreprints/ILMA/G119XXX_ILMA_vol70_no6
https://www.nxtbook.com/ygsreprints/ILMA/G118112_ILMA_vol70_no5
https://www.nxtbook.com/ygsreprints/ILMA/G117382_ILMA_vol70_no4
https://www.nxtbook.com/ygsreprints/ILMA/G116888_ILMA_vol70_no3
https://www.nxtbook.com/ygsreprints/ILMA/G115555_ILMA_vol70_no2
https://www.nxtbook.com/ygsreprints/ILMA/G114774_ILMA_vol70_no1
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no12
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no11
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no10
https://www.nxtbook.com/ygsreprints/ILMA/g109884_ILMA_vol69_no9
https://www.nxtbook.com/ygsreprints/ILMA/g109284_ILMA_vol69_no8
https://www.nxtbook.com/ygsreprints/ILMA/g108494_ILMA_vol69_no7
https://www.nxtbook.com/ygsreprints/ILMA/g107507_ILMA_vol69_no6
https://www.nxtbook.com/ygsreprints/ILMA/g106483_ILMA_vol69_no5
https://www.nxtbook.com/ygsreprints/ILMA/g105803_ILMA_vol69_no4
https://www.nxtbook.com/ygsreprints/ILMA/g104743_ILMA_vol69_no3
https://www.nxtbook.com/ygsreprints/ILMA/g103647_ILMA_vol69_no2
https://www.nxtbook.com/ygsreprints/ILMA/g102869_ILMA_vol69_no1
https://www.nxtbook.com/ygsreprints/ILMA/g101930_ILMA_vol68_no12
https://www.nxtbook.com/ygsreprints/ILMA/g100836_ILMA_vol68_no11
https://www.nxtbook.com/ygsreprints/ILMA/g99200_ILMA_vol68_no10
https://www.nxtbook.com/ygsreprints/ILMA/g98468_ILMA_vol68_no9
https://www.nxtbook.com/ygsreprints/ILMA/g97711_ILMA_vol68_no8
https://www.nxtbook.com/ygsreprints/ILMA/G96767ILMA_vol68_no7
https://www.nxtbook.com/ygsreprints/ILMA/G95397ILMA_vol65_no6
https://www.nxtbook.com/ygsreprints/ILMA/G94323ILMA_vol68_no5
https://www.nxtbook.com/ygsreprints/ILMA/G93127_ILMA_vol69_no4
https://www.nxtbook.com/ygsreprints/ILMA/G91785_ILMA_vol68_no3
https://www.nxtbook.com/ygsreprints/ILMA/G90956_ILMA_vol68_no2
https://www.nxtbook.com/ygsreprints/ILMA/G89146_ILMA_vol68_no1
https://www.nxtbook.com/ygsreprints/ILMA/G87981_ILMA_vol67_no12
https://www.nxtbook.com/ygsreprints/ILMA/G85409_ILMA_vol67_no11
https://www.nxtbook.com/ygsreprints/ILMA/G83595_ILMA_vol67_no10
https://www.nxtbook.com/ygsreprints/ILMA/G81672_ILMA_vol67_no9
https://www.nxtbook.com/ygsreprints/ILMA/G80238_ILMA_vol7_no8
https://www.nxtbook.com/ygsreprints/ILMA/G79388_ILMA_vol7_no7
https://www.nxtbook.com/ygsreprints/ILMA/G78361_ILMA_vol7_no6
https://www.nxtbook.com/ygsreprints/ILMA/G77448_ILMA_vol7_no5
https://www.nxtbook.com/ygsreprints/ILMA/G75899_ILMA_vol67_no4
https://www.nxtbook.com/ygsreprints/ILMA/G75036_ILMA_vol67_no3
https://www.nxtbook.com/ygsreprints/ILMA/G72720_ILMA_vol67_no2
https://www.nxtbook.com/ygsreprints/ILMA/G72220_ILMA_vol67_no1
https://www.nxtbook.com/ygsreprints/ILMA/G70970_ILMA_vol66_no12
https://www.nxtbook.com/ygsreprints/ILMA/G69813_ILMA_vol66_no11
https://www.nxtbook.com/ygsreprints/ILMA/G67522_ILMA_vol66_no10
https://www.nxtbook.com/ygsreprints/ILMA/G66343_ILMA_vol66_no9
https://www.nxtbook.com/ygsreprints/ILMA/G64859_ILMA_vol66_no8
https://www.nxtbookmedia.com