Scopelitis, Garvin, Light, Hanson & Feary, P.C.


News & Analysis

Publication Details

Transportation Brief: U.S. EPA Enforcement of California Air Resources Board (CARB) Regulations Outside of California

by Kelli M. Block, Nathaniel G. Saylor

January 21, 2019

U.S. EPA Enforcement of California Air Resources Board (CARB) Regulations Outside of California 

Does your company hire or dispatch heavy-duty trucks to operate in California? If so, various CARB regulations may apply to your operations, even if your company is not based in California and regardless of whether it owns the trucks at issue. 

EPA has been actively enforcing CARB regulations against certain out-of-state transportation companies since 2015.  EPA enforcement efforts have thus far focused on violations of the Truck and Bus Regulation (TBR) by motor carriers (some holding dual authority as property brokers) headquartered outside of California. EPA may, however, expand the scope of its enforcement efforts at any time. 

Proper record-keeping and reporting are critical to working through the EPA audit process. If a company has not implemented a compliance plan, it may be at risk when EPA comes calling, because EPA has discretion to propose significant penalties.



Scopelitis’ Transportation Brief® is intended as a report to our clients and friends on developments affecting the transportation industry. The published material does not constitute an exhaustive legal study and should not be regarded or relied upon as individual legal advice or opinion.

© Scopelitis, Garvin, Light, Hanson & Feary, P.C. 2019. All rights reserved. 

Also in this issue: