N.M. Auto. Dealers Assoc. v. N.M. Env't Improvement Bd.

CourtNew Mexico Court of Appeals
DecidedApril 8, 2026
StatusPublished

This text of N.M. Auto. Dealers Assoc. v. N.M. Env't Improvement Bd. (N.M. Auto. Dealers Assoc. v. N.M. Env't Improvement Bd.) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
N.M. Auto. Dealers Assoc. v. N.M. Env't Improvement Bd., (N.M. Ct. App. 2026).

Opinion

The slip opinion is the first version of an opinion released by the Clerk of the Court of Appeals. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Clerk of the Court for compliance with Rule 23-112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion. 1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number: __________

3 Filing Date: April 8, 2026

4 No. A-1-CA-41585

5 NEW MEXICO AUTOMOTIVE DEALERS 6 ASSOCIATION and AUTOMUNDO DE 7 GARCIA, LTD. COMPANY,

8 Appellants,

9 v.

10 NEW MEXICO ENVIRONMENTAL 11 IMPROVEMENT BOARD and 12 ALBUQUERQUE-BERNALILLO COUNTY 13 AIR QUALITY CONTROL BOARD,

14 Appellees,

15 and

16 NATURAL RESOURCES DEFENSE COUNCIL, 17 SOUTHWEST ENERGY EFFICIENCY PROJECT, 18 COALITION FOR CLEAN AFFORDABLE ENERGY, 19 350 NEW MEXICO, WESTERN RESOURCE 20 ADVOCATES, PROSPERITY WORKS, 21 CONSERVATION VOTERS NEW MEXICO, 22 SIERRA CLUB, NEW MEXICO INTERFAITH 23 POWER AND LIGHT, CENTER FOR CIVIC 24 POLICY, WESTERN ENVIRONMENTAL LAW 25 CENTER, CALSTART, NEW MEXICO 26 ENVIRONMENT DEPARTMENT, and 27 350 SANTA FE,

28 Intervenors-Appellees, 1 and

2 NICHOLAS R. MAXWELL,

3 Intervenor,

4 IN THE MATTER OF PETITION TO AMEND 5 EXISTING REGULATIONS 20.2.91 NMAC and 6 20.11.104 NMAC, NEW MOTOR VEHICLE 7 EMISSION STANDARDS.

8 APPEAL FROM ENVIRONMENTAL IMPROVEMENT BOARD and 9 THE ALBUQUERQUE BERNALILLO AIR QUALITY CONTROL BOARD 10 Felicia Orth, Administrative Hearing Officer

11 Atler Law Firm, P.C. 12 Timothy J. Atler 13 A. Howland Swift 14 Jazmine J. Johnston 15 Albuquerque, NM

16 Domenici Law Firm, P.C. 17 Pete Domenici 18 Albuquerque, NM

19 for Appellants

20 Raúl Torrez, Attorney General 21 Ellen Venegas, Assistant Solicitor General 22 Blaine N. Moffatt, Division Director 23 Seth C. McMillan, Deputy Solicitor General 24 Santa Fe, NM

25 for Appellee New Mexico Environmental Improvement Board

26 Antoinette Sedillo Lopez 27 Albuquerque, NM

28 for Appellee City of Albuquerque-Bernalillo County Air Quality Control Board 1 Baake Law, LLC 2 David R. Baake 3 Las Cruces, NM

4 for Intervenors-Appellees Southwest Energy Efficiency Project, 5 350 New Mexico, Western Resource Advocates, 6 Prosperity Works, Conservation Voters New Mexico, 7 Sierra Club, New Mexico Interfaith Power and Light, 8 Center for Civic Policy, Western Environmental 9 Law Center, and 350 Santa Fe

10 Andrew P. Knight, Assistant General Counsel 11 Brecken L. Scott, Assistant General Counsel 12 Santa Fe, NM

13 for Intervenor-Appellee New Mexico Environment Department

14 Charles de Saillan 15 Santa Fe, NM

16 for Intervenor-Appellee Coalition for Clean Affordable Energy

17 Vivian Wang 18 Alexis Mena 19 New York, NY

20 for Intervenor-Appellee Natural Resources Defense Council 1 OPINION

2 YOHALEM, Judge.

3 {1} Appellants New Mexico Automotive Dealers Association and Automundo De

4 Garcia, Ltd. Co. (collectively, Auto Dealers) appeal the adoption of the State of

5 California’s Advanced Clean Cars II (ACC II) new motor vehicle emission control

6 standards for model years 2027 through 2032 by the New Mexico Environmental

7 Improvement Board (EIB) and the Albuquerque-Bernalillo County Air Quality

8 Control Board (AQCB) 1 (collectively, the Boards). 2 See 20.2.91 NMAC (7/1/2022

9 as amended through 12/31/2023) (EIB statewide regulations); 20.11.104 NMAC

10 (7/1/2022 as amended through 12/31/2023) (AQCB regulations). The regulations

11 provide, in relevant part, that an increasing percentage of new vehicles provided to

12 New Mexico in each model year, beginning with model year 2027, must be zero

13 emission vehicles (ZEVs).3 Auto Dealers challenge the validity of these regulations

1 Regulations adopted by the EIB apply to all nontribal areas of the State of New Mexico, with the exception of the City of Albuquerque and Bernalillo County, where the regulations adopted by the AQCB apply. See NMSA 1978, §§ 74-2-4, -5(B) (2021); Albuquerque, N.M., Rev. Ordinance of Albuquerque, ch. 9, art. 5, §§ 9-5-1-4(B), -6 (1974, amended 1993); Bernalillo County, N.M., Code of Ordinances, ch. 30, art. II, §§ 30-33, -35 (1994). 2 Intervenors-Appellees Climate Advocates and the New Mexico Environment Department (NMED) are also parties to this appeal. They have filed briefs on appeal arguing in favor of the validity of the regulations, which we have reviewed and considered. 3 The EIB and AQCB regulations incorporate by reference Title 13 of the California Code of Regulations’ new vehicle emission control standards for model years 2027 through 2032. See 20.2.91.101(A) NMAC; 20.2.91.102 NMAC; 1 under both the federal Clean Air Act (CAA), Pub. L. 101-549, 104 Stat 2399 (1990),

2 42 U.S.C. §§ 7401-7671q, and the New Mexico Air Quality Control Act (AQCA),

3 NMSA 1978, §§ 74-2-1 to -17 (1967, as amended through 2021). Not persuaded by

4 Auto Dealers’ arguments, we affirm.4

5 BACKGROUND

6 The Federal Regulatory Scheme Governing Vehicle Emissions

7 {2} The CAA directs the EPA to adopt regulations setting emission control

8 standards for new motor vehicles nationwide. See 42 U.S.C. § 7521(a). To ensure

20.11.104.101(A) NMAC, 20.11.104.102 NMAC; see also Cal. Code Regs., tit. 13, § 1962.4(c)(1)(B) (2022) (mandating 43 percent ZEV manufacturing percentage requirement at model year 2027 and 82 percent by model year 2032). Because the regulations adopted by the EIB and the AQCB relevant to this appeal are identical and were adopted following a joint public hearing where the Boards heard the same evidence, we discuss the regulations together, and do not generally distinguish between the EIB and the AQCB. 4 We note that Auto Dealers previously filed a motion to stay this appeal with this Court. Auto Dealers’ request for a stay was based on pending litigation in federal court in California challenging Congress’s authority to withdraw by Congressional resolution a waiver previously granted to California by the Environmental Protection Agency (EPA). New Mexico, along with California and a number of other states, is a party-plaintiff in that lawsuit. See Complaint for Declaratory and Injunctive Relief, State of Cal. v. United States, No. 3:25-cv-04966 (N.D. Cal. June 12, 2025). We acknowledge that the outcome of this pending litigation is uncertain, and some or all of the New Mexico regulations at issue in this appeal could possibly be invalidated. We nevertheless denied the stay. We were persuaded by the Boards’ and Intervenors’ request that we proceed to decide this appeal so that automobile manufacturers and other interested parties are on timely notice of New Mexico’s choice of the California ACC II standards, and so that New Mexico will be ready to enforce the ZEV standards without the confusion and delay that would be created by having to wait for this appeal to be resolved should the federal courts allow the ACC II standards to be implemented. 1 national uniformity, Congress preempts state law concerning new vehicle emissions,

2 preventing each state from setting its own standards. See 42 U.S.C. § 7543(a).

3 Congress makes one exception, which is central to this case: the EPA is authorized

4 to grant a waiver of preemption to California—the only state having vehicle

5 emission standards in place prior to the enactment of the CAA.

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