OUT THE SMOKESTACK: RETOOLING CALIFORNIA'S MARINE VESSEL RULES FOR FEDERAL AUTHORIZATION.

This article discusses the regulation of emissions from auxiliary engines on ocean-going vessels by the California Air Resources Board (CARB). It explores the response by the CARB to the harms caused by the regulatory failures at the international and national level with the Marine Vessel Rules. It also reflects on the application of the regulation by the U.S. Court of Appeals for the Ninth Circuit in the case Pacific Merchant Shipping Association v. Goldstene.