This case addresses alleged violations of the Clean Air Act (CAA) by two Los Angeles-based consulting firms, MotorScience Inc., and MotorScience Enterprise Inc., (MotorScience) and their owner, Chi Zheng. The violations stem from the illegal import of 24,478 all-terrain, recreational vehicles into the U.S. from China without testing to ensure emissions would meet applicable limits on harmful air pollution.
MotorScience provides consulting services which enable its clients to import and sell vehicles and engines in the United States. A person may not sell or import vehicles and engines into the Unites States unless that vehicle is covered by an EPA-issued certificate of conformity (COC). Rather than handling the application process itself, an importer or manufacturer may hire a company like MotorScience to test its vehicles and prepare its application for submittal to EPAÂs Office of Transportation and Air Quality (OTAQ). When OTAQ approves an application, MotorScienceÂs client becomes the COC-holder.
MotorScience has submitted hundreds of COC applications on behalf of numerous companies, most of which are based in the PeopleÂs Republic of China. It was one of the leading firms of its kind when the recreational vehicle COC requirement came into effect in 2006. Millions of vehicles have been imported into the United States under COCs obtained from applications prepared by MotorScience.
The EPA began investigating MotorScience and Mr. Zheng in 2008. The investigation re