Enforcement of the MRB Rules Would Cause an Unreasonable Burden on Interstate Commerce The MRB Rules Are Incompatible With the Federal HOS Regulations for Passenger-Carrying CMVs The MRB Rules Have No Safety Benefits That Extend Beyond Those Provided by the FMCSRs The MRB Rules Are “Additional to or More Stringent Than” the Agency's HOS Regulations for Passenger-Carrying Vehicles Within the Meaning of Section 31141 The California MRB Rules, as Applied to Drivers of Passenger-Carrying CMVs, Are Laws or Regulations “on Commercial Motor Vehicle Safety” Within the Meaning of 49 U.S.C. Section 31141 Expressly Preempts State Law Therefore the Presumption Against Preemption Does Not Apply FMCSA's 2018 Decision Granting Petitions To Preempt the MRB Rules FMCSA's Decision Rejecting a Petition for a Preemption Determination
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