The city of Lodi, California enacted what the federal appeals court labeled an "innovative" ordinancea town version of CERCLA called MERLO (Municipal Environmental Response and Liability Ordinance). MERLO allowed Lodi to conduct environmental investigations and impose liability for contamination of its soil and groundwater. In an effort to rid its drinking water of various cancer-causing chemicals, Lodi attempted to impose remediation liability on a nameplate-etching company, among others. This company was insured by Fireman's Fund, which sued to avoid liability. CERCLA contains a provision allowing states to pass toxic cleanup acts, but says nothing about the right of a municipality to do so. Fireman's Fund argued that this statutory silence implicitly barred Lodi's effort at lawmaking.

Can local governments enforce CERCLA-like ordinances?Explain your answer.