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Allied Local and Regional Manufacturers Caucus v. EPA
United States Court of Appeals for the District of Columbia Circuit
215 F.3d 61 (2000)
The Environmental Protection Agency (EPA) (defendant) set national air-quality standards for ozone under the Clean Air Act. Ozone, a pollutant that poses hazards to human health and the environment, forms if nitrous oxides react with volatile organic compounds (VOCs). Section 183(e) of the Clean Air Act required the EPA to analyze VOC emissions from various consumer and commercial products and to regulate the products that accounted for the most VOC emissions. The EPA conducted a study and proposed rules limiting VOC emissions from architectural coatings, automobile coatings, and certain consumer products. During the public comment period, the EPA responded to concerns. Before finalizing the rules, the EPA considered alternatives to the VOC emissions limits. Allied Local and Regional Manufacturers Caucus (Allied) (plaintiff) challenged the EPA’s rule as a violation of the Regulatory Flexibility Act, which requires agencies to conduct a regulatory-flexibility analysis on a proposed rule to determine the rule’s potential impact on small businesses.
Rule of Law
Holding and Reasoning (Garland, J.)
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