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American Trucking Associations, Inc. v. Environmental Protection Agency
United States Court of Appeals for the District of Columbia Circuit
175 F.3d 1027 (D.C. Cir. 1999)
The Clean Air Act (Act), 42 U.S.C. §§ 7408-09, delegated authority to the Environmental Protection Agency (EPA) (defendant) to promulgate implementing regulations setting national ambient air quality standards (NAAQS) for air pollutants. For each pollutant, the EPA set a primary standard to protect public health “with an adequate margin of safety,” and a secondary standard to protect the public welfare. In 1997, the EPA issued rules revising the NAAQS for particulate matter (PM) and ozone. The rules indicated that any amount of PM or ozone posed a possibility of some health risk. The rules revised the ozone NAAQS from 0.09 to 0.08, but did not explain how the new level was set or how it worked. An internal EPA report stated that threats to public health decreased with each incrementally lower concentration level. American Trucking Associations, Inc. and numerous other groups (plaintiffs) petitioned the United States Court of Appeals for the District of Columbia Circuit for review, arguing that the EPA’s PM and ozone NAAQS failed to articulate clear standards to guide the application of the relevant Act provisions.
Rule of Law
Holding and Reasoning (Per curiam)
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