Sierra Club v. Environmental Protection Agency

The Washington, D.C. Metropolitan Area consisted of the District of Columbia and several counties in Maryland and Virginia. In 1991, the Environmental Protection Agency (EPA) (defendant) declared the Washington Area to be in serious nonattainment of the National Ambient Air Quality Standard (NAAQS) for ozone. Pursuant to the Clean Air Act (CAA), if an area did not meet the NAAQS, the EPA would designate it as one of nonattainment. All states were required to revise their state implementation plans (SIPs) to bring any areas of serious nonattainment into attainment by November 15, 1999. The District of Columbia Department of Health, the Maryland Department of the Environment, and the Virginia Department of Environmental Quality (the states) submitted nonattainment SIPs for the Washington area. The SIPs did not provide for attainment by November 15, 1999, and instead requested the EPA to extend the attainment deadline for the Washington area until November 15, 2005. The EPA determined that because the Washington area was a downwind area, the transport of ozone from upwind areas could delay the date by which the Washington area would reach attainment and granted the states’ SIPs, including the request for an extension. The Sierra Club (plaintiff) petitioned for a review of the EPA’s decision to approve the deadline-extension requests in the states’ SIPs.