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Sierra Club v. Ruckelshaus
United States District Court for the District of Columbia
344 F. Supp. 253 (1972)
The Clean Air Act (CAA) required states to meet national ambient air quality standards (NAAQS). The CAA did not provide separate requirements for states that already had air quality better than required by the NAAQS. The CAA contained a state implementation plan (SIP) provision that only explicitly required states to adopt SIPs that provided for the attainment of primary and secondary NAAQS. In 1972, the Administrator of the Environmental Protection Agency (EPA) stated before Congress that he did not have the legal authority under the CAA to require anything from the states beyond compliance with the NAAQS. States could implement more stringent air pollution controls than the NAAQS, but environmentalists were concerned that firms would relocate in clean air areas with lower costs and standards of air pollution control, and thus quickly reduce the air quality to the minimum NAAQS level. The Sierra Club (plaintiff) brought suit in district court to challenge the Administrator’s interpretation of the CAA, arguing that permitting states with better air quality than required by NAAQS to submit SIPs that would allow air quality to deteriorate to NAAQS levels was contrary to the policy of the CAA.
Rule of Law
Holding and Reasoning (Pratt, J.)
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