Train v. Natural Resources Defense Council
United States Supreme Court
421 U.S. 60, 95 S. Ct. 1470, 43 L. Ed. 2d 731 (1975)
- Written by Elliot Stern, JD
Facts
The State of Georgia submitted to the Environmental Protection Agency (EPA) (defendant) a state implementation plan as required under the Clean Air Act detailing the state’s plan to meet national ambient air quality standards. Georgia’s plan called for emission limitations that would go into effect immediately. The plan also provided for a procedure under which individual sources of emissions could apply for variances that would relieve the sources from compliance with general requirements of the implementation plan. The EPA interpreted the act to allow for states to grant variances from generally applicable standards and, accordingly, approved Georgia’s state implementation plan. The Natural Resources Defense Council, Inc. (NRDC) (plaintiff) challenged the EPA’s approval of Georgia’s plan in the court of appeals. The NRDC contended that such variances could be granted only if the state plan met the strict procedural and substantive requirements mandated under the act for a postponement. The court of appeals sided with the NRDC, and the EPA appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, J.)
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