Utility Air Regulatory Group v. Environmental Protection Agency
United States Supreme Court
573 U.S. ___ (2014)
The Environmental Protection Agency (EPA) (defendant) established regulations for greenhouse-gas emissions from new motor vehicles. The EPA determined that these regulations automatically triggered the Clean Air Act (Act) permitting requirement for stationary sources that emitted greenhouse gases. The Act, 42 U.S.C. § 7602(g), defined air pollutants as “any air pollution agent or combination of such agents . . . which is emitted into or otherwise enters the ambient air.” In Massachusetts v. EPA, 549 U.S. 497 (2007), the United States Supreme Court determined that the Act-wide definition of air pollutant included greenhouse gases because the definition was so broad. However, while the Act-wide definition was broad, the EPA consistently interpreted the term “air pollutant” much more narrowly when required by the context. In particular, the EPA determined that air pollutants, in the context of the Act’s permitting requirement, were limited to regulated air pollutants. The Utility Air Regulatory Group and others (plaintiffs) challenged the EPA’s determination its greenhouse-gas emissions regulations automatically triggered the Act’s permitting requirement. The EPA acknowledged that under its determination, administrative and regulatory costs for both the industry and the government would increase an untenable amount due to the required permitting of so many previously unregulated sources. Specifically, the EPA estimated that the number of sources required to obtain permits would increase from under 15,000 to over 6 million. The court of appeals held that because of the Massachusetts holding that greenhouse gases were air pollutants under the Act-wide definition, and because the Act required permitting for all major sources of air pollutants, the Act required permitting for all major sources that emitted greenhouse gases. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Scalia, J.)
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