Appendix — Mont. Power Co. v. U.S.E.P.A.

Supreme Court brief1977

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in the Supreme Court of the United States

OctToBEr Term, 1976

No. 76-529

Montana Power Company, Er AL., Petitioners,

v.

Unitep StaTes ENVIRONMENTAL PROTECTION AGENCY, ET AL.

No. 76-585

AMERICAN Personsum InstrruTE, ET AL., Petitioners,

v.

Unitep Stares ENVIRONMENTAL PROTECTION AGENCY, ET AL.

No. 76-594

InDIANA-KENTUCKY ELEcTRIC CORPORATION, ETMAL., Petitioners,

v.

UniTey Stares ENWRONMENTAL PROTECTION AGENCY, ET AL.

No. 76-603

ALABAMA Powsgr CoMPANY, ef AL., Petitioners,

Vv.

Unirep States EnvimonMENTAL PROTECTION AGENCY, ET AL.

No. 76-619

Utan Powzr & Licur Company, er AL., Petitioners,

v.

Unitep States ENVIRONMENTAL PROTECTION AGENCY, ET AL.

No. 76-620

WesTerN ENERGY SuPPLY AND TRANSMISSION ASSOCIATES, ET AL.,

Petitioners,

Vv

Unitep States ENVIRONMENTAL PROTECTION AGENCY, ET AL.

ON WRITS OF CERTIORARI TO THE UNITED STATES COURT OF

APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

PETITIONS FOR WRITS OF CERTIORARI FILED

ON OCTOBER 15 (NO. 76-529), 27 (NO. 76-585), 28 (NOS. 78-594,

76-603), AND NOVEMBER 1, 1976 (NOS. 76-619, 76-620)

CERTIORARI GRANTED APRIL 4, 1977

in the Supreme Court of the United States

Ocroser Term, 1976

No. 76-529

Montana Power Company, Et AL., Petitioners,

v.

Unrtep Srates EnviroNMENTAL Protection AGENCY, ET AL.

No. 76-585

AMERICAN PetroLteum InstiTUTE, ET AL., Petitioners,

v.

Uwrrep States ExvironMENTAL ProTecTION AGENCY, ET AL.

No. 76-594

Iyomna-Kentucky Eurerric CoRPORATION, ET AL,

Petitioners,

v.

Unsrep Srares BevironmentaL Protection AGENCY, ET AL.

No. 76-603

ALABAMA Power Company, ET AL., Petitioners,

v.

Unrrep States ExvironMENTAL Protection AGENCY, ET AL.

No. 76-619

Utan Power & Licut Company, eT a., Petitioners,

v.

Unrrep Srates EnvironMentaL Prorection AGENCY, BT AL.

ii

No. 76-620

WesTERN ENERGY Suppty aNp TRANSMISSION ASSOCIATES,

er AL., Petitioners,

v.

Unirep States ENviroNMENTAL Protection AGENCY, ET AL.

ON WRITS OF CERTIORARI TO THE UNITED STATES COURT OF

APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

INDEX

Page

Composite of relevant docket entries ................ la

Petitions to review an order of the Environmental Pro-

GRRE ST Sine bnb on 04850 sir ntaweceeuat lla

Petition to review of The Dayton Power and Light

Se SPS ions ocus cd an olnkcn bens lla

Petition to review of the Public Service Company

of Colorado, et al. (without attached exhibit) 13a

Petition to review of Utah Power & Light Com-

DEE wus chvuuds chen d&0 6045 06 wedbheeues eee l6a

Petition to review of Montana Power Company,

SS 6056-400ndec bethee eb cadesccmnnente l7a

Petition to review of Indiana-Kentucky Electric

SPI GD, csc novacusincvucseoses: 19a

Potition to review of Buckeye Power, Inc. et al. .. 22a

Petition to review of Alabama Power Company,

et al. - 24a

Petition to review of Salt River Project Agricul-

tural Improvement and Power District, et al. 26a

Petition to review of American Petroleum Insti-

"Pees Sees ee eee s €eseveses enn saves oeteoes 66

S| aa ay Slane iat ete sir PEN 2 28a

Petition to review of Pacifie Coal Gasification

IIIS << 5.0k dnduvicubauctdaeauke a. 3la

Petition to review of Utah International Inc. .... 32a

ili

Page

Motion to intervene of Western Energy Supply and

Transmission Associates, et al. ............4++: 35a

Order granting leave to intervene to Western Energy

Supply and Transmission Associates, et al. ...... 37a

GEE WHI oon cc cccsccccccccscesccccccecescecs 39a

Judgment below (See Petition for Writ of Certiorari

in No. 76-529 at p. 91a)

* “‘Sienificant deterioration’’ regulations as proposed

(38 Fed. Reg. 18986 (July 16, 1973)) ............ 9la

‘Significant deterioration’’ regulations as a revised

proposal (39 Fed. Reg. 31 (August 27, 1974)) .160a

‘Significant deterioration’’ regulations as promul-

gated (39 Fed. Reg. 42510 (December 5, 1974)). .206a

‘Significant deterioration’’ regulations as amended

(40 Fed. Reg. 2802 (January 16, 1975)) ...... 242a

(40 Fed. Reg. 25004 (June 12, 1975)) .......... 246a

(40 Fed. Reg. 42011 (September 10, 1975)) ....284a

Order of the Supreme Court of the United States is-

sued April 4, 1977 granting a writ of certiorari in

76-529—(corresponding orders entered in Nos. 76-

585, 76-594, 76-603, 76-619, and 76-620) .......... 292a

* The ‘‘significant deterioration’’ regulations, as reprinted oa pp. 9la to

29la herein, appear on pp. 1-36, 688-98 of the Joint Appendix filed in the

consolidated cases below.

la

Composite of Relevant Docket Entries Entered in Various

United States Courts of Appeals in Which Petitions Below

Were Considered *

DATE

1974

Nov. 27 [Sixth Circuit]**—Joint Petition to review an

order of the United States Environmental Protection

Agency (‘‘EPA’’) filed in the Sixth Cireuit, No. 74-

2297, by Petitioners: The Dayton Power and Light

Company; Kentucky Power Company; Kentucky

Utilities Company; Ohio Edison Company; and Ohio

Power Company.

Nov. 27—Petition to review an order of the EPA filed in

the District of Columbia Cireuit, No. 74-2063, by Pe-

titioner, the Sierra Club; ¢/m 11/27/74.

Dec. 5—Petition to review an order of the EPA filed in

the District of Columbia Circuit, No. 74-2079, by

Petitioner, the Sierra Club; ¢/m 12/5/74.

Dee. 20 [Tenth Cireuit]—Joint Petition to review an or-

der of the EPA filed in the Tenth Cireuit, No. 74-

1866, by Petitioners: Public Service Company of

Colorado; Colorado-Ute Electric Association, Inc.;

Platte River Power Authority; Cheyenne Light, Fuel,

* Petitions to review the Environmental! Protection Agency’s

‘*significant deterioration’’ regulations (40 C.F.R. §§ 52.01 (d),

(f), and 52.21 (1976)) were filed in the United States Courts of

Appeals for the Fifth, Sixth, Seventh, Ninth, Tenth, and District

of Columbia Circuits. All petitions filed in Circuits other than the

District of Columbia Circuit were eventually transferred to that

Circuit, where they were consolidated for review.

** Bracketed information denotes the United States Court of

Appeals in which the docket entry was made if other than the

United States Court of Appeals for the District of Columbia

Circuit.

2a

and Power Company; and Pacific Power & Light

Company.

Dec. 23 [Tenth Circuit]—Petition to review an order of

the EPA filed in the Tenth Cireuii, No. 74-1869, by

Petitioner, Utah Power & Light Company.

Dec. 26 [Ninth Cireuit]—Joint petition to review an order

of the EPA filed in the Ninth Cireuit, No. 74-3460, by

Petitioners: Montana Power Company; Pacific Power

& Light Company; Portland General Electric Com-

pany; Puget Sound Power & Light Company; and

Washington Water Power Company. [This joint pe-

tition to review was transferred on April 1, 1975 by

the Ninth Cireuit to the Sixth Cireuit and refiled on

* April 15, 1975 in the Sixth Cireuit, No. 75-1398. ]

Dec. 27 [Seventh Circuit]—Petition to review an order

of the EPA filed in the Seventh Cireuit, No. 74-2055,

by Petitioners: Indiana-Kentucky Electrie Corpora-

tion; Indiana & Michigan Electric Company; Indiana

Statewide Rural Electric Cooperative, Inc.; Indian-

apolis Power & Light Company; Northern Indiana

Publie Service Company; Public Service Company of

Indiana, Ine.; and Southern Indiana Gas and Electric

Company. .

Dec. 27 [Sixth Cirenit]—Petition to review an order of

the EPA filed in the Sixth Cireuit, No. 74-2358, by

Petitioners: Buckeye Power, Inc.; The Cincinnati Gas

& Electrie Company; The Cleveland Flectrie Tllumi-

nating Company; Columbus and Southern Ohio Elee-

tric Company; and Ohio Valley Electric Corporation.

Dec. 27 [Fifth Circuit]—Joint petition to review an order

of the EPA filed in the Fifth Cireuit, No. 74-4234, by

Petitioners: Alabama Power Company; Georgia Pow-

er Company; Gulf Power Company; and Miso, sippi

Power Company. [This joint petition to review was

transferred on January 15, 1975 by the Fifth Circuit

3a

to the Sixth Circuit and refiled on January 31, 1975

in the Sixth Cireuit, No. 75-1118.]

Dec. 30 [Ninth Circuit]—Joint petition to review an order

of the EPA filed in the Ninth Circuit, No. 74-3501, by

Petitioners: Salt River Project Agricultural Improve-

ment and Power District; Arizona Public Service

Company; Tucson Gas & Electric Company; Nevada

Power Co.; Pacific Power & Light Company; Ari-

zona Electric Power Co-Op, Inc.; San Diego Gas

& Electric Co.; and Soathern California Edison Com-

pany. [This joint petition to review was transferred

on April 1, 1975 by the Ninth Cireuit to the Sixth

Cireuit and refiled on April 15, 1975 in the Sixth Cir-

cuit, No. 75-1398.]

Dee. 30—Order per Chief Judge Bazelon in the District

of Columbia Circuit, Nos. 74-2063 and 742079, grant-

ing Petitioners’ motion to consolidate petitions for

review and Nos. 74-2063 and 74-2079 are consolidated

for consideration on the merits.

1975 -

Jan. 2 (Sixth Circuit]—Petition to review an order of the

EPA filed in the Sixth Circuit, No. 75-1001, by Peti-

tioners: American Petroleum Institute; The Standard

Oil Company (Ohio); Atlantic Richfield Company;

Continental Oil Company; Exxon Corporation; Gulf

Oil Corporation; Mobil Oil Corporation; Shell Oil

Company; Texaco Inc.; and Union Oil Company of

California.

Jan. 3 [Tenth Circuit]—Petition to review an order of

the EPA filed in the Tenth Cireuit, No. 75-1006, by

Petitioners: Pacific Coal Gasification Company and

Transwestern Coal Gasification Company.

Jan. 6 [Tenth Circuit]—Petition to review an order of

the EPA filed in the Tenth Circuit, No. 75-1007, by

Petitioner, Utah International Inc.

4a

Jan. 7—Order of the Clerk of the District of Columbia

Cireuit, in No. 74-2063, that Western Energy Supply

and Transmission Asso., Arizona Public Service Co.,

The Dayton Power and Light Co., Kentucky Power

Co., Kentucky Utilities Co., Ohio Edison Co., Ohio

Power Co., Utah Power & Light Co., and Edison

Electric Institute are granted leave to intervene.

Jan. 31 (Sixth Cireuit])—Joint petition to review an order

of the EPA filed by Petitioners: Alabama Power

Company; Georgia Power Company; Gulf Power

Company; and Mississippi Power Company; refiled

in the Sixth Cireuit, No. 75-1118, [This joint petition

to review was initially filed on December 27, 1974 in

the Fifth Cireuit, No, 74-4234; transferred on Janu-

ary 15, 1975 by the Fifth Cireuit to the Sixth Circuit;

and refiled on January 31, 1975 in the Sixth Circuit,

No, 75-1118. ]

Feb. 18—-Certified Index to the record filed in the District

of Columbia Cireuit, Nos. 74-2063 and 74-2079.

Mar. 24 [Ninth Cireuit]—Order entered in the Ninth Cir-

cuit to transfer Case Nos. 74-3447, 74-3460 and 74-

3501 in the Ninth Cireuit to the Sixth Cireuit.

Mar. 31 [Tenth Cireuit]—Order entered in the Tenth

Circuit to transfer Case Nos, 74-1866, 74-1869, 74-1871,

75-1006 and 75-1007 in the Tenth Circuit to the Dis-

trict of Columbia Cireuit.

Apr. 1 [Ninth Cireuit]—Records of Ninth Cireuit Case

Nos. 74-3447, 74-3460 and 74-3501 transferred from

the Ninth Cireuit to the Clerk for the Sixth Cireuit.

Apr. 2—Case Nos. 74-1866, 74-1869, 74-1871, 75-1006 and

75-1007 in the Tenth Circuit transferred to the Dis-

trict of Columbia Circuit and entered as Nos. 75-1368,

75-1369, 75-1370, 75-1371 and 75-1372 in the District

5a

of Columbia Circuit. See Tenth Circuit order to

transfer entered March 31, 1975.

Apr. 15 [Sixth Cireuit]—Joint petition to review an order

of the EPA filed by Petitioners: Montana Power

Company; Pacific Power & Light Company; Port-

land General Electric Company; Puget Sound Power

& Light Company; and Washington Water Power

Company; refiled in the Sixth Cireuit, No, 75-1398,

[This joint petition to review was initially filed on

December 26, 1974 in the Ninth Cireuit, No. 74-3460;

transferred on April 1, 1975 by the Ninth Cirenit to

the Sixth Cireuit; and refiled on April 15, 1975 in

the Sixth Cireuit, No, 75-1398, ]

Apr. 15 [Sixth Cireuit]—Joint petition to review an order

of the EPA filed by Petitioners: Salt River Project

Agricultural Improvement and Power Distriet; Ari-

zona Public Service Company; Tucson Gas & Elee-

tric Company; Nevada Power Co.; Pacific Power &

Light Company; Arizona Electric Power Co-Op, Inc. ;

San Diego Gas Electrie Co.; and Southern California

Edison Company; refiled in the Sixth Cireuit, No.

75-1398. [This joint petition to review was initially

filed on December 30, 1974 in the Ninth Cireuit, No.

74-3501; transferred on April 1, 1975 by the Ninth

Cirenit to the Sixth Cireuit; and refiled on April 15,

1975 in the Sixth Cireuit, No. 75-1398. ]

Apr. 15 [Sixth Cireuit]—Case Nos, 74-3447, 74-3460 and

74-3501 in the Ninth Cireuit transferred to the Sixth

Cireuit and entered as No, 75-1398 in the Sixth Cir-

cenit. See Ninth Cireuit order to transfer entered

March 24, 1975.

May 21 [Seventh Cireuit]—Order entered in the Seventh

Cireuit to transfer Case No, 74-2055 in the Seventh

Cireuit to the District of Columbia Circuit.

6a

June 10—Case No. 74-2055 in the Seventh Circuit trans-

ferred to the District of Columbia Circuit and entered

as No. 75-1575 in the District of Columbia Circuit.

See Seventh Circuit order to transfer entered May

21, 1975.

June 16 [Sixth Cireuit)—Judgment entered in the Sixth

Cireuit to transfer Case Nos, 74-2297; 74-2358; 75-

1001; 75-1118; and 75-1398 in the Sixth Circuit to the

District of Columbia Circuit.

July 14—Case Nos, 74-2297; 74-2358; 75-1001; and 75-1118

in the Sixth Cireuit transferred to the District of

Columbia Cireuit and entered as Case Nos. 75-1663;

75.1664; 75-1665; and 75-1666 in the Distriet of Co-

lumbia Cireuit. See Sixth Cireuit Judgment entered

June 16, 1975.

Aug. 6—Case No, 75-1398 in the Sixth Cireuit transferred

to the District of Columbia Cireuit and entered as

Case Nos. 75-1763 and 75-1764 in the District of Co-

lumbia Cireuit. See Sixth Cireuit Judgment entered

June 16, 1975,

August 6—Clerk’s order in Nos, 75-1763 and 75-1764 that

the petitions for review filed by the following parties

shall be assigned the following docket numbers in

this court: Nennecott Copper Corporation v. EPA,

No, 75-1668; Montana Power Company, et al. v. U.S.

Environmental Protection Agency, No. 75-1763; and

Salt River Project Agricultural Improvement and

Power District, et al. v. EPA and Russell EB. Train,

Administrator, No. 75-1764.

August 8—Clerk's order granting motion for leave to in-

tervene by The Sierra Club; the Metropolitan Wash-

ington Coalition for Clean Air; the New Mexico Citi-

zens for Clean Air and Water; and Sally Rodgers.

Counsel for the intervenors may participate in oral

argument only to the extent allowable under Rule 12

Ta

of the General Rules of this Court. (Nos. 75-1368;

75-1369; 75-1370; 75-1371; 75-1372; 75-1763 and 75-

1764.)

August 8—Clerk’s order in Nos. 75-1763 and 75-1764

granting motion of The State of Nevada for leave to

intervene in the consolidated cases. Counsel for the

intervenor may participate in oral argument only to

the extent allowable under Rule 12 of the General

Rules of this Court. [Order vacated per Clerk’s order

of 12/3/75 in Nos. 75-1763 and 75-1764. ]

August 8—Order per Chief Judge Bazelon granting mo-

tion of Sierra Club, et al. and the State of New Mex-

ico for consolidation and Nos, 74-2063, 74-2079, 75-

1368, 75-1369, 75-1370, 75-1371, 75-1372, 75-1575,

75-1663, 75-1664, 75-1665, 75-1666, 75-1667, 75-1763 and

75-1764 are hereby consolidated for consideration on

the merits.

August 8—Order per Chief Judge Bazelon that the cer-

tified index to record filed in Nos. 74-2063 and 74-2079

shall be deemed filed in all of the consolidated cases.

August 8—Certified index to record (filed in Nos, 74-2063

and 74-2079 on 2-18-75).

Nov. 24—Motion of Intervenor, the State of Nevada, in

Nos. 75-1763 and 75-1764 to vacate order granting

intervention.

Nov. 26—Joint Appendix, Vols. I & IT; ¢/m 11/26/75.

Dee. 3—Clerk’s order in Nos, 75-1763 and 75-1764 grant-

ing motion of Intervenor, the State of Nevada, to va-

cate order granting intervention and the order filed

August 8, 1975 in the consolidated cases granting the

motion of the State of Nevada for leave to intervene

be, and the same hereby is, vacated; the Clerk is di-

rected to make an appropriate notation on the rec-

ords of his office to reflect the vacation of the afore-

said intervention.

|

8a

Dec. 17-—Per Curiam order en banc that Petitioners’ sug-

gestion for appropriateness of initial hearing en banc

is denied; Chief Judge Bazelon; Wright, Tamm, Lev-

enthal, Robinson, MacKinnon, Robb and Wilkey, Cir-

cuit Judges.

1976

Feb. 25—Order per Chief Judge Bazelon that the motion

for expedited hearing of these consolidated cases is

granted. (Nos. 74-2063 and 74-2079 only).

June 9—Argued before Circuit Judges Wright, Robinson

and Wilkey.

August 2--Opinion for the Court filed by Circuit Judge

Wright.

August 2—Judgment affirming order of the EPA (N),

August 24—Certified copy of the opinion and judgment

issued to the EPA,

Oct. 20—Notice from Clerk, Supreme Court that petition

for certiorari was filed in S.C.No. 76-529 on Oct. 15,

1976. (Filed in No, 75-1763).

Oct. 29—Notice of filing of a petition for writ of certio-

rari in S.C, No. 76-585 on October 27, 1976. (Filed in

No. 75-1665),

Nov. 2—Notice from Clerk, Supreme Court that petition

for certiorari was filed in S.C. No. 76-594 on Oct. 29,

1976, (Filed in No. 75-1575).

Nov. 3—Notice of filing of petition for writ of certiorari

in S.C, No. 76-603 on October 29, 1976. (Filed in No.

75-1666).

Nov. 3—Notice of filing of petition for writ of certiorari

in S.C, No. 76-617 on November 1, 1976. (Filed in

Nos. 74-2063 and 74-2079).

9a

Nov. 3—Notice of filing of petition for writ of certiorari

in S.C. No. 76-619 on November 1, 1976. (Filed in

Nos. 75-1368 and 75-1369).

Nov. 3—Notice of filing of petition for writ of certiorari

in S.C. No. 76-620 on November 1, 1976. (Filed in

Nos. 75-1372 and 75-1764).

1977

April 11—Certified copy of order from Clerk, Supreme

Court, granting writ of certiorari limited to certain

questions in S.C. No. 76-529 on April 4, 1977. (See

order for questions). (Filed in No, 75-1763).

April 11—Certified copy of order from Clerk, Supreme

Court, granting writ of certiorari limited to certain

questions in S.C. No. 76-585 on April 4, 1977. (See

order for questions). (Filed in No, 75-1665).

April 11—Certified copy of order from Clerk, Supreme

Court, granting writ of certiorari limited to certain

questions in S.C. No. 76-594 on April 4, 1977. (See

order for questions). (Filed in No, 75-1575).

April 11—Certified copy of order from Clerk, Supreme

Court, granting writ of certiorari limited to certain

questions in S.C. No, 76-603 on April 4, 1977. (See

order for questions). (Filed in No, 75-1666),

April 11--Certified copy of order from Clerk, Supreme

Court, denying writ of certiorari in 8.C, No, 76-617

on April 4, 1977. (This was Sierra Club’s petition;

filed in Nos. 74-2063 and 74-2079).

April 11—Certified copy of order from Clerk, Supreme

Court, granting writ of certiorari limited to certain

questions in S.C. No. 76-619 on April 4, 1977. (See

order for questions.) (Filed in Nos, 75-1368 and

75-1369).

10a

April 11—Certified copy of order from Clerk, Supreme

Court, granting writ of certiorari limited to certain

questions in S.C. No. 76-620 on April 4, 1977. (This

was Western Energy Supply and Transmission Asso-

ciates, et al., petition; filed in No. 74-2063).

lla

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

No. 74-2297

[Filed November 27, 1974]

Tue Dayton Power anv Licut Company,

Kentucky Power Company,

Kentucky Utiuities Company,

Onto Epison Company,

Onto Power Company,

Petitioners,

v.

Unrrep States ENvironNMENTAL Protection AGENCY,

Respondent.

Joint Petition for Review

Pursuant to 42 U.S.C. § 1857h-5(b)(1) (1970) and Rule

15, Federal Rules of Appellate Procedure for the United

States Court of Appeals, Petitioners, the Dayton Power

and Light Company, Kentucky Power Company, Ken-

tucky Utilities Company, Ohio Edison Company, and Ohio

Power Company, petition the Court for review of the

regulation promulgated by Respondent, the United States

Environmental Protection Agency, on November 27, 1974,

amending Subpart A, Section 52.21 of the regulations of

the United States Environmental Protection Agency re-

lating to approvals and promulgations of State imple-

mentation plans under the Clean Air Act.

12a

/s/ Harry F* Voicur

Harry t. Voight

/s/ Henry V. Nicxei

Henry V. Nickel

LeBoegvr, Lams, Lersy & MacRag

1757 N Street, N.W.

Washington, D. C. 20036

(202) 872-8668

Attorneys for Petitioners

[Certificate of Service omitted in printing]

13a

UNITED STATES COURT OF APPEALS

FOR THE TENTH CIRCUIT

No. 74-1866

[Filed December 20, 1974]

Pusiic Service Company or CoLorapo, a Colorado cor-

poration, CoLorapo-Utr Exectric Association, INnc., a

Colorado corporation, PLatre River Power AvTuHoriry,

a Colorado nonprofit corporation, Cuevenne Licurt,

Fvet anp Power Company, a Wyoming corporation,

and Pacitric Power & Licur Company, a Maine cor-

poration, Petitioners,

vs.

Untrep States ENviroNMENTAL Protection AGENCY,

Respondent.

Joint Petition for Review

Pursuant to 42 USC §1857h-5(b) and Rule 15 of the

Federal Rules of Appellate Procedure for the United

States Court of Appeals, the above named petitioners

hereby petition this Court for review of the regulation

of the United States Environmental Protection Agency

published in the Federal Register December 5, 1974, Vol-

ume 39, pages 42510-42517, amending Subpart A, Section

52.21 of the regulations of the United States Environ-

mental Protection Agency relating to approvals and pro-

mulgation of state implementation plans under the Clean

Air Act, as amended. Said regulations are attached hereto

and incorporated herein as Exhibit A. [Exhibit A omitted

in printing. ]

Petitioners, Public Service Company of Colorado and

Colorado-Ute Electric Association, Inc., are public utilities

operating in the State of Colorado; Platte River Power

Authority is a Colorado nonprofit corporation being wholly

l4a

owned and an instrumentality of the municipalities of

Estes Park, Longmont, Loveland and Fort Collins, Colo-

rado; Cheyenne Light, Fuel and Power Company and

Pacific Power and Light Company are public utilities

operating in the State of Wyoming. All of said utilities

are directly affected by said regulations.

Dated this 20th day of December, 1974.

Respectfully submitted,

Lez, Bryans, Ket_ty & STansrieLp

/s/ Bryant O’DonneELL

Bryant O’Donnell

/s/ Donavp D. Cawetti

Donald D. Cawelti

990 Public Service Company Bldg.

Denver, Colorado 80202

Telephone: 222-3534

Attorneys for Public Service

Company of Colorado and

Cheyenne Light, Fuel and

Power Company

Girts Krumins, Esa.

P. O. Box 1149

Montrose, Colorado 81401

Telephone: 241-4501

Attorney for Colorado-Ute Electric

Association, Inc.

Moses, Wirtemyer & Harrison, P.C.

250 Arapahoe Street

Boulder, Colorado 80302

Telephone : 443-8782

Attorneys for Platte River Power

Authority

15a

Rives, Bonynapt & DrummMonp

1400 Public Service Building

Portland, Oregon 97204

Telephone: (503) 224-3920

Attorneys for Pacific Power &

Light Company

Addresses of Petitioners:

Public Service Company of Colorado

P. O. Box 840

Denver, Colorado 80201

Colorado-Ute Electric Association, Inc.

P. O. Box 1149

Montrose, Colorado 81401

Platte River Power Authority

3030 South College Avenue

Fort Collins, Colorado 80521

Cheyenne Light, Fuel and Power Company

P. O. Box 1409

Cheyenne, Wyoming 82001

Pacific Power & Light Company

Public Service Building

Portland, Oregon 97204

[Certificate of Service and Exhibit A omitted in printing]

16a

UNITED STATES COURT OF APPEALS

FOR THE TENTH CIRCUIT

No. 74-1869

[Filed December 23, 1974]

Utan Power & Licut Company,

Petitioner,

vs.

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Petition for Review

Utah Power & Light Company hereby petitions the

Court for review of the Order of the Environmental Pro-

tection Agency entitled ‘‘Part 52—Approval and Pro-

mulgation of Implementation Plans, Prevention of Sig-

nificant Air Quality Deterioration,’’ published at 39 Fed-

eral Register 42510 et seq. on December 5, 1974.

Respectfully submitted,

/s/ Gerry LeEvENBERG

Gerry Levenberg

PraTHER LevenBERG SEEGER

DoouittLe Farmer & Ewrne

1101 Sixteenth Street, N.W.

Washington, D.C. 20036

/s/ Stoney G. Baucom

Sidney G. Baucom

/s/ Vert R. Tornam

Verl R. Topham

P.O. Box 899

Salt Lake City, Utah 84110

Attorneys for Petitioner

(Certificate of Service omitted in printing]

17a

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

No. 74-3460

{Filed December 26, 1974]

Montana Power Company,

Pactric Power & Licut Company,

Port Lanp GENERAL E.ectric Company,

Pucet Sounp Power & Licut Company, and

Wasnincton Water Power Company,

Petitioners,

v.

Unrvep States EnvironMENTAL Protection AGENCY,

Respondent.

Joint Petition for Review

Pursuant to Section 307(b)(1) of the Clean Air Act,

as amended, 84 Stat. 1708, 42 U.S.C. § 1857h-5(b) (1), and

Rule 15, Federal Rules of Appellate Procedure, petition-

ers, Montana Power Company, Pacific Power & Light

Company, Portland General Electric Company, Puget

Sound Power & Light Company, and Washington Water

Power Company, hereby petition the Court for review of

the regulations promulgated by the respondent, United

States Environmental Protection Agency, on November

27, 1974, amending 40 C.F.R. §§ 52.01 and 52.21, and pub.

lished in 39 Fed. Reg. 42514-42517 (December 5, 1974).

These regulations, of which review is sought, relate to the

approvals and promulgations of state implenientation

plans under the Clean Air Act, as amended, with specific

reference to the significant deterioration of air quality.

18a

Francis M,. SHea

Ricuarp T, Conway

Daviw Boota Beers

James R, Biexe

Suea ano GaRDNEB

734 Fifteenth Street, N.W.

Washington, D.C, 20005

(202) 737-1255

Attorneys for Petitioners

Of Counsel:

Suea AND GARDNER

734 Fifteenth Street, N.W.

Washington, D.C. 20005

December 26, 1974

(Certificate of Service omitted in prioting])

- — ——

I CL

19a

UNITED STATES COURT OF APPEALS

FOR THE SEVENTH CIROUIT

No. 74-2055

[Filed December 27, 1974]

Inptiana-Kentucky Execrric Corporation,

Inpiana & Micutoan Exectric Company,

Inpiana Starewipe Rurat Exvecraic Cooperative, INe.,

InpraANaPoLis Power & Licut Company, _

NortHern Inpiana Pvusuic Service Company,

Pusuic Service Company or Inprana, Ino., and

Sournern Inptiwa Gas anp Execrric Company,

Petitioners,

v.

Unrrep States Environmental. Prorection AcEency,

Respondent.

Petition for Review

Indiana-Kentucky Electric Corporation, which generates

electric power primary for the Portsmouth, Ohio facility

of the United States Atomic Energy Commission, Indiana

& Michigan Electric Company, which generates electric

power for the residents of Indiana and Michigan, Indiana

Statewide Rural Electric Corporation, Inc., which geuer-

ates electric power for residents of Indiana, Indianapolis

Power & Light Company, which generates electric power

for residents of Indiana, Northern Indiana Public Service

Company, which generates electric power for residents of

Indiana, Public Service Company of Indiana, Inc., which

generates electric power for residents of Indiana and

Southern Indiana Gas and Electric Company, which gen-

erates electric power for residents of Indiana hereby peti-

tion the Court for review of the Order of the United

States Environmental Protection Agency entitled ‘Air

20a

Quality Implementation Plans, Prevention of Significant

Air Quality Deterioration’’ published in the Federal Reg-

ister on Thursday, December 5, 1974, at 39 Fed. Reg.

42509-42517, inclusive.

/s/ Jenny P. Betknap

Jerry P. Belknap

/s/ Jon D. Notann

Jon D, Noland

/s/ Bryan G, Tasier

Bryan G. Tabler

1313 Merchants Bank Building

Indianapolis, Indiana 46204

Telephone: (317) 638-1313

Attorneys for Petitioner

Livinestone, Ditpine, Haynie & Yopoer

425 Lincoln Bank Tower

Fort Wayne, Indiana 46802

Telephone: (219) 742-8341

Parr, Ricney, Osremskey, Peversen & Morton

Union Federal Savings and T.oan Building

Lebanon, Indiana 46052

Telephone: (317) 482-0110

Scuroer, Ercnnorn & Morrow

5243 Hohman Avenue

Hammond, Indiana 46320

Telephone: (219) 931-0560

Bampercer, Foreman, Oswaip ann Hann

708 Hulman Building

Evansville, Indiana 47708

Telephone: (812) 425-1591

2la

Maxcus E. Woops

Joun R. Hopowan

Arnoip A. Gorpus

P.O. Box 1595B

Indianapolis, Indiana 46206

Telephone: (317) 638-1313

Barnes, Hickam, Pantzer & Boyp

1313 Merchants Bank Building

Indianapolis, Indiana 46204

Telephone: (317) 638-1313

Of Counsel

[Certificate of Service omitted in printing]

22a

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

No. 74-2358

[Filed December 27, 1974]

Buckeye Power, INc., ET AL.,

Petitioners,

Vv.

ENVIRONMENTAL Protection AGENCY,

Russert E. Trary, Administrator of the

Environmental Protection Agency,

Respondent.

Petition for Review

Buckeye Power, Inc., The Cincinnati Gas & Electric Com-

pany, The Cleveland Electric Illuminating Company and

Columbus and Southern Ohio Electric Company, all own-

ing and operating electric generating plants in Ohio for

the supply of electric energy to residents of Ohio, and

Ohio Valley Electric Corporation, which generates electric

power in Ohio primarily for the Portsmouth, Ohio facility

of the United States Atomic Energy Commission, all of

which above referred plants are subject to the provisions

of the Ohio Implementation Plan described below, hereby

petition the Court for a review, pursuant to Title 42

United States Code, Section 1857h-5(b) and (ce), of the

Order of the Environmental Protection Agency, acting

through Russell Train, Administrator, dated November

27, 1974, as published in the Federal Register, Volume 39,

No. 235 at 42514 et seq., on Thursday, December 5, 1974,

titled 40 Code of Federal Regulations, Chapter I, Sub-

chapter A, Part 52, ‘‘Approval and Promulgation of Im-

plementation Plans,’’ as said Order relates to the Plan of

the State of Ohio entitled ‘‘Implementation Plan for the

Control of Suspended Particulates, Sulfur Dioxide, Car-

bon Monoxicle, Hydrocarbons, Nitrogen Diexide, and

Photochemical Oxidants in the State of Ohio,”’ together

with all supplements.

/8/ Leste Henry

Leslie Henry

/8/ Witson W. Syypver

Wilson W. Snyder

Attorneys for Ali Petitioners

12th Floor, Edison Plaza

300 Madison Avenue

Toledo, Ohio 43604

Telep} ‘ 29%

Of Counsel: phone: (419) 255-8220

Fuutiep, Henry, Hover & Snyper

12th Floor, Edison Plaza

300 Madison Avenue

Toledo, Ohio 43604

[Certificate of Service omitted in printing]

24a

UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

No. 74-4234

[Filed Decomber 27, 1974]

AvaBAMA Power Company,

Groraia Power Company,

Guir Power Company, and

Mississipp1 Power Company,

Petitioners,

v.

Russert E. Tram, as Administrator, Environmental

Protection Agency, 401 M Street, S.W.,

Washington, D. C. 20560

Respondent.

Joint Petition for Review

Pursuant to 42 U.S.C, § 1857h-5(b)(1) (1970) and Rule

15, Federal Rules of Appellate Procedure, Alabama

Power Company, Georgia Power Company, Gulf Power

Company, and Mississippi Power Company hereby peti-

tion this Court to review the Order of the Administrator

of the United States Environmental Protection Agency,

issued on November 27, 1974, promulgating regulations

relating to approvals of state implementation plans and

for the prevention of significant air quality deterioration.

These regulations were issued pursuant to the Clean Air

Act of 1970, 42 U.S.C. § 1857 et seq. and appear at 40

C.F.R. Part 52.

25a

Respectfully submitted,

/8/ 8. Eason Batcu

S. Eason Balch

/s/ Ropert A. Buetrner

Robert A. Buettner

/8/ Joun P. Scorr, Jr.

John P. Seott, Jr.

Batcu, Bincuam, Baker, HawTHorNez,

Witutiams & Warp

P.O. Box 306

Birmingham, Alabama 35201

Phone: (205) 323-8391

Attorneys for Petitioners

Dated: December 27, 1974

(Certificate of Service omitted in printing]

26a

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

No. 74-3501

[Filed December 30, 1974]

Satt River Prosect AcricuLtuRAL IMPROVEMENT AND

Power District, an Arizona Agricultural Improvement

District; Aztzona Pusiic Service Company, an Arizona

corporation; Tucson Gas & Evecrric Company, an Ari-

zona corporation; Nevapa Power Co., a Nevada corpo-

ration; Pactric Power & Licut Company, a Maine cor-

poration, doing business as a public utility corporation

in Idaho, California, Oregon, Washington, Montana

and Wyoming; Arizona Exectric Power Co-Op, Ixc.,

an Arizona corporation; San Dirco Gas & Execrtric

Co., a California corporation, doing business as a public

utility in California; and Sournern Catirornia Epison

Company, a California corporation,

Petitioners,

vs.

ENVIRONMENTAL Protection Acency and Russe. EK. Train,

Administrator, Environmental Protection Agency,

Respondent.

Joint Petition for Review

Pursuant to 42 U.S.C. § 1857h-5(b) (1) (1970) and Rule

15, Federal Rules of Appellate Procedure for the United

States Court of Appeals, petitioners seek review of the

regulations regarding significant deterioration of air qual-

ity which were promulgated by Respondent Ewnviron-

MENTAL Protection Acency on November 27, 1974, and

published in the Code of Federal Regulations on Decem-

ber 5, 1974, Vol. 39, No. 235, pgs. 42510, et seq., including

review of the regulations promulgated by Respondent

a

ee ne

27a

amending Subpart A, Part 52, Chapter I, Title 40 of the

Code of Federal Regulations, on the grounds that each

of them will be profoundly and adversely affected by said

promulgation and that it is the promulgation of an im-

plementation plan subject to review by this Court.

Petitioners are all suppliers of electrical energy to por-

tions of the Southwest United States and include Sar

River Prosect Acricu.trura. ImproveMENT AND Power

Disrrict, an Arizona Agricultural Improvement Dist rict;

ARIZONA Pusiic Service Company, an Arizona corpora-

tion; Tucson Gas ano Evectric Co., a corporation; Nevapa

Power Co., a Nevada corporation; Pactric Power & Licut

Company, a Maine corporation, doing business as a public

utility corporation in Idaho, California, Oregon, Utah,

Montana and Wyoming; San Dieco Gas & Execrric Co.,

a California corporation, doing business as a public utility

in California ; Arizona Exvectric Power Co-Op, Inc., an

Arizona corporation, and Sovrnern Cairornta Epison

Company, a California corporation.

Jenninas, Strouss & Satmon

/s/ Jow~ L. Kyu

Jon L. Kyl

111 West Monroe

Phoenix, AZ 85003

Rex E. Lee

2840 Iroquois Drive

Provo, UT 54601

Swett & Witmer

/s/ Bruce Norton

Bruce Norton

3100 Valley Center

Phoenix, AZ 85073

Attorneys for Petitioners

[Certificate of Service omitted in printing]

28a

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

No. 75-1001

(Filed January 2, 1975]

American PetrroLeuM INSTITUTE,

THe StanpaRp Or Company (Onto),

Atuantic Ricurire.p Company,

ConTINENTAL Or, Company,

Exxon CorporaTION,

Gur Or CorporaTION,

Mos. Or. CorporaTION,

SHeL_t Om Company,

Texaco Inc., and

Unton Or, Company or CaLirornia,

Petitioners,

vs.

ENVIRONMENTAL ProtecTION AGENCY,

Respondent.

Petition for Review of Regulations Promulgated by the

Environmental! Protection Agency

Pursuant to 42 U.S.C. § 1857h-5(b)(1) (1970), American

Petroleum Institute, The Standard Oil Company (Ohio),

Atlantic Richfield Company, Continental Oil Company,

Exxon Corporation, Gulf Oil Corporation, Mobil Oil Cor-

poration, Shell Oil Company, Texaco Inc., and Union Oil

Company of California petition this Court for review of

the regulations promulgated by the Environmental Pro-

tection Agency, amending Subpart A, Sections 52.01 and

52.21 of the regulations of the Environmental Protection

Agency relating to the approval and promulgation of

State implementation plans under the Clean Air Act, such

amending regulations being published in the Federal Reg-

ister of December 5, 1974 at 39 Fed. Reg. 42510 et seq.

29a

Petitioners, except for the American Petroleum Institute

of which all other petitioners are members, are petroleum

companies either having their principal operating office

refineries or other facilities in Ohio, Michigan, Tennessee

or Kentucky.

American Perroteum INstITUTE

Tue Sranparp Or Company (On10)

Atiantic Ricnrretp Company

ConTINENTAL Or. Company

Exxon Corporation

Gur Om Corporation

Most. Or Corporation

Suet Or Company

Texaco Inc.

Union Or Company or CaLrrorNiA

/s/ Rosert G. StacHier

Tart, Srettinrus & Houurster

600 Dixie Terminal Building

Cincinnati, Ohio 45202

(513) 381-2838

Cuakies D. LinpBerc

Tart, Sterrinrus & Houuister

600 Dixie Terminal Building

Cincinnati, Ohio 45202

(513) 381-2838

Joun J. Apams

Autson K. Scuuter

Hunton, WituaMs, Gay & Gisson

1730 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

(202) 833-1680

Josern C. Carter, JR.

Grorce C. FREEMAN, JB.

Davip F. Peters

Turner T. Smiru, JB.

Hunton, Wiu1aMs, Gay & Grsson

700 East Main Street

Richmond, Virginia 23219

(804) 649-3661

[Certificate of Service omitted in printing]

3la

UNITED STATES COURT OF APPEALS

FOR THE TENTH CIRCUIT

No. 75-1006

[Filed January 3, 1975]

Paciric Coat GasiricaTtion Company and

TRANSWESTERN Coat GasIFICATION CoMPaNy,

Petitioners,

We

ENVIRONMENTAL Protection AGENCY,

Respondent.

Petition for Review

Pursuant to the provisions of § 1857h-5(b)(1) of the

Clean Air Act, 42 U.S.C. § 1857, and 4 702 of the Adminis-

trative Procedure Act, 5 U.S.C. § 500 ef seq., Pacifie Coal

Gasification Company and Transwestern Coal Gasification

Company hereby petition the court for review of the

Order and Regulations of the Environmental Protection

Agency entitled ‘‘Air Programs, Approval and Promul-

gation of Implementation Plans, Prevention of Significant

Air Quality Deterioration,’’ and published in 39 Federal

Register, No. 235, December 5, 1974, at pages 42510 to

42517. Pacific Coal Gasification Company and Transwest-

ern Coal Gasification Company are adversely affected and

aggrieved by this action of the Environmental Protection

Agency.

James W. McCartney

Norman D. Raprorp, Jr.

Vinson, Evxins, Sraruts, Connatty & SmitH

/s/ Norman D. Raprorp, Jr.

Norman D. Radford, Jr.

2100 First City National Bank Building

Houston, Texas 77002

Attorneys for Petitioners

(Certificate of Service omitted in printing]

32a

UNITED STATES COURT OF APPEALS

FOR THE TENTH CIRCUIT

No. 75-1007

[Filed January 6, 1975)

Uran Invernationat Inc., a corporation,

Petitioner,

vs.

ENVIRONMENTAL Protection AGENCY,

Respondent.

Petition for Review

Utah International Inc., a corporation, hereby petitions

the Court for review of the order and regulations promul-

gated by the Environmental Protection Agency, acting by

and through its Administrator, dated November 27, 1974

and effective January 6, 1975 and entitled ‘‘Approval and

Promulgation of Implementation Plans-Prevention of

Significant Air Quality Deterioration’’, published in 39

Fed. Reg. No, 235, December 5, 1974, at pages 42510 et

seq., insofar as such order and regulations apply to the

State of New Mexico implementation plan and lands lying

within the exterior boundaries of the State of New Mexico.

Utah International Inc., the petitioner, is lessee under

a coal mining lease from the Navajo Tribe of Indians,

holding a valuable coal reserve on the Navajo Reservation

within the exterior boundaries of the State of New Mexico.

The coal reserve is committed by contracts for the fuel

supply for the adjacent Four Corners Powerplant and as

the basis for the future establishment of a coal gasification

complex to be constructed adjacent to the leasehold, Peti-

tioner also has contractual obligations for it to mine coal

for Western Coal Company for the fuel supply for exist-

ing and future units of the San Juan Generating Station.

a

33a

Said existing and prospective sources are located within

the State of New Mexico and have and would have emis-

sions affecting the air quality and deterioration increments

which are the subject of respondent's order and regula-

tions sought to be reviewed; and certain of the future

units at the gasification complex and at the San Juan

Generating Station would, under the regulations sought

to be reviewed, be subject to new source review and emis-

sion limitation as a coudition precedent to construction.

The denial of permission to construct new units at the

gasification complex or at the San Juan Generating Sta-

tion will immediately harm Utah International Inc.’s coal

sales and revenues from mining operations and to the

extent that said order and regulations may force any

curtailment of production at the existing or future sources

said order and regulations would affect adversely the

levels of petitioner’s coal sales and mining operations,

Petitioner has a personal stake and interest in the order

and regulations sought to be reviewed, and its interest

sought to be protected is within the zone of interests

protected by the Clean Air Act Amendments of 1970 and

the constitutional guarantees in question. Congress has

authorized judicial review by § 307(b)(1) of the Clean Air

on (42 U.S.C. § 1857h-5(b)(1)) and 5 U.S.C. §§ 702 and

/s/ Ricuarp N, Carpenter

Richard N. Carpenter

Bioser, Byrp, Carpenter & Crout

Post Office Box 669

Santa Fe, New Mexico 87501

34a

C, C. Dreraica

550 California Street

San Francisco, California 94104

Attorneys for Petitioner

[Certificate of Service omitted in printing)

35a

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 74-2063

[Filed December 27, 1974]

Srerra Cius,

Petitioner,

vs.

ENVIRONMENTAL Protection AGENCY, ET AL.,

Respondents.

Motion and Application of Western Energy Supply and

Transmission Associates and Arizona Public Service Company

to Intervene as Respondents

Western Enercy Suppiy ann Transmission Associates

(hereinafter ‘‘Wesr’’) and Arizona Pusiic Service Com-

pany (hereinafter ‘‘Arizona Public Service’’) move to

intervene as respondents in this action under Rule 24,

Federal Rules of Civil Procedure.

The facts and authorities upon which this Motion is

based are contained in the Memorandum of Points and

Authorities attached hereto and incorporated herein by

this reference. [Memorandum of Points and Authorities

omitted in printing. ]

Daten this 26th day of December, 1974.

Swett & Witmer

/s/ Bruce Norton

Bruce Norton

3100 Valley Center

Phoenix, Arizona 85073

36a

Jenninas, Strouss & SaLMon

/s/ Jow L. Kyu

Jon L. Kyl

Rex FE. Lee

111 West Monroe

Phoenix, Arizona

Cuapman, Durr & Lenzint

/s/ Henry BE. Brown

Henry E. Brown*

Suite 303

1709 New York Avenue, N.W.

Washington, D.C, 20006

Telephone: (202) 872-8311

Attorneys for Intervenors

Western Energy Supply and

Transmission Associates and

Arizona Public Service Company

* Member of Bar of United States Court of Appeals for

the District of Columbia Circuit.

[Certificate of Service omitted in printing]

37a

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

September Term, 1974

No. 74-2063

[Filed January 7, 1975]

Srerra Crivs, 1050 Mills Tower, 220 Bush Street,

San Francisco, California 94104

Petitioners,

Vv.

ENVIRONMENTAL Prorection Acency and

Russevt E. Tray, Administrator,

Environmental Protection Agency,

Respondents.

Berore: Bazelon, Chief Judge

Order

On considerations of the motions of Western Energy

Supply and Transmission Associates (‘‘WEST’’) and

Arizona Public Service Company (‘‘Arizona Public Serv-

ice’’), The Dayton Power and Light Company, Kentucky

Power Company, Kentucky Utilities Company, Ohio Fdi-

son Company, and Ohio Power Company, Utah Power &

Light Company, and Edison Electric Institute (‘‘EEI’’)

for leave to intervene herein, it is

Orperep that Western Energy Supply and Transmission

Associates (‘‘WEST’’) and Arizona Public Service Com-

pany (‘‘Arizona Public Service’’), The Dayton Power and

Light Company, Kentucky Power Company, Kentucky

Utilities Company, Ohio Edison Company, and Ohio Power

Company, Utah Power & Light Company, and Edison

Electric Institute (‘‘EEI’’) are granted leave to intervene

in the above case.

38a

Counsel for the aforesaid intervenors are encouraged

to file joint briefs wherever practicable and may partici-

pate in oral argument only to the extent allowable under

Rule 12 of the General Rules of this Court.

For tHe Court:

Huon E. Kune, ‘lerk

/s/ Danter M,. C atHey

Daniel M. Cathey

Deputy Clerk

39a

Unitep Srates Court or APPEALS

FOR THE D'STRICT OF COLUMBIA CIRCUIT

No. 74-2063

Srerra Civs, Petitioner

v.

ENVIRONMENTAL Protection AGENCY ET AL.,

Respondents

Tue Dayton Power & Licut Co. et aL., Intervenors

No. 74-2079

Srerra Cuus Ev ab., Petitioners

v.

ENVIRONMENTAL Protection AGENCY ET AL.,

Respondents

No. 75-1368

Pustic Service Company or CoLorapo ET AL.,

Petitioners

v.

Unitep States EnvinoNMENTAL Protection AGENCY,

Respondent

Sierra Cuus ev a., /ntervenors

40a

No. 75-1369

Uran Power & Licut Company, Petitioner

v.

ENVIRONMENTAL Protection Acency, Respondent

Srerra Civus et A., [ntervenors

No. 75-1370

State or New Mexico ex rEL. New Mexico

ENviroN MENTAL IMpRovEMENT AceENcy, Petitioner

V.

ENvinoNMENTAL Protection Acency, Respondent

Srerra Cus et Au., [ntervenors

No. 75-1371

Paciric Coat GastricatTion Company ET AL., Petitioners

Vv.

ENviroNMENTAL Protection Acency, Respondent

Srerra Cius et AL., /ntervenors

No. 75-1372

Uran International, Inc., Petitioner

v.

ENVIRONMENTAL Protection Acency, Respondent

Sierra Cuius et au., Intervenors

4la

No. 75-1575

Inptiana-Kentucky Evectric CoRPoRATION ET Ala,

Petitioners

Vv.

Unitep States EnvironMentaL Protection AGENCY,

Respondent

Srerra Cius et av., ntervenors

No. 75-1663

Tue Dayton Power & Licut Company ET AL.,

Petitioners

v.

ENvinonMENTAL Protection AceNncy, Respondent

Srerra Cus et au., [ntervenors

No. 75-1664

Buckeye Power, Inc. et av., Petitioners

v.

ENVIRONMENTAL PROTECTION AGENCY, ET AL.,

Respondents

Srerra Cxvs et a., ntervenors

No. 75-1665

AMERICAN PeTRoLeuM InstiTUTE eT AL., Petitioners

v.

ENVIRONMENTAL Protection Acency, Respondent

Srerra Cuvs et au., Intervenors

42a

No. 75-1666

AtaBaMa Power CoMPANY ET AL., Petitioners

Vv.

ENVIRONMENTAL Protection AGENCY, Respondent

Srerra CLuB ET AL., Imtervenors

No. 75-1763

Montana Power CoMPANY ET AL., Petitioners

v.

Unrrep States ENvinoNMENTAL PROTECTION AGENCY,

Respondent

Srerra Cus eT AL., [ntervenors

No. 75-1764

Sart River Prosect AGRICULTURAL IMPROVEMENT

anp Power District et AL., Petitioners

Vv.

ENVIRONMENTAL PROTECTION AGENCY ET AL.,

Respondents

Srerra Civ et AL., /ntervenors

Petitions for Review of Regulations Promulgated by

the Enivronmental Protection Agency

Argued June 9, 1976

Decided August 2, 1976

43a

Before Wricut, Ropinson, and Wiikey, Circuit Judges.

Opinion for the court filed by Circuit Judge Wricut.

Waicut, Circuit Judge:

Il. IntTROopUCTION

One of the primary purposes of the Clean Air Act, 42

U.S.C. § 1857 et seq. (1970), is ‘‘to protect and enhance

the quality of the Nation’s air resources so as to promote

the public health and welfare and the productive capacity

of its population * * *.’’ Section 101(b)(1), 42 U.S.C.

§ 1857(b)(1). Pursuant to the court order in Sierra Club

v. Ruckelshaus, 344 F.Supp. 253 (D. D.C. 1972), aff’d per

curiam, 4 ERC 1815 (D.C. Cir. 1972), aff’d by an equally

divided Court, sub nom. Fri v. Sierra Club, 412 US. 541

(1973), the Administrator of the Environmental Proteec-

tion Agency (EPA) promulgated regulations designed to

prevent ‘‘significant deterioration’’ of air quality in those

areas which have air that already is cleaner than the

national ambient air quality standards.’ The regulations

* The twin objectives of the Clean Air Act are to improve air

quality where pollution levels do not meet national minimum stand-

ards, and to protect the quality of air that already, as in this case,

is cleaner than national standards. See Part V-A of this opinion

infra. Accomplishment of those objectives is to be a joint enter-

prise of the federal government and the states, the former providing

informed guidance to the implementation efforts of the latter. See

§$ 101(a)(3), (4) of the Act, 42 U.S.C. §§ 1857(a) (3). (4).

Section 108 of the act, 42 U.S.C. § 1857e-3, required the Admin-

istrator of EPA to publish a list of air pollutants which have ‘‘an

adverse effect on public health or welfare.’’ The Administrator was

then to promulgate national primary and secondary ambient air

quality standards for those specified pollutants. National primary

air quality standards are those ‘‘the attainment and maintenance

of which * * * are requisite to protect the public health’’: national

secondary standards are those ‘‘requisite to protect the public wel-

fare from any known or anticipated adverse effects associated with

the presence of such air pollutant in the ambient air.’’ Se tien 109,

[continued |

44a

employ a classification scheme under which these gg

air’? regions may be designated Class I, I, or IIL.

———

42 U.S.C. § 1857e-4. The Administrator has promulzated ta

primary and secondary air quality standards for six po — + ;

sulfur dioxide, particulate matter, carbon monoxide, yr em

oxidants, hydrocarbons, and nitrogen dioxide, 40 C.F.R. §§ 90.

the poe are charged with the duty to develop pet age

plans designed to achieve the level of air quality preseribed by

national primary and secondary standards:

Each State shall have the primary responsibility for _

air quality within the entire geographic area ee = .

State by submitting an implementation plan for such § a

which will specify the manner in which national ot a

secondary ambient air quality standards will be ac oy 7

maintained within each air quality control region in such State.

Section 107, 42 U.S.C. § 1857e-2. The plans are submitted 7

Administrator for approval under the provisions of oa 4

Act, 42 U.S.C. § 1857¢-5 (1970), as yeni ge sar Pie

entation plan must satisfy the re s

eile) cas CAC), 42 USC. § 1857¢-5(a) (2) (A)-(HE), yee

requirements include attainment of the national primary stan a ;

within three years after approval of the plan, and wage eg

the secondary standards within a ‘‘reasonable time. Section

(a) (2)(A), 42 U.S.C. § 1857¢-5(a) (2) (A). . ee

Section 110 also provides that the Administrator is pee .

prepare and publish his own regulations for a state if (a) it Sas ia

submit a plan, (b) the plan ‘‘is determined hy the Administra :

not to be in accordance with the requirements of this section, ;

(«) the state fails to revise its plan pursuant to a provision reer

by § 110(a)(2)(H). Section 110(e) (1), 42 U.S.C. § 1857¢-5 c) “

(Supp. IV 1974). Subseetion (¢) (1) of § 110 also contains a -

ditional hearing requirement for these ‘‘replacement implement 4

tion plans: ‘‘If such State held no public hearing associated ms -

respect to such plan (or revision thereof), the Administrator 6 -

provide opportunity for such hearing within such State on any ” -

posed regulation.’’ Subsection (a) (2) (H) requires that an imple-

mentation plan provide for revision (i) to take account of changes

in either technology or the national standards and (ii) whenever

the Administrator determines that og plan is inadequate to achieve

imary or secondary standards.

Te tak structure jemand above is supplemented by § 111 of

45a

such areas initially are designated Class II, under which

specified increments in sulfur dioxide and particulate mat-

ter pollution are considered ‘‘insignificant.’”? A state, In-

dian territory, or federal land may be redesignated after

hearing and by application to EPA. Designation as Class

I implies a region of very clean air, in which relatively

small increments in air pollution would be considered sig-

nificant deterioration; Class III areas are those in which

deterioration of air quality to the national ambient air

quality standards would be considered insignificant.

The court has heard the regulations attacked from sev-

eral perspectives. Petitioner Sierra Club contends that the

regulations fail, in a variety of ways, to prevent signifi-

cant deterioration of existing clean air. The States of

New Mexico, Wyoming, and California? agree in some

respects with Sierra Club, but are concerned that the regu-

lations infringe on the general regulatory authority vested

in the states by the Clean Air Act. A large number of elec-

tric power companies and industrial organizations have

argued that the regulations are not authorized by the Clean

Air Act, that their promulgation was procedurally defee-

tive, that the allowable increments are arbitrary and eapri-

cious, and that the regulatory structure created by the regu-

lations is unconstitutional.

EEE a

the Act, 42 U.S.C. § 1857¢-6 (1970), as amended (Supp. IV 1974),

which provides for promulgation of ‘‘standards of performance”’

for emission limitations of significant new sources of pollution, by

categories of sources. The standards must reflect ‘the degree of

emission limitation achievable through the application of the best

system of emission reduction which (taking into account the cost of

achieving such reduction) the Administrator determines has been

adequately demonstrated.’’

* The three named states are joined by Maine, Alabama, Colorado,

Kansas, Minnesota, South Dakota, and Florida.

46a

We conclude that the Administrator’s action is ration-

ally based and has not been shown to be either without his

authority or unconstitutional. We therefore do not disturb

the regulations as promulgated.

Il. Lrriecation History

Suit was filed in May 1972 by the Sierra Club and other

environmental protection groups for a declaratory judg-

ment that the Clean Air Act prohibited approval of state

implementation plans which permitted significant deterio-

ration of air cleaner than the national secondary stand-

ards, and for injunctive relief to prevent the Administra-

tor from approving those portions of state implementation

plans which would permit significant deterioration. Dis-

trict Judge John H. Pratt granted plaintiffs’ motion for

a preliminary injunction and declared invalid an EPA

regulation ® which had required only that state implemen-

tation plans ‘‘be adequate to prevent * * * ambient pol-

lution levels from exceeding * * * [the applicable] sec-

ondary standard.’’ Sierra Club v. Ruckelhaus, 344 F.Supp.

253 (D. D.C. 1972). The Administrator was enjoined from

approving any state plan ‘‘unless he approves the state

plan subject to subsequent review by him to insure that

it does not permit significant deterioration of existing

air quality in any portion of any state where the existing

air quality is better than one or more of the secondary

standards promulgated by the Administrator.’’ *

As is apparent from the provisions of the Clean Air

Act outlined above,’ prohibition of significant deteriora-

tion of air cleaner than the national standards is not an

* 40 C.F.R, § 51.12(b) (1975).

* Sierra Club v. Ruckelshaus, Civil Action No. 1031-72 (D. D.C.

May 30, 1972), JA Vol. IV at 1487.

* See note 1 supra.

47a

express requirement of the Act. Judge Pratt based his

decision, rather, on the ‘‘ protect and enhance’’ language of

Section 101(b)(1) of the Act and on the legislative history

of both the Clean Air Act of 1970 and the Air Quality Act

of 1967.° The decision was affirmed per curiam by this

court, 4 .R.C. 1815 (1972), and was affirmed by an equally

divided Supreme Court, sub nom. Fri v. Sierra Club, 412

U.S. 541 (1973).

Pursuant to that order, the Administrator reviewed and

disapproved all state plans insofar as they failed to pro-

vide for prevention of significant deterioration. 37 Fed.

Reg. 22836 (November 9, 1971). Four alternative sets of

regulations were proposed for public comment, in an ef-

fort to determine what meaning to give the concept of

**significant deterioration.’’’ Final regulations were pub-

* The legislative history is discussed at notes 32-38 infra.

738 Fed. Reg. 18986 (July 16, 1973). In proposing alternative

solutions, EPA posed for public debate the problem of how sig-

nificant deterioration was to be defined :

The basis for preventing significant deterioration * * * lies

in a desire to protect aesthetic, scenic, and recreational values,

particularly in rural areas, and in concern that some air pol-

lutants may have adverse effects that have not been docu-

mented in such a way as to permit their consideration in the

formation of national ambient air quality scientific data on the

kind and extent of adverse effects of air pollution levels below

the secondary standards, significant deterioration must neces-

sarily be defined without a direct quantitative relationship

to specific adverse effects on public health and welfare.

* > @ eo

The relative significance of air quality versus economic

growth may be a variable dependent upon regional conditions.

For example, relatively minor deterioration of the aesthetic

quality of the air may be very significant in a recreational

area in which great pride (and economic development) is de-

rived from the ‘‘clean air.’’ Conversely, in areas with severe

[continued }

48a

lished December 5, 1974, 39 bag 3 hag Mg Nom Bong

ded slightly on January 16, : b 2 .

pt 12, 1975 (40 Fed. Reg. 25004), and September 10,

1975 (40 Fed. Reg. 42011).

Ill. Tue Recuiations

In promulgating final regulations * EPA was ee

primarily with the meaning of ‘significant deteriora a

As it stated in the discussion preceding the new reg

tions: |

Most of the comments implicitly recognized that there

is a need to develop resources in presently clean areas

of the country, and that significant aaa eget —e.

ulations should not preclude all growth, but . ou

ensure that growth occurs in an environmenta y -

ceptable manner. However, there are some — =

as national parks, where any deterioration woul awd

ably be viewed as significant. A single nationwi

deterioration increment would not be able to accom-

modate these two situations.

39 Fed. Reg. at 42520. The solution was to — 4

those areas with air cleaner than the national = na “

three classes of allowable total increments above t e —

of particulate matter and sulfur dioxide pollution as

unemployment and little recreational value, the se ne rd

deterioration might very well be considered “insigni * s.

comparison to the favorable impact of new industria —

with resultant employment and other economic — - _

Accordingly, the definition of what constitutes significan el

terioration must be accomplished in a manner to —— -

imposition of inequitable regulations on different segments

the Nation.

Id. at 18987, 18988.

*‘< Prevention of Significant Air Quality Deterioration,’’ 39 Fed.

Reg. 42510 (Dec. 5, 1974).

49a

January 1, 1975, with the intention that each area could

determine which class would prevent significant deterio-

ration of its air in light of the area’s air quality and

social and economic needs and objectives :

Class I applie([s] to areas in which practically any

nge in air quality would be considered significant;

Class II applie{s] to areas in which deterioration

normally accompanying moderate well-controlled

growth would be considered insignificant; and Class

III applie{s] to those areas in which deterioration up

to the national standards would be considered insig-

nificant.

Since the consideration of “air quality factors’”’ alone

essentially leads to an arbitrary definition of what is

**significant,’’ this term only has meaning when the

economic and social implications are analyzed and

considered. Therefore, the Administrator believes that

it is most important to recognize and consider these

implications, since the consideration of air quality

factors alone provides no basis for selecting one de-

terioration increment over another.

Id. The regulations, 40 C.F.R. $§ 52.01(d), (f), and 52.21

(1975), were promulgated as amendments to the disap-

proved state implementation plans.”

All areas initially are designated Class II,*° and may be

redesignated by proposal of state, federal land manager,

* Part 52 of 40 C.F.R. ‘‘sets forth the Administrator's approval

and disapproval] of State plans and the Administrator's promulga-

tion of such plans or portions thereof.’ 40 C_F_R. § 52.02(a) (1975).

Each state implementation plan has been amended to incorporate

by reference the new regulations. See, ey., 40 C.F.R. §§ 52.96

(Alaska), 52.144 (Arizona), 52.181 (Arkansas ).

*° 40 C.F.R. § 52.21(¢) (3) (i) (1975).

Oa

or Indian governing body where the state has not assumed

jurisdiction over Indian lands." Federal land may be des-

ignated only to a more restrictive classification than that

provided by the state(s) in which it is located.”

A state may redesignate if a hearing is held after notice

to states, federal land managers, and Indian governing

bodies that may be affected,” and if the proposed redesig-

nation is based on the record of the hearing,

which must reflect the basis for the proposed redes-

ignation, including consideration of (1) growth an-

ticipated in the area, (2) the social, environmental,

and economic effects of such redesignation upon the

areas being proposed for redesignation and upon other

areas and States, and (3) any impacts of such proposed

redesignation upon regional or national interests.”

A redesignation is to be approved if the state has com-

plied with the listed requirements, has not ‘‘arbitrarily

and eapriciously disregarded’’ the considerations listed

in the passage quoted above, and has undertaken the new

source review requirements of Sections 52.21(d) and (e),

discussed below.”* 40 C.F.R. § 52.21(¢)(3)(vi)(@) (1975).**

1140 C.F.R. §§ 52.21(e) (3) (ii), (iii), (iv), (v) (1975).

22 40 C.F.R. § 52.21(¢) (iv) (1975).

40 C.F.R. §§ 52.21(¢) (3) (ii) (@)-(e) (1975).

#40 C.F.R. § 52.21(e) (3) (ii) (d) (1975).

'* See discussion at notes 20-23 infra.

© In the event of a protest by a state or Indiana goverring body

to a redesignation proposed by another state, federal land manager,

or Indian governing body, the Administrator may approve the pro-

posal ‘‘only if he determines that in his judgment the redesignation

appropriately balances considerations of growth anticipated in the

area proposed to be redesignated; the social, environmental and

economic effects of such redesignation upon the area being redesig-

5la

Federal land managers and Indian governing bodies are

subject to requirements parallel to those imposed on the

states, with the added requirement that they consult with

the state(s) in which they are located.”

If an area is designated as Class I or II, the allowable

incremental pollution is measured from January 1, 1975."

No increments are specified for Class III; areas so des-

ignated are required to meet only the national secondary

standards.”

Enforcement of the limitation on incremental pollution

is accomplished partly through preconstruction review of

19 categories of stationary sources considered to be sig-

nificant sources of pollution.” Permission to construct or

to modify significantly one of the listed stationary sources

is conditioned on a showing that the source’s emissions

together with all other increases or decreases in emissions

in the area since January 1, 1975, will not violate the air

nated and upon other areas and States: and any i

. . . . - ‘

regional or national interests.’’ 40 C.F.R. § 52.21 (e)(3) (vidio)

(1975).

"40 C.F.R. §§ 52.21(¢) (3) (iv), (v) (1975).

*40 C.F.R. § 52.21(¢)(2)(i) (1975). The i

; { 2 . The increments a -

scribed in the following table, included in the cited a nt

Pollutant Class I (ug/m*) Class II

Particulate matter:

Annual geometric mean 5 10

24-hr. maximum 10 30

Sulfur dioxide:

Annual arithmetic mean 2 15

24-hr. maximum 5 100

3-hr. maximum 25 700

40 C.F.R. § 52.21(¢) (2) (ii) (1975).

* 40 C.F.R. § 52.21(d) (1) (i)-(xix) (1975).

Pa

quality increments applicable to qny area.” The source

also must meet an emission limit, specified by the Admin-

istrator, ‘‘which represents that level of emission reduc-

tion which would be achieved by the application of best

available control technology, as defined in § 52.01(f), for

particulate matter and sulfur dioxide.’’ * Preconstruction

review of new proposed sources will be conducted by the

Administrator or, by delegation, by the individual states.”

Last, it should be noted that the described classification

scheme is no procrustean bed to which all states are to be

bound. The states retain the option of proposing an alter-

native method of preventing significant deterioration of

air quility, thereby abandoning the regulatory frame-

work described by the regulations under review. As FPA

stated in proposing regulations:

The State plans need not be identical to the regula-

tions proposed herein, but should be developed to

accommodate more appropriately individual conditions

and procedures unique to specific State and local areas.

States are urged to develop and submit individual

plans as revisions to State Implementation Plans as

soon as possible. When individual State Implemen-

140 C.F.R. § 52.21(d) (2)(i) (1975), as amended, 40 Fed. Reg.

42011 (Sept. 10, 1975).

2240 C.F.R. § 52.21(d)(2) (ii) (1975). ‘Best available control

technology’’ is defined as equivalent to the new source performance

standards promulgated under § 111 of the Clean Air Act, 42 U.S.C.

§ 1857-6. See discussion at note 1 supra. If no standard of per-

formance has been promulgated for a source, best available control

technology is determined on a case-by-case basis. 40 C.F.R. § 52.01

(f) (1975).

2340 C.F.R. § 52.21(f) (1975). See also 40 C.F.R. § 52.21(d) (4)

(1975), which provides for cooperation between the Administrator

and federal land managers for review of new sources on federal

land, and between the Administrator and the Secretary of the

Interior as to lands over which a state has not assumed jurisdiction.

ia

tation Plan revisions are approved as adequate to pre-

vent significant deterioration of air quality, the ap-

plicability of the regulations proposed herein will be

withdrawn for that State.

39 Fed. Reg. at 31000 ( August 27, 1974).

IV. Stanparp or Review

It is well settled that EPA rulemaking is reviewed under

Section 10 of the Administrative Procedure Act, 5 U.S.C.

§ 706(2) (A)-(D) (1970). Ethyl Corp. v. EPA, —— US.

App.D.C. . . F.2d . , slip op. at 66-

74 (No. 73-2205, decided March 19, 1976). We must de-

termine whether the Agency’s action, findings, and con-

clusions are invalid as procedurally defective (4 706(2)

(D)), in excess of legislative authority (§ 706(2)(C)), un-

constitutional (§ 706(2)(B)), or ‘‘arbitrary, capricious, an

abuse of discretion, or otherwise not in accordance with

law’’ (§ 706(2)(A)).

The ‘‘arbitrary and capricious’”’ standard requires that

agency action be affirmed if a rational basis exists there-

fore *; it is not for us to inquire into whether the decision

is wise as a matter of policy, for that is left to the disere-

tion and developed expertise of the agency.”* The Supreme

Court has cautioned, with respect to review under the ‘‘ar-

bitrary and capricious’’ standard, that the reviewing court

is limited to deciding whether there has been a ‘‘clear error

of judgment * * *. Although this inquiry into the facts

is to he searching and careful, the ultimate standard of re-

view 1s a narrow one. The court is not empowered to sub-

** Bowman Transportation, Inc. v. Arkansas-Best Freigh

Inc., 419 U.S, 281, 290 (1974). —

“National Ass’n of Food Chains, Inc. v. ICC, —— US. App.

D.C. " ’ F.2d " , Slip op. at 13 (Ne. 75-1471

decided May 18, 1976) (per curiam). angie aie

Hj4a

stitute its judgment for that of the agency.’’ Citizens to

Preserve Overton Park v. Volpe, 401 U.S. 402, 416 (1972).

See Ethyl Corp. v. EPA, supra, —— U.S.App.D.C. at ——

n.74, F.2d at n.74, slip op. at 69 n.74.

We therefore must assure ourselves that the Agency has

presented a rational basis for its decision * ; that it ‘‘dem-

onstrably has given reasoned consideration to the issues,

and has reached a result which rationally flows from its

conclusions.’’ **

V. ARGUMENT

A. Should Sierra Club v. Ruckelshaus be rejected on fur-

ther consideration?

The question whether the Clean Air Act should be inter-

preted to prohibit significant deterioration of air cleaner

than the national standards is necessarily the first level of

analysis. Although this issue was decided by the earlier

Sierra Club v. Ruckelshaus litigation, it is contended by

the industrial petitioners (1) that the decision was clearly

wrong on the merits and should be reconsidered and (2)

that the later decision in Train v. NRDC, 421 U.S. 60

(1975), and enactment of the Energy Supply and Environ-

mental Coordination Act of 1974, 88 Srar. 246, are incon-

sistent with the prior decision in Sierra Club v. Ruckels-

haus.

26 We note that the basis of agency action must be provided by

the agency; an order ‘‘cannot be upheld merely because findings

might have been made and considerations disclosed which would

justify its order as an appropriate safeguard for the interests

protected by the Act. There must be such a responsible finding

***"’ SEC v. Chenery Corp., 318 U.S. 80, 94 (1943) ; see National

Ass’n of Food Chains, Inc. v. ICC, supra note 25, U.S.App.

D.C. at , —— F.2d at ——., slip op. at 12-13.

*? National Ass’n of Food Chains, Inc. v. 1CC, supra note 25, ——

U.S.App.D.C. at . F.2d at ——, slip op. at 14.

Da

The first argument obviously would require the clear-

est showing that Sierra Club v. Ruckelshaus was incorrect-

ly decided, since Judge Pratt’s decision was affirmed by

both another panel of this court and an equally divided

Supreme Court. It is posited that neither the ‘‘ protect and

enhance’’ language of Section 101(b)(1) nor the legisla-

tive history of the Clean Air Act need to be read to impose

a requirement of nondeterioration; petitioners then point

out that, to the contrary, a 1970 amendment to the Act,

Section 110(a)(2), 42 U.S.C. § 1857e-5(a)(2), states that

the Administrator ‘‘shall approve’’ a state implementa-

tion plan which meets the criteria listed in that section,

none of which implies a nondeterioration standard. The

conclusion advanced by petitioners is that the judicially-

created requirement of nondeterioration violates this plain

language of the 1970 amendment.

When a specific provision of a total statutory scheme

reasonably may be construed to be in conflict with the con-

gressional purpose expressed in the act, our first task

is to examine the act’s legislative history to determine

whether the specific provision is reconcilable and consistent

with the intent of Congress.** We find, in the legislative

history of the Clean Air Act of 1970, a clear understanding

that the Act embodied a pre-existing policy of nondeterio-

ration of air cleaner than the national standards. Inas-

much as we find no support for the proposition that the

addition of Section 110(a)(2) was intended to limit that

policy in any way, we reaffirm our prior holding in Sierra

Club v. Ruckelshaus.

The ‘‘proteect and enhance’’ language of the Clear Air

Act was added by the Air Quality Act of 1967, 81 Srart.

28 See FTC v. Fred Meyer, Inc., 390 U.S. 341, 349 (1968) : ‘‘{Wle

cannot, in the absence of an unmistakable directive, construe the

Act in a manner which runs counter to the broad goals which Con-

gress intended it to effectuate.’’

D6a

425.2% The administrative interpretation and, to a lesser

degree, the legislative history of the Air Quality Act ex-

pressed a policy of nondeterioration,” and that policy ap-

pears generally to have been accepted at the time of the

addition of the Clean Air Act amendments of 1970.

In the Senate hearings on the Clean Air Act amend-

ments of 1970, the officials charged with implementation

of the 1967 Act expressed their clear understanding that

the ‘‘protect and enhance’’ language of Section 101 man-

dated the policy of nondeterioration. HEW Secretary Rob-

29 Air Quality Act of 1967, S. Rep. No. 91-403, 90th Cong., 1st

Sess. 40 (1967).

9° Sierra Club v. Ruckelshaus, 344 F.Supp. 253, 255 (D. D.C.

1972) ; ENVIRONMENTAL Law INSTITUTE, FEDERAL ENVIRONMENTAL

Law, 1974 at 1077-1080. The Senate committee report on the Air

Quality Act emphasized that the Act would apply to all areas

of the country, and quoted Senator Muskie for the proposition that

it was necessary ‘‘to assure the lessening of current levels of pollu-

tion and to prevent further environmental deterioration in the

future.”’ Air Quality Act of 1967, supra note 29, at 2-3, 8.

The Act was administered by the National Air Pollution Control

Administration of the Department of Health, Education and Wel-

fare, which formalized the concept of nondeterioration in its Guide-

lines for the Development of Air Quality Standards and Implemen-

tation Plans, Part I, § 1.51 at 7 (1969):

‘‘TA]n explicit purpose of the Act is ‘*to protect and enhance

the quality of the Nation’s air resources’’ (emphasis added).

Air quality standards which, even if fully implemented, would

result in significant deterioration of air quality in any sub-

stantial portion of an air quality control region clearly would

conflict with this expressed purpose of the law.

See generally, Non-Degradation—Clean Air Act and Amendments

Held to Mandate a Policy Prohibiting Significant Deterioration of

Air Quality in Areas of Relatively Clean Air, 2 ForpHAM URBAN

L. J. 136 (1973) (hereinafter Clean Air Act Held to Prohibit Sig-

nificant Deterioration); The Clean Air Act and the Concept of

Non-Degradation: Sierra Club v. Ruckelshaus, 2 Eco.toey L. Q.

801 (1971) (hereinafter The Concept of Non-Degradation).

57a

ert H. Finch testified as follows in a state

nent

by Undersecretary John Veneman: ment presented

In their implementation plans, the States would

have to spell out the measures to be taken to achieve

and preserve national air quality standards. As I

have indicated, they would have the option of de-

signing their implementation plans to achieve or pre-

serve higher than national quality levels, if they wished

to do so. ,

As you know, one of the express purposes of the

Clean Air Act is ‘‘to protect and enhance the qual-

ity of the Nation’s air resources’’ * * *, Accordingly

it has been and will continue to be our view that inn

plementation plans that would permit significant de-

terioration of air quality in any area would be in con-

flict with this provision. We shall continue to expect

States to maintain air of good quality where it now

exists.

Air Pollution—1970, Hearings before the Subcommittee

on Air and Water Pollution of the Senate Committee on

Public Works, Part I, 132-133 (1970). Undersecretary

Veneman went on to state that ‘‘ [i]t will continue to he our

view that implementation plans that would permit signifi-

cant deterioration of air quality in any area would be in

conflict with the provisions of the Act. We do not intend

to condone ‘backsliding.’ If an area has air quality which is

better than the national standards, they would be required

to stay there an‘ not pollute the air ever further, even

though they may be below national standards.”’ /d. at 143.

The Senate committee report gave express recognition

to the concept of nondeterioration, directing that

[t]n areas where current air ollution levels are al-

ready equal to, or better than, the air quality goals

the Secretary should not approve any implementa.

tion plan which does not provide, to the marimum exr-

5Sa

tent practicable, for the continued maintenance of such

ambient air quality. Once such national goals are

established, deterioration of air quality should not be

permitted except under circumstances where there

is no available alternative.

S. Rep. No. 91-1196, 91st Cong., 2d Sess. 11 (1970) (em-

phasis added). Quite to the contrary, however, there was

no particular significance ascribed to the ‘‘shall approve

language of the section which became Section 110(a) (2).

Td. at 11-15.

The explanation of this omission in the legislative history

appears to be that the 1970 amendmeits were aimed at

states that refused to take action to improve their air

quality. The background of the 1970 amendments was

described in Train v. NRDC, supra, 421 U.S. at 64:

The response of the States to these manifestations

of increasing congressional concern with air pollution

was disappointing. Even by 1970, state planning and

implementation under the Air Quality Act of 1967 had

made little progress. Congress reacted by taking a

stick to the States in the form of the Clean Air Amend-

ments of 1970 * * *.

The ‘‘stick’? was the group of express requirements as to

the content of state implementation plans.” The ‘‘shall

21‘*The Committee recognized that because the proposed bill

would require a great deal in a short period of time and because

the brevity of the provision in existing law has lead to uneven and

inadequate interpretation, the character of an implementation plan

must be specified and the alternative methods of achievement listed.

The Committee bill would require that a rigorous time sequence be

met in the development of the implementation plan and would pro-

vide for the substitution of Secretarial authority if the State plan,

or a portion thereof, is inadequate to attain the quality of ambient

air established by the nationally promulgated ambient air quality

standard.’’ S. Rep. No. 91-1196, 91st Cong., 2d Sess. 12 (1970).

gow eC

59a

approve”’’ language was addressed to the administrative

problems that would be caused by a requirement that all

states submit complying implementation plans within a

limited time; the provisions of Section 110(a) are, more

than anything else, a summary of the mandatory require-

ments for all state implementation plans.*? We have, how-

ever, found no indication, nor have we been cited to any

indication in the legislative history, that Section 110 was

intended in any way to vitiate the nondeterioration man-

date contained in the Senate report.”

This court has recently cautioned that a failure by Con-

gress expressly to reject the administrative construction

of an act need not, without more, indicate congressional

asquiescence in the ageney interpretation.* In Chisholm v.

FCC, U.S. App.D.c. : F.2d (No. 75-

*2 See note 31 supra.

See The Concept of Non-Degradation, supra note 30, at 819:

The legislative history does support the contention that the

principle of non-degradation is implicit in the Clean Air Act.

It resolves the vagueness of both the purpose clause and section

110. Although the history of the 1967 Act conveys an ambigu-

ous picture of the legislative intent, the history of both the

1970 Amendments and the later Implementation Hearings

clearly indicates that Congress confronted the complexities of

air pollution control and undertook a program designed to

prevent the deterioration of clean air.

** Chisholm v. FCC, —~ US.App.D.C. . ; F.2d

; , Slip op. at 26 (No, 75-1951, decided April 12, 1976) :

We begin by noting that attributing legal significance to

Congressional inaction is a dangerous business * * *. The

Supreme Court has said that Congressional failure to repudiate

particular decisions ‘‘frequently betokens unawareness, pre-

occupation, or paralysis’’ rather than conscious choice, Zuber

v. Allen, 396 U.S. 168, 185-86 n. 21 (1969), and ‘‘affords the

most dubious foundation for drawing positive inferences,”’

United States v. Price, 361 U.S. 304, 310-11 (1960) (Harlan,

J.).

60a ae

1951, decided April 12, 1976), the court refused to ascribe

significance to congressional inaction when it appeared that

Congress was ‘‘aware’’ of the administrative interpreta-

tion only ‘‘in a technical sense.’” —— U.S. App.D.C. at

, — F.2d at , slip op. at 27. We are not presented

with that situation. Not only was the Agency’s interpre-

tation of the Air Quality Act of 1967 as mandating preven-

tion of significant deterioration clearly before the Congress

in 1970, but the committee reports contain express lan-

guage that the principle of nondeterioration was preserved

by the Clean Air Act Amendments of 1970.

of significant deterioration of air quality. In addition, we

find nothing in the legislative history to indicate that Con-

gress had any desire or intention that the 1970 amend-

ments hinder the fight against air pollution by voiding the

principle of nondeterioration.

It is significant in this regard that recent congressional

statements have supported the historic existence of a

requirement of nondeterioration. The report of the House

Committee on Interstate and Foreign Commerce on the

proposed Clean Air Act Amendments of 1976 (H.R. Rep.

This sort of express congressional recognition of the

implementing agency’s statutory construction can be ex-

tremely significant in interpreting legislative intent. In

NLRB v. Bell Aerospace Co., 416 U.S. 267 (1974), for in-

stance, the Court found approval of a long-standing admin-

istrative interpretation in Congress’ studied inaction:

In addition to the importance of legislative history,

a court may accord great weight to the longstanding

interpretation placed on a statute by an agency charged

with its administration. This is especially so where

Congress has re-enacted the statute without pertinent

change. In these circumstances, congressional fail-

ure to revise or repeal the agency’s interpretation 1s

persuasive evidence that the interpretation is the one

intended by Congress.

416 U.S. at 274-275. The Court reached similar results in

Zemel v. Rusk, 381 U.S. 1, 11 (1965) (administration of

Passport Act of 1926); C. 1. R. v. Estate of Noel, 380 U.S.

678, 682 (1965); NLRB v. Gullett Gin Co., 340 U.S. 361,

365-366 (1951); Helvering v. R.J. Reynolds Tobacco Co.,

306 U.S. 110, 114-225 (1939); and Norwegian Nitrogen Co.

v. United States, 288 U.S. 294, 313 (1933), among others.

In the instant case there is every indication that Con-

gress intended in 1970 to continue a policy of prevention

No. 94-1175, May 15, 1976) endorses a new statutory defini-

tion of nondeterioration, commenting that ‘‘[t]he Com-

mittee has developed this section to provide clearer defini-

tion of the nearly decade-old policy (reflected in section 101

(b) of the Act) that significant deterioration of clean air

must be avoided, and to provide more specific congressional

guidance as to how this policy is to be implemented.”’ Jd.

at 83. A contemporaneous report of the Senate Committee

on Public Works on similar proposed amendments has

both restated the language quoted above from the 1970

Senate report “ and reaffirmed the continuing policy of non-

deterioration:

A nondegradation policy was articulated first in

Federal water pollution law. That was in 1965. The

concept was incorporated into the 1967 Air Quality

Act, which stated that a basic purpose of the Act was

to *‘protect and enhance the quality of the Nation’s

air resources.’? That language was not altered by the

1970 Clean Air Amendments. This bill clarifies and

details that policy.

Clean Air Amendments of 1976, S. Rep. No. 94-717 at 20

(March 29, 1976). It would fly in the face of overwhelming

evidence of legislative intent to hold that the Clean Air

* See pp. [19a-20a] supra.

62a

Act does not contain a requirement of prevention of sig-

nificant deterioration.

Our belief that Sierra Club v. Ruckelshaus was decided

properly is bolstered by its acceptance in a number of

other circuits.** Petitioners suggest, however, that the later

decision in Train v. NRDC, 421 U.S. 60 (1975), and enact-

ment of the Energy Supply and Environmental Coordina-

tion Act of 1974, 88 Srat. 246, are necessarily inconsistent

with the concept of nondeterioration of air quality. We

reject both contentions.

Train v. NRDC involved construction of the **shall ap-

prove’’ language of Section 110(a)(3)(A),* which re-

quires that the Administrator approve revisions of state

plans which, after revision, meet the criteria of Section

110(a)(2). The Court held that state action which grants

a variance to an individual pollution source must be ap-

proved by the Administrator if the approval will not ex-

pand the time for compliance with national primary am-

bient air quality standards * or otherwise violate the re-

36 See NRDC v. EPA, 489 F.2d 390, 408 (5th Cir. 1974), rev'd

on other grounds, sub nom. Train v. NRDC, 421 U.S. 60 (1975);

Big Rivers Electric Corp. v. EPA, 8 ERC 1092 (6th Cir. 1975) ;

Union Electric Co. v. EPA, 515 F.2d 206, 220 (8th Cir. 1975),

aff’d on other grounds, USS. , 44 US. L. Week 5060

(June 25, 1976); NRDC v. EPA, 507 F.2d 905, 913 (9th Cir.

1974). Cf. Highland Park v. Train, 519 F.2d 681, 685 (7th Cir.

1975).

37‘<'The Administrator shall approve any revision of an imple-

mentation plan applicable to an air quality control region if he

determines that it meets the requirements of paragraph 2 {§ 110

(a) (2)] and has been adopted by the State after reasonable notice

and public hearings.’’ Section 110(a)(3)(A), 42 U.S.C. § 1857e-5

(a)(3)(A) (Supp. IV 1974).

38 Section 110(a) (2) (A), 42 U.S.C. § 1857e-5(a) (2) (A) (1970) :

The Administrator shall approve such plan, or any portion

thereof, if he determines that it was adopted after reasonable

63a

quirements of Section 110(a)(2). In the following passage,

strongly pressed upon us by petitioners, the Court em-

phasized the mandatory language of Section 110(a)(2):

The Agency is plainly charged by the Act with the

responsibility for setting the national ambient air

standards. Just as plainly, however, it is relegated by

the Act to a secondary role in the process of determin-

ing and enforcing the specific, source-by-source emis-

sion limitations which are necessary if the national

standards it has set are to be met. Under § 110(a) (2)

the Agency is required to approve a state plan which

provides for the timely attainment and subsequent

maintenance of ambient air standards, and which also

satisfies that section’s other general requirements

The Act gives the Agency no authority to question

the wisdom of a State’s choices of emission limita-

tions if they are part of a plan which satisfies the

standards of § 110(a)(2), and the Agency may devise

and promulgate a specific plan of its own only if a

State fails to submit an im i

plementation pl

satisfies those standards. oe

= US, at 79 (emphasis in original). It is argued that

is decision removes from the Administrator the discre-

notice and hearing and thet-——

(A) (i) in the case of a plan implementing a nationa i

. : :

— yey air quality standard, it provides for the seach

= of such primary standard as expeditiously as practicable

in no case later than three years from the date of

Page of such plan (or any revision thereof to take account

of a revised primary standard) ; and (ii) in the case of a plan

implementing a national secondary ambient air quality stand-

ard, it specifies a reasonable ti i

Pe we aenane ime at which such secondary

39

The language was repeated in Hancock v. Train, Us

. , 44 US. L. Weex 4767, 4768 (June 7 i

V EEK I » 7, 1976) (diet

+ sagen concerned the obligation of federal facilities to coun —

the requirements of state implementation plans. 4

64a

tion to disapprove a plan which complies with Section

110(a)(2), and therefore requires that Sierra Club v.

Ruckelshaus be overturned. This argument, however, is

subject to the same analysis by which we reject the argu-

ment based on Section 110(a)(2) alone. Unlike the instant

case, Train was concerned with air pollution below the

national standards, and the question was whether individ-

ual variances would prevent the states from achieving the

standards within the prescribed time limits. The Supreme

Court in Train did not consider the issue of nondeteriora-

tion, even though the decision below was based in part on

Sierra Club v. Ruckelshaus.” Rather than assume, as the

industrial petitioners would have us, that Train silently

overturned the earlier divided affirmance in Sierra Club,

we find it more reasonable to conclude that the Court did

not address the issue, and we reject the argument based on

Train.

In another recent decision, Union Electric Co. v. EPA,

U.S. —, 44 U.S. L. Weex 5060 (June 25, 1976),

the Supreme Court found challenges to state implementa-

tion plans based on economic infeasibility to be barred

by the mandatory nature of Section 110(a)(2). The Court

found in the legislative history of the 1970 amendments a

congressional determination that clean air objectives

should take precedence over claims of economic or techno-

logical infeasibility :

As we have previously recognized, the 1970 Amend-

ments to the Clean Air Act were a drastic remedy to

what was perceived as a serious and otherwise un-

checked problem of air pollution. The Amendments

place the primary responsibility for formulating pol-

lution control strategies on the States, but nonetheless

*°NRDC v. EPA, supra note 36, 489 F.2d at 408. The Train

decision was limited expressly to the question of approval of vari-

ances. 421 U.S. at 69-70.

peewee ee oe

65a

subject * * * the States to strict minimum compliance

requirements. These requirements are of a ‘‘technolo-

gy-forcing character,’’ Train v. NRDC, 421 US., at

91, and are expressly designed to force regulated

sources to develop pollution control devices that might

at the time appear to be economically or technologically

infeasible.

This approach is apparent on the face of § 110(a)

(2). The provision sets out eight criteria that an im-

plementation plan must satisfy, and provides that if

these criteria are met and if the plan was adopted

after reasonable notice and hearing, the Administra-

tor ‘‘shall approve’’ the proposed state plan. The

mandatory **shall’’ makes it quite clear that the Ad-

ministrator is not to be concerned with factors other

than those specified, Train v. NRDC, 421 U S., at 71 n.

11, 79, and none of the eight factors appears to permit

consideration of technological infeasibility.

— US. at —, 44 US. L. Week at 5063. Although

the Court stressed the ‘‘shall approve’’ language of Sec-

tion 110(a)(2), its construction was founded on a con-

cern that the congressional mandate of prompt implemen-

tation of pollution control plans not be disserved. The

Court was not presented with the distinct question whether

the ‘‘shall approve’’ language of Section 110(a)(2) must be

read to subvert the concomitant congressional directive

that significant deteriation of air cleaner than the national

standards be prevented.“ Thus, despite the emphasis

placed on (a)(2) by the opinions in Train v. NRDC and

*' As was the case in Train v. NRDC, the low i

’ A er court in Union

Electric expressly had approved the concept of prevention of sig-

nificant deterioration. Union Electric Co. v. EPA, supra note 36

515 F.2d at 220 n.39. The Supreme Court affirm

Appeals without mentioning that issue. affirmed the Court of

66a

Union Electric, we do not believe the result in the instant

case is controlled by either opinion.

Petitioners also rely on the Energy Supply and En-

vironmental Coordination Act of 1974 (ESECA), which

was enacted to encourage stationary fuel-burning sources

to convert from oil to coal, to minimize the nation’s de-

pendence on imported oil. Among other things, it (1) au-

thorized the Federal Energy Administration to require

power plants and other major fuel-burning sources to

burn coal, (2) amended the Clean Air Act to provide a

limited exemption from stationary source requirements

to those converting facilities,“ and (3) required the Ad-

ministrator of EPA to review the implementation plan

of each state and notify any state which could revise its

plan as to stationary fuel-burning sources without violating

the national ambient air quality standards. The ESECA

is accommodated in the ‘‘significant deterioration’’ regu-

lations by 40 C.F.R. §52.21(d)(1), which exempts from

preconstruction review modifications ‘‘to utilize an alter-

native fuel, or higher sulfur content fuel.’’

Although conversion to ‘‘dirtier’’ fuels such as coal

certainly will impair both improvement and maintenance

of air quality, there is no reason to believe that passage of

ESECA was intended to eliminate the requirement of non-

deterioration."* The amendinent was a necessary response

*2 Section 119, 42 U.S.C. § 1857¢-10 (Supp. IV 1974).

*8 Section 110(a) (3)(B), 42 U.S.C. § 1857¢-5(a) (3)(B) (Supp.

IV 1974).

** The ‘‘purpose’’ section of ESECA, 15 U.S.C. § 791 (Supp. IV

1974), is as follows:

The purposes of this chapter are (1) to provide for a means

to assist in meeting the essential needs of the United States for

fuels, in a manner which is consistent, to the fullest extent

practicable, with existing national commitments to protect and

67a

to the nationwide shortage of oil and natural gas, and no

reason has been presented for ascribing to it a greater

significance.”

We therefore find no substantial reason to question un-

der ESECA or Train, the continuing validity of Sierra

Club v. Ruckelshaus, and we proceed to the substance of

a under review using that decision as our

guide.

B. Are the regulations invalid on the ground that only

two of the six primary air pollutants are considered?

The regulations provide for control only of particulate

matter and sulfur dioxide emissions, whereas the Ad-

ministrator also has identified carbon monoxide, nitrogen

oxides, hydrocarbons, and photochemical oxidents as air

pollutants which have an adverse effect on public health

or welfare.” It is contended that the regulations violate

the District Court’s order in Sierra Club v. Ruckelshaus by

failing to prevent significant deterioration of air quality

with respect to those four pollutants.“

improve the environment, and (2) to provide requirements for

reports respecting energy resources.

(Emphasis added. )

*° We also Teject the argument that it is ‘‘unfair’’ to count the

np emissions from a source that is converted to coal against

the allowable pollution increment for the area, since that modifica-

= is exempted from preconstruction review. We see no reason

= y ao ” ron major utilities have been forced to convert to

not choose to impose commensuratel i

on the remainder of the area. ee

** See note 18 supra.

40 C.F.R. §§ 50.8-50.11 (1975).

“ The order required that the Administrator ‘‘

; ; prepare and pub-

lish proposed regulations, pursuant to 42 U.S.C. § 1857¢-5 (ec). as to

[continued |

68a

EPA has responded that the interrelationships among

those four pollutants, and the relationships between in-

cremental increases in those pollutants and deterioration

of air quality, are poorly understood and cannot be de-

termined with any reasonable degree of accuracy :

These [four pollutants] are commonly referred to as

‘automotive pollutants,’ because the automobile is

the major source of each of them * * *. The first three

(HC, NOz and O,) are also known as ‘* photochemical’”’

or ‘‘reactive’’ pollutants, because under the influence

of sunlight, they enter into a complex chemical reac-

tion in the atmosphere. * * * The rate at which the

reaction oceurs depends on a number of variables, in-

cluding temperature, humidity, solar intensity, and

the concentrations of the input pollutants. * * *

The chief reason for excluding photochemical pol-

lutants from these regulations is that the relationship

between the emission of HC and oxides of nitrogen,

on the one hand, and the resulting ambient levels of

the harmful pollutants. O. and NOs, on the other,

is very poorly understood. The only method for relat-

ing emissions to air quality for these pollutants is

the ‘‘area-wide proportional model.’’ This model as-

sumes, as its name suggests, that ambient pollutant

levels are proportional to total emissions. The model

is useful only in areas where ambient pollutant levels

are substantial and well-monitored, as in urban areas

with smog problems. * * * But the proportional model

cannot be used to regulate air quality deterioration

in clean-air areas. This is because the assumptions

any state plan which he finds, on the basis of his review, either

permits the significant deterioration of existing air quality in any

portion of any state or fails to take the measures necessary to pre-

vent such significant deterioration.’’ Sierra Club v. Ruckelshaus,

Civil Action No, 1031-72 (D. D.C. May 30, 1972).

69a

underlying the mode! do not hold in clean-air areas, and

also because it is not possible to make accurate mea-

surements of ambient levels of photochemical pollut-

ants that are substantially below the level

national standards. 4 oe

Br. for respondent at 32-33 (footnote omitted), elucidatin

9 Fed. Reg. 31006 (August 27, 1974), 39 Fed. Rog. 42511

( December 5, 1974); Technical Support Document—EPA

Regulations for Preventing the Significant Deterioration

of Air Quality, U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards (January

1975), at 21-27 (J A 117-123). EPA concluded that existing

technology ‘‘is inappropriate for analyzing the increment-

al impact of individual new sources’’ with respect to the

four ‘‘automotive pollutants,’ and that ‘‘lalt this time

the only practical approach for dealing with these pollut.

ants: appears to be to minimize emissions as much as

possible.’’ 39 Fed. Reg. 42511 (December 5, 1974). EPA

further has contended that ongoing programs toward re-

duction of automotive emissions ‘‘are adequate to prevent

any significant deterioration due to sources of carbon

monoxide, hydrocarbons or nitrogen oxides.’’

Petitioners have emphasized that the four omitted pol-

lutants can have extremely adverse effects on public health

and welfare, and have noted that they are emitted b

stationary sources as well as by moving vehicles. Peti-

tioners have not, however, directly clashed with EPA’s

contention that it does not have technology or modeling

techniques rationally to regulate emissions on a case-by-

case basis. This is the type of policy decision in which the

Agency’s developed expertise is heavily implicated, and

with which the court will not tamper so long as the deci-

sion was rational and based on consideration of the rele-

* 39 Fed. Reg. 31006 (Aug. 27, 1974).

70a

vant factors. Ethyl Corp. v. EPA, supra, U.S. App.

D.C. at - , — F.2d at - , slip op. at 66-

74. Given the absence of any direct denials of EPA’s as-

sertions on this point, the Agency is entitled to claim the

presumption of validity which attends its actions. Id., slip

op. at 68. We therefore hold that EPA did not act unlaw-

fully in excluding from its regulations the four ‘‘automo-

tive pollutants.”’

C. Are Class II and Class III invalid as permitting

significant deterioration of air quality?

D. Is it unlawful to make determinations as to per-

missible air quality deterioration on the basis of

considerations other than air quality?

It is argued by Sierra Club that Classes IT and III, by

permitting increases in sulfur dioxide and particulate mat-

ter pollution to levels which in some areas may be many

times present concentrations, allow significant deteriora-

tion of air quality. The ‘‘significance’’ is primarily a mat-

ter of the numbers involved; although evidence has been

presented that levels of pollution below the national sec-

ondary standards may have adverse health effects,” it is

for the Administrator rather than the courts to determine

that the national secondary standards no longer can be said

to protect the public from ‘‘any known or anticipated ad-

verse effects’’ of a pollutant. The question of significance

thus leads by implication to a second line of argument—

that it is unlawful to consider deterioration of air quality

‘‘insignificant’’ simply because it accompanies normal, con-

trolled economic development.

°° Br. for petitioners Sierra Club et al., No, 74-2063, at 18-20. See

also Clean Air Act Amendments of 1976, Report of the Senate

Committee on Public Works, S. Rep. No. 94-717 at 19-27 (March

29, 1976); Clean Air Act Amendments of 1976, Report of the

House Committee on Interstate and Foreign Commerce, II.R. Rep.

No. 94-1175 at 83-116 (May 15, 1976).

Tla

EPA recognized, in developing the concept of ‘‘signifi-

cant deterioration’’ pursuant to Judge Pratt’s order, that

**[p]ending the development of adequate scientific data on

the kind and extent of adverse effects of air pollutant levels

below the secondary standards, significant deterioration

must necessarily be defined without a direct quantitative

relationship to specific adverse effects on public health and

welfare.’’ 39 Fed. Reg. 18987 (July 16, 1973), It therefore

determined that each state must determine what level of

incremental polluticn, taking into account the air quality

and social and economic needs and objectives of the area,

would be ‘‘significant deterioration’’ of its air quality.”

In that context, it was a rational policy decision that

the significance of deterioration of air quality should be

determined by a qualitative balancing of clean air con-

siderations against the competing demands of economic

growth, population expansion, and development of alter-

native sources of energy. The approach provides a work-

able definition of significant deterioration which neither

stifles necessary economic development nor permits un-

regulated deterioration to the national standards. We

therefore find that EPA acted within the discretion it is

granted as to matters of policy * in choosing this design

to prevent significant deterioration of air quality.

** See pp. [10a-lla] supra.

** EPA acknowledges that all states theoretically could reclassify

to Class III, thereby permitting unregulated deterioration to the

national standards. It asks that the states not ‘‘arbitrarily and

capriciously”’ disregard its outlined considerations before redesig-

nating areas. 40 C.F.R. § 52.21(¢) (3) (vi) (a).

” ““However formal the type of agency proceeding, an agency’s

policy choices are reviewed under the arbitrary and capricious

standard, which asks merely whether the policy choice is rationally

connected to its factual basis.’’ Judicial Review of the Facts in

Informal Rulemaking: A Proposed Standard, 84 Y

1751 (1975). -_ rd, 84 Yaue L. J. 1750,

72a

We may state our belief, as a general overview at this

point, that for the most part it somewhat misses the

mark to raise objections to the specific emission limits

of the regulations under review. EPA has emphasized

that the individual states are free to conceive and adopt

their own methods of preventing significant deteriora-

tion. A state may use EPA’s system to classify itself as

industrial-metropolitan (Class IIT), as anticipating nor-

mal economic growth (II), or as desirous of protecting its

clean air (I). But it also may develop its own scheme,

based on its own needs, so long as the regulatory structure

prevents significant deterioration of air cleaner than the

national standards. Given the broad power vested in the

states to alter or amend these regulations, we find little

merit in objections to the specifics of the classification

scheme itself.

E. Has the effective date of the regulations been post-

poned unlawfully beyond the date contemplated by

the Clean Air Act?

The Clean Air Act of 1970 impusecd a series of time

limits for the various steps leading up to approval of state

implemention plans. Under that timetable regulations

should have become effective by the middle of 1972."

‘The Clean Air Act Amendments of 1970 were added on Dee.

31, 1970, 84 Star. 1677. The Administrator was given 90 days in

which to propose and promulgate national primary and secondary

ambient air quality standards. Section 199(a)(1)(B), 42 U.S.C.

§ 1857¢-4(a)(1)(B). The states then were given nine months to

submit proposed implementation plans to the Administrator, § 110

(a) (1), 42 U.S.C, § 1857e-5(a) (1), and the Administrator had four

months to approve or disapprove the plans. Section 110(a) (2), 42

U.S.C. §1857¢-5(a) (2). The Administrator was to ‘‘promptly pre-

pare and publish’’ implementation plans for states which failed to

submit a complying plan or which failed to revise a plan after 60

days notice. Section 110(¢), 42 U.S.C. § 1857e-5(¢). The target date

for effectiveness of state implementation plans was therefore mid-

1972.

73a

The regulations employ two later effective dates. First,

emissions increments are measured from a January 1, 1975

baseline, and all sources for which ‘‘approval’’ is given

after that date will have their emissions counted against

the allowable increment for the region. 40 C.F.R. § 52.21

(d)(2)(i) (1975). Second, preconstruction review is pro-

vided only for sources which have ‘‘not commenced con-

struction or modification prior to June 1, 1975.’’ 40 C.F.R.

§ 52.21(d)(1) (1975). ‘‘ ‘Commenced’ means that an owner

or operator has undertaken a continuous program of con-

struction or modification or that an owner or operator has

entered into a contractual obligation to undertake and com-

plete, within a reasonable time, a continuous program of

construction or modification.’? 40 ©.F.R. § 52.21(b)(7)

(1975). Compare 40 C.F.R. §52.01(b) (1975). All later-

commenced source construction must be reviewed for com-

pliance with new source performance standards and for

a determination that construction will not cause the pollu-

tion increments of any area to be violated. 40 C.F.R. § 52.21

(d)(2) (1975), as amended, 40 Fed. Reg. 42011 (S

10, 1975). g (September

We are asked to hold that sources for which construc-

tion was commenced after mid-1972 must be counted

against the allowable pollution increments for the various

regions. EPA answers that inclusion of the earlier con-

struction would limit practical use of the regulations to

regulate future development. We accept the latter position.

Whatever the effect of past construction has been upon

present pollution, each state must determine what will be

appropriate for future air quality and economic develop-

ment. So long as any state may choose to limit future de-

velopment to compensate for excessive past pollution, the

choice of starting dates for the applicability of the regula-

tions appears to be irrelevant. For the same reason we

** Similarly, we find no ground for objection to the manner in

[continued }

T4a

do not believe EPA acted unreasonably in failing to count

increases in pollution since 1972 against the allowable in-

crements. It was a rational policy decision to limit the in-

stant regulations to prospective concerns only.

F. Is it arbitrary and capricious to review proposed

construction of stationary sources on the basis of

compliance with the New Source Pe formance Stand-

ards, rather than on the basis of Best Available Con-

trol Technology on a case-by-case basis?

G. Was the Administrator required to provide for pre-

construction review of all sources, rather than for

‘*significant’’ sources only?

40 C.F.R. § 52.21(d) (ii) (1975) requires that new sources

which are subject to preconstruction review meet the level

of emissions that would be achieved by application of the

Best Available Control Technology (BACT) ; Section 52.01

(f) defines BACT as equivalent to the New Source Per-

formance Standards (NSPS) promulgated under Section

111 of the Clean Air Act, 42 U.S.C. §1857¢e-6 (1979),

amended (Supp. IV 1974), when those standards are avail-

able. If no NSPS has been established for a category of

sources, preconstruction review of emission reduction sys-

tems is done on a case-by-case basis. 40 C.F.R. §§ 52.21(d)

(2) (ii), 52.01(f) (1975). The Sierra Club posits that the

NSPS guidelines, defined by Section 111 as ‘‘the degree

of emission limitation achievable through the application

of the best system of emission reduction which (taking

into account the cost of achieving such reduction) the Ad-

which EPA has defined commencement of construction. 40 C.F.R.

§ 52.21(b)(7) (1975). Even if a source on which construction has

‘‘commenced’’ is not subject to preconstruction review, its emis-

sions may be considered in choosing the appropriate pollution in-

crement to be applied to the area.

75a

ministrator determines has been adequately demon-

strated,’” are a ‘‘lowest common denominator’’-based

group and are inconsistent with the policy of nondeteriora-

tion.

We accept EPA’s response that case-by-case review of

all new sources would not only be unworkable, but would

undermine Section 111 by limiting its application of NSPS

to those areas which have not yet achieved the national

secondary standards. It appears, in addition, that appli-

cation of NSPS rather than BACT will not of necessity

lead to more total pollution; a given area still is limited

to the specified increment for its classification, and the use

of a less effective emission reduction system by one new

statutory source will simply use up more of the allowable

increment and limit opportunities for other proposed new

sources. This trade-off, between types of contro! systems

and opportunities for new source construction, is best left

to the states, which by delegation will administer the pre-

construction review. As the Supreme Court held in Train

v. NRDC, supra, ‘‘so long as the ultimate effect of a State’s

choice of emission limitations is compliance with the na-

tional standards for ambient air, the State is at liberty to

adopt whatever mix of emission limitations it deems best

suited to its particular situation.’’ 421 U.S. at 79. We

therefore hold that the use of NSPS is rational and in

accord with the Clean Air Act.

An additional challenge to the procedures for precon-

struction review is based on the allegedly unlawful limita-

tion of review to 19 specified categories of sources. We

** The 19 listed categories are:

(i) Fossil-Fuel Steam Electric Plants of more than 1000

million B.T.U. per hour heat input.

(ii) Coal Cleaning Plants.

(iii) Krart Pulp Mills.

(iv) Portland Cement Plants.

[continued ]

76a

find this argument subject to the analysis presented above

with respect to use of NSPS rather than BACT. Review of

every new source of pollution clearly would be impossible

since every gas- or oil-heated house is a seurce of some

pollution. The decision to review only those sources which

emit more than 25 pounds per hour of sulfur dioxide or

particulate matter * does not mean there will of necessity

(v) Primary Zine Smelters.

(vi) Iron and Steel Mills.

(vii) Primary Aluminum Ore Reduction Plants.

(viii) Primary Copper Smelters.

(ix) Municipal Incinerators capable of charging more than

250 tons of refuse per 24 hour day.

(x) Sulfurie Acid Plants.

(xi) Petroleum Refineries.

(xii) Lime Plants.

(xiii) Phosphate Rock Processing Plants.

(xiv) By-Product Coke Oven Batteries.

(xv) Sulfur Recovery Plants.

(xvi) Carbon Black Plants( furnace process).

(xvii) Primary Lead Smelters.

(xviii) Fuel Conversion Plants.

(xix) Ferroalloy production facilities commencing construc-

tion after October 5, 1975.

40 C.F.R. §52.21(d)(1)(i)-(xix) (1975), as amended, 40 Fed.

Reg. 42011 (Sept. 10, 1975).

°™ The standard of 25 pounds/hour of emissions for addition of

new categories to the list of those subject to preconstruction review

was proposed on June 9, 1975 (40 Fed. Reg. 24534) and adopted

Sept. 10, 1975 (40 Fed. Reg. 42011) :

[T]he criteria the Administrator intends to use in adding

further sources in the future * * * are:

(1) a new source performance standard for sulfur di-

oxide (SO.) or particulate matter has been established for

the source or any facility of the source under Part 60 of

this chapter, and (2) the established new source perform-

ance standard will allow any anticipated future plant af-

fected by the standard to emit SO, or particulate matter

eee

77a

be more total pollution; it means only that a large number

of minor sources could use up the area’s allowable incre-

ment and thereby preclude construction of new major

sources of pollution. As EPA stated in a document ex-

plaining its regulations:

The 18 categories which are covered by the regula-

tion, except for fuel conversion plants, are the largest

present emitters of SO: and TSP on a nationwide

basis. Fuel conversion plants (coal gasification and

liquefication, oil shale processing, etc.) were included

due to their significant growth potential, particularly

in presently clean areas * * *. The air quality impact

of sources not included in the 18 categories is taken

into account since the total air quality deterioration

above the baseline is taken into account when an ap-

plication to construct a new source of one of the

18 categories reviewed.

Technical Support Document—EPA Regulations for Pre-

venting the Significant Deterioration of Air Quality, US.

Environmental Protection Agency Office of Air Quality

Planning & Standards (January 1975), at 27-28. Further,

it is within the power of the various states to enact more

stringent controls, and expanded preconstruction review

procedures, should limited review lead to problems in

regulating incremental pollution. We therefore hold that

the regulations are not invalid insofar as provision is

made for preconstruction review of only the specified

categories of stationary sources.

in excess of 25 pounds per hour from the affected facility

or facilities when operating at maximum design capacity.

The latter choice also added the 19th category, Ferroalluy produc-

tion facilities.

78a

H. Are the regulations arbitrary and capricious on the

ground that the allowable increments are unrelated

to anticipated adverse effects on public health and

welfare?

The regulations under review establish a classification

scheme which is not based on demonstrated adverse air

quality effects, but rather on a balancing of concerns with

air quality, economic and social needs and objectives, and

development of energy sources. The industrial petitioners

contend that EPA is not authorized to promulgate regula-

tions which are not related to adverse air quality effects,

and that Classes I and II therefore are invalid.

The need to prevent significant deterioration of air

cleaner than the national standards, and the statutory

authorization therefore, was settled by the Sierra Club

v. Ruckelshaus litigation. It clearly is a rational legislative

purpose to protect and enhance the quality of the nation’s

air, even in the absence of quantified evidence of adverse

effects.”

** EPA emphasized in promulgating regulations that levels of

pollution below the national standards still may have some adverse

effects :

Limitations on air quality that result in cleaner air than

the national ambient air quality standards cannot * * * be

based on any quantitative measure of harm to either public

health or welfare. This is not, however, to say that there are no

possible unquantified adverse effects on public health or welfare

below the levels of the national standards. Examples of such

unqua.:tified effects involve the transformation of sulfur dioxide

into suspended sulfates and sulfuric acid aerosols, resulting in

possible effects on health, visibility, climatic changes, acidity of

rain, and deterioration of materials.

Since there is no way to relate ‘‘significance’’ of deteriora-

tion of air quality to any adverse effects resulting from air

quality levels cleaner than the national standards, EPA con-

cluded that the determination of what is ‘‘significant’’ deterio-

ration must take into account factors other than air quality

_-—-—» - -_-

tgs gy eee

79a

The District Court order in Sierra Club v. Ruckelshaus

mandated that EPA enforce this legislative purpose by

preventing significant deterioration of air quality, but

left definition of ‘‘significant’’ to the Agency. EPA’s solu-

tion was a definition created by its own implementation;

each state’s evaluation of the relative importance of the

competing interests which surround continued maintenance

of air quality will determine what level of deterioration

would be significant for that state. The three classifications

thus are not intended to represent a scientific conclusion

as to what constitutes significant deterioration; rather,

they are suggested frameworks for use by the states after

independent evaluation. Because the regulations do not

purport to be mandatory requirements based on scientific

research, they properly cannot be judged by asking whether

the increments are related to demonstrated health effects.

As we have noted above, any state could adopt even more

stringent regulations by proposing its own revision to its

implementation plan.

We therefore find insubstantial the objection that the

varying allowable increments presented in the instant regu-

lations are unrelated to demonstrated adverse health

effects. The regulations flow from a valid legislative goal,

alone. For example, relatively minor deterioration of the aes-

thetic quality of the air may be very significant in a recrea-

tional area in which great pride (and economic development)

is derived from the ‘‘clean air.’’

Technical Support Document—EPA Regulations for Preventing

the Significant Deterioration of Air Quality, U.S. Environmental

Protection Agency, Office of Air Quality Planning & Standards

(January 1975), at 6. See also Clean Air Act Amendments of 1976,

Report of the Senate Committee on Public Works, S. Rep. No. 94-

717 at 19-27 (March 29, 1976) ; Clean Air Act Amendments of 1976,

Report of the House Committee on Interstate and Foreign Com-

merce, H.R. Rep. No. 94-1175 at 83-116 (May 15, 1976).

** See pp. [14a-15a] supra.

80a

and we believe EPA has acted reasonably in permitting

each state, in its informed discretion, to develop a workable

definition of significant deterioration.

I. Are the regulations unworkable because present

modeling techniques are inadequate to predict pre-

cisely how a new source will affect the ambient air?

Some petitioners ® have objected that present computer

modeling technology is inadequate to predict with precision

what effect a proposed new source will have on the am-

bient air, and therefore on the allowable increment for a

given region. EPA does not dispute the point as to the

accuracy of existing techniques, but does argue that present

diffusion modeling techniques, ‘‘while not corresponding to

actual conditions in the ambient air, do provide a consistent

and reproducible guide which can be used in comparing the

relative impact of a source.’’ 39 Fed. Reg. 31003 (August

27, 1974). So long as the method of measurement is con-

sistent, it may be used as a reliable benchmark of the rela-

tive impact of different sources; EPA argues that it there-

fore is unnecessary to be able to guarantee with precision

what effect a source will have.

We have no basis on which to question EPA’s judgment

as to its predictive techniques. Any consistent method of

prediction can be adjusted in light of actual experience,

and a state therefore may adjust its guidelines for future

development on the basis of changes in the measured pol-

lution levels over time. We cannot hold at this time, there-

fore, that lack of precision alone is a substantial objection

to the methods which may be used to estimate the impact

of a proposed source on actual levels of pollution.

* See, e.g., br. of American Petroleum Institute et al., in No. 75-

1665 at 38.

8la

J. Did EPA violate the Clean Air Act

(1) by not permitting submission of revised plans

before promulgating regulations, or

(2) by not holding hearings in each state before

promulgating the regulations?

The Administrator is required to prepare and publish

his own implementation plan, or portion thereof, for a

state if (a) the state fails to submit a plan as to any na-

tional standard, (b) the plan is not in accordance with the

requirements of Section 110 of the Act, or (c) the state

fails, within 60 days, to revise its plan pursuant to Section

110(a)(2)(H), which requires that implementation plans

provide for revisions (i) to take account of changes in

technology or (ii) if the Administrator determines that the

plan is inadequate to achieve the primary or secondary

standards. Section 110(c)(1), 42 U.S.C. § 1857e-5(e) (1)

(Supp. IV 1974). Subsection (c)(1) also contains a hearing

requirement; if a state did not hold a public hearing with

respect to the plan or revision being promulgated, the

Administrator must provide a hearing within the state.

The Administrator is to promulgate his regulations within

six months, unless within that time the state has adopted

and submitted an implementation plan which is in accord

with the requirements of Section 110. Id.

It is contended that the instant regulations, which

amended the implementation plans of all states,*: consti-

tuted a ‘‘revision’’ under Section 110(a)(2)(H), Under

Section 110(c)(1)(C) the Administrator may promulgate

new regulations only if a state fails, after 60 days, to sub-

mit the required (a)(2)(H) revision. Further, if the regu-

lations are considered ‘‘revisions,’’ it is claimed, the Ad-

ministrator was required by Section 110(c)(1) to hold a

hearing in each state before promulgating the regulations.

** See note 9 supra.

82a

The original order of the District Court required that

the ‘‘Administrator * * * prepare and publish proposed

regulations, pursuant to 42 U.S.C. § 1857¢-5(c), as to any

state plan which he finds, on the basis of his review, either

permits the significant deterioration of existing air quality

in any portion of any state or fails to take the measures

necessary to prevent such significant deterioration. Such

regulations shall be promulgated within six months of this

order.’’ Sierra Club v. Ruckelshaus, Civil Action No. 1031-

72 (D. D.C. May 30, 1972). That order—which was affirmed

by this court and the Supreme Court—clearly did not con-

template that a hearing be held in each state prior to prom-

ulgation of regulations, nor did it require that the states

be given a prior opportunity to revise their plans. We re-

affirm the order in both respects.

All states had held public hearings on their proposed im-

plementation plans before the District Court order was en-

tered.” After disapproving all state plans insofar as they

failed to prevent significant deterioration, the Adminis-

trator held five regional hearings in Washington, Atlanta,

Dallas, Denver, and San Francisco on proposed regula-

tions, and solicited written comments.* We believe that

procedure was sufficient in the circumstances presented.

Unfortunately, the requirement of prevention of significant

deterioration does not fit neatly into the statutory scheme,

as it is not expressly included in Section 110 of the Act.

The Administrator’s disapproval of all plans pursuant to

the District Court order, and the subsequent promulgation

6 In its initial approval and disapproval of state plans, published

May 31, 1972 (37 Fed. Reg. 10842), EPA noted that all states had

held hearings and had submitted implementation plans.

*3 37 Fed. Reg. 23836 (Nov. 9, 1972).

* See 39 Fed. Reg. 31000 ( Aug. 27, 1974).

$6 Id.

83a

of regulations, were required by Section 101 of the Act

and by the legislative history, but were not within the de-

fined processes of Section 110(c). Implementation of the

District Court order required an exercise of discretion by

the Administrator, and we find that he acted well within

that discretion by concluding that only regional hearings

were necessary to supplement the hearings which had al-

ready been held in all states.

In making this decision we wish to emphasize, first, that

petitioners have not alleged with any specificity how they

were harmed by the lack of individual state hearings. We

are presented only with a generalized statutory claim,

which apparently never was raised before the Agency.

Second, it should be remembered that the states arguably

have been denied no rights by promulgation of the nonde-

terioration regulations. They remain free, after public

hearing, to develop their own regulatory scheme to sup-

plant that promulgated by EPA, so long as the substitute

prevents significant deterioration of air quality.” We can-

not conclude, then, that the regulations are defective on

procedural grounds.

“Cf. American Airlines, Inc. v. CAB, 123 U.S.App.D.C. 310,

318-319, 359 F.2d 624, 632-633, cert denied, 385 U.S. 843 (1966) :

[T]here is no basis on the present record for concluding that

additional procedures were requisite for fair hearing. We might

view the case differently if we were not confronted solely with

a broad conceptual demand for an adjudicatory-type proceed-

ing, which is at least consistent with, though we do not say it is

attributable to, a desire for protracted delay. Nowhere in the

record is there any specific proffer by petitioners as to the sub-

jects they believed required oral hearings, what kind of facts

they proposed to adduce, and by what witnesses, etc. * * *

See also United States v. L. A. Trucker Lines, Inc., 344 US. 33

(1952).

** See pp. [14a-15a] supra.

Sta

K. By providing for reclassification of federal and In-

dian lands independent of state action, do the regu-

lations abrogate authority granted to the states by

the Clean Air Act?

Federal land managers and Indian governing bodies are

authorized to propose redesignation of their lands, after

consultation with officials of other affected areas and com-

pliance with procedural and hearing requirements. 40

C.F.R. § 52.21(c)(3) (1975). The industrial petitioners

and the petitioning state governments object that this au-

thority violates the delegation to the states of authority

over air quality within their boundaries in Section 101(a)

(3), 42 U.S.C. § 1857(a) (3), and Section 107(a), 42 U.S.C.

§ 1857c-2(a),” that it contradicts the submission of federal

facilities to state regulation in Section 118, 42 U.S.C.

§ 1857f,"" and that the authority to redesignate gives these

* See pp. [1la-12a] supra.

69 49 1.S.C. § 1857(a)(3) (1970) :

(a) The Congress finds—

a e e 2

(3) that the prevention and control of air pollution at its

source is the primary responsibility of States and local gov-

ernments|.]

7° 42 U.S.C. § 1857e-2(a) (1970) :

Each State shall have the primary responsibility for assuring

air quality within the entire geographic area comprising such

State by submitting an implementation plan for such State

which will specify the manner in which national primary and

secondary ambient air quality standards will be achieved and

maintained within each air quality control region in such State.

7142 U.S.C. § 1857f (1970) :

Each department, agency, and instrumentality of the execu-

tive, legislative, and judicial branches of the Federal Govern-

ment (1) having jurisdiction over any property or facility, or

(2) engaged in any activity resulting, or which may result, in

the discharge of air pollutants, shall comply with Federal,

85a

lands tremendous practical power over neighboring areas

which might be hindered in their development because of

designation of federal or Indian ‘ands as Class I areas.”

EPA has responded that federal land managers and In-

dian governing bodies have an important legal interest in

protecting the air quality of their lands, that redesignation

may not be proposed without consultation with officials of

the affected states,” and that the Administrator may dis-

State, interstate, and local requirements respecting control and

abatement of air pollution to the same extent that any person

is subject to such requirements. The President may exempt

any emission source of any department, agency, or instru-

mentality in the executive branch from compliance with such

a requirement if he determines it to be in the paramount

interest of the United States to do so * * *.

see?

7? See 39 Fed. Reg. 42512 (Dec. 5, 1974) :

Under the regulations promulgated below, a source could not

be allowed to construct if it would violate an air quality incre-

ment either in the area where the source is to be located or in

any neighboring area in the State. Therefore, wherever a Class

I area adjoins a Class II or III area, the potential growth re-

strictions, especially for power plant development, extends

[sic] well beyond the Class I boundaries into the adjacent area.

A similar situation exists, to a greater or lesser degree, where-

ever areas of different classification adjoin each other. There-

fore, the area with the less restrictive classification should in-

elude an additional area at the periphery where it is clearly

recognized that development will be somewhat restricted due

to the adjacent ‘‘cleaner’’ area. As a result, a Class I redesig-

nation could be fairly limited in size, yet the adjoining Class

II or Class III areas would need to cover a substantial area

in order to fully utilize the Class IT or III increment. Again,

it should be clear that the Class II or III increment could only

be fully utilized toward the center of the area and that at

the periphery, allowable deterioration will be dictated by the

—- Class I area rather than the Class II or III incre-

men

40 C.F.R. § 52.21(¢) (3) (iv), (v) (1975).

86a

approve redesignation if arbitrary and capricious disre-

gard of the interests of other affected areas is demonstrat-

ed."* With regard to submission of federal facilities to state

regulation, EPA notes that federal lands may be redesig-

nated only to a more restrictive classification than that

applicable to the entire state,” and thus cannot contribute

to unwanted deterioration of air quality.

We pretermit this question, as we find that the issue is

not yet ripe for review.”* No federal or Indian land has yet

™ 40 C.F.R. § 52.21(e) (3) (vi) (b), (e) (1975).

7540 C.F.R. § 52.21(e) (3) (iv) (1975).

16 See Toilet Goods Ass’n Inc. v. Gardner, 387 US. 158 (1967),

in which cosmetic manufacturers had brought a ape g -tewegae

action to challenge the authority of the Commissioner of Food an

Drugs to issue regulations under the Color Additive Amendments

to the Federal Food, Drug, as Cosmetic Act. The regulation at issue

authorized the Commissioner to suspend certification service to any

person who denied the FDA free access to manufacturing informa-

tion. Although the issue was purely legal, the Court found that, as

framed, it was not appropriate for judicial resolution:

The regulation serves notice only that the Commissioner may

under certain circumstances order inspection of certain facili-

ties and data, and that further certification of additives may

be refused to those who decline to permit a duly authorized

inspection until they have complied in that regard. At this

juncture we have no idea whether or when such an inspection

will be ordered and what reasons the Commissioner will give

to justify his order. The statutory authority asserted for the

regulation is the power to promulgate regulations ‘‘for the ef-

ficient enforeement’’ of the Act, § 701(a). Whether the regu-

lation is justified thus depends not only, as petitioners appear

to suggest, on whether Congress refused to include a specific

section of the Act authorizing such inspections, although this

factor is sure to be a highly relevant one, but also on whether

the statutory scheme as a whole justified promulgation of the

regulation. * * * This will depend not merely on an inquiry

into statutory purpose, but concurrently on an understanding

of what types of enforcement problems are encountered by the

FDA, the need for various sorts of supervision in order to

87a

been redesignated, and to that extent we cannot be certain

how a conflict may evolve. If the Administrator were to

approve, as replacements for these regulations, individual

state plans which did not include the powers granted to

federal land managers and Indian governing bodies, the

problems foreseen by petitioners might never arise.

We note that reservation of power to federal land man-

agers and Indian governing bodies should have no effect

on present conduct; there appears to be no reason why

economic development of any area should be hindered by

the possibility that a nearby area may be redesignated in

the future to a more restrictive classification. We there-

fore do not foresee any irreparable injury which may arise

from deferral of this question until it arises in a more con-

crete context.

L. Are the regulations constitutional?

We find the arguments challenging the constitutionality

of the nondeterioration regulations to be insubstantial.

Regulation of air pollution clearly is within the power of

the federal government under the commerce clause,”’ and

we can see no basis on which to distinguish deterioration of

air cleaner than national standards from pollution in other

effectuate the goals of the Act, and the safeguards devised to

protect legitimate trade secrets * * *. We believe that judicial

appraisal of these factors is likely to stand on a much surer

footing in the context of a specific application of this regula-

tion than could be the case in the framework of the generalized

challenge made here.

387 U.S. at 163-164 (emphasis in original).

™ See District of Columbia v. Train, 172 U.S.App.D.C. 311, 328,

521 F.2d 971, 988 (1975) ; Pennsylvania v. EPA, 500 F.2d 246, 259

(3d Cir. 1974) ; South Terminal Corp. v. EPA, 504 F.2d 646, 677

(1st Cir. 1974).

88a

contexts.” Nor do we agree that the regulations bear no

rational relationship to protection of public health and

welfare and therefore violate the due process clause of the

Fifth A:mendment. There is a rational relationship between —

air quality deterioration and the public health and wel-

fare,” and there is a proper legislative purpose ® in pre-

vention of significant deterioration of air quality. Neither

can the regulations be construed as an unconstitutional

‘‘taking’’ under the Fifth Amendment, any more than ex-

isting emission control regulations represent such a ‘‘tak-

ing.’’* The use of private land certainly is limited but the

™® Indeed, the vigorous objections that have been mounted against

redesignation of federal lands or Indian lands are based on recog-

‘nition that a pollution source can have air quality effects over 4

large area.

™ See note 58 supra.

* See Heart of Atlanta Motel, Inc. v. United States, 379 U.S. 241,

258-259 (1964), in which the Court held the Civil Rights Act of

1964 to be a valid exercise of congressional power under the com-

merce clause, and found the Act not barred by the Fifth Amend-

ment:

Nor does the Act deprive appellant of liberty or property

under the Fifth Amendment. The commerce power invoked

here by the Congress is a specific and plenary one authorized

by the Constitution itself. The only questions are: (1) whether

Congress had a rational basis for finding that racial discrimina-

tion by motels affected commerce, and (2) if it had such &

basis, whether the means it selected to eliminate that evil are

reasonable and appropriate. * * ®

See also Nebbia v. New York, 291 U.S. 502, 537 (1934) (Fourteenth

Amendment).

*! See South Terminal Corp. v. EPA, 504 F.2d 646, 678 (1st Cir.

1974), in which the court upheld a transportation contro) plan

which mandated a 40% reduction in available off-street parking

spaces:

[T]he Government has not taken title to the spaces, and the

decision about alternative uses of the space has been left to the

owner. The takings clause is ordinarily not offended by regula-

89a

limitation is not so extreme as to represent an appropria-

tion of the land.

The Tenth Amendment is not implicated either by in-

fringement on the reserved powers of the states, cf. Nation-

al League of Cities v. Usery, —~— US. —, 44 USS. L.

Week 4974 (June 24, 1976), or by any requirement of af-

firmative action, as in District of Columbia v. Train, 172

U.S.App.D.C, 311, 521 F.2d 971 (1975). The states retain

broad discretion under the regulations to control the use

of their land and the scope of their economic development,

and are required to take no affirmative action. Preconstruc-

tion review under the regulations is conducted by the Ad-

ministrator unless a state requests that responsibility be

delegated to it. 40 C.F.R. § 52.21(d), (f) (1975).

Last, we find no merit to the argument that the congres-

sional delegation of authority to EPA is unconstitutionally

vague. There is substantial basis for the instant regula-

tions in both the Clean Air Act and its legislative history

and we find the regulations to be a reasonable means of

implementing the congressional intent.” See South Termi-

nal Corp. v. EPA, 504 F.2d 646, 676-677 (Ist Cir. 1974).

tion of uses, even though the regulation ma

. , y severely or even

drastically affect the value of the land or real property. If the

highest-valued use of the property is forbidden by regulations

of general applicability, no taking has occurred so long as other

lower-valued, reasonable uses are left to the property's owner.

eee

"In Lichter v. United States, 334 U.S. 742, 785 (1947), the

Court upheld a congressional grant of authority to the Secretary

of War, the Secretary of the Navy, and the Chairman of the Mari-

time Commission to renegotiate contracts and to recover ‘‘ excessive

profits.’’ The Court applied the following reasoning to the claim

that the term ‘‘excessive profits’’ was unconstitutionally vague :

It is not necessary that Congress suppl ini i

y administrative offi-

cials with a specific formula for their guidance in a field named

flexibility and the adaptation of the congressional policy to

[continued }

90a

VI. ConcLusIon

We find no ground on which to disturb the regulations

under review, and we therefore affirm the EPA ‘*Preven-

tion of Significant Air Quality Deterioration’’ regulations.”

Our review of Sierra Club v. Ruckelshaus and subsequent

events has revealed no substantial reason for rejection of

that decision, and we hold that the nondeterioration regu-

lations promulgated pursuant to that decision are both

rational and in accordance with law.

Affirmed.

Circuit Judge WiLKey concurs in the result only.

infinitely variable conditions constitute the essence of the pro-

gram. ‘‘If Congress shall lay down by legislative act an intel-

ligible principle . . . such legislative action is not a forbidden

delegation of legislative power.’’ Hampton Co. v. United States,

276 U.S. 394, 409. Standards prescribed by Congress are to be

read in the light of the conditions to which they are to be ap-

plied. ‘‘They derive much meaningful content from the pur-

pose of the Act, its factual background and the statutory con-

text in which they appear.’’ American Power & Light Co. v.

S.E.C., 329 U.S. 90, 104. ° * *

83 As noted above, see pp. [45a-48a], we do not decide the ques-

tion whether reclassification of federal and Indian lands inde-

pendent of state action may be unlawful.

9la

[18986 }*

[Federal Register, Vol. 38, No. 135—Monday, July 16,

1973]

ENVIRONMENTAL PROTECTION AGENCY**

[40 CFR Part 52]

APPROVAL AND PROMULGATION oF IMPLEMENTATION PLANS

Prevention of Significant Air Quality Deterioration

Notice is hereby given that the Administrator of the En-

vironmental Protection Agency (EPA) intends to issue

regulations setting up a mechanism for preventing signifi-

cant deterioration of air quality in areas where air pollu-

tion levels currently are below the national ambient air

quality standards (40 CFR Part 50). These regulations

would be issued under the Clean Air Act and would pre-

scribe steps to be taken by the States. This notice sets forth

four proposed plans reflecting various approaches to defin-

ing and preventing significant deterioration. It is the Ad-

ministrator’s intention not only to receive written com-

ments on these proposals but also to hold public hearings

in various places in order to provide the greatest possible

opportunity for public involvement in this rule-making.

Certain questions on which public comment is specifically

invited are identified in the concluding section of this pref-

ace.

Publication of this notice is related to a suit filed May 24,

1972, in which the Sierra Club and other groups sought a

declaratory judgment and injunction requiring the Admin-

* Bracketed numbers represent the page in the Federal Register

upon which material following such a number can be found.

** The ‘‘significant deterioration’’ regulations, as reprinted on

“pp. 91a to 291a herein, appeared on pp. 1-36, 688-98 of the joint

appendix filed in the consolidated cases below.

92a

istrator to disapprove all State implementation plans

which did not contain procedures for preventing signifi-

cant deterioration in any portion of any State where air

qualit: is superior to national standards. On May 30, 1972,

the Discrict Court for the District of Columbia granted the

plaintiffs’ motion for a preliminary injunction and issued

a preliminary injunction requiring the Administrator,

within four months thereafter, to review all State plans

and ‘‘disapprove any portion of a State plan which fails

to effectively prevent significant deterioration of existing

air quality.’’ The preliminary injunction also required the

Administrator to promulgate regulations ‘‘as to any State

plan which he finds, on the basis of his review, either per-

mits the significant deterioration of existing air quality in

any portion of any State or fails to take the measures nec-

essary to prevent such significant deterioration. On No-

vember 1, 1972, the decision of the District Court was af-

firmed by the U.S. Court of Appeals for the District of

Columbia Circuit on the basis of an opinion filed by the

District Court on June 2, 1972. Subsequently, the U.S. Su-

preme Court stayed the effect of the District Court’s de-

cision pending its consideration and disposition of the case

on application for a writ of certiorari. On June 11, 1973,

the Supreme Court, by an equally divided court, affirmed

the judgment of the Court of Appeals; no opinion was

issued.

Each State plan has been reviewed in accordance with

the preliminary injunction issued by the District Court.

Although many State plans included regulations which

have the potential for resulting in the attainment of air

quality better than that required by the national standards,

and although some State plans contained general policy

statements indicating an intent to prevent or minimize de-

terioration of air quality, none was found to contain ex-

plicit and enforceable regulations for implementing such a

policy. Accordingly, all State plans were disapproved by

the Administrator on November 9, 1972 (37 FR 23836), in-

93a

sofar as they failed to provide for the prevention of sig-

nificant deterioration. This disapproval did not affect the

status of any previously or subsequently approved regula-

tions designed to provide for the attainment and mainte-

nance of national ambient air quality standards. Furtlier-

more, in the absence of Federal regulations prescribing re-

quirements for prevention of significant deteriowalion the

Administrator’s disapproval was necessarily based on a

generalized assessment of the State plans. To the extent

that any State plan is determined to meet any of the re-

quirements ultimately established as a result of this rule-

making proceeding, the Administrater’s disapproval will

be appropriately modified.

In EPA’s view, there has been no definitive judicial reso”

lution of the issue whether the Clean Air Act requires pre-

vention of significant deterioration of air quality. When

the issue was presented to the Supreme Court, the Court

was equally divided. The Court’s action had the effect of

permitting to stand the judgment of the Court of Appeals

for the District of Columbia Circuit, which was entered in

the procedural context of the issuance of a preliminary in-

junction.

In the absence of a definitive judicial decision on the

issue, the Administrator adheres to the view that Section

110 of the Clean Air Act requires EPA to approve State

implementation plans that will attain and maintain the

national ambient air quality standards, and that the Act

does not require EPA or the States to prevent significant

deterioration of air quality. The proposed alternative regu-

lations set forth herein would establish a mechanism for

preventing significant deterioration pursuant to the pre-

liminary injunction isued by the District Court.

Pusuic Potuicy Issue

The question raised by the Sierra Club suit was a legal

issue, i.e., interpretation of the language and legislative

94a

history of the Clean Air Act. Thus, the courts were asked

to determine that the Act requires the Administrator to

ensure that State implementation plans will not permit sig-

nificant deterioration of air quality. What the courts were

not asked to determine is what constitutes significant de-

terioration and exactly how it will be prevented.

A national policy of preventing significant deterioration,

however defined and implemented, will have a substantial

impact on the nature, extent, and location of future indus-

trial, commercial, and residentiai development throughout

the United States. It could affect the utilization of the

Nation’s mineral resources, the availability of employment

and héusing in many areas, and the costs of producing and

transporting electricity and manufactured goods. Without

implying any judgment as to the general acceptability of

any of the effects of a ‘‘no significant deterioration’’ policy,

the Administrator believes that they are potentially so

far-reaching that the question of how such a policy should

be defined and implemented cannot properly be addressed,

much less decided, on narrow legal grounds. Rather, it is

a question that musi be discussed, debated, and decided as

a public policy issue, with full consideration of its eco-

nomic and social implications. To approach the question

in any other manner would be much too simplistic. There

is, perhaps, no other environmental issue that imposes

upon the Administrator, and the public, a greater obliga-

tion to formulate and objectively evaluate a range of pos-

sible solutions. The usual rulemaking procedure of putting

forth a single proposal clearly is inadequate in this case.

Accordingly, this notice sets forth four alternative sets of

proposed regulations based upon different philosophies

and administrative approaches to defining and preventing

significant deterioration.

CuRRENT CONSTRAINTS ON DETERIORATION

It is important to recognize that many State plans, as

well as certain rule making actions already completed

95a

under provisions of the Clean Air Act, will have

pre f the ¢ the effect

an maintaining air quality significantly better

on A ear t secondary standards in many places, and

actions will have the effect of generally improv-

ing air quality nationwide. The following paragraphs sum-

marize the more significant of these actions, and there is no

intent that the alternatives proposed herein should in an

way mitigate the impact of these actions. ,

1. The Administrator has promulgated (36 FR 8186

= primary and secondary ambient air quality oo

= ee with the Act, the primary standards

he se at a level that provides an adequate margin of

ety for protection of the puitilic heulth, and secondarv

gcandarde were set at a.level that protects the pubilic wel-

are from any known or anticipated adverse offects. Al)

States have submitted mmplementation plans to attain and

maintain these standards. In many areas of the country,

air quality was not sufficient to meet these stendards and

— in these areas, the State plans will ensure that de-

rioration cannot oeeur because the regulations require

specific improvements in air quality.

2. Emission control actions to be taken by the Sta i

N tes, in

een with their plans to implement the National Am-

ir Quality Standards in heavily polluted areas, will

= air pollution concentrations in the periphery of

= [18987] areas. For example, the annual average sulfur

oxide concentration in Mercer County, New Jersey, is ex-

SS hp from about 25 micrograms per enbic meter

2 micrograms per cubic meter (as compared to

a ees standard of 60 micrograms) as a

t of emission reductions in and around Philadelphia.

3. Emissions reductions to be achieved under Sta

plans in major urban and industrial centers will denih.

—_ affect total national emissions and thereby lower

a background pollutant concentrations in rural areas.

us a 25 percent reduction in the background concentra-

96a

i i 40 micrograms per

tion of particulate matter (from about

cubic A. to about 30 micrograms) in rural areas in the

Northeast is anticipated.

ission limitations and other regulations, including

antue on the sulfur content of fossil fuels as —_

scribed by many State plans, go beyond what is —_ nd

necessary for attainment of the national standards. ; n

many instances, emission control regulations ——ae =

attainment of national standards in the most po r

area(s) of a State have been applied statewide. For = ur

dioxide, this has occurred in 33 States. Although imp ye

tation of these regulations may be deferred in some clean

areas in order to make available low sulfur fuels for —

heavily polluted areas, these regulations will eventually

result in further improvement in air quality in many areas

where the secondary standards were not exceeded.

ission standards for new motor vehicles

-- ben yd eprenrs decrease in motor vehicle se oa

in all parts of the Nation through the 1970’s and well Le

the 1980’s, as new automobiles equipped to meet t =

emission standards replace older models which were —

ject to less restrictive emission standards or none at all.

For example, 1974 model automobiles will have ~ om

reductions (per mile) of approximately 80% for car 2

monoxide, 70% for hydrocarbons, and 357% for 9 o

nitrogen, as compared to vehicles sold prior to 1969. =

trend is a result of the Federal emission standards alre y

in effect; it will be accelerated by the even more on

emission standards due to take effect in the 1975 and 1

model years.

6. Control of sulfur dioxide, nitrogen oxides, and hydro-

carbon emissions to meet national ambient air quality

standards and/or Federal emission standards for new sta-

tionary sources and motor vehicles can be expected to ~

hibit atmospheric reactions involving these pollutants an

97a

thereby reduce ambient air concentrations of particulate

matter such as sulfates, nitrates, and organics. Current

State implementation plans generally do not consider this

_ secondary reduction of particulate levels.

It can be seen that there are very strong regulatory

measures in existence to prevent any deterioration of air

quality in regions where the national standards are cur-

rently exceeded. Strong regulatory measures also exist to

insure that air quality in currently clean areas cannot de-

teriorate sufficiently to subject the public health or welfare

to any currently quantifiable adverse effects. Although the

effect of these regulations is to mitigate any deterioration

in most sections of the country, the alternatives presented

herein are intended to prevent, in accordance with the Dis-

trict Court’s preliminary injunction, any significant de-

terioration of air quality in any portion of any State.

Conceprua. Issues

Section 109 of the Clean Air Act requires the Adminis-

trator to establish national primary ambient air quality

standards ‘‘to protect the public health’’ and national sec-

ondary ambient air quality standards, ‘‘to protect the pub-

lic welfare from any known or anticipated adverse ef-

fects,’’ including, as specified by section 302(h), ‘effects

on soils, water, crops, vegetation, man-made materials, ani-

mals, wildlife, weather, visibility, and climate, damage to

and deterioration of property, and hazards to transporta-

tion, as well as effects on economic values and on personal

comfort and well-being.’’ Such national standards must be

based on air quality criteria which, under section 108, must

‘‘reflect the latest scientific knowledge useful in indicating

the kind and extent of all identifiable effects on public

health and welfare which may be expected from the pres

ence [of air pollutants] in the ambient air, in varying

quantities.’’ Thus, standard-setting under section 109 is

necessarily limited to demonstrable or predictable adverse

98a

effects which can be quantitatively related to pollutant con-

centrations in the ambient air.

The basis for preventing significant deterioration there-

fore lies in a desire to protect aesthetic, scenic, and recrea-

tional values, particularly in rural areas, and in concern

that some air pollutants may have adverse effects that

have not been documented in such a way as to permit their

consideration in the formulation of national ambient air

quality standards. Pending the development of adequate

scientific data on the kind and extent of adverse effects of

air pollutant levels below the secondary standards, signifi-

cant deterioration must necessarily be defined without a

direct quantitative relationship to specific adverse effects

on public health and welfare. It should be emphasized that

defining significant deterioration in this way does not im-

ply a judgment by EPA on the question of whether it is

sound public policy to define ‘*deterioration’’ as any incre-

ment above existing air pollution levels and to attempt to

define ‘‘significant’’ deterioration in the absence of docu-

mentation on the adverse effects thereof. Furthermore, it

is possible, indeed probable, that even when there are addi-

tional data, it will be evident that there are levels below

which some of the pollutants covered by national stand-

ards do not have effects that can be considered adverse to

public health and welfare.

To the extent that the Act provides any basis for de-

fining significant deterioration, it does so only in section

101(b)(1), which declares that one of the purposes of the

Act is ‘‘to protect and enhance the quality of the Nation’s

air resources so as to promote the public health and welfare

and the productive capacity of its population’’. Additional

guidance is available from the legislative history; specif-

ically, the Report of the Senate Committee on Public Works

(Report No. 91-1196, dated September 17, 1979) contained

the following statement:

99a

In areas where current air pollution levels are al-

ready equal to, or better than, the air quality goals

the Secretary should not approve any implementation

plan which does not provide, to the maximum extent

practicable, for the continued maintenance of such

ambient air quality.

Though the Report also suggested that it might be pos-

sible to prevent all deterioration, it is apparent that the

measures necessary for that purpose would bring growth

and development virtually to a standstill in many areas

and therefore are incompatible with protecting the ‘‘pro-

ductive capacity’’ of the Nation’s population.

Clearly, it is not within the province of E

either the Clean Air Act or lg wae Po agen * an

limitations on the Nation’s growth. Neither the Sierra Club

nor any of the States or organizations that filed amicus

curiae briefs with the Supreme Court in support of the

Sierra Club’s position argued that the District Court’s

preliminary injunction means that EPA must limit eco-

nomic growth, as such, in order to prevent significant de-

terioration of air quality. To the contrary, it was agreed

that growth could and would continue, albeit with the re-

strictions necessary to prevent significant deterioration.

En Sierra Club, for example, made the following state-

nt:

The development of rural areas will not be pre-

vented by a prohibition against significant deteriora-

tion of air quality. Such a prohibition on its face does

not prevent all increases in pollution. If the best avail-

able technological developments are utilized and if

numerous pollution producing sources are not concen-

trated in one place, most industry can enter clean

areas without causing significant deterioration. (p. 94)

100a

And the State of California made the following state-

ments :

Prevention of significant deterioration of air quality

does not foreclose the construction in clean air basins

and partially polluted air basins of well-planned and

well-disbursed fossil fuel power plants and other pol-

luting industries which utilize, on a continuing basis,

the best available technology. ‘No significant deteriora-

tion’ simply means that certain large and inadequately

controlled pollution sources will not be permitted. (pp.

1-2) Of course, economic and social factors may well

require some degradation of air quality in certain

areas. But this case does not involve any question of

prohibiting growth or prohibiting any deterioration of

air quality. It is not a ‘non-degradation’ case. (p. 28)°

[18988] There is, therefore, a consensus that the defini-

tion of significant deterioration is intended to represent

some level above zero deterioration. An upper bound can

also be established on the definition of significant deteri-

oration by recognizing that existing regulations prevent

deterioration to levels in excess of the secondary air qual-

ity standards.

Hence, any quantitative definition of significant deteri-

oration must fall between the levels of zero deterioration

and deterioration up to the secondary standards. Any

quantitative definition within this range must be essen-

tially subjective, because, within this range, data are not

available with which to quantify any adverse impact on

either public health or welfare.

Nationally, the steady deterioration in air quality over

the last several decades has already been reversed by

existing regulations, and air quality generally has begun

to improve in the last few years. Further, this improve-

ment will continue for the foreseeable future. The follow-

ing table summarizes the expected reductions in total na-

10la

tional emissions by 1980. The

1980. percentages sh

on the national emissions of 1970, rh include (i : oe

sorb’’) the : Pe

1980 period. SOurees anticipated for t

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Appendix — Mont. Power Co. v. U.S.E.P.A. · 430 U.S. 953 | Frix