Appendix — Appalachian Power Co. v. Environmental Protection Agency

Supreme Court brief1999

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IN THE ;

Supreme Court of the United States

OCTOBER TERM, 1998

APPALACHIAN POWER COMPANY, et al.,

7% Petitioners,

ENVIRONMENTAL PROTECTION AGENCY,

UNITED STATES,

Respondent.

On Petition for a Writ of Certiorari to the

United States Court of Appeals

for the District of Columbia Circuit

APPENDIX TO

PETITION FOR A WRIT OF CERTIORARI

DAVIb E. MENOTTI HENRY V. NICKEL

WILLIAM F’. PEDERSEN (Counsel of Record)

SHAW, PITTMAN, POTTS KEVIN L. FAST

& TROWBRIDGE LAUREN E. FREEMAN

2300 N St., N.W. MATTHEW F.. GOLDBERG

Washington, D.C. 20037 HUNTON & WILLIAMS

(202) 663-8675 1900 K Street, N.W.

Counsel for American Washington, D.C. 20006

Petroleum Institute (202) 955-1500

Counsel for Appalachian

Power Company, et al.

G. WILLIAM FRICK

JOHN E. REESE

AMERICAN PETROLEUM INSTITUTE

1220 L Street, N.W.

Washington, D.C. 20005

(202) 682-8240

Counsel for American

February 18, 1999 Petroleum Institute

[Additional Counsel Listed Inside]

WILSON - Ergs PRINTING Co., INC. - 789-0096 - WASHINGTON, D.C. 20001 al ¢e

RUSSELL S. FRYE

Roy S. BELDEN

CHADBOURNE & PARKE LLP

1200 New Hampshire Ave., N.W.

Washington D.C., 20036

(202) 974-5600

Counsel for American Forest &

Paper Association, Inc.

ROBERT A. KIRSHNER

General Counsel

AMERICAN FOREST &

PAPER ASSOCIATION, INC.

1111 19th Street, N.W.

8th Floor

Washington, D.C. 20036

(202) 463-27000

Counsel for American Forest &

Paper Association, Inc.

MICHAEL H. LEVIN

NEAL J. CABRAL

MICHAEL MCGOVERN

McGuIRE, Woops, BATTLE

& BooTHeE, L.L.P.

1627 Eye Street, N.W.

Washington, D.C. 20006

(202) 857-1700

Counsel for

Can Manufacturers Institute

WILLIAM H. LEwiIs, JR.

MICHAEL A. McCorD

JOSHUA D. SARNOFF

MorGAN, LEwIs & Bockius LLP

1800 M Street, N.W.

Washington, D.C. 20036

(202) 467-7145

Counsel for Clean Air

Implementation Project

DAVID E. MENOTTI

WILLIAM F.. PEDERSEN

SHAW, PITTMAN, PoTTs

& TROWBRIDGE

2300 N Street, N.W.

Washington, D.C. 20037

(202) 663-8675

Counsel for

Corn Refiners Association, Inc.

ROBERT L. BRUBAKER

JANET J. HENRY

KATERINA M. EFTIMOFF

PORTER, WRIGHT, MORRIS

& ARTHUR

41 South High Street

Columbus, Ohio 43215

(614) 227-2033

Counsel for Ohio Chamber of

Commerce, and Ohio

Chemical Couneil

LYNN L. BERGESON

BETHAMI AUERBACH

LisA CAMPBELL

BERGESON & CAMPBELL

1300 Eye Street, N.W.

Suite 1000 West

Washington, D.C. 20005

(202) 962-8585

Counsel for RSR Corporation

HOWARD B. MYERS

General Counsel

RSR CORPORATION

2777 Stemmons Freeway

Suite 1800

Dallas, Texas 75207

(214) 583-0238

Counsel for RSR Corporation

oD

APPENDIX TABLE OF CONTENTS

Page

Decision of the D.C; Circuit... la

Order Denying Petition for Rehearing... 17a

Crder Denying Suggestions for Rehearing In

St ERNE SEE IE RIOR fa aD aT NE eran ee 19a

mancate of the D.C. Cireuit 2la

Excerpts from Articles I & III of the Constitu-

NO rath Sikes a Ns Bt 23a

Excerpts from Sections 110, 111, 112 & 307 of

OUI Uh: ne: a re RIN ee 24a

Select Regulatory Provisions From 40 C.F.R.

ee dg tr Oe Ni 53a

Relevant Legislative History From S. Rep. No.

91-1196, 91st Cong., 2d Sess. (1970) & H.R.

Rep. No. 95-294, 95th Cong., Ist Sess. (1977)... 68a

Rule 29 Corporate Listing .................................... 83a

—

la

APPENDIX A

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

Argued April 21, 1998 Decided August 14, 1998

No. 97-1117

CLEAN AIR IMPLEMENTATION PROJECT, et al.,

Petitioners

v.

ENVIRONMENTAL PROTECTION AGENCY,

Respondent

NATURAL RESOURCES DEFENSE CoUNCIL, INC.

AND BATTERY COUNCIL INTERNATIONAL,

Intervenors

Consolidated with Nos.

97-1125, 97-1130, 97-1142, 97- 1169, 97-1173, 97-1179,

97- 1190, 97-1195, 97-1226, 97-1241, 97- 1242, 97-1253,

97-1254, 97-1259, 97-1261, 97- 1266, 97-1269, 97-1273,

97-1278, 97-1281, 97- 1282, 97-1283, 97-1286, 97-1289

On Petition for Review of an Order of the

Environmental Protection Agency

Before: SILBERMAN, WILLIAMS, and RANDOLPH, Cir-

cuit Judges.

2a

Opinion for the Court filed by Circuit Judge RANDOLPH.

RANDOLPH, Circuit Judge: Petitioners Clean Air Im-

plementation Project and other trade associations?

brought this action for judicial review of the Environ-

mental Protection Agency’s rule permitting the use of

“credible evidence” to prove or disprove violations of the

Clean Air Act, 42 U.S.C. §§ 7401 et seg. They allege

that the rule is illegal for various reasons, including lack

of statutory authority and unlawful revision of substantive

standards. We hold that the issues they raise are unripe

and cannot be decided at this time.

I

The Clean Air Act directs the EPA Administrator to

develop and promulgate three types of air pollution stand-

ards. National ambient air quality standards (“NAAQS”),

issued under § 109, 42 U.S.C. § 7409, specify the maxi-

mum permissible concentrations of six criteria pollutants

in the air. See 40 C.F.R. pt. 50. The Act makes states

primarily responsible for the attainment and maintenance

of the NAAQS through state-designed implementation

plans, see 42 U.S.C. § 7410, also called “SIPs,” which

EPA must approve and which become federally enforce-

able once approved, see id. § 7413(a). Performance

standards issued pursuant to § 111, 42 U.S.C. § 7411,

regulate emissions of air pollutants from newly constructed

or modified stationary sources. See 40 C.F.R. pt. 60.

Emission standards for stationary sources of hazardous

air pollutants for which no ambient air quality standard is

applicable are issued pursuant to § 112, 42 US.C.

§ 7412.2 See 40 C.F.R. pt. 61. EPA may enforce these

1The trade associations represent various industry groups, in-

cluding car manufacturers, lumber companies, steel producers,

petroleum companies, and mining companies.

2In the Clean Air Act Amendments of 1990, Congress rewrote

§ 112 to include a list of 189 toxic air pollutants that EPA was

required to regulate. However, §112(q) provides that standards

cn See seg i eee gr eee ene ny reine

3a

standards through administrative, civil, or, with the assist-

ance of the Attorney General, criminal actions. See 42

U.S.C. § 7413.

Before EPA adopted its credible evidence rule in Feb-

ruary 1997, 62 Fed. Reg. 8314, the agency’s air pollution

standards specified not only the maximum permissible !evel

of emissions, but also the performance or reference test

that should be used as a means of sampling and analyzing

air pollutants for the particular standard. See, e.g., 40

C.F.R. §§ 60.2, 61.02. A reference test is any “generic

multi-use test protocol[] that measure[s] whether a

source’s emissions comply with numeric performance

standards.” Paul D. Hoburg, Use of “Credible Evidence”

to Prove Clean Air Act Violations, 25 B.C. ENVTL. AFF.

L. Rev. 771, 784-85 (1998). Subparts of Title 40 pre-

scribe reference tests for various emission sources. Appen-

dix A to 40 C.F.R. Part 60, for instance, contains more

than fifty different test methods for determining compli-

ance with the new source performance standards. See also

40 C.F.R. pt. 61, App. B (listing test methods for hazard-

ous air pollutant standards); 40 C.F.R. pt. 51, App. M

(listing recommended test methods for state implementa-

tion plans). In all, there are approximately 130 reference

tests, although the same test may be “used in connection

with many different performance standards.” Hoburg,

supra, at 785.

In the rulemaking challenged here, EPA added nearly

identical language to five sections of its regulations, pro-

viding that nothing in them “shall preclude the use, in-

cluding the exclusive use, of any credible evidence infor-

mation, relevant to whether a source would have been in

compliance with applicable requirements if the appropriate

performance or compliance test or procedure had been

performed.” 40 C.F.R. § 60.11(g); see also 40 C.F.R.

in effect before the date of enactment “shall remain in force and

effect after such date.”

4a

§§ 51.212(c), 52.12(c), 52.33(a), and 61.12(e). The

agency based these revisions on its “long-standing author-

ity under the Act, and on amplified authority provided by

the 1990 [Clean Air Act Amendments],” specifically

§ 113(a) and (e), 42 U.S.C. § 7413(a), (e). 62 Fed.

Reg. 8314. Section 113 deals with federal enforcement of

emission standards and, according to its legislative history,

was amended to enhance EPA’s enforcement powers. See

S. Rep. No. 101-228, at 358 (1989), reprinted in 1990

U.S.C.C.A.N. 3385, 3741. EPA maintains that the “lan-

guage, history and intent” of the 1990 Amendments sup-

port its credible evidence revisions. 62 Fed. Reg. 8314.

Nothing in the rule itself defines or limits the possible

kinds of evidence encompassed within the phrase “credible

evidence.” EPA explained in the preamble to its final

rule: “today’s rule will make it clear that various kinds

of information other than reference test data, much of

which is already available and utilized for other purposes,

may be used to determine compliance or noncompliance

with emission standards.” 62 Fed. Reg. at 8315. The

preamble listed “engineering calculations, indirect esti-

mates of emissions, and direct measurement of emissions

by a variety of means” as methods on which EPA, state

agencies, and industry routinely rely. 7d. Also mentioned

were “continuous emission monitoring” and “parametric

monitoring” data. Jd. To illustrate, EPA discussed the

use of a continuous opacity monitor instead of Method 9,

the reference test method for opacity. Method 9 requires

that a “trained visible emissions observer (VEO) view a

smoke plume with the sun at a certain angle to the plume

in order to properly illuminate it. In contrast, a continu-

Ous opacity monitor (COM) contains a calibrated light

source that provides for accurate and precise measure-

ment of opacity at all times. Notably, EPA uses COM

data to certify and re-certify the credentials of VEOs

under Method 9.” Id. at 8319. Thus, according, to the

agency, continuous opacity monitoring data would be

CN mmrmnmemmenta mame ememeemereceeecnecamneeena a eS cc

5a

credible evidence in lieu of Method 9. The preamble also

cited two citizen suits based on credible evidence. Id. at

8318. In Sierra Club v. Public Service Co., 894 F. Supp.

1455 (D.Colo. 1995), the court accepted opacity monitor-

ing data and reports as means of proving emissions viola-

tions. In Unitek Environmental Servs. v. Hawaiian Ce-

ment, No. 95-00723 (D.Haw. 1996), the court upheld

teh use of evidence that included EPA’s notice of viola-

tion issued to Hawaiian Cement several months before,

Hawaiian Cement’s admission of noncompliance, and re-

sults of Hawaiian Cement’s computerized modeling of its

own particulate emissions.

Petitioners argue that EPA promulgated the rule with-

out statutory authority, that the revisions are unlawful

because EPA failed to comply with proper rulemaking

procedures, and that EPA violated the Clean Air Act by

forcing states to rewrite their implementation plans. The

heart of the argument is that the credible evidence rule,

by altering the means of determining compliance for the

new source performance standards and the hazardous air

pollutant standards, increases the stringency of the under-

lying standards. Since EPA admittedly did not conduct

a rulemaking for each of the standards to which the cred-

ible evidence rule may be applied, petitioners charge that

it violated the procedures required by the Act. See 42

U.S.C. § 7607(d). EPA’s short answer is that there was

no need for such proceedings because the standards have

not been changed.

II

Petitioners’ theory of the relationship between tests and

standards is this: the test method is an integral part of the

standard itself and the test method should not be changed

without a full evaluation of the impact such a change

might have on the standard. The theory proceeds from

the fact that in developing its standards, EPA relied on

tests showing the standards to be consistently achievable

using the best current technology. See Brief of Petitioners

6a

at 9-10. EPA then used these same test methods to deter-

mine compliance with the numerical standards it promul-

gated. Citing Portland Cement Ass’n v. Ruckelshaus, 486

F.2d 375 (D.C. Cir. 1973), petitioners argue that chang-

ing the means of testing compliance amounts to changing

the standard themselves. In Portland Cement, the court

stated that “a significant difference between techniques

used by the agency in arriving at standards, and require-

ments presently prescribed for determining compliance

with standards, raises questions about the validity of the

standard.” Id. at 396. There the court required EPA to

explain the discrepancy between the method used to de-

velop the standard and the method used to enforce it.

Id. at 397.

Petitioners’ view of the interaction between tests and

standards leads them to two contentions. First, they as-

sert that any change in compliance method or test is sub-

stantive because “use of a different test method or proce-

dure can lead to fundamental differences in results, due to

differences in analytical method, data reduction, or meas-

urement location.” Brief of Petitioners at 13-14. For

example, a newer and more sensitive test might detect

emissions in excess of the numerical limit at times when

the original reference test would show that emissions were

below the regulatory ceiling. Second, they claim that the

credible evidence rule converts “periodic” standards to

“continuous” ones. See id. at 35-42. That is, sources

previously subject to standards based on “snapshot” data

from infrequent “short-term” tests may now have their

compliance monitored on an ongoing basis through the

use of credible evidence. Id. at 35-36. Converting a

periodic standard into a continuous one makes the stand-

ard more rigorous because, petitioners assert, continuous

monitoring will capture all the fluctuations and variability

inherent in emissions and thus increase each source’s num-

ber of “violations.” (According to petitioners, variability

in emissions had previously been compensated for by

Ja

means of infrequent testing.) The issues raised by these

contentions are not, we hold, justiciable at this time.

In 1967, three Supreme Court cases, decided in tandem,

revolutionized judicial review of agency rulemaking. The

cases—Abbott Laboratories v. Gardner, 387 U.S. 136;

Toilet Goods Ass'n v. Gardner, 387 U.S. 158; and Gard-

ner v. Toilet Goods, Ass'n, 387 U.S. 167—dealt with the

then-unsettled question when, if ever, courts may pass

upon the validity of an agency regulation prior to its en-

forcement. “Before Abbott Laboratories the courts typ-

ically reviewed the lawfulness of an agency’s rule, not

when it was promulgated, but when it was enforced. After

Abbott Laboratories reviewing practice changed radically.”

STEPHEN G. BREYER & RICHARD B. STEWART, ADMINIS-

TRATIVE LAW AND REGULATORY Policy 1136 (2d ed.

1985). In deciding whether judicial review must await

application of the rule in the concrete setting of an en-

forcement action, the Supreme Court adopted Judge

Friendly’s formulation in Toilet Goods Ass'n v. Gardner,

360 F.2d 677, 684 (2d Cir. 1966) (quoting Joint Anti-

Fascist Refugee Comm. v. McGrath, 341 U.S. 123, 156

(1951) (Frankfurter, J., concurring): there must be an

evaluation of “both the fitness of the issues for judicial

decision and the hardship to the parties of withholding

court consideration.” Abbott Labs., 387 U.S. at 149.

In the three decades since Abbott Laboratories, “preen-

forcement review of agency rules and regulations has be-

come the norm, not the exception,” BREYER & STEWART,

supra, at 1137, a trend accelerated by Congress’ enact-

ment of a host of regulatory statutes specifically providing

for this. The review provision of the Clean Air Act, 42

U.S.C. § 7607(b), invoked here, is typical. It provides

that a petition for judicial review must be filed within 60

days of publication of a rule in the Federal Register, 42

U.S.C. § 7607(b)(1), and that action of the EPA Admin-

istrator “with respect to which review could have been

obtained . . . shall not be subject to judicial review in civil

8a

or criminal proceedings for enforcement,” 42 U.S.C.

§ 7607(b)(2). We have not considered this provision, or

like provisions in other regulatory statutes, as requiring

the court to adjudicate issues raised in a preenforcement

challenge to a rule unless those issues are suitable for

decision. If the issues are not of that nature, we will dis-

miss the petition as unripe. See Louisiana Environmental

Action Network v. Browner, 87 F.3d 1379, 1385 (D.C.

Cir. 1996); Association of American Railroads v. Surface

Transportation Bd., No. 97-1020, 1998 WL 343436 *4

(D.C. Cir. June 30, 1998).3 A necessary corollary is that

if the issues later become justiciable, as a result for in-

stance of an enforcement action, the petitioner may then

raise those issues, notwithstanding the portion of § 7607

(b)(2) just quoted. See Louisiana Environmental Action

Network, 87 F.3d at 1381; Baltimore Gas & Elec. Co. v.

ICC, 672 F.2d 146 (D.C. Cir. 1982).

As to petitioners’ first contention, neither element of the

Abbott Laboratories inquiry—fitness for judicial decision

and hardship of denying relief—has been satisfied. In

determining the fitness of an issue for judicial review we

look to see whether the issue “is purely legal, whether con-

sideration of the issue would benefit from a more con-

certe setting, and whether the agency’s action is sufficiently

final.” Natural Resources Defense Council, Inc. v. EPA,

22 F.3d 1125, 1133 (D.C. Cir. 1994) (quoting Her

Majesty the Queen ex rel. Ontario v. EPA, 912 F.2d

1525, 1532 (D.C. Cir. 1990)). EPA’s credible evidence

rule is final, but in contending that the rule alters the

standards, petitioners have raised issues that are not purely

legal, issues that are not suitable for decision in the ab-

3 The purpose of withholding judicial review “is to prevent the

courts, through avoidance of premature adjudication, from entan-

gling themselves in abstract disagreements over administrative

policies, and also to protect the agencies from judicial interference

until an administrative decision has been formalized and its effects

felt in a concrete way by the challenging parties.” Abbott Labs.,

387 U.S. at 148-49.

9a

stract. See Truckers United for Safety v. Federal High-

way Administration, 139 F.3q 934 (D.C. Cir. 1998).

Judicial resolution of these issues would benefit signifi-

cantly from having “the scope of the controversy . . . re-

duced to more manageable proportions, and its factual

components fleshed out, by some concrete action applying

the regulation to the [petitioners’] situation in a fashion

that harms or threatens to harm” them. Lujan v. National

Wildlife Fed’n, 497 U.S. 871, 891 (1990).

As matters now stand, there are too many imponder-

ables. EPA insists that using credible evidence will not

“change any of the numeric emission limits with which

sources must comply” and that reference tests remain the

benchmark against which credible evidence is measured.

Brief of Respondent at 3, 11. In promulgating the rule,

EPA stated that credible evidence was “not intended to

and will not serve to affect the stringency of underlying

emission standards by amending the nature of the com-

pliance obligation.” 62 Fed. Reg. at 8315. It explained:

Typically, reference test methods . - . quantify the

presence of particular physical attributes—for ex-

ample, mass or concentration of a chemical or group

of chemicals—over a specified period of time. As

long as these two elements, quantification and speci-

fied time period—are retained and the data from the

alternate method is related to the reference test, in-

formation generated by alternate methods yield data

bearing on what the results of a reference test would

have been, and the use of such information to estab-

lish compliance or noncompliance in an enforcement

action will not affect the stringency of the standard.

62 Fed. Reg. at 8319. Petitioners dismiss EPA’s asser-

tions, claiming that the agency “is in denial” about the

consequences of its own actions. Brief of Petitioners at

34,

Will each of the 130 or so reference tests truly be main-

tained as benchmarks against which credible evidence will

10a

be measured? The tests themselves are described in “pain-

staking technical detail in various appendices throughout

Title 40 C.F.R. chapter I.” Hoburg, supra, at 785. For

all we know, application of EPA’s credible evidence rule

in the place of a reference test may potentially affect some

standards but not others. Moreover, credible evidence is

not a closed set. Given the universe, of all possible evi-

dence that might be considered “credible,” it is impossible

for us to decide now what impact the rule will have.

EPA’s representation that credible evidence must be “re-

lated” to the results a reference test would have shown is

highly abstruse. See 62 Fed. Reg. 8314 (promulgation of

credible evidence rule). An enforcement action brought

on the basis of credible evidence would, we believe, pro-

vide the factual development necessary to determine

whether the new rule has affected whatever existing stand-

ard is involved. Until then, we have the “classic institu-

tional reason to postpone review: we need to wait for a

rule to be applied to see what its effect will be.” Louisiana

Environmental Action Network, 87 F.3d at 1385 (quot-

ing Diamond Shamrock vy. Costle, 580 F.2d 670, 674

(D.C. Cir. 1978) ).

Petitioners cannot point to any great hardship they

would suffer by our deferring judicial review. EPA’s rule

does not require them “to engage in, or to refrain from,

any conduct.” Texas v. United States, 118 S. Ct. 1257,

1260 (1998). Unlike the drug manufacturers in Abbott

Laboratories, but like the cosmetics companies in Toilet

Goods Ass'n v. Gardner, 387 U.S. at 164, petitioners here

need not change their behavior or risk costly sanctions.

Source owners and operators are already under an obliga-

tion to comply with EPA’s emission standards. If the

credible evidence rule has in fact altered these standards,

petitioners can raise that as a defense in an enforcement

action. The burden of participating in future proceed-

ings does not “constitute sufficient hardship for the pur-

poses of ripeness.” Florida Power & Light Co. v. EPA,

lla

No. 95-1093, 1998 WL 336520, *8 (D.C. Cir. June 26,

1998). To be sure, it is easier and cheaper to mount a

single challenge now rather than defend a series of en-

forcement actions. But “this kind of litigation cost-saving”

does not “justify review in a case that would otherwise be

unripe.” Ohio Forestry Ass’n v. Sierra Club, 118 S. Ct.

1665, 1671 (1998).

This brings us to petitioners’ contention that the cred-

ible evidence rule illegally converts “periodic” standards

to “continuous” ones. Owners and operators of emission

sources are required, according to petitioners, to meet

emission limits only when intermittent tests are conducted;

at all other times they are subject to no more than a “gen-

eral duty” requirement to maintain good operiting pro-

cedures. Brief of Petitioners at 18.

Again, we find that it would be premature for us to

decide this issue now. EPA points to provisions of the

Clean Air Act and implementing regulations seeming to

support its view that compliance is required continuously,

not periodically. Still, the effect of the credible evidence

rule on compliance obligations is difficult to assess without

any information or experience showing how the rule oper-

ates in particular settings. For some standards, measuring

emission levels at each and every instant—i.e., on a con-

tinuous basis—might affect stringency in ways that are im-

possible at this moment to foretell. We therefore find

this issue unripe for review as well.

Because the merits of petitioners’ first set of contentions

are not justiciable, we do not reach their related asser-

tion, also raised by Battery Council International as in-

tervenor, that the Clean Air Act Amendments provide no

basis for promulgating the credible evidence rule. Peti-

tioners argue that § 113(a) of the Act addresses only the

initiation of an enforcement action. Although this is a

#Section 113(a) provides that an action to enforce compliance

may be brought “[w]henever, on the basis of any information

12a

purely legal question, and thus presumably ripe, the need

for statutory authority depends in the first instance on

what it is that the credible evidence rule actually accom-

plishes. See Toilet Goods, 387 U.S. at 163-64.°

Ill

Petitioners also challenge EPA’s credible evidence addi-

tions to 40 C.F.R. Part 51 (requirements for the prepara-

tion, adoption, and submission of state implementation

plans) and Part 52 (requirements for the approval and

promulgation of implementation plans), claiming that

EPA has “violate[d] the Federal-State division of author-

ity established by [§ 110 of the Act] by requiring States

to revise SIPs that EPA has found are already adequate

to implement the Act.” Brief of Petitioners at 28. EPA’s

revisions inserted language to the effect that the state

plans “must not preclude the use, including the exclusive

use, of any credible evidence or information. . . .” 40

C.F.R. § 51.212; see also id. §§ 52.12(c) (federal en-

forcement of state plans), 52.33(a) (compliance certifi-

cations). According to petitioners, these changes “illegally

invade” the authority of states under the Clean Air Act.

Brief of Petitioners at 48.

available to the Administrator, the Administrator finds that any

person has violated or is in violation of” an applicable standard.

Although § 113(a) is written in terms of finding a violation, the

procedure followed is that the Administrator issues a notice of

violation and then may either issue an administrative order,

§113(d), or commence a civil action, §113(b). See 42 U.S.C.

§ 7413.

5If, as EPA maintains, the rule really does not change the

standards, then it might be seen as a permissible exercise of the

agency’s general rulemaking authority under § 301 of the Act, 42

U.S.C. § 7601(a)(1). (The agency itself does not rely exclusively on

§§ 113(a) and (e), noting that the credible evidence rulemaking was

“based primarily on EPA’s existing authority prior to the 1990

CAA Amendments.” 62 Fed. Reg. at 8320.)

a

oS a ee

13a

During the credible evidence rulemaking, the EPA re-

sponded to comments that these amendments were un-

authorized by asserting that

EPA is not by this rulemaking revising any SIP;

rather, EPA is amending the rules governing SIPs.

Such rules are promulgated under EPA’s authority

to (1) require SIPs to provide adequate enforcement

authority (see sections 110(a)(2)(A), (C), and

(E)); (2) call for SIP revisions to correct inade-

quacies (see section 110(k)(5)); and (3) “pre-

scribe such regulations as are necessary to carry out

[the Administrator’s] functions under this chapter.

42 U.S.C. § 7601.

Response to Comments at 103. EPA’s brief explains that

it derived its authority for the rule from § 110(a)(2)(H)

(ii), under which state plans shall “provide for revision”

whenever EPA finds that the plan is “substantially inade-

quate to . . . comply with any additional requirements

established under this chapter,” 42 U.S.C. § 7410(a)(2)

(H) (ii), and from the statutory requirement that state

plans must be “enforceable.” Brief of Respondent at 41.

This is hard to follow. If state plans approved by EPA

met the enforceability requirement prior to EPA’s adop-

tion of the credible evidence rule, one may wonder why

the state plans have now become “unenforceable” to the

extent they do not permit the use of credible evidence.

The pre-existing test methods, after all, are still available

to determine compliance. In any event the merits of this

claim are not properly before us.

Regardless whether a state might be able to challenge

directly the revised regulations (no state has), petitioners

cannot do so. Nothing in the amended regulations re-

quires states to change their implementation plans. That

can only occur through an independent procedure known

as a “SIP call.” Under § 110(k)(5), the EPA must notify

a state of inadequacies in its plan and request the sub-

mission of a revised plan. 42 U.S.C. § 7410(k)(5). This

14a

begins an extensive regulatory process that includes the

publication of a proposed plan in the Federal Register for

notice and comment before final approval by the agency.

See Greater Cincinnati Chamber of Commerce v. EPA,

879 F.2d 1379 (6th Cir. 1989) (finding that SIP calls do

not constitute final agency action).

This proces was set in motion before the promulgation

of the rule challenged here. See 62 Fed. Reg. at 8327.

SIP calls to various states were issued as early as 1994.

EPA’s notice to states included draft credible evidence

language that, “if adopted by the State and submitted to

EPA for aproval in the SIP, would satisfy the require-

ments of this SIP call.” 60 Fed. Reg. 46,222, 46,225

(1995) (approving South Dakota’s plan); see also 60

Fed. Reg. 36,361 (1995) (Kansas); 62 Fed. Reg. 17,081,

17,082 (1997) (Minnesota). When EPA published the

credible evidence rule, it noted that fifteen states had sub-

mitted new plans and several had already been approved.

Thus, the request that state plans be revised and the sub-

mission and approval of revised plans were not triggered

by the amendments to Parts 51 and 52. In this case,

petitioners have challenged neither the SIP calls nor any

of the newly-approved state plans.

Even if we were to assume that revising the regula-

tions forced the states to submit new plans—something

not suggested by the record—we would find petitioners’

challenge unripe. It is not at all apparent that use of cred-

ible evidence alters the emissions standards governing pe-

titioners’ activities. Although the question whether EPA

had statutory authority is a purely legal one, the effect of

the credible evidence rule on petitioners—that is, the ef-

fect of language in state plans specifying that use of

credible evidence is not precluded—is highly uncertain for

reasons already mentioned. In addition, an amicus brief

submitted by state air pollution authorities indicates that

states have historically used credible evidence and that

some state and local air agencies have relied on credible

15a

evidence as the exclusive basis for enforcement actions.

See Brief of Amici Curiae at 4-5. Like the Supreme Court

in Toilet Goods, 387 U.S. at 162, we believe that our ju-

dicial appraisal “is likely to stand on a much surer foot-

ing in the context of a specific application of this

regulation.”

IV

Battery Council International, as intervenor, claims that

EPA has “attempted unlawfully to revise” its permit shield

regulations in promulgating the credible evidence rule.

Brief of Intervenor at 27.

In the 1990 Amendments, Congress established an oper-

ating permit program for certain sources of air pollution,

including major stationary sources. See 42 US.C.

§§ 7661-7661f. Under this program, each permit issued

must include all emissions limitations and standards’ ap-

plicable to the source, as well as provisions concerning

inspection, monitoring, compliance certification, and re-

porting requirements. The regulations implementing the

permit program are contained in 40 C.F.R. Part 70.

Battery Council thinks the following language in EPA’s

preamble to the credible evidence rule “would undermine

the principal purpose” of the permits:

[although permits] can include a “permit shield” pro-

tecting [a source] from allegations that it has failed

to satisfy CAA monitoring requirements, such shield

does not relieve the source of its obligation to com-

ply with the underlying emission limits or other appli-

cable requirements being monitored. . . . In other

words, . . . the source would not be shielded from al-

legations of noncompliance with the underlying sub-

stantive requirements (e.g., emission limits) being

monitored even if the source’s required monitoring

failed to detect the violation.

62 Fed. Reg at 8320. Battery Council argues that, con-

trary to EPA's interpretation, “permit shields also protect

l6a

sources from enforcement of ‘underlying emission limits,’

as long as sources comply with their permits.” Brief of

Intervenor at 30,

We will not reach the merits of this argument. The

credible evidence rule did not change any language in Part

70. It is doubtful that the preamble alone is definite and

specific enough to be a binding statement of agency pol-

icy. For one thing, the statements concerning the permit

shield were not published in the Code of Federal Regula-

tions. See Florida Power & Light, 1998 WL 336520, *4.

For another, EPA has claimed that its statements were no

more than “an interpretation” given “existing permit shield

regulation,” Brief of Respondent at 45, and Battery Coun-

cil has presented no evidence that the preamble has a

direct and immediate effect on it. In Kennecott Utah

Copper Corp. v. Department of the Interior, 88 F.3d

1191, 1222 (D.C. Cir. 1996), we held that although a

“preamble may under some circumstances be reviewable,”

the preamble challenged there was nevertheless not ripe

because the issue presented was conjectural and “a more

complete understanding of its ramifications must await a

concrete application.” The same holds true here. This

chalenge is therefore unripe for review.

a * x oK

Petitioners and intervenor raise a number of other sub-

sidiary issues which, while we have considered fully, pre-

sent no need for discussion. For the reasons stated above,

we dismiss the petition for review. 4

So ordered.

17a

APPENDIX B

[Filed Nov. 20, 1998]

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 97-1117

CLEAN AIR IMPLEMENTATION PROJECT,

Petitioner

We

ENVIRONMENTAL PROTECTION AGENCY,

Respondent

NATURAL RESOURCES DEFENSE COUNCIL, INC.

and BATTERY COUNCIL INTERNATIONAL,

Intervenors

—

Consolidated with

97-1125, 97-1130, 97-1142, 97-1169, 97-1173, 97-1179,

97-1190, 97-1195, 97-1226, 97-1241, 97-1242, 97-1253,

97-1254, 97-1259, 97-1261, 97-1266, 97-1269, 97-1273,

97-1278, 97-1281, 97-1282, 97-1283, 97-1286, 97-1289

BEFORE: Silberman, Williams and Randolph, Circuit

Judges

ORDER

Upon consideration of the petitions for rehearing of pe-

titioners Appalachian Power Co., et al. and the Clean Air

Implementation Project, et al., filed September 28, 1998,

and of the response thereto, it is

18a

ORDERED that the petitions be denied.

Per Curiam

FOR THE COURT:

MarK J. LANGER

Clerk

By: /s/ Robert A. Bonner

RoBERT A. BONNER

Deputy Clerk

19a

APPENDIX C

[Filed Nov. 20, 1998]

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 97-1117

CLEAN AIR IMPLEMENTATION PROJECT,

Petitioner

Vv.

ENVIRONMENTAL PROTECTION AGENCY,

Respondent

NATURAL RESOURCES DEFENSE COUNCIL, INC.

and BATTERY COUNCIL INTERNATIONAL,

Intervenors

Consolidated with

97-1125, 97-1130, 97-1142, 97-1 169, 97-1173, 97-1179,

97-1190, 97-1195, 97-1226, 97-1241, 97-1242, 97-1253,

97-1254, 97-1259, 97-1261, 97-1266, 97-1269, 97-1273,

97-1278, 97-1281, 97-1282, 97-1283, 97-1286, 97-1289

BEFORE: Edwards, Chief Judge; Wald, Silberman,

Williams, Ginsburg, Sentelle, Henderson,

Randolph, Rogers, Tatel and Garland, Cir-

cuit Judges

ORDER

Upon consideration of the Suggestions for Rehearing

In Banc of petitioners Appalachian Power Co., et al. and

20a

the Clean Air Implementation Project, et al., the response

thereto, and the absence of a request by any member of

the court for a vote, it is

ORDERED that the suggestions be denied.

Per Curiam

FoR THE CouRT:

MARK J. LANGER

Clerk

By: /s/ Robert A. Bonner

ROBERT A. BONNER

Deputy Clerk

Circuit Judges Henderson and Tatel did not participate

in this matter.

21a

APPENDIX D

[Mandate Issued: 12/1/98]

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 97-1117

CLEAN AIR IMPLEMENTATION PROJECT, et al.,

Petitioners

Vv.

ENVIRONMENTAL PROTECTION AGENCY,

Respondent

NATURAL RESOURCES DEFENSE COUNCIL, INC.

and BATTERY COUNCIL INTERNATIONAL,

Intervenors

Consolidated with

97-1125, 97-1139, 97-1142, 97-1 169, 97-1173, 97-1179,

97-1190, 97-1195, 97-1226, 97-1241, 97-1242. 97-1253,

97-1254, 97-1259, 97-1261, 97-1266, 97-1269, 97-1273,

97-1278, 97-1281, 97-1282, 97-1283, 97-1286, 97-1289

On Petitioners for Review of an Order of the

Environmental Protection Agency

Before: SILBERMAN, WILLIAMS and RANDOLPH, Cir-

cuit Judges.

22a

JUDGMENT

These causes came on to be heard on the petitions for

review of an order of the Environmental Protection

Agency and were argued by counsel. On consideration

thereof, it is

ORDERED and ADJUDGED, by the Court, that the

petitions for review are dismissed, in accordance with the

opinion of the Court filed herein this date.

FOR THE CouRT:

MarK J. LANGER

Clerk

By: /s/ Robert A. Bonner

ROBERT A. BONNER

Deputy Clerk

Date: August 14, 1998

Opition for the Court filed by Circuit Judge Randolph.

23a

APPENDIX E

Excerpts From Articles I and III of the

United States Constitution

CONSTITUTION OF THE

UNITED STATES OF AMERICA

Article I, Section 8, Clause 9

ARTICLE I

* * * x

SECTION 8. The Congress shall have Power

* * of *

To constitute Tribunals inferior to the Supreme Court;

* * * *

Article III, Section 1

ARTICLE III

SECTION 1. The judicial Power of the United States,

shall be vested in one supreme Court, and in such inferior

Courts as the Congress may from time to time ordain and

establish. The Judges, both of the supreme and inferior

Courts, shall hold their Offices during good Behaviour,

and shall, at stated Times, receive for their Services, a

Compensation, which shall not be diminished during their

Continuance in Office.

* * * *

24a

APPENDIX F

Excerpts From Sections 110, 111, 112 and 307

of the Clean Air Act

Excerpt from Section 110 of the Clean Air Act

§ 7410. State implementation plans for national primary

and secondary ambient air quality standards

(a) Adoption of plan by State; submission to Adminis-

rator; content of plan; revision; new sources; indirect

source review program; supplemental or intermittent

control systems

(1) Each State shall, after reasonable notice and public

hearings, adopt and submit to the Administrator, within

3 years (or such shorter period as the Administrator may

prescribe) after the promulgation of a national primary

ambient air quality standard (or any revision thereof)

under section 7409 of this title for any air pollutant, a

plan which provides for implementation, maintenance, and

enforcement of such primary standard in each air quality

control region (or portion thereof) within such State. In

addition, such State shall adopt and submit to the Ad-

ministrator (either as a part of a plan submitted under the

preceding sentence or separately) within 3 years (or such

shorter period as the Administrator may prescribe) after

the promulgation of a national ambient air quality second-

ary standard (or revision thereof), a plan which provides

for implementation, maintenance, and enforcement of such

secondary standard in each air quality control region (or

portion thereof) within such State. Unless a separate pub-

lic hearing is provided, each State shall consider its plan

implementing such secondary standard at the hearing re-

quired by the first sentence of this paragraph.

(2) Each implementation plan submitted by a State

under this chapter shall be adopted by the State after

reasonable notice and public hearing. Each such plan

shall--

ey meet

EL ORAEPLAREELIV

fF Sibi A REREAD RAEI GO a ey in BN AGH

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4

;

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4

:

25a

(A) include enforceable emission limitations and

other control measures, means, or techniques (includ-

ing economic incentives such as fees, marketable per-

mits, and auctions of emissions rights), as well as

schedules and timetables for compliance, as may be

necessary Or appropriate to meet the applicable re-

quirements of this chapter;

(B) provide for establishment and operation of

appropriate devices, methods, systems, and _proce-

dures necessary to—

(i) monitor, compile, and analyze data on

ambient air quality, and

(ii) upon request, make such data available

to the Administrator;

(C) include a program to provide for the enforce-

ment of the measures described in subparagraph

(A), and regulation of the modification and con-

struction of any stationary source within the areas

covered by the plan as necessary to assure that na-

tional ambient air quality standards are achieved,

including a permit program as required in parts C

and D of this subchapter;

(D) contain adequate provisions—

(i) prohibiting, consistent with the provisions

of this subchapter, any source or other type of

emissions activity within the State from emitting

any air pollutant in amounts which will—

(I) contribute significantly to nonattain-

ment in, or interfere with maintenance by,

any other State with respect to any such

national primary or secondary ambient air

quality standard, or

(II) interfere with measures required to

be included in the applicable implementa-

26a

tion plan for ary other State under part C

of this subchapter to prevent significant

deterioration of air quality or to protect

visibility.

(ii) insuring compliance with the applicable

requirements of sections 7426 and 7415 of this

title (reating to interstate and international pol-

lution abatement) ;

(E) provide (i) necessary assurances that the

State (or, except where the Administrator deems in-

appropriate, the general purpose local government or

governments, or a regional agency designated by the

State or general purpose local governments for such

purpose) will have adequate personnel, funding, and

authority under State (and, as appropriate, local)

law to carry out such implementation plan (and is

not prohibited by any provision of Federal or State

law from carrying out such implementation plan or

portion thereof), (ii) requirements that the State

comply with the requirements respecting State boards

under section 7428 of this title, and (iii) necessary

assurances_that, where the State has relied on a local

or regional government, agency, or instrumentality

for the implementation of any plan provision, the

State has responsibility for ensuring adequate imple-

mentation of such plan provision;

(F) require, as may be prescribed by the Adminis-

trator—

(i) the installation, maintenance, and re-

placement of equipment, and the implementation

of other necessary steps, by owners or operators

of stationary sources to monitor emissions from

such sources,

(ii) periodic reports on the nature and

amounts of emissions and emissions-related data

from such sources, and

27a

(iii) correlation of such reports by the State

agency with any emission limitations or stand-

ards established pursuant to this chapter, which

reports shall be available at reasonable times for

public inspection;

(G) provide for authority comparable to that in

section 7603 of this title and adequate contingency

plans to implement such authority;

(H) provide for revision of such plan—

(i) from time to time as may be necessary to

take account of revisions of~such national pri-

mary or secondary ambient air quality standard

or the availability of improved or more expedi- |

tious methods of attaining such standard, and |

(ii) except as provided in paragraph (3)(C),

whenever the Administrator finds on the basis

of information available to the Administrator

that the plan is substantially inadequate to at-

tain the national ambient air quality standard

which it implements or to otherwise comply with

any additional requirements established under

this chapter;

(I) in the case of a plan or plan revision for an

area designated as a nonattainment area, meet the

applicable requirements of part D of this subchapter

(relating to nonattainment areas);

(J) meet the applicable requirements of section

7421 of this title (relating to consultation), section

7427 of this title (relating to public notification) and

part C of this subchapter ( relating to prevention of

Significant deterioration of air quality and visibility

protection);

(K) provide for—

(i) the performance of such air quality mod-

cling as the Administrator may prescribe for the

28a

purpose of predicting the effect on ambient air

quality of any emissions of any air pollutant for

which the Administrator has established a na-

tional ambient air quality standard, and

(ii) the submission, upon request, of data

related to such air quality modeling to the Ad-

ministrator;

(L) require the owner or operator of each major

stationary source to pay to the permitting authority,

as a condition of any permit required under this

chapter, a fee sufficient to cover—

(i) the reasonable costs of reviewing and act-

ing upon any application for such a permit, and

(ii) if the owner or operator receives a per-

mit for such source, the reasonable costs of im-

plementing and enforcing the terms and condi-

tions of any such permit (not including any

court costs or other costs associated with any

enforcement action),

until such fee requirement is superseded with respect

to such sources by the Administrator’s approval of a

fee program under subchapter V of this chapter; and

(M) provide for consultation and participation by

local political subdivisions affected by the plan.

(3)(A) Repealed. Pub. L. 101-549, title I, § 101(d)

(1), Nov. 15, 1990, 104 Stat. 2409.

(B) As soon as practicable, the Administrator shall,

consistent with the purposes of this chapter and the Energy

Supply and Environmental Coordination Act of 1974 [15

U.S.C. 791 et seq.], review each State’s applicable imple-

mentation plans and report to the State on whether such

plans can be revised in relation to fuel burning stationary

sources (or persons supplying fuel to such sources) with-

out interfering with the attainment and maintenance of

any niitional ambient air quality standard within the period

PrA ae iS RIL it Sacpalllans

hele ah VE Tans ADIN I OL SS nde:

29a

permited in this section. If the Administrator determines

that any such plan can be revised, he shall notify the

State that a plan revision may be submitted by the State.

Any plan revision which is submitted by the State shall,

after public notice and Opportunity for public hearing, be

approved by the Administrator if the revision relates only

to fuel burning Stationary sources (or persons supplying

fuel to such sources), and the plan as revised complies

with paragraph (2) of this subsection. The Administrator

shall approve or disapprove any revision no later than

three months after its submission.

(C) Neither the State, in the case of a plan (or por-

tion thereof) approved under this subsection, nor the

Administrator, in the case of a plan (or portion thereof)

Promulgated under subsection ( C) of this section, shall be

required to revise an applicable implementation plan be-

cause one or more exemptions under section 7418 of this

title (relating to Federal facilities), enforcement orders

under section 7413(d) of this title, suspensions under

subsection (f) or ( g) of this section ( relating to tempo-

rary energy or econmic authority), orders under section

7419 of this title ( relating to primary nonferrous smelt-

ers), or extensions of compliance in decrees entered under

section 7413(e) of this title ( relating to iron- and steel-

Producing operations) have been granted, if such plan

would have met the requirements of this section if no

such exemptions, orders, or extensions had been granted.

(4) Repealed.| Pub. L. 101-549, title I, § 101(d)

(2), Nov. 15, 1990, 104 Stat. 2409.

(5) (A) (i) Any State may include in a State imple-

mentation plan, but the Administrator may not require

as a condition of approval of such plan under this section,

any indirect source review program. The Administrator

may approve and enforce, as part of an applicable imple-

mentation plan, an indirect source review program which

the State chooses to adopt and submit as part of its plan.

30a

(ii) Except as provided in subparagraph (B), no plan

promulgated by the Administrator shall include any in-

direct source review program for any air quality control

region, or portion thereof.

(iii) Any State may revise an applicable implementa-

tion plan approved under this subsection to suspend or

revoke any such program included in such plan, provided

that such plan meets the requirements of this section.

(B) The Administrator shall have the authority to

promulgate, implement and enforce regulations under sub-

section (c) of this section respecting indirect source re-

view programs which apply only to federally assisted high-

ways, airports, and other major federally assisted indirect

sources and federally owned or operated indirect sources.

(C) For purposes of this paragraph, the term “indirect

source means a facility, building, structure, installation,

real property, road, or highway which attracts, or may

attract, mobile sources of pollution. Such term includes

parking lots, parking garages, and other facilities subject

to any measure for management of parking supply

(within the meaning of subsection (c)(2)(D) (ii) of this

section), including regulation of existing off-street parking

but such term does not include new or existing on-street

parking. Direct emissions sources or facilities at, within,

or associated with, any indirect source shall not be deemed

indirect sources for the purpose of this paragraph.

(D) For purposes of this paragraph the term “indirect

source review program” means the facility-by-facility re-

view of indirect sources of air pollution, including such

measures as are necessary to assure, or assist in assuring,

that a new or modified indirect source will not attract

mobile sources of air pollution, the emissions from which

would cause or contribute to air pollution concentra-

tions—

AND ems na saa ae Rh

3la

(i) exceeding any national primary ambient air

quality standard for a mobile source-related air pol-

lutant after the primary standard attainment date, or

(ii) preventing maintenance of any such standard

after such date.

(E) For purposes of this paragraph and paragraph

(2)(B), the term “transportation control measure” does

not include any measure which is an “indirect source re-

view program.”

(6) No State plan shall be treated as meeting the re-

quirements of this section unless such plan provides that

in the case of any source which uses a supplemental, or

intermittent control system for purposes of meeting the

requirements of an order under section 7413(d)* of this

title or section 7419 of this title (relating to primary

nonferrous smelter orders), the owner or operator of such

source may not temporarily reduce the pay of any em-

ployee by reason of the use of such supplemental or inter-

mittent or other dispersion dependent control system.

* * * *

(c) Preparation and publication by Administrator of

proposed regulations setting forth implementation

plan; transportation regulations study and report;

parking surcharge; suspension authority; plan imple-

mentation

(1) The Administrator shall promulgate a Federal

implementation plan at any time within 2 years after the

Administrator—

(A) finds that a State has failed to make a

required submisison or finds that the plan or plan

revision submitted by the State does not satisfy the

minimum criteria established under subsection (k)

(1)(A) of this section, or

(B) disapproves a State implementation plan sub-

mission in whole or in part,

32a

unless the State corrects the deficiency, and the Adminis-

trator approves the plan or plan revision, before the

Administrator promulgates such Federal implementation

plan.

(2)(A) Repealed. Pub. L. 101549, title I, § 101(d)

(3)(A), Nov. 15, 1990, 104 Stat. 2409.

(B) No parking surcharge regulation may be required

by the Administrator under paragraph (1) of this sub-

section as a part of an applicable implementation plan.

All parking surcharge regulations previously required by

the Administrator shall be void upon June 22, 1974. This

subparagraph shall not prevent the Administrator from

approving parking surcharges if they are adopted and sub-

mitted by a State as part of an applicable implementation

plan. The Administrator may not condition approval of

any implementation plan submitted by a State on such

plan’s including a parking surcharge regulation.

(C) Repealed. Pub. L. 101-549, title I, § 101(d)(3)

(B), Nov. 15, 1990, 104 Stat. 2409.

(D) For purposes of this paragraph—

(i) The term “parking surcharge regulation”

means a regulation imposing or requiring the imposi-

tion of any tax, surcharge, fee, other area used for

the temporary storage of motor vehicles.

(ii) The term “management of parking supply”

shall include any requirement providing that any new

facility containing a given number of parking spaces

shall receive a permit or other prior approval, issu-

ance of which is to be conditioned on air quality

considerations.

(iii) The term “preferential bus/carpool lane” shall

include any requirement for the setting aside of one

or more lanes of a street or highway on a permanent

ere ae

salliaeint ainda

he aE Ne ein

i, AA lel Mig tc a i > she Nec ac id lis shih is deta

33a

or temporary basis for the exclusive use of buses or

carpools, or both.

(E) No standard, plan, or requirement, relating to

management of parking supply or preferential bus/carpool

lanes shall be promulgated after June 22, 1974, by the

Administrator pursuant to this section, unless such promul-

gation has been subjected to at least one public hearing

which has been held in the area affected and for which

reasonable notice has been given in such area. If substan-

tial changes are made following public hearings, one or

more additional hearings shall_be held in such area after

such notice.

(3) Upon application of the chief executive Officer of

any general purpose unit of local government, if the Ad-

ministrator determines that such unit has adequate author-

ity under State or local law, the Administrator may dele-

gate to such unit the authority to implement and enforce

within the jurisdiction of such unit any part of a plan

promulgated under this subsection. Nothing in this para-

graph shall prevent the Administrator from implementing

or enforcing any applicable provision of a plan promul-

gated under this subséction.

(4) Repealed. Pub. L. 101-549, title I, § 101(d)(3)

(C), Nov. 15, 1990, 104 Stat. 2409.

(5)(A) Any measure in an applicable implementation

plan which requires a toll or other charge for the use of

a bridge located entirely within one city shall be elim-

inated from such plan by the Administrator upon applica-

tion by the Governor of the State, which application shall

include a certification by the Governor that he will revise

such plan in accordance with subparagraph (B).

(B) In the case of any applicable implementation plan

with respect to which a measure has been eliminated under

subparagraph (A), such plan shall, not later than one year

34a

after August 7, 1977, be revised to include comprehensive

measures to:

(i) establish, expand, or improve public transpor-

tation measures to meet basic transportation needs,

as expeditiously as is practicable; and

(ii) implement transportation control measures

necessary to attain and maintain national ambient air

quality standards.

and such revised plan shall, for the purpose of implement-

ing such comprehensive public transportation measures,

include requirements to use (insofar as is necessary) Fed-

eral grants, State or local funds, or any combination of

such grants and funds as may be consistent with the terms

of the legislation providing such grants and funds. Such

measures shall, as a substitute for the tolls or charges elim-

inated under subparagraph (A), provide for emissions re-

ductions equivalent to the reductions which may reason-

ably be expected to be achieved through the use of the

tolls or charges eliminated.

(C) Any revision of an implementation plan for pur-

poses of meeting the requirements of subparagraph (B)

shall be submitted in coordination with any plan revision

required under part D of this subchapter.

* * 26 *

(k) Environmental Protection Agency action on plan

submissions

(1) Completeness of plan submissions

(A) Completeness criteria

Within 9 months after November 15, 1990, the

Administrator shall promulgate minimum criteria

that any plan submission must meet before the Ad-

ministrator is required to act on such submission

35a

under this subsection. The criteria shall be limited

to the information necessary to enable the Adminis-

trator to determine whether the plan submission com-

plies with the provisions of this chapter.

(B) Completeness finding

Within 60 days of the Administrator’s receipt of a

plan or plan revision, but no later than 6 months

after the date, if any, by which a State is required

to submit the plan or revision, the Administrator

shall determine whether the minimum criteria estab-

lished pursuant to subparagraph (A) have been met.

Any plan or plan revision that a State submits to the

Administrator, and that has not been determined by

the Administrator (by the date 6 months after re-

| ceipt of the submission) to have failed to meet the

minimum criteria established pursuant to subpara-

3 graph (A), shall on that date be deemed by opera-

i tion of law to meet such minimum criteria.

| (C) Effect of finding of incompleteness

Where the Administrator determines that a plan

4 submission (or part thereof) does not meet the min-

imum criteria established pursuant to subparagraph

(A), the State shall be treated as not having made

the submission (or, in the Administrator’s discretion,

part thereof).

(2) Deadline for action

Within 12 months of a determination by the Ad-

ministrator (or a determination deemed by operation

of law) under paragraph (1) that a State has sub-

mitted a plan or plan revision (or, in the Adminis-

trator’s discretion, part thereof) that meets the mini-

mum criteria established pursuant to paragraph (1),

if applicable (or, if those criteria are not applicable,

~ P= 4 4 Pet + ee =

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36a

within 12 months of submission of the plan or revi-

sion), the Administrator shall act on the submission

in accordance with paragraph (3).

(3) Full and partial approval and disapproval

In the case of any submittal on which the Admin-

istrator is required to act under paragraph (2), the

Administrator shall approve such submittal as a

whole if it meets all of the applicable requirements of

this chapter. If a portion of the plan revision meets

all the applicable requirements of this chapter, the

Administrator may approve the plan revision in part

and disapprove the plan revision in part. The plan

revision shall not be treated as meeting the require-

ments of this chapter until the Administrator approves

the entire plan revision as complying with the appli-

cable requirements of this chapter.

(4) Conditional approval

The Administrator may approve a plan revision

based on a commitment of the State to adopt specific

enforceable measures by a date certain, but not later

than 1 year after the date of approval of the plan

revision. Any such conditional approval shall be

treated as a disapproval if the State fails to comply

with such commitment.

(5) Calls for plan revisions

Whenever the Administrator finds that the appli-

cable implementation plan for any area is substan-

tially inadequate to attain or maintain the relevant

national ambient air quality standard, to mitigate ade-

quately the interstate pollutant transport described in

section 7506a of this title or section 7511c of this

title, or to otherwise comply with any requirement of

this chapter, the Administrator shall require the State

to revise the plan as necessary to correct such inade-

37a

quacies, The Administrator shal] notify the State of

the inadequacies, and may establish reasonable dead-

lines (not to exceed 18 months after the date of such

notice) for the submission of such plan revisions.

Such findings and notice shall be public. Any finding

under this paragraph shall, to the extent the Admin-

istrator deems appropriate, subject the State to the

requirements of this chapter to which the State was

subject when it developed and submitted the plan for

which such finding was made, except that the Admin-

istrator may adjust any dates applicable under such

requirements as appropriate (except that the Admin-

istrator may not adjust any attainment date prescribed

under part D of this subchapter, unless such date has

elapsed).

(6) Corrections

Whenever the Administrator determines that the

Administrator’s action approving, disapproving, or

promulgating any plan or plan revision (or part

thereof), area designation, redesignation, classifica-

tion, or reclassification was in error, the Adminis-

trator may in the same manner as the approval, dis-

approval, or promulgation revise such action as ap-

propriate without requiring any further submission

from the State. Such determination and the basis

thereof shall be provided to the State and public.

* * * %

Excerpt from Section 111 of the Clean Air Act

§ 7411. Standards of performance for new stationary

sources

(a) Definitions

For purposes of this section:

(1) The term “standard of performance” means

a standard for emissions of air pollutants which re-

38a

flects the degree of emission limitation achievable

through the application of the best system of emis-

sion reduction which (taking into account the cost of

achieving such reduction and any nonair quality

health and environmental impact and energy require-

ments) the Administrator determines has been ade-

quately demonstrated.

(2) The term “new source” means any stationary

source, the construction or modification of which is

commenced after the publication of regulations (or,

if earlier, proposed regulations) prescribing a stand-

ard of performance under this section which will be

applicable to such source.

(3) The term “stationary source” means any

building, structure, facility, or installation which

emits or may emit any air pollutant. Nothing in sub-

chapter II of this chapter relating to nonroad engines

shall be construed to apply to stationary internal com-

bustion engines.

(4) The term “modification” means any physical

change in, or change in the method of operation of,

a stationary source which increases the amount of

any air pollutant emitted by such source or which

results in the emission of any air pollutant not pre-

viously emitted.

(5) The term “owner or operator” means any per-

son who owns, leases, operates, controls, or super-

vises a stationary source.

(6) The term “existing source” means any station-

ary source other than a new source.

(7) The term “technological system of continuous

emission reduction” means—

(A) a technological process for production

or operation by any source which is inherently

low-polluting or nonpolluting, or

39a

(B) a technological system for continuous

reduction of the pollution generated by a source

before such pollution is emitted into the ambient

air, including precombustion cleaning or treat-

ment of fuels.

(8) A conversion to coal (A) by reason of an

order under section 2(a) of the Energy Supply and

Environmental Coordination Act of 1974 [15 U.S.C.

792(a)] or any amendment thereto, or any subse-

quent enactment which supersedes such Act [15

U.S.C. 791 et seq.], or (B) which qualifies under sec-

tion 7413(d)(5)(A) (ii) of this title, shall not be

deemed to be a modification for purposes of para-

graphs (2) and (4) of this subsection.

(b) List of categories of Stationary sources; standards of

performance; information on pollution control tech-

niques; sources owned or operated by United States;

particular systems; revised standards

(1)(A) The Administrator shall, within 90 days after

December 31, 1970, publish (and from time to time there-

after shall revise) a list of categories of stationary sources.

He shall include a category of sources in such list if in

his judgment it causes, or contributes significantly to, air

pollution which may reasonably be anticipated to endan-

ger public health or welfare.

(B) Within one year after the inclusion of a category

of stationary sources in a list under subparagraph (A),

the Administrator shall publish proposed regulations, es-

tablishing Federal standards of performance for new

sources within such category. The Administrator shall af-

ford interested persons an opportunity for written com-

ment on such proposed regulations. After considering

such comments, he shal! promulgate, within one year after

such publication, such standards with such modifications

40a

as he deems appropriate. The Administrator shall, at least

every 8 years, review and, if appropriate, revise such stand-

ards following the procedure required by this subsection

for promulgation of such standards. Notwithstanding the

requirements of the previous sentence, the Administrator

need not review any such standard if the Administrator

determines that such review is not appropriate in light of

readily available information on the efficacy of such stand-

ard. Standards of performance or revisions thereof shall

become effective upon promulgation. When implementa-

tion and enforcement of any requirement of this chapter

indicate that emission limitations and percent reductions

beyond those required by the standards promulgated

under this section are achieved in practice, the Adminis-

trator shall, when revising standards promulgated under

this section, consider the emission limitations and percent

reductions achieved in practice.

(2) The Administrator may distinguish among classes,

types, and sizes within categories of new sources for the

purpose of establishing such standards.

(3) The Administrator shall, from time to time, issue

information on pollution control techniques for categories

of new sources and air pollutants subject to the provisions

of this section.

(4) The provisions of this section shall apply to any

new source owned or operated by the United States.

(5) Except as otherwise authorized under subsection

(h) of this section, nothing in this section shall be con-

strued to require, or to authorize the Administrator to

require, any new or modified source to install and operate

any particular technological system of continuous emis-

sion reduction to comply with any new source standard of

performance.

(6) The revised standards of performance required by

enactment of subsection (a)(1)(A)(i) and (ii) of this

4la

section shall be promulgated not later than one year after

August 7, 1977. Any new or modified fossil fuel fired

stationary source which commences construction prior to

the date of publication of the proposed revised standards

shall not be required to comply with such revised

standards.

(c) State implementation and enforcement of standards

of performance

(1) Each State may develop and submit to the Admin-

istrator a procedure for implementing and enforcing stand-

ards of performance for new sources located in such

State. If the Administrator finds the State procedure is

adequate, he shall delegate to such State any authority he

has under this chapter to implement and enforce such

standards,

(2) Nothing in this subsection shall prohibit the Ad-

ministrator from enforcing any applicable standard of per-

formance under this section.

* cd * *

Excerpt from Section 112 of the Clean Air Act

§ 7412. Hazardous air pollutants

* a a ©

(q) Savings provision

(1) Standards previously promulgated

Any standard under this section in effect before the

date of enactment of the Clean Air Act Amendments

of 1990 [November 15, 1990] shall remain in force

and effect after such date unless modified as provided

in this section before the date of enactment of such

Amendments or under such Amendments. Except as

provided in paragraph (4), any standard under this

42a

section which has been promulgated, but has not

taken effect, before such date shall not be affected

by such Amendments unless modified as provided in

this section before such date or under such Amend-

ments. Each such standard shall be reviewed and, if .

appropriate, revised, to comply with the requirements 4

of subsection (d) of this section within 10 years after i

the date of enactment of the Clean Air Act Amend- F

ments of 1990. If a timely petition for review of any

such standard under section 7607 of this title is pend-

ing on such date of enactment, the standard shall be

upheld if it complies with this section as in effect

before that date. If any such standard is remanded .

2 the Administrator, the Administrator may in the

Administrator’s discretion apply either the require-

ments of this section, or those of this section as in

effect before the date of enactment of the Clean Air

Act Amendments of 1990.

(2) Special rule

Notwithstanding paragraph (1), no standard shall

be established under this section, as amended j

by the Clean Air Act Amendments of 1990, for ’

radionuclide emissions from (A) elemental phospho-

rous plants, (B) grate calcination elemental phos- !

phorous plants, (C) phosphogypsum stacks, or (D)

any subcategory of the foregoing. This section, as in

effect prior to the date of enactment of the Clean Air :

Act Amendments of 1990 [November 15, 1990], ;

shall remain in effect for radionuclide emissions

from such plants and stacks.

(3) Other categories

Notwithstanding paragraph (1), this section as in

effect prior to the date of enactment of the Cican Air

43a

Act Amendments of 1990 [November 15, 1990],

shall remain in effect for radionuclide emissions from

non-Department of Energy Federal facilities that are

not licensed by the Nuclear Regulatory Commission,

coal-fired utility and industrial boilers, underground

uranium mines, surface uranium mines, and disposal

of uranium mill tailings piles, unless the Adminis-

trator, in the Administrator’s discretion. applies the

requirements of this section as modified by the Clean

Air Act Amendments of 1990 to such sources of

radionuclides.

(4) Medical facilities

Notwithstanding paragraph (1), no standard prom-

ulgated under this section prior to November 15,

1990, with respect to medical research or treatment

facilities shall take effect for two years following No-

vember 15, 1990, unless the Administrator makes a

determination pursuant to a rulemaking under sub-

section (d)(9) of this section. If the Administrator

determines that the regulatory program established by

the Nuclear Regulatory Commission for such facilities

does not provide an ample margin of safety to pro-

tect public health, the requirements of this section

shall fully apply to such facilities. If the Administrator

determines that such regulatory program does provide

an ample margin of safety to protect the public

health, the Administrator is not required to promul-

gate a stancard under this section for such facilities,

as provided in subsection (d)(9) of this section.

* 76 * 76

44a

Excerpt from Section 307 of the Clean Air Act

§ 7607. Administrative proceedings and judicial review

* o * %

(b) Judicial review

(1) A petition for review of action of the Adminis-

trator in promulgatingg any national primary or secondary

ambient air quality standard, any emission standard or re-

quirement under section 7412 of this title, any standard

of performance or requirement under section 7411 of this

title, any standard under section 7521 of this title (other

than a standard required to be prescribed under section

7521(b)(1) of this title), any determination under sec-

tion 7521(b)(5) of this title, any control or prohibition

under section 7545 of this title, any standard under sec-

tion 7571 of this title, any rule issued under section 7413,

7419, or under section 7420 of this title, or any other

nationally applicable regulations promulgated, or final ac-

tion taken, by the Administrator under this chapter may

be filed only in the United States Court of Appeals for the

District of Columbia. A petition for review of the Ad-

ministrator’s action in approving or promulgating any im-

plementation plan under section 7410 of this title or sec-

tion 7411(d) of this title, any order under section 7411

(j) of this title, under section 7412 of this title, under

section 7419 of this title, or under section 7420 of this

title, or his action under section 1857c-10(c)(2)(A),

(B), or (C) of this title (as in effect before August 7,

1977) or under regulations thereunder, or revising regu-

lations for enhanced monitoring and compliance certifica-

tion programs under section 7414(a)(3) of this title, or

any other final action of the Administrator under this

chapter (including any denial or disapproval by the Ad-

ministrator under subchapter I of this chapter) which is

locally or regionally applicable may be filed only in the

United States Court of Appeals for the appropriate cir-

cuit. Notwithstanding the preceding sentence a petition

45a

for review of any action referred to in such sentence may

be filed only in the United States Court of Appeals for

the District of Columbia if such action js based on a

determination of nationwide scope or effect and if in tak-

ing such action the Administrator finds and publishes that

such action is based on such a determination. Any peti-

tion for review under this subsection shall be filed within

sixty days from the date notice of such promulgation,

approval, or action appears in the Federal Register, ex-

cept that if such petition is based solely on grounds aris-

ing after such sixtieth day, then any petition for review

under this subsection shall be filed within sixty days after

such grounds arise. The filing of a petition for reconsid-

eration by the Administrator of any otherwise final rule or

action shall not affect the finality of such rule or action

for purposes of judicial review nor extend the time within

which a petition for judicial review of such rule or action

under this section may be filed, and shall not postpone

the effectiveness of such rule or action.

(2) Action of the Administrator with respect to which

review could have been obtained under paragraph (1)

shall not be subject to judicial review in civil or criminal

proceedings for enforcement. Where a final decision by

the Administrator defers performance of any nondiscre-

tionary statutory action to a later time, any person may

challenge the deferral pursuant to paragraph (1).

* bd * *

(d) Rulemaking

(1) This subsection applies to—

(A) the promulgation or revision of any national

ambient air quality standard under section 7409 of

this title,

(B) the promulgation or revision of an implemen-

tation plan by the Administrator under section 7410

(c) of this title,

46a

(C) the promulgation or revision of any standard

of performance under section 7411 of this title, or

emission standard or limitation under section 7412

(d) of this title, any standard under section 7412

(f) of this title, or any regulation under section

7412(g)(1)(D) and (F) of this title, or any regula-

tion under section 7412(m) or (n) of this title,

(D) the promulgation of any requirement for solid

waste combustion under section 7429 of this title,

(E) the promulgation or revision of any regula-

tion pertaining to any fuel or fuel additive under sec-

tion 7545 of this title,

(F) the promulgation or revision of any aircraft

emission standard under section 7571 of this title,

(G) the promulgation or revision of any regula-

tion under subchapter IV-A of this chapter (relating

to control of acid deposition),

(H) promulgation or revision of regulations per-

taining to primary nonferrous smelter orders under

section 7419 of this title (but not including the grant-

ing or denying of any such order),

(I) promulgation or revision of revulations under

subchapter VI of this chapter (relating to strato-

sphere and ozone protection),

(J) promulgation or revision of regulations under

part C of subchapter I of this chapter (relating to

prevention of significant deterioration of air quality

and protection of visibility),

(K) promulgation or revision of regulations under

section 7521 of this title and test procedures for new

motor vehicles on engines under section 7525 of this

title, and the revision of a standard under section

7521(a)(3) of this title,

135 vate oo Awid ney aiilhl d foc

Sr ere ae

47a

(L) promulgation or revision of regulations for

noncompliance penalties under section 7420 of this

title,

(M) promulgation or revision of any regulations

promulgated under section 7541 of this title (relating

to warranties and compliance by vehicles in actual

use),

(N) action of the Administrator under section

7426 of this title (relating to interstate pollution

abatement),

(O) the promulgation or revision of any regula-

tion pertaining to consumer and commercial products

under section 7511b(e) of this title,

(P) the promulgation or revision of any regula-

tion pertaining to field citations under section 7413

(d)¢€3) of this title,

(Q) the promulgation or revision of any regula-

tion pertaining to urban buses or the clean-fuel ve-

hicle, clean-fuel fleet, and clean-fuel programs under

part C of subchapter IT of this chapter,

(R) the promulgation or revision of any regula-

tion pertaiing to nonroad engines or nonroad ve-

hicles under section 7547 of this title,

(S) the promulgation or revision of any regulation

relating to motor vehicle compliance program fees

under section 7552 of this title,

(T) the promulgation or revision of any regula-

tion under subchapter IV-A of this chapter (relating

to acid deposition),

(U) the promulgation or revision of any regula-

tion under section 7511b(f) of this title pertaining

to marine vessels, and

(V) such other actions as the Administrator may

determine.

“48a

The provisions of section 553 through 557 and section

706 of title 5 shall not, except as expressly provided in

this subsection, apply to actions to which this subsection

applies. This subsection shall not apply in the case of any

rule or circumstance referred to in subparagraphs (A) or

(B) of subsection 553(b) of title 5.

(2) Not later than the date of proposal of any action

to which this subsection applies, the Administrator shall

establish a rulemaking docket for such action (hereinafter

in this subsection referred to as a “rule”). Whenever a

rule applies only within a particular State, a second

(identical) docket shall be simultaneously established in

the appropriate regional office of the Environmental Pro-

tection Agency.

(3) In the case of any rule to which this subsection

applies, notice of proposed rulemaking shall be published

in the Federal Register, as provided under section 553(b)

of title 5, shall be accompanied by a statement of its basis

and purpose and shall specify the period available for

public comment (hereinafter referred to as the “comment

period”). The notice of proposed rulemaking shall also

state the docket number, the location or locations of the

docket, and the times it will be open to public inspection.

The statement of basis and purpose shall include a sum-

mary of—

(A) the factual data on which the proposed rule

is based;

(B) the methodology used in obtaining the data

and in analyzing the data; and

(C) the major legal interpretations and policy

considerations underlying the proposed rule.

The statement shall also set forth or summarize and pro-

vide a reference to any pertinent findings, recommenda-

tions, and comments by the Scientific Review Committee

established under section 7409(d) of this title and the

49a

National Academy of Sciences, and, if the proposal differs

in any important respect from any of these recommenda-

tions, an explanation of the reasons for such differences.

All data, information, and documents referred to in this

paragraph on which the proposed rule relies shall be in-

cluded in the docket on the date of publication of the

proposed rule.

(4)(A) The rulemaking docket required under para-

graph (2) shall be open for inspection by the public at

reasonable times specified in the notice of proposed rule-

making. Any person may copy documents contained in

the docket. The Administrator shall provide copying fa-

cilities which may be used at the expense of the person

seeking copies, but the Administrator may waive or reduce

such expenses in such instances as the public interest re-

quires. Any person may request copies by mail if the

person pays the expenses, including personnel costs to

do the copying.

(B)(i) Promptly upon receipt by the agency, all writ-

ten comments and documentary information on the pro-

posed rule received from any person for inclusion in the

docket during the comment period shall be placed in the

docket. The transcript of public hearings, if any, on the

proposed rule shall also be included in the docket

promptly upon receipt from the person who transcribed

such hearings. All documents which become available

after the proposed rule has been published and which the

Administrator determines are of central relevance to the

rulemaking shall be placed in the docket as soon as pos-

sible after their availability.

(ii) The drafts of proposed rules submitted by the Ad-

ministrator to the Office of Management and Budget for

any interagency review process prior to proposal of any

such rule, all documents accompanying such drafts, and

all written comments thereon by other agencies and all

written responses to such written comments by the Admin-

50a

istrator shall be placed in the docket no later than the

date of proposal of the rule. The drafts of the final rule

submitted for such review process prior to promulgation

and all such written comments thereon, all documents ac-

companying such drafts, and written responses thereto

shall be placed in the docket no later than the date of

promulgation.

(5) In promulgating a rule to which this subsection

applies (i) the Administrator shall allow any person to

submit written comments, data, or documentary informa-

tion; (ii) the Administrator shall give interested persons

an opportunity for the oral presentation of data, views, or

arguments, in addition to an opportunity to make written

submissions; (iii) a transcript shall be kept to any oral

presentation; and (iv) the Administrator shall keep the

record of such proceeding open for thirty days after com-

pletion of the proceeding to provide an opportunity for

submission of rebuttal and supplementary information.

(6)(A) The promulgated rule shall be accompanied

by (i) a statement of basis and purpose like that referred

to in paragraph (3) with respect to a proposed rule and

(ii) an explanation of the reasons for any major changes

in the promulgated rule from the proposed rule.

(B) The promulgated rule shall also be accompanied

by a response to each of the significant comments, criti-

cisms, and new data submitted in written or oral presen-

tations during the comment period.

(C) The promulgated rule may not be based (in part

or whole) on any information or data which has not been

placed in the docket as of the date of such promulgation.

(7)(A) The record for judicial review shall consist

exclusively of the material referred to in paragraph (3),

clause (i) of paragraph (4)(B), and subparagraphs (A)

and (B) of paragraph (6).

ee Ra Ate iit Sit

S5la

(B) Only an objection to a rule or procedure which

was raised with reasonable specificity during the period

for public comment (including any public hearing) may

be raised during judicial review. If the person raising an

objection can demonstrate to the Administrator that it

was impracticable to raise such objection within such time

or if the grounds for such objection arose after the period

for public comment (but within the time specified for

judicial review) and if such objection is of central rele-

vance to the outcome of the rule, the Administrator shall

convene a proceeding for reconsideration of the rule and

provide the same procedural rights as would have been

afforded had the information been available at the time

the rule was proposed. If the Administrator refuses to

convene such a proceeding, such person may seek review

of such refusal in the United States court of appeals for

the appropriate circuit (as provided in subsection (b) of

this section). Such reconsideration shall not postpone the

effectiveness of the rule. The effectiveness of the rule may

be stayed during such reconsideration, however, by the

Administrator or the court for a period not to exceed

three months.

(8) The sole forum for challenging procedural deter-

minations made by the Administrator under this subsec-

tion shall be in the United States court of appeals for the

appropriate circuit (as provided in subsection (b) of this

section) at the time of the substantive review of the rule.

No interlocutory appeals shall be permitted with respect

to such procedural determinations. In reviewing alleged

procedural errors, the court may invalidate the rule only

if the errors were so serious and related to matters of

such central relevance to the rule that there is a substan-

tial likelihood that the rule would have been significantly

changed if such errors had not been made.

(9) In the case of review of any action of the Admin-

istrator to which this subsection applies, the court may

reverse any such action found to be—

52a

(A) arbitrary, capricious, an abuse of discretion,

or otherwise not in accordance with law;

(B) contrary to constitutional right, power, priv-

ilege, or immunity;

(C) in excess of statutory jurisdiction, authority,

or limitations, or short of statutory right; or

(D) without observance of procedure required by

law, if (i) such failure to observe such procedure is

arbitrary or capricious, (ii) the requirement of para-

graph (7)(B) has been met, and (iii) the condition

of the last sentence of paragraph (8) is met.

(10) Each statutory deadline for promulgation of rules

to which this subsection applies which requires promulga-

tion less than six months after date of proposal may be

extended to not more than six months after date of pro-

posal by the Administrator upon a determination that

such extension is necessary to afford the public, and the

agency, adequate opportunity to carry out the purposes

of this subsection.

(11) The requirements of this subsection shall take

effect with respect to any rule the proposal of which oc-

curs after ninety days after August 7, 1977.

(e) Other methods of judicial review not authorized

Nothing in this chapter shall be construed to authorize

judicial review of regulations or orders of the Adminis-

trator under this chapter, except as provided in this

section.

Nitty “acon ia

Heiss facies

53a

APPENDIX G

Select Regulatory Provisions From

40 C.F.R. Parts 51, 52, 60 and 61

Excerpt from 40 C.F.R. Part 51 (1997)

§ 51.212 Testing, inspection, enforcement, and com-

plaints.

The plan must provide for—

(a) Periodic testing and inspection of stationary

sources; and

(b) Establishment of a system for detecting violations

of any rules and regulations through the enforcement of

appropriate visible emission limitations and for investigat-

ing complaints.

(c) Enforceable test methods for each emission limit

specified in the plan. For the purpose of submitting com-

pliance certifications or establishing whether or not a per-

son has violated or is in violation of any standard in this

part, the plan must not preclude the use, including the

exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compli-

ance with applicable requirements if the appropriate per-

formance or compliance test or procedure had been per-

formed. As an enforceable method, States may use:

(1) Any of the appropriate methods in appendix M tc

this part, Recommended Test Methods for State Imple-

mentation Plans; or

(2) An alternative method following review and ap-

proval of that method by the Administrator; or

(3) Any appropriate method in appendix A to 40

CFR part 60.

[51 FR 40673, Nov. 7, 1986, as amended at 55 FR

14249, Apr. 17, 1990; 62 FR 8328, Feb. 24, 1997]

54a

Excerpt from 40 C.F.R. Part 52 (1997)

§ 52.12 Source surveillance

(a) Each subpart identifies the plan provisions for

source surveillance which are disapproved, and sets forth

the Administrator’s promulgation of necessary provisions

for requiring sources to maintain records, make reports,

and submit information.

(b) No provisions are promulgated for any disap-

proved State or local agency procedures for testing, in-

spection, investigation, or detection, but detailed critiques

of such portions are provided to the State.

(c)For purposes of Federal enforcement, the following

test procedures and methods shall be used, provided that

for the purpose of establishing whether or not a person

has violated or is in violation of any provision of the

plan, nothing in this part shall preclude the use, includ-

ing the exclusive use, of any credible evidence or infor-

mation, relevant to whether a source would have been in

compliance with applicable requirements if the appropriate

performance or compliance test procedures or methods

had been performed:

(1) Sources subject to plan provisions which do not

specify a test procedure and sources subject to provisions

promulgated by the Administrator will be tested by means

of the appropriate procedures and methods prescribed in

part 60 of this chapter unless otherwise specified in this

part.

(2) Sources subject to approved provisions of a plan

wherein a test procedure is specified will be tested by the

specified procedure.

[37 FR 10846, May 31, 1972, as amended at 40 FR

26032, June 20, 1975; 62 FR 8328, Feb. 24, 1997]

eenmsaiiit reece pan cer cares eoee

My CBP be A ae CE in RECENT A OR ig BSE EW orl TAB ERP A Git tifa tinal ig tL Sa aia

55a

§ 52.33 Compliance certifications.

(a) For the purpose of submitting compliance certifica-

tions, nothing in this part or in a plan promulgated by the

Administrator shall preclude the use, including the exclu-

sive use, of any credible evidence or information, relevant

to whether a source would have been in compliance with

applicable requirements if the appropriate performance or

compliance test had been performed.

(b) For all federal implementation plans, paragraph

(a) of this section is incorporated into the plan.

[62 FR 8328, Feb. 24, 1997]

Excerpt from 40 C.F.R. Part 60 (pre-“Credible

Evidence” Rule)

$ 60.11 Compliance with standards and maintenance re-

quirements,

(a) Compliance with standards in this part, other than

opacity standards, shall be determined only by perform-

ance tests established by § 60.8, unless otherwise specified

in the applicable standard.

(b) Compliance with opacity standards in this part

shall be determined by conducting observations in accord-

ance with Reference Method 9 in appendix A of this part,

any alternative method that is approved by the Adminis-

trator, or as provided in paragraph (e)(5) of this section.

For purposes of determining initial compliance, the mini-

mum total time of observations shall be 3 hours (30 6-

minute averages) for the performance test or other set of

observations (meaning those fugitive-type emission sources

subject only to an opacity standard).

(c) The opacity standards set forth in this part shall

apply at all times except during periods of startup, shut-

down, malfunction, and as otherwise provided in the ap-

plicable standard.

56a

(d) At all times, including periods of startup, shut-

down, and malfunction, owners and operators shall, to the

extent practicable, maintain and operate any affected

facility including associated air pollution control equip-

ment in a manner consistent with good air pollution con-

trol practice for minimizing emissions. Determination of

whether acceptable operating and maintenance procedures

are being used will be based on information available to

the Administrator which may include, but is not limited

to, monitoring results, opacity observations, review of oper-

ating and maintenance procedures, and inspection of the

source.

(e)(1) For the purpose of demonstrating initial com-

pliance, capacity observations shall be conducted concur-

rently with the initial performance test required in § 60.8

unless one of the following conditions apply. If no per-

formance test under § 60.8 is required, then opacity

observations shall be conducted within 60 days after

achieving the maximum production rate at which the af-

fected facility will be operated but no later than 180 days

after initial startup of the facility. If visibility or other

conditions prevent the opacity observations from being

conducted concurrently with the initial performance test

required under § 60.8, the source owner or operator shall

reschedule the opacity observations as soon after the ini-

tial performance test as possible, but not later than 30

days thereafter, and shall advise the Administrator of the

rescheduled date. In these cases, the 30-day prior noti-

fication to the Administrator required in § 60.7(a)(6)

shall be waived. The rescheduled opacity observations

shall be conducted (to the extent posible) under the same

operating conditions that existed during the initial per-

formance test conducted under § 60.8. The visible emis-

sions observer shall determine whether visibility or other

conditions prevent the opacity observations from being

made concurrently with the initial performance test in ac-

cordance with procedures contained in Reference Method

9 of appendix B of this part. Opacity readings of portions

Saar RS Mt eae Eh Setaic nee ORT EI ND

i

$

4

4

¥

3

57a

of plumes which contain condensed, uncombined water

vapor shall not be used for purposes of determining com-

pliance with opacity standards. The owner or operator of |

an affected facility shall make available, upon request by

the Administrator, such records as may be necessary to

determine the conditions under which the visual observa-

tions were made and shall provide evidence indicating

proof of current visible observer emission certification.

Except as provided in paragraph (e)(5) of this section,

the results of continuous monitoring by transmissometer

which indicate that the opacity at the time visual observa-

tions were made was not in excess of the standard are

probative but not conclusive evidence of the actual opacity

of an emision, provided that the source shall meet the bur-

den of proving that the instrument used meets (at the

time of the alleged violation) Performance Specification 1

in appendix B of this part, has been properly maintained

and (at the time of the alleged violation) that the result-

ing data have not been altered in any way.

(2) Except as provided in paragraph (e)(3) of this

section, the owner or operator of an affected facility to

which an opacity standard in this part applies shall con-

duct opacity observations in accordance with paragraph

(6) of this section, shall record the opacity of emissions,

and shall report to the Administrator the opacity results

along with the results of the initial performance test re-

quired under § 60.8. The inability of an owner or opera-

tor to secure a visible emissions observer shall not be con-

sidered a reason for not conducting the opacity observa-

tions concurrent with the initial performance test.

(3) The owner or operator of an affected facility to

which an opacity standard in this part applies may request

the Administrator to determine and to record the opacity

of emissions from the affected facility during the initial

performance test and at such times as may be required.

The owner or operator of the affected facility shall report

the opacity results. Any request to the Administrator to

determine and to record the opacity of emissions from

58a

an affected facility shall be included in the notification re-

quired in § 60.7(a)(6). If, for some reason, the Admin-

istrator cannot determine and record the opacity of emis-

sions from the affected facility during the performance

test, then the provisions of paragraph (e)(1) of this

section shall apply.

(4) An owner or operator of an affected facility using

a continuous opacity monitor (transmissometer) shall re-

cotd the monitoring data produced during the initial per-

formance test required by § 60.8 and shall furnish the

Administrator a written report of the monitoring results

along with Method 9 and § 60.8 performance test results.

(5) An owner or operator of an affected facility sub-

ject to an opacity standard may submit, for compliance

purposes, continuous opacity monitoring system (COMS)

data results produced during any performance test re-

quired under § 60.8 in lieu of Method 9 observation data.

If an owner or operator elects to submit COMS data for

compliance with the opacity standard, he shall notify the

Administrator of that decision, in writing, at least 30 days

before any performance test required under § 60.8 is con-

ducted. Once the owner or operator of an affected facility

has notified the Administrator to that effect, the COMS

data results will be used to determine opacity compliance

during subsequent tests required under § 60.8 until the

owner or operator notifies the Administrator, in writing,

to the contrary. For the purpose of determining compli-

ance with the opacity standard during a performance test

required under § 60.8 using COMS data,the minimum

total time of COMS data collection shall be averages of

all 6-minute continuous periods within the duration of the

mass emission performance test. Results of the COMS

opacity determinations shall be submitted along with the

results of the performance test required under § 60.8.

The owner or operator of an affected facility using a

COMS for compliance purposes is responsible for dem-

Onstrating that the COMS meets the requirements speci-

fied in § 60.13(c) of this part, that the COMS has been

i a a al

Sido Ob A cha Cat Ms sia < ON Ooi hii at

s

bd

59a

properly maintained and operated, and that the resulting

data have not been altered in any way. If COMS data

results are submitted for compliance with the opacity

standard for a period of time during which Method 9

data indicates noncompliance, the Method 9 data will be

used to determine opacity compliance.

(6) Upon receipt from an owner or operator of the

written reports of the results of the performance tests re-

quired by § 60.8, the opacity observation results and ob-

server certification required by § 60.11(e)(1), and the

COMS results, if applicable, the Administrator will make

a finding concerning compliance with opacity and other

applicable standards. If COMS data results are used to

comply with an opacity standard, only those results are

required to be submitted along with the performance test

results required by § 60.8. If the Administrator finds that

an affected facility is in compliance with all applicable

standards for which performance tests are conducted in

accordance with § 60.8 of this part but during the time

such performance tests are being conducted fails to meet

any applicable opacity standard, he shall notify the owner

or operator and advise him that he may petition the Ad-

ministrator within 10 days of receipt of notification to

make appropriate adjustment to the opacity standard for

the affected facility.

(7) The Administrator will grant such a petition upon

a demonstration by the owner or operator that the af-

fected facility and associated air pollution control equip-

ment was operated and maintained in a manner to mini-

mize the opacity of emisions during the performance tests;

that the performance tests were performed under the condi-

tions established by the Administrator; and that the af-

fected facility and associated air pollution control equip-

ment were incapable of being adjusted or operated to meet

the applicable opacity standard.

(8) The Administrator will establish an opacity stand-

ard for the affected facility meeting the above require-

ments at a level at which the source will be able, as indi-

60a

cated by the performance and opacity tests, to meet the

opacity standard at all times during which the source is

meeting the mass or concentration emission standard. The

Administrator will promulgate the new opacity standard

in the FEDERAL REGISTER.

(f) Special provisions set forth under an applicable

subpart of this part shall supersede any conflicting provi-

sions of this section.

[38 FR 28565, Oct. 15, 1973, as amended at 39 FR

39873, Nov. 12, 1974; 43 FR 8800, Mar. 3, 1978; 45

FR 23379, Apr. 4, 1980; 48 FR 48335, Oct. 18, 1983;

50 FR 53113, Dec. 17, 1985; 51 FR 1790, Jan. 15,

1986; 52 FR 9781, Mar. 26, 1987]

Excerpt from 40 C.F.R. Part 60 (1997)

§ 60.11 Compliance with standards and maintenance re-

quirements.

(a) Compliance with standards in this part, other than

opacity standards, shall be determined in accordance with

performance tests established by § 60.8, unless otherwise

specified in the applicable standard.

(b) Compliance with opacity standards in this part

shall be determined by conducting observations in accord-

ance with Reference Method 9 in appendix A of this part,

any alternative method that is approved by the Admin-

istrator, or as provided in paragraph (e)(5) of this sec-

tion. For purposes of determining initial compliance, the

minimum total time of observations shall be 3 hours (30

6-minute averages) for the performance test or other set

of observations (meaning those fugitive-type emission

sources subject only to an opacity standard).

(c) The opacity standards set forth in this part shall

apply at all times except during periods of startup, shut-

down, malfunction, and as otherwise provided in the ap-

plicable standard.

a ac aa aiid a at

6la

(d) At all times, including periods of startup, shut-

down, and malfunction, owners and operators shall, to the

extent practicable, maintain and operate any affected fa-

cility including associated air pollution control equipment

in a manner consistent with good air pollution control

practice for minimizing emissions. Determination of

whether acceptable operating and maintenance procedures

are being used will be based on information available to

the Administrator which may include, but is not limited

to, monitoring results, opacity observations, review of

operating and maintenance procedures, and inspection of

the source.

(e€)(1) For the purpose of demonstrating initial com-

pliance, opacity observations shall be conducted concur-

rently with the initial performance test required in § 60.8

unless one of the following conditions apply. If no per-

formance test under § 60.8 is required, then opacity ob-

servations shall be conducted within 60 days after achiev-

ing the maximum production rate at which the affected

facility will be operated but no later than 180 days after

initial startup of the facility. If visibility or other condi-

tions prevent the opacity observations from being con-

ducted concurrently with the initial performance test re-

quired under § 60.8, the source owner or operator shall

reschedule the opacity observations as soon after the ini-

tial performance test as possible, but not later than 30

days thereafter, and shall advise the Administrator of the

rescheduled date. In these cases, the 30-day prior notifica-

tion to the Administrator required in § 60.7(a)(6) shall

be waived. The rescheduled opacity observations shall be

conducted (to the extent possible) under the same operat-

ing conditions that existed during the initial performance

test conducted under § 60.8. The visible emissions ob-

server shall determine whether visibility or other condi-

tions prevent the opacity observations from being made

concurrently with the initial performance test in accord-

ance with procedures contained in Reference Method 9

of appendix B of this part. Opacity readings of portions

62a

of plumes which contain condensed, uncombined water

vapor shall not be used for purposes of determining com-

pliance with opacity standards. The owner or operator of

an affected facility shall make available, upon request by

the Adminstrator, such records as may be necessary to

determine the conditions under which the visual observa-

tioris were made and shall provide evidence indicating

proof of current visible observer emission certification.

Except as provided in paragraph (e)(5) of this section,

the results of continuous monitoring by transmissometer

which indicate that the opacity at the time visual observa-

tions were made was not in excess of the standard are

probative but not conclusive evidence of the actual opacity

of an emission, provided that the source shall meet the

burden of proving that the instrument used meets (at the

time of the alleged violation) Performance Specification 1

in appendix B of thls part, has been properly maintained

and (at the time of the alleged violation) that the result-

ing data have not been altered in any way.

(2) Except as provided in paragraph (e)(3) of this

section, the owner Or operator of an affected facility to

which an opacity standard in this part applies shall con-

duct opacity observations in accordance with paragraph

(b) of this section, shall record the opacity of emissions,

and shall report to the Administrator the opacity results

along with the results of the initial performance test re-

quired under § 60.8. The inability of an owner or opera-

tor to secure a visible emissions observer shall not be con-

sidered a reason for not conducting the opacity observa-

tions concurrent with the initial performance test.

(3) The owner or operator of an affected facility to

which an opacity standard in this part applies may request

the Administrator to determine and to record the opacity

of emissions from the affected facility during the initial

performance test and at such times as may be required.

The owner or operator of the affected facility shall report

the opacity results. Any request to the Administrator to

63a

determine and to record the opacity of emissions from an

affected facility shall be included in the notification re-

quired in § 60.7(a)(6). If, for some reason, the Admin-

istrator cannot determine and record the opacity of emis-

sions from the affected facility during the performance

test, then the provisions of paragraph (e)(1) of this sec-

tion shall apply.

(4) An owner or operator of an affected facility using

a continuous opacity monitor (transmissometer) shall

record the monitoring data produced during the initial

performance test required by § 60.8 and shall furnish the

Administrator a written report of the monitoring results

along with Method 9 and § 60.8 performance test results.

(5) An owner or operator of an affected facility sub-

ject to an opacity standard may submit, for compliance

purposes, continuous opacity monitoring system (COMS)

data results produced during any performance test re-

quired under § 60.8 in lieu of Method 9 observation data.

If an owner or operator elects to submit COMS data for

compliance with the opacity standard. he shall notify the

Administrator of that decision, in writing, at least 30 days

before any performance test required under § 60.8 is con-

ducted. Once the owner or operator of an affected facility

has notified the Administrator to that effect. the COMs

data results will be used to determine opacity compliance

during subsequent tests required under §$ 60.8 until the

Owner or operator notifies the Administrator. in writing,

to the contrary. For the purpose of determining com-

pliance with the opacity standard during a performance

test required under § 60.8 using COMS data, the mini-

mum total time of COMS data collection shall be aver-

ages of all 6-minute continuous periods within the dura-

tion of the mass emission performance test. Results of

the COMs opacity determinations shall be submitted along

with the results of the performance test required under

§ 60.8. The owner or operator of an affected facility

using a COMS for compliance purposes is responsible for

64a

demonstrating that the COMS meets the requirements

specified in § 60.13(c) of this part, that the COMS has

been properly maintained and operated, and that the re-

sulting data have not been altered in any way. If COMS

data results are submitted for compliance with the opacity

standard for a period of time during which Method 9

data indicates non-compliance, the Method 9 data will be

used to determine opacity compliance.

(6) Upon receipt from an owner or operator of the

written reports of the results of the performance tests re-

quired by § 60.8, the opacity observation results and ob-

server certification required by § 60.11(e)(1), and the

COMS results, if applicable, the Administrator will make

a finding concerning compliance with opacity and other

applicable standards. If COMS data results are used to

comply with an opacity standard, only those results are

required to be submitted along with the performance test

results required by § 60.8. If the Administrator finds that

an affected facility is in compliance with all applicable

standards for which performance tests are conducted in

accordance with § 60.8 of this part but during the time

such performance tests are being conducted fails to meet

any applicable opacity standard, he shall notify the owner

or operator and advise him that he may petition the Ad-

ministrator within 10 days of receipt of notification to

make appropriate adjustment to the opacity standard for

the affected facility.

(7) The Administrator will grant such a petition upon

a demonstration by the owner or operator that the affected

facility and associated air pollution control equipment was

operated and maintained in a manner to minimize the

opacity of emissions during the performance tests: that

the performance tests were performed under the conditions

established by the Administrator; and that the affected

facility and associated air pollution control equipment

were incapable of being adjusted or operated to meet the

applicable opacity standard.

IN ECL LAS OIE INA G8 Te HI

engi k hs

agi at x . 4 “elds, OES he Rie Pak fs Sle

ae i lee JE ig Sa etki Sues kD) ENE ARTA Ries

Ee aes

65a

(8) The Administrator will establish an opacity stand-

ard for the affected facility meeting the above require-

ments at a level at which the source will be able, as indi-

cated by the performance and opacity tests, to meet the

opacity standard at all times during which the source is

meeting the mass or concentration emission standard. The

Administrtaor will promulgate the new opacity standard

in the FEDERAL REGISTER.

(f) Special provisions set forth under an applicable

subpart shall supersede any conflicting provisions in para-

graphs (a) through (e) of this section.

(g) For the purpose of submitting compliance certifica-

tions or establishing whether or not a person has violated

or is in violation of any standard in this part, nothing in

this part shall preclude the use, including the exclusive

use, of any credible evidence or information, relevant to

whether a source would have been in compliance with

applicable requirements if the appropriate performance or

compliance test or procedure had been performed.

{38 FR 28565, Oct. 15, 1973, as amended at 39 FR

39873, Nov. 12, 1974; 43 FR 8800, Mar. 3, 1978: 45

FR 23379, Apr. 4, 1980; 48 FR 48335, Oct. 18, 1983:

50 FR 53113, Dec. 27, 1985; 51 FR 1790, Jan. 15,

1986; 52 FR 9781, Mar. 26, 1987; 62 FR 8328, Feb. 24,

1997]

Excerpt from 40 C.F.R. Part 61 (1997)

§ 61.12 Compliance with standards and maintenance re-

quirements.

(a) Compliance with numerical emission limits shall

be determined in accordance with emission tests estab-

lished in § 61.13 or as otherwise specified in an individual

subpart.

(b) Compliance with design, equipment, work practice

or operational standards shall be determined as specified

in an individual subpart.

66a

(c) The owner or operator of each stationary source

shall maintain and operate the source, including asso-

ciated equipment for air pollution control, in a manner

consistent with good air pollution control practice for

minimizing emissions. Determination of whether accept-

able operating and maintenance procedures are being used

will be based on information available to the Administra-

tor which may include, but is not limited to, monitoring

results, review of operating and maintenance procedures,

and inspection of the source.

(d)(1) If, in the Administrator’s judgment, an alterna-

tive means of emission limitation will achieve a reduction

in emissions of a polluant from a source at least equiv-

alent to the reduction in emissions of that pollutant from

that source achieved under any design, equipment, work

practice or operational standard, the Administrator will

publish in the FEDERAL REGISTER a notice permitting the

use of the alternative means for purposes of compliance

with the standard. The notice will restrict the permission

to the source(s) or category(ies) of sources on which the

alternative means will achieve equivalent emission reduc-

tions. The notice may condition permission on require-

ments related to the operation and maintenance of the

alternative means.

(2) Any notice under paragraph (d)(1) shall be pub-

lished only after notice and an opportunity for a hearing.

(3) Any person seeking permission under this subsec-

tion shall, unless otherwise specified in the applicable sub-

part, submit a proposed test plan or the results of testing

and monitoring, a description of the procedures followed

in testing or monitoring, and a description of pertinent

conditions during testing or monitoring.

(e) For the purpose of submitting compliance certifica-

tions or establishing whether or not a person has violated

or is in violation of any standard in this part, nothing in

this part shall preclude the use, including the exclusive

aaa cc a

sb ——

67a

use, of any credible evidence or information, relevant to

whether a source would have been in compliance with

applicable requirements if the appropriate performance or

compliance test had been performed.

[50 FR 46292, Nov. 7, 1985, as amended 62 FR 8328,

Feb. 24, 1997]

68a

APPENDIX H

Excerpt from S. Rep. No. 91-1196

SECTION 308. JUDICIAL REVIEW

One of the uncertainties in the existing Clean Air Act

is the availability or opportunity for judicial review of

administratively developed and promulgated standards and

regulations. Moreover, the effect on the general program

of a review itself is not clear.

Administratively developed standards, rules and regula-

tions under the Act and under this bill would clearly affect

the interests of persons. The courts are increasingly adapt-

ing this test to what administrative actions are reviewable.

In several recent cases [Environmental Defense Fund, Inc.

Vv. Hardin (C.A. No. 23,813, May 28, 1970); Barlow v.

Collins (397 U.S. 159, 167 (1970)); Abbott Labora-

tories Vv. Gardner (387 U.S. 136, 140-41 (1967))] the

Courts have held that even in matters committed by statute

to administrative discretion, preclusion of judicial review

“is not lightly to be inferred . . . it requires a showing of

clear evidence of legislative intent.” (E.D.F. v. Hardin,

supra, p. 7.) The Courts have granted this review to those

being regulated and to those who seek “to protect the

public interest in the proper administration of a regulatory

system enacted for their benefit.” (E.D.F. v. Hardin supra,

p. 6.) Since precluding review does not appear to be war-

ranted or desirable, the bill would specifically provide for

such review within controlled time periods. Of course, the

person regulated would not be precluded from seeking such

review at the time of enforcement insofar as the subject

matter applies to him alone.

Because many of these administrative actions are na-

tional in scope and require even and consistent national

application, the provision specifies that any review of such

actions shall be in the United States Court fo Appeals for

the District of Columbia. For review of the approval or

promulgation of implementation plans which run only to

one air quality control region, the section places jurisdic-

69a

tion in the U.S. Court of Appeals for the Circuit in which

the affected air quality control region, or portion thereof,

is located.

In order to maintain the integrity of the time sequences

provided throughout the Act, the bill would provide that

any review sought must be filed within 30 days of the date

of the challenged promulgation or approval. It would be

further provided that the filing of a petition does not

operate as a stay of the application of the promulgation

or decision for which review is sought, unless the party

seeking such review is able to demonstrate to the court

that there is a substantial likelihood that such party will

prevail on the-merits and that the interests of the public

will not be harmed by such stay. It should be noted that

the provision restricting stays would apply not only to

actions brought pursuant to this section, but also to any

review of an administrative action pursuant to this Act or

under any provision of law.

In this section, and in two other provisions of the bill,

section 115 and section 202(b)(4) the Committee directs

any court reviewing any administrative promulgation or

decision to presume that the findings of the Administrator

related to the matter subject to review are correct. In

adopting this position offered by Senator Baker, the Com-

mittee proposes to clarify for purposes of this Act the

value, or weight, given to administrative findings and de-

cisions by the reviewing court.

The Committee does not intend by this language to

provide a statutory provision that establishes administra-

tive promulgations or decisions as conclusive and thereby

effectively extinguishing the right of review. Rather, the

presumption of correctness established is rebuttable by

proof that the administrative promulgation or decision is

not supported by a prepondarence of its evidence. It

should also be noted that evidence regarding any exclusion

Or Omission of relevant material from the administrative

70a

record may be adduced to challenge the sufficiency of the

administrative record.

The committee recognizes that it would not be in the

public interest to measure for all time the adequacy of a pro-

mulgation of any standard or regulation by the information

available at the time of such promulgation. In the area

of protection of public health and environmental quality,

it is clear that new information will be developed and that

such information may dictate a revision or modification of

any promulgated standard or regulation established under

the act. The judicial review section, therefore, provides

that any person may challenge any promulgated standard,

regulation, or approved or promulgated implementation

plan after the date of promulgation whenever it is alleged

that significant new information has become available.

New information may become available at some future

date which indicates that a particular pollution agent or

combination of agents is hazardous to the health of persons

and therefore should be added to those pollution agents

subject to the provisions of section 115. Conversely, new

information may become available indicating that a pollu-

tion agent for which a prohibition had been established

under section 115 is not hazardous to the health of per-

sons. If the Secretary failed to act in either event, the

promulgation could be challenged.

Excerpt from H.R. Rep. No. 95-294

SECTION 305—ADMINISTRATIVE PROCEDURES

AND JUDICIAL REVIEW

BACKGROUND

Under the 1970 Clean Air Act Amendments, the Ad-

ministrator was directed to promulgate rules and regula-

tions under informal rulemaking procedures. These pro-

cedures call for notice of the proposed rule, opportunity

to submit written comments, public hearing (when required

expressly by the act), and final promulgation of the rule.

Tla

The formal adjudicatory-type procedures of 5 U.S.C. 554,

556, and 557 were not required to be involved in the rule-

making process under the act. For some actions of the

Administrator (e.g., State implementation plan approval),

no procedural requirements were specified in the act.

In some ways the informal rulemaking approach has

worked well. The administrative process has been quicker

and more flexible than if more elaborate procedures had

been required. But in several respects, the informal rule-

making procedures of the current act have been challenged

as inadequate.

First, the existing Clean Air Act does not require the

establishment of a clearly defined record on which agency

consideration of a rule, public comments, and judicial

review can be based. Thus, for instance, in Texas v. EPA,

499 F. 2d 289 (Sth Cir. 1974), both the majority and

| the concurring opinions expressed dissatisfaction with the

state of the record. Other courts have voiced similar

concerns.

Second, concern was expressed about the absence of a

requirement for a public hearing prior to approval or dis-

approval of the State implementation plan by the Ad-

ministrator.®

Third, the legislative-type hearings provided for in the

current act have been challenged as not providing an ade-

quate opportunity to challenge the factual basis under-

lying the proposed rule. Thus, for instance, Representative

Van Deerlin introduced and testified in favor of H.R. 2765,

a bill introduced in 1975 which provided in part that “no

element of an implementation plan . . . could be approved

(if submitted by a State) or promulgated by the Agency,

unless a hearing has been held at the State or Federal level

where a record was kept and where participants were

given the opportunity to examine agency officials”. (H.

968).

ee

51973 Hearings, op. cit., pp. 813-828.

el

72a

A fourth alleged procedural shortcoming of the existing

act is its failure to require the Administrator of EPA to

state clearly the reasons for his action. This criticism was

implicit in the Court’s decision in Kennecott Copper Corp.

v. EPA, 462 F. 2d 846 (D.C. Cir. 1972). It was explicit

in the 1973 testimony from the Director of the Texas Air

Control Board:

When EPA disapproved the hydrocarbon control

strategy portion of the Texas implementation plan, it

was some time before the State could obtain any

indication of the reasons for the disapproval. Formal

findings of fact and supportive data for the dis-

approval have still not been received by the State.®

Fifth, the Clean Air Act was arguably deficient in fail-

ing to establish an express standard of review for the

courts to apply in judicial review of Agency rulemaking.

While the committee did not agree to some of the pro-

posed solutions to these problems, it did agree that they

needed to be remedied. For in the committee’s view,

appropriately broad administrative discretion to promul-

gate regulations to protect health or the environment must

be restrained by thorough and careful procedural safe-

guards that insure an effective opportunity for public par-

ticipation in the rulemaking process.

The committee was also concerned about inconsistencies

in procedures, policies, practices, and legal interpretations

in EPA’s regional offices. These problems are highlighted

by the factual situation which is detailed in Montana Power

Company v. EPA, CV-76-136-BLG (D. Mont. 1977).

While the committee’s action on the section 108 definition

of “commenced construction” makes clear its disagreement

with the interpretation of the judge in that case, the case

does raise important, broader issues relating to regionali-

zation, which the committee believed should be addressed.

6 1973 Hearing, op. cit., p. 814; see also p. 828,

73a

COMMITTEE PROPOSAL

Section 305 of the committee bill establishes a new

subsection 307(d) of the act. This provision of the com-

mittee bill attempts to cure each of the problems which

have been identified under the current act’s approach to

rulemaking. At the same time, the committee bill is in-

tended to retain the flexibility and expedition of the in-

formal rulemaking approach. It is not intended to require

formal rulemaking proceedings under the Clean Air Act.

The Record.—Section 305 of the bill clearly defines

what the record for a rule consists of, and how and when

material must be placed in the record. By and large, this

section represents a legislative adoption of the suggestions

for a rulemaking record set forth in a law review article

dealing with EPA. (Pederson, “Formal Records and In-

formal Rulemaking,” 85 Yale L.J. 38 (1975).)

Several points about this reform should be emphasized.

First, the new record system cannot be expected to yield

its full benefits unless EPA establishes a record room in

which to keep the records, and adequate staff and other

resources to keep the records in order. The committee

expects this to be done. |

Second, the record system will not result in better

records unless all those participating in the rulemaking

process keep in mind the objective of creating a useful

record. This means the agency should include in the

record only those documents in its possession which are of

genuine material relevance to the rule. Of course, the

agency has at least as great an obligation to include any

such documents that contradict its position as it does to

include those that support it.

These central documents should where necessary cite or

summarize, and place in perspective, less relevant docu-

ments on which they in turn rely.

Other participants should make their points clearly and

concisely, and not submit for inclusion in the record ma-

74a

terial of only marginal relevance, or that could have been

submitted in more abbreviated form.

Third, though the committee is not requiring the adop-

tion of a formal discovery system for use in rulemaking,

it realizes that the current use of the Freedom of Informa-

tion Act for this purpose will undoubtedly continue.

Accordingly, it expects EPA to take any necessary ad-

ministrative steps to ensure that its procedures for dealing

with such requests are coordinated with the record making

system established by this legislation.

Hearings.—Section 305 of the bill expands the require-

ments relating to public hearings to apply to specified

actions of the Administrator which are not now subject

to the hearing requirement.

In specific, under new section 307(d)(5) of the act,

the Agency would be required to afford opportunity for a

public hearing with respect to specified actions where no

such opportunity is currently required to be afforded.

In regard to this provision as well as the rest of section

305, the committee intends that these procedures be re-

quired to be applied only prospectively. Thus, any rule-

making proceeding which commenced prior to date of

enactment of the 1977 amendments would not be required

to follow such procedures, nor would it be subject to

attack in judicial review for failure to follow such proce-

dures. Furthermore, the committee does not intend to

change the established rule that even where opportunity

for a hearing is required by statute that hearing may be

omitted if .t is clear no useful purpose would be served.

Weinberger v. Hynson, Westcott & Dunning, Inc., 412

U.S. 609, 620-22 (1973); United States v. Storer Broad-

casting Co., 351 U.S. 192, 205 (1956).

Hearing procedures.—In general, the committee has di-

rected the Administrator to permit opportunity for cross-

examination in the course of any such hearing. There are

several limits on this obligation to permit cross-examina-

Ea er aie Oe eee a Ne

—————$—$—————————

75a

tion, however,. First, the opportunity for cross-examina-

tion need only be afforded with respect to disputed issues

of material fact. Second, the opportunity for cross-exami-

nation need only be afforded to the extent and in the

manner which the Administrator determines is necessary

and appropriate.’ Third, of course, the committee does

not intend that this procedural opportunity should over-

ride the statutory deadlines in the act. Therefore, cross-

examination must be limited so as to permit adequate

time for the entire rulemaking process to be concluded

within such deadlines. Fourth, section 307(d)(5)(B) (iii)

makes clear that the Administrator may require classes of

participants with similar interests to participate through a

single representative, and that he may deny cross-exami-

nation of any sort in cases where such a limiting agree-

ment cannot be reached.

In determining the extent to which cross-examination is

appropriate and necessary, the Administrator may consider

the other types of opportunities for illumination of dis-

puted issues of material fact which have been or will be

afforded. Thus, for example, scientific and technical issues

might be probed by discussions between panels of scien-

tists, and these discussions may be considered in deter-

mining the extent to which cross-examination is necessary

and appropriate. The use of such panels has been EPA’s

practice in a number of cases, and a study of them has

reported that it has worked well. Williams “ ‘Hybrid Rule-

making’ Under the Administrative Procedure Act: A Legal

and Empirical Analysis”, 42 U. Chi. L. Rev. 401, 448-455

(1975).

In cases where only one request for cross-examination

is received, section 307 (d)(5)(B)(ii) permits formal

cross-examination under 5 U.S.C. 556. There is no re-

7 Section 307(d)(5)(B)(i) of the act would confer broad discre-

tion on the Administrator in making such determinations. It would

clearly include, but not be limited to, the Authority to prevent

irrelevant, repetitive, or improper cross-examination.

76a

quirement, however, that an administrative law judge pre-

side at the hearing. That would be inconsistent’ with the

purpose of rulemaking to directly expose the responsible

staff of the agency to the problems raised during the com-

ment period. Instead, a responsible member of the agency

staff may preside.

By using the phrase “disputed issue of material fact” to

designate the allowable scope of cross-examination, the

committee intends to refer to what Professor Davis calls

“adjudicative facts”*® the truth or falsity of which is sub-

ject to evidentiary proof and which could reasonably be

expected to affect the outcome of the rule. The burden

of proving that any issue is a “disputed issue of material

fact” rests on the person seeking to engage in cross-

examination.

In many cases, such facts may not be present, or even

if they are, it may not be possible to say that their truth

or falsity could reasonably be expected to affect the out-

come of the rulemaking. The data base may be so broad,

or policy considerations so dominant as to reduce to in-

significance the question whether one particular “adjudi-

cative” fact is true or not.

Even where this is true, however, a hearing must still

be held whenever legitimate policy questions are still open.

The statute requires an opportunity to present “views and

arguments” in all such cases.

Administrative decision.—In promulgating any rule re-

ferred to in this section, the Administrator must state the

basis of purpose of the final rule, just as such a statement

must accompany the proposed rule. The final rule must

also be accompanied by an explanation of he reasons for

any major changes from the proposed version and a re-

sponse to the significant comments, criticisms and data

submitted during the comment period. While these state-

ments need not be exhaustive or respond to every argu-

8 K. Davis, I Administrative Law Treatise, sec. 702.

77a

ment regardless of weight, they must be of sufficient depth

and complexity to show that the Administrator did con-

sider public comments, to provide basis for States to know

how to revise plans so as to be approvable (in case of a

disapproval), and to permit any court reviewing the rule

under section 307(b) to be fairly apprised of the basis

for the Administrator’s action.

Judicial review.—The committee bill expands the time

available for petitioning for judicial review under section

307 of the act from 30 to 60 days. Moreover, the bill

makes clear the intention of the 1970 amendments that

this period for filing a section 307 judicial review petition

runs from the date the final rule is published in the Federal

Register, not from the date the Administrator signs the

rule and transmits it for publication therein.

With repect to the change in the deadline for filing a

petition for judicial review, the committee notes the recent

decision in Investment Company Institute v. Board of

Governors of the Federal Reserve System (F. 2d—District

of Columbia Cir. 1977). In that case, the court inter-

preted a provision similar to section 307 of the Clean Air

Act. What is of concern to the committee is the possible

application of dictum in that case to the Clean Air Act.

The dictum which is of concern states that with an un-

defined legitimate excuse, the statutory deadline (and the

underlying policies of expedition and finality) may be

circumvented.

In extending to 60 days the time within which a party

may file a petiiton for review of certain EPA actions, the

committee wishes to reaffirm its intent to strictly limit

section 307 challenges to those which are actually filed

within that time. The only instance in which the com-

mittee intends that later challenges may be entertained by

the court of appeals are those in which the grounds arise

solely after the 60th day. Thus, unless a petitioner can

show that the basis for his challenge did not exist or was

not reasonably to be anticipated before the expiration of

78a

60 days, the court of appeals is without jurisdiction to

consider a petition filed later than 60 days after the publi-

cation of the promulgated rule. The committee deems 60

days a legally adequate opportunity for judicial review.

Under the flexible procedures specified by the commit-

tee, disputed questions of classification may arise concern-

ing, for example, whether a given question involves “facts”

or “policy” or whether a given fact is “legislative” or

“adjudicative”. To prevent rulemaking from bogging down

in arguments about such matters, and to underline that

the agency is authorized to adapt rulemaking procedures

to the individual case, the committee has limited the extent

to which the Administrator’s decisions on such procedural

matters may be reversed during judicial review.

As indicated in new section 307(d)(9)(D) of the act

the court may reverse any “rule” if that action is taken

“without observance of procedure required by law”. In

deciding whether or not such reversal is warranted on pro-

cedural grounds, the court is directed to consider two

factors. The first is whether the Administrator’s determi-

nation on the procedural point is “arbitrary or capricious”.

(Section 307(d)(5)(C)).

The second is whether the procedural errors “were so

serious and related to matters of such centrai relevance to

the rule that there is a substantial likelihood that the rule

would have been significantly changed if such errors had

not been made.” (Section 307(d)(8)). Only if the re-

viewing court can make affirmative findings as to each

of these questions would it be authorized to reverse the

Administrator’s action on the ground that it was “without

observance of procedures required by law”.

The committee bill would explicitly adopt the “sub-

stantial evidence” test for judicial review of the substance

of rules under the Clean Air Act. Neither this provision,

nor the requirement of a record, hearing or limited cross-

examination is meant to imply criticism of the courts in

79a

their past reviews of administrative action under the act.

Those reviews have in general been thorough and search-

ing. Nor is the purpose of this provision to shift the

traditional burden of proof in judicial review of adminis-

trative action. The traditional presumption of validity

would remain in effect and the petitioner would, of course,

bear the burden of showing that the rule is invalid. Thus,

the purpose of the committee’s provision in this regard

is to endorse the court’s practice of engaging in searching

review without substituting their judgment for that of

the Administrator and to assure that no retreat to a less

search approach takes place,

The committee recognizes that the factual support

needed for a rule may vary greatly according to the sub-

ject being addressed, and that rules on some subjects,

such as procedures, may not require any factual basis

at all. There is no intention to increase the amount of

“factual” support now required to support “policy judg-

ments where no factual certainties exist or where facts

alone do not provide the answer”, Industrial Union De-

partment, AFL-CIO v. Hodgson, 499 F.2d 467, 476

(D.C. Cir. 1974). Nor is there any intent to diminish

the Administrator’s authority to adopt precautionary regu-

lations based on a showing of risk, which has been con-

firmed by the amendments to various sections of the

Clean Air Act set forth in section 102 of this bill.

Section 307(d)(7)(B) would specify the circumstances

in which a reviewing court may consider data and argu-

ments that were not presented to the agency during the

rulemaking. Even in such cases, however, the Agency

must first be given an opportunity to pass on the signifi-

cance of the materials and determine whether supple-

® Thus, the committee bill would confirm the judgment of the

Court in upholding EPA regulations in Texas Vy. EPA, 499 F, 2d

289 (5th 1974), where the Court found there was no better basis

of support for the State’s assumptions about hydrocarbon reactivity

than for EPA’s assumptions.

80a

mentary proceeding are called for or not. Thus, the com-

mittee bill confirms the court’s decision in Oljato Chapter

of the Navajo Tribe v. Train, 515 F.2d 654 (D.C. Cir.

1975).

Subsection (c) of section 305 of the bill is intended to

clarify some questions relating to venue for review of rules

or orders under the act. Paragraph (1) of that sub-

section makes it clear that any nationally applicable regu-

lations promulgated by the Administrator under the Clean

Air Act could be reviewed only in the U.S. Court of Ap-

peals for the District of Columbia. These would include,

to mention but a few examples, regulations to carry out

the nonattainment policy referred to in section 117 of this

bill and regulations to effectuate motor vehicle assembly-

line test provisions of section 206 of the act or inspection/

maintenance requirements under section 208 of this bill.

Subsection (c)(2) of section 305 provides for essen-

tially locally, statewide, or regionally applicable rules or

orders to be reviewed in the U.S. court of appeals for the

circuit in which such locality, State, or region is located.

This provision applies, except as otherwise provided in

paragraph (4), to the Administrator’s action in approving

or promulgating an implementation plan for any State.

On the other hand, if an action of the Administrator

is found by him to be based on a determination of nation-

wide scope or effect (including a determination which has

scope or effect beyond a single judicial circuit), then ex-

clusive venue for review is in the U.S. Court of Appeals

for the District of Columbia, under paragraph (4).

In adopting this subsection, the committee was in large

measure approving the portion of the Administrative

Conference of the United States recommendation section

305.76—4(A), that deals with venue.2° The committee’s

view also concurs, however, with the comments, con-

cerns, and recommendation contained in item No. 1 of

10 See 41 Fed. Reg. 56767-69, December 30, 1976.

—

Sila

the separate statement of G. William Frick, which accom-

panied the Administrative Conference’s views.

Also, as indicated earlier, the committee bill incorpor-

ates recommendation D2 of the Administrative Confer-

ence on extending the period for petitioning for judicial

review in the court of appeals.

However, in no event should these provisions be con-

strued as endorsement of the remainder of the Admin-

istrative Conference’s recommendations. Some of these

recommendations, such as those contained in items B

and C, were simply not considered by the committee.

Others (such as the recommendations in D1 and D3,

were rejected.”

The committee also included amendments to section

114 of the act in this section to assure that the authorities

contained in section 114 could be used for the purpose

of implementing or enforcing any provision of the act

with respect to any person other than a new motor vehicle

manufacturer. Adequate authority for implementing or

enforcing provisions of the act with respect to new motor

vehicle manufacturers are contained in section 209 of

the bill.

The amendments to section 114 extend beyond persons

Owning or operating emission sources. Thus, for instance,

these authorities may be applied to fuel or fuel additive

manufacturers or suppliers, or to any other person subject

to a requirement, permit, condition, certification, or limi-

tation under the act.

11 Jd. at 56768.

12 See supra in this section for a discussion of the committee’s

views on item D3. On recommendation D3, largely for the reasons

stated in the separate statement of G. William Frick, the committee

oposed the Conference’s recommendation. See also Getty Oil Co.

v. Ruckelshaus, 467 F. 2d (3d Cir. 1972); Lloyd A. Fry Roofing

Co. Vv. EPA, 415 F. Supp. 799 (W.D. Mo. 1976).

82a

Section 305(e) of the bill contains measures necessary

for rational administration of a regional system. In no

way, however, are these provisions intended to require

EPA to continue its regional-based system of adminis-

tration of the act.

If the Agency chooses to continue to rely on this

approach, it must do so subject to the following con-

straints. First, there must be reasonable uniformity in the

criteria, procedures, and policies applied by the various

regional offices under the act. Thus, use of different air

quality models in different regions for the purposes of

implementing the provision requiring prevention of sig-

nificant deterioration would no longer be permitted. Sec-

ond, regional offices would be required to identify poten-

tial inconsistencies and the Administrator must provide

for their expeditions resolution and for policy standardi-

zation. Third, no legal interpretation of the regional of-

fices would be entitled to legal weight unless approved

in writing by the Office of General Counsel. This pro-

vision, designed to prevent instances such as those de-

tailed in the Montana Power case (referred to above),

would not prevent regional offices from applying OGC

approval legal interpretations to specific factual situations

in the regions, but would prevent inconsistent legal inter-

pretations of the act and regulations thereunder in differ-

ent regions.

Finally, the section requires the Administrator to assure

at least an adequate quality audit of State efforts in carry-

ing out the act. Particular attention is directed to the

need for adequate federal review of State permitting of

new and modified sources and of State enforcement efforts.

83a

APPENDIX I

PARENT COMPANIES, SUBSIDIARIES

AND AFFILIATES

The following is a list of the individual electric utility

petitioners, their parent companies, subsidiaries, and af-

filiates:

Alabama Power Company

(a subsidiary of Southern Company )

Appalachian Power Company

(a subsidiary of American Electric Power Company,

Inc.)

Subsidiaries:

Central Operating Company

Baltimore Gas and Electric Company

Subsidiaries:

Constellation Energy Projects & Services, Inc.

Constellation Energy Source, Inc.

Constellation Enterprises, Inc.

Subsidiaries:

BGE Home Products & Services, Inc.

Constellation Power, Inc.

Constellation Investments, Inc.

Constellation Real Estate Group, Inc.

Joint Venture:

Safe Harbor Water Power Corp.

84a

Carolina Power & Light Company

Subsidiaries:

CaroHome, LLC

Caronet, LLC

SRS

Central and South West Services, Inc.

(a subsidiary of Central and South West Corporation)

Central Hudson Gas & Electric Corporation

Subsidiaries:

C H Resources, Inc.

Central Hudson Cogeneration, Inc.

Central Hudson Enterprises

Central Hudson Resources, Inc.

Greene Point Development Corp.

Phoenix Development Co., Inc.

Central Illinois Light Company

(a subsidiary of CILCORP INC.)

Subsidiaries:

CILCO Energy Corp.

CILCO Exploration & Development Co.

Central Illinois Public Service Company

(a subsidiary of Ameren Corporation)

Central Power and Light Company

(a subsidiary of Central and Southwest Corporation)

85a

CINergy Corp.

Subsidiaries:

Cinergy

Cinergy Corp.

Subsidiaries:

Miami Power Corp.

Tri-State Improvement Co.

Union Light, Heat & Power Co.

The West Harrison Gas & Electric Co.

Subsidiaries:

Cinergy Investments, Inc.

CGE Corporation

CGE Eck, Inc.

CG&E Resource Marketing, Inc.

PSI Power Resource Development, Inc.

PSI Power Resource Operations

Power Equipment Supply Company

Cinergy Services, Inc.

K O Transmission Company

Subsidiaries:

Lawrenceburg Gas Co.

Cleveland Electric Illuminating Co.

(a subsidiary of FirstEnergy)

Columbus Southern Power Company

(a subsidiary of American Electric Power Company,

Inc.)

Subsidiaries:

Colomet, Inc.

Conesville Coal Preparation Company

: Simco, Inc.

86a

ComEd Co. (formerly Commonwealth Edison)

(a subsidiary of Unicom Corporation)

Subsidiaries:

Commonwealth Research Corp.

Concomber, Ltd.

Cotter Corp.

Edison Development Canada, Inc.

Consumers Energy (formerly Consumers Power Co.)

(a subsidiary of CMS Energy Corporation)

Subsidiaries:

Michigan Gas Storage Co.

Dayton Power & Light Company, The

(a subsidiary of DPL Inc.)

Delmarva Power & Light Company

(a subsidiary of Conectiv)

Subsidiaries:

Delmarva Capital Investments, Inc.

Delmarva Energy Company

Delmarva Industries, Inc.

Delmarva Services Company

Affiliate:

Atlantic City Electric Company

DTE Energy Company (formerly Detroit Edison

Company, The)

Subsidiaries:

The Edison Illuminating Co. of Detroit

Midwest Energy Resources Co.

Syndeco Realty

a a ee

87a

Duke Energy Corporation (formerly Duke Power

Company)

Subsidiaries:

Algonquin Gas Transmission Corporation

Crescent Resources, Inc.

Duke Energy Field Services, Inc.

Subsidiary:

Trunkline Gas Co.

Duke Energy International, L.L.C.

Duke Engineering & Services, Inc.

Duke Power Company McGuire Nuclear

Duke Power Oconee Nuclear Station

Nantahala Power & Light Company

National Helium Corporation

TEPPCO Partners, L.P.

Subsidiary:

Texas Eastern Production Pipelines Company,

LF.

Subsidiary:

Trans-Ohio Pipeline Company

Texas Eastern Transmission Corporation

Trunkline LNG Co.

Duke/Fluor Daniel

Lachmar

Westana Gathering Company

FirstEnergy Corporation

(a merger of Centerior Energy and Ohio Edison)

Subsidiaries:

The Cleveland Electric Illuminating Company

Ohio Edison Company

88a

Subsidiaries:

Ohio Edison Company—Akron Division

Ohio Edison Company—Springfield Division

Ohio Edison Company—Stark Division

Ohio Edison Company—Western Division

Ohio Edison Company—Youngstown Division

OES Capital, Inc.

OES Fuel, Incorporated

Pennsylvania Power Co.

The Toledo Edison Company

Florida Power Corporation

(a subsidiary of Florida Progress Corporation)

Georgia Power Company

(a subsidiary of Southern Company)

Subsidiary:

Southern Electric Generating Company

Gulf Power Company

(a subsidiary of Southern Company)

Illinois Power Company

(a subsidiary of Illinova Inc.)

Subsidiaries:

IP Gas Supply Co.

Illinois Power Fuel Co.

Electric Energy, Inc.

Indiana Michigan Power Company

(a subsidiary of American Electric Power Company,

Inc.)

ia

a i a ican

EEE mmmmaneineene enna

89a

Subsidiaries:

Blackhawk Coal Co.

Price River Coal Co., Inc.

Indianapolis Power & Light Company

(a subsidiary of IPALCO Enterprises, Inc.)

Jacksonville Electric Authority

Kansas City Power & Light Company

Subsidiaries:

KLT Gas, Inc.

KLT Inc.

Subsidiaries:

KLT Energy Services, Inc.

KLT Investments

KLT Power, Inc.

KLT Telecom Inc.

Wymo Fuels Inc.

Subsidiaries:

Red Hill Coal Co.

Wolf Creek Nuclear Operating Corp.

Kentucky Power Company

(a subsidiary of American Electric Power Company,

Inc.)

Kentucky Utilities Company

(a subsidiary of KU Energy)

Louisville Gas and Electric Company

(a subsidiary of LG&E Energy Corp.)

90a

Madison Gas and Electric Company

Subsidiaries:

Central Wisconsin Development Corporation

Great Lakes Energy Corp.

Subsidiary:

American Energy Management :

National Energy Management, LLC

MAGAEL, Inc.

Minnesota Power

Subsidiaries:

Adesa Corporation

Adesa, Inc.

Subsidiary:

Adesa Pittsburgh Auto Auction

Automotive Finance Corp.

BNI Coal, Ltd.

Energy Land, Incorporated

Florida Water, Inc.

Lehigh Utilities Inc.

Rainy River Energy Corporation

RendField Land Company, Inc.

Superior Water, Light & Power Company

Synertec, Incorporated

Topeka Group, Incorporated

Subsidiary:

Heater Utilities, Incorporated

UtilEquip, Incorporated

Capital Re Corporation

Mississippi Power Company

(a subsidiary of Southern Company)

9la

Monongahela Power Company

(a subsidiary of Allegheny Energy, Inc.)

Northern Indiana Public Service Company

(a subsidiary of NIPSCO Industries, Inc.)

Subsidiaries:

NIPSCO Exploration Co., Inc.

Shore Line Shops, Inc.

Oglethorpe Power Corp.

Subsidiaries:

Black Diamond Energy, Inc.

Ohio Power Company

(a subsidiary of American Electric Power Company, Inc.)

Subsidiaries:

Central Ohio Coal Co.

Southern Ohio Coal Co.

Windsor Coal Co.

Ohio Valley Electric Corporation

Subsidiary:

Indiana Kentucky Electric Corporation

Otter Tail Power Company

Subsidiary:

Minnesota-Dakota Generating Co.

PacifiCorp

Subsidiaries:

Pacific Power & Light Company

Utah Power & Light Company

92a

Centralia Mining Company

Energy West Mining Company

Glenrock Coal Company

Pacific Minerals, Inc.

PacifiCorp Group Holdings Company

Subsidiary:

PacifiCorp Financial Services, Inc.

Subsidiaries:

Paccom Leasing Corporation

PacifiCorp Aviation (Holdings), Inc.

PacifiCorp Credit, Inc.

PacifiCorp Trans, Inc.

Subsidiaries:

Cascade Autovon Co.

Gem State Utilities Corporation

Inter Island Telephone Co., Inc.

International Communications Holdings,

Inc.

Northwestern Telephone Systems, Inc.

Pacific Telecom Cellular, Inc.

Telephone Utilities of Alaska, Inc.

Telephone Utilities of Eastern Oregon, Inc.

Telephone Utilities of Oregon, Inc.

Telephone Utilities of Washington, Inc.

TPC Corporation

Powercor Australia-Limited

Pennsylvania Power and Light Company (Now PP&L

Resources )

Subsidiaries:

Pennsylvania Power & Light Company——

Harrisburg Div.

93a

Pennsylvania Power & Light Company—

Lancaster Div.

Pennsylvania Power & Light Company—

Lehigh Div.

Pennsylvania Power & Light Company—

Northeast Div.

Pennsylvania Power & Light Company—

Susquehanna Div.

CEP Group, Inc.

Subsidiary:

Power Markets Development Company

Interstate Energy Co.

Pennsylvania Coal Resources Corp.

Subsidiary:

Pennsylvania Mines Corp.

Subsidiary:

Rushton Mining Co.

Realty Co. of Pennsylvania

Subsidiaries:

BDW Corp.

Greene Manor Coal Co.

Lady Jane Collieries, Inc.

Safe Harbor Water Power Corp.

Plains Electric Generation & Tranmission Cooperative,

Inc.

Potomac Edison Company, The

(a subsidiary of Allegheny Energy, Inc.)

Potomac Electric Power Company

Subsidiary:

Potomac Capital Investment Corporation

94a

Public Service Company of New Mexico

Subsidiaries:

Meadows Resources, Inc.

Paragon Resources, Inc.

Sunbelt Mining Co., Inc.

Sunterra Gas Gathering Company

Sunterra Gas Processing Company

Public Service Company of Oklahoma |

(a subsidiary of Central and Southwest Corporation)

Subsidiaries:

Public Service Company of Oklahoma—

Eastern Division

Public Service Company of Oklahoma—

Mantulsa Division

Public Service Company of Oklahoma—

Northern Division

Public Service Company of Oklahoma—

Western Division

Salt River Project Agricultural Improvement and Power

District

Savannah Electric & Power Company

(a subsidiary of Southern Company)

South Carolina Electric & Gas Company

(a subsidiary of SCANA Corporation)

Southern Company

Subsidiaries:

Alabama Power Company

Georgia Power Company

Subsidiary:

Southern Electric Generating Company

95a

Gulf Power Company

Mississippi Power Company

Savannah Electric & Power Company

Southern Communications Services

Southern Company Services, Inc.

Southern Development and Investment Group

Southern Nuclear

Southwestern Electric Power Company

(a subsidiary of Central Southwest Corporation)

Tampa Electric Company

(a subsidiary of TECO Energy, Inc.)

Subsidiaries:

TECO Coal Corp.

TECO Coalbed Methane, Inc.

Toledo Edison Co.

(a subsidiary of FirstEnergy)

Tucson Electric Power Company

(a subsidiary of UniSource Energy Corporation)

Subsidiaries:

Advanced Energy Technologies

Global Solar Energy

Nations Energy Corporation

Southwest Energy Solutions, Inc.

Southwest Power Productions

Union Electric Company

(a subsidiary of Ameren Corporation)

Subsidiary:

Union Electric Development Corporation

inaiiicenieeaenaiiiaaiiliiaaauusails

96a

Virginia Electric

(a subsidiary of Dominion Resources, Inc. )

West Penn Power Company

(a subsidiary of Allegheny Energy, Inc.)

West Texas Utilities Company

(a subsidiary of Central and South West Corporation)

Wisconsin Electric Power Company

(a subsidiary of Wisconsin Energy Corporation )

The following is the other petitioner with a parent or

subsidiary to list under Rule 29.

RSR Corporation

(a subsidiary of Quexco, Inc.)

The following petitioners have no parents or subsidiaries

to list pursuant to Rule 29.

American Forest and Paper Association, Inc.

American Public Power Association

American Petroleum Institute

Can Manufacturers Institute

Clean Air Implementation Project

Corn Refiners Association

Edison Electric Institute

Ohio Chamber of Commerce

Ohio Chemical Council

National Rural Electric Cooperative Association

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Appendix — Appalachian Power Co. v. Environmental Protection Agency · 527 U.S. 1021 | Frix