''Train v. Natural Resources Defense Council'', 421 U.S. 60 (1975), is a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

case in which the Court held that the

EPA The Environmental Protection Agency (EPA) is an independent executive agency of the United States federal government tasked with environmental protection matters. President Richard Nixon proposed the establishment of EPA on July 9, 1970; it be ...

must approve a State Implementation Plan if it meets the criteria under the Clean Air Act.

Facts

The 1970 amendments to the Clean Air Act required states to meet federally mandated air quality standards within a statutorily specified period of time. States were directed to submit to the Administrator of the EPA a plan to "implement, attain and maintain" the federally adopted standards within nine months of the promulgation of such standards. The EPA Administrator was required to approve implementation plans meeting the statutory criteria and to promulgate substitutes for those found deficient. A number of states included variance procedures in their implementation plans, which the EPA approved. The NRDC challenged the EPA's approval of Georgia's implementation plan on the grounds that the postponement provision of the Clean Air Act was the only method to modify the state implementation plans. The

Fifth Circuit Court of Appeals The United States Court of Appeals for the Fifth Circuit (in case citations, 5th Cir.) is a federal court with appellate jurisdiction over the district courts in the following federal judicial districts: * Eastern District of Louisiana * M ...

held that the Georgia plan should not have been approved, and the Supreme Court granted certiorari.

Opinion

In an opinion delivered by

Justice Rehnquist William Hubbs Rehnquist ( ; October 1, 1924 – September 3, 2005) was an American attorney and jurist who served on the U.S. Supreme Court for 33 years, first as an associate justice from 1972 to 1986 and then as the 16th chief justice from 1 ...

, the Court concluded that the Fifth Circuit erred in holding that postponements were the exclusive means by which individual sources could obtain relief from state implementation plans. The Court held that the Fifth Circuit had improperly substituted their judgment for the agency's judgment, and the flexibility in the language of the Clean Air Act left the states with the requisite authority to grant source-specific variances. The Court further held that as long as the "ultimate effect of a State's choice of emission limitations is compliance with the national standards for ambient air," a state is "at liberty to adopt whatever mix of emission limitations it deems best suited to its particular situation."

References

External links

* 1975 in United States case law United States Supreme Court cases United States environmental case law {{SCOTUS-stub