Train v. Natural Resources Defense Council, Inc.
421 U.S. 60, 43 L. Ed. 2d 731, 1975 U.S. LEXIS 107 (1975)
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Rule of Law:
The Clean Air Act allows the Environmental Protection Agency (EPA) to approve a State Implementation Plan (SIP) that treats individual source variances as 'revisions' under § 110(a)(3), provided the variances do not interfere with the timely attainment and subsequent maintenance of national ambient air quality standards. The Act's stricter 'postponement' procedures under § 110(f) are reserved for situations that would prevent the attainment or maintenance of such standards.
Facts:
- In response to the Clean Air Amendments of 1970, which required states to meet national ambient air quality standards within a specified time, the State of Georgia submitted its State Implementation Plan (SIP) to the Environmental Protection Agency (EPA).
- Georgia's plan established general, immediately effective emission limitations for pollution sources across the state.
- The plan also included a state-level variance procedure (Ga. Code Ann. § 88-912) that allowed Georgia's environmental agency to grant specific, temporary relief from the general emission limitations to individual sources under certain conditions.
- The EPA Administrator, interpreting the authority granted by the Act, approved Georgia's SIP, including the variance provision.
- The EPA treated these potential variances as 'revisions' to the plan under § 110(a)(3) of the Act, which are permissible as long as the revised plan as a whole continues to ensure the attainment and maintenance of national air quality standards.
Procedural Posture:
- The Natural Resources Defense Council, Inc. (NRDC) filed a petition for review in the United States Court of Appeals for the Fifth Circuit, challenging the EPA Administrator's approval of Georgia's State Implementation Plan.
- The NRDC specifically contested the legality of the plan's variance provision.
- The Court of Appeals for the Fifth Circuit ruled in favor of the NRDC, holding that the 'postponement' provision of § 110(f) was the exclusive method for granting variances to individual sources.
- The appellate court ordered the EPA Administrator to disapprove the variance provision in Georgia's plan.
- The EPA Administrator, Train, petitioned the United States Supreme Court for a writ of certiorari, which the Court granted.
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Issue:
Does the Clean Air Act permit the Environmental Protection Agency (EPA) to approve a state's implementation plan that allows for individual variances from pollution emission limits as 'revisions' under § 110(a)(3), or must all such individual variances meet the stricter requirements for 'postponements' under § 110(f)?
Opinions:
Majority - Justice Rehnquist
Yes, the Clean Air Act permits the EPA to approve a state's plan that allows for individual variances as 'revisions' under § 110(a)(3). The EPA's interpretation of the statute was sufficiently reasonable and should have been accepted by the reviewing court. The Act establishes a system of cooperative federalism, giving states the primary responsibility for determining the specific mix of emission limitations to achieve federal air quality standards. Section 110(a)(3) provides the mechanism for states to modify that mix by allowing for 'any revision' to a plan, so long as the revised plan still meets the core statutory requirements, including timely attainment of national standards. Conversely, the court found that § 110(f) is a narrow 'safety valve' intended only for situations where a source needs an exception that would delay or prevent attainment of the national standards themselves, requiring a much stricter showing of necessity. The EPA’s interpretation is consistent with the statutory structure and legislative history, and as the agency charged with administering the Act, its reasonable construction is entitled to deference.
Dissenting - Justice Douglas
Justice Douglas dissented without a written opinion.
Analysis:
This decision solidified the principle of cooperative federalism within the Clean Air Act, affirming that states retain significant flexibility in designing and modifying their implementation plans. It established a critical two-track system for variances: minor adjustments that do not jeopardize national standards can proceed as flexible 'revisions,' while more significant changes require the stringent 'postponement' process. By upholding the EPA’s statutory interpretation, the case also reinforced the principle of judicial deference to administrative agencies, a precursor to the landmark Chevron deference doctrine, empowering agencies to resolve ambiguities in complex regulatory statutes.
