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Administrative Law Keyed to Funk
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
Citation:
467 U.S. 837 (1984)Facts
In the Clean Air Act Amendments of 1977, Congress established requirements for states that had not achieved national air quality standards, requiring them to establish permit programs regulating “new or modified major stationary sources” of air pollution. The EPA promulgated regulations in 1981 allowing states to adopt a plantwide definition of “stationary source,” known as the “bubble concept.” Under this approach, an existing plant could modify equipment without meeting permit conditions if the alteration would not increase total emissions from the plant. The NRDC challenged these regulations, arguing they contravened the purpose of the nonattainment program to improve air quality. The Court of Appeals agreed, holding that the bubble concept was inappropriate in programs designed to improve air quality, but the EPA maintained its interpretation was a reasonable accommodation of competing interests in environmental protection and economic growth.
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