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Administrative Law Keyed to Asimow
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
Citation:
467 U.S. 837 (1984)Facts
In 1977, Congress amended the Clean Air Act to address states that had not achieved national air quality standards. The amendments required these “nonattainment” states to establish permit programs for new or modified major stationary sources of air pollution. In 1981, the EPA promulgated regulations allowing states to adopt a plantwide definition of “stationary source,” which treated all pollution-emitting devices within the same industrial grouping as though they were encased in a single “bubble.” Under this definition, a plant could modify or install new equipment without meeting permit requirements if the alteration did not increase total emissions from the plant. The NRDC challenged this interpretation, arguing it was contrary to the purpose of the Clean Air Act, which was to improve air quality. The Court of Appeals agreed with NRDC and set aside the regulations, holding that the bubble concept was inappropriate in programs designed to improve air quality.
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