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Legislative Process Keyed to Mikva, 5th Ed.
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
Citation:
467 U.S. 837 (1984)Facts
In 1981, the EPA promulgated regulations implementing the Clean Air Act Amendments of 1977, which required states that had not achieved national air quality standards to establish permit programs regulating “new or modified major stationary sources” of air pollution. The EPA’s regulations allowed states to adopt a plantwide definition of “stationary source,” permitting an existing plant to modify equipment without meeting permit conditions if the modification would not increase total emissions from the plant (the “bubble concept”). This approach was a change from the EPA’s previous position. The Natural Resources Defense Council challenged this interpretation, arguing that it contradicted the Clean Air Act’s purpose of improving air quality. The Court of Appeals agreed with NRDC and invalidated the regulations, holding that the bubble concept was inappropriate in programs designed to improve air quality.
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