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Keywords

regulationrelevanceclean air act

Related Cases

Michigan v. E.P.A., 576 U.S. 743, 135 S.Ct. 2699, 192 L.Ed.2d 674, 80 ERC 1577, 83 USLW 4620, 15 Cal. Daily Op. Serv. 6936, 2015 Daily Journal D.A.R. 7421, 25 Fla. L. Weekly Fed. S 523

Facts

The Clean Air Act directs the EPA to regulate emissions of hazardous air pollutants from power plants if it finds regulation 'appropriate and necessary.' The EPA concluded that regulation was appropriate due to the risks posed by power plant emissions and the availability of controls to reduce these emissions. However, the EPA refused to consider the costs of regulation, estimating that the costs would be $9.6 billion annually while the quantifiable benefits would only be $4 to $6 million per year. This decision was challenged by several states and industry groups, leading to a review by the D.C. Circuit, which upheld the EPA's decision.

The Clean Air Act directs the EPA to regulate emissions of hazardous air pollutants from power plants if it finds regulation 'appropriate and necessary.'

Issue

Did the EPA act unreasonably by refusing to consider costs when determining whether regulation of power plants was 'appropriate and necessary' under the Clean Air Act?

Rule

Agency action is unlawful if it does not rest on a consideration of the relevant factors, including costs, when determining whether regulation is appropriate and necessary.

Analysis

The Supreme Court found that the EPA's interpretation of the Clean Air Act was unreasonable because it ignored the relevance of costs in its decision-making process. The Court emphasized that the phrase 'appropriate and necessary' should encompass cost considerations, as imposing significant economic costs for minimal health benefits is not rational. The Court also noted that the statutory context required the EPA to consider costs, as other provisions of the Clean Air Act explicitly mention cost considerations.

The Supreme Court found that the EPA's interpretation of the Clean Air Act was unreasonable because it ignored the relevance of costs in its decision-making process.

Conclusion

The Supreme Court reversed the D.C. Circuit's decision and remanded the case, holding that the EPA must consider costs when determining whether to regulate power plants under the Clean Air Act.

Who won?

The petitioners, including several states and industry groups, prevailed because the Supreme Court found that the EPA's refusal to consider costs was unreasonable.

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Keywords

Related Cases

Alabama Power Co. v. Costle, 636 F.2d 323, 13 ERC 1993, 204 U.S.App.D.C. 51, 10 Envtl. L. Rep. 20,001

Environmental Defense v. Duke Energy Corp., 549 U.S. 561, 127 S.Ct. 1423, 167 L.Ed.2d 295, 63 ERC 2088, 75 USLW 4167, 07 Cal. Daily Op. Serv. 3424, 2007 Daily Journal D.A.R. 4293, 20 Fla. L. Weekly Fed. S 123

International Fabricare Institute v. U.S. E.P.A., 972 F.2d 384, 35 ERC 1281, 297 U.S.App.D.C. 331, 22 Envtl. L. Rep. 21,385

PruneYard Shopping Center v. Robins, 447 U.S. 74, 100 S.Ct. 2035, 64 L.Ed.2d 741, 6 Media L. Rep. 1311

Environmental Defense Center, Inc. v. U.S. E.P.A., 319 F.3d 398, 55 ERC 1833, 33 Envtl. L. Rep. 20,139, 03 Cal. Daily Op. Serv. 369, 2003 Daily Journal D.A.R. 467