Train v. Natural Resources Defense Council, Inc.
Train v. Natural Resources Defense Council | |
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Decided April 16, 1975 | |
Full case name | Train v. Natural Resources Defense Council |
Citations | 421 U.S. 60 (more) |
Holding | |
The EPA must approve a State Implementation Plan if it meets the requisite criteria under the Clean Air Act. | |
Court membership | |
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Train v. Natural Resources Defense Council, 421 U.S. 60 (1975), is a United States Supreme Court case in which the Court held that the EPA must approve a State Implementation Plan if it meets the criteria under the Clean Air Act.[1]
Facts
The 1970 amendments to the Clean Air Act required states to meet federally mandated air quality standards within a statutorily specified period of time. States were directed to submit to the Administrator of the EPA a plan to "implement, attain and maintain" the federally adopted standards within nine months of the promulgation of such standards. The EPA Administrator was required to approve implementation plans meeting the statutory criteria and to promulgate substitutes for those found deficient. A number of states included variance procedures in their implementation plans, which the EPA approved. The NRDC challenged the EPA's approval of Georgia's implementation plan on the grounds that the postponement provision of the Clean Air Act was the only method to modify the state implementation plans. The Fifth Circuit Court of Appeals held that the Georgia plan should not have been approved, and the Supreme Court granted certiorari.
Opinion
In an opinion delivered by Justice Rehnquist, the Court concluded that the Fifth Circuit erred in holding that postponements were the exclusive means by which individual sources could obtain relief from state implementation plans. The Court held that the Fifth Circuit had improperly substituted their judgment for the agency's judgment, and the flexibility in the language of the Clean Air Act left the states with the requisite authority to grant source-specific variances.[2] The Court further held that as long as the "ultimate effect of a State's choice of emission limitations is compliance with the national standards for ambient air," a state is "at liberty to adopt whatever mix of emission limitations it deems best suited to its particular situation."[3]
References
- ^ Train v. Natural Resources Defense Council, 421 U.S. 60 (1975)
- ^ "Train v. Natural Resources Defense Council: The Genesis of a New Era of Federal-State Relationships in Air Pollution Control" (PDF). CORE. Retrieved November 11, 2021.
- ^ "The Important, Yet Limited, Role of State Environmental Actions". Westlaw. Retrieved November 11, 2021.
External links
- Text of Train v. Natural Resources Defense Council, 421 U.S. 60 (1975) is available from: Cornell Findlaw Justia
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decisions
- Missouri v. Holland (1920)
- Sierra Club v. Morton (1972)
- Vermont Yankee v. NRDC (1978)
- Hughes v. Oklahoma (1979)
- Lujan v. National Wildlife Federation (1990)
- Friends of the Earth v. Laidlaw Environmental Services (2000)
- BP P.L.C. v. Mayor and City Council of Baltimore (2021)
federal legislation,
treaties,
and lower court
decisions
- Yellowstone National Park Protection Act (1872)
- Forest Service Organic Administration Act (1897)
- Rivers and Harbors Act (1899)
- Lacey Act (1900)
- Weeks Act (1911)
- North Pacific Fur Seal Convention of 1911 (1911)
- Weeks–McLean Act (1913)
- Migratory Bird Treaty Act (1918)
- Clarke–McNary Act (1924)
- Oil Pollution Act (1924)
- McSweeney-McNary Act (1928)
- Fish and Wildlife Coordination Act (1934)
- Watershed Protection and Flood Prevention Act (1954)
- Air Pollution Control Act (1955)
- Fish and Wildlife Act (1956)
- Oil Pollution Act (1961)
- Clean Air Act (1963, 1970, 1977, 1990)
- Scenic Hudson Preservation Conference v. Federal Power Commission (2nd Cir. Court of Appeals, 1965)
- Solid Waste Disposal Act (1965)
- Endangered Species Act (1969)
- Environmental Quality Improvement Act (1970)
- National Environmental Policy Act (1970)
- Clean Water Act (1972, 1977, 1987, 2014)
- Coastal Zone Management Act (1972)
- Federal Insecticide, Fungicide, and Rodenticide Act (1972)
- Marine Protection, Research, and Sanctuaries Act (1972)
- Noise Control Act (1972)
- Endangered Species Act (1973)
- Oil Pollution Act (1973)
- Safe Drinking Water Act (1974, 1986, 1996)
- Water Resources Development Act (1974, 1976, 1986, 1988, 1990, 1992, 1996, 1999, 2000, 2007, 2014, 2016, 2022)
- Federal Noxious Weed Act (1975)
- Hazardous Materials Transportation Act (1975)
- Magnuson–Stevens Act (1976)
- Resource Conservation and Recovery Act (1976)
- Toxic Substances Control Act (1976)
- Surface Mining Control and Reclamation Act (1977)
- Uranium Mill Tailings Radiation Control Act (1978)
- CERCLA (Superfund) (1980)
- Emergency Planning and Community Right-to-Know Act (1986)
- Emergency Wetlands Resources Act (1986)
- Global Change Research Act (1990)
- National Environmental Education Act (1990)
- Oil Pollution Act (1990)
- Alien Species Prevention and Enforcement Act of 1992
- Food Quality Protection Act (1996)
- Energy Policy Act (2005)
- Energy Independence and Security Act (2007)
- Coalition for Responsible Regulation, Inc. v. EPA (D.C. Cir. Court of Appeals, 2012)
- Lautenberg Chemical Safety Act (2016)
- America's Water Infrastructure Act (2018)
- Infrastructure Investment and Jobs Act (2021)
- Louisiana v. Biden (5th Cir. Court of Appeals, 2022)
- CHIPS and Science Act (2022)
- Inflation Reduction Act (2022)
and concepts
- Best available technology
- Citizen suit
- Clean Power Plan
- Corporate average fuel economy
- Discharge Monitoring Report
- Effluent guidelines
- Environmental crime
- Environmental impact statement
- Environmental justice
- Executive Order 13432 (2007)
- Executive Order 13990 (2022)
- LDV Rule (2010)
- Maximum contaminant level
- National Ambient Air Quality Standards
- National Climate Assessment
- National Emissions Standards for Hazardous Air Pollutants
- National Priorities List
- New Source Performance Standards
- New Source Review
- Not-To-Exceed (NTE)
- PACE financing
- Presidential Climate Action Plan
- Renewable Fuel Standard
- Right to know
- Section 608 Certification
- Significant New Alternatives Policy
- State of the Climate
- Tailoring Rule (2010)
- Total maximum daily load
- Toxicity category rating
- Uranium Mill Tailings Remedial Action
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