Blue Ridge Environmental Defense League v. Regan

CourtDistrict Court, District of Columbia
DecidedDecember 12, 2024
DocketCivil Action No. 2022-3134
StatusPublished

This text of Blue Ridge Environmental Defense League v. Regan (Blue Ridge Environmental Defense League v. Regan) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blue Ridge Environmental Defense League v. Regan, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA _________________________________________ ) BLUE RIDGE ENVIRONMENTAL ) DEFENSE LEAGUE, et al., ) ) Plaintiffs, ) ) v. ) Case No. 22-cv-3134 (APM) ) MICHAEL S. REGAN, ) Administrator of the EPA, ) ) Defendant. ) _________________________________________ )

MEMORANDUM OPINION

Plaintiffs are various environmental advocacy groups, who seek to compel the

Environmental Protection Agency (“EPA” or “the Agency”) to fulfill certain mandatory

rulemaking duties updating emissions standards for hazardous waste combustors under the

Clean Air Act, 42 U.S.C. § 7401 et seq. The EPA does not dispute that it has failed to complete

the rulemaking required of it by Congress. The only contested issue is the timeline under which

this court should order the Agency to issue a final rule.

Before the court are the parties’ cross-motions for summary judgment. See Pls.’ Mot. for

Summ. J., ECF No. 24 [hereinafter Pls.’ Summ. J. Mot.]; Def.’s Cross-Mot. for Summ. J., ECF No.

26 [hereinafter Def.’s Summ. J. Mot.]. Having considered the parties’ various submissions, the

court orders the EPA to complete rulemaking by December 31, 2025.

I. BACKGROUND

A. Legal and Regulatory Landscape

The Clean Air Act (“CAA”) serves “to protect and enhance the quality of the Nation’s air

resources so as to promote the public health and welfare and the productive capacity of its population.” 42 U.S.C. § 7401(b)(1). By the late 20th century, Congress was concerned with the

CAA’s ineffectiveness and amended it in 1990 “to strengthen and expand the [CAA] through a

technology-based program.” Sierra Club v. EPA, 353 F.3d 976, 979 (D.C. Cir. 2004) (quoting H.R.

Rep. No. 101-490, pt. 1, at 144 (1990)) (internal quotation marks and alterations omitted). It did

so in a few ways. First, Congress included a specific list of nearly 200 hazardous air pollutants

(“HAPs”) for mandatory regulation by the EPA. See id. at 979–80 (citing 42 U.S.C. § 7412(b)).

Second, it “established an emission standards implementation process ‘based on the maximum

reduction in emissions which can be achieved by application of best available control technology.’”

Id. at 980 (quoting S. Rep. No. 101-228, at 133 (1989)). And, third, Congress “imposed a series

of deadlines by which the EPA was required to promulgate, and periodically revise, emission

standards for sources that emit those pollutants.” Cmty. In-Power & Dev. Ass’n, Inc. v. Pruitt,

304 F. Supp. 3d 212, 216 (D.D.C. 2018) (citing 42 U.S.C. § 7412(c)(1), (c)(2), (d)).

Under the 1990 CAA amendments, the EPA was required to publish an initial list of all

categories of “major” and “area” sources of HAPs within one year. 42 U.S.C. § 7412(c)(1).

A major source is “any stationary source or group of stationary sources located within a contiguous

area and under common control that emits . . . 10 tons per year or more of any hazardous air

pollutant or 25 tons per year or more of any combination of hazardous air pollutants.” Id.

§ 7412(a)(1). A stationary source, in turn, includes “any building, structure, facility, or installation

which emits or may emit any air pollutant.” Id. § 7411(a)(3). An area source is “any stationary

source of hazardous air pollutants that is not a major source.” Id. § 7412(a)(2). The CAA “calls

upon [the] EPA to list the ‘source categories’ most responsible for emissions of each HAP listed in

the statute” and “promulgate regulations governing their emission of HAPs.” Sierra Club v.

Johnson, 444 F. Supp. 2d 46, 48 (D.D.C. 2006).

2 To regulate emissions, the Agency had to “specify the source’s maximum allowable

emission” of listed HAPs. La. Env't Action Network v. EPA, 955 F.3d 1088, 1092 (D.C. Cir. 2020)

[hereinafter LEAN] (citing 42 U.S.C. § 7412(d)(1)). Congress created a two-step approach for the

initial promulgation of emissions standards. For the first step, the Agency must use technology-

based standards known as “Maximum Achievable Control Technology” (“MACT”). See Sierra

Club v. EPA, 353 F.3d at 980 (citing S. Rep. No. 101-228, at 148 (1989)). EPA begins by

establishing what are known as “MACT floors”—the minimum emissions standards set by

comparison to the best-performing sources in a particular category. Id. For new sources,

i.e., stationary sources built after the EPA published its HAP regulations, see 42 U.S.C.

§ 7412(a)(4), the statute provides that “[t]he maximum degree of reduction in emissions that is

deemed achievable . . . shall not be less stringent than the emission control that is achieved in

practice by the best controlled similar source,” id. § 7412(d)(3) (emphasis added). For existing

sources, i.e., those stationary sources which are not considered new sources, see id. § 7412(a)(10),

emissions standards must be at least as stringent as the average emissions limitations achieved by

(1) the best-performing 12% of existing sources for which the EPA has emissions information or

(2) the best-performing five sources for which the EPA has emissions information in categories

that contain fewer than 30 existing sources, id. § 7412(d)(3)(A)–(B). With these MACT floors set,

the EPA’s second step is to determine whether stricter standards are “achievable,” in light of costs

and other factors listed in the statute. Id. § 7412(d)(2); see also LEAN, 955 F.3d at 1093.

Congress expected the EPA to act expeditiously in setting MACT standards. It required

the Agency to complete emissions standards for 40 source categories within two years and all

remaining emissions standards by no later than November 15, 2000. 42 U.S.C. § 7412(e)(1)(A),

3 (E). When a new source category is listed, the EPA must promulgate emissions standards within

two years. Id. § 7412(c)(5).

Congress recognized that environmental conditions and technology do not stand still, so it

also required the EPA to conduct ongoing reviews of emissions standards. Under 42 U.S.C.

§ 7412(d)(6) and § 7412(f)(2), the EPA must revisit its initial emissions standards within eight

years of promulgation on two fronts. First, § 7412(d)(6) requires EPA to reevaluate its current

emissions standards every eight years to consider improvements in pollution “practices, processes,

and control technologies,” a process known as a “technology review.” See 42 U.S.C. § 7412(d)(6);

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