Sierra Club v. United States Environmental Protection Agency

CourtDistrict Court, District of Columbia
DecidedJuly 25, 2025
DocketCivil Action No. 2023-1744
StatusPublished

This text of Sierra Club v. United States Environmental Protection Agency (Sierra Club v. United States Environmental Protection Agency) 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
Sierra Club v. United States Environmental Protection Agency, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SIERRA CLUB, et al.,

Plaintiffs, v. Civil Action No. 23-1744 (JDB) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, et al.,

Defendants.

MEMORANDUM OPINION

The Sierra Club, the National Parks Conservation Association, and the Environmental

Integrity Project (collectively “Plaintiffs”) brought this action to compel the United States

Environmental Protection Agency (“EPA”) and its Administrator, Lee Zeldin 1 (collectively

“Defendants”), to take certain required actions under the Clean Air Act (“CAA”), 42 U.S.C. §

7401 et seq. Fortunately, the parties’ negotiations bore fruit and resulted in a consent decree.

Now, the Plaintiffs move to recover $173,217 in attorney’s fees and costs. Upon careful

consideration, the Court will grant the Plaintiffs’ motion in part and award them $99,343.43 in

total—$98,841.43 in attorney’s fees and $502 in costs.

BACKGROUND

The CAA aims to protect visibility in “class I Federal areas . . . from manmade air

pollution.” 42 U.S.C. § 7491(a)(1).2 Thus, it requires qualifying states periodically to submit State

1 See Fed. R. Civ. P. 25(d). 2 156 national parks and wilderness areas comprise “Class I Federal areas.” United States Environmental Protection Agency, Regional Haze Program, (Mar. 12, 2025), https://www.epa.gov/visibility/regional-haze-program. Throughout this Opinion, the Court takes judicial notice of government websites. See, e.g., Santos v. Collins, Civ. A. No. 24-1759 (JDB), 2025 WL 1905596, at *1 n.2 (D.D.C. July 10, 2025).

1 Implementation Plans (“SIPs”) to the EPA to address visibility impairment in these areas. See id.

§ 7491(b)(2); 40 C.F.R. § 51.308. Within sixty days of a state’s SIP submission, but no later than

six months after a state’s SIP submission deadline, the EPA must determine whether the

submission is “complete” under criteria established by the CAA and relevant regulations. See 42

U.S.C. § 7410(k)(1); 40 C.F.R. pt. 51, app. V. If the EPA does not make a timely finding of

completeness, the plan is deemed complete by operation of law. 42 U.S.C. § 7410(k)(1)(B).

Within twelve months of a SIP being declared “complete,” the EPA must approve (wholly or in

part), conditionally approve, or disapprove the submission.3 Id. § 7410(k)(2)–(4).

The Plaintiffs filed their initial complaint in June 2023, alleging that the EPA had failed to

take final action within twelve months of the completion of SIP submissions from seven states.4

See Compl. for Declaratory & Injunctive Relief [ECF No. 1] (“Initial Compl.”). They amended

their complaint in November 2023, expanding the list of states to thirty-four.5 See Am. Compl.

for Declaratory & Injunctive Relief [ECF No. 15] (“Am. Compl.”).

Eventually, through a series of unopposed motions for extension, the Plaintiffs and

Defendants negotiated a consent decree, see Consent Decree [ECF No. 53-1] (“CD”), which this

Court approved in July 2024, see Order Approving Consent Decree [ECF No. 53]. In the decree,

the parties established a schedule by which the Defendants agreed to take final action on all

3 The Court will refer to these actions collectively as “final actions.” 4 Kansas, Massachusetts, Michigan, New York, Ohio, Texas, and Wisconsin. 5 The additional 27 states are: Alaska, Arkansas, Arizona, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Indiana, Maryland, Montana, Nevada, New Hampshire, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Utah, Washington, West Virginia, and Wyoming.

2 completed SIP submissions still pending such action.6 See CD ¶ 3. They also agreed that the

Plaintiffs could “file a motion for costs of litigation (including attorney fees).” Id. ¶ 13.

The Plaintiffs filed the instant fee motion in January 2025, requesting $181,977 in total.

Pls.’ Mot. for Costs of Litigation, Including Att’ys’ Fees [ECF No. 57] (“Fee Mot.”) at 9. In

response to the Defendants’ objections to some of the billed hours, see Defs.’ Fee Resp. to Pls.’

Mot. [ECF No. 59] (“Defs.’ Resp.”) at 9–10 & n.6, the Plaintiffs reduced their request to $173,217.

See Pls.’ Reply Supp. Fee Mot. [ECF No. 63] (“Pls.’ Reply”) at 7. The Defendants agree that the

Plaintiffs are entitled to fees and costs, Defs.’ Resp. at 1, but for “no more than $42,500.” Id. at

14.

ANALYSIS

Under the CAA, this Court “may award costs of litigation (including reasonable attorney

and expert witness fees) to any party, whenever the court determines such award is appropriate.”

42 U.S.C. § 7604(d). Because the parties do not dispute that the Plaintiffs are entitled to fees, see

Defs.’ Resp. at 1, the Court considers only the fees’ magnitude.7

The “basic formula” for calculating reasonable attorney’s fees is to multiply “the number

of hours reasonably expended in litigation by a reasonable hourly rate.” DL v. District of Columbia,

924 F.3d 585, 588 (D.C. Cir. 2019) (cleaned up). The movant bears the burden of demonstrating

the reasonableness of both the rates and hours. See Eley v. District of Columbia, 793 F.3d 97, 100

(D.C. Cir. 2015). And the opposing party can rebut the movant’s claims “by equally specific

6 The Plaintiffs dropped claims relating to two (Maryland and Massachusetts) out of the thirty-four states in the Amended Complaint, because the EPA had taken final actions on those states’ SIPs before this Court approved the consent decree. See CD at 4. 7 The Defendants also do not challenge the reasonableness of the $502 in costs.

3 countervailing evidence.” Nat’l Ass’n of Concerned Veterans v. Sec’y of Def., 675 F.2d 1319,

1326 (D.C. Cir. 1982). The Court will examine the rates and hours in turn.

I. Rates

The parties disagree first about the hourly rates. See Pls.’ Reply at 5. The Plaintiffs bear

the burden of establishing the reasonableness of their requested rates through a three-part

framework: “(1) the attorneys’ billing practices; (2) the attorneys’ skill, experience, and reputation;

(3) and the prevailing market rates in the relevant community.” Salazar ex rel. Salazar v. District

of Columbia, 809 F.3d 58, 61–62 (D.C. Cir. 2015) (cleaned up). The Defendants challenge only

the third prong, specifically what fee matrix among those in existing case law to apply. Defs.’

Resp. at 4.

a. Fitzpatrick Matrix

“A court calculating a prevailing market rate allows fee applicants to submit attorneys’ fee

matrices as one type of evidence.” Salazar, 809 F.3d at 62. These matrices suggest hourly rates

based on years of attorney experience. See id. Here, the Plaintiffs urge the Court to apply the LSI

Laffey Matrix, while the Defendants advocate for the newer and less generous Fitzpatrick Matrix.8

See Defs.’ Resp. at 4.

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