Train v. Natural Resources Defense Council, Inc.
Headline: Court allows states and EPA to approve source-specific pollution variances through plan revisions, reversing a lower court and making it easier for states to grant limited variances that do not harm national air standards.
Holding:
- Lets states use plan revisions to approve source-specific pollution variances.
- Keeps strict postponement process for delays that would harm national deadlines.
- Increases EPA and state flexibility while preserving national air-quality goals.
Summary
Background
An environmental group and local residents challenged the EPA’s approval of Georgia’s air-quality plan. Congress required each State to submit plans to meet national outdoor air standards within set deadlines. Georgia adopted strict emission limits effective immediately but included a state law authorizing individual variances for particular factories or businesses. The Court of Appeals ordered the EPA to disapprove that variance procedure, and the EPA appealed to this Court.
Reasoning
The key question was whether individual, source-specific variances had to proceed only under the narrow postponement rule or could be approved as revisions to state plans. The Court examined the statute’s language, history, and how the Clean Air Act assigns roles to the national agency and the States. It concluded that the postponement provision is a limited safety valve for delaying national deadlines, while the plan-revision provision reasonably permits states to adopt variances so long as the revised plan still ensures attainment and maintenance of national air standards. The Court also emphasized deference to the EPA’s reasonable interpretation and reversed the Fifth Circuit’s disapproval of Georgia’s variance procedure.
Real world impact
States and the EPA can use the normal plan-revision process to approve narrowly tailored, source-specific variances when those variances will not prevent meeting national air standards. The stricter postponement procedure remains available for cases that would delay or weaken national attainment deadlines. The ruling affects State agencies, industrial sources seeking relief, environmental groups, and the EPA’s review role.
Dissents or concurrances
One Justice dissented. Justice Douglas disagreed with the majority; Justice Powell did not participate.
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