Environmental Defense v. Duke Energy Corp., 549 U.S. 561 (2007)
Primary Holding
The Court held that the Environmental Protection Agency (EPA) must ensure that its Prevention of Significant Deterioration (PSD) regulations regarding "modification" conform to the definitions established in the New Source Performance Standards (NSPS), and that any judicial review of EPA regulations must comply with the restrictions set forth in the Clean Air Act.
In the case of Environmental Defense v. Duke Energy Corp., the Supreme Court decided that the Environmental Protection Agency (EPA) must follow specific rules when it comes to regulating air pollution from power plants, especially when those plants make changes that could increase pollution. This ruling is important because it helps ensure that the air we breathe is protected from harmful emissions, giving consumers more rights to expect cleaner air and better environmental standards. This case is relevant for consumers when they are concerned about air quality and pollution from nearby industrial facilities. It emphasizes that the EPA has to enforce strict regulations to limit air pollution, which ultimately helps protect public health and the environment.
AI-generated plain-language summary to help you understand this case
In the case of Environmental Defense v. Duke Energy Corp., the underlying dispute arose from the interpretation of the Clean Air Act's provisions regarding air pollution control, specifically concerning the definitions of "modification" under the New Source Performance Standards (NSPS) and the Prevention of Significant Deterioration (PSD) regulations. The Environmental Defense Fund, along with other petitioners, challenged Duke Energy Corporation's compliance with these regulations, asserting that the company had made modifications to its power plants that increased emissions without obtaining the necessary PSD permits. The case centered on whether the Environmental Protection Agency (EPA) was required to align its PSD regulations with the definitions provided in the NSPS. The procedural history of the case began when the Fourth Circuit Court of Appeals ruled that the EPA's PSD regulations must conform to the NSPS definitions of "modification." This ruling effectively invalidated the EPA's 1980 PSD regulations, leading to the petitioners seeking certiorari from the Supreme Court to review the appellate court's decision. The Supreme Court heard the case and issued its opinion on April 2, 2007, addressing the interpretation of the Clean Air Act and the authority of the EPA in regulating modifications to stationary sources of air pollution. The relevant background context includes the Clean Air Amendments of 1970, which expanded federal authority to combat air pollution and directed the EPA to establish National Ambient Air Quality Standards (NAAQS). These amendments introduced the NSPS and PSD provisions, which aimed to regulate both new and modified stationary sources of air pollution. The 1977 Clean Air Act Amendments further refined the PSD provisions, requiring permits for major emitting facilities in areas that needed additional air quality protection. The case highlights the complexities of environmental regulation and the interplay between statutory definitions and agency interpretations.
Whether the Environmental Protection Agency (EPA) is required to align its Prevention of Significant Deterioration (PSD) regulations on "modification" with the definitions provided in the New Source Performance Standards (NSPS) under the Clean Air Act.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 1, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Souter
- Damages Awarded
- N/A
- Data Quality
- high
National Assn. of Home Builders v. Defenders of Wildlife, 551 U.S. 644 (2007)
Consumer LostThe transfer of permitting authority under the Clean Water Act to state authorities does not require compliance with the consultation provisions of the Endangered Species Act, as Section 7(a)(2) of the ESA does not operate as an additional criterion for such transfers.
Massachusetts v. EPA, 549 U.S. 497 (2007)
Consumer WonThe Environmental Protection Agency (EPA) has the statutory authority under the Clean Air Act to regulate greenhouse gas emissions from new motor vehicles if it determines that such emissions may reasonably be anticipated to endanger public health or welfare.
S. D. Warren Co. v. Maine Bd. of Environmental Protection, 547 U.S. 370 (2006)
Consumer WonOperating a dam to produce hydroelectricity may result in a discharge into navigable waters, thus requiring state certification under §401 of the Clean Water Act to ensure compliance with water protection laws.
Rapanos v. United States, 547 U.S. 715 (2006)
Consumer LostThe Supreme Court held that the Clean Water Act's jurisdiction over "waters of the United States" is limited to relatively permanent, standing, or continuously flowing bodies of water, as well as wetlands that have a continuous surface connection to such waters, thereby rejecting the broader interpretation that included intermittent and ephemeral water bodies.