The Clean Air Act's New Source Review provisions require power plants and other large facilities to meet modern pollution control standards whenever they make physical or operational changes that cause them to emit additional air pollution. EPA issued rules in 2002 and 2003 that would undermine the important air quality protections provided by the NSR program. The Clean Air Task Force has sued the Agency to prevent these rollbacks from taking effect.
Enforcing NSR
After a long investigation found that many old coal-fired power plants were not complying with NSR, EPA initiated a broad enforcement action in 1999. In conjunction with the Clean Air Task Force, other environmental groups and a variety of states, EPA sued numerous power companies for rebuilding their aging plants without installing modern pollution controls. Several of the lawsuits have been settled as power companies have agreed to reduce annual emissions of sulfur dioxide and nitrogen oxides by approximately one million tons. The Clean Air Task Force represents a collection of citizen groups in the two largest enforcement cases.
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CATF, Partners Reach Record Settlement in Case Against AEP
October 9, 2007
CATF and its partner organizations have joined with EPA and eight states to settle their new source review case against American Electric Power. The agreement is the single largest legal settlement in US history in terms of the air pollution reductions that will be achieved, and requires AEP to install $4.6 billion worth of pollution controls, fund $60 million worth of environmental mitigation projects, and pay a civil fine of $15 million.
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United States v. American Elec. Power Serv. Corp., 137 F.Supp. 2d 1060 (S.D. Ohio 2001)
(rejecting AEP's motion to dismiss the NSR enforcement suit brought by EPA, states, and several citizen groups including CATF)
October 2003 NSR Rule
Under the Clean Air Act's NSR provisions, a facility must install modern pollution controls when it makes a physical or operational changes that result in additional air pollution. EPA's October 2003 Rule attempted to excuse power plants and other major emitters from having to upgrade their pollution controls as long as the changes in question cost less than 20% of the replacement value of the facility. That would have amounted to an enormous loophole. On March 17, 2006, the Clean Air Task Force, other citizen groups, and numerous state and local governments, won an unanimous decision from the DC Circuit that permanently invalidates the exemption.
DC Circuit Strikes Down 2003 NSR Rule
March 17, 2006
Reconsideration Comments on October 2003 NSR Rule
August 30, 2004
Petition for Reconsideration of October 2003 NSR Rule
December 24, 2003
Court Order Granting Stay Pending Review
December 24, 2003
Reply in Support of Stay Motion
December 12, 2003
Motion for Stay Pending Review
November 17, 2003
Supplemental Comments on Proposed Rule
August 26, 2003
Administrative Comments on Proposed Rule
May 2, 2003
December 2002 NSR Rule
EPA's December 2002 Rule created new methods for calculating baseline emissions and post-change emissions, allowed the use of "plantwide applicability limits," and carved specific exemptions for "pollution control projects" and "clean units" -- all of which can be used by industrial facilities and power plants to avoid New Source Review while making phyiscal or operational changes.
CATF represented several environmental groups in a challenge to the December 2002 Rule's legality. On June 24, 2005, the U.S. Court of Appeals for the D.C. Circuit struck down several aspects of the rule and reaffirmed the program's focus on actual emissions (rather than potential emissions).
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State of New York v. EPA (D.C. Cir. 2005)
June 24 2005
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CATF Press Release on DC Circuit Decision
June 24 2005
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Reply Brief
September 20 2004
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Intervenor Response Brief
August 30 2004
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NSR Opening Brief
May 11 2004
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EPA's New Source Review Rules Massacre: The Environmentalists' Perspective
Briefing presented by Ann Weeks to the Boston Bar Association on November 17, 2003
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Comments on Notice of Reconsideration of NSR Rule, 68 Fed. Reg. 44620
Detailed comments on EPA's Reconsideration of several aspects of the NSR rule that was finalized by the Agency in December 2002. These comments were filed on August 29, 2003, by CATF and other organizations as counsel to the environmental and public health groups that are litigating the final rule.
