Chevron, U.S.A., Inc. v. NRDC, Inc.

467 U.S. 837

 

RULE:

Arguments regarding policies are better handled by legislators or administrators, not courts. In cases where agencies clash, the Administrator's interpretation represents a reasonable accommodation of competing interests and is entitled to deference over other interpretations. Though the regulatory scheme may be technical and complex, the agency considered the matter in a detailed and reasonable fashion, and is entitled to have its interpretation honored.

FACTS:

The Clean Air Act made requirements applicable to states that had not achieved national air quality standards established by the EPA. States that did not comply were allowed to establish permit programs regulating "stations sources" of air pollution, under strict conditions. The EPA's decision to allow States to treat all pollution-emitting devices within the same industry grouping as a single "bubble" was challenged by the defendant as an incorrect interpretation. The DC Circuit set the regulation aside, and plaintiff appealed the ruling.

ISSUE:

Whether the EPA's decision to treat all pollution-emitting devices within the same industry grouping as a single "bubble" was based on a reasonable construction of the term "stationary source?"

ANSWER:

Yes, the EPA's decision to treat all pollution-emitting devices within the same industry grouping as a single "bubble" was based on a reasonable construction of the term "stationary source."

CONCLUSION:

In reversing the lower court's ruling, the Supreme Court held that the EPA's definition of "source" is a permissible construction of the statute which seeks to accommodate progress in reducing air pollution and economic growth. The EPA consistently viewed the term flexibly, and in the context of implementing policy decisions, it had maintained that definition. The DC Circuit, not the EPA, read the statute inflexibly, and it was an error for them to do so. The EPA, and not the DC Circuit, should have been able to attest to what the statute should mean, and how it should be construed.

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