Today's Big Environmental Decisions:

Today was Clean Air Act day at the Supreme Court, as the justices issued two long-awaited opinions in cases involving the scope of the EPA's power under the Clean Air Act.

The marquee case was Massachusetts v. EPA, in which the Court held, 5-4, that (a) states have standing to sue the EPA alleging injuries from climate change, (b) the EPA has the authority to regulate greenhouse gases as "pollutants" under the Clean Air Act, and (c) the EPA did not adequately justify its decision not to regulate greenhouse gas emissions from motor vehicles under the Act. On remand, the EPA must ground its decision whether to regulate greenhouse gas emissions on the nature and magnitude of the risk posed by climate change, as the CAA requires.

As longtime readers know, I disagree with the Court's first two conclusions. I do not believe that the petitioners had standing (as argued by Chief Justice Roberts in his dissent), nor do I believe that Congress delegated the EPA authority to regulate greenhouse gases. Given that the Court concluded otehrwise on these two points, however, I think it is very difficult to argue, as the EPA did, that the EPA declined to exercise its regulatory authority on statutorily permissible grounds. I will have more to say about the case once I've had a chance to read all of the opinions.

The Supreme Court also issued its opinion in Environmental Defense v. Duke Energy unanimously siding with the EPA's interpretation of the New Source Review provisions of the Clean Air Act. I blogged about the case here, and I hope to have more to say about this case later today as well.

Anderson (mail):
Another example, to judge by Prof. Adler's link, that predicting a case by how the oral argument seemed to go is a risky undertaking.
4.2.2007 1:47pm
Richard Fagin (mail):
The decision in Massachusetts v. EPA is a monumentally bad one for constitutional law. Granting standing to a state that can show no particularized injury opens the Federal courts to resolving what are at bottom political disputes. The Federal courts were not and are not consitutionally empowered to resolve such disputes. All manner of people unhappy with the way their elected officials (even Congress) handle matters will be open to judicial review. What's next, the courts telling Congress what they must or must not legislate? Federal courts have already exercised such power over states and their political subdivisions.
4.2.2007 1:50pm
Houston Lawyer:
Does the EPA regulate smoking? Clearly it should if it must regulate CO2 emissions or at least justify why it doesn't. Since the law is in effect, a change of administrations could put Al Gore in charge of the EPA with almost carte blanche to regulate all emissions.
4.2.2007 1:57pm
Salaryman (mail):
What I can't understand (aside from how Massachusetts has standing) is why environmental advocacy groups aren't pestering the EPA to require that all American cattle be force-fed the anti-flatulence elixir Beano. Methane (a primary component of cow-farts) has been estimated to comprise up to 15% of anthropogenic greenhouse gas emissions. Moreover, given Justice Stevens' well known enthusiasm for the efficacy of Beano, any suit seeking to compel such a result would undoubtedly find favor with the federal courts. God knows they'd have no trouble alleging standing.
4.2.2007 2:30pm
Scotus Watcher (mail):
Massachusetts is claiming that its coasts will be flooded. This is a ripe controversy, in the sense that the legal issues are developed and the opinion will not be advisory. I find it hard to believe that this is not a "case or controversy." The requirement that the injury must be particularized is an extratextual requirement that makes very little sense to me (and is met in this case anyway; different states will be affected in different ways).

If the Founders were told that a State thought that the Federal Government's lawlessness was causing the State grave injury to its economy, and that an opinion would not be advisory and would force prompt federal action, do you really think the Founders have held that there is no "case" and no "controversy" at stake? Seems implausible.
4.2.2007 2:35pm
Anon 2L:
Reading the Chief's dissent I couldn't help but think he was influenced by your Cato amicus brief. So you've got that going for you, which is nice.
4.2.2007 2:36pm
Sigivald (mail):
Scotus: A grave injury such as you postulate has not, of course, actually happened, is the problem.

There is some thought that it might, possibly (though the most plausible estimates for the next century are at most, what, a foot and a half of sea-level rise? Please.) ... but the real problem comes even beyond that - US CO2 isn't the primary cause of any of it.

Asking for a non-remedy to a theoretical future harm is not much of a case, nor a controversy, is it?

Of course, Congress could fix all this in a few hours, should it desire to. Possibly it will; this Pandora's Box gores oxen all over the country, to very little particularized benefit even if the assumptions are correct.
4.2.2007 2:59pm
Clayton E. Cramer (mail) (www):
Does EPA's authority extend to cattle, termites, pets, and people? All of them produce CO2, and as others have noted, methane as a greenhouse gas is even more serious than CO2, and produced in large quantities by ruminants and termites--and your pet cat, and you, and your children. Can EPA regulate the amount of CO2 I produce? Can some clever lawyer figure out a way to use this as a basis for limiting the number of children you are allowed to have?

Ordinarily, I wouldn't worry about this going down the slippery slope to that level of regulatory control, but environmentalists aren't exactly noted for their lack of extremism when it comes to control the lives of others.
4.2.2007 4:36pm
Tom Holsinger (mail):
Clayton,

I was wondering about the latter myself. Given that only human emissions of C02, direct and indirect, can be controlled, the most efficient way to reduce those is with mandatory abortions enforcing strict birth control limits.
4.2.2007 5:50pm
Max Parrish (mail):
At this point I am more concerned about the distinction between the power to regulate (which the EPA now has) vs. a mandate to regulate.

Adler said "On remand, the EPA must ground its decision whether to regulate greenhouse gas emissions on the nature and magnitude of the risk posed by climate change, as the CAA requires."

If risk is a primary consideration, then there is little doubt that the global warming MIGHT have a huge impact on global climate (although it's local effects might be uncertain). Does the CAA mandate imposing serious regulation irrespective of costs and/or benefits? Does the CAA permit consideration of the US benefits vs. the that of the world? This is a case where the benefits of regulation are diluted by global pollution - unlike typical local impact pollution most human caused CO2 is generated outside the United States, and projections are that the US will continue to decline in its contribution as India and China develop.

Does SCOTUS intend to 'make' the Republic regulate its own emissions, regardless of social/economic costs or the diluted benefits?
4.2.2007 11:58pm
Lev:

Does SCOTUS intend to 'make' the Republic regulate its own emissions, regardless of social/economic costs or the diluted benefits?


It depends on whether five of the superannuated geezers feel Algore's movie is actually a documentary with real facts.
4.3.2007 1:24am