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Sixth Circuit Holds Clean Air Act Requires Compliance with RACT even where Attainment Application is Pending
In a recent decision by the United States Court of Appeals for the Sixth Circuit, Sierra Club v. EPA, Nos. 23-3581/3583 (6th Cir. Dec. 5, 2025), the Court invoked its statutory interpretation authority to hold that EPA contravened the plain language of the Clean Air Act (“CAA”) by redesignating the Detroit area as in attainment with the 2015 ozone National Ambient Air Quality Standards (“NAAQS”). Conversely, the Court deferred to EPA’s technical expertise in determining that certain air emissions should be excluded from consideration of the Detroit area’s compliance with the ozone NAAQS because of their qualification as “exceptional events” under the CAA, demonstrating that Courts will continue to defer to agencies’ expertise, but will not defer to agency interpretations of their enabling statutes.
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