Center for Biological Diversity v. EPA, No. 11-1101 (D.C. Cir. 2013)
Annotate this CaseEnvironmental groups petitioned for review of the EPA's "Deferral Rule," which deferred regulation of biogenic carbon dioxide for three years. The EPA justified this Deferral Rule on the basis of the de minimis, one-step-at-a-time, and administrative necessity doctrine. Concluding that the dispute was ripe for review, the court rejected the EPA's use of the de minimus doctrine where EPA expressly disavowed this doctrine, explaining that the Deferral Rule had a three-year sunset provision whereas the de minimis doctrine was used to establish permanent exemptions; the EPA's invocation of the one-step-at-a-time doctrine was arbitrary and capricious where the EPA failed to explain in the Deferral Rule what "full compliance" with the "statutory mandate" means; the court rejected the administrative necessity doctrine where the EPA rejected a proposed middle-ground option; and the court rejected the absurd results doctrine that the EPA raised for the first time in its brief. Accordingly, the court granted the petition for review.
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