The D.C. Circuit Does it Again! Why Should EPA Even Bother to Propose CAA Rules?

Partner Richard Stoll contributed an article to the American College of Environmental Lawyers, “The D.C. Circuit Does it Again! Why Should EPA Even Bother to Propose CAA Rules?” on August 10, 2015. The article discussed the rationale used by the D.C. Circuit for two recent rulings related to the Clean Air Act, the Mexichem opinion of May 2015 and the “Transport Rule” decision from August 2015.