The brief urges the Ninth Circuit to hold that a letter issued by EPA—which reversed statutory interpretations and a regulatory safe harbor that EPA had announced three months earlier—is judicially reviewable final agency action and is inconsistent with Section 328 of the Clean Air Act.
Thomas A. Lorenzen, Elizabeth B. Dawson, and Siyi Shen of Crowell & Moring LLP and the U.S. Chamber’s Litigation Center served as co-counsel for the U.S. Chamber.
