UNITED STATES COURT OF APPEALS
For the District of Columbia Circuit
No. 23-1127
PETITIONER'S BRIEF ON THE MERITS
I. INTRODUCTION AND SUMMARY OF ARGUMENT
This Court should grant relief because the EPA's Final Rule relies on an impermissible expansion of its statutory authority. As established in Chevron U.S.A. Inc. v. NRDC, 467 U.S. 837 (1984), when a statute is ambiguous, courts must defer to the agency's reasonable construction. Petitioner's regulatory scheme squarely falls within this well-established framework for administrative deference.
Under Auer v. Robbins, 519 U.S. 452 (1997), the agency's interpretation of its own regulations must receive controlling weight unless plainly erroneous or inconsistent with the regulation. Furthermore, City of Arlington v. FCC, 569 U.S. 290 (2013) confirmed that Chevron deference extends to agency determinations of jurisdictional authority — a holding that reinforces broad deference to EPA's technical expertise in environmental regulation.
II. ARGUMENT
A. The EPA's Interpretation Merits Chevron Deference
The arbitrary-and-capricious standard of Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983) requires agencies to examine the relevant data and articulate a satisfactory explanation for their action including a rational connection between the facts found and the choice made. The EPA's rule meets this standard. See also FCC v. Fox Television Stations, 556 U.S. 502 (2009); Encino Motorcars v. Navarro, 579 U.S. 211 (2016).
B. Congressional Silence Does Not Limit Agency Authority
Where Congress has not directly addressed the precise question at issue, the agency's reasonable interpretation governs. The EPA's long-standing construction of the Clean Air Act reflects decades of consistent administrative practice and scientific expertise that this Court should respect. Under the principles established in Chevron, 467 U.S. at 843, such consistent agency interpretation is entitled to deference even in cases of apparent ambiguity. CONCLUSION: For the foregoing reasons, this Court should deny the petition for review and affirm the EPA's Final Rule.