Little Manila Rising v. United States Environmental Protection Agency

ELR Citation: 56 ELR 20018
No(s). 24-6990 (9th Cir. Feb 24, 2026)

In an unpublished opinion, the Ninth Circuit, 2-1, granted environmental groups' challenge to EPA's final rule granting California a one-year extension for the San Joaquin Valley's "five percent plan" to attain the 1997 annual NAAQS for fine particulate matter. The court concluded the extension was permitted under the CAA, but that an EPA regulation nonetheless prohibited it. It granted the petition and remanded without vacatur.

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