On behalf of the States of Kansas and Nebraska, Boyden Gray & Associates filed the final briefs yesterday in a challenge to EPA’s new vehicular emissions model, MOVES2014. The States are required to use the computer model when they prepare State Implementation Plans for EPA’s air quality standards, but EPA did not give notice and accept comments on the model…
On July 2, Boyden Gray & Associates filed the Petitioners’ opening brief in Kansas v. EPA (D.C. Cir. No. 14-1268), challenging EPA’s new vehicular emissions model. In the challenged rule, which was promulgated without notice and an opportunity for comment, EPA requires States to use its new model, MOVES2014, in developing state implementation plans for compliance with National Ambient Air Quality Standards under the Clean Air…