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Sierra Club v. Fri

In Sierra Club v. Fri, 344 F. Supp. 253 (D.D.C. 1972), affirmed, 4 ERC 1815 (D.C. Cir. 1972), affirmed by an equally divided Court, 412 U.S. 451 (1973), the Supreme Court held that the Clean Air Act requires that air quality in areas still having clean air must be protected from significant deterioration as well as that air quality must be improved in areas with heavily polluted air. As a result of this case, EPA issued regulations for the prevention of significant deterioration (PSD) of air quality in clean air areas and subsequently Congress included specific PSD provisions, based on these regulations, into the Clean Air Act itself.


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