TOPICS·SUSTAINABILITY·42 U.S.C. §7401 et seq.

US EPA & Clean Air Act

The cornerstone of American air quality regulation since 1970, now undergoing its most significant rollback in history. Track EPA deregulation, landmark litigation, NAAQS standards, and the widening gap between federal and state enforcement.

US FEDERAL8 ROLLBACKS1918 regulations tracked7 landmark casesUpdated April 2026
THE ESSENTIALS

The Clean Air Act is the main federal law that controls air pollution in the United States. Passed in 1970 and strengthened in 1990, it gives the Environmental Protection Agency the power to set limits on harmful pollutants -- things like soot, smog-forming chemicals, mercury, and carbon dioxide -- and to require factories, power plants, and vehicles to meet those limits. For more than fifty years, this law has been the reason American air got steadily cleaner.

That trajectory changed sharply in 2025. The Trump administration began rolling back Clean Air Act protections at a pace and scale not seen before. The most consequential action came in February 2026, when the EPA formally rescinded its finding that greenhouse gases endanger public health -- the legal foundation for every federal climate regulation. Without that finding, all federal limits on carbon dioxide emissions from cars, trucks, and power plants have been eliminated.

The federal pullback has created a split between Washington and the states. California and roughly two dozen other states are fighting the rollbacks in court and maintaining their own, stricter air quality programmes. For businesses, this means the regulatory landscape depends heavily on where you operate: companies in states like California, New York, and Washington face rules as strict or stricter than the federal standards that existed a year ago, while companies in states aligned with the federal position face significantly less oversight.

The litigation will take years to resolve, and some rollbacks may ultimately be blocked by the courts. In the meantime, the practical advice for any company subject to air quality regulation is straightforward: understand which states you operate in, track both federal and state rules, and do not assume that reduced federal enforcement means reduced legal risk.

What
US federal legislation authorising the EPA to regulate air pollutant emissions from stationary and mobile sources. The 2025-2026 Trump administration has rescinded the Greenhouse Gas Endangerment Finding, eliminating the legal basis for climate-related regulation.
Who
All operators of facilities emitting regulated pollutants, vehicle manufacturers, fuel producers, and importers. State governments implementing SIPs. 17 Section 177 states following California standards.
When
Enacted 1970, amended 1990. Now in a period of unprecedented regulatory reversal. Key litigation over Endangerment Finding and California waiver expected to resolve 2026-2027.
Penalty
Civil penalties up to USD 25,000 per day per violation remain on the books. Criminal penalties including imprisonment for knowing violations. State penalties vary and may exceed federal levels.

The Trump administration has targeted 31+ environmental rules for rollback. Below are the most significant Clean Air Act actions taken or proposed since January 2025.

From Massachusetts v. EPA to the Endangerment Finding challenge, the Clean Air Act's scope has been shaped as much by courts as by Congress.

DECIDEDU.S. Supreme Court
Massachusetts v. EPA
CO2 is an air pollutant under the Clean Air Act; EPA must regulate if it endangers health
Established foundational legal basis for all EPA greenhouse gas regulation.
DECIDEDU.S. Supreme Court
West Virginia v. EPA
EPA cannot mandate generation-shifting; "major questions doctrine" limits agency power
Constrained EPA to facility-level standards, blocking sector-wide decarbonization mandates.
DECIDEDU.S. Supreme Court
Sackett v. EPA
Narrowed "waters of the United States" definition under Clean Water Act
Reduced federal jurisdiction over wetlands; signaled Court skepticism of broad EPA authority.
DECIDEDU.S. Supreme Court
Loper Bright v. Raimondo
Overturned Chevron deference; courts no longer defer to agency statutory interpretations
Fundamentally weakened all federal agencies' rulemaking authority, including EPA's.
DECIDEDU.S. Supreme Court
Diamond Alternative Energy v. EPA
Allowed EPA power plant emissions rule to stand during litigation
Power plants need not comply for 6-8 years; moot now given Trump EPA reconsideration.
PENDINGN.D. California
California v. United States (Waiver CRA)
California and 10 other states challenge Congressional Review Act nullification of three Clean Air Act waivers
Tests whether CRA -- designed for agency rules -- can be used to revoke adjudicatory waiver orders. First-ever CRA challenge of this kind.
FILEDFederal District Court
California v. EPA (Endangerment)
24 state AGs + 10 cities challenge rescission of Endangerment Finding
Most consequential environmental lawsuit in decades; could restore or permanently end federal GHG regulation.

The six criteria pollutants regulated under the Clean Air Act. NAAQS form the backbone of air quality regulation -- states must develop plans to meet these standards.

PM2.5
Particulate Matter (fine)
STANDARD9 ug/m3 (primary annual)
AVERAGINGAnnual mean
ROLLBACK PROPOSED
Cardiovascular and respiratory disease, premature death
O3
Ozone
STANDARD0.070 ppm
AVERAGING8-hour
STABLE
Lung inflammation, asthma attacks, reduced lung function
CO
Carbon Monoxide
STANDARD9 ppm / 35 ppm
AVERAGING8-hour / 1-hour
STABLE
Reduced oxygen delivery to organs and tissues
SO2
Sulfur Dioxide
STANDARD75 ppb
AVERAGING1-hour
STABLE
Respiratory effects, aggravation of asthma
NO2
Nitrogen Dioxide
STANDARD100 ppb / 53 ppb
AVERAGING1-hour / Annual
STABLE
Airway inflammation, worsened respiratory symptoms
Pb
Lead
STANDARD0.15 ug/m3
AVERAGINGRolling 3-month
STABLE
Neurological damage, especially in children

The Clean Air Act operates on cooperative federalism: EPA sets standards, states implement them. As federal enforcement retreats, a patchwork of state responses is emerging.

DIMENSIONFEDERAL (EPA)STATE
Primary authorityEPA under Clean Air Act Sections 113, 120State environmental agencies under delegated authority and SIPs
Inspection powerEPA can inspect any regulated source; consent decree authorityStates conduct ~90% of all inspections under cooperative federalism
Penalty authorityUp to $25,000/day/violation (civil); criminal penalties for knowing violationsVaries by state; often matches or exceeds federal penalty levels
GHG regulationEndangerment Finding rescinded (Feb 2026); no new GHG rules expectedCalifornia, 16 other states maintain independent GHG programs
Vehicle standardsGHG vehicle standards eliminated; traditional pollutant standards remainCalifornia waivers nullified via CRA; litigation pending; Section 177 states affected
Citizen suitsClean Air Act Section 304 allows suits against violators and EPAMany states have parallel citizen suit provisions
Current postureDeregulatory; 31+ rules targeted for rollbackAggressive enforcement in blue states; aligned with federal rollbacks in red states

As federal EPA retreats from Clean Air Act enforcement, states are diverging sharply. Below is a sample of state positions as of April 2026.

Independent enforcement Mixed approach Federal-aligned
CA
California
Independent enforcement
Leading waiver litigation; independent GHG programs
NY
New York
Independent enforcement
Climate Leadership and Community Protection Act
MA
Massachusetts
Independent enforcement
Clean Energy & Climate Plan; Section 177 state
WA
Washington
Independent enforcement
Climate Commitment Act cap-and-invest
OR
Oregon
Independent enforcement
Climate Protection Program
CO
Colorado
Independent enforcement
GHG reduction roadmap; ozone non-attainment measures
CT
Connecticut
Independent enforcement
Section 177 state; RGGI participant
MN
Minnesota
Independent enforcement
100% clean electricity by 2040 law
PA
Pennsylvania
Mixed approach
RGGI participation contested; industrial state tensions
MI
Michigan
Mixed approach
Clean energy standards adopted; auto industry ties
NC
North Carolina
Mixed approach
Clean energy plan; bipartisan approach
VA
Virginia
Mixed approach
Withdrew from RGGI; moderate enforcement
TX
Texas
Federal-aligned
Supports federal deregulation; independent grid
WV
West Virginia
Federal-aligned
Plaintiff in West Virginia v. EPA; pro-coal policies
LA
Louisiana
Federal-aligned
Petrochemical corridor; industry-aligned enforcement
OH
Ohio
Federal-aligned
Rolled back clean energy standards

How the current regulatory landscape affects different industries under the Clean Air Act.

KEY REGULATORY CHANGES
Mercury/MATS exemptions for 68 coal plants
Power plant GHG standards under reconsideration
West Virginia v. EPA limits EPA to facility-level standards
PM2.5 standard rollback reduces attainment obligations
OUTLOOK

Significant regulatory relief for coal and gas generators in the near term. However, state-level policies and market economics continue to drive coal plant retirements.

Apr 23, 2026
YOU ARE HERE

Despite ongoing rollbacks, the core Clean Air Act permitting and monitoring framework remains in force. These requirements continue to apply.

01
Operating permits
Obtain Title V operating permits for major sources and ensure all emission limits and monitoring requirements are met.
02
National standards compliance
Meet National Ambient Air Quality Standards (NAAQS) for criteria pollutants: ozone, PM, CO, NOx, SO2, and lead.
03
New Source Review
Obtain pre-construction permits and install Best Available Control Technology for new or modified major sources.
04
Hazardous air pollutants
Comply with Maximum Achievable Control Technology (MACT) standards for 187 listed hazardous air pollutants.
05
Emissions reporting
Report annual emissions to EPA through the Toxics Release Inventory and Greenhouse Gas Reporting Program.
06
Mobile source standards
Meet tailpipe emission standards and fuel quality requirements for vehicles and engines.

Select your company type for tailored compliance guidance.

KEY OBLIGATIONS
Obtain and maintain Title V operating permits for major sources
Install Best Available Control Technology (BACT) for new or modified sources
Monitor and report emissions under Continuous Emissions Monitoring requirements
Comply with NESHAP for hazardous air pollutant emissions
YOUR FIRST STEP

Review your Title V permit conditions and ensure all monitoring, reporting, and compliance requirements are current