CONFERENCE OF MAYORS; AND 18 CITIES, TOWNS, COUNTIES, AND MAYORS IN SUPPORT OF STATE AND LOCAL GOVERNMENT AND PUBLIC INTEREST PETITIONERS Michael Burger (counsel of record) Hillary Aidun Sabin Center for Climate Change Law Columbia Law School 435 W. [...] 13, 2021 CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES Except for those listed in the Identities and Interests section below, all parties, intervenors, and amici appearing in this case are listed in the briefs for State and Local Government and Public Interest Petitioners. [...] 13, 2021 IDENTITIES AND INTERESTS OF AMICI CURIAE The National League of Cities (NLC), founded in 1924, is the oldest and largest organization representing U. [...] Coastal communities are responding to the devastating effects of sea level rise, and the associated high costs of infrastructure corrosion and general disruption to daily life resulting from shrinking coastlines.4 In Annapolis, flooding events have increased 925% in the past 50 years, inflicting devastating revenue losses on the city and local businesses that depend on tourism in the coastal downt. [...] The SAFE Rule Frustrates Cities’ Efforts to Address and Adapt to Climate Change Cities are not only on the front lines of climate impacts—they are also at the forefront of climate change adaptation and mitigation efforts nationwide.
Authors
- Pages
- 42
- Published in
- United States of America
Table of Contents
- CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES 3
- STATEMENT REGARDING SEPARATE BRIEFING, 4
- AUTHORSHIP, AND MONETARY CONTRIBUTIONS 4
- CORPORATE DISCLOSURES 5
- TABLE OF CONTENTS 6
- TABLE OF AUTHORITIES 7
- GLOSSARY 12
- IDENTITIES AND INTERESTS OF AMICI CURIAE 13
- 1. Cities Are Already Grappling with the Effects of Climate Change. 14
- A. The SAFE Rule Frustrates Cities’ Efforts to Address and Adapt to Climate Change 19
- 2. Cities Are Overburdened By Criteria Pollutants Emitted by Vehicles. 23
- ARGUMENT 26
- 1. EPA Acted Arbitrarily and Capriciously by Failing to Consider the Need to Reduce Transportation Emissions to Address Climate Change. 26
- 2. EPA Acted Arbitrarily and Capriciously by Disregarding the Clean Air Act’s Purpose. 30
- 3. The Agencies Failed to Adequately Consider Local Governments' Reliance Interests. 33
- 4. The Agencies’ Environmental Justice Analysis is Arbitrary and Capricious 35
- CONCLUSION 40