IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

NATIONAL PARKS CONSERVATION ASSOCIATION ) 

1300 19th Street NW, Suite 300 ) 

Washington, DC 20036 ) 

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SIERRA CLUB ) . 

85 Second Street, Second Floor ) 

San Francisco, CA 94105-3441 ) 

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MONTANA ENVIRONMENTAL INFORMATION CENTER ) 

PO Box 1184 ) 

Helena, MT 59624 ) 

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ENVIRONMENTAL DEFENSE FUND ) 

257 Park Avenue South, 17th Floor ) 

New York, NY 10010 

GRAND CANYON TRUST 

2601 N. Fort Valley Rd 

Flagstaff, AZ 86001 

SAN JUAN CITIZENS ALLIANCE 

P.O. Box 2461 

1022 112 Main Avenue 

Durango, Colorado 81302 

OUR CHILDREN'S EARTH FOUNDATION 

3701 Sacramento S1. # 194 

San Francisco, CA 94118 

PLAINS JUSTICE 

2606 Montana A venue 

Billings, Montana 59101 

POWDER RIVER BASIN RESOURCE COUNCIL 

934 N. Main St., 

Sheridan, WY 82801 

Plaintiffs, 

v. 

Case: 1: 11-cv-01S48 

Assigned To: Jackson, Amy Berman 

Assign. Date. 8/29/2011 

Description: Admn. Agency Review 

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UNITED STATES ENVIRONMENTAL ) 

PROTECTION AGENCY ) 

Ariel Rios Building ) 

1200 Pennsylvania Avenue, NW ) 

Washington, DC 20460 ) 

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LISA P. JACKSON, in her official capacity as Administrator, ) 

United States Environmental Protection Agency ) 

Ariel Rios Building ) 

1200 Pennsylvania Avenue, NW ) 

Washington, DC 20460 ) 

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Defendants. ) 

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF 

INTRODUCTION 

1. By January 15,2011, the Administrator of the United States Environmental 

Protection Agency ("Administrator" or "EPA") was required by the federal Clean Air Act to 

have promulgated complete, final, and enforceable plans for 34 states and territories that failed to 

submit timely plans to prevent and remedy unhealthful, scenery-impairing air pollution ("haze") 

in our nation's "Class I" national parks and wilderness areas. 74 Fed. Reg. 2392 (January 15, 

2009). EPA did not meet that deadline, or deadlines for acting on haze plans submitted by nine 

other states and one region. EPA's failure to meet these deadlines compounds a long line of 

delays by the agency in addressing regional haze that stretches back to at least 1979. That is the 

year when EPA was required by the Clean Air Act to have promulgated regulations to make 

"reasonable progress" towards "remedying ... existing visibility impairment" in mandatory 

Class I areas. 42 U.S.C. § 7491(a)(4). 

2. This action seeks orders compelling EPA to perform its nondiscretionary duties 

by date or dates certain to: a) promulgate federal implementation plans ("FIPs") for 34 states 

covered by EPA's January 15,2011 promulgation deadline to reduce haze in federal national 

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parks and wilderness areas; and b) take final action approving or disapproving regional haze state 

implementation plans ("SIPs" "plans" or "haze plans") for nine states and one region that 

submitted such SIPs and for which EPA approval or disapproval action is overdue under the 

Act.' EPA's failure to perform these duties violates controlling and explicit deadlines set forth in 

the Act, and thereby deprives Plaintiffs' members of health, welfare, and procedural protections 

required by the Act. 

JURISDICTION AND VENUE 

3. The instant action arises under the Clean Air Act ("CAA" or "the Act"), 42 

U.S.C. §§ 7401 et seq. This Court has jurisdiction over this action pursuant to 42 U.S.C. § 7604 

and 28 U.S.C. §§ 1331 and 1361. The relief requested herein by Plaintiffs is authorized pursuant 

to 42 U.S.C. § 7604 and 28 U.S.C. §§ 2201,2202, and 1361. 

4. In accordance with 42 U.S.C. § 7604(b)(2) and 40 C.F.R. Part 54, Plaintiffs 

served prior notice on the Administrator of the violations alleged herein and Plaintiffs' intent to 

initiate the present action. This notice was provided via certified letters, posted January 19, 

2011, and addressed to the Administrator. More than 60 days have passed since the notices were 

served pursuant to 42 U.S.C. § 7604(b), and the violations complained of in the notices are 

continuing. 

5. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 (e) because Defendant 

Lisa P. Jackson is an officer of the United States sued for acts and omissions in her official 

capacity, and her official residence is in the District of Columbia. 

, Unless otherwise indicated, references herein to "regional haze plans," "regional haze SIPs," 

"haze SIPs," or "haze plans" refer to the regional haze state implementation plans required by the 

Act and EPA rules to be submitted to EPA by December 17,2007. 42 U.S.C. § 7407(d)(7)(A); 

40 C.F.R. §§51.308 & 51.309. 

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PARTIES 

6. Plaintiff National Parks Conservation Association ("NPCA") is a national not-forprofit corporation organized and existing under the laws of the District of Columbia with its 

principal place of business in Washington, D.C. Its mission is to protect and enhance America's 

National Parks for the use and enjoyment of present and future generations. Since NPCA was 

established in 1919, it has advocated for protection of the natural environment (including air 

quality) in and around the national parks, educated decision makers and the public about the 

importance of preserving the parks, worked to convince officials in the Executive Branch and 

members of Congress to uphold the laws that protect the public's use and enjoyment of the parks 

and to support new legislation to address threats to the parks, litigated to uphold these laws, and 

assessed the health of the parks and adequacy of park management to better inform the public 

and advocate for parks. 

7. Plaintiff Montana Environmental Information Center is a non-profit 

environmental organization that works to protect clean air, water, and a healthy environment for 

all Montanans. The Center is headquartered in Helena, Montana. 

8. Plaintiff Grand Canyon Trust is a non-profit, regional conservation organization 

dedicated to conserving the natural and cultural resources of the Colorado Plateau. The Trust 

advocates an ecologically responsible and sustainable balance between resource use and 

preservation, along with the protection of areas of beauty and solitude. The Trust recognizes that 

clear air and vast panoramas are defining characteristics of the Colorado Plateau, and has been 

involved in air quality issues since its founding in 1985. The Trust is headquartered in Flagstaff, 

Arizona. 

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9. Plaintiff San Juan Citizens Alliance is a grass roots organization dedicated to 

social, economic, and environmental justice in the San Juan Basin of Colorado and New Mexico. 

The Alliance helps citizens protect the water and air, public lands, rural character, and unique 

quality ofIife in the San Juan Basin, while embracing the diversity of the region's people, 

economy, and ecology. San Juan Citizens Alliance is headquartered in Durango, Colorado. 

10. Plaintiff Our Children's Earth Foundation ("OCEF") is a non-profit organization 

dedicated to protecting the public from the harmful effects of air and water pollution. Through a 

combined strategy of enforcement, education, and advocacy, OCEF empowers individuals, 

families and local communities to participate in decisions that impact air and water quality. 

OCEF is based in San Francisco, California. 

11. Plaintiff Plains Justice is a non-profit organization based in Montana that provides 

legal resources to help communities in the Northern Plains make the transition to a new energy 

future. Plains Justice fights for a healthy and productive environment. 

12. Plaintiff Powder River Basin Resource Council ("Powder River") is a Wyoming 

non-profit organization dedicated to the preservation and enrichment of Wyoming's agricultural 

heritage and rural lifestyle. Powder River and its members support the conservation of 

Wyoming's unique land, mineral, water, and clean air resources consistent with responsible use 

of those resources to sustain the livelihood of present and future generations. Powder River is 

headquartered in Sheridan, Wyoming. 

13. Plaintiff Sierra Club ("the Club") is a not-for-profit corporation organized and 

existing under the laws of California, with its principal place of business located in San 

Francisco, California. Sierra Club is a national membership organization with more than 

600,000 members residing throughout the United States. Club members reside in each of the 

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States as defined in 42 U.S.C. §7602(d) (hereinafter, "States"). The Club's mission is to protect 

and enhance the quality of the natural and human environment. Its activities include public 

education, advocacy, and litigation to enforce environmental laws. The Club and its members 

are greatly concerned about the effects of air pollution on human health and the environment and 

have a long history of involvement in activities related to air quality. 

14. Plaintiff Environmental Defense Fund (EDF) is a not-for-profit corporation 

organized and existing under the laws of New York, with its principal place of business in New 

York, New York. EDF is a national membership organization with more than 400,000 members. 

EDF members reside in each of the States. EDF's mission is to protect the environmental rights 

of all people, including the rights to clean air and water and a flourishing ecosystem. Since the 

organization was founded in 1967, a key aspect ofEDF's mission has been to advocate control 

of air pollution for the benefit of human health and the environment. EDF and its members are 

greatly concerned about the effects of air pollution on human health and the environment, and have 

a long history of involvement in activities related to air quality. 

15. The Act requires the regional haze SIPs and FIPs at issue herein ("haze plans") to 

remedy and protect against any existing and future human-caused visibility impairment in 

specified national parks, wilderness areas, wildlife refuges, and o$er areas designated by the Act 

and EPA rules as mandatory "Class I" Federal areas. Plaintiffs' members use and enjoy these 

Class I areas throughout the nation for recreation and aesthetic enjoyment, including enjoyment 

of the scenic vistas. These areas suffer from visibility impairment due to human-caused air 

pollution and/or are threatened with future visibility impairment due to human-caused air 

pollution. Human-caused air pollution in or from each of the states at issue herein causes or 

contributes (and/or may reasonably be anticipated to cause or contribute) to visibility impairment 

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in Class I areas used and enjoyed by Plaintiffs' members. Plaintiffs' members' use and 

enjoyment of these areas is adversely affected by the visibility impairment that the Act requires 

regional haze plans to remedy and protect against. 

16. The acts and omissions of EPA complained of herein cause injury to Plaintiffs and 

their members by delaying the adoption, submission, review, approval or promulgation, and 

implementation of plans required by the Act to remedy and protect against visibility impairment 

adversely affecting use and enjoyment of Class I areas by Plaintiffs' members. These delays 

cause injury to Plaintiffs' members by prolonging existing, and allowing future, visibility 

impairment that significantly interferes with Plaintiffs' members' use and enjoyment of Class I 

areas, and by nullifying or delaying measures mandated by the Act to remedy and prevent such 

visibility impairment. The recreational, aesthetic, and environmental interests of Plaintiffs' 

members have been and continue to be adversely affected by the acts and omissions of EPA alleged 

herein. 

17. The acts and omissions of EPA alleged herein further deprive Plaintiffs and their 

members of procedural rights and protections to which they would otherwise be entitled, including, 

but not limited to, the right to comment on and judicially challenge the adequacy of regional haze 

plans (and EPA action thereon), and the right to ensure EPA effectuates its statutory duty to 

promulgate federal implementation plans to address state planning deficiencies. 

18. EPA approval of a regional haze SIP renders the provisions of that SIP federally 

enforceable via both EPA action and citizen suits. EPA disapproval of a regional haze SIP would 

trigger a two-year statutory deadline for the Administrator to prepare a FIP to implement the Act's 

requirements for a regional haze plan in that state. 42 U.S.C. § 741O(c)(1). EPA's failure to timely 

approve or disapprove regional haze SIPs as complained of herein thereby causes an indefInite 

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delay that thwarts Plaintiffs' and their members' rights, to which they would otherwise be entitled, 

to comment on, be protected by, enforce, and (if necessary) challenge in court the adequacy of 

regional haze state implementation plans required by the Act, and to compel EPA to carry out its 

responsibility to issue federal implementation plans where state plans are disapproved. 

19. The acts and omissions alleged herein further deprive Plaintiffs and their members 

of information to which they would otherwise have access, specifically formal published findings 

by EPA on whether regional haze SIPs do or do not meet all the Act's requirements and formal 

published determinations (in connection with promulgation of regional haze FIPs) of the measures 

that are needed to implement the Act's regional haze requirements in the relevant states. If 

Plaintiffs and their members had access to such information, they would use it to educate the public 

about air pollution throughout the nation and to advocate for adoption of measures to remedy and 

protect against regional haze in Class I areas. EPA's failure to produce such information deprives 

Plaintiffs and their members of these benefits and thus causes them injury. 

20. For all the foregoing reasons, the failures complained of herein cause Plaintiffs 

and their members injuries for which they have no adequate remedy at law. Granting the 

requested relief would redress these injuries. 

21. Defendant Lisa P. Jackson is the Administrator of the United States 

Environmental Protection Agency and is charged with the task of taking various actions to 

implement and enforce the Clean Air Act, including those actions sought herein. Defendant 

Jackson is sued in her official capacity, and she officially resides in Washington, D.C. 

22. Defendant United States Environmental Protection Agency is the federal agency 

charged with implementation of the Clean Air Act. 

BACKGROUND & FACTS 

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EPA's FIP Obligations 

23. Section 11O(c) of the Clean Air Act, 42 U.S.C. § 7410(c), requires the 

Administrator of EPA to promulgate a FIP within two years of finding that a state has failed to 

make a required a SIP submittal. The pertinent provision of Section 11O( c) states: 

(1) The Administrator shall promulgate a Federal implementation plan at any time 

within 2 years after the Administrator-

(A) finds that a State has failed to make a required submission or finds that the 

plan or plan revision submitted by the State does not satisfy the minimum criteria 

established under section 11O(k)(l )(A). 

24. On January 15,2009, EPA made a formal finding that the States referenced in 

paragraph 25 herein had failed to submit any of the required regional haze SIP elements set forth 

at 40 C.F.R. §51.30S. 74 Fed. Reg. 2392,2393 (January 15,2009). EPA also found that the 

States referenced in paragraph 26 herein had submitted some, but not all, of the required regional 

haze SIP elements set forth at 40 C.F.R. §§51.30S and 51.309. Id. 

25. In particular, EPA found that the following States had failed to submit SIPs 

addressing any of the required regional haze SIP elements of 40 C.F.R. §51.30S: Alaska, 

Connecticut, District of Columbia, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Kansas, 

Maine, Maryland, Massachusetts, Minnesota, Nebraska, Nevada, New Hampshire, New Jersey, 

New York, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Texas, 

Vermont, U.S. Virgin Islands, Virginia, Washington, and Wisconsin. 74 Fed. Reg. at 2393 

(January 15,2009). 

26. EPA found that the several States had failed to submit portions of the required haze 

SIPs. Those States, and the missing haze SIP portion(s) by regulatory citation, Arizona-40 

C.F.R. §51.309(g) and 40 C.F.R. §51.309(d)(4); Michigan-40 C.F.R. §51.30S(d) and 40 C.F.R. 

§51.30S(e) for six sources; and New Mexic0-40 C.F.R. §51.309(g) and 40 C.F.R. 

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§51.309(d)(4). 

27. The above-referenced EPA findings of failure to submit all or part of required 

regional haze SIPs triggered a nondiscretionary duty under 42 U.S.C. §741O(c)(l)(A) for EPA to 

promulgate regional haze FIPs by January 15,2011 for each of the above named States for which 

EPA had not fully approved regional haze SIPs by that date. EPA's January 15,2009 notice 

confirmed that the agency was obligated to promulgate regional haze FIPs for each of the abovenamed States within two years of the date of that notice. 74 Fed. Reg. at 2393. 

28. EPA has failed to meet the January 15,2011 deadline through the final 

promulgation of regional haze FIPs and/or SIPs for any of the States listed above, and such 

failure is ongoing. Accordingly, the Administrator is in violation of her nondiscretionary duty to 

promulgate regional haze FIPs and/or SIPs for each of the above-named States by January 15, 

2011. 

EPA's Duty To Timely Act on Haze SIP Submittals 

29. Section 11O(k)(I)(B) of the Act requires the Administrator to determine, within 

60 days of receipt of a plan or plan revision submitted by a state, whether the plan or plan 

revision meets the minimum criteria ("completeness criteria") for plan submissions promulgated 

under CAA § 11O(k)(I)(A). 42 U.S.C. § 741O(k)(l)(B). If, by the date six months after 

receiving a plan or revision from a state, the Administrator has made no finding as to whether a 

plan or plan revision meets the completeness criteria, the plan or plan revision shall be deemed 

by operation of law to meet such criteria i.e., to be "complete.,,2 Id. 

30. The Act further imposes a nondiscretionary duty on the Administrator to act on a 

plan or plan revision in accordance with CAA § 11O(k)(3) (i.e., to approve or disapprove the 

2 For ease of reference, plans that meet the completeness criteria are referred to herein as 

"complete," and plans that do not meet the completeness criteria are referred to as "incomplete." 

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submission) within 12 months after the submission is determined by Administrator, or deemed 

by operation oflaw, to meet the completeness criteria. 42 U.S.C. § 7410(k)(2), (3). Thus, at the 

absolute outside, the Administrator has a nondiscretionary duty to take final action on a SIP 

submission within 18 months of EP A's receipt of such submission, except where the 

Administrator finds by the date six months after receipt that the submission is incomplete. 

31. EP A received regional haze SIP submissions from each of the following States 

(and one region) more than 18 months before the date of Plaintiffs' notice letters in these matters 

(referenced in paragraph 4, supra) and made no finding within six months of receipt of such SIP 

submissions that any such submissions were incomplete: Alabama; Albuquerque, NM; Iowa; 

Louisiana; Mississippi; Missouri; North Carolina; South Carolina; Tennessee; and West 

Virginia. Further, the Administrator has not acted on any of these submissions in accordance 

with CAA § 110(k)(3). The Administrator is therefore in violation of her above-described 

nondiscretionary duty under CAA § 110(k)(2) to act on each of the above-referenced regional 

haze SIP submissions in accordance with CAA § 11O(k)(3) within 18 months of her receipt of 

such submissions. EPA's failure to take action on each of these SIPs in accordance with CAA § 

110(k)(3) constitutes a failure to perform a duty that is not discretionary with the Administrator 

within the meaning of § 304(a)(2) of the Act. 

32. EPA's failure to perform the above-referenced non-discretionary duties is 

ongoing and, on information and belief, will continue absent the relief sought herein. 

FIRST CLAIM FOR RELIEF 

Failure to Promulgate final Regional Haze FIPs 

33. Plaintiffs hereby incorporate all previous paragraphs by reference. 

34. On January 15,2009, EPA found that the following States had failed to submit 

SIPs addressing any of the required regional haze SIP elements of 40 C.F.R. §51.308: Alaska, 

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Connecticut, District of Columbia, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Kansas, 

Maine, Maryland, Massachusetts, Minnesota, Nebraska, Nevada, New Hampshire, New Jersey, 

New York, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Texas, 

Vermont, U.S. Virgin Islands, Virginia, Washington, and Wisconsin. 

35. EPA's January 15,2009 finding established a two-year period, ending on January 

15,2011, within which EPA was required to promulgate final regional haze FIPs for each of the 

states identified in paragraph 34, except where EPA approved a SIP revision correcting the 

deficiency for a given state before EPA's FIP promulgation. 

36. EPA failed by the January 15,2011 deadline to promulgate final regional haze 

FIPs for any of the states above. Further, by the January 15,2011 deadline, EPA had not 

approved regional haze SIPs correcting the deficiencies identified in EPA's January 15,2009 

finding for any of the states identified in paragraph 34. 

37. EPA's failure to promulgate final regional haze FIPs by the January 15,2011 

deadline for the states listed in paragraph 34 constitutes a failure to perform acts or duties that 

are not discretionary with the Administrator within the meaning of 42 U.S.C. § 7604(a)(2). Such 

failure is ongoing and, on information and belief, will continue absent the relief sought herein. 

38. Accordingly, Plaintiffs are entitled to an order from this Court directing EPA to 

forthwith promulgate final and complete regional haze FIPs, meeting all the Act's requirements 

for regional haze implementation plans, for each of the States referenced in paragraph 34 

forthwith. 

SECOND CLAIM FOR RELIEF 

39. Plaintiffs hereby incorporate all previous paragraphs by reference. 

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40. On January 15,2009, EPA found that the following States had submitted some, 

but not all, of the required regional haze SIP elements of 40 C.F .R. §51.308 and §51.309: 

Arizona, Michigan, and New Mexico. 

41. EP A's January 15, 2009 finding established a two-year period, ending on January 

15,2011, within which EPA was required to promulgate final regional haze FIPs for each of the 

states listed in paragraph 40, except where EPA approved a SIP revision correcting the 

deficiency for a given state before EPA's FIP promulgation. 

42. EPA failed by the January 15,2011 deadline to promulgate final regional haze 

FIPs for any of the states listed in paragraph 40. Further, by the January 15,2011 deadline, EPA 

had not approved any regional haze SIPs correcting the deficiencies identified in EPA's January 

15,2009 finding for any of the states identified in paragraph 40. 

43. EPA's failure to promulgate final regional haze FIPs by the January 15,2011 

deadline for the each state listed in paragraph 40 constitutes a failure to perform acts or duties 

that are not discretionary with the Administrator within the meaning of 42 U.S.C. § 7604(a)(2). 

Such failure is ongoing and, on information and belief, will continue absent the relief sought 

herein. 

44. Accordingly, Plaintiffs are entitled to an order from this Court directing EPA to 

forthwith promulgate final regional haze FIPs for Arizona, Michigan, and New Mexico 

satisfying the Act's requirements for each haze plan element that EPA found, in its January 15, 

2009 notice, had not been timely submitted by each of these states. 

THIRD CLAIM FOR RELIEF 

45. Plaintiffs hereby incorporate all previous paragraphs by reference. 

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46. Regional haze SIPs submitted by the following States (and one region) were 

either found by the Administrator or deemed by operation of law to be complete pursuant to 

CAA § 11 O(k)(l )(B) more than 18 months prior to January 19, 2011: Alabama; Albuquerque, 

NM; Iowa; Louisiana; Mississippi; Missouri; North Carolina; South Carolina; Tennessee; and 

West Virginia. 

47. The Administrator has not acted on any of the regional haze SIP submissions 

referenced in the preceding paragraph in accordance with CAA § 11O(k)(3), 42 U.S.C. § 

741O(k)(3). The Administrator is therefore in violation of her nondiscretionary duty under CAA 

§ 11 O(k) to act on each of the above-referenced haze SIP submissions in accordance with CAA § 

11O(k)(3) within 18 months of her receipt of such submissions. EPA's failure to take action on 

each of these SIPs in accordance with CAA § II 0(k)(3) constitutes a failure to perform a duty 

that is not discretionary with the Administrator within the meaning of § 304(a)(2) of the Act. 

Such failure is ongoing and, on information and belief, will continue absent the relief sought 

herein. 

48. Accordingly, Plaintiffs are entitled to an order of this Court directing EPA to take 

final action in accordance with CAA §11O(k)(3) on each of the haze SIP submissions referenced 

in paragraph 46 forthwith. 

RELIEF REQUESTED 

49. WHEREFORE, Plaintiffs pray that this Court: 

(1) Declare that EPA's failures to act as complained of herein constitute failures to 

perform nondiscretionary duties required by 42 U.S.C. §§ 741O(c)(1) and (k)(2) within the 

meaning of the Clean Air Act § 304(a)(2), 42 U.S.C. § 7604(a)(2); 

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(2) Preliminarily and permanently enjoin the Administrator from continuing to violate the 

above-described nondiscretionary duties; 

(3) Order the Administrator to complete all actions required by 42 U.S.C. § 741O(c)(l) 

and (k)(2) forthwith; 

(4) Award Plaintiffs their reasonable costs oflitigation, including attorneys' fees, 

pursuant to 42 U.S.C. § 7604(d); 

(5) Retain jurisdiction over this action to ensure compliance with the Court's orders; and 

(6) Grant such other relief as the Court deems just and proper. 

DATED: this 29rd day of August, 2011. 

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D VID S. BARON 

D.C. Bar No. 464222 

EARTHJUSTICE 

1625 Massachusetts Avenue NW, Suite 702 

Washington, DC 20036-2212 

Phone: (202) 667-4500 

Fax: (202) 667-2356 

dbaron@earthjustice.org 

REEDZARS 

Wyoming Bar No. 6-3224 

Attorney at Law 

910 Kearney Street 

Laramie, WY 82070 

307-745-7979 

rzars@lariat.org 

Counsel for Plaintiffs 
United States District Court 

For the District of Columbia 

C()"386-online 

10/03 

National Parks Conservation 

Association! et aL, 

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Case: 1: 11-cv-01548 

Assigned To: Jackson, Amy Berman 

Plaintiff Assign. Date: 8/29/2011 . vs Civ 

Description: Admn. Agency Review 

United States Environmental 

Protection Agency, et aI., 

Defendant 

CERTIFICAJE RULE LCyR 7.1 

I, the undersigned, counsel of record for _P_I_8_nt_iff_s __________ _ certify that to the best of my knowledge and 

belief, the following are parent companies, subsidiaries or affiliates of _P_I_a_nt_iff_s ____________ which have 

any outstanding securities in the hands of the public: 

None 

These representations are made in order that judges of this court may determine the need for recusaL 

AttOOley ofRecor ~ '\ ) 

.J./t 

464222 David S. Baron 

BAR IDENTIFICATION NO. Print Name 

1625 Massachusetts Suite 702 

Address 

Washington DC 20036-2212 

City State Zip Code 

(202) 667-4500 

Phone Number