Train v. Natural Resources Defense Council: The Genesis of a New Era of Federal-State Relationships in Air Pollution Control

The purpose of this article is to analyze the Supreme Court's decision in Train v. Natural Resources Defense Council, Inc., and to assess its impact on the federal-state relationship under the Clean Air Act. In order to understand the implications of the Court's decision, it is first necessary to examine briefly the federal-state relationship envisioned by Congress in the legislative history surrounding the 1970 amendments and then consider the decisions of various courts interpreting that relationship.