St MI v. EPA

                  United States Court of Appeals

               FOR THE DISTRICT OF COLUMBIA CIRCUIT

       Argued September 4, 2001   Decided October 30, 2001 

                           No. 99-1151

                        State of Michigan,
          Michigan Department of Environmental Quality, 
                            Petitioner

                                v.

                Environmental Protection Agency, 
                            Respondent

                         Navajo Nation, 
                            Intervenor

                        Consolidated with 
                99-1152, 99-1153, 99-1154, 99-1155

         On Petitions for Review of a Final Rule of the 
                 Environmental Protection Agency

                            ---------

     Henry V. Nickel argued the cause for petitioners.  With 
him on the briefs were Lauren E. Freeman, David S. Har-
low, Edmund H. Kendrick, Brian J. Renaud, Susan M. 
McMichael, Jennifer M. Granholm, Attorney General, State 
of Michigan, and John Fordell Leone, Assistant Attorney 
General.  Richard S. Wasserstrom entered an appearance.

     Cynthia A. Drew, Attorney, U.S. Department of Justice, 
argued the cause for respondent.  With her on the brief were 
John C. Cruden, Acting Assistant Attorney General, Andrew 
J. Doyle, Attorney, Anthony F. Guadagno, Attorney, Envi-
ronmental Protection Agency, and Michael W. Thrift, Attor-
ney.  Lois J. Schiffer, Assistant Attorney General, U.S. De-
partment of Justice, and Christopher S. Vaden, Attorney, 
entered appearances.

     Jill E. Grant was on the brief for intervenor Navajo 
Nation.

     Before:  Ginsburg, Chief Judge, Edwards and Sentelle, 
Circuit Judges.

     Opinion for the Court filed by Circuit Judge Sentelle.

     Sentelle, Circuit Judge:  State of Michigan, et al. (herein-
after petitioners), petition this Court for review of the Envi-
ronmental Protection Agency's ("EPA") 1999 revisions to the 
Part 71 federal operating permit program rule, 64 Fed. Reg. 
8247 (Feb. 19, 1999) (codified at 40 C.F.R. pt. 71).1  Petition-
ers argue that the EPA has exceeded its authority under the 
Clean Air Act ("CAA" or "the Act"), 42 U.S.C. s 7401 et seq. 
(2000), in proposing to promulgate and administer a federal 

__________
     1 The following petitions for review challenging the same EPA 
rule were consolidated and are before us:  State of Michigan, 
Michigan Dep't of Envtl. Quality v. EPA, No. 99-1151, American 
Forest and Paper Ass'n, Inc. v. EPA, No. 99-1152, New Mexico Oil 
& Gas Ass'n v. EPA, No. 99-1153, New Mexico Env't Dep't v. EPA, 
No. 99-1154, and Public Serv. Co. of New Mexico and Salt River 
Project Agric. Improvement and Power Dist. v. EPA, No. 99-1155.  
Arizona Public Serv. Co. v. EPA, No. 99-1146, challenging the 
same rule, was voluntarily dismissed without prejudice on Septem-
ber 14, 2000.

operating permits program for areas where EPA believes the 
Indian country status is in question, and in proposing to make 
state/tribe jurisdictional determinations on a case-by-case ba-
sis rather than through notice and comment rulemaking.  
Because we agree with petitioners that EPA has exceeded its 
authority, we grant the petition for review.

                          I. Background

              A. The Clean Air Act and Indian Tribes

     The Clean Air Act establishes an intergovernmental part-
nership to regulate air quality in the United States.  De-
scribed as an "experiment in federalism," Virginia v. EPA, 
108 F.3d 1397, 1408 (D.C. Cir. 1997) (quoting Bethlehem Steel 
Corp. v. Gorsuch, 742 F.2d 1028, 1036-37 (7th Cir. 1984)), the 
Act gives EPA responsibility for establishing National Am-
bient Air Quality Standards ("NAAQS").  42 U.S.C. s 7409;  
see also Whitman v. American Trucking Ass'ns, 531 U.S. 
457, __, 121 S. Ct. 903, 907 (2001). Title V of the 1990 Clean 
Air Act Amendments gives states responsibility for imple-
menting these standards.  See, e.g., 42 U.S.C. ss 7407, 7410.

     As part of the 1990 Clean Air Act Amendments, Congress 
also authorized EPA to "treat Indian tribes as States," thus 
affording Indian tribes the same opportunity as states to 
implement the NAAQS within tribal jurisdictions under a 
Title V program.  42 U.S.C. s 7601(d).  Title V requires that 
states submit and obtain EPA approval of a state operating 
permit program ("SOP") that meets the "minimum elements" 
set forth under 42 U.S.C. s 7661a(d) and EPA regulations 
promulgated pursuant to 42 U.S.C. s 7661a(b).  Among the 
requirements is that the state demonstrate that it has "ade-
quate authority," including jurisdiction, to regulate the emis-
sion sources subject to the SOP.  Id. at s 7661a(d).  This 
same requirement applies to Indian tribes seeking to enact 
their own implementation plan.  Id. at s 7601(d).

     Congress recognized the unique legal status and circum-
stances of Indian tribes by allowing tribes to be treated as 
states, but not requiring them to apply to EPA to manage 

Clean Air Act programs.  See id. at s 7601(d)(1)(A).  Tribes 
may be treated as states if:  they have a governing body;  the 
functions they are to exercise pertain to the management and 
protection of air resources within the tribe's jurisdiction;  and 
the tribe is capable of carrying out these functions.  See 42 
U.S.C. s 7601(d)(2).  No tribe to date has sought to create an 
implementation plan.  In the Tribal Authority Rule ("TAR"), 
EPA exercised authority under 42 U.S.C. ss 7601(d)(2), (4) 
by specifying those portions of the Clean Air Act for which it 
deemed it appropriate to treat Indian tribes as states, and the 
requirements necessary for tribes to establish jurisdiction to 
develop Title V permitting programs.  See Indian Tribes:  Air 
Quality Planning and Management, 63 Fed. Reg. 7254 (Feb. 
12, 1998) (to be codified at 40 C.F.R. pts. 9, 35, 49, 50, and 81).  
EPA's interpretation was upheld by this Court in Arizona 
Pub. Serv. Co. v. EPA, 211 F.3d 1280 (D.C. Cir. 2000), cert. 
denied, 121 S. Ct. 1600 (2001).  Under the TAR a tribe may 
only develop a Title V permitting program for non-
reservation areas if the tribe can demonstrate jurisdiction 
under federal Indian law.  Therefore the TAR provides a 
procedure for resolving jurisdictional disputes.  See 40 C.F.R. 
s 49.9(e).

     If a state fails to create an EPA-approved implementation 
plan, or in cases where an approved program is not being 
properly implemented, Congress requires EPA to "promul-
gate, administer, and enforce" a federal operating permit 
program. 42 U.S.C. ss 7661a(d)(3), (i)(3).  Further, in the 
absence of an EPA-approved tribal implementation program, 
EPA may adopt a federal implementation program.  See 42 
U.S.C. s 7601(d)(4).  However, the parties before us disagree 
as to the source of EPA's power to enact such a program for 
Indian country.  The EPA claims its "authority under the 
CAA is based in part on the general purpose of the CAA," 
which was only supplemented in the Indian tribe context by 
42 U.S.C. s 7601(d)(4).  64 Fed. Reg. at 8251;  see also 62 
Fed. Reg. 13748, 13749 (proposed rule and notice) ("Today's 
notice makes it clear that EPA's implementation of part 71 
programs in Indian country is based on EPA's overarching 
authority to protect air quality within Indian country, not 

solely on its authority to act in the stead of an Indian Tribe.").  
In contrast, petitioners essentially contend EPA is merely 
authorized to act in the shoes of the tribes--providing a 
federal implementation program for tribes as it would for a 
state that failed to develop an approved program.  In any 
event, both sides agree that in the absence of a tribal 
implementation plan, EPA may provide a federal operating 
plan for lands under the tribe's jurisdiction.

                      B. Federal Indian Law

     Determining tribal jurisdiction is far from straightforward 
and involves delicate questions involving state and tribal 
sovereignty.  Indeed, state-tribal relations have been a con-
cern since the time of the founding.  See The Federalist No. 
42 (Madison) ("What description of Indians are to be deemed 
members of a State, is not yet settled, and has been a 
question of frequent perplexity and contention in the federal 
councils.").  Under principles of federal Indian law, "Indian 
country" denotes the geographic scope where "primary juris-
diction ... rests with the Federal Government and the Indian 
tribe inhabiting it, and not with the States."  Alaska v. 
Native Village of Venetie Tribal Gov't, 522 U.S. 520, 527 n.1 
(1998).  "Indian country" is defined by statute as "all land 
within the limits of any Indian reservation," "all dependent 
Indian communities," and "all Indian allotments." 18 U.S.C. 
s 1151 (2001).  "Although this definition by its terms relates 
only to federal criminal jurisdiction, [the Supreme Court has] 
recognized that it also generally applies to questions of civil 
jurisdiction such as the one at issue here."  Venetie Tribal 
Gov't, 522 U.S. at 527 (citing DeCoteau v. District County 
Court for Tenth Judicial Dist., 420 U.S. 425, 427 n.2 (1975)).  
Thus, unlike typical political boundaries, the jurisdictional 
boundaries of Indian tribes are not always clearly delineated, 
and often are determined through adjudication or other ad-
ministrative proceedings.  See, e.g., id. at 534;  Tribal Author-
ity Rule, 40 C.F.R. pt. 49, 63 Fed. Reg. 7254 (Feb. 12, 1998).

     "[T]he test for determining whether land is Indian country 
does not turn upon whether that land is denominated 'trust 

land' or 'reservation.'  Rather, we ask whether the area has 
been 'validly set apart for the use of the Indians as such, 
under the superintendence of the Government.' "  Oklahoma 
Tax Comm'n v. Citizen Band Potawatomi Indian Tribe of 
Oklahoma, 498 U.S. 505, 511 (1991) (quoting United States v. 
John, 437 U.S. 634, 648-49 (1978)). Difficult jurisdictional 
questions can arise over lands that do not meet the prima 
facie test for "Indian country."  Claims of superintendence 
can be controversial for lands that tribes claim to be "depen-
dent Indian communities," where title is not held by the 
federal government or Indians, e.g. Venetie Tribal Gov't, 522 
U.S. at 525-27, or lands outside the exterior boundaries of 
formally-established reservations such as lands taken into 
trust for tribes pursuant to the Indian Reorganization Act (25 
U.S.C. s 465 (2000)), for which no action was taken by treaty, 
Executive Order, or act of Congress to set the lands aside for 
the use and benefit of a tribe.

     It is against this background that EPA adopted its new 
Part 71 rules providing for federal administration of an 
operating permits program in Indian country.

                     C. The 1999 Part 71 Rule

     In 1999, EPA finalized its 1997 proposal, 62 Fed. Reg. 
13748 (March 21, 1997), establishing the Part 71 federal 
operating permits plan throughout "Indian country unless a 
Tribal or State Part 70 program has been explicitly approved 
for the area."  64 Fed. Reg. at 8247, 8249 (codified at 40 
C.F.R. s 71.4(b)).  The major area of contention between 
petitioners and EPA, and thus the issue before this Court is 
EPA's authority to promulgate "Part 71 programs for Indian 
country."  Section 71.4(b) provides:

     The Administrator will administer and enforce an operat-
     ing permits program in Indian country as defined in 
     s 71.2, when an operating permits program which meets 
     the requirements of part 70 of this chapter has not been 
     explicitly granted full or interim approval by the Admin-
     istrator for Indian country.  For purposes of administer-
     ing the part 71 program, EPA will treat areas for which 
     
     EPA believes the Indian country status is in question as 
     Indian country.
     
40 C.F.R. s 71.4(b) (emphasis added).  Specifically, this 
Court must evaluate whether EPA's decision to "treat areas 
for which EPA believes the Indian country status is in 
question as Indian country" has exceeded the agency's au-
thority under the Clean Air Act.

     In its 1995 proposal for Part 71, EPA stated that the "Act 
authorizes EPA to protect air quality on lands over which 
Indian Tribes have jurisdiction."  60 Fed. Reg. at 20809 
(emphasis added).  The purpose was to provide a "mechanism 
by which EPA [could] assume responsibility to issue permits 
in situations where the State, local, or Tribal agency has not 
developed, administered, or enforced an acceptable permits 
program...."  Id. at 20805.  Thus, under the 1995 proposal, 
EPA would issue permits for "Tribal areas" that "EPA 
determines to be within a Tribe's inherent authority."  Id. at 
20830 (emphasis added).  As a prerequisite the 1995 proposal 
would have "required Tribes to establish their jurisdiction 
over certain areas of Indian country before EPA could imple-
ment a Federal program for those areas."  64 Fed. Reg. at 
8249 (emphasis added);  see 60 Fed. Reg. at 20809.  The 1999 
rules adopted in Part 71 and the agency's approach to deter-
mining jurisdiction differ sharply from the original 1995 pro-
posal. Unlike the present rule, a final jurisdictional determi-
nation would have been required regardless of whether the 
tribe sought its own program.  Moreover, EPA proposed to 
follow the same "approach to resolving jurisdictional issues 
taken in the Tribal air rule."  60 Fed. Reg. at 20810.  "EPA 
would notify appropriate governmental entities of the bound-
ary of the Tribal area for a part 71 program at least 90 days 
prior to the effective date of the program," and where a 
dispute arose provide notice in the Federal Register and seek 
comments.  Id.  Finally, the 1995 proposal anticipated that 
EPA would "implement a part 71 program that covers all 
undisputed areas, while withholding action on the portion 
that addresses areas where a jurisdiction issue has not been 
satisfactorily resolved."  Id. (emphasis added).  In contrast, 
under the adopted rule, EPA assumes jurisdiction if "EPA 

believes" the status of the area is "in question." 40 C.F.R. 
s 71.4(b);  64 Fed. Reg. at 8262.

     EPA contends that under its new Part 71 rule it need only 
conclude there is a "bona fide" question before it will treat an 
area's Indian country status as "in question."   See 64 Fed. 
Reg. at 8248 n.1.  EPA claimed its authority with respect to 
"in question" lands is based on the agency's "overarching 
authority to protect air quality within Indian country, not 
solely on its authority to act in the stead of an Indian Tribe."  
62 Fed. Reg. at 13749.  Further, rather than determine 
whether an area's status is Indian country or at least "in 
question" through notice and comment rulemaking, the agen-
cy proposes to use adjudications over individual emitting 
sources to determine an area's status.  See 64 Fed. Reg. at 
8255 ("EPA would not conduct area-specific rulemaking pro-
cedures to assess the boundaries of programs in Indian 
country....  Specific 'boundary' questions relating to appli-
cability of the program to particular sources would be ad-
dressed through a less formal consultation process [and] EPA 
would make case-specific determinations on whether particu-
lar sources are in Indian country.");  id. at 8257.  Petitioners 
sought review in this Court of the portion of EPA's 1999 Part 
71 Rule authorizing EPA to treat as "Indian country" lands 
for which EPA has deemed "Indian country" status to be "in 
question" and of EPA's determination to make jurisdictional 
inquiries through case-by-case adjudications rather than no-
tice and comment rulemakings.

                           II. Analysis

                        A. EPA's Authority

     It is elementary that our federal government is one of 
limited and enumerated powers.  "The powers of the legisla-
ture are defined and limited;  and that those limits may not be 
mistaken or forgotten, the constitution is written." Marbury 
v. Madison, 5 U.S. (1 Cranch) 137, 176 (1803) (Marshall, C.J.).  
This principle applies with equal force to the so-called modern 
administrative state.  EPA is a federal agency--a creature of 
statute.  It has no constitutional or common law existence or 

authority, but only those authorities conferred upon it by 
Congress.  "It is axiomatic that an administrative agency's 
power to promulgate legislative regulations is limited to the 
authority delegated by Congress." Bowen v. Georgetown 
Univ. Hosp., 488 U.S. 204, 208 (1988).  Thus, if there is no 
statute conferring authority, a federal agency has none.  We 
must reverse EPA's decision to administer a federal operat-
ing permit program in lands whose Indian country status is 
considered to be "in question" if it is arbitrary, capricious, an 
abuse of discretion, or otherwise not in accordance with law.  
See Motor Vehicle Mfrs. Ass'n of the United States, Inc. v. 
EPA, 768 F.2d 385, 389 n.6 (D.C. Cir. 1985), cert. denied, 474 
U.S. 1082 (1986).  If EPA lacks authority under the Clean Air 
Act, then its action is plainly contrary to law and cannot 
stand.  See American Petroleum Inst. v. EPA, 52 F.3d 1113, 
1119-20 (D.C. Cir. 1995) ("API");  Ethyl Corp. v. EPA, 51 
F.3d 1053, 1060 (D.C. Cir. 1995).  To determine whether the 
agency's action is contrary to law, we look first to determine 
whether Congress has delegated to the agency the legal 
authority to take the action that is under dispute.  United 
States v. Mead Corp., 121 S. Ct. 2164, 2171 (2000) ("We hold 
that administrative implementation of a particular statutory 
provision qualifies for Chevron deference when it appears 
that Congress delegated authority to the agency generally to 
make rules carrying the force of law....");  Chevron U.S.A. 
Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 
837, 843-44.  Mere ambiguity in a statute is not evidence of 
congressional delegation of authority.  See Sea-Land Servs., 
Inc. v. Dep't of Transp., 137 F.3d 640, 645 (D.C. Cir. 1998) 
("[Chevron] deference comes into play of course, only as a 
consequence of statutory ambiguity, and then only if the 
reviewing court finds an implicit delegation of authority to the 
agency.") (emphasis added);  City of Kansas City, Mo. v. 
Dep't of Housing & Urban Dev., 923 F.2d 188, 192-93 (D.C. 
Cir. 1991) ("implicit delegation of interpretive authority," as 
well as ambiguity, are required before Chevron-step-two def-
erence is appropriate);  cf. Railway Labor Exec. Ass'n v. 
Nat'l Mediation Bd., 29 F.3d 655 (D.C. Cir. 1994) (en banc).  
However, when Congress has explicitly or impliedly left a gap 

for an agency to fill, there is a delegation of authority to the 
agency to give meaning to a specific provision of the statute 
by regulation, "and any ensuing regulation is binding in the 
courts unless procedurally defective, arbitrary and capricious 
in substance, or manifestly contrary to the statute."  Mead, 
121 S. Ct. at 2171.

     Agency authority may not be lightly presumed.  "Were 
courts to presume a delegation of power absent an express 
withholding of such power, agencies would enjoy virtually 
limitless hegemony, a result plainly out of keeping with 
Chevron and quite likely with the Constitution as well."  
Ethyl Corp. 51 F.3d at 1060 (D.C. Cir. 1995).2  "Thus, we will 
not presume a delegation of power based solely on the fact 
that there is not an express withholding of such power."  
API, 52 F.3d at 1120.

     We conclude that the plain meaning of 42 U.S.C. s 7601(d) 
and s 7661a grants EPA the authority to "promulgate, ad-
minister and enforce a [federal operating permit] program" 
for a state or tribe if, and only if, (1) the state or tribe fails to 
submit an operating program or (2) the operating program is 
disapproved by EPA or (3) EPA determines the state or tribe 
is not adequately administering and enforcing a program.  
See 42 U.S.C. ss 7661a(d), (i).  Since Congress has not 
delegated authority to the agency to act beyond these statuto-
ry parameters, we will not defer to EPA's interpretation of 
the Act as giving it the broader power to indefinitely run a 
federal operating permit program in the absence of the 
conditions set out by sections 7661a(d), (i), and 7601(d).  See 
Mead, 121 S. Ct. at 2177 (Chevron deference not applicable 
"where statutory circumstances indicate no intent to delegate 
general authority to make rules with force of law");  Chevron, 
467 U.S. at 842-43.

            B. EPA's Treatment of "In Question" Lands

     Petitioners and EPA agree that under the regime Congress 
has created in the Clean Air Act, the states have primary 
responsibility for ensuring that ambient air meets federally-

__________
     2 Such a result would be out of keeping with Mead as well.

established standards.  Section 502 of the Act, 42 U.S.C. 
s 7661a, addresses EPA approval of state programs.  EPA 
must establish minimum elements of a permit program and 
each state must develop such a program.  Id. at ss 7661a(b) 
and (d).  Section 502(d)(3) specifies that "[i]f a program 
meeting the requirements of this subchapter has not been 
approved in whole for any State, the Administrator shall, 2 
years after the date required for submission of such a pro-
gram ... promulgate, administer, and enforce a program 
under this subchapter for that State."  42 U.S.C. 
s 7661a(d)(3) (emphasis added).  Similarly, if EPA deter-
mines that a state (or tribe) is "not adequately administering 
and enforcing a program, or portion thereof" then "unless the 
State has corrected such deficiency within 18 months after 
the date of such finding, the Administrator shall, 2 years after 
the date of such finding, promulgate, administer, and enforce 
a program under this subchapter for that State."  42 U.S.C. 
ss 7661a(i)(1), (4) (emphasis added).

     Section 502, 42 U.S.C. s 7661a, does not speak of underly-
ing, residual, or even default EPA jurisdiction, authority, or 
power.  It only speaks of the EPA running an implementa-
tion program for a state that fails to develop an approved 
program.  EPA has no authority or jurisdiction under section 
502 to operate a federal program unless or until the state fails 
to have a SOP approved within a specified time frame. 
Further, if EPA does implement a program, the Administra-
tor is instructed only "to administer and enforce federally 
issued permits under this subchapter until they are replaced 
by a permit issued by a permitting program," and EPA must 
"suspend the issuance of permits promptly upon publication 
of notice of approval of a permit program under this sec-
tion...."  42 U.S.C. s 7661a(e).  Thus, once a state program 
is approved, EPA's authority to operate a federal program 
under section 502(d)(3) lapses.

     Nothing in CAA section 301(d), 42 U.S.C. s 7601(d), adds 
to EPA's jurisdiction to implement a federal program in place 
of the states.  Section 301(d) permits the EPA to "treat 
Indian tribes as States" if certain prerequisites are met, 
including that the "functions to be exercised by the Indian 

tribe pertain to the management and protection of air re-
sources within the exterior boundaries of the reservation or 
other areas within the tribe's jurisdiction." 42 U.S.C. 
s 7601(d)(2)(B) (emphasis added).  If the EPA determines 
that treatment of Indian tribes as identical to states is 
inappropriate or administratively infeasible, then the EPA 
"will directly administer such provisions so as to achieve the 
appropriate purpose."  42 U.S.C. s 7601(d)(4).  Thus, under 
section 301, EPA may treat qualifying tribes as states, and if 
the tribe fails to meet the requirements set out under section 
502, then EPA must implement a federal program.  Alterna-
tively, if the tribe fails to qualify, then EPA must likewise 
implement a federal program.  Again, there is no suggestion 
of inherent or underlying EPA authority, but rather a role for 
the EPA if the tribe, for whatever reason, does not promul-
gate a tribal implementation program.

     It is significant that neither the EPA nor the Intervenor, 
Navajo Nation, can cite a single reference in the Clean Air 
Act that suggests that the agency has some overarching 
jurisdiction to implement federal programs.  If anything, the 
"structure" and "history" of the Act, to which they appeal, 
suggest otherwise, for it is an experiment in cooperative 
federalism, as Intervenor notes.  Certainly the Act intended 
to create an overarching federal role in air pollution control 
policy, as Intervenor argues, but that overarching role is in 
setting standards, not in implementation. EPA's role for 
implementation is limited to the conditions set out in 42 
U.S.C. ss 7601(d), 7661a.

     The Intervenor's brief is telling.  To support its contention 
of default federal jurisdiction it cites vague statements that 
the Act is "national in scope," that it is to "protect and 
enhance the quality of the Nation's air resources" or that 
EPA has the authority to issue regulations necessary to 
implement the Act.  But none of these implies that EPA has 
some default authority to operate an implementation plan 
except as specified in sections 301(d) and 502 of the Clean Air 
Act, 42 U.S.C. ss 7601(d), 7661a.  In its brief, EPA claims 
that it "always has nationwide enforcement authority under 
the Act" because "Congress charged EPA not only with 

generally administering the Act, but also with nationally 
overseeing and enforcing its requirements."  Similarly, in 
adopting the new Part 71 rules, EPA claimed its "authority 
under the CAA is based in part on the general purpose of the 
CAA." 64 Fed. Reg. at 8251.  However, "EPA cannot rely on 
its general authority to make rules necessary to carry out its 
functions when a specific statutory directive defines the rele-
vant functions of EPA in a particular area." API, 52 F.3d at 
1119.  Rather, we have before had occasion to remind EPA 
that its mission is not a roving commission to achieve pure air 
or any other laudable goal.   See, e.g., API, 52 F.3d at 1119;  
Ethyl Corp., 51 F.3d at 1058.  Commendable though these 
goals may be, they are not within EPA's portfolio unless the 
states and tribes fail to implement a program, and the 
conditions in 42 U.S.C. ss 7601(d) and 7661a are therefore 
met.

     Having determined that EPA's only authority to administer 
a federal operating permit program is found in 42 U.S.C. 
ss 7601(d) and 7661a, we must next determine whether EPA 
is acting within that authority in the challenged procedure.  
The answer is plainly no.  EPA asserts that where a state has 
applied to operate a SOP under 42 U.S.C. s 7661a, EPA need 
not actually determine whether the state has jurisdiction.  
Rather, EPA claims it may administer a federal operating 
permit program for sources in Indian country, including 
areas where EPA believes a bona fide question of Indian 
country status exists.  Much of EPA's brief is dedicated to 
arguing that it has authority to administer a federal operating 
permit program in Indian country.  However, these words 
are wasted as petitioners do not claim otherwise.  At issue in 
this case is EPA's authority to administer a federal program 
where the Indian country status is merely in question.  The 
petitioner states do not contend, as EPA and Intervenor 
suggest, that the states should have jurisdiction over Indian 
country lands.  Petitioners happily concede that tribes, and 
thus, potentially the EPA--acting for the tribe--have juris-
diction over Indian country.  Similarly, petitioners not only 
concede that EPA may undertake initial jurisdictional line-
drawing, subject to judicial review, they insist, correctly, that 

EPA must make jurisdictional determinations.  That is, EPA 
cannot acquire jurisdiction for itself merely by determining 
that an area's status is in question.  Were we to hold other-
wise, EPA would effectively have a blank check to expand its 
own jurisdiction by not deciding jurisdictional questions.  The 
Clean Air Act does not confer such authority.

     EPA argues that it is the state's burden under 42 U.S.C. 
s 7661a(d)(1) to make a showing of "adequate authority" (and 
thus state jurisdiction) to carry out a SOP, and that unless a 
state can demonstrate authority to regulate an area, then 
EPA must provide for effective implementation of Title V 
programs.  EPA contends it need not determine whether the 
disputed area is within the jurisdiction of a state or a tribe, 
and that by operating a federal program over "in question" 
areas it avoids jurisdictional disputes. See 64 Fed. Reg. at 
8254.  Because Congress has given EPA discretion to deter-
mine how to preserve tribes' statutorily-granted options to 
seek to run a Title V program for sources within Indian 
country, EPA argues that this Court should defer to its 
decision under Chevron step two, as a rule reasonably filling 
the gap left by Congress.

     What EPA fails to appreciate is that its actions create a 
jurisdictional dispute.  If a state has an approved implemen-
tation plan, then EPA's only grounds for jurisdiction under 
the Act is the fact that an area is Indian country, not that its 
status is "in question."  If the state does not have an ap-
proved plan, then EPA is acting for the state.  There are no 
intermediate grounds on which EPA may indefinitely exercise 
jurisdiction--it is either acting in the shoes of a tribe or the 
shoes of the state.  There is no residual authority granted by 
the CAA for the EPA to refuse to make a jurisdictional 
determination and operate a federal program under some 
general authority of its own.  EPA comes close to arguing 
that because Congress has not expressly forbidden this asser-
tion of federal jurisdiction, the agency may assert it.  Howev-
er, as we reminded the EPA in Ethyl Corp. and American 
Petroleum Institute, to suggest "that Chevron step two is 
implicated any time a statute does not expressly negate the 
existence of a claimed administrative power ..., is both flatly 

unfaithful to the principles of administrative law ... and 
refuted by precedent."  51 F.3d at 1060;  52 F.3d at 1120.

     EPA and Intervenor Navajo Nation also argue that EPA's 
obligation to protect Indian interests in land, including juris-
diction and other facets of self-government, and the strong 
federal interest in preserving the sovereign rights of tribal 
governments to regulate activities and enforce laws on Indian 
lands, support the 1999 Part 71 rule allowing EPA to operate 
a federal program for lands in question.  See Exec. Order No. 
13175, s 3(a), 65 Fed. Reg. 67249 (Nov. 9, 2000) ("Agencies 
shall respect Indian tribal self-government and sovereignty, 
honor tribal treaty and other rights, and strive to meet the 
responsibilities that arise from the unique legal relationship 
between the Federal Government and Indian tribal govern-
ments.").  Intervenor argues that to allow states to imple-
ment Title V programs where the Indian country status is "in 
question" would infringe on rights that belong to the tribes 
under both the CAA and "general principles" of federal 
Indian law.  EPA similarly asserts that by operating a feder-
al program for "in question" areas, it "protect[s] tribal sover-
eignty interests."  EPA essentially argues that its interpreta-
tion of the CAA is correct because it favors Indian interests.  
Yet, the bedrock canon of statutory interpretation in Ameri-
can Indian jurisprudence that " 'statutes are to be construed 
liberally in favor of the Indians, with ambiguous provisions 
interpreted to their benefit' " is simply not implicated here. 
Cobell v. Norton, 240 F.3d 1081, 1101 (D.C. Cir. 2001) (quot-
ing Montana v. Blackfeet Tribe of Indians, 471 U.S. 759, 766 
(1985)).  EPA is not interpreting 42 U.S.C. ss 7601(d) and 
7661a for the benefit of Indian tribes.  It does not, for 
example, propose to give Indian tribes jurisdiction over "in 
question" lands. Rather it is refusing to make a jurisdictional 
determination, thereby depriving both tribes and states of the 
opportunity afforded them by Title V to operate a permitting 
program.  If anything, by claiming independent federal juris-
diction over "in question" areas, EPA is construing these 
statutes for its own benefit.

     EPA notes in its brief that "disputes" over whether a 
particular parcel of land is Indian country "typically are 

resolved by tribunals other than EPA."  However, EPA 
offers no reason why it should refrain from deciding such 
jurisdictional questions when they arise under the CAA.  
Quite to the contrary, EPA has willingly accepted that it 
must make jurisdictional decisions before approving a tribal 
implementation plan.  That very issue was the topic of litiga-
tion before this Court just last year in Arizona Public Service 
Co. v. EPA, 211 F.3d 1280 (D.C. Cir. 2000).  EPA is not 
seriously contending that it cannot or should not make juris-
dictional decisions.  Rather it is suggesting it would prefer 
just to run the program itself.  Ironically in the Tribal 
Authority Rule at issue in Arizona Public Service Co., EPA 
stated that a "territorial approach to air quality regulation 
best advances rational, sound air quality management," 59 
Fed. Reg. 43956, 43959 (Aug. 25, 1994), yet here EPA does 
not want to decide who controls the territory, instead leaving 
pockets of "in question" lands under federal, not Indian, 
jurisdiction.

     EPA claims in its brief that it will only assert authority if 
there is a "bona fide" question of an area's status.  However, 
in the Federal Register, EPA concluded that for the "pur-
poses of this rule, there may be, but need not be, a formal 
dispute, such as active litigation or other form of public 
disagreement, for EPA to consider the Indian country status 
of the area to be in question."  64 Fed. Reg. at 8254.  Thus, 
at least in the Federal Register, EPA has set a low, indeed 
virtually undefined, threshold for deciding there is a dispute.  
In any event, the Clean Air Act does not provide for EPA to 
administer a federal program even if there is a bona fide 
question of the area's status.  Instead, under 42 U.S.C. 
s 7661a(d), EPA must determine whether the state has ade-
quate authority to carry out the SOP.  And EPA must tell 
the state if the SOP is disapproved because of a lack of 
jurisdiction.  Section 7661a(d)(1) requires that if the SOP is 
disapproved, "in whole or in part, the Administrator shall 
notify the Governor of any revisions or modifications neces-
sary to obtain approval."  As petitioners point out, there 
either is jurisdiction or there isn't, but either way EPA must 
decide and not simply grab jurisdiction for itself on the 

ground that an area is "in question."  Jurisdiction as between 
states and tribes is binary, it must either lie with the state or 
with the tribe--one or the other--and EPA does not have a 
third option of not deciding.

     Petitioners correctly fear that EPA is creating a situation 
in which it may assume jurisdiction for itself and perpetually 
keep it from the states (or the tribes) because of a lack of 
showing of jurisdiction, without ever deciding who has juris-
diction.  EPA even anticipates such an eventuality.  It notes:

     Where a State and Tribe assert jurisdiction over an area 
     whose Indian country status EPA believes is in question 
     (and EPA has not resolved the question and has not 
     explicitly approved a part 70 program as applying in the 
     area), EPA would not view either the State or the Tribe 
     as having satisfied the CAA section 502(b)(5) require-
     ments to have adequate authority....  Only when the 
     State or Tribe prevails on the Indian country question 
     would EPA then be able to conclude that the section 
     502(b)(5) requirements have been met for the area.  Un-
     til that time, the absence of an approved part 70 pro-
     gram in the area necessitates implementation of part 71.  
     By federally implementing the title V program in areas 
     for which EPA believes the Indian country status is in 
     question, EPA can help avoid jurisdictional disputes that 
     might hinder effective implementation of the CAA.
     
64 Fed. Reg. at 8254 (emphasis added).  Instead, EPA de-
clines to resolve the dispute and imposes its own program.  
This situation arises in part because "EPA believes there is 
no reason to impose on Tribes the burden of making a 
jurisdictional showing prior to EPA administering a Federal 
program."  62 Fed. Reg. at 13750.  The source of EPA's 
belief is not entirely clear.  EPA purports to rely on HRI, 
Inc. v. EPA, 198 F.3d 1224 (10th Cir. 2000).  However, the 
issues in that case were quite different from those confront-
ing us today.  In HRI, Inc., the court was called upon to 
determine whether (1) the EPA had properly determined that 
a parcel of land was Indian country and (2) whether the EPA 
had determined that another parcel of land was in dispute.  

The Tenth Circuit affirmed the EPA decisions before it, but 
remanded for the EPA to make the jurisdictional determina-
tion concerning the disputed land.  That court certainly did 
not determine that the EPA had acquired potentially perma-
nent jurisdiction over a parcel of land simply by reason of its 
status being in dispute.  Here we need not decide whether 
EPA could temporarily operate a Part 71 federal program 
while determining whether a state or a tribe has jurisdiction, 
as that is not before us.  EPA does not propose to impose 
federal jurisdiction over "in question" lands only until it can 
resolve the dispute, but in perpetuity, or at least until a tribe 
or state makes an adequate showing through some other 
regulatory or adjudicatory mechanism.  EPA did announce it 
would work with states, tribes, the Department of the Interi-
or and other stakeholders "to assess whether sources are 
located in Indian country," which EPA defines as including 
areas for which EPA believes the Indian country is in ques-
tion.  64 Fed. Reg. at 8256.  But that means only EPA will 
take questions and comments on whether something is "in 
question."  EPA does not promise--or even suggest--it will 
determine jurisdiction.  It proposes to run a federal program 
so long as the area is "in question" without resolving that 
question--and EPA lacks that statutory authority to do so. 
Even if Congress intended for EPA to fill jurisdictional gaps, 
it did not empower EPA to create permanent, or even semi-
permanent, ones.

     Because EPA's only authority under the Clean Air Act to 
operate a federal permitting program arises from 42 U.S.C. 
ss 7601(d) and 7661a, and because these provisions require 
that EPA make a determination as to whether a state or a 
tribe has jurisdiction, we vacate the portion of EPA's 1999 
Part 71 rule authorizing EPA to treat lands for which EPA 
has deemed "Indian country" status to be "in question" as 
"Indian country" for purposes of implementing a federal 
program in those areas.

       C. Procedure for Determining "Indian country" Status

     In evaluating EPA's decision to use adjudication to resolve 
jurisdictional questions on a case by case basis, we are guided 

by SEC v. Chenery, 332 U.S. 194 (1947).  When Congress has 
not specified an approach for the agency to follow, the form of 
rulemaking or adjudicative procedure "lies primarily in the 
informed discretion of the administrative agency." 332 U.S. at 
203;  see Vermont Yankee Nuclear Power Corp. v. Natural 
Resources Defense Council, Inc., 435 U.S. 519, 543 (1978) 
("Absent constitutional constraints or extremely compelling 
circumstances the administrative agencies should be free to 
fashion their own rules of procedure and to pursue methods 
of inquiry capable of permitting them to discharge their 
multitudinous duties.") (quotations omitted).  Thus, EPA's 
procedures for determining whether a particular emitting 
source (and thus a particular area) falls within Indian country 
(or is "in question") would typically be entitled to deference, 
as the agency has broad discretion to choose between rule-
making and adjudication.  See Chenery, 332 U.S. at 203;  
Vermont Yankee, 435 U.S. at 543.  However, when Congress 
has spoken, we are bound by that pronouncement.  Chevron, 
467 U.S. at 842-43 (Chevron's step one).  Further, regardless 
of the reasonableness of EPA's decision under Chenery or 
Chevron step two, under the Administrative Procedure Act 
("APA") this Court must determine whether the EPA's deci-
sionmaking process was arbitrary, capricious, an abuse of 
discretion, or otherwise not in accordance with law.  See 5 
U.S.C. s 706(2)(A).  Here, Congress has clearly spoken, and 
under Chevron step one, the inquiry ends there.

     Section 502(d) of the Act, 42 U.S.C. s 7661a(d), requires 
each state to develop a state program to submit to the EPA.  
Each state must submit a legal opinion from the attorney 
general (or environmental agency's chief legal officer) "that 
the laws of the State, locality, or the interstate compact 
provide adequate authority to carry out the program."  42 
U.S.C. s 7661a(d)(1) (emphasis added).  It is this provision 
which has been interpreted to require a showing of jurisdic-
tion.  Then, "[n]ot later than 1 year after receiving a pro-
gram, and after notice and opportunity for public comment, 
the Administrator shall approve or disapprove such program, 
in whole or in part."  Id. (emphasis added).  The Act clearly 
requires notice and comment in approving or disapproving 

any part of a state program.  That includes the showing of 
adequate authority and thus jurisdiction.  EPA must deter-
mine, as part of that proceeding, which must include notice 
and comment, whether the state has jurisdiction.  It follows 
that if the state has jurisdiction, then the tribe does not, and 
vice versa.  Such proceedings are open to public comment, 
and judicial review, thus protecting the interests of the tribes 
as well as the states. Congress has explicitly required use of 
notice and comment in determining adequate authority (and 
jurisdiction) when the agency is evaluating the SOPs, and 
therefore EPA's decision to use separate adjudicatory pro-
ceedings that do not include notice and comment is contrary 
to law and does not survive either Chevron step one or APA 
review.

     Section 502(i), 42 U.S.C. s 7661a(i), further confirms Con-
gress's clear pronouncement.  Under that provision, "[w]hen-
ever the Administrator makes a determination that a permit-
ting authority is not adequately administering and enforcing a 
program, or portion thereof, in accordance with the require-
ments of this subchapter, the Administrator shall provide 
notice to the State...."  42 U.S.C. s 7661a(i)(1).  If the 
agency believes the state lacks jurisdiction, it must provide 
notice to the state and give the state 18 months to correct the 
"deficiency."  See id. at s 7661a(i)(4).

     Thus, it is clear under 42 U.S.C. s 7661a that jurisdictional 
determinations are to be made as part of approving or 
disapproving a state's (or tribe's) operating permit program, 
and with procedures that include "notice and opportunity for 
public comment."  42 U.S.C. s 7661a(d)(1).  The statute here 
is neither silent nor ambiguous;  it requires the use of notice 
and comment proceedings in the context where questions of 
jurisdiction are to be resolved.  As petitioners concede, such 
proceedings will likely be complex and difficult.  Nonetheless, 
they are mandated by Congress.  That ends our inquiry.

                         III.  Conclusion

     EPA must make jurisdictional determinations under the 
Clean Air Act.  It cannot simply declare a jurisdictional 

conflict and then implement a federal program in the absence 
of clear state or tribal authority.  Congress specifically delin-
eated a role for EPA and a role for states and tribes in the 
Clean Air Act.  Under the Act's plain language, EPA's au-
thority to implement a federal operating permits program is 
premised on the failure of a state or tribe to implement its 
own program, not some overarching national authority.  See 
42 U.S.C. ss 7601(d), 7661a.  Where a valid state program 
exists, EPA may implement a federal program only for 
Indian country itself, not for lands the status of which EPA 
deems "in question."  Thus, prior to implementing any feder-
al operating permits program EPA must determine the scope 
of state and tribal jurisdiction.

     In making such determinations EPA must use notice and 
comment proceedings.  The Act specifically provides for "no-
tice and opportunity for public comment" in approving or 
disapproving a state plan, in whole or in part, and it requires 
"notice to the State" whenever the "Administrator makes a 
determination that a permitting authority is not adequately 
administering and enforcing a program, or portion thereof."  
42 U.S.C. ss 7661a(d)(1), (i)(1).  This includes determinations 
of "adequate authority," and thus determinations of jurisdic-
tion under the Act.  Id. at s 7661a(d)(1).  Because Con-
gress's intent is clear, EPA's proposed approach is simply 
contrary to law.

     We grant the petition for review, vacate the portion of the 
1999 Part 71 rules authorizing EPA to treat lands for which 
EPA has deemed "Indian country" status to be "in question" 
as "Indian country," and remand to the agency for proceed-
ings consistent with this opinion.