Congress passed new amendments to the Clean Air Act relating to control new sources in non-attainment areas of the nation that had yet to achieve national air quality standards. The EPA promulgated new rules that allowed states to define an entire plant under the bubble theory of pollution; as long and the total emissions from a plant as a unit became no worse, changes were allowed to be made by the plant at will. The Court of Appeals determined that the statute did not permit the EPA to allow the bubble definition to define a 'stationary source' in non-attainment areas of the country; as this would undermine Congress's goal of speedy compliance with national air quality standards. During the Carter administration, the EPA had considered adopting a plantwide definition of 'source' but eventually adopted a regulation that defined each unit as a 'source.' The Reagan, EPA, changed the regulation and allowed states to use the plantwide definition of source (or in other words, the bubble theory).

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