North Carolina Reply On Motion To Intervene 11/18/2013 ND Cal

Marc Bernstein (admitted pro hac vice)
Special Deputy Attorney General

North Carolina Department of Justice
P.O. Box 629
Raleigh, NC 27602
NC State Bar No. 21642
Phone Number: (919) 716-6956
Fax Number: (919) 716-6764
E-mail Address: [email protected]

Michael N. Westheimer (State Bar No. 178938)
Buchalter Nemer, PC
55 Second Street, Suite 1700
San Francisco, CA 94105-3493
Phone Number: (415) 227-0900
Fax Number: (415) 904-3111
E-mail Address: [email protected]

Attorneys for the State of North Carolina, Proposed Plaintiff-Intervenor

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

SIERRA CLUB and NATURAL
RESOURCES DEFENSE COUNCIL
Plaintiffs,
and

THE STATE OF NORTH CAROLINA
Proposed Plaintiff-Intervenor,

v.

REGINA MCCARTHY, in her official
capacity as Administrator of the United States
Environmental Protection Agency
Defendant.

_____________________________________

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Case No: 3:13-cv-03953 SI

Proposed Plaintiff-Intervenor
North Carolinas Reply
Memorandum of Points and
Authorities in Further Support of
Motion to Intervene

Date: Friday December 13, 2013
Time: 9:00 AM
Place: Courtroom 10, 19th Floor
Senior Judge: The Hon. Susan Illston

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Case3:13-cv-03953-SI Document69 Filed11/18/13 Page1 of 14

Reply Memorandum of Points and Authorities in Further Support of CASE NO.: 3:13-cv-03953 (SI)
Motion to Intervene Page i

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TABLE OF CONTENTS

TABLE OF AUTHORITIES .......................................................................................................... ii
INTRODUCTION .......................................................................................................................... 1
ARGUMENT .................................................................................................................................. 2
I. NORTH CAROLINA IS ENTITLED TO INTERVENE AS A MATTER OF RIGHT. ... 2
A. North Carolina Has Timely Moved to Intervene. ................................................... 2
B. North Carolina Has a Significant Protectable Interest in the Subject of this Action.
................................................................................................................................. 2
C. Disposition of this Action May Impair or Impede North Carolinas Ability to
Protect its Interests. ................................................................................................. 6
D. North Carolinas Interests Are Not Adequately Represented by the Existing
Plaintiffs. ................................................................................................................. 6
II. ALTERNATIVELY, NORTH CAROLINA IS ENTITLED TO INTERVENE ON A
PERMISSIVE BASIS ......................................................................................................... 8

III. INTERVENTION SHOULD BE ALLOWED WITHOUT CONDITIONS ..................... 9

IV. TO THE EXTENT THAT NORTH CAROLINAS INTERESTS ARE INSUFFICIENT
TO ALLOW INTERVENTION, PLAINTIFFS DO NOT HAVE STANDING ............. 10

V. CONCLUSION ................................................................................................................. 11


Motion to Intervene Page ii

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TABLE OF AUTHORITIES
Cases
Arakaki v. Cayetano, 324 F.3d 1078 (9th Cir. 2003) .................................................................. 2, 6
Beethoven.com LLC v. Librarian of Cong., 394 F.3d 939 (D.C. Cir. 2005) .................................. 5
Cetacean Cmty. v. Bush, 386 F.3d 1169 (9th Cir. 2004) .............................................................. 10
Natural Res. Def. Council v. U.S. E.P.A., 542 F.3d 1235 (9th Cir. 2008) ...................................... 3
Nw. Forest Res. Council v. Glickman, 82 F.3d 825 (9th Cir. 1996) ............................................... 7
Sierra Club v. U.S. E.P.A., 995 F.2d 1478 (9th Cir. 1993) ......................................................... 2, 6
State ex rel. Lockyer v. United States, 450 F.3d 436 (9th Cir. 2006) ........................................... 10

Sw. Ctr. for Biological Diversity v. Berg, 268 F.3d 810 (9th Cir. 2001) ........................................ 7
Trbovich v. United Mine Workers of Am., 404 U.S. 528 (1972) ................................................. 6,7
Statutes
42 U.S.C. 7401(a)(3)-(4) ............................................................................................................. 3
42 U.S.C. 7407(d)(1)(A)(i)-(iii) ................................................................................................... 8
42 U.S.C. 7407(d)(1)(B)(i) ......................................................................................................... 2
42 U.S.C. 7413(g) ....................................................................................................................... 5
Rules
Fed. R. Civ. P. 24(a)(2) ................................................................................................................... 2
Fed. R. Civ. P. 24(b) ....................................................................................................................... 8
Regulations
78 Fed. Reg. 47,191 (Aug. 5, 2013)............................................................................................... 9


Motion to Intervene Page 1

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INTRODUCTION
North Carolina should be granted intervention as a matter of right, or, in the alternative,
permissive intervention, in this action regarding the Environmental Protection Agency's (EPA)
failure to perform its nondiscretionary duty to designate all areas with respect to the revised
sulfur dioxide (SO
2
) National Ambient Air Quality Standard (NAAQS). Plaintiffs and EPA
claim that North Carolina does not have a significant protectable interest and therefore should
not be granted intervention as a matter of right. In order to make their arguments, both EPA and
Plaintiffs have misconstrued North Carolinas motion for intervention, citing inapposite cases in
an attempt to rebut their straw man argument. North Carolinas interest lies in obtaining EPAs
compliance with the Clean Air Act (CAA), in order to protect North Carolinas citizens and
comply with North Carolinas own duties in implementing the CAA. In addition, North Carolina
expressed concern that the existing parties might reach the content of or methodology for the
SO
2
designations in a potential disposition of this case, and expressed a desire that the resolution
of this case instead be limited to the deadline for EPAs designation action. EPA and Plaintiffs
have inappropriately focused their responses on North Carolinas desire to keep this action
limited to the schedule for EPAs designations and they intimate that the States sole interest
here is the substance of the designations and not the timing. The parties misconstruction of
North Carolinas interest aside, North Carolina has demonstrated a significant protectable
interest in the precise subject matter of this case.
North Carolina has a significant protectable interest in this action, and that interest would
be impaired or impeded by the disposition of this action. In addition, North Carolina would not
be adequately represented by the existing parties. Therefore, North Carolinas timely motion to
intervene as a matter of right should be granted. In the alternative, North Carolina should be
granted permissive intervention, an issue on which EPA does not take a position.


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ARGUMENT
I. NORTH CAROLINA IS ENTITLED TO INTERVENE AS A MATTER OF
RIGHT.

The four requirements for intervention pursuant to Rule 24(a)(2) of the Federal Rules of
Civil Procedure are (1) a timely application, (2) a significant protectable interest in the subject
matter of the action, (3) the potential for impairment or impediment of that interest by the
resolution of the action, and (4) inadequate representation of that interest by the existing parties.
These requirements are liberally construed in favor of applicants for intervention. Arakaki v.
Cayetano, 324 F.3d 1078, 1083 (9th Cir. 2003). North Carolina meets these four requirements.
A. North Carolina Has Timely Moved to Intervene.
North Carolina filed its motion at a very early stage of the proceeding without any
improper delay, and without causing any prejudice to the existing parties. The Defendant (EPA)
had not yet filed a responsive pleading to Plaintiffs Complaint and the Court had not yet held
the initial case management conference. Order Setting Deadlines (ECF No. 8). Neither EPA nor
Plaintiffs have challenged the timeliness of North Carolinas motion in their responses.
B. North Carolina Has a Significant Protectable Interest in the Subject of this
Action.

The requirement of a significant protectable interest is satisfied when the interest is
protectable under some law, and . . . there is a relationship between the legally protected interest
and the claims at issue. Arakaki, 324 F.3d at 1084 (quoting Sierra Club v. EPA, 995 F.2d 1478,
1484 (9th Cir. 1993)). North Carolina has a protectable interest in ensuring that the Court
remedies EPAs failure to carry out its nondiscretionary duty to designate areas in North
Carolina for the revised SO
2
NAAQS, and has a protectable interest in seeing that this is done, as
Congress mandated, as expeditiously as practicable. 42 U.S.C. 7407(d)(1)(B)(i) (2013).


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As noted by EPA, the CAA is a cooperative joint state and federal program. EPAs
Resp. to Motions to Intervene at 5 (ECF No. 54) (citing 42 U.S.C. 7401(a)(3)-(4)). North
Carolina has been charged under the CAA with ensuring that the NAAQS are met in a timely
manner and maintained within its borders. Proposed Plaintiff-Intervenor North Carolinas
Motion to Intervene at 7 (ECF No. 16 at 7). Achieving and maintaining the SO
2
NAAQS is a
protectable interest under the CAA, as is protecting the States resources and the health of its
citizens. See, e.g., NRDC v. EPA, 542 F.3d 1235 (9th Cir. 2008) (recognizing state-intervenors
proprietary interest in protecting their waterways). North Carolina has an interest in knowing
EPAs designations, regardless of their content or the methodology used, so that North Carolina
may fulfill its duties under the CAA. Ironically, Plaintiffs challenge North Carolinas interest in
this information despite the fact that Plaintiffs themselves allege a similar interest in this
information in their Complaint for Declaratory and Injunctive Relief (ECF No. 1 at 4-5, 10)
albeit from the perspective of a citizen group that would use the information in a different
manner than a State. Indeed, the State maintains an even closer connection with this interest in
that it has a legal obligation regarding the public health and welfare and the environment and is
charged with specific mandates under the CAA itself with regard to these obligations.
EPAs failure to designate areas as required by the CAA subjects North Carolina to a
detrimental uncertainty that will negatively affect the States economy, development, and the
public interest, as set forth in North Carolinas Motion to Intervene. Holman Decl. at 6, 16
(ECF No. 16-1). EPA and Plaintiffs otherwise conveniently ignore North Carolinas significant
protectable interest in the deadline for EPAs designations, preferring to mischaracterize North
Carolinas interest as primarily an interest in the content of the designations. Plfs Opp. to
States Motions to Intervene at 1 (ECF No. 52); ECF No. 54 at 9. However, both Plaintiffs and
EPA admit that if EPA chooses to designate an area as nonattainment, the requirements placed


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on States such as North Carolina by the CAA would change. ECF No. 54 at 7, 11-12; ECF No.
52 at 12. While Plaintiffs mischaracterize North Carolinas interest in EPAs designations as an
interest in avoiding additional regulation, ECF No. 52 at 12, North Carolinas motion to
intervene is completely devoid of such an interest. North Carolina is instead interested in
knowing EPAs designations, whatever they may be. As admitted by Plaintiffs and EPA, EPAs
designations have the potential to change the requirements expected of North Carolina and a
nonattainment designation would mean that North Carolinas citizens are not currently being
sufficiently protected under federal law. That is the crux of this case, as framed by the Plaintiffs
the interest of Plaintiffs and the States in knowing EPAs actual designations, whatever their
content, allowing them to use that information as appropriate. See Complaint at 4-5, 8-10
(ECF No. 1).
North Carolinas stated concern that the disposition of this action should be limited to the
timeframe for EPAs overdue designations, rather than the content or methodology for those
designations, has been painted by the existing parties as an interest in the content of the
designations. In fact, it is just the opposite. North Carolina has an interest in the deadline for
EPAs designations and desires to ensure that the disposition of this action is limited to the same.
Plaintiffs and EPA attempt to cast North Carolinas interest as one that is too remote or
speculative, since they allege that North Carolina is only interested in the content of the
designation, which is not at issue in this case. See, e.g., ECF No. 54 at 17; ECF No. 52 at 15. In
support of this incorrect interpretation of North Carolinas interest, Plaintiffs and EPA cite
numerous cases wherein a movant was not allowed to intervene because its interests were outside
of the scope of the claims at issue in the case or were too speculative because they hinged not
only on the outcome of the case but on some second, later action. ECF 54 at 13-14; ECF 52 at 9,
11. These cases are inapposite. North Carolinas interest in this matter is not contingent on any


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later action by EPA, but rather is directly related to the deadline for EPAs designations. North
Carolinas uncertainty regarding its compliance with its duties under the CAA and its citizens
health will be resolved once EPA designates, no matter what the content of the designations may
be. Unlike in cases such as Beethoven.com LLC v. Librarian of Cong., 394 F.3d 939 (D.C. Cir.
2005), where the potential intervenors raised issues outside of those raised in the original
complaint, North Carolina has raised the same issues as are already alleged in this case, which is
evidenced by North Carolinas Complaint in Intervention. In fact, North Carolina has expressed
a desire that the remedy be limited to just what is alleged in Plaintiffs and North Carolinas
Complaints. See, e.g., ECF No. 16 at 14. Therefore, North Carolina should be allowed to
intervene.
Both EPA and Plaintiffs have alleged that North Carolinas interest in being heard in any
settlement negotiations is not a sufficient interest. See, e.g., ECF No. 54 at 15. EPA suggests
that Section 113(g) of the CAA, 42 U.S.C. 7413(g), provides adequate protection. However,
Section 113(g) only allows an entity to comment on a settlement that has already been drafted
and to which the parties have already agreed. Furthermore, Section 113(g) only provides that
EPA may withdraw from the settlement if a commenting entity shows that EPAs consent was
improper. Id. EPA also notes that, if allowed to intervene, North Carolina could not bar the
existing parties from settling the matter. ECF No. 54 at 15. However, EPA admits that as an
intervenor, North Carolina would be entitled to have objections to a proposed settlement, if any,
heard by the Court rather than just by EPA pursuant to CAA Section 113(g). Id.
North Carolina has demonstrated its significant protectable interest in having the
designations completed by a date certain, which is the subject matter of this case. See ECF No.
16 at 11-12. Therefore, North Carolina should be allowed to intervene as a matter of right.


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C. Disposition of this Action May Impair or Impede North Carolinas Ability to
Protect its Interests.

An applicant for intervention must also show that disposition of the action may, as a
practical matter, impair or impede the partys ability to protect that interest. [I]f the resolution
of the plaintiffs claims actually will affect the applicant, this requirement has been met.
Arakaki, 324 F.3d at 1084 (quoting Sierra Club, 995 F.2d at 1484). Plaintiffs allege that North
Carolina does not have significant protectable interests that can be impaired or impeded. As
explained above, that argument stems from a mischaracterization of North Carolinas motion.
The resolution of this matter would actually affect North Carolina, since an order or other
instrument requiring designation by a date certain would resolve North Carolinas uncertainty
about EPAs designations. Therefore, North Carolina has met the third requirement for
intervention.
While North Carolina noted in its motion an additional interest in assuring that any
resolution of this matter is limited to requiring EPA to immediately promulgate and publish SO
2

designations, this was not North Carolinas sole stated interest as EPA would have the Court
believe. See ECF No. 54 at 16. As North Carolinas Complaint in Intervention makes very
plain, ECF No. 16-2, the State is undoubtedly interested in the deadline for EPAs designations,
no matter what the content of or procedure for the designations.
D. North Carolinas Interests Are Not Adequately Represented by the Existing
Plaintiffs.

An applicants burden in showing inadequate representation is minimal, and the
applicant need only show that representation of its interests by existing parties may be
inadequate. Trbovich v. United Mine Workers of Am., 404 U.S. 528, 538 n.10 (1972). In
determining whether the prospective intervenors interest will be adequately represented by an
existing party, courts consider:


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(1) whether the interest of a present party is such that it will undoubtedly make all
the intervenors arguments; (2) whether the present party is capable and willing to
make such arguments; and (3) whether the would-be intervenor would offer any
necessary elements to the proceedings that other parties would neglect.

Nw. Forest Res. Council v. Glickman, 82 F.3d 825, 838 (9th Cir. 1996). [I]t is not the
Applicants burden at this stage in the litigation to anticipate specific differences in trial strategy.
It is sufficient for Applicants to show that, because of the difference in interests, it is likely that
Defendants will not advance the same arguments as Applicants. Sw. Ctr. for Biological
Diversity v. Berg, 268 F.3d 810, 824 (9th Cir. 2001).
As a State responsible for ensuring that the NAAQS are met and maintained within its
borders, North Carolina may have substantially different views on the schedule for EPA's
designations that may not be adequately represented by the Plaintiffs or EPA. See ECF No. 16 at
15. This difference in position between North Carolina and the existing Plaintiffs was pointed
out in North Carolinas motion, contrary to EPAs allegations. See ECF No. 54 at 17. As set
forth in Sw. Ctr. for Biological Diversity and Trbovich, North Carolina need not go into great
detail to meet its minimal burden regarding this element. Therefore, North Carolina has met
the test for intervention as a matter of right and should be allowed to intervene.
In fact, North Carolinas unique and inadequately represented position has now become
even more apparent since Plaintiffs filed their Motion for Summary Judgment. In their Motion,
Plaintiffs requested separate briefing on the issue of remedy, to which EPA agreed in its
Response. Plfs Mot. for Summary Judgment at 6 (ECF No. 55); EPAs Resp. to Mot. for
Summary Judgment at 2 (ECF No. 63). It is North Carolinas position that the determination of
the remedy should be a relatively simple matter. Because the substantive options open to EPA


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regarding designations are very limited at this point,
1
extensive briefing on remedy is
unnecessary. Arguably, in order to discharge its duty to promulgate designations under the SO
2

standard, EPA should need little more than the time required for the ministerial act of drafting
and publishing a notice in the Federal Register. The parties request for a fourteen-day meet-
and-confer period in order to develop a briefing schedule suggests that the parties view the issue
of remedy in a different light. This apparent difference in positions only further serves to
demonstrate that North Carolinas interests are not adequately represented by the existing parties,
and North Carolina should therefore be granted intervention.
II. ALTERNATIVELY, NORTH CAROLINA IS ENTITLED TO INTERVENE ON A
PERMISSIVE BASIS.

In the alternative, North Carolina should be allowed to intervene in this action on a
permissive basis. Rule 24(b) of the Federal Rules of Civil Procedure states that the court may
grant permissive intervention on a timely motion to anyone who has a claim or defense that
shares with the main action a common question of law or fact. North Carolina clearly meets
these requirements.
The existing parties have not challenged the timeliness of North Carolinas motion.
Accordingly, the motion is conceded to be timely.
As evidenced by North Carolinas Complaint in Intervention, its claims share common
issues of law or fact with this action. In addition, North Carolina informed the Court of its
Notice of Intent to Sue in its motion to intervene, ECF No. 16 at 16, and has since filed an action
in the United States District Court for the Eastern District of North Carolina demanding that EPA

1
Because EPAs time to promulgate designations has expired, if EPA now lacks a sufficient base
of data on which to designate an area as attainment or nonattainment, it must designate the
area as unclassifiable. It cannot instead simply further defer the designation on the hope of
collecting more data. See 42 U.S.C. 7407(d)(1)(A)(i)-(iii).


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be ordered to perform its nondiscretionary duty to designate. State of North Carolina v. EPA,
E.D.N.C. Case No. 5:13-cv-710, ECF No. 1 (Complaint). Therefore, North Carolina has a claim
that shares a common question of law and fact with the claim in this action. North Carolinas
involvement in this litigation would not prejudice or delay the adjudication of the original
parties rights, and North Carolina should be granted permissive intervention.
III. INTERVENTION SHOULD BE ALLOWED WITHOUT CONDITIONS.

Plaintiffs and EPA have both requested conditions on any potential intervention granted
by this Court. EPA requests that no attorneys fees be required of it for any work done in
connection with the proposed intervention of North Carolina and other States. ECF No. 54 at 18.
However, EPA provides no justification for its request that it not be required to pay fees to the
proposed intervenor States even though its actions have harmed not only the Plaintiffs, but the
States as well. There is no rule of law that the party who gets to the courthouse steps first may
be entitled to fees to the exclusion of parties who timely file thereafter and have equally
justifiable claims. Nor is there any equity in EPAs legally unsupported suggestion.
Plaintiffs request that the actions of other States against EPA be transferred to this Court,
and that any intervention be limited in such a way that the States not delay the suit in any way,
including by conducting discovery. ECF No. 52 at 16. North Carolina believes that the Eastern
District of North Carolina is the most appropriate venue for this action, since EPAs Office of
Air Quality Planning and Standards (OAQPS), which has a principal role in promulgating
designations, is located in that district. See, e.g., 78 Fed. Reg. 47,191, 47,192 (Aug. 5, 2013)
(naming OAQPS as the contact for any questions regarding EPAs designations). Therefore, if
these actions should be consolidated anywhere, it would make the most sense to transfer them to
the Eastern District of North Carolina, rather than vice versa. In addition, while North Carolina
cannot yet say whether discovery will be necessary, North Carolina should not be limited in its


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intervention to anything less than what the Plaintiffs are permitted to do. The Plaintiffs present
no justification for their attempt to hamstring North Carolinas participation aside from their own
fear that resolution of the matter will be delayed. North Carolina has consistently taken the
position that EPAs failure to act is unlawful and that the agency should be held strictly to the
CAAs mandate to act as expeditiously as practicable. See ECF No. 16 at 11; ECF No. 16-1 at
5, 10. North Carolina has no interest in delaying the resolution of this case and prolonging
EPAs inexplicable failure to implement Congress statutory scheme. The Plaintiffs fears are
entirely unfounded.
IV. TO THE EXTENT THAT NORTH CAROLINAS INTERESTS ARE
INSUFFICIENT TO ALLOW INTERVENTION, PLAINTIFFS DO NOT HAVE
STANDING.

Plaintiffs contend that North Carolina has not demonstrated how uncertainty caused by
EPAs failure to act prejudices North Carolinas protectable interests. In their Complaint,
Plaintiffs allege injury due to the same uncertainty they now challenge as insufficient in their
response to North Carolinas motion to intervene. ECF No. 1 at 4-5. If the Court agrees with
Plaintiffs that uncertainty does not rise to the level of a significant protectable interest allowing
North Carolina to intervene in this matter, Plaintiffs should not be able to rely on what is
essentially a similar but arguably less clearly protected interest in alleging that the Court has
subject matter jurisdiction over their claims. See Cetacean Cmty. v. Bush, 386 F.3d 1169, 1174
(9th Cir. 2004) (confirming that standing is a subject matter jurisdiction issue); see also State ex
rel. Lockyer v. United States, 450 F.3d 436, 442 (9th Cir. 2006) (noting the relationship between
the standing and intervention standards). North Carolina therefore submits that if the Court
denies North Carolinas Motion for Intervention as a matter of right for lack of a significant
protectable interest, that North Carolina at a minimum be granted permissive intervention for the
limited purpose of filing a motion to dismiss Plaintiffs action for lack of standing.


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V. CONCLUSION
For the foregoing reasons, the State of North Carolina respectfully requests that the Court
grant its Motion to Intervene.
DATED: November 18, 2013
Respectfully submitted,
ROY COOPER
Attorney General

By: /s/ Marc Bernstein
Marc Bernstein
Special Deputy Attorney General
N.C. Department of Justice

/s/ Michael N. Westheimer
Michael N. Westheimer
Buchalter Nemer, PC

Attorneys for the State of North Carolina


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Marc Bernstein (admitted pro hac vice)

Special Deputy Attorney General

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