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Abstract

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.

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