Deep South v. EPA

United States Court of Appeals for the Fifth Circuit · May 21, 2025 · No. 24-60084

Summary

The Fifth Circuit dismissed a petition for review challenging the EPA's grant of primacy to Louisiana over Class VI underground injection control wells for carbon sequestration. The court held that the environmental organizations lacked Article III standing, finding their alleged injuries—such as diverted resources and speculative future economic or health harms—were not concrete, particularized, or imminent. The decision relies heavily on recent Supreme Court precedent regarding organizational and associational standing.

Court
United States Court of Appeals for the Fifth Circuit
Writing for the Court
Graves; Engelhardt; Oldham
Jurisdiction
United States Court of Appeals for the Fifth Circuit
Decision date
May 21, 2025
Docket number
24-60084
Procedural posture
Petition for review of EPA's final rule granting Louisiana primacy over Class VI underground carbon sequestration wells under the Safe Drinking Water Act.
Standard of review
de novo
Precedential value
published
Parties
Deep South Center for Environmental Justice, Healthy Gulf, Alliance for Affordable Energy v. United States Environmental Protection Agency, Lee Zeldin, Administrator, United States Environmental Protection Agency
Disposition
dismissed

Topics

standingadministrative lawjudicial review of agency actioncivil procedure

Practice areas

environmental lawadministrative lawcivil procedure

Questions Presented

  1. Whether Deep South Center for Environmental Justice has organizational standing to challenge EPA's grant of primacy.
  2. Whether Healthy Gulf and Alliance for Affordable Energy have associational standing to challenge EPA's grant of primacy.
  3. Whether the alleged injuries are concrete, particularized, imminent, and traceable to EPA's action.

Holdings

  1. All three petitioners lack standing; the petition for review is dismissed.

Key quotations

Article III requires plaintiffs to show they have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.
The Court unanimously found that injury insufficient: An organizational plaintiff cannot spend its way into standing simply by expending money to gather information and advocate against the defendant’s action.

Factual background

The EPA issued a final rule granting the State of Louisiana primacy to regulate Class VI underground injection control wells used for carbon dioxide sequestration. The petitioners—Deep South Center for Environmental Justice, Healthy Gulf, and Alliance for Affordable Energy—asserted that the EPA action would force them to divert resources and cause various speculative injuries, and they sought judicial review under the SDWA.

Procedural history

EPA granted Louisiana primary enforcement authority over Class VI UIC wells. Three environmental organizations filed petitions for review in the Fifth Circuit, alleging lack of standing. The Fifth Circuit considered organizational and associational standing doctrines and dismissed the petitions.

Court Document

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