In an attempt to expedite and achieve consistency in judicial review of Environmental Protection Agency (EPA) actions taken pursuant to the Clean Air Act, Congress made certain regulatory decisions reviewable exclusively in the courts of appeals. Challenges to all other EPA actions, however, were relegated to the district courts. Not surprisingly, the proper forum for judicial review of particular EPA actions has been a matter of chronic dispute. In Harrison v. PPG Industries, Inc.,¹ a decision with potentially far-reaching implications, the Supreme Court recently adopted a very broad interpretation of the scope of direct appellate review under §307(b)(1) of the Act,² as amended in 1977. The Court acknowledged that its ruling may entail a massive jurisdictional shift from the district courts to the courts of appeals, giving rise to procedural difficulties because fact-finding devices are severely limited at the appellate level. It determined, however, that these problems are matters for congressional rather than judicial consideration and do not authorize the Court to disregard the clear if somewhat troubling import of the statutory provision vesting such broad jurisdiction in the courts of appeals.