A district court held that Washington state must establish reasonably available control technology (RACT) for greenhouse gas emissions.

A district court denied environmental groups' motion to intervene in a proposed consent decree resolving the District of Columbia's lawsuit against a power company alleging PCB contamination in the Anacostia River, but allowed the groups to participate as amici curiae.

A California appellate court held that a state agency's certification of an environmental impact report (EIR) and approval of a master plan for the expansion of a state university violated the California Environmental Quality Act (CEQA).