On July 10, EPA issued a proposed finding that 20 upwind states satisfied their Clean Air Act obligations to address interstate transport of air pollution that allegedly contributes significantly to certain downwind states’ problems with meeting the 2008 National Ambient Air Quality Standards (NAAQS) for ozone. EPA explained that since its Cross State Air Pollution Update Rule (CSAPR II), which created a NOx emissions allowance trading scheme across 20 states to address their CAA “good neighbor” obligations, EPA has conducted further modeling and determined that the CSAPR II trading program will allow all downwind eastern states to achieve compliance with the 2008 ozone NAAQS by 2023. Thus, EPA proposes that it and the upwind states have no obligation to take additional action to satisfy those upwind states’ good neighbor obligations. A federal court had imposed deadlines on EPA to issue federal implementation plans for several of these states. If finalized as written, the proposal would also resolve all of EPA’s remaining obligations under the court order.