An official website of the United States government. As relevant here, Section 505(a)(1) provides that "any citizen may commence a civil action on his own behalf * * * against any person * * * who is alleged to be in violation of * * * an effluent standard or limitation under this chapter." 456 U.S. at 316. Compare pay Our offices are strategically located in the Gulf Coast. WebFriends of Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (2000) Argued: October 12, 1999 Decided: January 12, 2000 Annotation Primary Holding A party trying to show that the mootness doctrine applies because it will voluntarily cease an activity must show that the activity would not recur. On-Call Environmental Services for Metropolitan Water District of Southern California. WebRincon Consultants, Inc. was founded in 1994 and has grown to be a leading environmental consulting firm throughout California. Get free summaries of new US Supreme Court opinions delivered to your inbox! The court of appeals also stated that petitioners are not entitled to recover their costs of litigation because they are not "prevailing or substantially prevailing part[ies]" within the meaning of Section 505(d). CWA 505(c)(3), 33 U.S.C. District Court found that Laidlaw had gained a total economic benefit of $1,092,581 as a result of its extended period of noncompliance with the permit's mercury discharge limit; nevertheless, the court concluded that a civil penalty of $405,800 was appropriate. WebFriends of the Earth, Inc. v. Laidlaw Environmental Services, Inc. 528 U.S. 167 (2000) Study Aids Case Briefs Overview Casebooks Case Briefs From our private database of 38,100+ Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (2000), exposes fundamental incoherencies within environ-mental standing doctrine, even while it ostensibly makes standing easier to prove for plaintiffs in environmental citizen suits. Headquarters. Pet. The court of appeals concluded that the district court's refusal to provide injunctive relief had critical constitutional implications. 9a n.5. WebLaidlaw Environmental Services - Case - Faculty & Research - Harvard Business School Harvard Business School Faculty & Research Publications July 1993 (Revised August 1994) Case HBS Case Collection Laidlaw Environmental Services By: Richard H.K. City of Mesquite v. Aladdin's Castle, Inc., 455 U. S. 283, 289. Respectfully submitted. Weve been identifying carbon-rich wastes to use in our Chem-Fuel program since 1975. 1319(d)]" to deter future violations. Defendant-respondent Laidlaw Environmental Services (TOC), Inc., bought a facility in Roebuck, South Carolina, that included a wastewater treatment plant. May 21, 2018. Pet. Company size. at 477, 478-479 (J.A. Web394 Virginia Environmental Law Journal [Vol. The question, for purposes of Article III's case-or-controversy requirement, is whether petitioners' claim for relief presented a live controversy under the principles that this Court has established for determining mootness. Read More Syllabus See also Maher v. Gagne, 448 U.S. 122, 129 (1980) ("for purposes of the award of counsel fees [under 42 U.S.C. 98-10463-MEL. Data inaccuracies may exist. WebLaidlaw was a great company and community. At the time of that suit, Section 505(d) of the Clean Water Act authorized courts to award attorneys' fees "whenever the court determines such award is appropriate." BBB Rating: A+. Pp.180-195. LES LOKERN proposed to add a landfill and a container storage facility. CONCLUSION The judgment of the court of appeals should be vacated and the case remanded for further proceedings. The Respondent was acquired by Laidlaw Environmental Services, Inc. on December 23, 1992. Ibid. In the Supreme Court of the United States FRIENDS OF THE EARTH, INC., ET AL., PETITIONERS v. LAIDLAW ENVIRONMENTAL SERVICES (TOC), INC. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT BRIEF FOR THE UNITED STATES AS AMICUS CURIAE SUPPORTING PETITIONERS SETH P. WAXMAN Solicitor General Counsel of Record LOIS J. SCHIFFER Assistant Attorney General LAWRENCE G. WALLACE Deputy Solicitor General JEFFREY P. MINEAR Assistant to the Solicitor General DAVID C. SHILTON R. JUSTIN SMITH Attorneys Department of Justice Washington, D.C. 20530-0001 (202) 514-2217 QUESTIONS PRESENTED 1. 523 U.S. at 108. $500,000 civil penalty addressing hazardous waste burning violations. Laidlaw began to discharge various pollutants into the waterway. Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (2000), exposes fundamental incoherencies within environmental standing doctrine, even while it ostensibly makes standing easier to prove for at 477 (J.A. The Clean Water Act's Citizen-Suit Provisions Authorize Private Judicial Actions To Compel Dischargers To Comply With Their Discharge Permits The Clean Water Act, like other federal environmental statutes, creates a federal-state partnership for developing environmental standards and providing for their enforcement. See, e.g., W.T. The Court has previously indicated, in connection with other federal statutes that authorize "prevailing parties" to recover attorneys' fees, that a plaintiff whose suit induces the defendant to comply with the law voluntarily is a "prevailing party." The doctrine of mootness, by contrast, requires a court to discontinue its exercise of judicial power if it determines that a live case or controversy no longer exists in light of changed circumstances. WebECOS provides all of its customers with a one year guarantee on its water damage and fire damage repairs. 588, 600-01, 610 (D.S.C.1997). 5 The courts of appeals, other than the Fourth Circuit, have concluded under various rationales that a citizen plaintiff who proves that the defendant was in violation of a NPDES permit at the time of suit may obtain civil penalties to deter future violations, even if the violations by that time ceased. C. The court of appeals erred in failing to apply the Court's teachings in City of Mesquite and other decisions, which establish that a defendant's mere voluntary cessation of unlawful conduct does not automatically moot a case. By authorizing citizens to seek civil penalties, Congress intended to provide citizens with an additional means of compelling compliance through the specific deterrent force of a monetary sanction. See CWA 309(a)-(g), 33 U.S.C. Pet. 1998); Atlantic States Legal Found., Inc. v. Stroh Die Casting, Inc., 116 F.3d 814, 820 (7th Cir. at 478 (J.A. Self-operation conversions for all three were urged by Virginia Department of Education officials as "cost-saving." Id. In 1978, Laidlaw entered the United States solid waste industry, Laidlaw Waste Systems, a wholly owned subsidiary of Laidlaw Inc, In 1986 Laidlaw acquired Genstar Corp (GSX) of Boston and in 1996 then sold its solid waste business to Allied Waste Industries and many former Laidlaw operations where then rebranded to local names depending on the locations. Fined $1 million for violations including illegal handling and disposalof hazardous wastes at its commercial hazardous waste fuel blending facilityin Crowley. Pet. The court then requested and received, through a brief amicus curiae, the views of the United States on that issue. 1342(a)(2); 40 C.F.R. In 1998, a watershed year, Laidlaw Inc. acquired Greyhound Lines U.S. operations, Greyhound Canada, the DAVE Companies (specialists in paratransit) and emergency management companies EmCare and Spectrum Emergency Care. Grant Co., and Oregon State Med. May 22, 2018. 2-3, supra. Specifically, the court of appeals incorrectly concluded that the district court's discretionary decision to withhold injunctive relief in the face of Laidlaw's post-complaint cessation of its permit violations necessarily rendered petitioners' enforcement action moot. Ibid. Laidlaw undertook those steps to interpose a bar to the citizen suit under Section 505(b)'s "diligent prosecution" provision, 33 U.S.C. Id. See 33 U.S.C. With locations in Reston, VA, Philadelphia, PA, and Baltimore, MD, Comstock Environmental also offers regulatory compliance, site characterization and remediation, Garbage, on the other hand, always had to be dealt with. Laidlaw Environmental Services - Interim Decision, December 21, 1993 Interim Decision, December 21, 1993 STATE OF NEW YORK : DEPARTMENT OF ENVIRONMENTAL CONSERVATION Office of Hearings 50 Wolf Road Albany, New York 12233-1550 In the Matter of the Application of Laidlaw Environmental Services, Inc. and If there were no such exception to the mootness doctrine, a defendant could thwart the efforts of other parties or the government to enforce the law indefinitely. In August 1992, Laidlaw denied all charges but agreed to pay US andCanadian shareholders $7.65 million in a class action settlement whichclaimed that the officers had "misrepresented the financial condition ofLaidlaw. Cadence developed the use of Chem-Fuel using industrial wastes to replace the use of non-renewable resources as fuels for use in cement kilns. See, e.g., Lujan v. Defenders of Wildlife, 504 U.S. at 561; Lujan v. National Wildlife Fed'n, 497 U.S. 871, 883-889 (1990); Gladstone, Realtors v. Village of Bellwood, 441 U.S. 91, 114-115 & n.31 (1979). 1991) (dictum). Whether a citizen plaintiff is barred from recovering litigation costs under Section 505(d) of the Clean Water Act if the citizen suit is dismissed as moot. Laidlaw sold the Canadian operations to USA Waste Services, Inc. Laidlaw American branch's where re-branded to many different names, depending on the location of were they were. See 33 U.S.C. Laidlaw II, 956 F. Supp. 1365(b)(1)(A). FRIENDS OF THE EARTH, INC., ET AL. Assuming, arguendo, that FOE initially had standing, the appellate court held that the case had become moot once Laidlaw complied with the terms of its permit and the plaintiffs failed to appeal the denial of equitable relief. See, e.g., Murphy v. Hunt, 455 U.S. 478, 482 (1982) (evaluating whether challenged conduct is "capable of repetition, yet evading review"); Geraghty, 445 U.S. at 400 (noting, in the class action context, the "flexible character of the Article III mootness doctrine"); see also Honig v. Doe, 484 U.S. 305, 331 (1988) (Rehnquist, C.J., concurring). The court rejected Laidlaw's diligent prosecution defense after an extensive analysis of the substance of the settlement and the circumstances by which it was reached. The court additionally instructed that petitioners are not entitled to recover their litigation costs because they failed to prevail on the merits and therefore are not a "prevailing or substantially prevailing party" within the meaning of Section 505(d) of the Clean Water Act. Under the Clean Water Act, corporations such as Laidlaw Environmental Services received permits that limited them to certain amounts of discharges of dangerous substances. The defendant must show that "subsequent events made it absolutely clear that the allegedly wrongful behavior could not reasonably be expected to recur." Paid a fine of $80,000 in November, 1993 and agreed to $3.5 million inimprovements to abate odors emanating from "bio-sludge.". Laidlaw (/ledl/), organized as Laidlaw International, Inc. (with corporate headquarters in Naperville, Illinois) was the largest provider of intercity bus services, contract public transit and paratransit, and contract school bus service in both the United States and Canada. WebIn 1995, NELC filed suit against garbage giant Laidlaw Environmental Services for violating the Clean Water Act hundreds of times at its Hilliard, OH, facility. The state court approved the settlement on June 10, 1992, the day after the expiration of Section 505(b)'s 60-day notice period, 33 U.S.C. Laidlaw Environmental Services, Inc. filed as a Domestic Business Corporation in the State of New York on Wednesday, May 7, 1980 and is approximately forty-three years old, as recorded in documents filed with New York Department of State. As we next explain, the court's ruling overlooks established principles that guide how the mootness doctrine should be applied in this case. WebLAIDLAW WASTE SYSTEMS INC is located at and is classified as a Transporter by the Environmental Protection Agency. 33 U.S.C. 1365(a)(1).1 Section 505(b) generally bars a citizen from suing until 60 days after the citizen gives notice of the alleged violation to EPA, the relevant State, and the alleged violator, 33 U.S.C. Troubles at Laidlaw, however, continued to dog DeGroote even after heleft. 98-822 FRIENDS OF THE EARTH, INC., ET AL., PETITIONERS v. LAIDLAW ENVIRONMENTAL SERVICES (TOC), INC. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT BRIEF FOR THE UNITED STATES AS AMICUS CURIAE SUPPORTING PETITIONERS INTEREST OF THE UNITED STATES The United States, in cooperation with the individual States, has primary responsibility for implementing and enforcing the Clean Water Act (CWA), 33 U.S.C. Allied Waste SystemsAllied's Chief Executive Officer, Roger Ramsey, was the Vice Presidentand Chief Financial Officer for BFI from 1968 to 1976. 1993); see also Comfort Lake Ass'n v. Dresel Contracting, Inc., 138 F.3d 351, 356 (8th Cir. in Opp. In Romero-Barcelo, citizens demanded an injunction to abate government discharges of ordnance, which qualified as a pollutant under the Clean Water Act. 1365(b). Stern, supra, at 716; see id. WebWe put it to work as energy to make cement. The civil penalty remedy is also a useful alternative to an injunction because, if the court concludes that an assessment of civil penalties will effectively deter future violations, then the court will not need to engage in the potentially cumbersome role of supervising the defendant's future compliance through an ongoing injunction. City of Mesquite, 455 U.S. at 289 n.10 (quoting Concentrated Phosphate Export Ass'n, 393 U.S. at 203, and W.T. 15-19, supra. In acquiring Laidlaw, FirstGroup announced that the Laidlaw name would not be kept, but that the Greyhound name would be maintained. Under this Court's normal practice, the case will be remanded for resolution of the remaining issues that the court of appeals did not reach, including the question of petitioners' standing. The company`s management are President, Director - Stilwell William E Jr, Vice President - 956 F. Supp. Cf. "It is the duty of the courts to beware of efforts to defeat injunctive relief by protestations of repentance and reform, especially when abandonment seems timed to anticipate suit, and there is probability of resumption." We next address how this Court's mootness doctrine operates in the context of those provisions. WebFind company research, competitor information, contact details & financial data for Laidlaw, Inc. of Little Rock, AR. Laidlaw operated a hazardous waste incineration facility in Roebuck, South Carolina. The district court assessed civil penalties and attorneys fees to "provide adequate deterrence under the circumstances of this case," ibid. Penalized $30,000 for unauthorized emissions from their incinerator's stacks. 7 Congress drafted Section 309(d)'s standards for assessing civil penalties (see note 6, supra) with deterrence of violations specifically in mind. 4, In the meanwhile, Degroote busied himself building a new waste empire.In 1991, DeGroote took over Republic Waste from Browning Ferris Industriesfounder Tom Fatjo.5In 1995 DeGroote gave up control of Republic to Waste Management Inc. founderWayne Huizenga. Work is often performed at active facilities in densely populated, urban areas. 183). Laidlaw used these A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Gwaltney, 484 U.S. at 66 (quoting Concentrated Phosphate Export Ass'n, 393 U.S. at 203) (emphasis added by the Court in Gwaltney). After Laidlaw Environmental Services, Inc. bought a wastewater treatment plant, it was granted a National Pollutant Discharge Elimination System (NPDES) permit. B. The company`s registered agent is FL. See CWA 309, 33 U.S.C. | Library of Congress. at 611 (J.A. This Court has recognized that the foregoing principles governing mootness are directly applicable to Clean Water Act citizen suits. See Gwaltney, 484 U.S. at 65-66; id. Newport News, Virginia. But it nevertheless denied injunctive relief, stating that Laidlaw need not demonstrate "no chance of a future permit violation" to defeat petitioners' request for an injunction. The court concluded that "the fact that Laidlaw is now and has for an extended time been in compliance with its permit" supported its decision that "no injunction or other form of equitable relief is appropriate." at 600-601 (J.A. Forced to address complaints from the school next door of odors and noiseIn 1994, odors from Laidlaw's industrial wastewater treatment facilitywere so strong, children reported burning eyes and throats. Id. 33 U.S.C. at 600-601 (J.A. Laidlaw II, 956 F. Supp. Hewitt v. Helms, 482 U.S. 755, 761 (1987). 123.27. Id. at 7a.3 The court of appeals noted that the district court had denied injunctive relief and, instead, assessed civil penalties, which are payable to the United States Treasury. United States Bancorp Mortgage Co. v. Bonner Mall Partnership, 513 U.S. 18, 24-25 (1994) ("The judgment is not unreviewable, but simply unreviewed by [the losing party's] own choice."). In addition, if the defendant knows that it faces the prospect of civil penalties as well as an injunction, it will not have an incentive to engage in "dilatory tactics" to prolong the litigation in the hope of eliminating the need for an injunction and then claiming that the citizen's claim for assessment of the accumulated civil penalties is moot. 33 U.S.C. The civil penalties, which the court expressly levied to deter future violations, were an appropriate judicial means to that end. This Court indicated in Gwaltney that citizens would be entitled to recover litigation costs for suits that "result in successful abatement but do not reach a verdict." Pt. A citizen who is aggrieved by permit violations has standing to sue to enforce the permit and thereby abate those violations. 8a-9a. If the United States has not filed its own action, it may intervene in the citizen action. at 318. The citizen "may seek civil penalties only in a suit brought to enjoin or otherwise abate an ongoing violation." B. See 33 U.S.C. A. It argued that the case was now moot because it had corrected the problems from which it had stemmed. WebRincon Consultants, Inc. was founded in 1994 and has grown to be a leading environmental consulting firm throughout California. at 600-601 (J.A. Id. WebECOS provides all of its customers with a one year guarantee on its water damage and fire damage repairs. In the 1990s, Laidlaw continued to acquire hundreds of smaller school bus and public transit contractors in the U.S. and Canada. Office of the Solicitor General Under this Court's normal practice, the case should be remanded for resolution of the remaining issues that the court of appeals did not reach. ARGUMENT The Court of Appeals Erred In Holding That A Citizen Suit Must Be Dismissed As Moot Unless The Citizen Plaintiff Obtains Injunctive Relief The court of appeals' ruling that petitioners' citizen suit is moot rests on a misunderstanding of the Clean Water Act's citizen-enforcement provisions and this Court's mootness jurisprudence. WebFind 6 listings related to Laidlaw Environmental Svc Inc in Newport News on YP.com. Decided: November 22, 1999 1342(a). However, DeGroote is still one of Republic's largest shareholdersand is Vice-Chairman.6, Rollins Environmental ServicesBusiness Week ranked Rollins Environmental's board of directors asone of the worst. The Court ruled that, even if EPCRA authorized a citizen to sue for wholly past violations, the citizens' suit must be dismissed because the citizens lacked Article III standing to seek relief that does not redress a cognizable "injury in fact" to the citizens. Decided November 22, 1999. But the court denied injunctive relief as a matter of equitable discretion, treating Laidlaw's compliance history as a factor bearing on the exercise of that discretion. The permit authorized Laidlaw to discharge treated water into the North Tyger River, but limited, among other things, the discharge of pollutants into the waterway. Nevertheless, the district court found that, within two months after petitioners filed their complaint, Laidlaw was in "substantial compliance." If the Court concludes that petitioners' suit is not moot, the issue of petitioners' standing would be resolved on remand. The court refused to grant petitioners' request for injunctive relief, reasoning that an injunction was inappropriate because "Laidlaw has been in substantial compliance with all parameters in its NPDES permit since at least August 1992." 8a-9a. 149). The court of appeals based its determination of mootness on the fact that the district court did not provide injunctive relief. LAIDLAW WASTE SYSTEMS INC has the Handler ID: #TXD000454710. 122; pp. Argued October 12, 1999-Decided January 12,2000. Ibid. In Virginia, several school districts canceled their school bus contracts with private operators and brought bus operations in-house. U.S. Const. (J.A. No. 158), with Steel Co., 523 U.S. at 88, and Gwaltney, 484 U.S. at 55. The companies and people profiled on Corporation Wiki are displayed for research purposes only and do not imply an endorsement from or for the profiled companies and people. 183). The court also found that Laidlaw had committed 420 monitoring violations, including 13 post-complaint violations, and that Laidlaw had committed 503 reporting violations, including ten post-complaint violations. Laidlaw I, 890 F. Supp. 1319(a), 1342(b)(7). In 1986, the State of South Carolina, which administers a federally approved NPDES permit program through the State's Department of Health and Environmental Control (DHEC), issued a NPDES permit for Laidlaw's wastewater treatment plant. 92-93). The Clean Water Act The Clean Water Act creates a comprehensive program "to restore and maintain the chemical, physical, and biological integrity of the Nation's waters." TES has developed and sustained partnerships with thousands of clients including petrochemical facilities, manufacturing facilities, shipyards, offshore facilities, chemical plants, hospitals, and In 1969 DeGroote began to expand beyond trucking by acquiring a solid waste management company. 4 In the proceedings below, Laidlaw also contested petitioners' standing to bring suit. The Court applies the doctrine of standing as a threshold jurisdiction requirement that a plaintiff must normally satisfy to invoke the federal judicial power. It ruled, based on an extrapolation of this Court's decision in Steel Co., that the district court's denial of petitioners' request for an injunction rendered this case constitutionally moot and prohibited the district court from assessing civil penalties. See Arizonans for Official English v. Arizona, 520 U.S. 43, 66-67 (1997) (courts may assume that standing exists to resolve whether a case has nevertheless become moot). [6] Allied Waste sold the Canadian operations to USA Waste Services, Inc. Laidlaw American branches were re-branded to many different names, depending on their location. Services. See Arizonans for Official English, 520 U.S. at 67-68. Section 402(b) and (c) authorizes the States to develop and administer their own NPDES permit programs and provides that EPA shall suspend issuance of federal permits upon determining that a State has adopted an adequate program. 523 U.S. at 102-104. Pushed for a bill that would make environmental audits priviledged informationwhich is inadmissable as evidence. Laidlaw II, 956 F. Supp. See Arizonans for Official English v. Arizona, 520 U. S. 43, 66-67. 159). TES has developed and sustained partnerships with thousands of clients including petrochemical facilities, manufacturing facilities, shipyards, offshore facilities, chemical plants, hospitals, and The company later sold American Medical Response and EmCare, its EMS contract operations, to new owners. 1986). Accord W.T. 182-183). A. But the citizen, unlike the federal or state government, may not bring suit simply to assess civil penalties for "wholly past violations." In February 2007, FirstGroup, a bus and rail transportation operator in the United Kingdom with subsidiaries in North America, acquired Laidlaw International, Inc.[1][2][3] FirstGroup completed the acquisition of Laidlaw International on October 1, 2007, and rebranded Laidlaw services under the First umbrella. 1993). On the last day before FOE's 60-day notice period expired, DREC and Laidlaw reached a settlement requiring Laidlaw to pay $100,000 in civil penalties and to make "every effort" to comply with its permit obligations. See Laidlaw II, 956 F. Supp. The court of appeals' exclusive focus on what relief the citizen received departs from the methodology that courts normally apply in analyzing mootness. The district court's statements respecting the appropriateness of equitable relief do not provide what a determination of mootness would require: a definitive finding that it is absolutely clear there is no reasonable prospect that Laidlaw would repeat its violations. Laidlaw International, Inc. listed its common shares on the New York Stock Exchange (Ticker: LI), on February 10, 2004, and emerged from reorganization on June 23, 2003, as the successor to Laidlaw Inc. Canadian Pacific sold its remaining 17% interest in Laidlaw Inc. We nevertheless observe that there is good reason to question the court of appeals' dictum that "[petitioners'] failure to obtain relief on the merits of their claim precludes any recovery of attorneys' fees or litigation costs because such an award is available only to a 'prevailing or substantially prevailing party.'" No warranties, expressed or implied, are provided for the business data on this site, its use, or its interpretation. Tull v. United States, 481 U.S. 412, 422-423 (1987). 1993); Atlantic States Legal Found., Inc. v. Pan Am. Indeed, that is what the district court apparently concluded here. D. Because the court of appeals erred in concluding that the district court's decision to withhold injunctive relief rendered petitioners' citizen suit moot, there is no occasion for this Court to review the court of appeals' suggestion that a finding of mootness would preclude petitioners from recovering their costs of litigation. 86-87). 141-143); Friends of the Earth, Inc. v. Laidlaw Envtl. In 1996, Laidlaw sold its solid waste business to Allied Waste Industries. The district court did not find that there was no reasonable prospect of future violations; it therefore could assess civil penalties, as an alternative to an injunction, to deter future violations and redress the injuries that prompted petitioners' suit. Historical business data for Laidlaw International Inc.: Historical business data for Laidlaw Global Corp.: This page was last edited on 19 April 2023, at 16:25. On-Call Environmental Services for Metropolitan Water District of Southern California. Finally, we show why the court of appeals erred in holding that, because the district court denied injunctive relief, the petitioners' enforcement action is moot.4 A. In Laidlaw the Court held in a Clean Water Act suit that the plaintiff environ-mental organization could seek civil penalties payable to the United States Treasury because such relief redressed its continuing interest in 470 (D.S.C.1995). Id. But this case differs crucially from Steel Co. because petitioners brought suit to abate Laidlaw's ongoing environmental violations, Laidlaw was in a state of non-compliance when the suit was filed, Laidlaw failed to demonstrate that its voluntary cessation had left no reasonable prospect of future violations, and petitioners were therefore entitled to seek a remedy that would adequately ensure future compliance. The facility included a wastewater treatment plant that removed pollutants from water generated by the facility's air pollution control system.
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