document
October 11, 2016
Fairbanks North Star Borough (the Borough) has the worst episodic fine particulate matter (PM-2.5) pollution in the nation—“worse than Los Angeles, Milwaukee and Detroit combined,” a local newspaper put it. See Exhibit 1 (Amanda Bohman, Air pollution in North Pole worse than Los Angeles, Milwaukee and Detroit combined, Fairbanks News Miner (May 27, 2016)). Defendants have known about Fairbanks’s PM-2.5 problem for more than half a decade, but they have repeatedly failed to take action mandated by the Clean Air Act to address the problem.