Environmental Protection Agency v. Coalition for Clean Air

How later courts describe this case

• reversing district court determination that the policy statement is a legislative rule triggering the notice and comment procedures of the APA
• the use of the word “or” by Congress between “two separate triggering events” showed that Congress clearly intended that either one of the events would trigger the “EPA’s obligation to promulgate” a plan
• "We prefer the interpretive/legislative terminology because it avoids any potential confusion."