The Clean Air Act (CAA) requires EPA to develop regulations and complete timely review of existing rules.. Review NAAQS every 5 years.. Review NSPS/NESHAPs every 8 years Historically.. EPA did not fulfill this CAA obligation. In recent years, lawsuits have forced EPA to follow CAA schedules EPA will lose these lawsuits Legislative CAA fix is needed to alter these mandated schedules EPA and litigant often agree to Court ordered Consent Decree schedule for regulation development EPA typically meets Court ordered schedules » Most recent EPA rules driven by Consent Decree schedules