In 2012, the Environmental Protection Agency (EPA) approved California's plan for the reduction of ozone and pesticide levels in the state, particularly the San Joaquin Valley. The state had originally agreed to a 20 percent reduction of volatile organic compound (VOC) emissions by 2005, but the EPA allowed the state to reduce that goal to a 12 percent reduction. A consortium of environmental groups challenged the EPA's approval. The court noted that the state had submitted paperwork to the EPA setting the goal at a 12 percent reduction level and that 20 percent was merely a goal or target. The court also pointed out that the plaintiffs had not established any proof of a current or ongoing violation of environmental rules. The court deferred to the EPA that CA's plan was enforceable and that compliance would occur in years involving high fumigation of crops in the San Joaquin Valley. El Comite Para El Bienestar De Earlimart, et al. v. United States Environmental Protection Agency, No. 12-74184, 2015 U.S. App. LEXIS 7631 (9th Cir. May 8, 2015).
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