Stephen Fotis was quoted in an article in The Energy Daily, entitled, "Court Orders EPA to Rewrite PM 2.5 Implementation Rules," which details the recent US Court of Appeals for the DC Circuit decision to remand two Clean Air Act regulations.

WIth regard to what the decision means, Mr. Fotis said, "what it meands is the more stringent implementation rules now apply for PM 2.5 nonattainment areas."