Even after these prodigious efforts, smog in Pennsylvania remained among the worst in the country. Though the Clean Air Act of 1977 required the state to reach its ozone standard by the end of 1987, Pennsylvania’s problem worsened over that period. More than 8 millions Pennsylvanians – over 75% of the state population – lived in areas where the ozone standard was violated.

The Law Center brought another lawsuit against the state and the EPA seeking to extend the auto emissions program established in the previous lawsuit, require gas stations to use pumps that prevent volatile organic compound (VOC) emissions, and to reduce the volatility of gasoline.

Most of the claims were dismissed by the federal court, though later EPA action compelled Pennsylvania to adopt a more complete plan to meet the requirements of the Clean Air Act.