Metropolitan Edison Co. v. People Against Nuclear Energy
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Metropolitan Edison Co. v. People Against Nuclear Energy, 460 U.S. 766 (1983), represents a decision by the United States Supreme Court.
Background
After the meltdown at Three Mile Island reactor 2, People Against Nuclear Energy (PANE) contended that reactivating reactor 1 would inflict psychological damage on residents living nearby. When the Nuclear Regulatory Commission (NRC) failed to address this concern in its environmental impact statement as mandated by the National Environmental Policy Act (NEPA), PANE pursued judicial intervention. The appellate court determined that the NRC had improperly excluded this consideration from its evaluation.
Holding
The Supreme Court concluded that the NRC's exclusion of PANE's psychological harm argument was appropriate. The NRC adequately assessed environmental hazards, including thermal pollution in the Susquehanna River and exposure to low-level radiation under § 102(C) of NEPA.
Concurrence
Justice Brennan, while concurring with the majority, emphasized that PANE's claim extended causation too far by associating the reactor's restart with speculative psychological effects arising from perceived risk.