Opening Brief of Non-State Petitioners, On Petitions for Review of Final Agency Action of the United States Environmental Protection Agency, 80 Fed.Reg.64,510 (Oct.23, 2015) and 81 Fed.Reg. 27,442 (May 6, 2016), In the United States Court of Appeals for the District of Columbia Circuit, No. 15-1381 (and consolidated cases)