Audit, Compliance and Risk Blog

On March 12, the US Environmental Protection Agency (EPA) issued a memorandum announcing significant revisions to the agency’s enforcement policies, entitled “Implementing National Enforcement and Compliance Initiatives Consistently with Executive Orders and Agency Priorities.” The memo directs EPA’s civil and criminal enforcement staffs, revising existing Biden-era policies (which I last wrote about HERE) to conform with President Trump’s executive orders (EOs) and policy statements by new EPA administrator Zeldin. The remainder of this note summarizes this new direction. 

Read More

On August 17, the US Environmental Protection Agency (EPA) issued a memorandum announcing its National Enforcement and Compliance Initiatives and continuing enforcement priorities for the upcoming fiscal years 2024-2027 (NECI memo). This announcement specifies existing initiatives that EPA will extend, and additional new ones. The NECI memo explains that EPA selected its priorities based on the following three criteria:

• the need to address serious and widespread environmental issues and significant violations impacting human health and the environment, particularly in overburdened and vulnerable communities
• a focus on areas where federal enforcement authorities, resources, and/or expertise are needed to hold polluters accountable and promote a level playing field
• alignment with EPA’s Strategic Plan.

The remainder of this note summarizes the enforcement priorities expressed in the NECI memo.

Read More