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ARTICLE · 10 FEBRUARY 2015

EPA’s OECA Announces Enforcement Tools For Civil Enforcement Cases And Administrative Settlements

Troutman Pepper Locke LLP
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In a recent memo issued by EPA’s Office of Enforcement & Compliance Assurance (OECA), Assistant Administrator Cynthia Giles announced that four specific "enforcement tools" should be considered "in all civil enforcement cases and incorporated in civil and administrative settlements whenever appropriate."

United StatesEnvironment
Randy Brogdon
Randy Brogdon
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In a recent memo issued by EPA's Office of Enforcement & Compliance Assurance (OECA), Assistant Administrator Cynthia Giles announced that four specific "enforcement tools" should be considered "in all civil enforcement cases and incorporated in civil and administrative settlements whenever appropriate."  OECA notes that these measures can be imposed via settlement through "injunctive relief, mitigation, or Supplemental Environmental Projects."

These tools include:

  •  "Advanced monitoring," including both point source emission/discharge monitoring and ambient monitoring,
  • Independent third party verification of a settling party's compliance with settlement obligations,
  • Electronic reporting, and

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