By Eric E. Boyd and Jeryl L. Olson
The U.S. Environmental Protection Agency’s (EPA) Office of Enforcement and Compliance Assurance has issued its draft guidance on the Fiscal Year 2013 enforcement program (FY 2013 Draft Guidance). The FY 2013 Draft Guidance identifies EPA’s intent to significantly cut back traditional federal enforcement strategies across all major federal environmental programs, and to eliminate the voluntary disclosure program long relied upon by industry to disclose violations discovered during compliance audits.
The full management alert on this topic is available here.