August 7, 2019
Reprinted with permission from Law360
On July 11, 2019, Susan Parker Bodine, assistant administrator for the U.S. Environmental Protection Agency’s Office of Enforcement and Compliance Assurance, or OECA, released a seven-page memorandum to the EPA's regional administrators that “sets out expectations and procedures for enhancing effective partnerships in civil enforcement and compliance assurance work between the U.S. Environmental Protection Agency and states that are authorized, delegated, or approved to implement federal environmental programs.”
The partnership memo withdraws and replaces an interim policy that had previously been released Jan. 22, 2018. Reading the memo as removing the EPA from the state-enforcement process, or as somehow lessening the EPA’s role in this process as a whole, would appear to be a mistake.
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