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The EPA has made public an April 30 memo from the acting assistant administrator for the Office of Enforcement and Compliance Assurance (OECA) to the national and regional enforcement managers that signals clear and specific enforcement policy expectations, at least in the stressed communities and environmental justice context (referred to herein as the EJ enforcement memo or the memo). And while the specific subject of the memo is enforcement’s approach in support of greater environmental equity, there are multiple and notable references to overall enforcement policy direction.
The memo is “assuming current resources” and does not contain bold new initiatives, although there are references to planned focus on environmental justice in connection with “national initiatives” and a reference to the prospect for use of “additional resources” in the community involvement context. The April 30 memo is very much a “what we can do right now” agenda, but goes into the “hows” of enforcement in ways that almost certainly point to future approaches in these areas at EPA. The memo is available here.