On November 19, EPA issued a discussion draft of its fiscal year 2014-18 strategic plan. This draft is notable for an explicit statement that EPA intends to reduce very significantly the resources it devotes to enforcement. That is good and bad for regulated entities. On the negative side, private NGOs may fill the void of governmental enforcement. They have different, and often much more narrow, agendas than does the government. That can make cases more difficult to settle.
I consider these issues in my December column for the Pennsylvania Law Weekly. Read Government Enforcement in a Time of Budget Constraints, 36 Pa. L. Weekly 1100 (Dec. 10, 2013), by clicking here .
EPA will accept comments on its draft until January 3, 2014.