A Bold Step Taken by the Agency

摘要

Recently EPA simultaneously issued and requested comment on its "Interim Approach to Applying the Audit Policy to New Owners." The agency delivers much of what it sought - a recognition that owners should be encouraged to "assess, disclose, and address environmental compliance at their newly acquired facilities."rnEPA's stated goal in looking at this policy is to try to achieve significant pollution reductions, something it admits the original audit policy has not always accomplished. As such, the agency made what appears to be an enlightened examination of what it could do to encourage new owners to make these critical assessments.rnThe Interim Approach makes several significant changes to the existing policy. It adjusts the long-standing audit policy penalty structure by recognizing that the economic benefit component of the policy should be relaxed for new owners reporting violations that occurred prior to their ownership. The policy already allows flexibility on the gravity portion of the penalty, but the economic benefit portion could still be significant.