Rulemaking:

Environmental Enforcement and Compliance Assurance Activities, Request for Comments

Stated Purpose:

EPA . . . requests comments on its current efforts to protect public health and the environment through its national compliance and enforcement program and to solicit ideas on how it can further improve public health and the environment through new compliance and enforcement initiatives.

Summary of RSP Comment:

RSP commends the Office of Compliance and Enforcement Assurance for its thoughtful examination of its programs and its recognition that it needs to target its enforcement efforts more effectively. There is wide variation in risk reduction benefits across different environmental regulations, so effective targeting of finite enforcement resources could achieve significant improvements in the protection of public health and the natural environment.

RSP recommends that EPA:

• Target its enforcement and compliance assurance efforts on violations that pose real health or environmental risks, with a goal of maximizing the net benefits to human health and the environment,
• Clearly articulate compliance expectations, and link those expectations to reductions in real health and environmental risks, but leave actual enforcement of environmental regulations to the states,
• Provide communities and consumers objective and risk-based information that can aid in decision-making without causing unnecessary alarm, and
• Respond objectively and appropriately to public concerns about perceived risks, and Evaluate market-based ways to better align the goals of the regulated community with social goals.