EPA Formalizes New Policy To Coordinate Civil, Criminal Enforcement

EPA enforcement chief David Uhlmann has formalized a new policy requiring coordination of civil and criminal enforcement, a measure that attorneys at Baker Botts say is “perhaps the most significant change in environmental enforcement since the passage of the basic environmental law decades ago.” Uhlmann, head of EPA’s Office of Enforcement & Compliance Assurance (OECA), signed a 10-page April 17 memo setting forth the Strategic Civil-Criminal Enforcement Policy with requirements to ensure that EPA’s enforcement program “maintains and strengthens the...