Our Issues
Significant environmental enforcement issues in the regulatory, legislative and judicial context, including participating with government officials and preparing comments regarding:
- Federal and State Audit Policy legislation
- EPA’s Strategic Planing Process
- Environmental Justice
- U.S. Sentencing Commission Guidelines
- EPA’s Proposed Changes to its Benefit Recapture Approach to its “BEN Model”
- Non-utility specific aspects of EPA’s NSR enforcement initiative
- EPA’s Interim Guidance on Federally Permitted Releases
- EPA’s Consolidated Rules of Practice
- EPA’s practice of overfiling state enforcement actions;
- EPA’s Draft Guidance for Community Involvement in Supplemental Environmental
- Projects;
- Proposed Rule Amending the General Provisions of the National Emission Standards for
- Hazardous Air Pollutants
- Financial Accounting Standards Board “FASB”
- Chemical Release Reporting
Participating in Amicus Briefs
Participation as parties or as amicus curiae in litigation that involves significant enforcement policy issues, including:
- United States v. Atlantic Research Superfund case
- EPA’s Overfiling Authority Under RCRA in Harmon Industries v. Browner
- CERCLA cost recovery in U.S. v. E.I. DuPont de Nemours & Co., Inc.
- Interfaith Community Organization v. Honeywell International
- RCRA Overfiling: U.S. v Power Engineering Co.
- Hoechst Celanese Corporation v. United States of America
Engaging with Key Environmental Stakeholders
CEEC meets regularly with top EPA, Department of Justice, Administration, Capitol Hill and state environmental enforcement leaders, many of whom participate in CEEC’s quarterly membership meetings as guests. Most recently, DOJ Assistant Attorney General, ENR Division Ignacia Moreno and EPA Assistant Administrator, OECA, Cynthia Giles participated in a CEEC membership meeting.
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