The Road to Improved Compliance

by Daniel Farber | June 09, 2016

As I wrote earlier this week, environmental enforcement is not nearly as effective as it should be. EPA and others have been working on finding creative ways of obtaining compliance, often with the help of new technology.

One aspect of enforcement that has become clear is the need to focus on small, dispersed sources that may cumulatively cause major problems. EPA has focused its past efforts on the largest non-complying facilities. But EPA has found serious noncompliance in terms of water pollution at about 45 percent of smaller facilities, with significant impacts on water quality (especially where there are clusters of facilities. Small, dispersed sources can also be major contributors to toxic air pollutants. Often, smaller sources simply don't know what the rules are or what they need to do to comply. In some industries with numerous small emitters, EPA simply sent letters to firms with suggestions about low-cost methods of compliance; the letters were inexpensive but produced noticeable results.

As this example indicates, there has also been considerable interest in use of cooperative compliance strategies. There are a number of economic reasons why some firms may wish to comply voluntarily, or even go beyond strict legal requirements, such as a desire to improve brand image, avoidance of potential future litigation or penalties, and attracting investors by signaling effective risk management systems. The empirical evidence on the relative effectiveness of these two enforcement strategies is unclear. Regulators seem to use ...

Porter Ranch Gas Leak Mitigation Program Shows Hints of EPA NextGen Strategies

by Evan Isaacson | April 11, 2016
Last month, the California Air Resources Board released a draft Aliso Canyon Methane Leak Climate Impacts Mitigation Program. The program comes in response to Gov. Jerry Brown’s January 6 proclamation that Southern California Gas be held responsible for mitigating the estimated 100,000 tons of methane released from the gas storage facility at Porter Ranch, which leaked the equivalent of about one-fifth of all other California sources of the powerful greenhouse gas combined over that same period. While this high-profile case ...

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