ENV-11-30 From Here To A Penalty: Anatomy of EPA Civil Administrative Enforcement

Description:

On one typically ordinary day, you are casually opening the morning mail and find a letter on U.S. Environmental Protection Agency (EPA) letterhead (with that distinctive logo) signed by some kind of “division director.” Attached to the letter is a legal-looking document with the word “Complaint” emblazoned prominently across the first page. The sunlit room suddenly seems to go dim around you and you start to feel your ears getting warm and your stomach tightening, especially when you get to the part with the heading “Civil Penalty.” It quickly sinks in that you are about to embark on a potentially long and nerve-racking odyssey: Yes…It’s time for “from here to a penalty!”1