| Summary: | Through intense studies of agency audits, EPA policies and documents, state environmental compliance data and state agency issued documents, I have evaluated the enforcement programs of Region Six state environmental agencies. The four elements utilized to perform this evaluation were listed in EPA compliance assurance program documents. The analysis was conducted by comparing state program performance in each element. Element 1 is the appropriate identification of violations. Element 2 is the timely issuance of enforcement actions. Element 3 is the escalation of enforcement actions when violations continue. Element 4 is the ability to assess and collect penalties. These elements are interdependent. Their success depends on the perception of their success by the regulated community. A lack of success in one element will prevent the effectiveness of all elements. The community must perceive a high likelihood of being inspected, and a high likelihood of receiving enforcement orders and penalties for existing violations. Without this perception, an enforcement program cannot effectively deter the regulated community from subsequent violations. Because each agency needed to improve in some area of enforcement, it was determined that none of the Region Six state agencies were completely efficient in all elements. Because a successful program relies upon all elements, there is no best or worst program. Each agency contains strengths and weaknesses among the elements, and each agency can improve their environmental enforcement procedures.
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