Last week, EPA released its report on Enforcement Annual Results in EPA Regions for Fiscal Year 2014. As always, the report is worth reading, if only for the interactive map which shows where EPA has brought various kinds of cases.
Notwithstanding the traditional self-congratulatory tone of the report, the press coverage has almost uniformly focused on the year-to-year decrease in cases brought and dollars recovered. Greenwire’s headline was “Enforcement actions decline again; agency blames shutdown, budget woes.”
I’m just a poor country lawyer and I don’t have the time to do the necessary sophisticated statistical analysis, but isn’t it also possible that the decline results from a decrease in noncompliance?
