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Special Litigation and Projects Division
Offices
- Administration and Policy (OAP)
- Civil Enforcement (OCE)
- Air Enforcement (AED)
- Special Litigation & Projects (SLPD)
- Waste & Chemical Enforcement (WCED)
- Water Enforcement (WED)
- Criminal Enforcement, Forensics and Training (OCEFT)
- Compliance (OC)
- Environmental Justice (OEJ)
- Federal Activities (OFA)
- Federal Facilities Enforcement (FFEO)
- Site Remediation Enforcement (OSRE)
| Acting Director: | Susan O'Keefe |
|---|---|
| Acting Associate Director: | Gale Bonanno |
| Phone Number: | (202) 564-2230 |
| FAX | (202) 564-0010 |
The Special Litigation and Projects Division develops, implements and manages several of EPA's priority enforcement approaches, including (1) multimedia enforcement, that emphasizes a whole facility and/or a whole geographical or sector-based approach to enforcement; and (2) a rapid response capability that focuses on remedying environmental harm through targeted and streamlined enforcement mechanisms. The Division also focuses on the use of innovative enforcement tools, such as the Audit Policy, as well as the development and support of models and cross-media enforcement policies (such as the BEN and ABEL programs and policies governing the recovery of economic benefit and supplemental environmental projects) that are used by EPA Regions, States and others in enforcement actions across all media. The Division incorporates risk reduction, environmental equity, and pollution prevention techniques consistent with Agency priorities. Through its Resource Management Team, the Division provides support to the entire Office of Civil Enforcement in the areas of financial management, strategic planning, human resources, contracts management, and other administrative areas.
Through its Multimedia Enforcement Branch, the Division supplies legal, technical and policy support to assist the EPA Regions (and State) in developing and prosecuting multimedia enforcement cases. The Branch is also responsible for the development and prosecution of national multimedia enforcement cases. National enforcement cases may include those of first impression, precedential in nature, multi-regional, in support of a national enforcement priority, or requiring use of national expertise. In addition, the Branch reviews Federal and State cross-program policies for consistency. The Branch ensures that single-media enforcement programs and policies are developed and implemented in a logically consistent cross-media manner. The Branch also provides communications support for the entire Office of Regulatory Enforcement. This support includes coordinating media relations efforts; writing, editing and producing communications materials; developing strategic communications plans; and advising OCE management on enforcement-related communication issues.
The multimedia or comprehensive approach to case development can be employed in the context of three basic types of enforcement actions:
- Against single facilities, where entire industrial processes at a facility may be examined as a whole to determine compliance with all environmental statutes;
- Against entire companies, where violations of different statutes occur at various facilities indicating ineffectual corporate-wide management of environmental compliance; and
- Geographically based enforcement efforts arising from a comprehensive multimedia analysis of the environmental problem(s) in a given area.
Environmental contamination is, by nature, unconstrained by statutory boundaries. Removal of artificial and occasional bureaucratic boundaries can result in:
- Improved detection and resolution of environmental compliance problems. Cross- statutory targeting, inspections, and analysis of violations afford the most effective method of identifying the extent of environmental problems. This leads to comprehensive enforcement activities.
- Achievement of optimal enforcement results. Multimedia enforcement actions raise the possibility of significantly broader environmental benefits as a part of settlement. This is in addition to penalties which more accurately reflect the full extent of the gravity of harm and economic benefit gained by noncompliance. Increasing the penalty amount available for offsetting and widening the scope of violations resolved also provide an increased opportunity for Supplemental Environmental Project (SEP) proposals.
- More effective enforcement. Targeting facilities or companies with significant, pervasive violations can eliminate the root cause of an environmental problem. This may not be possible through an enforcement action brought pursuant to one statutory authority.
- More efficient use of resources. Multimedia actions reduce and streamline the resource burden otherwise required by the numerous single-statute cases brought to resolve a complex environmental problem.
- Fundamentally change the regulated community's perceptions and behavior regarding environmental compliance. Broad-based actions and subsequent results can only assist the regulated community's meaningful implementation of environmental management systems. Furthermore, publicity of far-reaching multimedia cases can only assist in general deterrence.
The Division functions as the primary liaison for other EPA offices, the Department of Justice U.S. Department of Justice's Environment and Natural Resources Division
,Congress and other organizations on multimedia enforcement cases and issues. The Division supplies legal, technical and policy support to assist the EPA Regions (and States) in developing and prosecuting multimedia and other nationally significantly enforcement cases. Nationally significant enforcement cases may include those of first impression, precedential in nature, multi-regional, in support of a national enforcement priority, or requiring use of national expertise. In addition, the Division places an emphasis on more targeted and quicker responses, relying upon coordination with other OCE Divisions, EPA Program offices, the NEIC, and of each of the Regions to effectively and expeditiously carry out its mission.
The Special Litigation & Projects Division's offices are located in the Ariel Rios Building, near 12th and Pennsylvania Streets adjacent to the Federal Triangle MetroRail stop, in downtown Washington, DC. Our mailing address is U.S. Environmental Protection Agency, Special Litigation & Projects Division (2248A), Washington, D.C.