Abstract
The US Environmental Protection Agency (USEPA) is always starting things. Once the agency has issued a compliance order, filed suit against you, or begun a criminal investigation, how do you determine the best way to end what USEPA has started? Sometimes it is not as easy to do as you might think, so before you sign that administrative Compliance Order on Consent and high‐five your co‐workers, we'll discuss the options USEPA has at its disposal and why it does not always want to fully explain or disclose them before you agree to a settlement.
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