Planning and Information Sharing
· IEPA and USEPA will hold an annual planning meeting to discuss enforcement and
· USEPA and IEPA will share information regularly about pending and potential
enforcement cases in order to avoid surprises, ensure consistency, minimize
duplication and ensure timely coordination of activities. For those enforcement
programs where the authorizing statute does not provide for delegation to the states
(e.g., non-delegable programs such as TSCA), USEPA will share enforcement
information with IEPA to the extent allowed under existing OECA policies and
procedures. USEPA will also provide IEPA with a copy of each non-delegable
program enforcement action issued within the State. Information which is
enforcement-confidential will be protected from disclosure by all parties to the fullest
extent of the law.
Coordination of Activities
· Each agency will identify cases in which inconsistency with national enforcement
response policies or state environmental compliance strategies or duplication of
resources are potential problems, or in which coordination between USEPA and IEPA
· These cases will be discussed at meetings or conference calls, held at least quarterly.
· Each agency will designate appropriate contacts to attend meetings and discuss
· For each facility identified, USEPA and IEPA will discuss and attempt to agree on
the appropriate response for the violation and the appropriate agency to take the lead
role. For some cases, joint actions may be preferable.
USEPA will take enforcement actions in Illinois as necessary and appropriate to
ensure implementation of federal programs and as a deterrent to non-compliance, in
accordance with the communication and coordination activities outlined above.
There may be emergency situations or criminal matters that require USEPA to take
immediate action (e.g., seeking a temporary restraining order); in those
circumstances, USEPA will consult with the State as quickly as possible following
initiation of the action.
For both USEPA and IEPA, enforcement and compliance assistance is conducted
through individual media programs. However, both agencies conduct multi-media
enforcement and compliance activities that will require coordination. While
individual program activities will be coordinated on a program-specific basis, multi-media
activities will be coordinated, when appropriate, through Region 5's OECA and
the Compliance Management Panel. Specific multi-media activities that IEPA and
USEPA will work together on in FY 2002 include coordination on multi-media
inspections, including consideration of facilities appropriate for multi-media
inspections in the Greater Chicago Initiative area, participation in the Greater Chicago
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