EPA’s National Compliance Initiatives — Say Goodbye to NSR Enforcement

Earlier this month, EPA released its recommendations for its National Compliance Initiatives for 2020-2023.  I face a dilemma in posting about the NCI, because I actually agree with the two biggest changes EPA is proposing.  This administration has given regulatory reform a bad name.  It’s sort of like a reverse “Nixon in China” situation.  These changes might be credible if they were made in any administration other than this one.

Nonetheless, I have to call them as I see them.  The first change is actually just in the name.  The NCI used to be called the National Enforcement Initiatives.  I have always thought that enforcement is just a means to an end and it’s a very bad proxy for how we’re actually doing in attaining our environmental goals.

In terms of specifics, most of the attention has been on the proposal to eliminate enforcement of New Source Review requirements from the list of priorities.  Since I have previously described the NSR enforcement initiative as the most successful program that shouldn’t exist, my views should be pretty clear.  I still think it would be a huge win-win to eliminate the NSR program completely as part of a grand bargain to put a price on greenhouse gases and move to more market-based regulation of traditional criteria pollutants as well.

I can dream, can’t I?

One thought on “EPA’s National Compliance Initiatives — Say Goodbye to NSR Enforcement

  1. I think there’s danger here of oversimplification. NSR encompasses quantification of emissions and control determinations in locally customized, multi-source evaluations that might not be accomplished easily in market-based systems. Perhaps there could be a hybrid review procedure that does a better job of incorporating economic incentives, but the “big and rich” would likely make out better than the little guys for whom the marginal costs of pollution controls have disproportionate impacts on their bottom lines…

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