Complying with Environmental Permits after Issuance

Stephen D. Bundy, Berkeley Law


Over the past several years, regulatory agencies have started demanding and courts are imposing more expensive civil and, in some cases, criminal penalties on permit violators. An outline is presented on maintaining permit compliance. Compliance organization will necessarily depend on the permit type, whether it be a fee-type, an operating permit, or a preconstruction permit. A compliance team should be established to assign a compliance structure according to the mandates of the permit. An effective auditing program should be implemented and conducted as an independent operation. And since most permits have a defined life span, early efforts must be made to evaluate requirements for permit renewals and revisions.