Bergeson & Campbell, P.C. (B&C®) is a Washington, D.C. law firm providing chemical and chemical product stakeholders unparalleled experience, judgment, and excellence in matters relating to TSCA, and other global chemical management programs.
Internal EPA Memoranda Outline Approach for Regulatory Deconstruction
  • Email This
  • Print
  • Share Link

By Christopher R. Bryant and Lynn L. Bergeson

A trio of recent internal U.S. Environmental Protection Agency (EPA) memoranda are providing insight into how EPA intends to implement President Trump’s review and potential pogrom of EPA regulations.  Virtually no program or regulation appears to be secure from the chopping block.  Many stakeholders in industry and other sectors may be alarmed to see programs that are of benefit to them assigned a slot in the guillotine.  Supporters of these programs, thus, would be wise to educate senior EPA officials to help them understand the benefits of those programs or regulations, and save them from elimination.  These internal memoranda demonstrate that the regulatory dismantling of EPA’s programs is being robustly carried out by EPA.  Those stakeholders who wish to save a program benefitting their interests should act immediately to educate EPA.  The three memoranda are:

  • March 21, 2017, Memorandum -- FY 2018 President’s Budget:  Major Policy and Final Resources Decisions;
  • March 24, 2017, Memorandum -- Executive Order 13777:  Enforcing the Regulatory Reform Agenda; and
  • March 24, 2017, Memorandum -- Improved Management of Regulatory Actions.

More information on these memoranda are available in our full memorandum Internal EPA Memoranda Outline Approach for Regulatory Deconstruction; Stakeholders Have the Opportunity to Seek to Protect Programs at Risk.

On Wednesday, April 12, 2017, from 11:00 a.m. to 12:30 p.m. (EDT), the American Bar Association’s Section of Environment, Energy, and Resources will be hosting a teleconference on this very topic, entitled “What Happens Now at EPA: Assessing the Executive Orders and Upcoming Regulatory Reform.”  Registration is available online.