|5-12.001||Establishment and Purpose|
|5-12.100||Area of Responsibility—Categories of Litigation|
|5-12.111||Cases Brought on Behalf of the United States|
|5-12.121||Responsibility for Cases With New Issues and/or Altered Character|
|5-12.300||Supervision and Handling of Environmental Enforcement Section Cases—Requests for Instructions|
|5-12.302||Transmittal of Papers to Environmental Enforcement Section and Client Agencies|
|5-12.320||Direct Referral Civil Cases Not Requiring Prior Approval by the Assistant Attorney General|
|5-12.321||Notification to Environmental Enforcement Section of Intention to File Actions|
|5-12.340||Cooperation and Coordination with Environmental Protection Agency|
|5-12.520||Investigation and Administrative Processing of Violations—Responsibility for Detecting and Investigating Violations|
|5-12.522||Transmittal of Reports of Unauthorized Activities|
|5-12.523||Coordination With State Programs|
|5-12.524||Administrative Disposition of Violations|
|5-12.530||Litigation Procedures; Draft Complaints|
|5-12.531||Lis Pendens and the Recording of Judgments|
|5-12.600||Settlement Authority in Direct Referral Cases|
|5-12.611||Transmittal of Settlement Offers|
|5-12.613||Settlement Policy in Suits Brought on Behalf of the Administrator of the Environmental Protection Agency|
|5-12.620||Consent Decrees; Public Notice Policy|
5-12.001 – Establishment and Purpose
The Environmental Enforcement Section was created on September 10, 1980, by Environment and Natural Resources Division Directive No. 17-80. The Environmental Enforcement Section was organized in order to provide a specialized legal staff capable of carrying out the effective civil judicial enforcement of laws relating to protection of the environment.
5-12.100 - Area of Responsibility—Categories of Litigation
The Environmental Enforcement Section is responsible for conducting civil enforcement litigation arising under the following statutes:
- Federal Water Pollution Control Act or Clean Water Act, 33 U.S.C. § 1251 except for cases concerning dredged or fill material under 33 U.S.C. §§ 1311(a), 1344 that are supervised by the Environmental Defense Section;
- The Oil Pollution Control Act of 1990, 33 U.S.C. § 2701;
- Clean Air Act, 42 U.S.C. § 7401;
- Resource Conservation and Recovery Act, 42 U.S.C. § 6901 (also known as the Solid Waste Disposal Act);
- Comprehensive Environmental Response, Compensation, and Liability Act (Superfund), 42 U.S.C. § 9601;
- Safe Drinking Water Act, 42 U.S.C. § 300f;
- Toxic Substances Control Act, 15 U.S.C. § 2601;
- Residential Lead-Based Paint Hazard Reduction Act, 42 U.S.C. § 4852d;
- Federal Insecticide, Fungicide and Rodenticide Act, 7 U.S.C. § 136;
- Rivers and Harbors Act, 33 U.S.C. §§ 403, 407;
- Marine Protection Research and Sanctuaries Act, 33 U.S.C. § 1401;
- Noise Control Act, 42 U.S.C. § 4901;
- The Atomic Energy Act of 1954, 42 U.S.C. § 2011, insofar as it relates to the civil enforcement of violations committed by a company in matters involving the licensing and operation of nuclear power plants and affecting the environment;
- Powerplant and Industrial Fuel Use Act of 1978, 42 U.S.C.§ 8301; and Title I of the Public Utility Regulatory Policies Act of 1978, 16 U.S.C. § 2601;
- Uranium Mill Tailings Radiation Control Act, 42 U.S.C. § 7901;
- Section 2 of the Energy Supply and Environmental Coordination Act of 1974, 15 U.S.C. § 791;
- The Deepwater Port Act of 1974, 33 U.S.C. § 1501, insofar as the violation involves a provision of the Act or the rules and regulations promulgated pursuant thereto that are designed to prevent environmental pollution;
- The Outer Continental Shelf Lands Act of August 7, 1953, 43 U.S.C. § 1350, where the violation is of a rule or regulation that is designed to prevent environmental pollution;
- National Marine Sanctuaries Act, 16 U.S.C. § 1431;
- National Park System Unit Resource Protection provisions of P.L. 113-287, 54 U.S.C. § 100721
- Emergency Planning and Community Right to Know Act, 42 U.S.C. § 1101; and
- Pipeline Safety Act, 49 U.S.C. § 60101
EES also brings cases pursuant to the Federal Debt Collection Procedures Act, the Federal Priority Statute, state law, and other authorities as appropriate. Where EES seeks to proceed in rem against a vessel under a specific statutory provision or under the Admiralty Rules, EES will coordinate with the Torts Branch (Aviation & Admiralty Section) of the Civil Division.
5-12.110 - General Responsibilities
The Environmental Enforcement Section enforces, supports, and coordinates civil enforcement of all cases, matters, and proceedings arising under the statutes and other authorities identified in JM 5-12.100.
5-12.111 - Cases Brought on Behalf of the United States
- The Environmental Enforcement Section has Departmental responsibility for civil matters initiated on behalf of the United States to secure the control and abatement of sources of pollution, to protect the natural environment, to recover response costs and natural resource damages on behalf of the public, or to deter future violations through the imposition of penalties to the extent that such cases may arise under the statutes and other authorities identified in JM 5-12.100. As a matter of policy and practice, civil enforcement actions are initiated at the request of the Administrator of the Environmental Protection Agency, the Commandant of the Coast Guard, and other government officials having statutory responsibility for the enforcement of laws designed to protect the public health, welfare, and the environment. Section 12 of the statute that authorized the Department's 1980 budget authorized the Attorney General with the concurrence of any agency or department with primary enforcement responsibility for an environmental or natural resource law to investigate any violation, and bring such actions as are necessary to enforce such laws. Except for cases initially subject to treatment as direct referrals, see JM 5-1.310 and 5-12.320, the Assistant Attorney General of the Environment and Natural Resources Division must review and approve in advance the following actions in cases referred by or brought on behalf of the Environmental Protection Agency and other Federal client agencies under the statutes identified in JM 5-12.100:
- Filing or amending a complaint or counterclaim;
- Filing a claim or otherwise initiating process or filing a counterclaim in a bankruptcy or probate matter;
- Raising issues involving statutes administered by the EPA or other Federal agencies;
- Compromising, closing or dismissing a case or claim; or
- Modifying or enforcing a consent decree or judgment
- When apparent violations of the statutes identified in JM 5-12.100 are brought to the attention of the Department of Justice by persons or agencies other than those with statutory enforcement responsibilities, the Department either forwards those reports to appropriate executive branch enforcement officials for evaluation and possible referral for legal proceedings or, in criminal cases, may itself undertake the necessary investigation and prosecution. The practice of forwarding reports of suspected violations to appropriate agencies has several potential benefits: (1) it allows the agencies to bring to bear their technical expertise to determine whether violations actually have occurred; (2) it allows the agencies to settle cases administratively in certain circumstances; and (3) it allows the agencies to apply technical and investigative resources in order to develop those cases which do have merit.
[cited in JM 3-8.130]
5-12.121—Responsibility for Cases with New Issues and/or Altered Character
- Occasionally issues involving laws for which the Environmental Enforcement Section is responsible may be injected into existing litigation by way of amendment or supplemental pleadings or sua sponte by the court. The United States Attorney should not add or raise such matters without first notifying and receiving approval from the Chief of the Environmental Enforcement Section. In cases where such issues have been raised by others, the United States Attorney should immediately notify the Chief of the Environmental Enforcement Section to assure that the Section can properly perform its responsibilities.
- On other occasions, the fundamental character of existing litigation may change and environmental enforcement issues may become dominant issues. In such situations, the Environmental Enforcement Section staff attorney responsible for the case shall notify the Section Chief, who may request a transfer of Section responsibility if he/she deems it appropriate. If Environmental Enforcement Section issues become dominant in a case in which no Environmental Enforcement Section attorney is directly involved, the United States Attorney shall notify the Environmental Enforcement Section Chief of the situation and he/she may make a written request to the Assistant Attorney General of the Environment and Natural Resources Division to have the case transferred to the Environmental Enforcement Section.
5-12.200 - Organization
The Section is administered by a Chief, Deputy Chiefs, and multiple Assistant Chiefs. Within the Section, work is assigned among staff attorneys by the Assistant Chiefs, under the supervision of the Chief and Deputy Chief(s), according to experience and workload. General information relating to the Section or cases within its supervision may be obtained by emailing or calling the Chief at (202) 514-5271. Information on a specific case should be requested from the staff attorney assigned to that case. When the staff attorney's name is unknown, the Case Management Unit of the Section (EESCaseManagement.ENRD@usdoj.gov) may furnish that information.
5-12.300 - Supervision and Handling of Environmental Enforcement Section Cases—Requests for Instructions
All requests for instructions and guidance relating to the conduct of actions under the jurisdiction of the Environmental Enforcement Section shall be referred, first, to the EES attorney known to be handling such action and, second, to the Chief of the Environmental Enforcement Section of the Environment and Natural Resources Division by email or telephone (at (202) 514-5271).
5-12.302 - Transmittal of Papers to Environmental Enforcement Section and Client Agencies
In any case being handled by a United States Attorney arising under the statutes identified in JM 5-12.100, a copy of each substantive letter sent or received by a United States Attorney as well as a copy of each significant pleading and paper filed by any party or by the court shall be forwarded promptly by email to the Environmental Enforcement Section and the referring client agency. In appropriate cases, the Environmental Enforcement Section, in consultation with the assigned Assistant United States Attorney, will register as additional counsel to be noticed with the Court’s electronic case filing system.
5-12.311 - Exigent Circumstances
- Whenever the United States Attorney becomes aware of a situation in his/her district not previously the subject of any report or referral which merits a temporary restraining order or preliminary injunction, he/she should contact both the regional legal office of the client agency and the Chief of the Environmental Enforcement Section directly by telephone. An example would be a United States Attorney learning of a company's intention to burn hazardous material in an uncontrolled incinerator thereby endangering the lives and health of those living near the incinerator. To prevent such action a temporary restraining order or a preliminary injunction may be in order.
- Under circumstances which involve immediate threats to life or health, the Chief of the Environmental Enforcement Section may give authorization by telephone for the filing of a complaint and application for a temporary restraining order. If the Section Chief, Deputy Chief, the Assistant Chiefs, the Deputy Assistant Attorney General, and the Assistant Attorney General, cannot be reached by telephone, the United States Attorney may seek a temporary restraining order to prevent threats to life or health without prior approval.
5-12.320 - Direct Referral Civil Cases Not Requiring Prior Approval by the Assistant Attorney General
- As specified in ENRD Directive No. 2016-04, the following groups of cases arising under the statutes identified in JM 5-12.100 may be handled by the United States Attorneys as direct referrals, i.e., as not requiring specific authorization by the Assistant Attorney General of the Environment and Natural Resources Division:
- Claims referred by the United States Coast Guard, in response to a written request from an authorized field officer, seeking the collection of federal clean-up costs and/or imposition of civil penalties under section 311 of the Clean Water Act (CWA), 33 U.S.C. § 1321; or seeking the collection of federal clean-up costs and/or imposition of civil penalties under sections 1002 and 1017 of the Oil Pollution Act of 1990 (OPA), 33 U.S.C. §§ 2702 and 2717.
- Miscellaneous proceedings, such as warrant requests, undertaken to assist agencies seeking investigative entry under section 308 of the CWA, 33 U.S.C. § 1318; sections 114 or 206 of the Clean Air Act (CAA), 42 U.S.C. §§ 7414, 7525; sections 3007 or 3013 of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. §§ 6927, 6934; section 11 of the Toxic Substances Control Act (TSCA), 15 U.S.C. § 2610; or section 9 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), 7 U.S.C. § 136g; but not the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), 42 U.S.C. § 9601.
- Claims under any statute listed in JM 15-12.100 for collection of civil penalties previously assessed by the referring agency in an administrative proceeding where the amount of the penalty does not exceed $1 million.
All other enforcement cases arising under the statutes identified in JM 5-12.100 require the approval of the Assistant Attorney General or, in accordance with applicable ENRD Directives, the Chief of the Environmental Enforcement Section before they can be filed.
- The Assistant Attorney General and his/her designee retain the authority to direct that any case within the responsibility of the Environment and Natural Resources Division shall be handled in whole or in part by Division attorneys.
5-12.321 - Notification to Environmental Enforcement Section of Intention to File Actions
Prior to filing a civil complaint in a case authorized for direct referral, the United States Attorney shall notify the Chief of the Environmental Enforcement Section of the proposed action and shall furnish the section with a copy of the written request from the respective client agency for the initiation of the action.
5-12.340 - Cooperation and Coordination with Environmental Protection Agency
- Pursuant to a Memorandum of Understanding with the Environmental Protection Agency, within 60 days of receipt from the Environmental Protection Agency of a formal request to file a suit under the Clean Air Act, the Clean Water Act, or the Safe Drinking Water Act, and the submission of a civil litigation report, Department attorneys are required to either file a complaint or report to the Chief of the Environmental Enforcement Section why a complaint has not been filed. Thereafter, the Department attorney shall submit periodic reports to the Chief of the Environmental Enforcement Section until a complaint is filed or a decision is reached that a complaint will not be filed.
- If the Department of Justice fails to file a complaint within 120 days of its receipt of a request for litigation and a civil litigation report by the agency to the Attorney General, then the Administrator may request that the Attorney General file a complaint within 30 days. Failure of the Department thereafter to file a complaint within 30 days may be considered by the Administrator or his/her delegate to be a failure of the Attorney General to notify the Administrator within a reasonable time that he/she will appear in litigation for purposes of Section 305 of the Clean Air Act, 42 U.S.C. § 7605; Section 506 of the Federal Water Pollution Control Act, 33 U.S.C. § 1366; or Section 1450 of the Safe Drinking Water Act, 42 U.S.C. § 300j-9(f). If such a failure occurs, attorneys of the Environmental Protection Agency may represent the Administrator without the United States Attorney or Department attorneys. However, the failure of the Attorney General to file a complaint within the time period requested by the Administrator in a case in which the Administrator requested immediate action to protect public health under §§ 311(e) and 504 of the Federal Water Pollution Control Act, 33 U.S.C. §§ 1321(e) and 1364; Section 303 of the Clean Air Act, 42 U.S.C. § 7603; or Section 1450 of the Safe Drinking Water Act, 42 U.S.C. § 300(i), may also be considered by the Administrator to be a failure of the Attorney General to notify the Administrator under 42 U.S.C. § 7605; 33 U.S.C. § 1366; or 42 U.S.C. § 300j-9(f).
5-12.520 - Investigation and Administrative Processing of Violations—Responsibility for Detecting and Investigating Violations
The primary responsibility for detecting and investigating suspected violations of statutes identified in JM 5-12.100 rests with the federal agencies which are charged by statute with administering those acts. After investigating reports of suspected violations, the respective agencies generally evaluate them internally under their own procedures to determine which matters merit referral to the Department of Justice for judicial enforcement action. Generally, whether it goes directly to the United States Attorney or to the Environment and Natural Resources Division, a referral will be accompanied by a litigation report describing the alleged violation and the evidence available to the agency to support an enforcement action.
While primary responsibility for investigating violations of an environmental enforcement statute may reside with the agency administering the act, this does not mean that other agencies, including United States Attorneys' offices, should not have a role in this phase of enforcement. Some United States Attorneys' offices have employed legal technicians, whose duties include assisting the Environmental Protection Agency, the Coast Guard or other agencies in investigating activities proscribed by environmental statutes and preparing cases for litigation.
Because of a United States Attorney’s function as representative of the various federal agencies in legal matters, the United States Attorney is in a position to coordinate the investigative efforts of those agencies into violations of environmental statutes. Such coordination can result in more thorough and efficient case development with fewer resources devoted to duplicative efforts. The United States Attorneys, therefore, are encouraged to establish contact with the investigative agencies which operate within their districts, to render to them useful advice regarding sound case development, and to take a lead in creating a cooperative federal effort. The Environmental Enforcement Section is prepared to assist the United States Attorneys in establishing contact with personnel of the federal agencies who operate within the various districts.
5-12.522 - Transmittal of Reports of Unauthorized Activities
Notwithstanding the source, all reports of violations of environmental enforcement statutes should be referred to the enforcement agencies charged with administering the acts. There are numerous reasons for this policy. In addition to the fact that prompt referral may avert wasteful duplication of federal effort, under certain of the statutes identified in JM 5-12.100, administrative consideration may be a prerequisite to civil enforcement. See, e.g., 42 U.S.C. § 7413(a)(1). In some instances, such matters may be resolved administratively without resort to litigation.
5-12.523 - Coordination with State Programs
Most states have environmental enforcement programs which overlap, in whole or in part, with federal programs. United States Attorneys should familiarize themselves with state environmental enforcement laws and state enforcement officials. Frequently, an unauthorized activity constitutes a violation of both federal and state law. United States Attorneys should remain advised of pending state environmental enforcement actions. If it appears that all federal interests in the case will be vindicated in the state court proceeding, action in federal court may be an unnecessary duplication of effort.
On the other hand, if federal interests will not be protected completely in state court, federal proceedings may be warranted. Where legal action in federal court appears warranted, the United States Attorney should continue to consult and, as appropriate, coordinate with relevant state authorities. Many federal environmental statutes employ cooperative federalism, under which states and tribes share responsibilities with the United States as co-regulators. Some of the statutes identified in JM 5-12.100, e.g., 33 U.S.C. § 1319(b) and 42 U.S.C. § 7413(b), specifically require that notice of any federal civil action be given immediately to appropriate state officials. At least one statute, 33 U.S.C. § 1319(e), requires that a state be made a party to any enforcement action against one of its municipalities.
5-12.530 - Litigation Procedures; Draft Complaints
Referral packages from the environmental agencies may include draft complaints. The United States Attorney is not bound by the form of such a draft complaint, but a well-drafted complaint can be helpful in expediting the initiation of an action. Whether an agency draft is used or a new draft is generated, once a complaint has been approved by the approving official, it may not be altered prior to filing without the express approval of the official.
5-12.531 - Lis Pendens and the Recording of Judgments
In civil environmental enforcement actions for prohibitory or mandatory injunctive relief, complications may arise if the ownership of the property in question changes hands during the pendency of the action. Where there is a threat of transfer of ownership, the United States Attorney should consider filing a notice of the pendency of the action, of lis pendens. The steps necessary for the filing of such a notice are determined by the law of the particular state. See 28 U.S.C. § 1964.
The final judgment in a civil environmental enforcement action, including a consent decree, may, in effect, place a permanent burden on the property which was subject to the unauthorized activities. In order to protect the future interests of the United States, the United States Attorney should consider recording the judgment as appropriate and in accordance with applicable law.
5-12.532 - Pleadings
The Environmental Enforcement Section maintains files of pleadings which have been employed successfully in past cases. Upon request to the staff attorney, United States Attorneys may obtain pertinent, sample papers or other assistance in preparing for a particular case.
[updated April 2018]
5-12.533 - Trial Assistance
In cases in which United States Attorneys have primary litigating responsibilities, they are encouraged to request assistance in trial preparation from the Environmental Enforcement Section staff attorney assigned to a case. Memoranda, trial briefs, information on unreported cases, and other material relevant to environmental cases also can be obtained through the staff attorneys. Additionally, the Section keeps a file on expert witnesses used in various cases.
5-12.600 - Settlement Authority in Direct Referral Cases
Subject to the limitations on delegations therein, United States Attorneys are authorized to compromise cases directly referred to them in accordance with ENRD Directive No. 2016-04.
[cited in JM 5-8.600]
5-12.611 - Transmittal of Settlement Offers
Any offer to settle or dismiss an action which the United States Attorney is not authorized to compromise shall be transmitted to the Environmental Enforcement Section attorney assigned to the case for consideration and disposition at the appropriate level. Such offers should be accompanied by the written comments and recommendation of the referring United States Attorney and of the referring agency. In emergency situations, such as with settlement offers received during trial or settlement offers dealing exclusively with monetary damages or penalties, those offers may be communicated to the Chief or one of the Deputy Chiefs of the Environmental Enforcement Section by telephone or email. See ENRD Directive No. 2016-04.
5-12.613 - Settlement Policy in Suits Brought on Behalf of the Administrator of the Environmental Protection Agency
Frequently, cases brought on behalf of the Administrator of the Environmental Protection Agency result in agreed judgments or consent decrees. Copies of consent decrees in previously settled cases are available from the Environmental Enforcement Section as well as assistance in understanding the types of settlements and consent decree terms that are generally acceptable.
To assist United States Attorneys' offices, the following general guidance is also provided:
- Defendants should be informed that any settlement must be approved by the Assistant Attorney General of the Environment and Natural Resources Division and by the Assistant Administrator for the Office of Enforcement and Compliance Assurance of the Environmental Protection Agency or his/her delegate, and are subject to review by them. This is a requirement of the Memorandum of Understanding with the Environmental Protection Agency.
- Defendants should be advised that only the Department of Justice and the attorneys specifically designated may bind the United States to any agreement.
- In most cases, the pendency of settlement negotiations should not cause a cessation of litigating activities. Defendants in enforcement cases often are more amenable to settlements favorable to the United States when discovery and trial preparations proceed in parallel with settlement negotiations.
- In no civil settlement agreement will the Environment and Natural Resources Division compromise the ability of the United States to undertake criminal prosecutions (See Parallel Proceedings Policy, ENRD Directive No. 2016-12; Global Settlement Policy, ENRD Directive No. 2016-11).
- Defendants should be advised that the United States is bound only by the provision actually set forth in any consent decree, and that no alleged agreement, written or oral, with any client agency representative or with anyone else, which does not appear expressly in the decree, alters the actual terms of that decree or binds the United States.
[cited in JM 3-8.130]
5-12.620 - Consent Decrees; Public Notice Policy
- Consent judgments in actions in which the complaint seeks to enjoin the discharge or emission of pollutants, after being approved by the Assistant Attorney General, are to be lodged with the court and made available for public comment for a period of 30 days prior to their entry. This is required by Departmental Order No. 529-73, 38 Fed. Reg. 19029, dated July 17, 1973, 28 C.F.R. § 50.7. Certain statutes enforced by the Environmental Enforcement Section also require public notice and comment; furthermore, as a matter of Environmental Enforcement Section Policy, settlements in many additional cases are lodged with the court and made available for public comment, as appropriate.
- The purpose of the practice is to allow the public to comment and to allow the Executive Branch to receive the benefit of such input, and to allow it to withdraw or modify its consent to the decree based upon such information.
- Whenever a proposed consent decree is lodged with the court pursuant to 28 C.F.R. § 50.7, the United States Attorney shall notify the Environmental Enforcement Section of that fact immediately. In most cases, the Environmental Enforcement Section will undertake publishing notice of the proposed settlement in the Federal Register and collecting any comments that are submitted.
- In some instances, district judges have proceeded to enter consent decrees prior to the expiration of the public notice and comment period. If this should occur, the United States Attorney must notify the Environmental Enforcement Section of that fact immediately. In general, the appropriate response is to move to vacate the order.
- When the public comment period has expired, the Environmental Enforcement Section will notify the United States Attorney as to whether any comments have been received and will coordinate with the United States Attorney on the appropriate next steps for seeking entry of the decree. It is the policy of the Environmental Enforcement Section to respond to the public comments received and to provide a memorandum in support of a Motion to Enter the Consent Decree that contains or attaches such response.
- After the court has approved the consent decree, the United States Attorney should provide hard or electronic copies of the file-stamped and court-signed decree to the Environmental Enforcement Section and to the appropriate regional EPA office. The mailing list for these offices is as follows:
Case Management Unit
Environmental Enforcement Section
Environment and Natural Resources Division
Department of Justice
P.O. Box 7611
Washington, D.C. 20044-7611
|UNITED STATES ATTORNEY OFFICES LOCATED IN THE FOLLOWING STATES||SHOULD SEND DECREES TO THE FOLLOWING EPA REGIONAL OFFICES|
Vt., Mass., R.I., Conn.
EPA - Region I
5 Post Office Square
Boston, MA 02109
|N.Y., N.J., P.R., V.I.||Regional Counsel
EPA - Region II
New York, NY 10007
|Pa., Del., Md., Va.,
EPA - Region III
1650 Arch Street
Philadelphia, PA 19103
|N.C., S.C., Ga., Tenn.
Ky., Fla., Miss., Ala.
EPA - Region IV
61 Forsyth Street, S.W. Atlanta, GA 30303
|Ill., Ind., Ohio, Minn.,
EPA - Region V
77 West Jackson Blvd.
Chicago, IL 60604
|Tex., La., Okla., N.M.,
EPA - Region VI
1445 Ross Avenue
12th Floor - Suite 1200
Dallas, TX 75202
|Kan., Mo., Iowa, Neb.||Regional Counsel
EPA - Region VII
11201 Renner Blvd.
Lenexa, KS 66219
|Col., Utah, Wyo., Mont.,
EPA - Region VIII
1595 Wynkoop Street
Denver, CO 80202
|Cal., Ariz., Nev., Hawaii||Regional Counsel
EPA - Region IX
75 Hawthorne Street
San Francisco, CA 94105
|Wash., Ore., Idaho, Alaska||
[updated May 2018]