From: JD Supra
“In response to the Policy, concerns have been raised that delegating primary and greater enforcement responsibility upon state agencies (with limited funding and staffing) will reduce environmental law enforcement. Others have criticized the “no surprises” provision as an effort to “tak[e] the element of surprise away from inspections . . . mask[ing] a ‘see-no-evil’ approach to corporate polluters.” Tim Whitehouse, the Executive Director of the Public Employees for Environmental Responsibility”