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  • Model EPA Penalty Policy - Download 
    On November 18th, on behalf of CERT, George Lawrence, the prior Chief of U.S. EPA’s Mobile Source Enforcement Branch, will present the enclosed PowerPoint slides to Ellen Peter – CARB’s Chief Counsel. These slides summarize Mr. Lawrence’s “Note” . Mr. Lawrence’s slides explain the rational and benefits of not only EPA’s Penalty Policy – but also how EPA tempers its enforcement discretion when there are regulatory ambiguities, when there would be unintended consequences, or when it is impossible to comply with a regulation. 
    Download Slides

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