EPA’s “Compliance First” and LEAPS-Based Enforcement: Opportunities and Risks

A December 2025 memo issued by an Environmental Protection Agency office outlined a sea-change in focus toward a “find-and-fix” voluntary compliance approach. Enforcement decisions will be judged by applying five factors: Law, Evidence, Analysis, Programmatic impact, and Stakeholder impact (LEAPS). Our speakers will draw upon their public service and private practice experiences to take you through EPA’s new playbook and provide thoughts on how to navigate through its opportunities and risks.