The nation’s major environmental statutes provide avenues for states to assume delegation, authorization, or primacy to implement these laws. Through U.S. EPA-developed documents known as Compliance Monitoring Strategies (CMS), states and U.S EPA ensure state compliance with environmental laws. State program offices may, with U.S. EPA regional approval, diverge from the requirements outlined in these strategies through use of an Alternative CMS (ACMS). Use of an ACMS is a relatively common practice among state agencies, with substantial variation among states and programs as to the type and scope of flexibilities afforded in these agreements, their level of formality, and other factors. States may pursue U.S. EPA approval of these alternatives in order to inspect facilities outside of a fixed schedule, or to gain flexibility to conduct more compliance evaluations at smaller generators to reach more of the total regulated universe. This report provides a national overview of ACMS adoption and highlights state case studies.
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