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Enforcement Strategy & Defense
Horizon has substantial experience working with facilities, their attorneys, and, when appropriate, with outside counsel in anticipation of an inspection from the regulatory agency and in situations when a notice of violation has been received. Horizon has also assisted companies responding to federal Clean Air Act Section 114 requests for information and participated at U.S. EPA regional offices in discussions and negotiations regarding settlement of notices of violation.
Horizon is also experienced with U.S. EPA’s economic benefits model for assessing the costs deferred by the alleged violation, and implementing the U.S. EPA’s civil penalty guidance for calculating economic penalties commensurate with the gravity of the alleged violation. Using this knowledge and experience, Horizon assists its clients and their attorneys with intelligent counteroffers to the regulators’ proposed economic penalty in enforcement situations. Horizon also has extensive experience working with attorneys regarding the review and negotiation of proposed administrative and judicial consent decrees.
For more information email Brian Leahy or call him at our Grand Rapids office - (616) 554-3210.
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