Environmental Auditing and Audit Disclosure in a New Era

WHAT DOES THIS MEAN FOR AUDITS AND DISCLOSURE? • Putting it all together, enforcement exposure continues to be strong ‒ Focus will continue on larger emitters/dischargers ‒ Continuing/increasing reliance on paper trail and electronic record ‒ Advanced technologies and citizen-collected evidence ‒ Enhanced use of information request authorities to simplify agency efforts ‒ Auditing continues to be crucial and audit disclosure continues to be an important, if somewhat less definitive, tool to consider • Auditing continues to create legal/evidentiary risk ‒ Carefully consider the use of available privileges – increased importance ‒ Carefully counsel auditors on appropriate reporting practices • Audit disclosure provides somewhat less protection than it had

12