Environmental Auditing and Audit Disclosure in a New Era

WHAT DOES THIS MEAN FOR AUDITS AND DISCLOSURE? • What does the evolution in enforcement approaches suggest for your audit program and your audit protocol? ‒ Looking for confessions or anomalies in reporting: deviation reports, emissions inventories, NORs, DMRs, RQ release and other emissions events ‒ Using advanced technologies to spot potential concerns from the air, the fenceline, up and down stream, and during on-sites – “facts, not factors” ‒ Your cyber footprint will be treated as gospel despite its questionable quality ‒ Enhanced information requests – not “just the facts” – more demands for records, as well as requests for admissions, requests to develop evidence • Audits as an inspection-readiness tool require adapting to these new realities

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