EPA’s “Compliance First” and LEAPS-Based Enforcement: Opportunities and Risks
Panelists:
J. Michael Showalter, Partner, Arent Fox Schiff LLP
Tom Boer, Co-Chair, Environmental Practice, Hogan Lovells
About:
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.
Slide deck: https://www.wlf.org/wp-content/uploads/2026/04/Compliance-First-WLF-Panel.pdf
Panelists
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J. Michael Showalter is a partner with ArentFox Schiff LLP practicing in the firm’s New York, NY and Chicago, IL offices. He is a litigator focusing on business and public policy disputes. He is well-versed in decades-old statutes and regulations that govern rapidly evolving issues such as fracking, superfund remediation, and carbon capture sequestration. While much of his work involves disputes arising under environmental statutes including CERCLA, RCRA, the Clean Air Act, and the Clean Water Act, Mike has represented parties involved in civil rights, commercial, class action, toxic tort, and regulatory litigation in courts throughout the United States.
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Tom Boer is a Partner with Hogan Lovells practicing in the firm’s San Francisco and Los Angeles offices. He serves as Global Co-Chair of the environmental practice. He previously served as a trial lawyer at the U.S. Department of Justice (DOJ) Environmental Enforcement Section and in the Environmental Protection Agency’s (EPA) Office of General Counsel. Tom represents clients in federal and state environmental litigation, in defense of environmental enforcement actions and citizen suits, in response to catastrophic environmental emergencies and chemical releases, and in connection with site cleanup and cost recovery.
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