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This year the Environmental Protection Agency (EPA) has announced its “next generation” enforcement strategy purportedly aimed at improving compliance with environmental laws. Faced with fewer resources, EPA will have to do more with less—trying to improve compliance with rules and permitting requirements, improving transparency, and adopting innovative enforcement approaches, all in the face of an ever-diminishing budget. One would think that in this context, EPA would be relying even more heavily on the self-disclosure program to ensure that regulated sources and entities have incentive to self-police, audit and report any identified noncompliance. But EPA is taking the precise opposite approach.