The men on the EPA’s wanted list didn’t kill anyone, but they could make a lot of people sick. They are accused of dumping mercury contaminated soil, smuggling ozone depleting freon into the US or covering up illegal cruise ship discharges.

But a story in The American Prospect magazine suggests that many states don’t have lawyers or detectives prepared to go after environmental criminals. The piece is based on an internal EPA document and was originally published for subscribers to The Capitol Forum.

Twenty states have zero dedicated criminal enforcement attorneys or investigators, according to a document maintained by the Environmental Protection Agency’s (EPA) Office of Enforcement and Compliance Assurance. The Capitol Forum obtained the document through an open records request.

To effectively monitor, enforce, and deter criminal environmental conduct, states should have dedicated staff members and resources, according to interviews with former EPA staff who collaborated with state-level environmental programs during their careers.

The document was a list of “full-time employee[s] whose job is investigating and/or prosecuting pollution control crime.” Only eight states had both an inspector and an attorney. The EPA told The Capital Forum that the agency does not have minimum law enforcement staffing requirements for state  programs. Sometimes they work with state police or an attorney general’s office on environmental crimes, according to the EPA’s comment. State regulators described similar partnerships.


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Corrupt government officials and informants who fear retribution. These are some of the challenges faced by citizens who become involved in helping enforce illegal logging regulations.

Three panelists discussed these and other forestry crime issues at March 21 webinar on “Citizen enforcement in the forestry sector”– Melissa Blue Sky, of the Center for International Environmental Law (CIEL); Ruth Noguerón, of the World Resources Institute and  Shelley Gardner, Illegal Logging Program Coordinator, USDA Forest Service. Each touched on the issue.

Interpol estimates that illegal timber comprises 15-30% of the global timber trade. That amounts to between $51 and $152 billion worth of wood every year.

A study of illegal timber harvesting in Peru found that exporters are adept at finding new ways to evade export controls, Blue Sky said.

For example, harvesting modalities not always subject oversight in Peru. Timber is “red flagged” as illegal but exported anyway– often to countries without timber regulations. In some cases, documentation about the source of the timber is manipulated.

“In many cases, it involves that active participation of government officials and until they are held accountable for that, you don’t get at the root of the problem,” Blue Sky said.


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corruption TimberProtecting and incentivizing whistleblowers is essential to combat environmental crimes

The world is facing daunting environmental challenges, many exacerbated by corruption. A number of the planet’s protected species are disappearing rapidly, due in part to the illegal trade in flora and fauna, and corruption comes into play as traffickers often rely on fraudulent paperwork to move parts from endangered species and illegal timber across borders.
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Wildlife whistleblowersThe International Network for Environmental Compliance and Enforcement (INECE) was formed in 1989 by the United States’ Environmental Protection Agency and the Netherlands’ Ministry of Housing, Spatial Planning and the Environment on the need for greater collaboration between environmental compliance and enforcement actors globally. To date, it remains the only global organization focused exclusively on improving compliance with environmental law through effective compliance promotion and enforcement at all levels of governance. By partnering with the National Whistleblower Center, INECE hopes to help address the relationship between environmental crime, economic growth, and national security.
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