The shelter-in-place orders and essential business guidelines and directives that have been issued by the federal government and the states of Illinois and Missouri have raised questions about the feasibility of compliance with environmental requirements during the COVID-19 pandemic. As outlined below, the United States Environmental Protection Agency (“USEPA”), Illinois Environmental Protection Agency (“IEPA”) and Missouri Department of Natural Resources (“MDNR”) have issued separate policies addressing enforcement discretion for environmental violations related to the COVID-19 pandemic. These policies are not a waiver of compliance with environmental regulatory standards, and an understanding of the policies is important for regulated entities in
