Center-right accountability journalism. Filings, dockets, and disclosures — not advocacy.
The federal environmental enforcement landscape entered the second quarter of 2026 in an unsettled state, marked by record-setting headline numbers from the Environmental Protection Agency, sharp pushback from independent watchdogs, billion-dollar private settlements, and the continued unwinding of Biden-era environmental, social and governance (ESG) disclosure rules at the Securities and Exchange Commission. This month’s roundup tracks the most consequential public records, court filings and agency announcements between the close of the federal fiscal year 2025 reporting cycle and late April 2026.
1. EPA Touts Record FY 2025 Enforcement Numbers — Watchdogs Push Back
In late March 2026 the Environmental Protection Agency released its Enforcement and Compliance Assurance Annual Results Report for Fiscal Year 2025, which the agency framed as the strongest performance “in years.” According to the EPA’s own data, the agency concluded 2,127 civil enforcement cases — the highest tally in nine years — and assessed more than $1.2 billion in civil penalties, criminal fines, restitution and other court-ordered relief. The agency also reported charging 156 criminal defendants, the most since 2016, and obtaining 65 years of incarceration. The EPA further reported $6.4 billion in commitments to return facilities to compliance and 65 Superfund instruments worth more than $888 million, including $714.3 million tied to roughly 59.4 million cubic yards of contaminated land and water.
Those headline numbers, however, are contested. The Environmental Integrity Project, a nonprofit founded by former EPA enforcement officials, found in its first-year analysis that only 16 new civil judicial actions were filed by the Justice Department on behalf of the EPA in the year following Inauguration Day — 76 percent below the same period in the prior administration. Federal court records cited by the group show settlements declined from 186 in 2013, to 115 in 2017, to 112 in 2021, and to 40 in 2025. Independent reporting confirms the gap and notes that 87 percent of the FY2025 air pollution cases that closed had been opened under the prior administration. Records suggest the EPA’s reported “highest in nine years” figure is being driven by closures of inherited inventory rather than new docket filings.
Verifiable trail: EPA FY 2025 results landing page; Environmental Integrity Project enforcement records database; ECHO Enforcement and Compliance History Online.
2. Q1 2026 Penalty Totals: $3.37 Million Across 91 Settlements
An industry compilation of EPA settlement data released in April shows the agency finalized 91 settlement agreements in the first quarter of calendar 2026 — modestly above the 74 in Q4 2025 — for a combined $3,369,398 in civil fines. By statute, Clean Air Act actions generated $1,430,004 in penalties; the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) produced $575,743, including a $370,000 settlement with a Florida HVAC firm and a $106,110 fine against a Georgia pest-control operator for selling unregistered or misbranded pesticides. Sixteen Clean Water Act respondents — including a New Mexico municipal wastewater plant and a Kansas subdivision cited under their National Pollutant Discharge Elimination System (NPDES) permits — paid a combined $488,781. Resource Conservation and Recovery Act actions included a $165,000 penalty against a Hawaii environmental services company. Toxic Substances Control Act export-notification violations yielded $108,853 from a California chemical manufacturer and $40,700 from a Georgia plastics recycler.
Records indicate the average per-settlement penalty in Q1 — roughly $37,000 — remains well below the headline penalties typically associated with consent decrees and is consistent with the watchdog finding that 71 percent of cases newly opened and resolved in the first year of the current administration carried zero penalty.
3. Amazon’s $20.5 Million Oregon Nitrate Settlement
On March 31 — finalized into early April — Amazon agreed to pay $20.5 million to settle a class-action lawsuit (Pearson v. Port of Morrow, U.S. District Court, D. Oregon) brought by Morrow County, Oregon residents whose drinking-water wells were contaminated with nitrates above the federal Maximum Contaminant Level. According to court filings reported by the Oregon Capital Chronicle and Oregon Public Broadcasting, the Oregon Health Authority has identified at least 634 area domestic wells with unsafe nitrate levels — some at nearly ten times the federal limit — tied to fertilizer-laden wastewater from food processors and data centers at the Port of Morrow that was applied to surrounding farmland.
Amazon, one of 17 named defendants, did not admit liability. The agreement directs proceeds toward private well remediation and public water infrastructure. Filings indicate this is the first instance of a major U.S. cloud provider paying damages tied to public-health impacts associated with data-center wastewater. The case warrants a deeper TIJ investigation into the broader water-quality footprint of hyperscale data infrastructure across the Mid-Columbia basin.
4. New Jersey’s $2 Billion DuPont/Chemours PFAS Settlement Continues to Distribute
Distributions continued in April from the August 2025 New Jersey settlement under which DuPont, Chemours and affiliated entities agreed to pay $2 billion to remediate PFAS contamination at four industrial sites — the largest environmental settlement secured by any U.S. state on record. Separately, on April 7, the Ohio EPA announced a $65 million distribution from a parallel state-level settlement with the chemical company.
According to federal docket trackers, 15,222 PFAS and aqueous film-forming foam cases remained pending in the Aqueous Film-Forming Foams multidistrict litigation as of April 1, 2026. Cumulative settlements addressing public water system contamination have now exceeded $12 billion. The Williams Mullen April environmental bulletin notes that the EPA has signaled it intends to finalize a rule designating nine specific PFAS compounds — and their salts and structural isomers — as RCRA hazardous constituents in April 2026, opening a new front for cost-recovery litigation under CERCLA.
5. Texas AG Sues Blue Cube Operations Over 70,000-Pound Air Release
On April 27, the Texas Attorney General’s office filed suit against Blue Cube Operations LLC, alleging the company released more than 70,000 pounds of air pollution from its Freeport, Texas chemical manufacturing facility. The complaint seeks civil penalties and asks the court to require Blue Cube to engage independent auditors and implement compliance measures. The case is one of several recent state-level enforcement actions filling gaps left by reduced federal civil docket activity. Records indicate Texas environmental enforcement filings are running ahead of the prior year’s pace.
6. SEC Greenwashing Posture: Names Rule Stays, Disclosure Rule Withdrawn
The Securities and Exchange Commission’s posture on ESG disclosure has bifurcated. According to filings reported in March, the SEC formally withdrew the Biden-era proposed rule requiring enhanced disclosure for ESG-labeled funds, one of 14 prior-administration proposals abandoned. However, the Investment Company Act “Names Rule” — which requires funds whose names suggest a sustainability or similar objective to invest at least 80 percent of assets toward that goal — remains on the books, with compliance dates of June 2026 (funds with more than $1 billion in net assets) and December 2026 (smaller funds). Records suggest greenwashing risk has not abated; private litigation and state attorneys general continue to pursue consumer-protection and false-advertising claims against funds and product manufacturers using climate marketing language.
The SEC’s prior enforcement record remains a useful baseline: the agency previously charged Deutsche Bank subsidiary DWS Investment Management Americas with the largest ESG-greenwashing penalty on record, and Keurig Dr Pepper Inc. paid $1.5 million for omitting material recyclability information about its K-Cup pods.
7. Carbon Credit Fraud: Multi-Agency Posture Hardens
April research published in peer-reviewed analysis warns that global voluntary carbon credit programs continue to risk rewarding the wrong behavior, echoing the systemic concerns aired in the October 2024 indictment unsealed in the Southern District of New York charging executives of CQC Impact Investors LLC with wire fraud and securities fraud. The CFTC ordered CQC to pay a $1 million civil monetary penalty and to retire fraudulently generated voluntary carbon units; the SEC entered a parallel cease-and-desist order. As defense bar analysts noted in January, the CQC matter has become the template for multi-agency carbon-market enforcement: DOJ pursues wire and securities fraud, the CFTC characterizes voluntary carbon units as “commodities” under the Commodity Exchange Act, and the SEC pursues securities-law violations in parallel.
The voluntary market’s structural weaknesses — inflated baselines, missing additionality and unverifiable climate claims — remain a target-rich environment for prosecutors and short-sellers alike. Filings indicate further indictments are likely in 2026.
8. Stanford Study: Companies Undercount Supply-Chain Emissions by Nearly 1 Billion Tons
A January 2026 Stanford-led analysis of more than 400 corporate carbon disclosures concluded that companies relying on a popular U.S.-only statistical model missed approximately 973 million tons of emissions from Chinese suppliers in a single reporting cycle, with the largest gaps in steel, cement and electronic components. Scope 3 emissions — which represent roughly 75 percent of a typical company’s footprint — remain the largest credibility gap in voluntary sustainability reporting. Fewer than half of reporting firms have set Scope 3 targets, according to industry data. Records suggest that ESG marketing language at major U.S. retailers and technology companies routinely outpaces what the underlying emissions disclosures actually show.
9. Coal Ash Rule Rollback: Comment Period Open Through June
On April 13, the EPA published a proposed rule that, according to Earthjustice analysis, would exempt hundreds of legacy coal ash dumps from federal cleanup requirements, delay closure of legacy ponds, allow some groundwater contamination above health-based standards, permit deposition of coal ash in aquifers and authorize use of toxic ash as a soil substitute. The agency is accepting public comments through June 12, 2026, and will hold a virtual public hearing on May 28. The proposal reverses portions of the 2024 Legacy Coal Ash Rule that the U.S. Supreme Court declined to stay. The forthcoming docket will be a key dataset for tracking environmental-justice impact, given that a substantial share of legacy coal ash sites sit in or adjacent to historically overburdened communities.
10. Border Interdiction: 469 Refusals, 1.4 Million Pounds of Illegal Pesticides Blocked
The EPA’s FY 2025 Annual Results Report further documents that the agency executed 469 Notices of Refusal of Admission and related actions to prevent illegal imports of toxic pesticides, waste and chemicals, blocking nearly 1.4 million pounds of illegal pesticides from entering U.S. commerce. The agency’s criminal enforcement summary shows continued focus on FIFRA pesticide smuggling, with the March 2026 guilty plea of Paulo Perez-Mendoza on conspiracy charges (sentencing scheduled August 28) consistent with a stated agency priority of border-interdiction casework.
Trend Lines
Three patterns emerge from this month’s records. First, headline EPA enforcement totals remain robust on paper but are being driven largely by closure of cases inherited from the prior administration; new civil judicial filings have collapsed to a 20-year low. Second, the locus of accountability is shifting to state attorneys general, private class actions, and multi-agency criminal cases involving carbon markets and PFAS — areas where the federal civil docket is thin but legal exposure remains substantial. Third, the gap between corporate ESG marketing and disclosed emissions is widening rather than narrowing, even as the SEC withdraws the rule that would have required the gap to be quantified.
Findings That Warrant a Deeper TIJ Investigation
Records suggest several threads merit further reporting. The Pearson v. Port of Morrow data-center water case raises questions about which other hyperscale facilities are operating under similar wastewater-recycling arrangements in the Pacific Northwest and Phoenix-area aquifers. The Stanford supply-chain analysis points to specific Fortune 500 retailers whose published Scope 3 figures appear inconsistent with the volume of imported steel, aluminum, and electronics they are publicly known to source. The CQC carbon-credit indictment raises the question of which other voluntary-carbon-market intermediaries used the same “cookstove” and LED-replacement methodologies now alleged to have inflated VCU issuance. And the gap between EPA’s civil-judicial filings and its self-reported “best-in-nine-years” metrics warrants a granular audit, on a case-by-case basis, of which dockets actually originated under the current administration. TIJ will continue tracking these threads in subsequent filings.
All cases discussed above involve allegations or, where indicated, agreed settlements without admissions of liability. Pending matters are noted as such. Right-of-reply outreach is recorded in TIJ’s editorial files.