March 1^st is the deadline for submission to the U.S. Environmental Protection Agency (“EPA”) of annual facility reports under the Emergency Planning and Community Right-to-Know Act (“EPCRA”). EPCRA requires companies to notify state and local planning and emergency response authorities, and local fire departments, of the presence of certain chemicals at their facilities. These annual “chemical inventory reporting” requirements can be triggered by telecommunications operations involving sulfuric acid and lead-acid batteries, as well as diesel, lead, halon, and propane. The failure of many companies in the industry to file these reports has been a major source of EPA enforcement actions over the last decade. Our July 2013 Advisory, “What Telecom Carriers Need to Know about the EPA’s Facility Compliance Enforcement”, provides more information on EPA’s telecommunications industry enforcement initiative. Kelley Drye’s Environmental Law practice can assist companies in determining whether reporting is required and the submission of such reports.

Reminder: EPA Facility Reporting Deadline Approaching