The January 5, 2010, issue of BNA Daily Environment Report quotes Charles Auer and Bergeson & Campbell, P.C.’s (B&C) December 31, 2009, memorandum regarding the action plans announced by the U.S. Environmental Protection Agency (EPA) on December 30, 2009. Auer described the action plans as “very ambitious” and noted that it remains to be seen whether EPA will have the staff and other resources to be as ambitious as it wants to be. In its memorandum, B&C stated: “EPA has never previously announced so many actions under the Toxic Substances Control Act, nor has it ever cited use of Section 6 so widely.” The fact that OMB approved these plans “is significant and portends potentially great and largely unfettered EPA activity in the months to come.”