LDEQ Voluntary Self-Audit Program Management

Whiteboard covered in sticky notes sorted into questions, answers and action items

Louisiana’s Voluntary Environmental Self-Audit Program (LAC 33:I Chapter 70) lets facilities find, disclose and fix their own violations, and those violations may qualify for reduced civil penalties. LDEQ’s January 2026 amendments tightened the calendar. ClearPath, based in Lake Charles, manages the whole process so deadlines don’t slip, and your team signs and files every submission.

The timeline at a glance

StepDeadlineRule
Notice of AuditBefore the audit begins§7009.A.1
Complete the auditWithin 6 months of the commencement date (extensions up to 180 days, requested at least 30 days before the period expires)§7009.A.3, §7009.B
Disclosure of ViolationNo later than 30 calendar days after the audit period ends§7009.A.2
Corrective actionsWithin 90 calendar days of discovery§7009.C.1
Progress reportsFor fixes past 90 days, until complete (the rule says monthly; confirm the schedule with LDEQ)§7009.C.1.b
Final written reportWithin 30 days after the audit or the last corrective action, whichever is later§7009.C.1.c
Keep the audit report5 years, on-site or accessible§7009.D
LDEQ review fee$1,500 initial minimum, nonrefundable§7013

What ClearPath does

Standard self-audit

  • Prepare the Notice of Audit on LDEQ’s current form
  • Plan and run a multi-media compliance audit inside the window (air/Title V, water/LPDES and stormwater, waste, and spill prevention as they apply to your site)
  • Draft the Disclosure of Violation, including corrective actions
  • Track every corrective action, progress report and final report date in Q-hub. ClearPath is an official Q-hub partner.

Acquisition and new-owner audits

  • Inventory every permit, across all media, at the target facility
  • Prepare the NOC-1 transfer packages, which are due before the change or no later than 45 days after it (LAC 33:I.1907/1909)
  • Run a new-owner audit under §7011. A new owner’s own audit gets up to nine months from commencement, and a continued seller audit must finish within six months of closing.
  • Pair the work with a Phase I ESA on the same deal

About penalty mitigation

A disclosed violation that meets all nine conditions in §7009.E may qualify for a 100% reduction in civil penalties, or 75% if everything except systematic discovery is met. Some violations are excluded entirely (§7007). LDEQ makes the decision in writing and can recover any economic benefit from noncompliance. We don’t promise any particular outcome.

New owners must also make the ownership-independence certifications in §7011.B.5 as of the closing date.

Who signs

The owner or operator signs, certifies and files every notice, disclosure and report. ClearPath prepares the drafts and tracks the dates. We recommend that your environmental counsel be involved from the start, including in how the audit engagement is structured. ClearPath works alongside your attorney, and if you don’t have one, we can make a referral.

Talk it through

If a self-audit or a Louisiana acquisition is coming up, ClearPath can walk through the timeline with you and your counsel. Contact ClearPath


Disclaimer: This page is general information about LAC 33:I Chapter 70 and Chapter 19. It is not legal advice and doesn’t create an attorney-client relationship. Regulations change, so check the current rule text and consult your environmental counsel before filing anything with LDEQ.

Sources: LAC 33:I Chapter 70 (LDEQ) · LAC 33:I Chapter 19

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