“The firms need to file properly and avoid programs that could incentivize bad behavior

“present compliance concerns.

“it's seeing an increase in their filings in pursuit of incentive programs, and they are often "procedurally or substantively deficient,"

“city officials should have conducted an ‘individualized statutorily-required initial determination’ before issuing the notices to homeowners, so as to not place the burden on the property owners.

“These bills would allow… federal programs to continue under other agencies. Instead of eliminating programs, these agreements have allowed federally authorized services to continue…

“procedurally or substantively deficient

“the agency could impose constraints, including requiring officials to consider costs imposed on permit holders and their reliance on previously issued permits

“she did not know XPCC was a sanctioned entity at the time and had not received training on sanctions compliance