The EPA’s new “compliance first” doctrine is sparking concern from some environmental advocates who expect increases in unlawful air emissions, waste dumping, and toxic releases if companies believe the agency is no longer aggressively pursuing bad actors.

But lawyers say the policy doesn’t necessarily mean less enforcement will take place, depending on how it’s put into practice.

The new approach, outlined in an internal memo dated Dec. 5 and reviewed by Bloomberg Law, directs the Environmental Protection Agency’s enforcement staff to “prioritize ensuring compliance when addressing potential noncompliance” with federal laws, which govern topics such as air and water pollution. …