You are in your office one afternoon when the phone rings. It's the vice president of environmental affairs for one of your clients. He tells you the company just discovered a major violation of an environmental law. The good news is that it has been corrected. "Do we have to report it?," he asks. Your quick review of the law and regulations shows there is no requirement to report. "O.K.," he says, "but should we report it anyway?"

Welcome to The Twilight Zone of environmental law, a dimension where there are no easy answers. Deciding whether to report when there is no obligation to do so is not just a legal decision; it also involves considerations of corporate philosophy and ethics. Some clients may decide to report all major violations regardless of a legal requirement to do so. In that situation, your job is relatively straightforward: find the best way to disclose the violation with the least onerous consequences. The question is no longer whether to report, but how to do it.