This article is the first of two related articles which examine the extent to which
administrative law mechanisms can be, and have been, utilised to ensure the accountability
of regulators for decisions made under the core piece of New South Wales pollution
legislation -the Protection of the Environment Operations Act 1997 (NSW) (POEO Act).
This article considers the ability of merits review to hold regulators to account. A forthcoming
article examines the impact of judicial review and civil enforcement on government
accountability in pollution law.