In 2024, I filed an unfair labor practice charge with the National Labor Relations Board (NLRB) alleging that Northeastern University maintained workplace policies that violated federal labor law — specifically, that they were written broadly enough to chill employees' rights under Section 7 of the National Labor Relations Act: the right of workers to organize, act together, and speak up about their working conditions.

The NLRB investigated and it agreed: three of Northeastern's policies were overbroad and in violation of the Act. Rather than let the case proceed toward a complaint and trial, Northeastern amended all three policies by adding explicit language protecting workers' Section 7 rights.

• Media Relations (Policy 119) — Northeastern added language at the start of the policy making clear it does not apply to employees exercising their Section 7 rights (including talking to the media in their personal capacity about their terms and conditions of employment).
• Non-Solicitation and Sales (Policy 300) — Northeastern added that nothing in the policy is intended to prevent employees from soliciting support for a labor organization, including distributing labor-related materials during non-working time in non-working areas.
• Endorsements and Use of University Identifiers (Policy 116) — Northeastern added that nothing in the policy may be interpreted or applied to interfere with, restrain, or deny employees' Section 7 rights, including protected concerted activity for collective bargaining or other mutual aid and protection.

Overbroad workplace rules chill worker organizing even if they're not enforced. When employees read a policy that could be used to prevent them from talking to a reporter, handing a coworker a flyer, or organizing, many will simply stay quiet instead of accept the risk of discipline. Getting these carve-outs in writing means Northeastern's own policies now tell workers, in plain terms, that the university will not interfere with worker's federally protected labor rights.

The charge was formally dismissed — but the dismissal letter reads like a settlement. It documents what was unlawful and exactly how Northeastern came into compliance. That record is now public.

You can read the dismissal letter here: 

You can read my full position statement here: ​

​-Ashley 

The petition works through a specific legal mechanism. CERCLA — the Superfund toxic waste dump clean-up law — includes a provision, § 105(d), that lets any person petition EPA to assess a site for the National Priorities List. And here's the important part: once you file, EPA must respond. The statute gives the Agency twelve months to either complete a "preliminary assessment" of the site, or send the petitioner a written explanation of why it won't. EPA doesn't get to shrug. Congress built this provision specifically so ordinary people could force the government to look at contaminated sites it was ignoring.

So in February 2026, I started that twelve-month clock. We're now around the six-month mark so I sent EPA Region 1 a formal status inquiry asking where things stand. Within a day, I got two written answers — one from the Superfund program, one from EPA's enforcement lawyers.

The Superfund program answered first. EPA has assigned a Site Assessment Manager to my petition: Mandy Liao of Region 1's Superfund and Emergency Management Division. A Site Assessment Manager is the EPA staffer who shepherds a site through the Superfund evaluation pipeline. 

Ms. Liao's response confirmed that:

• EPA is actively reviewing the petition. In her words, EPA is "reviewing the Petition for Preliminary Assessment" and "currently evaluating the Site...".
• EPA acknowledged the deadline, in writing. The twelve-month statutory clock runs out on February 13, 2027. If EPA decides an assessment is warranted, that's the completion date. If EPA decides it isn't, the Agency committed to sending me its reasons in writing by that same date.
• No decision yet, either way. The site hasn't been entered into EPA's Superfund database (called SEMS) and the formal assessment hasn't started. EPA is at the threshold stage and promised to notify me once it decides what to do next.

The EPA has now confirmed in writing that it's bound to this process and this deadline. By February 13, 2027, one of two things happens: EPA assesses the site, or EPA explains itself. Both are formal agency actions. Both give Boston an answer it has never had. And if the explanation doesn't hold up, I can take it to a federal judge.

​When I filed the CERCLA petition, I also served a Notice of Intent to File a Citizen Suit under the Clean Water Act. The Clean Water Act lets private citizens sue polluters directly in federal court — but first you have to send a notice and give the government a window to bring its own enforcement case. If the government steps up and "diligently prosecutes" the violations, the citizen suit is off. If it doesn't, the courthouse doors open.

So my status inquiry also asked: has EPA brought any enforcement action on the violations in my notice? The Superfund team kicked that question to EPA's Office of Regional Counsel, and Jeff Kopf, Senior Enforcement Counsel for Region 1, answered in writing:

1. No. EPA has not commenced any enforcement action under the Clean Water Act with respect to my notice. For citizen-suit purposes, that's the answer that matters — there is no government prosecution standing in the way.
2. I also asked whether EPA had referred the matter to the Department of Justice or the Army Corps of Engineers. On that one, EPA declined to answer, citing its "long-standing policy" of not disclosing the existence of ongoing referrals.

Notice what that second answer isn't. It isn't "no." EPA could have simply said no referral exists. Instead it invoked the policy it uses to protect referrals that do. Draw your own conclusions.

When I served my citizen suit notice, I voluntarily extended the standard sixty-day waiting period to a full year to accommodate the year-long CERCLA process. If I have to take this matter to court myself, I'll likely bundle the claims.

Now the petition has a named Site Assessment Manager, an active review, and a written deadline. That's the process I extended the clock for, and it's happening.

Between now and February 13, 2027, I'll post updates here as things move. If EPA completes the assessment and the site scores the way I expect, the South Bay heads toward the National Priorities List — the first Superfund site in Boston's history. If EPA declines, I get a written explanation, and I already have the citizen suit noticed, preserved, and ready to file.

Either way, this is now on the record, on a clock, and in writing — which is exactly where I want it.

- Ashley 

Read the emails with US EPA Region 1: ​

Read more in the Petition and the dedicated South Bay pages: South Bay/Boston Marsh

Today I filed a written statement with exhibits as part of the Boston City Council Committee on Education's hearing to examine administrative transparency, student representation, and student rights at Northeastern University and other private higher education institutions in the City of Boston.

See, Docket #0587, "Order for a hearing to review administrative transparency, equitable student representation, and student freedoms in higher education," https://www.boston.gov/public-notices/16570106. 

The hearing was sponsored by Councilors Julia M. Mejia and Miniard Culpepper and held on March 23, 2026 at Boston City Hall. The notice states: "the Boston City Council has an interest in understanding how higher education institutions in the City are addressing issues related to transparency, governance, and student engagement." (Notice PDF).

My statement provides firsthand testimony and documentary evidence from my time as Program Manager at Northeastern University from September 2023 through September 2024. My statement addresses the three core concerns identified and documents how NEU's internal "accountability" infrastructure functions as an instrument of suppression and concealment.

My statement includes:

• NEU's "Impact Engine" initiative, which based on my experience, are internally funded shell programs designed to obtain federal center grants without substantive program scope or activity, while concurrently operating outside university policy, federal grant regulations, and applicable law;
• My formal complaints to NEU's internal compliance, audit, and HR functions beginning in January 2024 about a large "Impact Engine", and NEU's institutional poor response to those complaints;
• The retaliatory performance review issued fifty-eight days after my formal complaint and escalation that claimed my protected complaint was misconduct and my performance development plan was to stop making complaints and do whatever my supervisor told me to do; it also claimed I don't "understand" "regulations" and instructed me to not speak with legal, compliance, or HR teams without prior supervisor approval; and then NEU's VP of Audit/Compliance's subsequent condonation of both the underlying violations and the retaliation;
• NEU's abrupt termination of my employment during PFML-protected medical leave, citing the "performance plan" that directed me to stop reporting compliance concerns or insisting on regulatory compliance; 
• Federal enforcement actions following my complaints, including an NLRB finding of merit on my complaint of unlawful policies, FBI and EPA OIG investigations, OSHA and MassDEP investigations, and NSF audit findings confirming the same failures I had reported internally; and,
• Examples of the structural mechanisms by which NEU coerces student workers (particularly international students on temporary visas) into complicity with its institutional misconduct.

The statement is accompanied by a sixteen-exhibit evidentiary packet including the EthicsPoint complaint, performance review, audit correspondence, PFML and termination documentation, NLRB charges and letter, and federal agency complaints and correspondence.
​
Written comments submitted to the Committee become part of the public record and are available to all Councilors. The statement and exhibits are attached below.
​

E-filed statement: 

E-filed appendix with evidence packet: 

By 1854, the South Bay covered 306 acres. By 1898, it covered only about sixty acres. Today it is a neighborhood. The fill is still there. The garbage is still there. The wood piles are rotting. And the ocean is still trying to come in twice a day through 1,360 miles of Victorian brick sewers that were documented as "ill-adapted" and "usually leaky" in 1885, so is certainly in even worse condition now. They also documented that the groundwater in the fill across the old South Bay is "tidally influenced" meaning the tides are ebbing and flowing through the garbage, ash, sewage, and hazardous waste every day, pushing it inland and moving it all around.
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