EPA has determined that an effective enforcement strategy for ensuring continuing compliance with air pollution regulations must provide quickly imposed sanctions, appropriate remedies, and a means of building a record in cases involving recalcitrant sources. EPA believes that an enforcement strategy which incorporates an administrative fines component may be well suited to meeting these goals and has decided to pursue development of a model administrative fines program. This report develops a list of issues that must be addressed by a model administrative fines program, and then formulates an initial set of design criteria for such a program. This analysis is based on the operating experience of nine state and local agencies that currently employ administrative fines programs as part of their overall air pollution enforcement effort.