Abstract |
The report covers the new Clean Water Act civil penalty policy used by EPA in calculating the penalty that the Federal government will seek in settlement of judicial actions brought under Section 309 of the CWA. The policy supersedes the CWA Civil Penalty Policy issued on July 8, 1980 and represents the Office of Water's guidance in response to EPA's Policy on Civil Penalties (GM-21) and A Framework for Statute-Specific Approaches to Penalty Assessments (GM-22) issued on February 16, 1984. The document consists of the following three parts: (1) the CWA Penalty Policy; (2) the policy 'methodology', which is a one-page description of each of the steps to be taken in a penalty calculation, along with one page of footnotes; and (3) the 'worksheet', a proposed model sheet to be used to record the different numerical components of the final penalty. |