Multi-Program (Multimedia) Cases
Multi-program cases are enforcement cases that address separate environmental problems under different programs. This could include violations of different programs within one media or statute. The following rules determine which cases qualify as multi-program:
–When a case addresses separate environmental problems under different programs, even if the violations arose from a single event or the same set of facts (e.g., a spill), it is entitled to multi-program status/credit; if a case addresses a single environmental or regulatory problem and the choice of whether to cite multiple statutes is primarily a tactical one, that case does not count as multi-program;
–For purposes of multi-program case counting, failure to respond to a multi-statute information request constitutes failure to respond to one reporting requirement and does not qualify a case as multi-program; and
–Penalty collection actions and bankruptcy referrals that include a claim under more than one program are not treated as multi-program actions.
In FY 2004, OECA began reporting the number of multi-program case initiations and conclusions separate from single program case initiations and conclusions.
To receive credit in ICIS for a multi-program case, find the "Multimedia field" on the Enforcement Action Detail screen. Select the "Edit Multimedia" button for the list of choices and pick two or more programs from the list. The list of programs that may consitute a multi-program enforcement case in also attached below.