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Claiming direct complying actions and quantified environmental benefits for expedited settlements that are penalty only actions

If EPA's enforcement action caused a violator to take a complying action, then EPA may take credit for the complying action and its associated results, the value of the injunctive relief/complying action and environmental benefits. If the enforcement action was not the cause of a violator taking a complying action, then EPA may not take credit for the complying action or any environmental benefits.


Expedited enforcement actions, like other administrative enforcement actions, can be the cause of a complying action, even in the case of penalty actions for which there is no statutory authority for EPA to compell compliance (e.g., CWA section 309(g) administrative penalty actions).


Administrative compliance orders should not be issued simultaneously with expedited settlement agreements for CWA violations.


The expedited settlement order issued for CWA violations can assess a penalty and require the respondent to return to compliance.

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