This guidance revises the approach that the United States Environmental Protection Agency (EPA) will use in counting its enforcement actions. This guidance requires that the Office of Enforcement and Compliance Assurance (OECA) and the EPA Regions cease the calculation of extra-credits for multi-program and multi-facility cases, as well as supplemental referrals. Instead, under the new approach to case counting set forth herein, the number of case initiations and conclusions reported for these case categories will be only the actual number of these cases initiated and concluded. This new approach will increase the profile of these categories of more complicated enforcement actions by better portraying information about them. The change to case counting will take effect in FY 2003 for enforcement case initiation and multi-facility case conclusion statistics. The new approach will take effect in FY 2004 for multi-program case conclusion statistics.
OECA continues its commitment to a multi-program and multi-facility approach to enforcement. The Agency believes that EPA compliance and enforcement resources are often best directed to large cases with violations that occur in multiple programs and at multiple facilities. Identifying these types of cases should continue to be a priority for OECA and the EPA Regions.