Article: How far should the bar on citizen suits extend under section 309 of the Clean Water Act?(1996 Ninth Circuit Environmental Review)

I. INTRODUCTION

In an effort to increase enforcement actions, Congress amended the Clean Water Act (CWA)(1) in 1987 to include a new administrative penalty section that allows agencies to assess civil penalties.(2) This section also includes provisions that allow certain administrative enforcement actions to preclude a citizen suit.(3) An analysis of this provision gives some insight into the question that existed in the courts concerning whether an administrative enforcement action could be considered a "court" under [sections] 505(b)(1)(B) of the Act and could thus preclude a citizen suit.(4) The provision precludes a citizen suit if 1) the Administrator of ...

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