Civil Enforcement Case Report Data Dictionary

The Civil Enforcement Case Report data dictionary describes the data elements that are presented in the Civil Enforcement Case Report (see Civil Enforcement Case Report Help). The Civil Enforcement Case Report contains data from EPA's Integrated Compliance Information System (ICIS). A Case Report summarizes federal administrative or judicial enforcement actions taken by the U.S. EPA, as well as state formal enforcement actions taken pursuant to delegated authority to implement the Clean Water Act National Discharge Elimination Program System (NPDES) program. Users may report possible data errors by selecting the "Report Data Error" link at the top of the Civil Enforcement Case Report.

The Civil Enforcement Case Report is organized into the following sections:

Civil Enforcement Case

Basic Information

The Basic Information section contains information that identifies the action and some key descriptive variables, such as case status (e.g., concluded) and case type (e.g., judicial). This information is a summary of the more detailed record of the case that is presented in the rest of the report.

Case Number: A unique number identifying the enforcement action. For EPA cases, these numbers begin with either the two digit EPA Region Code, "HQ" (headquarters initiated cases), and "EF" or "WF" (Eastern or Western Field Office CAA Mobile Source Program cases); followed by the fiscal year. In a majority of cases, this is the year in which the action was initiated. After the fiscal year there is a sequence number. State NPDES cases start with the two character post abbreviation, followed by a sequence number.
Case Name: The name of the case assigned to the enforcement action by the lead attorney. Generally, the primary defendant's name is used as the case name. For CERCLA cases, the facility/site name may be used.
Case Category: Identifies the type of action based on the enforcement authority used. The current options are Administrative - Formal or Judicial.
Case Status: The current status of the enforcement action. Status is based on the most recent milestone activity reported in the case record. The "as of" status date reflects the date of the most recent milestone activity. The following list presents the most common status values in their typical order of occurrence.; The following is a list of possible outcomes:

Administrative

Complaint/Proposed Order
Administrative Hearing
Admin Law Judge Decision
Appeal To Administrator
EAB Decision
Final Order Issued
Compliance Achieved
Demand for Stipulated Penalties
Stayed While Under Appeal
Enforcement Action Closed

Judicial

Returned To Region
Complaint Filed With Court
Final Order Lodged
Final Order Entered
Settlement Present
Concluded
Stayed While Under Appeal
Demand for Stipulated Penalties
Enforcement Action Closed

Case Lead: The name of the lead agency responsible for the case (EPA or state).
Court Docket Number: The number the Clerk of the Court assigned to the case that is filed or to a consent decree when it is lodged. For administrative cases, this number is assigned to the case by the Regional Hearing Clerk.
DOJ Docket Number: The docket number assigned by the Department of Justice to EPA's Enforcement Action. This number will identify cases in the Federal Register and in DOJ press releases when a settlement is lodged and entered.
Relief Sought: The type of enforcement relief requested in the complaint. Examples are: penalties, injunctive relief, and cost recovery.
Enforcement Outcome: The outcome of the enforcement action. The following is a list of possible outcomes:

Combined With Another Case(s)
Default Order, No Penalty
Default Order With Penalty
Default Order With Penalty & Specified Cost Recovery
Default Order With Specified Cost Recovery
Dismissed By Tribunal
DOJ Declined
EPA Did Not Pursue
EPA HQ Declined To Refer
Final Order No Penalty
Final Order With Penalty
Final Order With Penalty & Specified Cost Recovery
Final Order With Penalty & Unspecified Cost Recovery
Final Order With Specified Cost Recovery
Final Order With Unspecified Cost Recovery
Litigated, Lost
Litigated No Penalty
Litigated With Penalty
Litigated With Penalty & Specified Cost Recovery
Litigated With Penalty & Unspecified Cost Recovery
Litigated With Specified Cost Recovery
Litigated With Unspecified Cost Recovery
Source Agrees
Unilateral Administrative Order Without Adjudication
Unknown
US Attorney Declined
Voluntarily Dismissed After Filing
Withdrawn By EPA HQ
Withdrawn By Region
Withdrawn: Deferred To State

Headquarters Division: The EPA Headquarters Division responsible for the enforcement action.
Branch: The branch or unit in the Office of Regional Counsel or Office of Civil Enforcement responsible for the enforcement action.
Result of Voluntary Disclosure?: A Yes/No flag indicating whether the enforcement action was the result of a facility self disclosure.
Multi-media Case?: A Yes/No flag indicating whether the enforcement action is a multimedia action. Multimedia actions involve violations of multiple environmental laws.
Enforcement Type: A designation of the type of enforcement action. For administrative enforcement actions, the type describes the section of the statute authorizing the action. A case may have multiple enforcement types.
Violations: A description of the violation(s) associated with the enforcement action. A case may have multiple violation values.

Penalties/SEPs/Compliance Action Costs/Cost Recovery Amounts - Case Level

Total Federal Penalty Assessed or Agreed To: The total federal penalty assessed is the dollar penalty amount to be paid from all settlements in a concluded enforcement action. EPA settles the vast majority of its administrative and civil judicial enforcement actions, and these settlements (often called a consent order or consent decree) include an agreed upon penalty amount. In most of these settlements, there is not a direct admission by the defendant of liability for violations. In a few cases that involve bankruptcy, the penalty amount may be determined as an "allowed claim" in bankruptcy, and the amount actually recovered may be less than the amount of the allowed claim. The total federal penalty amount includes assessments due to both EPA and to other federal agencies that are party to the settlement, e.g., the Coast Guard.
Total State/Local Penalty Assessed: The total dollar penalty amount from all settlements to be paid to a state or local enforcement authority that is party to a concluded enforcement action.
Total SEP (Supplemental Environmental Project) Value: The total estimated value of environmentally beneficial projects from all settlements which a defendant/respondent agrees to undertake as part of the settlement of an enforcement action, but which the defendant/respondent is not otherwise legally required to perform.
Total Compliance Action Cost: The estimated dollar value of injunctive relief and other physical/nonphysical costs of returning to compliance, from all settlements associated with a case. Injunctive relief represents the actions a defendant is ordered to undertake to achieve and maintain compliance, such as installing a new pollution control device to reduce air pollution, or preventing emissions of a pollutant in the first place.
Total Cost Recovery: The total cost recovery associated with an enforcement action. These are generally the costs incurred by EPA to clean up Superfund sites which are then recovered from the parties responsible.
Penalty Amount Collected: The total penalty amount collected pursuant to a final order. Data may not be submitted to or available in all EPA source systems.

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Case Summary

A summary of the violation(s), environmental problem(s), and a description of the cause of action (basis of legal action). The summary may be extracted from the referral transmission memo or letter or as the first section of a revised standardized referral document.

Laws and Sections

This section lists the laws and regulations that were violated. It also identifies which EPA programs took the lead in addressing the specified violations.

Law, Sections: Identifies the law(s) and section(s) violated and cited in the enforcement action. For additional information, view a list of possible Statute Codes (Law), Law Section Codes, and Law Section description combinations (PDF) (11 pp, 365 K, About PDF).
Programs: A description of the EPA program(s) under which an enforcement action has been taken, and which correspond to the cited statutes and sections.

Citations

Title: The title of the corresponding regulation in the Code of Federal Regulations associated with an enforcement action. In most cases, this will be Title 40 - PROTECTION OF ENVIRONMENT, displayed as "40CFR" or "40 CFR".
Part: The part of the corresponding regulation in the Code of Federal Regulations associated with the enforcement action.
Section: The section of the corresponding regulation in the Code of Federal Regulations associated with the enforcement action.

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Facilities

This section provides detailed facility and address information on all of the facilities associated with the case.

FRS Number: The identification number assigned to a facility in the Facility Registry Service (FRS) to uniquely identify a facility site. The Detailed Facility Report for each facility can be accessed by clicking the hyperlinked FRS number. The Detailed Facility Report presents a concise enforcement and compliance history for a selected facility.
Program System Identifier: A unique ID assigned for each facility within the data system the facility reports to. These identifiers are used for tracking purposes.
Facility Name: The public or commercial name of a facility or site (i.e., the name that commonly appears on invoices, signs, or other business documents, or as assigned by the state when the name is ambiguous).
Address: The address that describes the physical (geographic) location of the front door or main entrance of a facility site, including urban-style street address or rural address.
City Name: The name of the city, town, village or other locality, when identifiable, within whose boundaries (the majority of) the facility site is located. This is not always the same as the city used for USPS mail delivery.
State: The two letter abbreviation that represents the state or state equivalent for the U.S.
ZIP: US postal ZIP code, as maintained by ICIS.
SIC Codes: The Standard Industrial Classification (SIC) system code of the facility, as identified in FRS. SIC codes were established by the Census Bureau to identify processes, products and services. The SIC code describes the primary activity of the facility. The first two digits in the code define a major business sector; the last two digits denote a facility's specialty within the major sector. The Census Bureau replaced the SIC system with the North American Industry Classification System (NAICS) starting in 1987.
NAICS Codes: A 6-digit code to classify industrial establishments, as identified in FRS. North American Industry Classification System (NAICS) has replaced the U.S. Standard Industrial Classification (SIC) system. For detailed information about NAICS and for a crosswalk between NAICS and SIC codes, please check the U.S. Census Bureau NAICS page.

Defendants

This section lists each defendant's name and whether the defendant was named in the complaint and/or in the settlement.

Defendants and Settlements: The name of the defendant, Potentially Responsible Party (PRP for Superfund cases), or respondents associated with the enforcement action.
In Complaint: A Yes/No flag indicating whether the defendant was named in the filed complaint.
In Settlement: A Yes/No flag indicating whether the defendant was named in the settlement document(s).

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Case Milestones

This section lists the major milestone events tracked for the enforcement action and the date on which each event occurred.

Events: The most commonly occurring milestones (by Case Type) are:

Administrative

Enforcement Action Data Entered
Complaint/Proposed Order
Administrative Hearing
Admin Law Judge Decision
Appeal To Administrator
EAB Decision
Final Order Issued
Enforcement Action Closed

Judicial

Enforcement Action Data Entered
PRN Sent
Referred To Headquarters
Referred To Dept Of Justice
Referred To U.S. Attorney
Complaint Filed With Court
Final Order Lodged
Final Order Entered
Enforcement Action Closed

Not all of the listed milestone events are required or appropriate for every case.
Actual Date: The date of the case milestone event.

Pollutants

This section contains information about the pollutants that were involved in the case.

Pollutant Name: The common name of the pollutant.
Chemical Abstract Number: The Chemical Abstract Service (CAS) number of the pollutant, if available.

Related Activities

This report section provides an Activity Type description and date for other ICIS activities (e.g., inspections, or compliance assistance) that are linked to the enforcement action.

Description: A general description of the activity linked to the enforcement action. Activity descriptions include the following:

Permit
Compliance Assistance
Voluntary Disclosure
Information Request
Offsite Record Review
Compliance Investigation
Inspection/Evaluation
Compliance Determination
Alternative Dispute Resolution
Administrative - Informal
Administrative - Formal
Judicial

Actual Date: The actual date on which the activity began.

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Final Order

This section contains information about the conclusion(s) of the case, where it resulted in an order, consent decree, or other enforceable settlement. It describes any monetary penalties, Supplemental Environmental Projects, cost recovery, and injunctive relief/complying actions required under the order or settlement agreement. It also includes estimated pollutant reductions resulting from the required compliance activities.

A single formal enforcement action may result in multiple final orders. Most enforcement actions tend to follow a one-case, one-final order scenario. However, and in particular with judicial actions involving multiple defendants, more than one final order may result. Each one is presented in this section as a separate conclusion/settlement.

Final Order Type: Provides a description of the enforcement instrument used by EPA to settle the case.
Final Order Name: The name assigned to the final order/settlement as assigned by the lead EPA attorney for the case. The default name for the enforcement conclusion is the case name, which may be modified to reflect changes to the case, or to provide specificity where multiple settlements result from one case.
Linked Facilities (FRS ID): The unique identification number assigned to a facility in the Facility Registry Service (FRS), for each facility included in the settlement. These identification numbers are the same as, or a subset of those displayed in the Facilities section of the Case Report.
Final Order Lodged Date: For federal judicial actions, this is the date a proposed consent decree is given to the Clerk of the Court for lodging in the District Court. Upon lodging a consent decree, a notice is published in the Federal Register indicating nature of the proposed settlement and the acceptance period for public comments.
Final Order Entered Date: For federal judicial actions, this is the date the settlement document is signed by the presiding judge and entered by the Clerk of the Court. At that point, the settlement becomes a binding court order. For administrative actions, this is the date that the final order is signed and issued by the enforcement authority.
Enforcement Action Closed Date: The date that all requirements of all final orders are met and the case is considered fully closed. This milestone event and date is also reflected in the Case Milestones section. It is displayed at the final order section to differentiate the status of final orders where a case has multiple final orders being tracked, all of which are not yet closed.
Actual Termination Date: The date that all requirements of the final order are met. It is displayed at the final order section to differentiate where a case has multiple final orders being tracked, all of which are not yet closed.

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NPDES Violations

This section provides information about violations for National Pollutant Discharge Elimination System (NPDES) violations linked to Clean Water Act (CWA) formal enforcement action final orders. When this table contains over 100 records, users are prompted to download the data as a CSV file.

FRS Number

The identification number assigned to a facility in the Facility Registry Service (FRS) to uniquely identify a facility site.

NPDES ID

A unique 9-character ID assigned for reach permit within the NPDES program. The ID may contain both letters and numbers and often begins with the two-letter abbreviation for the statute in which the facility is permitted.

Violation Type

The types of NPDES violation identified (DMR Non-Receipt, Effluent, Schedule, or Single Event) followed by the code for reference (i.e., D80, E90, C10, etc).

Violation Description

The description of the NPDES violation type.

Violation Date

The date on which the violation was determined, which depends on the violation type.

Source of violation date
Violation Type	Violation Date
DMR Reporting [D80/D90]	DMR Due Date
Effluent [E90]	DMR Monitoring Period End Date
Schedule [C10, C20, C30, C40]	Schedule Date
Other [All SEVs codes]	Single Event Start Date

Penalties/SEPs/Compliance Action Costs/Cost Recovery Amounts

Federal Penalty Assessed or Agreed To: For civil judicial enforcement actions, this amount is the federal penalty assessed against the defendant(s) as specified in the final entered Consent Decree or Court Order. For administrative enforcement actions, it is the penalty assessed in the Consent/Final Order. It does not include the amount of the penalty shared with the state or local entities. Interest payments associated with a penalty paid over time are not included in this amount. EPA settles the vast majority of its administrative and civil judicial enforcement actions, and these settlements include an agreed upon penalty amount. In most of these settlements, there is not a direct admission by the defendant of liability for violations.
State/Local Penalty Assessed: The dollar penalty amount to be paid to a state or local enforcement authority that is party to a concluded enforcement action.
SEP Value: The estimated cost of environmentally beneficial projects which a defendant/respondent agrees to undertake as part of the settlement of an enforcement action, but which the defendant/respondent is not otherwise legally required to perform.

Compliance Action Cost: Dollar value of sum of compliance action amounts for the final order. This field is the settlement-level sum of the dollar values of injunctive relief and the physical or nonphysical costs of returning to compliance. Injunctive relief represents the actions a regulated entity is ordered to undertake to achieve and maintain compliance, such as installing a new pollution control device to reduce air pollution, or preventing emissions of a pollutant in the first place.

Federal Cost Recovery Awarded: The amount of cost recovery ordered or agreed to be repaid by the responsible party of parties and due the Superfund in accordance with either an administrative or judicial settlement.

Complying Actions

Complying Action ID: The unique identifier for a complying action requirement obliging the defendant/respondent to take or refrain from certain specified actions. This number is provided to facilitate identification of pollutant reductions specific to a particular complying action where multiple complying actions exist at a settlement.
Category: Category description provides a way to group similar or related complying actions, based on the nature of the actions, e.g., work practices, prevention, reduction, and removal.
Description: A code description of the complying action(s) required by the settlement. Descriptions preceded by "Migrated" reflect complying action code values from the legacy civil Enforcement Docket system.

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Supplemental Environmental Projects (SEP)Supplemental Environmental Projects (SEP)

As part of a settlement, a defendant may voluntarily agree to undertake an environmentally beneficial project (Supplement Environmental Project) related to the violation in exchange for mitigation of the penalty to be paid. It does not include activities a defendant must take to return to compliance with the law. A single settlement may have multiple SEPs. A complete description of EPA's SEP policy may be found on the EPA SEPs webpage.

SEP ID

The unique identifier for a SEP. This number is provided to facilitate identification of pollutant reductions specific to a particular SEP where multiple SEPs exist at a settlement.

Category

Category description provides a way to group similar or related SEPs, based on the nature of their implementation and/or environmental impact. The following is a list of acceptable SEP categories:

Assessments and Audits
Environmental Compliance Promotion
Pollution Prevention/Energy Efficiency-Conservation
Emergency Planning and Preparedness
Environmental Restoration and Protection
Pollution Prevention/Equipment-Technology Modification
Pollution Prevention/Improved Housekeeping/O&M, Training, Inventory Control
Pollution Prevention/In-Process Recycling
Other Program Specific SEP
Public Health
Pollution Prevention/Process-Procedure Modification
Pollution Reduction
Pollution Prevention/Product Reformulation/Redesign
Pollution Prevention/Raw Materials Substitution

SEP Value

The total estimated or actual dollar value of the Supplemental Environmental Project (SEP).

Description

A description of the Supplemental Environmental Project (SEP).

Estimated Pollutant Reductions

This section provides a table relating complying actions and SEPs to their estimated or actual environmental impact on pollutant reduction.

Resulting From: A value indicating the source(s) of the pollutant reduction(s). If the reductions are the result of a complying action or SEP, the value of the appropriate Complying Action ID or SEP ID is displayed. For the handful of reductions that are the result of an injunctive relief action (from the legacy Docket system) and which do not have a Complying Action ID, the phrase "Inj. Relief" is displayed.
Pollutant: The common name identifying the pollutant, waste material, substance, or chemical reduced.
Estimated Annual Amount: The estimated average annual amount of pollutant reduction in "Units" to "Media Affected."
Units: The units in which the pollutant reduction amount is measured (e.g., pounds, gallons, tons).
Media Affected: A description of the type of environmental media (air, water, land, etc.) where the pollutants or waste would have been emitted/discharged.

NPDES Compliance Schedule

This section provides information about compliance schedule milestone activities for Clean Water Act (CWA) formal enforcement actions that have a compliance schedule included in a final order.

Facilities

This section provides detailed facility and address information on all of the facilities listed in each settlement or enforcement conclusion of the case.

Schedule Number: The unique identifier for the compliance schedule.
FRS ID(s): The identification number assigned to a facility in the Facility Registry Service (FRS) to uniquely identify a facility site.
Program System Identifier: A unique ID assigned for each facility within the data system the facility reports to. These identifiers are used for tracking purposes.
System: The data system to which the facility reports.
Active ID: "Y" indicates that the program system identifier exists in the source data system and FRS. "N" indicated the identifier no longer exists in FRS.
NPDES ID(s): A unique 9-character ID assigned for each permit within the National Pollutant Discharge Elimination System (NPDES) program. The ID may contain both letters and numbers and often begins with the two-letter abbreviation for the state in which the facility is permitted.
Event: Displays the compliance schedule event description, as described above.
Schedule Date: Date by which the facility must complete the compliance schedule event.
Actual Date: Date on which the facility completed the compliance schedule event.
Amount: Required penalty amount the facility is required to pay as part of the compliance schedule.
FRS Number: The identification number assigned to a facility in the Facility Registry Service (FRS) to uniquely identify a facility site. The Detailed Facility Report for each facility can be accessed by clicking the hyperlinked FRS number. The Detailed Facility Report presents a concise enforcement and compliance history for a selected facility.
Facility Name: The public or commercial name of a facility or site (i.e., the name that commonly appears on invoices, signs, or other business documents, or as assigned by the state when the name is ambiguous).
Address: The address that describes the physical (geographic) location of the front door or main entrance of a facility site, including urban-style street address or rural address.
City Name: The name of the city, town, village or other locality, when identifiable, within whose boundaries (the majority of) the facility site is located. This is not always the same as the city used for USPS mail delivery.
State: The two letter abbreviation that represents the state or state equivalent for the U.S.
ZIP: US postal ZIP code, as maintained by ICIS.
SIC Codes: The Standard Industrial Classification (SIC) system code of the facility, as identified in FRS. SIC codes were established by the Census Bureau to identify processes, products and services. The SIC code describes the primary activity of the facility. The first two digits in the code define a major business sector; the last two digits denote a facility's specialty within the major sector. The Census Bureau replaced the SIC system with the North American Industry Classification System (NAICS) starting in 1987.
NAICS Codes: A 6-digit code to classify industrial establishments, as identified in FRS. North American Industry Classification System (NAICS) has replaced the U.S. Standard Industrial Classification (SIC) system. For detailed information about NAICS and for a crosswalk between NAICS and SIC codes, please check the U.S. Census Bureau NAICS page.

Civil Enforcement Case Report Data Dictionary