The civil penalty remedy is also a useful alternative to an injunction because, if the court concludes that an assessment of civil penalties will effectively deter future violations, then the court will not need to engage in the potentially cumbersome role of supervising the defendant's future compliance through an ongoing injunction. Stern, supra, at 716; see id. Data inaccuracies may exist. If the United States has not filed its own action, it may intervene in the citizen action. Otherwise, that party could resume the behavior as soon as the case was dismissed for mootness. The potential for future violations gives rise to a disputed question of fact in this instance, since the company has retained its permit. (a) The Constitution's case-or-controversy limitation on federal judicial authority, Art. The court of appeals erred in this case by failing to take those principles into account. App. Ibid. WebThis past terms decision in Friends of the Earth, Inc. v. Laidlaw Environmental Services, Inc.7 raises the deference issue. These discharges, particularly of mercury, repeatedly exceeded the limits set by a discharge 531, 536 (1984). If the Court agrees, then there will be no occasion to reach the question whether citizens may recover litigation costs if the citizen action becomes moot as a consequence of the defendant's cessation of its unlawful conduct. The company has also been subjectto several. Our offices are strategically located in the Gulf Coast. 98-822. (J.A. In October 1991, Laidlaw Environmental Services, Inc. (LES LOKERN), noticed its intention to seek a conditional use permit and general plan amendment from Kern County to expand and modify its existing hazardous waste facility The court's ruling rests on a mistaken understanding of the Clean Water Act's citizen-enforcement provisions, CWA 505, 33 U.S.C. ", Named a potentially responsible party (prp) in at least 6 Superfund sites.And they are also listed in EPA court data as defendents at several otherSuperfund sites, according to EPA data. The party claiming mootness has the burden of showing that the offending behavior cannot be repeated. See Steel Co., 523 U.S. at 88-89. 1993). v. LAIDLAW ENVIRONMENTAL SERVICES (TOC), INC. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT, No. These also included major competitors, including Mayflower Contract Services in 1995, and National Bus Service in 1996. Servs. Court of Appeals of South Carolina. Id. See Friends of the Earth, Inc. v. Laidlaw Envtl. 1365(b)(1)(B).2 Once the citizen files a suit, Section 505(c) directs that the citizen must serve a copy of the complaint on the Attorney General and the Administrator of EPA, and the citizen must provide them with advance notice of any proposed consent judgment. See CWA 309(a)-(g), 33 U.S.C. 98-10463-MEL. In the Supreme Court of the United States FRIENDS OF THE EARTH, INC., ET AL., PETITIONERS v. LAIDLAW ENVIRONMENTAL SERVICES (TOC), INC. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT BRIEF FOR THE UNITED STATES AS AMICUS CURIAE SUPPORTING PETITIONERS SETH P. WAXMAN Solicitor General Counsel of Record LOIS J. SCHIFFER Assistant Attorney General LAWRENCE G. WALLACE Deputy Solicitor General JEFFREY P. MINEAR Assistant to the Solicitor General DAVID C. SHILTON R. JUSTIN SMITH Attorneys Department of Justice Washington, D.C. 20530-0001 (202) 514-2217 QUESTIONS PRESENTED 1. See, e.g., Vitek, 436 U.S. at 410 (remanding case to the district court for consideration of the question of mootness); McLeod v. General Elec. The coercive effect of that sanction can be calibrated to respond to the likelihood of future violations. Garbage, on the other hand, always had to be dealt with. See, e.g., Natural Resources Defense Council, Inc. v. Southwest Marine, Inc., 28 F. Supp. Section 402(a) provides that the Environmental Protection Agency (EPA) shall issue NPDES permits authorizing effluent discharges in strict compliance with conditions specified in the permit. at 320. Safety-Kleen provides cleaning services for parts and tools and is a processor of used lubricating oil. But the citizen, unlike the federal or state government, may not bring suit simply to assess civil penalties for "wholly past violations." Laidlaw was fined only $10,000 dueto the $9 million they had already spent cleaning up the site. 2-3, supra. When that occurs, the plaintiff is deemed to have prevailed despite the absence of a formal judgment in his favor. 484 U.S. at 67 n.6 (quoting S. Rep. No. After FOE initiated this suit, but before the District Court rendered judgment on January 22, 1997, Laidlaw violated the mercury discharge limitation in its permit 13 times and committed 13 monitoring and 10 reporting violations. Weblaidlaw environmental services, inc. 1301 grevais street, suite 300 columbia, sc 29201 WebFriends of Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (2000) Argued: October 12, 1999 Decided: January 12, 2000 Annotation Primary Holding A party 33 U.S.C. See Baker v. Carr, 369 U.S. 186, 204 (1962).8 D. The Court of Appeals' Judgment Should Be Vacated And The Case Remanded For Further Proceedings, Including Appropriate Proceedings Respecting Petitioners' Entitlement To Litigation Costs For the foregoing reasons, we submit that the court of appeals erred in concluding that the district court's determination not to award injunctive relief rendered this case moot. The district court had denied injunctive relief, however, as a matter of remedial discretion and not because the case satisfied this Court's criteria for mootness. Congress has since revised Section 505(d) to allow an award of litigation costs "to any prevailing or substantially prevailing party, whenever the court determines such award is appropriate." April 12, 1999. Pet. Under this Court's normal practice, the case will be remanded for resolution of the remaining issues that the court of appeals did not reach, including the question of petitioners' standing. In addition, the court may award costs of litiga- The facility included a wastewater treatment plant that removed pollutants from water generated by the facility's air pollution control system. See Arizonans for Official English v. Arizona, 520 U.S. 43, 67 (1997); County of Los Angeles v. Davis, 440 U.S. 625, 631 (1979). 1251 et seq. WebHistorically Laidlaw Waste and Laidlaw Environmental Services have been subsidiaries of Laidlaw, Inc., which in turn is a 47.5% owned subsidiary of Canadian Pacific. Office of the Solicitor General See Laidlaw II, 956 F. Supp. See reviews, photos, directions, phone numbers and more for Laidlaw Environmental Svc Inc locations in Newport News, VA. A-1 Environmental Services Inc. Environmental Services-Site Remediation Janitorial Service. In August 1992, Laidlaw denied all charges but agreed to pay US andCanadian shareholders $7.65 million in a class action settlement whichclaimed that the officers had "misrepresented the financial condition ofLaidlaw. As we next explain, the court's ruling overlooks established principles that guide how the mootness doctrine should be applied in this case. See 33 U.S.C. WebFRIENDS OF EARTH, INC. V. LAIDLAW ENVI-RONMENTAL SERVICES (TOC), INC. (98-822) 528 U.S. 167 (2000) 149 F.3d 303, reversed and remanded. WebAfter Laidlaw Environmental Services, Inc. bought a wastewater treatment plant, it was granted a National Pollutant Discharge Elimination System (NPDES) permit. For example, the Court stated in Hewitt, supra, a case arising under 42 U.S.C. Id. Signed a consent decree with the state to close and clean GSX toxic wastesite- five years later, the soil is still contaminated. Web394 Virginia Environmental Law Journal [Vol. Nevertheless, the determination of whether injunctive relief is warranted is a matter within the trial court's discretion. The facility included a wastewater treatment plant that removed pollutants from An NPDES permit also typically imposes monitoring and reporting obligations, which require the facility to measure its discharges at prescribed times and document those measurements through publicly available discharge monitoring reports (DMRs). A Defendant's Voluntary Cessation Of Permit Violations Does Not Moot A Citizen Suit Unless The Defendant Demonstrates That The Permit Violations Will Not Recur The constitutional doctrines of standing and mootness each originate from Article III's specification that the "judicial Power" extends only to "Cases" or "Controversies." In 1998, a watershed year, Laidlaw Inc. acquired Greyhound Lines U.S. operations, Greyhound Canada, the DAVE Companies (specialists in paratransit) and emergency management companies EmCare and Spectrum Emergency Care. at 600, 613-619 (J.A. 181-182). The Court has since indicated in Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998), a case involving the citizen-suit provisions of the Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA), 42 U.S.C. 1365. A party trying to show that the mootness doctrine applies because it will voluntarily cease an activity must show that the activity would not recur. 8 In its brief in opposition, Laidlaw indicated that it closed the facility after the district court assessed civil penalties. WebFriends of Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (2000) Argued: October 12, 1999 Decided: January 12, 2000 Annotation Primary Holding A party trying to show that the mootness doctrine applies because it will voluntarily cease an activity must show that the activity would not recur. at 613-621 (J.A. Id. C. The Court of Appeals' Decision Petitioners appealed solely on the ground that the district court's penalty was inadequate, and Laidlaw cross-appealed on the grounds that petitioners lacked standing to bring the suit and that the district court had improperly rejected Laidlaw's diligent prosecution defense. Weve been identifying carbon-rich wastes to use in our Chem-Fuel program since 1975. Laidlaw sold the Canadian operations to USA Waste Services, Inc. Laidlaw American branch's where re-branded to many different names, depending on the location of were they were. They could stop operations whenever a case was filed and resume once it was dismissed. The site had problemsbefore Laidlaw purchased GSX, but Ohio EPA Director Richard Shank latercalled Laidlaw's operation, "horrendous and shoddyI never would havedreamed that (Laidlaw) would have gotten themselves into this kind of troublethisis not some corner drug store, this is a hazardous waste facility. Art. Grant Co., 345 U.S. at 633 (the defendant bears the "heavy" burden of demonstrating that "there is no reasonable expectation that the wrong will be repeated"). See generally Robert L. Stern, et al., Supreme Court Practice 710-721 (7th ed. References1 "Pricing Surfaces on LaidlawFund Tranches," Institutional Investor, Bank Letter, March 10, 1997.2 "Allied Waste Announces Completionof Shareholder Transactions Closes Senior Discount Note Offering," PR Newswire,May 15, 1997, "Drexel to Pay $650 million in Guity Plea," Chicago Tribune,December 22, 1988.3 "Class Action Suits Lure Shareholders:But Laidlaw case shows it's not easy money," Eric Reguly, Financial Post,September 30, 1993.4 "Cragnotti pays $ 2.67 million,"Tony van Alphen, Toronto Star, April 29, 1993.5 "Fatjo and Hall Return to WasteManagement Business with ENVIRx," Integrated Waste Management, July 22,1992.6 "Odd Union Intrigues Wall St.;Waste Manager Joins with Insurer," Terrence L. Johnson; and Stephen Phillips,The Cleveland Plain Dealer, May 26, 1996.7 "Attwoods PLC - BFI Offer Extended,etc," Extel Financial Limited, Regulatory News Service, November 4, 1994,"Laidlaw expands hazardous waste business with purchase of Union Pacific[sic]" The Ottawa Citizen, December 7, 1994.8 "Waste Plant Fined $10,000 AfterLime Leak," Rob Moritz; The Nashville Banner, October 31, 1995.9 "Law Laid Down for Laidlaw,"Louisiana Industry Environmental Advisor April, 1994.10 "Laidlaw Hammered by DEQ,"Louisiana Environmental Compliance Update, March, 1994.11 "EPA Targets Waste-BurningViolators For Penalties," Reuters, November 15, 1994; "EPA Cites MonsantoFor Hazardous Waste Violation; Seeks $555,900 Fine," PR Newswire, November16, 1994.12 "Laidlaw: No Collusion," APOnline, December 13, 1994.13 "EPA Fines Two South CarolinaIncinerators," South Carolina Environmental Compliance Update, March, 1994.14 "EPA Announces Hazardous WasteCombustion Enforcement Iniative," Arnall Golden & Gregory; GeorgiaEnvironmental Law Letter, October, 1993.15 "Sewer District Annexes Laidlaw,"Shelly Haskins; Spartanburg Herald-Journal, July 11, 1996.16 "SCDHEC Issues Twenty-ThreeConsent Orders," Haynsworth, Marion, McKay & Guerard, L.L.P. Under this Court's normal practice, the case should be remanded for resolution of the remaining issues that the court of appeals did not reach. Read More Syllabus Cf. 1365(c)(3). Pushed for a bill that would make environmental audits priviledged informationwhich is inadmissable as evidence. LAIDLAW ENVIRONMENTAL SERVICES (TOC), INC., a subsidiary of Laidlaw Environmental Services, Inc., Appellant, v. AETNA CASUALTY & SURETY COMPANY OF ILLINOIS, Respondent. Attorney (s) appearing for the Case The court observed that the Constitution's "Case[]" or "Controvers[y]" requirement, U.S. Const. at 109. 185-195). 182), but it refused to issue an "injunction or other form of equitable relief" in light of "the fact that Laidlaw is now and has for an extended period of time been in compliance with its permit," ibid. App. WebLaidlaw Environmental Services Environmental Services Division Is this Your Business? Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (2000), exposes fundamental incoherencies within environmental standing doctrine, even while it ostensibly makes standing easier to prove for See Tull, 481 U.S. at 422 n.8. Petitioners sought to deter violations that caused them, and would in the future cause them, injury in fact. 1365(d) (1982). On June 12, 1992, FOE filed this citizen suit against Laidlaw, alleging noncompliance with the NPDES permit and seeking declaratory and injunctive relief and an award of civil penalties. Laidlaw II, 956 F. Supp. See CWA 309(b) and (c), 33 U.S.C. Many at 760-761. The court of appeals' exclusive focus on what relief the citizen received departs from the methodology that courts normally apply in analyzing mootness. 1365(f). The citizen may obtain enforcement through an injunction that compels compliance. 1990). Penalized $30,000 for unauthorized emissions from their incinerator's stacks. The court of appeals did not reach any of those issues and instead concluded, after supplemental briefing, that the case was non-justiciable as a constitutional matter because the action had become moot. Id. Section 505(b) also bars a citizen from suing if EPA or the State has already commenced and is "dili- gently prosecuting" an enforcement action. The court of appeals should not have based a determination of mootness on the mere fact that the district court imposed civil penalties but did not provide injunctive relief. on Investigations and Oversight of the House Comm. WebECOS provides all of its customers with a one year guarantee on its water damage and fire damage repairs. Laidlaw Environmental Services - Interim Decision, December 21, 1993 Interim Decision, December 21, 1993 STATE OF NEW YORK : DEPARTMENT OF ENVIRONMENTAL CONSERVATION Office of Hearings 50 Wolf Road Albany, New York 12233-1550 In the Matter of the Application of Laidlaw Environmental Services, Inc. and In 1983, Laidlaw entered the U.S. school bus transportation sector with its acquisition of ARA Transportation, a major contract school bus provider which also owned a Wayne Corporation bus dealership. To contact LAIDLAW WASTE SYSTEMS INC, call (903) 984-8621, or view more information below. 7 Congress drafted Section 309(d)'s standards for assessing civil penalties (see note 6, supra) with deterrence of violations specifically in mind. The state court approved the settlement on June 10, 1992, the day after the expiration of Section 505(b)'s 60-day notice period, 33 U.S.C. If an NPDES permit holder fails to comply with the specified permit conditions, the federal and state governments may take enforcement action. Work is often performed at active facilities in densely populated, urban areas. 1995). The court of appeals concluded that the district court's refusal to provide injunctive relief had critical constitutional implications. Allied Waste SystemsAllied's Chief Executive Officer, Roger Ramsey, was the Vice Presidentand Chief Financial Officer for BFI from 1968 to 1976. III, 2, underpins both standing and mootness doctrine, but the two inquiries differ in crucial respects. We nevertheless observe that there is good reason to question the court of appeals' dictum that "[petitioners'] failure to obtain relief on the merits of their claim precludes any recovery of attorneys' fees or litigation costs because such an award is available only to a 'prevailing or substantially prevailing party.'" 5 (1976)). City of Mesquite, 455 U.S. at 289 n.10. 8a-9a. Laidlaw Environmental Services has laid off 23 employees at its Reidsville office and its Columbia, S.C., headquarters in its third round of layoffs in eight months. See Gwaltney, 484 U.S. at 66-67. Fined $60,000 for air quality violations involving petroleum liquids storedin tanks at its storage and treatment facility near Silverwood. City of Mesquite, 455 U.S. at 289. Our offices are strategically located in the Gulf Coast. 33 U.S.C. As the Court has explained: "Mere voluntary cessation of allegedly illegal conduct does not moot a case; if it did, the courts would be compelled to leave '[t]he defendant . Indeed, the lower courts, which have practical experience with the effectiveness of particular remedies, have concluded that civil penalties are an effective deterrent for Clean Water Act violations. D. Because the court of appeals erred in concluding that the district court's decision to withhold injunctive relief rendered petitioners' citizen suit moot, there is no occasion for this Court to review the court of appeals' suggestion that a finding of mootness would preclude petitioners from recovering their costs of litigation. Required to pay into a trust fund, to total $133 million cash in the year2004, to cover any clean-up costs. 1365(a)(1).1 Section 505(b) generally bars a citizen from suing until 60 days after the citizen gives notice of the alleged violation to EPA, the relevant State, and the alleged violator, 33 U.S.C. If this case were truly like Steel Co., and petitioners had brought suit simply to seek imposition of civil penalties for past violations, then they would lack standing, because punishing pre-complaint conduct, discontinued before the suit began, would not redress any cognizable injury to petitioners that could provide the basis for the suit. A district court does not necessarily transgress Article III's case-or-controversy limitation by resolving a Clean Water Act citizen suit through the imposition of civil penalties as the sole form of relief. 33 U.S.C. 149). Gwaltney, 484 U.S. at 66. Please verify address for mailing or other purposes. Id. Assuming, arguendo, that FOE initially had standing, the appellate court held that the case had become moot once Laidlaw complied with the terms of its permit and the plaintiffs failed to appeal the denial of equitable relief. Citing this Court's decision in Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998), the court of appeals concluded that "this action is moot because the only remedy currently available to [petitioners]-civil penalties payable to the government-would not redress any injury [petitioners] have suffered." Company size. Receive an email notification when changes occur for Laidlaw Environmental Services, Inc.. at 70 (Scalia, J., concurring in part and dissenting in part). WebFind 6 listings related to Laidlaw Environmental Svc Inc in Newport News on YP.com. A plaintiff prevails on the "merits of his claim" if a court finds that the defendant, in direct response to the plaintiff's suit, has altered his behavior in a way that renders the claim moot as a matter of law. The Fourth Circuit vacated the District Court's order and remanded with instructions to dismiss the action. 159-181). 1993); Atlantic States Legal Found., Inc. v. Tyson Foods, Inc., 897 F.2d 1128, 1135-1136 (11th Cir. Art. Petitioners Friends of the Earth, Inc., Citizens Local Environmental Action Network, Inc., and the Sierra Club brought this citizen suit against respondent Laidlaw Environmental Services, Inc., to enjoin Laidlaw's violations of its Clean Water Act permit. In general, "a case is moot when the issues presented are no longer 'live' or the parties lack a legally cognizable interest in the outcome." WebLAIDLAW ENVIRONMENTAL SERVICES, INC., Defendant. This Court ruled in Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Foundation, Inc., 484 U.S. 49 (1987), that Section 505 authorizes citizens to bring citizen suits to compel compliance with the Clean Water Act, but not to sue merely to punish past violations. Headquarters. at 7a.3 The court of appeals noted that the district court had denied injunctive relief and, instead, assessed civil penalties, which are payable to the United States Treasury. Laidlaw Environmental Services Inc. increased the cash portion of its hostile offer for the Safety-Kleen Corporation to $18 a share, but the overall value of the offer remains $30 a share. This article is about the transportation corporation. See, e.g., W.T. It directs that the court may impose a maximum penalty of $25,000 per day of violation and that, when assessing the penalty, the court shall consider "the seriousness of the violation or violations, the economic benefit (if any) resulting from the violation, any history of such violations, any good-faith efforts to comply with the applicable requirements, the economic impact of the penalty on the violator, and such other matters as justice may require." See Arizonans for Official English, 520 U.S. at 67-68. The citizens argued that their suit could nevertheless proceed because EPCRA, unlike the Clean Water Act, authorized citizens to obtain a judicial assessment of civil penalties for past infractions. Congress empowered the government to seek civil penalties to punish wrongful conduct as well as to deter future violations, both of which are proper government objectives. On Sunday, Safety-Kleen's board approved a revised merger offer after Laidlaw increased the cash component to $18.30 a share from $18. Referrals increase your chances of interviewing at Compunnel Inc. by 2x. at 600-601 (J.A. The court accordingly vacated the district court's decision and remanded with instructions to dismiss the action. Civ.A. After almost 20 years of expansion, Laidlaw Inc. filed for protection under Chapter 11 of the U.S. Bankruptcy Code in June 2001. In May 1995, the parties filed cross-motions for summary judgment. Since the environmental services arm went bankrupt, needless to say those of us that worked there were shocked and dismayed. WebLaidlaw Environmental Services, Inc. filed as a Domestic Business Corporation in the State of New York on Wednesday, May 7, 1980 and is approximately forty-three years old, as (J.A. But this case differs crucially from Steel Co. because petitioners brought suit to abate Laidlaw's ongoing environmental violations, Laidlaw was in a state of non-compliance when the suit was filed, Laidlaw failed to demonstrate that its voluntary cessation had left no reasonable prospect of future violations, and petitioners were therefore entitled to seek a remedy that would adequately ensure future compliance. The district court did deny petitioners' request for injunctive relief, which would have gone beyond a simple prohibitory injunction and imposed special reporting obligations. See 33 U.S.C. WebCode Environmental Services, Inc. has been providing turn-key remedial and environmental construction services to a repeat customer base of Fortune 500 corporations, national engineering firms, and major utility companies for almost 30 years. 1991) (dictum). See 523 U.S. at 86-88. See, e.g., City of Mesquite v. Aladdin's Castle, Inc., 455 U.S. 283, 288-289 (1982); United States v. Concentrated Phosphate Export Ass'n, 393 U.S. 199, 203 (1968); United States v. W.T. In 2019, ECOS is celebrating its 15th year anniversary due to our highly regarded customer service. WebLaidlaw played a major role in helping BFI launch their hostile takeoverof Attwoods in 1994. OCTOBER TERM, 1999 See 890 F. Supp. These addresses are known to be associated with Laidlaw Environmental Services, Inc. however they may be inactive or mailing addresses only. See CWA 505(b)(1)(B), 33 U.S.C. The Clean Water Act's Citizen-Suit Provisions Authorize Private Judicial Actions To Compel Dischargers To Comply With Their Discharge Permits The Clean Water Act, like other federal environmental statutes, creates a federal-state partnership for developing environmental standards and providing for their enforcement. The doctrine of mootness, by contrast, requires a court to discontinue its exercise of judicial power if it determines that a live case or controversy no longer exists in light of changed circumstances. C. A Court's Decision To Withhold Injunctive Relief Does Not Constitute A Finding That The Discharger's Violations Will Not Recur The court of appeals concluded that petitioners' citizen suit was necessarily moot because the district court refused to grant an injunction in light of Laidlaw's cessation of its permit violations and "the only remedy currently available to [petitioners]-civil penalties payable to the government-would not redress any injury [petitioners] have suffered." 482 U.S. at 760. [6] Allied Waste sold the Canadian operations to USA Waste Services, Inc. Laidlaw American branches were re-branded to many different names, depending on their location. WebLaidlaw (/ l e d l /), organized as Laidlaw International, Inc. (with corporate headquarters in Naperville, Illinois) was the largest provider of intercity bus services, contract public (b) FOE had Article III standing to bring this action. Newport News, Virginia. It was the parent company of Laidlaw Transit (which was merged into First Transit), Laidlaw Education Services (merged into First Student), Greyhound Lines and Greyhound Lines of Canada, and a number of Gray Line Sightseeing franchises in major North American cities. See CWA 505(c)(2), 33 U.S.C. Ibid. Laidlaw is offering $30 per share for the Elgin, Ill.-based oil and chemicals recycler. 159). The civil penalties, which the court expressly levied to deter future violations, were an appropriate judicial means to that end. 28-30, infra. Tull v. United States, 481 U.S. 412, 422-423 (1987). See Laidlaw I, 890 F. 2d at 478-479 (J.A. at 611 (J.A. ACTION CLEANUP ENVIRONMENTAL SERVICES INC Environmental Services But as this Court explained in Weinberger v. Romero-Barcelo, 456 U.S. 305 (1982), the Clean Water Act does not employ injunctions as "the only means of ensuring compliance."
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