Enforcement Tools and Applications

Objective: This advanced course gives participants the opportunity to explore primary and alternative enforcement tools through SMCRA. The course includes a brief visit with the more familiar primary enforcement actions, such as citing violations and determining patterns of violation. The majority of the course is devoted to the next level C alternative enforcement topics and issues. The alternative enforcement section cover injunctions, criminal sanctions, individual civil penalties, and permit suspension or revocation. Related topics include: early indicators of potential failure, bankruptcy, bond release, investigations, the Applicant/Violator System, and State statutes and regulations. Participants should be familiar with State and/or Federal enforcement issues and be prepared to participate in practical exercises. Advance notice of required materials will be given. Duration: 2 days

Agenda

Setting the Stage

Existing Regulatory Provisions for Alternative Enforcement

Civil Actions

Individual Civil Penalty

Pattern of Violations

Criminal Sanctions

Efficient Primary Enforcement, the first step of Alternative Enforcement

Debunking Some Myths and Common Beliefs

Early Indicators of Potential Failure

Investigations

Investigation Questions

Potential Sources of Information/

Records

More Alternative Enforcement Actions

False Information

Permanent Permit Ineligibility

Civil Action for Civil Penalties

Permit Suspension or Revocation

Developing a System

Practical Exercises

Analysis of Cases

Completing the Checklists

Preparing Civil Complaints

Administrative Decisions

WHO SHOULD ATTEND: Permitting, legal and enforcement staff, program staff who coordinate alternative enforcement, and managers.

National Technical Training Program: (202) 208-2769

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