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Administrative Assessment of Civil Penalties Against Federal Agencies Under the Clean Air Act (CAA)

Memorandum for the General Counsels of the EPA and Department of Defense (DoD) in regards to EPA's authority to initiate enforcement proceedings under the Clean Air Act (CAA) as set forth in section 113 of the CAA, entitled "Federal Enforcement," 42 U.S.C. § 7413 (1994).

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