When more formal and progressive enforcement is necessary, the District’s sewer use ordinance provides a multiplicity of formal enforcement tools such as administrative orders, emergency actions, legal actions, revocation of permit and cost recovery.  Under the District Plan, penalties can only be assessed through the Circuit Court system.  Such legal action is resource intensive and often time consuming.  The District has found that attaching a cost recovery provision to an administrative order will normally result in corrective action by the violator after negotiation and enable recovery of the costs of sampling, lab analysis, problem investigation and/or damages to the sewer system.  Court action and related publicity is thus avoided by the violator.  We believe such user-friendly incentive enforcement is unique to our program and establishes good will among our industrial users to promote voluntary pollution prevention.

When violations appear to be of a criminal nature, we engage support from higher authority.  Since February of 1991 an Environmental Crimes Task Force has served the United States Attorney in the Eastern District of Missouri where our District is located.  The District has been a participating party in Task Force investigations and has a policy of referral when conditions indicate criminal intent or negligence.  It is through such cooperative investigations that the District has been able to resolve several violations of federal, state and local environmental laws and regulations.  We consider this enforcement relationship to be unique and quite effective.  Due to publicity received during these cooperative investigations and resulting enforcement actions we have added to the success of preventing pollution from industrial sources within our jurisdiction.