its motion the Agency, in justifying the usefulness of thecontingent or suspended penalty, compares the Board’s reasoning in determining standard penalties and simultaneouslyrequiring the execution of performance bonds.
Often the contingent part of a
penalty, which is designed to ensure enforcement, is stipulatedto even though it can be deemed excessive.
The Board is not only
asked to accept stipulated facts, a compliance program, anda penalty for spe...
Allowed
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