ELR Citation: ELR 20362
No(s). C 84-3435 (N.D. Cal. Dec 16, 1988)

On remand from the Ninth Circuit, the court holds that a violation is ongoing for purposes of a citizen suit under the Federal Water Pollution Control Act (FWPCA) if the same parameter has been exceeded or if a violation recurs and the cause has not been completely eradicated. The court first holds ...