EPA enforcement against wastewater plants, 2020–2026: small fines, $950 million in required fixes

542 federal cases, 450 plants, and almost no fines

Since the start of fiscal year 2020, EPA has brought 542 formal civil enforcement cases naming 450 publicly owned wastewater treatment plants in the United States. That is about 4% of the 11,774 plants in the Klarifi directory. Only 96 of those cases carried a penalty, and the median penalty was $3,000. The orders themselves are a different matter: EPA recorded compliance actions worth $950 million across 358 of the cases, the fixes, upgrades and programmes a plant must deliver to close the case.

This analysis reads EPA's civil enforcement records for every plant in the directory and looks at where the cases are, what they are about, which plants get them, how long they run, and what they mean for the people who sell into those plants. Every case cited here links to its report on EPA's ECHO site, and every plant to its Klarifi profile, where the enforcement history now sits next to the permit and compliance data.

Key findings

• Formal actions against wastewater plants nearly doubled between fiscal 2021 and fiscal 2024, from 51 to 109, and have stayed above 80 a year since.
• Fines are rare and small: 96 of 542 cases carried a penalty, $1.7 million in total, median $3,000. The value of required compliance actions in the same period is $950 million.
• EPA Region 6, covering Texas, New Mexico, Louisiana, Oklahoma and Arkansas, brought 242 of the 542 cases, 45% of the national total. Texas alone accounts for 148.
• Four in five cases are NPDES permit violations. The rest include drinking-water rules at utilities that run both systems, discharges without a permit, chlorine risk-management plans and sewage sludge.
• Size matters: 12% of plants above 10 MGD have had a case since 2020, against 3% of plants under 1 MGD. Sixty-seven plants have had two or more cases in the period; one has had seven.
• A case runs a median 17 months from the first order to closure, and one in ten runs for more than ten years, which is the consent-decree tail.

Actions climbed to a 2024 peak and stayed high

Federal enforcement against wastewater plants was quiet in the first pandemic years, 58 cases in fiscal 2020 and 51 in 2021, then climbed for three years to a peak of 109 cases at 104 plants in fiscal 2024. Fiscal 2025 and 2026 came in at 82 and 80, still well above the 2017 to 2021 range. The mix changed too: judicial cases, the ones referred to the Department of Justice, have all but disappeared from this set, with none recorded since fiscal 2022. Enforcement against wastewater plants is now almost entirely administrative, run by the regional offices under section 309 of the Clean Water Act.

Formal EPA civil enforcement cases naming plants in the Klarifi directory, by EPA fiscal year (1 October to 30 September). Penalties are amounts assessed or agreed; compliance actions are EPA's recorded value of the fixes a case requires. Source: EPA ICIS-FE&C via ECHO.

The fines are small; the orders are not

The largest penalty assessed against a wastewater plant in the period is $400,000, in the 2022 judicial case against the City of Driggs, Idaho, which also required $25 million of compliance actions. The next largest are $260,000 against the Green Bay Metropolitan Sewerage District in Wisconsin, a Clean Air Act new-source case at a wastewater utility, and $142,000 and $115,000 in two separate cases against the City of Rio Rancho, New Mexico, in 2023 and 2025. Across all 542 cases the penalties add up to $1.7 million. Two thirds of the cases carry no penalty at all: 204 ended in a final order without one, 82 were unilateral orders, and 146 are recent orders still open.

The compliance-action values tell the real story. EPA records the estimated cost of the corrective work an order requires, and 358 of the 542 cases carry one, $950 million in total. The largest single figure is the $100 million judicial referral over the Chinle wastewater treatment facility on the Navajo Nation in Arizona, filed in 2021. The five largest since 2020:

Compliance-action values as recorded by EPA for cases since fiscal 2020. Each case links to its ECHO report.

One EPA region brings nearly half the cases

Enforcement is regional in practice. EPA Region 6, the Dallas office that covers Texas, New Mexico, Louisiana, Oklahoma and Arkansas, brought 242 of the 542 cases, 45% of the total, naming 179 plants. Region 5 in Chicago is a distant second with 75, followed by Region 7 in Kansas City with 57 and Region 2 in New York with 52. By state, Texas leads with 148 cases, then New Mexico with 60, which is remarkable for a state with a small directory, New York with 45, Ohio with 31 and Louisiana with 23. Pennsylvania, Illinois, Missouri, Wisconsin and Idaho each have between 15 and 17.

Region from the case number prefix. State pages with the full lists: Texas, New Mexico, New York, Ohio, Louisiana, and every other state from the national enforcement page.

Permit violations, and a few surprises

Four in five cases, 427 of 542, are NPDES permit violations: effluent limits exceeded, monitoring or reporting missed, or a permit condition ignored. The remainder is more varied than the headline suggests. Thirty-one cases cite the national drinking-water regulations, because many of the utilities in the directory run the water system as well as the sewer system and EPA files the case against the utility. Twenty-three are discharges without a permit at all. Eighteen are risk-management-plan cases under the Clean Air Act, which at a wastewater plant almost always means chlorine gas on site, and fifteen cite pretreatment and toxic effluent standards, the rules that govern what industries may send to the plant. Eleven concern sewage sludge disposal and five are recorded as intentional acts.

Larger plants, repeat plants, and how long a case runs

Enforcement finds the plants that discharge the most. Of the 246 directory plants above 10 MGD of average flow, 29 have had a formal case since fiscal 2020, one in eight. Among the 1,571 plants between 1 and 10 MGD it is one in ten. Among the 7,083 plants under 1 MGD it is one in thirty-five. The pattern is partly exposure, since large plants report more parameters and more often, and partly priority, since EPA's national enforcement initiatives have targeted sewer overflows and nutrient loads at larger systems.

Sixty-seven plants have had two or more formal cases since 2020, eighteen have had three or more, and one plant has accumulated seven. Rio Rancho's two penalty cases two years apart are typical of how a repeat looks in the record: the first order sets a schedule, the second follows when the schedule slips. Of the 395 cases opened and closed in the period, the median ran 17 months from the first order or complaint to closure. One in ten ran for more than ten years, which is the consent-decree tail, where a court-ordered capital programme keeps the case open until the last project is built.

What an order means for the plant and for vendors

For a utility, a formal EPA case is rarely about the fine. It is a schedule: a corrective action plan, interim limits, construction milestones and reporting, with the cost of the work recorded by EPA in the compliance-action value. That is why the 358 cases with such a value add up to $950 million while the penalties add up to $1.7 million. For a company that sells treatment equipment, controls, engineering or operations services, a plant under an order is a plant with a funded, dated problem, which is the same signal as a permit renewal but with a deadline attached by a regulator.

Every plant in the Klarifi directory with a federal enforcement record now shows it on its profile: the count of formal actions, penalties, the compliance-action value, EPA inspections and the latest case with the opening of EPA's own description. The national enforcement page ranks the states and lists the 10 largest Clean Water Act penalties on record, and each state page lists recent actions and the largest penalties. The full case histories, with every milestone and violation type, are available with a free Klarifi account, alongside the treatment technology and the decision-maker contacts at each plant.

Sources and method

The data is EPA's Integrated Compliance Information System for federal enforcement and compliance (ICIS-FE&C), the same records ECHO publishes case by case, loaded into Klarifi's database on 16 September 2026 and joined to the 11,774 publicly owned treatment works in the Klarifi directory. Cases are counted once per plant they name, by EPA fiscal year. Penalties are the amounts assessed or agreed; for cases after 2000 they come from the case penalty records as federal and state or local shares added together, not from the case header, which is empty for modern cases. Compliance-action values are EPA's recorded estimates and are shown per case rather than summed into headline totals elsewhere on the site, because ICIS records some national cases twice. State-led enforcement, which is the majority of all wastewater enforcement in the United States, is not in this data set; neither are informal federal actions, of which 21 are on record for these plants in the period. EPA's free-text case summaries are quoted on the site only as short attributed excerpts, and never for cases against named individuals.

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