Cooper Marine & Timberlands Corporation
|Underlying Misconduct:||Clean Water Act|
|Matter Type:||Suspension & Debarment|
|Relevant Jurisdiction(s):||Washington, DC|
|Penalties:||Debarment, Fine, Suspension, Settlement Payment|
|Reporting Agencies:||Environmental Protection Agency|
|Resolution Form:||Administrative Agreement|
|Agreement Date:||August 9, 2016|
|Monitor Reference Term:||Independent Monitor|
|Monitorship Term:||5 Years|
|Monitor Selection Process:||
Host Organization to provide EPA with the Monitor's name, telephone number, email address, current position, resume, certification of independence and summary of qualifications. If any change in Monitor during Agreement term, Host Organization to provide same information for new Monitor within 14 days of engaging.
|Time to Propose Monitors:||14 days|
|Time to Engage Monitor:||30 days|
|Time to First Report:||10 mos|
|Monitor Required Qualifications:||
Necessary education, training and experience to determine Host Organization's compliance with the Agreement. Shall be qualified to evaluate compliance with the terms of the Agreement, including the Plea Agreement, the Environmental Compliance Program, and the Self-Governance Program.
|Summary of Monitor's Scope:||
Review Host Organization's reports required under Agreement and certify whether or not Host Organization has complied with the Terms of the Agreement.
|Summary of Monitor's Activities:||
Certify Host Organization's compliance with Agreement. Perform an annual review of the Agreement and submit findings to Host Organization and EPA. Monitor will annually review Host Organization's reports, and supporting documents, and any other documents required in order to prepare annual report evaluating Host Organization's compliance with Agreement and recommending any changes that seem appropriate. Perform on-site audits. Shall issue reports directly to EPA without first discussing with Host Organization.
Could have no former business relationship with Host Organization, not an agent of the Host Organization or EPA. Work not subject to attorney client or work-product privilege. Monitor to provide certification of independent annually to EPA.