According to Biewer's disclosure, you discovered these potential violations during due diligence activities performed in relation to the renewal of a Title V permit under Chapter NR
407, Wis. Adrn. Code and 40 C.F.R. Part 70. Under D(4) of EPA's April 11, 2000, Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (Self-Disclosure Policy) Final Policy Statement (65 Fed. Reg. 19618), the discovery and disclosure of the potential violations must be voluntary. U.S. EPA's Frequently Asked Questions of April 30, 2007, which can be found at http://www .epa. gov/compliance/incentives/auditing/auditpolicy.html, state in response to Question 2, that CAA violations discovered during activities supporting Title V certification
requirements are not eligible for penalty mitigation under the Policy. As a result, Biewer cannot satisfy this condition of the Self-Disclosure Policy and does not qualify for the penalty reduction
provided for in that Policy.