This is a consolidated action pursuant to our Consolidated Rules of Practice (40 C.F.R. ?22.18(b)(2) and (3)), which provide that a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint (if a complaint was issued the proposed penalty would have been $37,400). Eastman Kodak submitted a false Notice of Commencement of Manufacture.