This action seeks penalties and injunctive relief from the County of Maui (�County�) for violations of the Standards of Performance for New Stationary Sources (�NSPS�) regulations, promulgated pursuant to Section 111 of the Clean Air Act, 42 U.S.C. �� 701 et seq. (�CAA� or the �Act�), that are applicable to existing and new municipal solid waste (�MSW�) landfills. The violation involves failing to timely delays in submitting a compliant design plan install a gas collection and control system, which involves emissions of NonMethane Organic Compounds. EPA Region 9 seeks a civil penalty to recover the economic benefit the County realized by the delays in submitting a compliant design plan and installing a compliant GCCS. EPA Region 9 also seeks the assessment of appropriate gravity-based penalties for the two violations at issue.