NATURE OF THE CASE THE NY CITY HOUSING AUTHORITY OWNS AND OPERATES NINE PUBLIC HOUSING PROJECTS WHICH ARE SUBJECT TO THIS ACTION. INCINERATORS ARE USED TO DISPOSE OF GARBAGE AT THESE HOUSING COMPLEXES, RESULTING IN EMISSIONS OF PARTICULATES, NITROGEN OXIDES, AND HYDROCARBONS. CAUSE OF ACTION ON 4/23/82, EPA ISSUED A NOV TO THE AUTHORITY, CITING 184 INCINERATORS FOR VIOLATIONS OF THE VISIBLE EMISSION LIMITA- TION IN THE SIP. THE NOV ALSO CITED THE AUTHORITY FOR OPERATING THESE INCINERATORS WITHOUT A CERTIFICATE TO OPERATE. IN 11/82, AN EPA INSPECTOR DOCUMENTED CONTINUING VISIBLE EMISSION VIOLATIONS AT 13 OF THE 184 INCINERATORS. THE REGION IS RECOMMENDING FILING A CIVIL ACTION ALLEGING OPACITY VIOLATIONS AT ONLY THE 13 INCINERATORS BUT HOPES TO REACH A SETTLEMENT ADDRESSING ALL 184. (NOTE: DOCUMENTA- TION OF CONTINUING VIOLATION IS A STATUTORY PREREQUISITE FOR FILING AN ENFORCEMENT ACTION.) ALL INCINERATORS ARE LOCATED IN AREAS WHICH ARE SECONDARY NON-ATTAINMENT OR NON-CLASSIFIABLE FOR PARTICULATES AND NITROGEN OXIDES AND WHICH HAVE AN EXTENDED ATTAINMENT DEAD- LINE FOR OZONE. THEREFORE THE POST-1982 ENFORCEMENT POLICY DOES NOT APPLY. PROPOSED REMEDY IN JUNE 1982, THE AUTHORITY SIGNED A S