of criminal fines in those actions, do not trigger the statutory bar even, if the state laws under which the penalties were assessed were “comparable” to the Clean Water Act in a general sense. Nor do the 2008 consent orders trigger § 1319(g)(6)(A)’s bar to citizen enforcement. We have held that a state administrative action must seek and assess administrative penalties to trigger the § 1319(g)(6)(A) bar. Knee Deep, 94 F.3d at 516 (“[F]or § 1319(g)(6)(A) to apply, the comparable state law must contain penalty provisions and a penalty must actually have been assessed under the state law.” (citing Citizens for a Better Env’t-California v. UNOCAL, 83 F.3d 1111, 1115 (9th Cir.1996))); cf. Wash. Pub. Interest Research Grp. v. Pendleton Woolen Mills, 11 F.3d 883, 885-87 (9th Cir.1993) (<HOLDING>). In other words, “the comparable state law
holding that an administrative compliance order issued by the epa did not trigger the  1319g6ai bar which applies if the epa has commenced federal administrative penalty proceedings under  1319g holding  2254 applies to administrative proceedings holding the epa has the discretion to consider an untimely certification by a state agency holding that epa regulations do not allow the agency to act contrary to federal statute holding that inadequate notice did not trigger plans time bar for administrative review