This is an Administrative Order pursuant to Sections 402 and 404 of the CWA. It is one of four Orders that the NPDES program (WTR-7) and the Wetlands program (WTR-8) jointly issued addressing combined construction stormwater and wetland fill violations at three construction project sites involving the proposed Whetstone Ranch in Benson, Arizoina. This order is directed to Cottonwood Bluffs, LLC which is building �The Cottonwood Bluffs,� a residential subdivision. The AO requires Cottonwood Bluffs to stop fill and stormwater discharges within affected waters, prepare restoration and monitoring plans, and put in place a system to ensure there will be no further violations.