On September 29, 2005, USEPA issued a Compliance Order under Section 309(a) of the CWA to Richard M. Osborne, Sr., Richard M. Osborne, Jr., the City of Willoughby, Ohio, JTO, Inc. and 7 additional entities. The Compliance Order alleges that during the development of the Riverside Commons Industrial Development Park Lake County, Ohio, that more than 62.5 acres of wetlands and more than 2,600 l.f. of streams, located adjacent to the Chagrin River in Willoughby and Mentor, Ohio, were filled without a Federal permit under Section 404 of the CWA. The Compliance Order seeks appropriate injunctive relief, including restoration of the wetlands and streams.