On February 6, 2008, EPA issued against the Respondent an Administrative Compliance Order (ACO) for its failure to submit a Notice of Intent (NOI) application as required by 40 CFR 122.23(a) for the MS4 General Permit. According to the ACO, Respondent had to: file a NOI form seeking coverage under the Small MS4 Permit; prepare, implement and enforce a SWMP to bring the municipalityÂs Small MS4 into compliance and submit to EPA a hard and electronic copy of the SWMP; and submit a Compliance Cost Report to EPA. On August 1, 2008, the Respondent filed the NOI, but the SWMP was not received. On September 24, 2010, EPA issued a Class II Civil Penalty. On September 6, 2011, EPA issued a Consent Agreement and Final Order (CA/FO) in settlement of the enforcement action.