COUNT 1: RESPONDENT DID NOT COMPLY WITH PART IV.D.2.A(1) OF THE PERMIT AS REQUIRED DURING THE TERM OF ITS PERMIT FROM SEPTEMBER 25, 1992, UNTIL SEPTEMBER 25, 1997. RESPONDENT FAILED TO DEVELOP AND IMPLEMENT A SWPPP IN ACCORD ANCE WITH PART IV OF THE PERMIT. COUNT 2: RESPONDENT DID NOT SUBMIT A COMPLETED NOI IN THE TIMEFRAME REQUIRED BY THE PERMIT. THEREFORE, RESPONDENT DID NOT HAVE COVERAGE UNDER A STORMWATER PERMIT AS OF SEPTEMBER 25, 1997, THE DATE THE BASELINE PERMIT EXPIRED. COUNT 3: PORT MANATEE DID NOT DEVELOP AND IMPLEMENT A SWPPP IN ACCORDANCE WITH PART IV OF THE MULTI-SECTOR PERMIT BY JULY 20, 1998. COUNT 4: RESPONDENT DID NOT APPLY FOR EXTENDED COVERAGE FOR ITS STORMWATER DISCHARGES UNDER THE BASELINE PERMIT PRIOR TO THE EXPIRATION DATE OF THE PERMIT AND DID RECEIVE COVERAGE UNDER ANY OTHER PERMIT OPTION UNTIL JULY 22, 1998, TWO DAYS AFTER RESPONDENT SUBMITTED AN NOI FOR COVERAGE UNDER THE MULTI-SECTOR PERMIT. THEREFORE, BETWEEN THE PERIOD OF SEPTEMBER 26, 1997, UNTIL JULY 22, 1998, RESPONDENT'S STORMWATER DISCHARGES WERE NOT AUTHORIZED BY AN NPDES PERMIT.