CITY OF LOWELL, MICHIGAN LITIGATION REFERRAL STATUTORY BASIS THE STATUTES AND REGULATIONS WHICH ARE THE BASIS FOR THE PROPOSED ACTION ARE: SECTIONS 301 AND 309 OF THE CLEAN AIR ACT, 33 U.S.C. SECTIONS 1311 AND 1319. VIOLATIONS THE VIOLATIONS UPON WHICH THE ACTION IS BASED ARE: SECTION 301 OF THE CLEAN WATER ACT, 33 U.S.C. SECTION 1311, INCLUDING DISCHARGING IN VIOLATION OF FINAL EFFLUENT LIMITA- TIONS IN THE CITY'S NPDES PERMIT, FAILURE TO CONSTRUCT A NEW FACILITY TO ACHIEVE THE FINAL EFFLUENT LIMITATIONS, AS REQUIRED IN THE SCHEDULE OF COMPLIANCE FOR FACILITY CON- STURCTION IN THE CITYS NPDES PERMIT, FAILURE TO IMPLEMENT AND ENFORCE AN INDUSTRIAL WASTE PRETREATMENT PROGRAM AS RE- QUIRED IN THE CITY'S NPDES PERMIT; AND SECTION 309 OF THE CLEAN WATER ACT, 33 U.S.C. SECTION 1319, FOR FAILURE TO COMPLY WITH AN ADMINISTRATIVE ORDER REQUIRING LOWELL TO SUBMIT A MUNICIPAL COMPLIANCE PLAN (MCP) WITH A FIRM SCHE- DULE TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS IN THE CITY'S NPDES PERMIT AND SECTION 301. RELIEF SOUGHT THE RELIEF TO BE SOUGHT IS: THAT THE CITY BRING ITS WASTEWATER DISCHARGE INTO COMPLIANCE WITH THE FINAL EFFLU- ENT LIMITATIONS AS SET FORTH IN ITS