THE CITY OF DETROIT HAS VIOLATED ITS NPDES PERMIT BY FAIL- ING TO IMPLEMENT AND ENFORCE ITS APPROVED PRETREATMENT PRO- GRAM. THE STATE OF MICHIGAN IS BEING JOINED, PURSUANT TO SECTION 309(E) OF THE CLEAN WATER ACT. - IN PARTICULAR, DETROIT HAS FAILED TO IMPLEMENT THE FOLLOWING REQUIREMENTS OF ITS APPROVED PRETREATMENT PROGRAM: SYSTEMA- TICALLY IDENTIFY ALL ITS INDUSTRIAL USERS; FULLY SCREEN SAMPLING DATA TO DETERMINE IF ITS INDUSTRIAL USERS ARE COM- PLYING WITH ALL INSTANCES OF NONCOMPLIANCE BY ITS ENFORCE- MENT RESPONSE BEYOND THE ISSUANCE OF NOTICES OF VIOLATIONS AND NON-PUNITIVE COMPLIANCE SCHEDULES. REGION V BELIEVES THAT DETROIT'S FAILURE TO SCREEN MONITORING DATA FOR COMPLI- ANCE WITH ALL PRETREATMENT STANDARDS, COUPLED WITH THE LACK OF MEANINGFUL ENFORCEMENT BY DETROIT, MEANS THAT DETROIT IS FAILING TO IMPLEMENT ONE OF THE FUNDAMENTAL OBLIGATIONS OF A LOCAL PRETREATMENT PROGRAM: TO ENSURE THAT INDUSTRIAL USERS COMPLY WITH PRETREATMENT STANDARDS. REGION V BELIEVES THAT DETROIT'S FAILURE TO IMPLEMENT AND ENFORCE ITS PRETREATMENT PROGRAM IS CONTRIBUTING TO THE POLLUTION OF THE ROUGE RIVER AND THE DETROIT RIVER, AS WELL AS LAKE ERIE. -