VIOLATIONS OF THE CWA, 33 USC SS 1251 ET SEQ., BY ALLEN COUNTY, OHIO (THE COUNTY OR DEFENDANT , AND THE STATE OF STATE OF OHIO, AT THE AMERICAN BATH WWTP, AND THE SHAWNEE #2 WWTP, IN ALLEN COUNTY, OHIO. THE USEPA RECOMMENDS THE INI- TIATION OF A CIVIL ACTION AGAINST THE COUNTY, AND THE STATE OF OHIO, UNDER SECT 309B OF THE CWA, 33 USC S1319B, SEEKING CIVIL PENALTIES AND INJUNCTIVE RELIEF. - THE COUNTY OWNS AND OPERATES THE PLANTS, WHICH ARE OPERATING IN VIOLATION OF THE EFFLUENT LIMITS IN THEIR NPDES PERMITS. COMPLIANCE WITH THOSE LIMITS IS NECESSARY TO ENSURE ATTAIN- MENT OF THE WATER QUALITY STANDARDS FOR THE OTTAWA RIVER AND ITS TRIBUTARY PIKE RUN. UNLESS CORRECTIVE ACTION IS ORDERED THE REGION BELIEVES THAT THE COUNTY WILL NOT ACHIEVE COM- LIANCE WITH THE NPDES PERMITS IN THE FORESEEABLE FUTURE. - PURSUANT TO SECT 309E OF THE CWA, 33 USC S1319E, USEPA HAS INCLUDED THE STATE OF OHIO AS A PARTY BECAUSE THE DEFENDANT COUNTY IS A MUNICIPALITY AS THAT TERM IS DEFINED BY SECT 502 (4) OF THE CWA, 33 USC S1362(4). THE STATE OF OHIO MAY BE LIABLE FOR EXPENSES INCURRED BY THE COUNTY AS A RESULT OF THIS CASE. - USEPA, REGION V REQUESTS PRE-FILING SETTLEMENT AUTHORITY IN THIS CASE. IN ADDITION, WE REQUEST