DURING AUGUST 1990, JMB FILLED APPROXIMATELY 37 ACRES OF WET LANDS (WATERS OF THE U.S.) WITHOUT A SECTION 404 PERMIT. THIS UNAUTHORIZED ACTIVITY OCCURRED ON PROPERTY WHICH JMB DESIRED TO USE FOR THE CONSTRUCTION OF A REGIONAL MALL SITE. - THE REPORT RECOMMENDS THE FILLING OF A CIVIL ACTION SEEKING COMPLIANCE WITHTHE ACT THROUGH JMB'S RECEIPT OF A SECTION 404 AFTER-THE-FACT PERMIT, AS WELL AS THE IMPOSITION OF CIVIL PENALTIES.