The Respondent owns the NJPDES permitted combined sewer systems (CSS) located in the Cities of Hoboken, Union City, and West New York and in the Township of Weehawken, New Jersey. EPA and EPA contractors conducted compliance evaluation inspections of the CSS from December 3-5, 2013. Based on the inspection findings, the Respondent failed to comply with the conditions of its NJPDES permit including failure to prevent the intrusion of surface waters, failure to prevent a dry weather overflow, failure to maximize the conveyance of wastewater to the WWTP for treatment, failure to maximize the treatment of wastewater at the WWTP, unpermitted discharges and failure to prevent asset overflows and backups. This Order establishes a compliance schedule to address all violations identified during the inspection. The pollutant reductions and cost estimates in the CCDS were estimated for known projects to be implemented, such as sediment removal from the CSS along Observer Highway. Additional costs and pollutant reductions are unknown at this time and will be determined as projects are developed in response to this AO.