The City failed to comply with conditions of the state's NPDES permit for stormwater discharges from municipal separate storm sewer systems (MS4 General Permit) and failed to comply with two EPA administrative compliance orders. The City owns and operates an MS4 consisting of approximately 33 outfalls and associated catch basins and connecting pipe segments. The MS4 outfalls discharge to two rivers. In addition, the City owns and operates a sanitary sewer system (SSS) consisting of at least 195 miles of piping and associated manholes, which convey sanitary sewage from within the City to the Westchester County interceptor trunk sewer line for conveyance to the Westchester County Department of Environmental Facilities Yonkers Joint Wastewater Treatment Plant. Unpermitted discharges of sanitary sewage to the rivers were identified in a Region 2 inspection, and on February 25, 2014, Region 2 issued an administrative compliance order that required the City to develop and implement a Capacity, Management, Operation and Maintenance Program for the SSS and a Stormwater Management Plan for the MS4, in order to address and eliminate all identified illicit connections and discharges, as required by the MS4 General Permit. On March 8, 2016, Region 2 issued to the City a second administrative compliance order revising the schedule for the remaining compliance deadlines, including deadlines that the City had already failed to meet. The revised compliance deadlines were developed in a coord