RUSSELL KIRK AND HIS BUSINESSES, BREAKING GATE LLC AND OTTUMWA NORTHSHORE LLC BUILT A RV PARK ON THE DES MOINES RIVER, WHICH INVOLVED THE UNPERMITTED FILLOF WETLAND AND TRIBUTARY, AND UNAUTHORIZED BANK STABILIZATION OF THE DES MOINES RIVER. DEFENDANTS FILLED APPROXIMATELY SEVEN ACRES OF FORESTED WETLANDS AND IMPACTED APPROXIMATELY 2000 LINEAR FEET OF THE DES MOINES RIVER AND 55 LINEAR FEET OF A TRIBUTARY TO THE RIVER.