On March 6, 2019, a CWA CAFO between the EPA the City of Annapolis was entered in Region 3. The CAFO resolves violations of the City's MS4 permit and includes a SEP. The civil penalty required under the CD is $10,800. The SEP is a pilot silva cell tree planting project intended to capture stormwater runoff in downtown Annapolis. The MS4 violations included failures to implement pollution prevention plans, maintain pollution controls measures and prevent discharges from City owned facilities. The City also took steps to improve its MS4 program consistent with its permit. MS4 violations lead to unpermitted and uncontrolled discharges into local tributaries.