On April 5, 2021, Region III entered into an Administrative Order on Consent ( AOC ) with the City of Martinsburg ( City ) which requires the City to correct violations of its NPDES Municipal Separate Storm Sewer System ( MS4 ) Permit. These violations include the City's (1) failure to meet MCM 3 requirements, relating to Illicit Discharge Detection And Elimination ( IDDE ); (2) failure to meet MCM 5 requirements, relating to Controlling Runoff from New Development and Redevelopment; (3) failure to meet MCM 6 requirements, pertaining to Pollution Prevention and Good Housekeeping for Municipal Operations; and (4) failure to meet requirements pertaining to Stormwater Monitoring. The City agreed to enter into this AOC to address these violations. Pursuant to the AOC, the City will: (1) propose, for EPA review and approval, a Corrective Action Plan (?CAP?) which will achieve certain milestones within the timeframes outlined in the AOC; (2) develop IDDE spill response procedures; and (3) develop a standard operating procedure (?SOP?), formal enforcement procedure, and inspection calendar, for conducting required inspections and enforcing maintenance agreements for private BMPs.