final Administrative Order on Consent (Order) to the City of Cahokia Heights (?City?) to mitigate potential Clean Water Act violations. The City owns and operates a small MS4 that discharges storm water to waters of the United States. Pursuant to CFR 40 ? 122.33(a), the operator of any regulated small MS4 under ? 122.32 must seek coverage under an NPDES permit issued by the applicable NPDES permitting authority