1. SECTION 309(A)(3) OF THE CLEAN WATER ACT * CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. ENTACT, INC. WEST PIONEER MANAGEMENT, INC. JPI TEXAS DEVELOPMENT, INC. FACILITY: UPTOWN PARKS FIELD AND RIVERS DALLAS, DALLAS COUNTY, TEXAS 75202 3. ENTACT, INC. AND WEST PIONEER MANAGEMENT, INC. WERE IN VIOLATION OF SECTION 301(A) BY NOT HAVING NPDES PERMIT COVERAGE AT THE TIME CONSTRUCTION ACTIVITIES COMMENCED, INCLUDING THE INSPECTION, AND JPI TEXAS DEVELOPMENT DID NOT HAVE NPDES PERMIT COVERAGE WHEN IT ASSUMED OPERATION- AL CONTROL OF THE SITE, AND THE RESPONDENTS VIOLATED THE PARTS OF ITS PERMIT PERTAINING TO STORM WATER POLLUTION PREVENTION PLAN IMPLEMENATION AND MANAGEMENT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENTS TO CORRECT AND PREVENT THE RECURRENCE OF THE VIOLATIONS, SUBMIT A REPORT DETAILING THE STEPS TAKEN TO CORRECT AND ENSURE PREVENTION OF RECURRENCE, SUBMIT A STORM WATER POLLUTION PREVENTION PLAN (SWPPP), AND APPEAR AND MEET WITH EPA AND SHOW CAUSE.