1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. AUTONATION USA FAULKNER CONSTRUCTION COMPANY FACILITY: 5725 UTSA BOULEVARD SAN ANTONIO, BEXAR COUNTY, TEXAS 78217 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301(A) OF THE CWA WHEN ONE OF THE RESPONENTS ENGAGED IN AN INDUSTRIAL ACTIVITY WITHOUT NPDES PERMIT COVERAGE, AND BY VIOLATING THE REQUIREMENTS FOR STORM WATER POLLUTION PREVENTION PLAN (SWPPP) PARTS OF ITS PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO EXPLAIN THE FACILITY'S NON-COMPLIANCE, OBTAIN AN NPDES PERMIT, SUBMIT STORM WATER POLLUTION PREVENTION PLANS (SWPPP), AND APPEAR AT AND MEET WITH EPA AND SHOW CAUSE.