REQUEST FOR CIVIL LITIGATION/COUNTERCLAIM IN THE CIVIL ACTION BROUGHT BY MR. PAUL H. COPEHAGEN ON JULY 20,1990. * COPENHAGEN IS A PRIVATE CITIZEN WHO HAS PLACED UNPERMITTED FILL IN LAKE ONTARIO, A WATER OF THE U.S., IN VIOLATION OF SECTION 301 OF THE CWA. IN HIS ACTION, HE SEEKS TO HAVE THE COURT EITHER DIRECT THAT PERMITS BE ISSUED FOR THE WORK THAT HE HAS DONE AND SEEKS TO DO, OR DECLARE THAT NO PERMITS ARE REQUIRED FOR THE WORK. * COPENHAGEN HAS VIOLATED THE CWA THROUGH HIS UNPERMITTED PLACEMENT OF METAL STRUCTURES AND FILL IN LAKE ONTARIO, A WATER OF THE UNITED STATES. * PROPOSED RELIEF: A JUDICIAL ORDER DIRECTING COPENHAGEN TO REMOVE THE ILLEGALLY PLACED FILL. THE IMPOSITION OF A CIVIL PENALTY. * US EPA REGION II ISSUED A FINDINGS OF VIOLATION AND ORDER ON JUNE 25, 1990. * THIS CASE IS IMPORTANT IN THE CONTEXT OF REGIONAL ENFORCE- MENT EFFORTS, TO ESTABLISH A STRONG ENFORCEMENT PRESENCE IN ORDER TO CURTAIL ILLEGAL FILL ACTION BY INDIVIDUAL VIOLATERS.