BEGINNING IN THE SPRING OF 1995 AND CONTINUING TO THE PRESENT, SAN LUIS OBISPO COUNTY HAS BEEN PERFORMING SUBSTANTIAL ROAD AND BRIDGE REPAIR WORK AT WELL OVER 200 SITES SPREAD THROUGHOUT THE COUNTY. ROAD AND BRIDGE WORK AT ABOUT 104 OF THESE SITES INVOLVED DISCHARGE OF FILL MATERIAL TO WATERS OF THE UNITED STATES. THE COUNTY HAS LACKED CWA SECTION 404 PERMITS FOR THIS WORK. ACCORDINGLY, THESE FILL DISCHARGES VIOLATED CWA SECTION 301(A), WHICH PROHIBITS THE DISCHARGE OF FILL TO WATERS OF THE UNITED STATES EXCEPT AS AUTHORIZED BY A SECTION 404 PERMIT.