THIS CASE ARISES UNDER THE CLEAN WATER ACT ( CWA OR THE ACT ) AND CONCERNS UNAUTHORIZED SPILLS OF SEWAGE INTO WATERS OF THE UNITED STATES IN VIOLATION OF SECTION 301(A) OF THE ACT. THE COUNTY OF MAUI ( MAUI COUNTY ), HAS HAD NUMEROUS SPILLS OF SANITARY SEWAGE TO THE PACIFIC OCEAN AND OTHER WATERS WITHOUT AUTHORIZATION OF A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT. EPA IS ORDERING THE COUNTY TO REDUCE OR ELIMINATE SEWAGE SPILLS. EPA COUNSEL WAS LAWRENCE LAU (FOR THIS UAO), WHILE A RELATED REFERRAL (09-1997-0077) HAS CHRIS SPROUL AS COUNSEL.