Respondent failed to prepare a Long Term Control Plan (LTCP) for their Combined Sewer System (CSS) per the conditions of their NPDES Permit. In April 2005, the city submitted a LTCP that did not meet the conditions of their permit. The Order requires the city to submit a LTCP tht meets the conditions within 60 days of the issuance of the Order. (This is the only Combined Sewer Overflow (CSO) facility that Region 10 has direct permitting authority over.)