THIS CASE IS A CIVIL ACTION AGAINST THE LOUISVILLE & JEFFERSON COUNTY METROPOLITAN SEWER DISTRICT (MSD) FOR VIOLATIONS OF SECTION 301 OF THE CWA. THE VIOLATIONS ALLEGED INCLUDE UNAUTHORIZED SANITARY SEWER OVERFLOWS (SSOs) (INCLUDING INTENTIONAL DISCHARGES OF RAW SEWAGE); UNPERMITTED DISCHARGES AT TREATMENT PLANTS; EXCESSIVE DRY WEATHER COMBINED SEWER OVERFLOWS (CSOs); UNPERMITTED CSOs; CSOs NOT IN COMPLIANCE WITH THE NPDES PERMIT, THE NINE MINIMUM CONTROLS OR THE LONG TERM CONTROL PLAN; AND HISTORIC EFFLUENT LIMIT VIOLATIONS AT TREATMENT PLANTS. THE ACTION WILL SEEK EXTENSIVE INJUNCTIVE RELIEF TO ADDRESS COLLECTION SYSTEM AND TREATMENT PLANT NON-COMPLIANCE ALONG WITH A SUBSTANTIAL CIVIL PENALTY.