GASTON BARRETT, THE SOLE DEFENDANT, HAS ILLEGALLY DISCHARGED DREDGED AND FILL MATERIAL INTO WATERS OF THE U.S. IN VIOLATION OF SECTIONS 301 AND 404 OF THE CWA. THESE VIOLATIONS OCCURRED AT THREE SITES IN PHILADELPHIA, MS. BARRETT WAS PREPARING ALL SITES FOR COMMERCIAL DEVELOPMENT. REGION 4 SEEKS TO HAVE BARRETT RESTORE THE SITES AND PAY A PENALTY. THE AMOUNT OF THE PENALTY PROPOSED IS $1,123,000; HOWEVER, THE LITIGATION CONSIDERATIONS HAVE YET TO BE FACTORED IN. GASTON BARRETT HAS PREVIOUS VIOLATIONS. BECAUSE THIS IS A WETLANDS CASE, IT IS OF NATIONAL SIGNIFICANC