Respondent is a small Municipal Separate Storm Sewer System (sMS4), the owner of a system of storm water conveyances or system or conveyances including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, manmade channels, or storm drains. The Phase II Rule required a Notice of Intent (NOI) and a Storm Water Management Program be submitted by March 10, 2003. The sMS4 General Permit became effective July 1, 2007, and required an updated NOI and SWMP be submitted by October 1, 2007. The RespondentÂs NOI and SWMP was submitted a NOI and SWMP on August 24, 2009, but as of December 9, 2011, the SWMP was determined to be inadequate after several exchanges between the Respondent and EPA. A Complaint for penalties was issued to address violations of the permit. The Consent Agreement Final Order was filed June 28, 2012.