EPA reached a negotiated settlement with Richmond and both parties signed a Consent Agreement and Final Order (CAFO), for settlement of the RespondentÂs alleged violations of Section 301 of the Clean Water Act (CWA), 33 U.S.C. § 1311, related to its municipal separate storm sewer system (MS4) NPDES permit. The CAFO specifically addresses the CityÂs failure to adhere to the good housekeeping and pollution prevention sections of the permit. Based on negotiations initiated with a Show Cause Letter, Respondent has agreed to pay a $12,000 penalty to settle EPAÂs alleged violations.