FWIW here's an approach....If my little puddle ever comes under their gun, I might try to approach things maybe a little differently. I would try to choke them in their own redtape instead of fighting their right to rule. I would hire a smart attorney to petition the court to stay all penalties until the EPA provides proof of a violation. I would have him challenge ever tiny bit, make them provide detailed credentials of the analyst that identified the violation, technical data proving the satelite data is accurate, credentials of the people assessing the accuracy of the the satelite data, banking and audit information of all EPA personnel involved to verify they were not bribed to cause me a problem, EPA family ties to any of the people downstream will require detailed family trees of all involved (how far is downstream?), etc. etc. etc. Keep all the requests for info as ambiguous as possible (sound familar). You get the idea. A huge amount of trite info. They will never be organized or have the manpower enough to comply and provide the info required in the time the judge allows. If they are, well then, what are the credentials of the people that did the family trees, how accurate is that info, etc. etc. etc. Case will never go to court.
Now let's say all the paperwork, motions, etc that causes the headaches for the EPA is published free on the internet for others to use should they come under the gun...
Good luck. They get paid the same while you get charged by the hour.
