1. This action is a citizen suit brought under section 505 of the Clean
Water Act (“CWA”), 33 U.S.C. § 1365, by Plaintiffs Center for Food Safety and
Wild Fish Conservancy against Defendants Pacific Aquaculture – Nespelem, LLC
and Pacific Seafood Aquaculture, LLC (collectively, “Pacific”) for Pacific’s
repeated and ongoing violations of sections 301(a) and 402 of the CWA, 33 U.S.C.
§§ 1311(a) and 1342, and the terms and conditions of Pacific’s National Pollutant
Discharge Elimination System (“NPDES”) permits authorizing discharges of
pollutants from Pacific’s commercial steelhead farms to the Columbia River.
2. Center for Food Safety and Wild Fish Conservancy (collectively,
“Plaintiffs”) seek declaratory judgment, injunctive relief, the imposition of civil
penalties, and an award of costs, including attorney and expert witness fees.
