This is an appeal by the U.S. EPA Region V and EPA's Office of Regulatory Enforcement (collectively the "Region") from an Initial Decision issued by Administrative Law Judge William B. Moran ("Presiding Officer") imposing upon Respondent, the City of Marshall, Minnesota ("Marshall"), a civil penalty of $ 6,000 for violations of section 309(g)(1)(A) of the Clean Water Act ("CWA"), 33 U.S.C. § 1319(g)(1)(A), arising from the alleged illegal application of sewage sludge on agricultural land in contravention of regulatory requirements codified at 40 C.F.R. part 503.