Henry Stevenson and Parkwood Land Co. (together, "Parkwood") appeal from an Initial Decision issued by Regional Judicial Officer ("RJO") Pat Rankin on February 11, 2013. The U.S. Environmental Protection Agency ("EPA" or "Agency"), Region 6 ("Region"), in turn, filed a cross appeal. The Agency's administrative complaint charged Parkwood with violations of Clean Water Act ("CWA" or "Act") sections 301(a) and 404, 33 U.S.C. §§1311(a) and 1344, when it discharged fill material into wetlands while repairing a levee by constructing a truck ramp and truck turnaround on the levee.