The Springfield Water and Sewer Commission (“Commission”) owns and operates the Springfield Regional Wastewater Treatment Facility (“Facility”) and combined sewer collection system in and around Agawam, Massachusetts. On September 30, 2020, Region 1 (“Region”) of the U.S. Environmental Protection Agency (“EPA” or “Agency”) issued a final National Pollutant Discharge Elimination System (“NPDES”) permit to the Commission and six co-permittees, pursuant to Clean Water Act § 402, 33 U.S.C.