Defendant Agribusiness Development Corporation (“ADC”) has been violating, and continues to violate, the Federal Water Pollution Control Act, also known as the Clean Water Act (“CWA”), 33 U.S.C. §§ 1251–1388, by discharging polluted drainage waters from the Mānā Plain drainage canal system it owns, operates, and maintains, including but not limited to the canals, two pumping stations, and seven drainage ditch outfalls in West Kaua‘i, Hawai‘i.