Varnum contested an NPDES permit with discharge limits and requirements for an electroplater/metal finisher. This permit challenge addressed, with a consultant, a mixing zone compliance strategy, impact of the Great Lakes Initiative (GLI), and categorical pretreatment standards, as well as sampling methodology. Contesting the permit at re-issuance extended prior permit provisions and avoided possible "anti-backsliding" considerations with new discharge limits. Administrative challenges also allowed informal settlement negotiations to address MDEQ civil penalties for alleged past exceedances/violations.