In September of 2014, before the City Attorney's Office adopted outside counsel retention policies, Colorado Springs Utilites retained Ryley Carlock to consult on the SDS project which included Pueblo County 1041 Permit matters and related MS4 (NPDES) permit compliance. Over nearly two years, Ryley Carlock, and its lead attorney, Alan Gilbert, had worked closely with CSU on these SDS 1041 permit issues which involved a great deal of information concerning the City's MS4 stormwater program. Mr. Gilbert gained expertise in the City's MS4 program in that effort. Per the City Attorney's Office Outside Counsel Retention Policy, the existing retention agreement with Ryley Carlock was amended to include legal services related to the then-potential enforcement issues related to the City's stormwater program and MS4 permit. That retention agreement was subsequently amended as the City became aware of the EPA's and State's intended enforcement action and, later, the litigation.