I really don't think this situation is all that complicated. (Finding a guilty party may be, but the permit issue is not.) I haven't done any research, but it appears to be nothing more than a permit violation. The permit is violated. The permittee pays the fine and then pursues any avenues available to recover any losses.
The permitting agency is not going to wait for a long, drawn out investigation before they issue the fines. To the agency, it's clear cut...there is a violation and a permittee. The permittee pays the fine regardless of who might have actually committed the acts.
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