This Class II Administrative Penalty Complaint pursunat to Section 309(g) of the Clean Water Act is being issued to address NPDES permit violations by Richmond, VA housing developer Avon Assoicates, LLC and it contractor H&b Construction Company, Inc. Responsdents failed to timely develop a complete Storm Water Pollutlion Prevention Plan and to Bridge Road and Falling Creek in Richmond, VA, as required by the applicable storm water compliance inspections of the site conducted by the C ity of Richmond and by Region III Water Protectio Division representatives disclosed that Respondents had also failed to properly implement several erosion and sediment control measures including installation and maintenance of sediment traps and basins, silt fences and a construction entrace.