Respondent is a permitted Phase II MS4 in New York. An MS4 Audit was conducted on October 17-18, 2011 and determined that the City was not complying with the conditions of the NYSDEC SPDES General Permit for Stormwater Discharges from Municipal Separate Storm Sewer Systems. Permit violations include, but are not limited to, fully identifying responsible entities for MS4 program implementation, IDDE program development and implementation, construction stormwater program development and implementation, and pollution prevention and good housekeeping for municipal operations development and implementation. An Administrative Order is being issued to order the City to comply with Permit conditions.