Respondent is a permitted Phase II MS4 in New York. An MS4 Audit was conducted on April 26-27, 2012 and determined that the University 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: failure to fully develop and implement an IDDE program, failure to fully develop and implement a construction stormwater program, and failure to fully develop and implement a pollution prevention/good housekeeping program for municipal operations. An Administrative Order is being issued to order the University to comply with Permit conditions.