Respondent owns and operates a town-wide MS4. An MS4 Audit was conducted in September 2014 and identified that the Respondent was not complying with the terms and conditions of the NYSDEC MS4 General Permit. Permit violations included failure to fully implement the Stormwater Management Program Plan; failure to fully develop and implement an adequate IDDE program; failure to develop and implement an adequate construction stormwater program; failure to fully develop and implement a post-construction program; failure to fully develop and implement a pollution prevention / good housekeeping program; and failure to conduct self assessments as required. An Administrative Order was issued on February 11, 2015 to order the Respondent to comply with the requirements of the NYSDEC MS4 General Permit. Compliance with the Administrative Order was determined as a result of correspondence received from the Respondent in response to the Administrative Order. Once compliance was determined, EPA assessed a penalty.