THIS IS AN APO PUSUANT TO THE CWA ISSUED TO SHARPE AND ASSOC IATES AND PALISADES DEVELOPMENT CO. FOR VIOLATIONS OF EPA'S NPDES STORMWATER PROGRAM RESULTING FROM A FAILURE TO OBTAIN COVERAGE UNDER THE STORMWATER CONSTRUCTION GENERAL PERMIT AN D FOR FAILURE TO IMPLEMENT THE REQUIREMENTS OF THE PERMIT. THE APO SEEKS A PENALTY OF UP TO $137,000.