As part of the 2004-07 and 2008-10 Wet Weather Enforcement Strategies and parallel to other National Homebuilder cases, EPA Region III inspected multiple large construction sites owned and operated by Toll Brothers, Inc. or their subsidiaries. It was found that erosion and sediment control and stormwater management issues were consistently problematic and in violation of NPDES-Construction permit conditions. In order to be consistent with other similar cases and builders, the case was referred to US DOJ. Unfortunately, the case received little attention for an extended period because of a conscious decision to wait to observe the results of the other cases.
This Consent Decree creates a similar Environmental Management System as previous case settlements, but takes into account some of the particulars of Toll?s system, which they had developed in anticipation of this action. Some of these particulars include a more robust electronic tracking and reporting system from the site to Division to National levels and training.