THE VIOLATIONS AT THESE SITES CONSIST PRIMARILY OF FAILURE TO EITHER OBTAIN PERMIT COVERAGE OR TO IMPLEMENT THE REQUIREMENTS OF THE APPLICABLE PERMIT. EPA, TOGETHER WITH LOCAL COUNTY CONSERVATION DISTRICTS, CONDUCTED INSPECTIONS AT THREE SITES IN PENNSYLVANIA. IN PARTICULAR, EROSION CONTROLS AT THE SITES WERE NOT BEING IMPLEMENTED AND/OR MAINTAINED. EPA SOUGHT ADDITIONAL INFORMATION PURSUANT TO THE CWA SECTION 308, ON THE CONSTRUCTION ACTIVITIES OF HOVNANIAN ENTERPRISES IN THE REGION. HOVNANIAN'S RESPONSE TO THE 308 REQUEST PROVIDED EVIDENCE OF MORE VIOLATIONS: 45 OTHER CONSTRUCTION SITES WHICH WERE NEVER COVERED BY AN NPDES PERMIT, OR WHERE CONSTRUCTIONI ACTIVITY BEGAN BEFORE PERMIT COVERAGE WAS OBTAINED. BY FAILING TO OBTAIN COVERAGE UNDER, OR TO COMPLY WITH, AN NPDES STORMWATER PERMIT, HOVNANIAN HAS VIOLATED THE PROHIBITION OF SETION 301(A) OF THE CWA, 33 U.S.C. SECTION 1311(A), AGAINST UNAUTHORIZED DISCHARGES OF POLLUTANTS.