1) Referral concerns 12 construction sites in NJ, where Richmond American Homes has conducted grading, grubbing, and/or other land-disturbing construction activity. Richmond has discharged pollutants in stormwater at some of these sites without obtaining an NPDES permit. Richmond has also failed to provide information necessary for coverage under the applicable NPDES permits at some sites. Finally, Richmond has routinely violated the condiitons of the permits it has obtained, including failing to fully implement and maintain stormwater pollution prevention erosion controls. 2) EPA requests compliance with the applicable laws as well as a substantial penalty. A complete list of the construction sites covered by this settlement is included in Appendix A of the complaint and Appendix M of the consent decree. This information is also available on the EPA website, Compliance and Enforcement, Newsroom, Cases and Settlements. http://cfpub.epa.gov/compliance/cases/.